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 The area disturbed would overlap with soil vapor monitoring well (MW) KAFB-2604, <strong>and</strong> could also affect MW KAFB-2606. In addition, the construction would overlap with groundwater MW KAFB-2622 <strong>and</strong> MW KAFB-2602A (KAFB 2008e). These <strong>and</strong> other MWs around the periphery of the Proposed Action footprint are Long Term Monitoring (LTM) wells <strong>for</strong> monitoring soil vapor <strong>and</strong> groundwater components of the WP-26. Presently, WP-26 is in the remedial investigation phase. During the construction of the proposed <strong>hot</strong> <strong>cargo</strong> <strong>pad</strong>, BMPs should be followed to avoid damage to the existing MWs. Additional MWs may need to be installed in the future. These MWs would require continued use, which could also require surface modification (i.e., modification to flush-covering). The NMED concurs that the removal of the surface sewage sludge would alleviate any potential adverse effects on the environment <strong>and</strong> human health from soil contamination (Bitner 2009). Additionally, the Proposed Action includes setting the existing MWs flush with the paving of the proposed <strong>hot</strong> <strong>cargo</strong> <strong>pad</strong>. This would allow <strong>for</strong> the continued use of the MWs to aid in the remediation of the soil vapor <strong>and</strong> ground water contamination, once appropriate remedial actions <strong>for</strong> these areas are selected. Consequently, construction activities at Kirtl<strong>and</strong> AFB would result in impacts on the ERP site; however, these impacts would be expected to be less than significant. No significant impacts on ERP site WP-26 would be expected from the operation <strong>and</strong> maintenance of the proposed <strong>hot</strong> <strong>cargo</strong> <strong>pad</strong>. While a remedial action has not been selected <strong>for</strong> the soil vapor <strong>and</strong> perched groundwater contamination identified in the RFI, the samples with the highest identified levels of contaminants were at the perched groundwater interface at approximately 200 feet bgs (KAFB 2008e). It is likely that the approved remedial action will require periodic access to the area <strong>for</strong> collection of media samples from the MWs. In addition, because the final remedial abatement has not been selected, additional surface equipment, such as soil vapor extraction blowers/piping, might need to be installed. While it is anticipated that interference with the proposed <strong>hot</strong> <strong>cargo</strong> <strong>pad</strong> would be minimal <strong>and</strong> required equipment installation would be designed to operate from remote locations, some overlap might occur. No significant impacts associated with the four MMRP sites would be expected during construction or operational activities under the Proposed Action. Use of the four historic ranges identified in the Kirtl<strong>and</strong> AFB MMRP that overlap with the proposed <strong>hot</strong> <strong>cargo</strong> <strong>pad</strong> site was discontinued prior to 1962, <strong>and</strong> the Proposed Action area has undergone significant alteration in the intervening years. It is unlikely that quantities of MC <strong>and</strong> MECs, if any, would be encountered during construction. Asbestos-Containing Material. The construction, operation, <strong>and</strong> maintenance of the proposed <strong>hot</strong> <strong>cargo</strong> <strong>pad</strong> would not involve the h<strong>and</strong>ling of ACMs; there<strong>for</strong>e, the Proposed Action would not result in any impacts related to ACMs. Lead-Based Paint. The construction, operation, <strong>and</strong> maintenance of the proposed <strong>hot</strong> <strong>cargo</strong> <strong>pad</strong> would not involve the use of LBP; there<strong>for</strong>e, the Proposed Action would not result in any impacts related to LBP. Polychlorinated Biphenyls. The construction, operation, <strong>and</strong> maintenance of the proposed <strong>hot</strong> <strong>cargo</strong> <strong>pad</strong> would not involve the h<strong>and</strong>ling of materials containing PCBs; there<strong>for</strong>e, the Proposed Action would not result in any impacts related to PCBs. Pollution Prevention. Less-than-significant impacts on the Pollution Prevention Program at Kirtl<strong>and</strong> AFB would be expected from implementation of the Proposed Action. An incremental increase in hazardous materials <strong>and</strong> wastes would be expected during construction <strong>and</strong> operation under the Proposed Action. Adherence to the Pollution Prevention Program <strong>and</strong> associated plans at Kirtl<strong>and</strong> AFB, in particular the Hazardous Material Emergency Planning <strong>and</strong> Response Plan, would reduce adverse impacts Kirtl<strong>and</strong> AFB, NM January 2011 4-18
<strong>Final</strong> <strong>EA</strong> Addressing Construction, Operation, <strong>and</strong> Maintenance of a Hot Cargo Pad resulting from the Proposed Action. BMPs utilized during construction activities would minimize impacts on the natural environment. The operation <strong>and</strong> maintenance of the proposed <strong>hot</strong> <strong>cargo</strong> <strong>pad</strong> would not result in an increase in the type or quantity of <strong>hot</strong> <strong>cargo</strong> missions. No impacts on the Pollution Prevention Program would be expected from the operation <strong>and</strong> maintenance activities. 4.10.2.2 No Action Alternative The No Action Alternative would result in no change to the existing hazardous materials or waste management conditions discussed in Section 3.10.2. No impacts on hazardous materials or waste management would be expected as a result of the Proposed Action not being implemented. 4.11 Safety 4.11.1 Evaluation Criteria If implementation of the Proposed Action were to increase risks associated with the safety of construction personnel, contractors, military personnel, or the local community; or hinder the ability to respond to an emergency, it would represent an adverse effect. An effect would be significant if implementation of the Proposed Action were to substantially increase risks associated with the safety of construction personnel, contractors, military personnel, or the local community; substantially hinder the ability to respond to an emergency; or introduce a new health or safety risk <strong>for</strong> which the installation is not prepared or does not have adequate management <strong>and</strong> response plans in place. 4.11.2 Environmental Consequences 4.11.2.1 Proposed Action Contractor Safety. Implementation of the Proposed Action would slightly increase the health <strong>and</strong> safety risk to contractors per<strong>for</strong>ming demolition <strong>and</strong> construction work at the Proposed Action site during the normal workday because the level of such activity would increase. Contractors would be required to establish <strong>and</strong> maintain health <strong>and</strong> safety programs <strong>for</strong> their employees. The implementation of the Proposed Action would require the disturbance of a small area of ground surface within the northwestern portion WP-26 (likely less than 0.5 acres). While not part of the Proposed Action, remedial action to clean the surface of WP-26 will be conducted during Spring 2010. This surface remediation will consist of removing <strong>and</strong> disposing of the top 5 inches of the ground surface, which is potentially contaminated sewage sludge, within WP-26 in a manner consistent with Federal, state, <strong>and</strong> USAF regulations. The remedial action would not involve subsurface products or groundwater contamination, <strong>and</strong> monitoring wells would remain in place to continue tracking the contamination. Although the surface remedial ef<strong>for</strong>ts would reduce the potential health <strong>and</strong> safety concerns to contractors working on site, all contractors would still need to take health <strong>and</strong> safety precautions to guard against potential exposure to contaminates <strong>and</strong> pathogens at WP-26. Health <strong>and</strong> safety precautions might include contractors listing exposure guidelines in the site specific health <strong>and</strong> safety programs, <strong>and</strong> training all employees working on site how to reduce potential exposure to these contaminates. If any soil potentially containing contamination was discovered during the construction of the Proposed Action, the contractor would be required to immediately stop work, report the discovery to the installation, <strong>and</strong> implement appropriate safety measures. Commencement of field activities would not continue in this area until the Kirtl<strong>and</strong> AFB, NM January 2011 4-19
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APPENDIX C AIR QUALITY SUPPORTING D
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Air Quality Emissions from Proposed
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