Title : Fuel Bladder Replacement-South Pole Type : Antarctic EAM NSF Org: OD / OPP Date : January 16, 1992 File : opp93056 DIVISION OF POLAR PROGRAMS OFFICE OF THE ENVIRONMENT 202/357-7766 MEMORANDUM Date: January 16, 1992 From: Environmental Officer, DPP Subject: Environmental Action Memorandum (Amundsen-Scott South Pole Station Fuel Bladder Replacement) To: Files (S.7 - Environment) This Environmental Action Memorandum describes the need for, and location of, proposed actions to replace fuel bladders at Amundsen-Scott South Pole Station, Antarctica, during the 1991- 1992 austral summer season. The Environmental Officer posed a set of questions relating to the proposed project, and to the potentially affected environment. These questions were responded to by the civilian support contractor's Environmental Engineer on December 22, 1991; the questions and responses are shown below: Environmental Assessment Queries and Responses GENERAL Capacity exists to store 225,000 gallons of JP-8 fuel at the South Pole station for use by heavy equipment and generation of heat and electricity. The fuel is delivered to McMurdo Station, Antarctica, by tanker and then to the South Pole Station by aircraft each January. Survival of personnel stationed at the South Pole is dependent on the existence of a secure supply of fuel, especially during the austral winter months. The existing fuel storage system consists of nine rubber fuel bladders. Each bladder is set on top of an additional piece of rubber. The underlying rubber currently used serves to reduce the potential for leakage through the bottom of the bladder but does not provide adequate secondary containment. The old fuel bladders have been in service for more than ten years beyond their expected life-time. Proposed improvement of the fuel storage facilities is to occur in several. Last season five bladders were replaced with new bladders identical in design to existing bladders. During the 1991-1992 austral season, replacement of the remaining four old bladders is proposed. During the 1992-1993 season, installation of secondary containment for the bladders is proposed. This Environmental Assessment Memorandum (EAM) covers activity proposed to occur during the 1991-1992 season (replacement of four bladders). At a later date, when the design is finalized, an addendum to this EAM will cover the proposed containment system. 1. What is the specific purpose of the proposed activity? It is proposed to replace existing fuel bladders, in service for more than ten years beyond their expected life-time, with new bladders. What alternatives to the proposed activity have the Program and the Contractor considered? The following alternatives were considered: 1. Do nothing (the no-action alternative); 2. Replace the existing bladders with underground storage tanks to be buried in front of the station's fuel arch; 3. Replace the existing bladders with double-walled, steel tanks placed within the fuel arch; 4. Replace the existing bladders with identical bladders and eventually provide secondary containment as proposed; and 5. Build an all-new fuel storage facility (e.g., an elevated building or a new fuel storage arch. Have probable impacts of all alternatives been considered by the Program and the Contractor? Please explain how. The main environmental concern regarding fuel storage is the potential for release of fuel through leaking stor- age facilities, or from spills as fuel is transferred into and out of a facility. Each of the different alternatives considered has a different potential to allow fuel releases to occur. The probability that spills will occur varies with: 1) the likelihood that the storage facility will leak; 2) the ability of a storage facility to contain any spills that occur; and 3) the ability of personnel to inspect the facility for evidence of points where a leak has occurred or is like- ly to occur. The alternatives considered are listed above in approxi- mate order of their relative potential to cause environ- mental impact, from highest impact potential to lowest. The "do nothing" alternative is rated the lowest as the existing fuel bladders have a relatively high chance of failure due to their age, and since no secondary containment exists for them. The second alternative, below-grade tanks, is considered less protective than the third and fourth alternatives for two reasons. First, below-grade storage tanks could experience large amounts of stress due to shifting of the polar plateau. Also, the third and fourth alterna- tives call for placing storage containers above ground and within secondary containment. Compared to below ground systems this typically affords a greater capabil- ity to inspect both the primary and secondary contain- ment systems for evidence of leaks. The proposed alternative, use of fuel bladders within secondary containment, is preferred over installation of double-walled steel tanks for logistical reasons. As access into the existing arch is limited, steel tanks could not be installed without major snow removal and arch bulkhead removal. Also, the reliability of steel tanks at the South Pole has not been evaluated. Rubber bladders have been used at the South Pole for fuel stor- age without any major leakage problems. The last alternative, construction of an all-new storage facility, is not proposed because the expense of con- structing a new structure for fuel storage is not justi- fied at this time, given that viable alternatives exist. Whether or not an-all new storage system would have less potential for environmental impact than the proposed alternative is unknown and may require further study. Should the chosen alternative involve potential impacts, how would these impacts be mitigated by the Program or the Contractor During installation care will be taken not to puncture or otherwise cause the new bladders to leak. The bladders will be placed in a heated area and warmed before handling to ensure they are not brittle due to cold. Have measures to assess the indirect costs of the proposed activity been identified or considered by the Program or the Contractor? Please explain how. A decrease in potential for fuel loss from the storage facility will conserve fuel and save money. The extent of this will be shown by closely tracking the amount of fuel placed in the bladders and the amount used. LAND USE AND PLANNING 2. Where would the proposed activity be located, specifically? New fuel bladders would replace existing bladders in the same location in the South Pole Station fuel arch. Have alternative locations been considered by the Program or the Contractor? If yes, which are they; if no, explain why. No new locations for placing fuel bladders were considered. As discussed above alternative locations for other types of fuel storage containers were considered. 3. How would any aesthetic impacts to the area from the propos- ed activity be handled by the Program or the Contractor? As the proposed project involves replacement of existing equipment with identical equipment, the appearance of the fuel storage facility would not change. Bladders are located within an arch and would not be visible from outside or from within the dome. 4. Would the proposed activity have any other indirect impacts on the environment? If yes, what are they; if no, explain why none are expected. The existing bladders would have to be properly disposed. This is unavoidable since repairing the existing bladders is not considered a satisfactory option. 5. Would the proposed activity change the traditional use(s) of the proposed (or chosen) site? If yes, how; if no, why. No. The proposed action replaces existing equipment with new and provides fuel system improvements. 6. Are the physical and environmental characteristics of the neighboring environment suitable for the proposed activity? If yes, explain why; if no, explain why. Yes. If properly contained and monitored, fuel stored at the station poses negligible threat to the physical environment. As there are no resident biota (i.e., non- human) at the South Pole, properly contained and monitored, fuel stored at the station poses no threat to antarctic wildlife. IMPACT AND POLLUTION POTENTIAL AND ENVIRONMENTAL MANAGEMENT: 7. How has protection of the environment and human health from unnecessary pollution or impact been considered for the proposed activity (includes such considerations as pollution abatement or mitigation, and waste management [e.g., of noise, dust, fuel loss, disposition of one-time-use materials, construction wastes])? The project would increase environmental protection at the station by reducing the potential for fuel loss. Workers would be instructed in, and required to follow, cleanup following construction; and, any wastes associated with construction would be properly disposed or processed. 8. Would the proposed activity change ambient air quality at the proposed (or chosen) site? If yes, how; if no, why. No. Based on the lack of fuel vapor emissions during the fuel bladder removal which occurred in 1990-1991 and the fact that the vapor pressure of the fuel is low at the typical temperature of the fuel arch, vapor emissions are expected to be minimal. 9. Would the proposed activity change water quality or flow (drainage), at the proposed (or chosen) site? If yes, how; if no, why. Not applicable. 10. Would the proposed activity change waste generation or management at the proposed (or chosen) site? If yes, how; if no, why. The four remaining old bladders would require disposal. This is unavoidable as repair of the existing bladders is an unsatisfactory option. Bladders will be cut into pieces, placed in crates and retrograded through McMurdo to Port Hueneme for disposal. 11. Would the proposed activity change energy production or demand, personnel and life support, or transportation requirements at the site? If yes, how; if no, why. No. By reducing the potential for fuel loss energy consumption may be decreased. 12. Is the proposed activity expected to adversely affect scientific studies or locations of research interest (near and distant, in the short-term and in the long-term)? If yes, how; if no, why. No. Past storage of fuels in bladders at the station have not evidenced impacts to science. 13. Would the proposed activity generate pollutants that might affect terrestrial, marine or freshwater ecosystems within the environs of the station or inland camp? If yes, how; if no, why. No. If properly contained and monitored the proposed fuel storage system should not pose a threat to the environment. 14. Does the site of the proposed activity serve as habitat for any significant assemblages of Antarctic wildlife (for example, mosses or lichens, or antarctic birds or marine mammals)? No, there are no known assemblages of antarctic wildlife that would be affected by the proposed activity. The activity will take place inside an existing building. HUMAN VALUES 15. Would he proposed activity encroach upon any historical property of the site? If yes, how; if no, why. No. The fuel bladders to be replaced are old but not considered of significant historical value. OTHER CONSIDERATIONS 16. What other environmental considerations may be potentially affected by the proposed activity at the proposed (or chosen) site? For example, have impacts associated with decommissioning of the activity been considered (and how). None. Although the new bladders may not be reusable and may require disposal at some point in the future they are expected to function for a long enough period of time to justify their installation. Finding The Environmental Officer, after reviewing the information presented above, believes that the proposed activity poses neither potentially minor nor transitory impacts to the antarctic environment. There are, in fact, anticipated environmental benefits as fuel storage at the station would have improved containment and inspection of bladders and their containment systems would be enhanced. The contractor and Program are authorized to proceed with the proposed activity. Sidney Draggan