Final FONSI and EA for hot cargo pad on Kirtland AFB - Kirtland Air ...

<strong>Final</strong> <strong>EA</strong> Addressing Construction, Operation, <strong>and</strong> Maintenance of a Hot Cargo Pad
4.6.2 Environmental Consequences
4.6.2.1 Proposed Action
Under the Proposed Action, less-than-significant impacts on water resources would be expected.
Groundwater might be temporarily used <strong>for</strong> dust suppression during demolition <strong>and</strong> construction
activities, depending on site conditions. If water application were required <strong>for</strong> dust suppression, sufficient
water resources are available on the installation; there<strong>for</strong>e, less-than-significant adverse impacts on
groundwater availability would be expected.
The Proposed Action would create ground disturbances on a small scale, which could in turn increase
erosion potential <strong>and</strong> runoff during heavy precipitation events. Demolition <strong>and</strong> construction debris could
reach waterways through wind or surface runoff if measures were not taken to keep debris on site. Proper
housekeeping <strong>and</strong> retention of debris within the site boundaries would prevent construction debris from
entering waterways. The USEPA’s Construction General Permit outlines a set of provisions construction
operators must follow to comply with the requirements of the NPDES storm water regulations. The
NPDES storm water program requires construction site operators engaged in clearing, grading, <strong>and</strong>
excavating activities that disturb 1 acre or more to obtain coverage under an NPDES permit <strong>for</strong> their
storm water discharges. Kirtl<strong>and</strong> AFB manages an active program <strong>for</strong> tracking <strong>and</strong> inspecting large
(greater than 5 acres) <strong>and</strong> small (1 to 5 acres) construction activities that require coverage under the
NPDES program (KAFB 2002). Because the Proposed Action would disturb more than 1 acre
(approximately 11 acres <strong>for</strong> proposed <strong>pad</strong> <strong>and</strong> taxiway), it would require NPDES permit coverage, which
would further require the preparation of a Notice of Intent (NOI) to discharge storm water <strong>and</strong> preparation
of a Storm Water Pollution Prevention Plan (SWPPP) that would be implemented during construction.
The SWPPP would be developed in accordance with the requirements of the Construction General permit.
Prior to submission of the NOI to the USEPA, which is the NPDES permitting authority in New Mexico,
the construction operator would be required to submit the SWPPP to the 377 MSG/C<strong>EA</strong>NC <strong>for</strong> review.
A SWPPP would identify BMPs to reduce erosion <strong>and</strong> runoff from construction of the proposed <strong>hot</strong> <strong>cargo</strong>
<strong>pad</strong>.
As a new requirement under the CWA <strong>Final</strong> Rule <strong>for</strong> its NPDES Construction General Permit, Kirtl<strong>and</strong>
AFB would be required to meet the non-numeric effluent limitations of the CWA <strong>and</strong> design, install, <strong>and</strong>
maintain effective erosion <strong>and</strong> sedimentation controls as described in Section 3.6.1. The implementation
of these non-numeric effluent limitations would minimize short-term adverse effects on surface waters
from erosion, sedimentation, <strong>and</strong> pollution. In addition, Kirtl<strong>and</strong> AFB would be subject to the new storm
water design requirements of Section 438 of the EISA that require Federal construction projects that
disturb 5,000 square feet or more of l<strong>and</strong> to maintain or restore predevelopment site hydrology to the
maximum extent technically feasible with respect to temperature, rate, volume, <strong>and</strong> duration of flow.
Under the Proposed Action, construction contractors would be required to provide documentation on how
they would meet Section 438 of the EISA requirements. There<strong>for</strong>e, no significant short-term or longterm,
adverse impacts on water resources would be expected from the Proposed Action.
Design of the proposed <strong>hot</strong> <strong>cargo</strong> <strong>pad</strong> would include storm water control. Storm water from the proposed
<strong>hot</strong> <strong>cargo</strong> <strong>pad</strong> would be incorporated into Kirtl<strong>and</strong>’s MS4; there<strong>for</strong>e, no long-term adverse effects on
water resources from sheet runoff during storm events would be expected from the operation of the <strong>hot</strong>
<strong>cargo</strong> <strong>pad</strong>. In addition, Kirtl<strong>and</strong> AFB’s MS4 permit requires that all construction activities, regardless of
size, implement BMPs to ensure that storm water pollutants do not enter the storm drainage system <strong>and</strong>
that storm water pollutants are contained within the project area. All storm water drop inlets in the
project area must be protected with a barrier (e.g., hay bales, socks, s<strong>and</strong> bags). Contractors must
minimize stock piles <strong>and</strong> keep the construction area clean of debris, designate equipment <strong>and</strong> storage
areas, ensure equipment are free of leaks, minimize exits <strong>and</strong> entrances to the project area, minimize track
Kirtl<strong>and</strong> AFB, NM January 2011
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