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

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<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 4-10
<strong>Final</strong> <strong>EA</strong> Addressing Construction, Operation, <strong>and</strong> Maintenance of a Hot Cargo Pad out, <strong>and</strong> implement good housekeeping measures to ensure practices are reducing storm water pollutants to the maximum extent practicable. Heavy equipment (e.g., bulldozers, backhoes, dump trucks, concrete mixers, asphalt vehicles) <strong>and</strong> generators would be on site throughout periods of demolition <strong>and</strong> construction. Fuels, hydraulic fluids, oils, <strong>and</strong> other lubricants would be stored on site during the project to support contractor vehicles <strong>and</strong> machinery. No other hazardous materials are anticipated to be stored on site during demolition or construction activities. It is assumed that construction personnel would follow appropriate BMPs to protect against potential petroleum or hazardous material spills. Proper housekeeping, maintenance of equipment, <strong>and</strong> containment of fuels <strong>and</strong> other potentially hazardous materials would be conducted to minimize the potential <strong>for</strong> a release of fluids into groundwater or surface waters. In the event of a spill, procedures outlined in Kirtl<strong>and</strong> AFB’s Hazardous Material Emergency Planning <strong>and</strong> Response Plan would be followed to quickly contain <strong>and</strong> clean up a spill (see Sections 3.10 <strong>and</strong> 4.10 <strong>for</strong> more in<strong>for</strong>mation on hazardous materials <strong>and</strong> wastes). There<strong>for</strong>e, less-than-significant adverse impacts on water quality would be expected as a result of the Proposed Action. The existing <strong>and</strong> proposed <strong>hot</strong> <strong>cargo</strong> <strong>pad</strong>s are outside of the Tijeras Arroyo <strong>and</strong> Arroyo del Coyote 100-year floodplains; there<strong>for</strong>e, no direct impacts on floodplains would be expected. Although the quantity of storm water sheet flow from disturbed sites to the intermittent streams on Kirtl<strong>and</strong> AFB could increase during demolition <strong>and</strong> construction activities, this increase is not anticipated to be significant. There<strong>for</strong>e, the Proposed Action would have less-than-significant impacts on floodplain flow characteristics. 4.6.2.2 No Action Alternative Under the No Action Alternative, the proposed <strong>hot</strong> <strong>cargo</strong> <strong>pad</strong> <strong>and</strong> related components would not be constructed <strong>and</strong> there would be no changes to current water resources. There<strong>for</strong>e, no new impacts on water resources would be expected as a result of the No Action Alternative. Without implementation of the Proposed Action, the pavement conditions at Pad 5 would continue to deteriorate. Deterioration could lead to cracks in pavement, which would not prevent release of pollutants into soils or groundwater in the event of a spill; there<strong>for</strong>e, long-term, adverse effects could occur from the No Action Alternative. 4.7 Biological Resources 4.7.1 Evaluation Criteria The level of impact on biological resources is based on (1) the importance (i.e., legal, commercial, recreational, ecological, or scientific) of the resource, (2) the proportion of the resource that would be affected relative to its occurrence in the region, (3) the sensitivity of the resource to the proposed activities, <strong>and</strong> (4) the duration of ecological ramifications. Impacts on biological resources are considered significant if species or habitats of high concern are adversely affected over relatively large areas, or disturbances cause reductions in population size or distribution of a species of special concern. A habitat perspective is used to provide a framework <strong>for</strong> analysis of general classes of effects (i.e., removal of critical habitat, noise, human disturbance). Determination of the significance of wetl<strong>and</strong> impacts is based on (1) the function <strong>and</strong> value of the wetl<strong>and</strong>, (2) the proportion of the wetl<strong>and</strong> that would be affected relative to the occurrence of similar wetl<strong>and</strong>s in the region, (3) the sensitivity of the wetl<strong>and</strong> to proposed activities, <strong>and</strong> (4) the duration of ecological ramifications. Impacts on wetl<strong>and</strong> resources are considered significant if high value wetl<strong>and</strong>s would be adversely affected. Kirtl<strong>and</strong> AFB, NM January 2011 4-11
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Comments Received on the Draft Envi
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APPENDIX C AIR QUALITY SUPPORTING D
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