United States Department of the Interior Bureau of Land Management
Preliminary Environmental Assessment DOI-BLM-UT-C030-2016-40-EA May 2017
Gunlock Arsenic Treatment Plant
Applicant: City of St. George 175 East 200 North St.
U.S. Department of the Interior Bureau of Land Management St. George Field Office 345 East Riverside Drive St. George, Utah 84790 Phone: (435) 688-3200 Fax: (435) 688-3252 Gunlock Arsenic Treatment Plant DOI-BLM-UT-C030-2016-40-EA
1.0 PURPOSE AND NEED ...... 1 1.1 Introduction ...... 1 1.2 Background ...... 1 1.3 Purpose and Need for the Proposed Action ...... 4 1.4 Decision to be Made...... 4 1.5 Conformance with BLM Land Use Plan ...... 4 1.6 Relationship to Statutes, Regulations, or other Plans ...... 4 1.7 Identification of Issues ...... 5 1.7.1. Issues Identified for the Proposed Action...... 5 1.7.2. Resources Considered but Eliminated from Further Analysis ...... 6 1.8 Summary ...... 6 2.0 DESCRIPTION OF ALTERNATIVES, INCLUDING PROPOSED ACTION ...... 7 2.1 Introduction ...... 7 2.2 Alternative A - Proposed Action...... 7 2.2.1. Location ...... 7 2.2.2. Right-of-Way ...... 7 2.2.3. Construction Schedule ...... 13 2.2.4. Access Road, Pipeline and Transmission Line Construction ...... 13 2.2.5. Arsenic Treatment Plant Construction ...... 13 2.2.6. Standard Operating Procedures...... 14 2.2.7. Operation and Maintenance ...... 15 2.3 Alternative B – No Action ...... 16 2.4 Alternatives Eliminated From Further Evaluation ...... 16 3.0 AFFECTED ENVIRONMENT ...... 17 3.1 Introduction ...... 17 3.2 General Setting...... 17 3.3 Resources Brought Forward for Analysis ...... 18 3.3.1. Water Resources/Quality (drinking/surface/ground) ...... 18 3.3.2. Cultural Resources...... 18 3.3.3. Soils...... 20 3.3.4. Fish and Wildlife Resources (excluding USFWS Designated Species) ...... 20 3.3.5. Migratory Birds ...... 21 3.3.6. Visual Resources...... 22 3.3.7. National Historic Trails (Old Spanish Trail) ...... 23 4.0 ENVIRONMENTAL IMPACTS ...... 24 4.1 Introduction ...... 24 4.2 General Analysis Assumptions and Guidelines ...... 24 4.3 Direct and Indirect Impacts ...... 24
4.3.1. Alternative A – Proposed Action...... 25 4.3.2. Alternative B – No Action ...... 32 4.4 Cumulative Impacts Analysis ...... 33 4.4.1. Past and Present Actions...... 33 4.4.2. Reasonably Foreseeable Action Scenario (RFAS) ...... 33 4.4.3. Cumulative Impacts ...... 33 5.0 CONSULTATION AND COORDINATION ...... 34 5.1 Introduction ...... 34 5.2 Persons, Groups, and Agencies Consulted...... 35 5.3 Summary of Public Participation ...... 35 5.3.1. Comment Analysis ...... 35 5.3.2. List of Commenters...... 36 5.3.3. Response to Public Comment ...... 36 5.4 List of Preparers ...... 36 6.0 REFERENCES, GLOSSARY AND ACRONYMS ...... 37 6.1 References Cited ...... 37 6.2 List of Acronyms Used in this EA ...... 37
Tables Table 2-1. New Surface Disturbance Summary ...... 8 Table 2-2. Estimated Personnel & Equipment Required for Project ...... 14 Table 2-3. Estimated Personnel & Equipment Required for Operation & Maintenance ...... 16 Table 4-1 Terms Used to Describe the Environmental Effects ...... 25 Table 5-1: List of all Persons, Agencies and Organizations Consulted for Purposes of this EA . 35 Table 5-2: List of Staff Used in the Preparation of this EA ...... 36 Figures Figure 1-1 Project Location ...... 3 Figure 2-1 Existing BLM ROWs ...... 9 Figure 2-2 Existing Conditions ...... 10 Figure 2-3 Site Plan ...... 11 Figure 2-4 New Water Lines ...... 12 Figure 3-1 Existing view (upper) of proposed project from Gunlock Road (Travel Route KOP) 23 Figure 3-2 Existing view (lower) of proposed project from Gunlock Road (Travel Route KOP) 23 Figure 4.1 Existing view of proposed project site due west of site ...... 31 Figure 4.2 Existing view approximately 30 feet above project site looking Northeast ...... 31 Appendices Interdisciplinary Team Checklist ...... Appendix A Plan of Development ...... Appendix B Best Management Practices and Standard Operating Procedures ...... Appendix C Visual Contrast Rating Worksheet ...... Appendix D
1.0 PURPOSE AND NEED 1.1 Introduction This Environmental Assessment (EA) has been prepared to disclose and analyze the environmental consequences of the Gunlock Arsenic Treatment Plant (GATP) as proposed by the City of St. George. The EA is a site-specific analysis of potential impacts that could result with the implementation of a proposed action or alternatives to the proposed action. The EA assists the United States Bureau of Land Management (BLM) in project planning and ensuring compliance with the National Environmental Policy Act (NEPA), and in making a determination as to whether any “significant” impacts could result from the analyzed actions. “Significance” is defined by NEPA and is found in regulation 40 CFR 1508.27. An EA provides evidence for determining whether to prepare an Environmental Impact Statement (EIS) or a statement of “Finding of No Significant Impact” (FONSI). If the decision maker determines that this project has “significant” impacts following the analysis in the EA, then an EIS would be prepared for the project. If not, a Decision Record may be signed for the EA approving the selected alternative, whether the proposed action or another alternative. A Decision Record (DR), including a FONSI statement, documents the reasons why implementation of the selected alternative would not result in “significant” environmental impacts (effects) beyond those already addressed in the BLM’s St. George Field Office Resource Management Plan hereinafter referred to as the RMP (BLM 1999).
1.2 Background The City of St. George, located in southwest Utah, supplies water to the cities of St. George, Santa Clara and Ivins. The City currently obtains its culinary water supply from Pine Valley Mountain springs, eleven wells located in the Gunlock area, five wells located in the Snow Canyon area, two wells located in the Mill Creek area, one well located in City Creek and from the Virgin River through the Quail Creek Water Treatment Plant.
In January 2001, the Environmental Protection Agency (EPA) implemented the “Arsenic and Clarifications to Compliance and New Source Monitoring Rule” which changed the arsenic Maximum Contaminant Level (MCL) from 50 ppb to 10 ppb. The objective of the arsenic treatment is to reduce arsenic levels in the source water to less than 10 ppb. With the promulgation of the new arsenic rule, the City started evaluating arsenic treatment at the Gunlock Well Field. Arsenic above the new MCL of 10 ppb has been detected in the Gunlock, Snow Canyon, and City Creek wells. The purpose of this project is to assist the City of St. George in planning to comply with the new arsenic regulatory requirements at the Gunlock Well Field.
The Gunlock Well Field is located approximately 15 miles northwest of the City of St. George. The well field consists of eleven wells, three of which have been drilled recently between the year 2002 and 2003. The wells pump from the highly productive Navajo Sandstone formation. Water
Gunlock Arsenic Treatment Plant page 1 Environmental Assessment from the well field is pumped into the Gunlock tank, which then gravity feeds to the City of St. George via 18 and 20 inch transmission pipelines. Potable water is also supplied to the Shivwits Band of the Paiute Indian Tribe (Shivwits) from an 8 inch line connected directly to the Gunlock Tank.
The City plans to install a new pipeline and arsenic treatment plant to be known as the Gunlock Arsenic Treatment Plant (GATP). The GATP will be located on lands administered by the BLM St. George Field Office. If approved, construction operations would commence in spring of 2017. Figure 1-1 shows the proposed location of the GATP. The following are approximate dimensions and description of the facilities that will be constructed as part of the GATP:
Building 6 MGD Building – 75’ x 90’ Block Building Future 6 MGD Building Addition – 50’ x 70’ Building wall height approximately 14 feet Building Roof with standard 3/12 roof pitch would be approximately 11 feet high. Overall height of building at roof peak would be 25 feet (this dimension can be reduced using flatter roof slope).
Outside Tanks Two metal tanks to be located outside as shown on plan approximately 25 feet in diameter and 20 feet high (to be placed immediately behind building to avoid visibility)
Settling Ponds There will be 4 drying beds initially which would be expanded to 8 drying beds in the future. They will be constructed of reinforced concrete and be approximately 30 feet wide and 200 feet long and approximately 6 feet deep. Most of the structure will be below ground.
Treatment Process The building will house coagulation/filtration pressure vessels provided with media and chemical feeds that are effective in removing arsenic. The outside tanks are used to store water for back wash of the filters. The drying beds are used to settle solids from the back wash. When dry, materials will be removed and disposed of at an approved landfill.
The implementation of this project will allow the City to provide water from the Gunlock Well Field meeting current culinary water standards to the Shivwits as well as other the other communities it currently serves.
Gunlock Arsenic Treatment Plant page 2 Environmental Assessment
Figure 1-1 Project Location
Gunlock Arsenic Treatment Plant page 3 Environmental Assessment
1.3 Purpose and Need for the Proposed Action The purpose of the federal action is to respond to the City of St. George’s application for a ROW for siting an arsenic treatment plant and water pipe line in Washington County, Utah. The need for the Proposed Action is established by the BLM’s statutory and regulatory responsibilities regarding ROWs under the Federal Land Policy and Management Act (FLPMA) of 1976 (43 CFR 2800). The City of St. George’s need for the proposed action is to remove arsenic from the culinary water well sources in the Gunlock Well Field area in order to meet EPA standards pursuant to the “Arsenic and Clarifications to Compliance and New Source Monitoring Rule”. The water from the wells needs to be treated prior to delivery to the Shivwits. In order to meet this requirement, the City has determined that the best location of the treatment facility would be near the source of water, which would place the treatment facility on BLM land.
1.4 Decision to be Made The decision the BLM will make based on the NEPA analysis is whether or not to grant a ROW to the City of St. George for the construction and operation of the proposed Gunlock Arsenic Treatment Plant, and under what terms and conditions.
1.5 Conformance with BLM Land Use Plan The SGFO RMP was approved in March 1999 and includes an objective to “continue to make public lands available for a variety of ROWs where consistent with planning goals and prescriptions for other resources.” The SGFO RMP goes on to state, “[w]here possible, BLM will encourage project sponsors to locate new ROWs in existing or designated utility and transportation corridors” (BLM 1999). The proposed arsenic treatment plant facility would be located in existing utility corridors. The SGFO RMP Decision LD-12 requires that ROW proposals be reviewed for consistency with planning decisions and evaluated under NEPA and other applicable laws (BLM 1999). It also requires the integration of mitigation to avoid adverse impacts, and the identification of alternatives, where appropriate. The SGFO RMP Decision LD-14 describes existing utility corridors and the preference to keep any proposed utilities within these corridors (BLM 1999). The proposed ROW and arsenic treatment facility conforms to both LD-12 and LD-14.
1.6 Relationship to Statutes, Regulations, or other Plans The application for ROW acquisition was submitted and will be processed and evaluated under the BLM statutory mandates and authority governing federal land use and other federal authorities listed below.
Multiple-use Sustained Yield Act of 1960 National Environmental Policy Act of 1969, as amended Federal Land Policy and Management Act of 1976 (BLM’s multiple-use mandate)
Gunlock Arsenic Treatment Plant page 4 Environmental Assessment
Other than BLM land use planning, no other federal land use plans apply to the alternatives presented in Chapter 2. The State of Utah does not maintain planning documents, nor does it conduct planning processes relating to the proposed arsenic treatment facility. The facility drawings and processes will be reviewed and approved by the City of St. George and Utah State Division of Drinking Water. All permits required for construction will be obtained.
1.7 Identification of Issues The BLM Interdisciplinary Team screened the proposed ROW and completed ID Team Checklists for the Gunlock Arsenic Treatment Plant (see Appendix A) to identify resource values and land uses that could be impacted by the Proposed Action and therefore require analysis in the EA.
1.7.1. Issues Identified for the Proposed Action Water Resources/Quality (drinking/surface/ground) This Proposed Action will affect drinking water, will likely affect surface water, and is not anticipated to affect ground water. The EA will identify the water resources and water quality affected by construction of this project and operation of the treatment plant.
Cultural Resources This Proposed Action has the potential to impact cultural resources and is an undertaking as identified by CFR 36 800.16(y). A cultural resource inventory will need to be completed to assess impacts to sites eligible for the National Register of Historic Places (NRHP). The EA will identify what potential historic properties could be impacted by construction of this project and operation of the treatment plant.
Soils Construction of this project and operation of the treatment plant affect soils throughout the site. The EA will identify the potential for erosion and sedimentation in the short/long-term and during construction.
Fish and Wildlife Resources (excluding USFWS Designated Species) Based upon field surveys conducted by the project biologist during fall 2015, spring 2016, summer 2016, and spring 2017, there will be no impacts to fish and minor impacts to wildlife resources (loss of habitat) during construction and operation of the treatment plant. Construction and operation of the plant will not impact the Santa Clara River.
Migratory Birds Field surveys conducted in spring and summer of 2015, 2016 and spring of 2017 did not indicate the presence of migratory bird nesting within the project site or adjacent to the treatment plant. Various species of songbirds were observed in the pinion-juniper trees within the project site. However, no nests were observed. Construction activities may temporarily
Gunlock Arsenic Treatment Plant page 5 Environmental Assessment
displace these species but they should return to the area or adjacent areas in and around the project site. In addition, construction and operation of the treatment plant will not significantly impact the Santa Clara River where waterfowl and other migratory birds were observed. Migratory birds were observed during the field survey flying over the project area, many on the way back and forth from Gunlock Reservoir. Construction and operation of the treatment plant is not expected to impact these migratory birds. Based upon the field surveys, and no direct impacts to the Santa Clara River and associated riparian habitat, the construction and operation of the treatment plant will not significantly impact migratory birds.
Visual Resources Construction of this project and operation of the treatment plant will affect visual characteristics of the surrounding landscape, including potential impacts to views along the adjacent highway. The EA will identify these issues.
National Historic Trails With the presence of national historic trails in the vicinity of the site, the construction of this project and operation of the treatment plant will potentially affect nearby national historic trails. The EA will identify these issues.
Native American Religious Concerns The project may potentially have adverse effects on nearby Native American sites (Appendix A), specifically regarding rock art sites within the vicinity of the project. Any concerns that arise from local Native American groups will be coordinated and resolved.
1.7.2. Resources Considered but Eliminated from Further Analysis The ID Team Checklists (see Appendix A) detail issues and resources considered by the BLM ID Team and provide a rationale for the findings of the resource specialists. Issues and resources were dismissed from further analysis in this EA because they are either not present or would not be affected to a degree that requires detailed analysis.
1.8 Summary This chapter has presented the purpose and need of the proposed project, as well as the relevant issues, i.e., those elements of the human environment that could be affected by the implementation of the proposed project. In order to meet the purpose and need of the proposed project in a way that resolves the issues, the BLM has developed a range of action alternatives. These alternatives, as well as a no action alternative, are presented in Chapter 2. The potential environmental impacts or consequences resulting from the implementation of each alternative are then analyzed in Chapter 4 for each of the identified issues.
Gunlock Arsenic Treatment Plant page 6 Environmental Assessment
2.0 DESCRIPTION OF ALTERNATIVES, INCLUDING PROPOSED ACTION 2.1 Introduction This EA analyzes the potential effects of implementing Alternative A (Proposed Action) and Alternative B (the No Action Alternative). The No Action Alternative is considered and analyzed to provide a baseline against which to compare the impacts of the Proposed Action. No other alternatives were brought forward for detailed analysis (see Section 2.5, Alternatives Considered but Eliminated from Detailed Analysis, for further details and rationale concerning alternatives eliminated from detailed analysis).
2.2 Alternative A - Proposed Action The proposed action is to build an arsenic treatment plant with associated piping, access road and other appurtenances herein described. The existing wells, piping system, and power lines associated with the Gunlock Well Field, which were approved as part of multiple BLM ROW grants, are shown on Figure 2-1. The existing wells, piping system, and power lines as well as access roads that would be included in the overall project are shown in Figure 2-2. In addition to the existing facilities, it will be necessary to parallel existing water transmission lines in Gunlock Road with new water transmission lines to convey untreated and treated water to and from the new GATP facility.
The plant will initially be sized to treat 6 million gallons per day (MGD) with an additional future expansion of 6 MGD (Figure 2-3). With the future expansion, it will also be necessary to parallel the existing transmission line in Gunlock Road with an additional water transmission line to be able to convey the additional treated water. This line will be approximately 4,800 feet in length and be constructed parallel to existing water transmission lines in Gunlock Road. A parallel pipeline will also be required to convey water from Wells 1, 2, 3, 4, and 6 to the GATP (Figure 2- 4).
2.2.1. Location The GATP components would be located on lands administered by the BLM (Figure 2-3) generally located below Gunlock Reservoir. The GATP would be located in the SW1/4NE1/4 and NW1/4SE1/4 of Section 8, Township 41 South, Range 17 West. The GATP would be accessed from Gunlock Road in two locations as shown on Figure 2-3. All other water pipelines for the project are located within previously granted ROWs
2.2.2. Right-of-Way The treatment plant would require a 5.05 acre permanent ROW and does not include the access road or the two pipelines feeding the plant. For the access road and pipelines, temporary 100 foot ROWs along the alignments, totaling 1.64 acres, will be required during construction for
Gunlock Arsenic Treatment Plant page 7 Environmental Assessment
grading, vehicle passage and pipe assemblage to access the treatment plant site, which is located about 380 feet from Gunlock Road (Figure 2-3). After construction, the permanent ROW will be reduced to a 50-foot width, totaling 0.82 acres.
In addition, with the expansion of the treatment plant in the future, a parallel water pipeline will need to be extended from the treatment plant site to the intersection of the water transmission line from Wells 1, 2, 3, 4, and 6 with Gunlock Road as shown on Figure 2-4. This pipeline will be installed within the existing Gunlock Road ROW. An additional 20-foot temporary ROW will be required during construction for grading, vehicle passage and pipe assemblage. After construction of the water transmission line, the ROW will revert to the existing Gunlock Road ROW. Table 2-1 provides length and new surface disturbance acreages for the various project components.
Table 2-1. New Surface Disturbance Summary Linear Feet Temporary New Surface Permanent New Land of New Surface Disturbance ROW Surface Disturbance Ownership Disturbance (Acres) ROW (Acres) Access Road and Pipeline (From Gunlock Road to Treatment Plant) BLM ‐ 0.82 0.82 Arsenic Treatment Plant BLM ‐ 0.00 5.05 Transmission Line (Parallels Gunlock Road within existing ROW); Temporary New Surface Disturbance ROW [20 feet] BLM 5,631 2.59 0.00 GRAND TOTAL 5,631 3.41 5.87
Gunlock Arsenic Treatment Plant page 8 Environmental Assessment
04 09 16 21 # * # * # * # * # * 05 # * # *
# * 08 T41S R17W # * 17 # * # * # * 20 # * # * # * # * # * # * # * # * # *
06 07 18 19 # * # * # *
0 500 1,000 2,000 Switch OHP Secondary Municipalities Gunlock Well Field Feet Power Pole UGP Primary PLSS Section Lines *# Transformer UGP Secondary PLSS Township Lines Existing BLM ROWs
Water Main O Spatial Reference: Utah State Plane NAD 83, feet OHP Primary Drawn By: JRH Scale: 1" = 1,000 ' Figure 2-1 Date: MAY 2, 2016 04 09 16 21 # * # *
Well 7 # * Well 8 Well 11 # * # * 05 Well 10 Well 4 # * # *
# * 08 T41S R17W # * 17 20 # * # *
Well 5 # *
Well 9 # * # * Well 1 # * # * # * # * Well 3 # * # * # * Well 6 06 07 18 19 # * # * # * Well 2
0 500 1,000 2,000 Existing Switch Existing OHP Primary Federal Land Gunlock Well Field Feet Existing Power Pole Existing OHP Secondary Private Land *# Existing Transformer Existing UGP Primary State Land Existing Conditions Existing Access Road Existing UGP Secondary PLSS Section Lines
O Spatial Reference: Utah State Plane NAD 83, feet Existing Water Line PLSS Township Lines Drawn By: JRH Scale: 1" = 1,000 ' Figure 2-2 Date: May 2, 2016 DATE BY DESCRIPTION NO. REVISIONS WCWCD SITE PLAN GUNLOCK WELLS ARSENIC TREATMENT TITLE PROJECT
PROJECT # 041-114
NAME RKB
DATE MAY 22, 2017
SCALE AS NOTED
SHEET FIGURE 2-3 1 OF 1 FILE rbeazer, DWG To PDF.pc3 DWG To rbeazer, P:\041-114 Gunlock Arsenic Treatment\Drawings\Exhibit Drawings\041-114 EXH.dwg, UPPER2, 5/22/2017 9:32:11 AM, 9:32:11 5/22/2017 UPPER2, EXH.dwg, Drawings\041-114 Treatment\Drawings\Exhibit Arsenic Gunlock P:\041-114 041-114 EXH.dwg 04 09 16 21 # * # * # *
Well 11 Well 7 # * Well 8 # * 05 Well 10 # * # * # * 08 Well 4 T41S R17W # * 17 20 ## ** Well 5 # * Well 9 # * ## ** Well 1 # * # * # * Well 3
# * # * # * Well 6 06 07 18
19 # * # * # * Well 2
0 500 1,000 2,000 New Site Existing OHP Primary Federal Land Gunlock Well Field Feet Existing Power Pole Existing OHP Secondary Privat e Land *# Existing Transformer Existing UGP Primary State Land New Water Lines New Water Lines Existing UGP Secondary
O Spatial Reference: Utah State Plane NAD 83, feet ExWater PLSS Section Lines Drawn By: JRH Existing Access Road PLSS Township Lines Scal e: 1" = 1,000'
P:\041-114 Gunlock Arsenic Treatment\Drawings\GIS\041-114 New Transmission Lines.mxd, Transmission New Treatment\Drawings\GIS\041-114 Arsenic PM 2:02:36 10/12/2016 Gunlock P:\041-114 jheward Figure 2-4 Date: October 12, 2016 2.2.3. Construction Schedule Construction would commence as soon as necessary ROW and permits are obtained and all plans are finalized. Construction of the GATP, including site improvements and pipeline, is estimated to take up to 12 months to complete. Construction of the phase 1 pipeline and treatment plant would occur simultaneously. The expansion of the treatment plant would be constructed simultaneously with the parallel transmission lines.
2.2.4. Access Road, Pipeline and Transmission Line Construction The proposed pipeline will be sized to properly convey design flows from the Gunlock Road to the treatment plant and also along the existing Gunlock Road ROW. Pipeline installation activities would include survey staking for alignment and grade, clearing and grubbing, access road construction, trenching, hauling equipment and materials, pipeline assembly and installation, and backfill, in this order. The approximate number of workers and typical types of equipment used for this type of construction are provided in Table 2-2. Prior to construction, the exact centerline of the pipeline ROW would be staked. The ROW boundaries will also be flagged. Following staking, vegetation within the ROW would be cleared and grubbed to the extent necessary to provide for equipment clearance, construction, and maintenance operations.
It is anticipated that the access road and trench for the pipeline would be excavated using CAT 345 (or smaller) track hoes. Grading will be designed and performed to balance the cut and fill quantities, thus eliminating the need to import or export material. The pipeline would be bedded and buried to a minimum depth of 3 feet to the top of pipe. The trench will generally be 2 feet wider than the pipe.
A typical installation for the pipe would require four to six feet of width by five to seven feet of depth. The pipeline will be provided with tracer wire for locating the underground piping. Where the pipeline would be installed under existing asphalt or where it would cross paved roads, asphalt would be replaced according to the governing agency’s recommended specifications and requirements. Design and coordination will include appropriate traffic control measures ensuring safe traffic flow. It is anticipated that construction will constrict traffic to a single lane requiring flagmen to be placed at both ends of the constricted traffic lane to control one-way traffic. Other signage and traffic control devices will also be employed to further ensure safety of both travelers and workers. All construction will be completed in a timely manner to minimize the traffic control.
2.2.5. Arsenic Treatment Plant Construction It is proposed to construct an arsenic treatment plant on lands administered by the BLM. This would also include the installation of supply, drain and overflow pipes, which would drain into
Gunlock Arsenic Treatment Plant page 13 Environmental Assessment
the proposed drying beds, buried a minimum of 3 feet below ground surface (as reflected by the red lines on Figure 2-3). The plant construction activities would include survey staking of the building and pipeline corridor, clearing and grubbing, excavation, hauling equipment and materials, trenching, backfill, compaction, pipeline installation, concrete work (forming, pouring, and curing), and site cleanup. The number of workers and type of equipment expected to be used to construct the treatment plant are provided in Table 2-2.
Table 2-2. Estimated Personnel & Equipment Required for Project Number of Task Equipment People Survey and Staking 2 1 ‐ Pickup Truck Trenching 1 1 ‐ Track Hoe (CAT 345) 1 ‐ Semi‐Truck w/ Flatbed Trailer Materials Hauling 2 1 ‐ Forklift/Loader 1 ‐ Bulldozer (CAT D10) 1 ‐ Track Hoe (CAT 345) 1 ‐ Loader Pipeline Installation and Burial 4 2 ‐ Pickup Trucks Compaction Equipment 1 ‐ Water Truck 1 ‐ Bulldozer (CAT D10) Road Construction 2 1 ‐ Blade 1 ‐ Water Truck 1 ‐ Loader 1 ‐ Dump Truck 1 ‐ Blade 1 ‐ Compactor Treatment Plant Construction 10 3 ‐ Concrete Trucks 1 ‐ Track Hoe (CAT 345) 1 ‐ Concrete Pump Truck 1 ‐ Crane 3 ‐ Pickup Trucks Clean‐up 2 1 ‐ Pickup Truck
2.2.6. Standard Operating Procedures Standard Operating Procedures (SOP) would be followed (except in unforeseen conditions) during construction, operation and maintenance of the proposed action. SOPs for this project include:
Gunlock Arsenic Treatment Plant page 14 Environmental Assessment
Construction Restoration – To include determination of native vegetation, reseeding rates, landscaping, re-vegetation and noxious weed removal as appropriate for construction zones. Construction Monitoring – To include mitigation efforts and modifications to construction methods as required to maintain environmental mitigation procedures in correlation with project requirements. Post-Construction Monitoring – To include treatment as required to maintain successful implementation of Construction Restoration. Flushing Pipeline – To include inspection and maintenance of hydraulic and structural integrity of pipe. Pipeline Alignment Maintenance – To include inspection and maintenance of native vegetation where possible and re-vegetation appropriate for site conditions while allowing maintenance of the pipe. Treatment Plant Site Maintenance – To include maintenance of native vegetation where possible and re-vegetation appropriate for site conditions while allowing access around the site and use of the treatment plant.
The SOP and features of the proposed action herein described are designed to avoid or minimize adverse impacts on public health and safety. Upon final design of the project, a complete SOP Manual will be prepared and kept on-site during and after construction. A preconstruction meeting with all entities involved in the project will be held prior to commencing construction on the project to review and assess standard SOP and other commitments. During construction, weekly project team meetings would be held to assess the progress of the work.
Specifics of restoration to disturbed areas would be outlined in the SOP Manual and/or ROW easements. Monitoring and treatment will continue until the success criteria are met for two consecutive years without human intervention. These actions would provide that disturbed areas are returned to a natural state as appropriate. Chapter 4 presents the impact analysis for resources after SOP have been successfully implemented. The following section includes additional operation and maintenance procedures to be incorporated into the SOP Manual.
2.2.7. Operation and Maintenance It is anticipated that routine maintenance would include the following (refer to Table 2-3): The treatment plant will be inspected and maintained weekly to meet EPA requirements. Equipment and products will be replaced as needed to meet the EPA standards. The pipeline system is estimated to have a 50 year life before major pipeline repair would be required.
Gunlock Arsenic Treatment Plant page 15 Environmental Assessment
The GATP will generate waste solids as a result of chemical addition ahead of filters to capture naturally occurring arsenic. These solids will be dried on site and tested for metals content according to EPA toxic characteristic leaching procedure (TCLP) requirements. Arsenic in the waste solids must be less than 5 milligram per kilogram or part per million for disposal in a traditional solid waste facility (landfill). Water treatment waste solids are typically disposed of as non-hazardous wastes. Gunlock WTP solids will likely be disposed of at the Washington County Landfill. Should the arsenic concentration exceed the TCLP limit, the City of St George may be able to demonstrate that the arsenic is no longer leachable (fixed) as a result of the treatment process so that landfill disposal is permissible, or transport the solids to either the Grassy Mountain or Energy Solutions Facilities in Tooele County for proper disposal.
Table 2-3. Estimated Personnel & Equipment Required for Operation & Maintenance Number of Task Equipment People
Flushing Pipeline 2 1 - Pickup Truck 1 - Pickup Truck Pipeline Maintenance 2 1 - Track Hoe (CAT 345) Compactors 1 - Crane Treatment Plant 1 - Pickup Truck 2 Maintenance 1 - Tanker Truck (Quarterly Basis) 1 - Septage Hauler (Quarterly Basis)
2.3 Alternative B – No Action Under the No Action Alternative, BLM would not grant a ROW for the proposed Gunlock Arsenic Treatment Plant. The City of St. George would be unable to comply with EPA’s Maximum Containment Levels of 10 ppb for Arsenic in their culinary water source from the Gunlock Well Field.
2.4 Alternatives Eliminated From Further Evaluation Other options were discussed on an economic and environmental feasibility level versus effectiveness. There were no other treatment methods considered as the technology of the proposed GATP is significantly the most effective and feasible method for arsenic treatment. The alternatives considered were therefore location-based only. These alternatives did not provide the most optimum beneficial solution for the City of St. George.
Gunlock Arsenic Treatment Plant page 16 Environmental Assessment
One alternative included locating the GATP further downstream nearer to Ivins on private property. However, as the required service area for the treated water was assessed, it was determined that the GATP needed to be above the delivery point for the Shivwits potable water supply. Additionally, being nearer to the source of the Gunlock wells will provide a maximum future use of the treated water by allowing higher connection points into the system.
Beyond the Ivins location, there are not any feasible areas with adequate site constraints to construct the GATP. The proximity to environmentally sensitive areas and topography of any other location would create excessive disturbance to the environment. Alternative locations further away from these environmentally sensitive areas would include excessive piping and/or pumping that would deem the project financially unfeasible. Thus, it was determined that the Proposed Action is the only cost effective option that would accomplish the goals of the project and would have the least environmental impacts of the alternatives evaluated.
3.0 AFFECTED ENVIRONMENT 3.1 Introduction This chapter presents the potentially affected existing environment (i.e., the physical, biological, social, and economic values and resources) of the impact area as identified in the Interdisciplinary Team Analysis Record Checklist (BLM ID checklist) found in Appendix A and presented in Chapter 1 of this assessment. This chapter provides the baseline for comparison of impacts/consequences described in Chapter 4.
Resources that do not exist within the project area and/or are present, but not affected by the Proposed Action to a degree that detailed analysis is required, were not carried forward for analysis (Appendix A). These resources, presented in Chapter 1.7.1, have been eliminated from detailed analysis in this EA consistent with 40 CFR 1500.4.
3.2 General Setting The proposed ROW is located approximately four miles south of the town of Gunlock in Washington County. Washington County is located at the junction between three major physiographic provinces: the Colorado Plateau, the Great Basin, and the Mojave Desert. The region’s landscape characteristics are highly variable, creating a rich biological diversity that is rather uncommon in the arid Intermountain West. Average annual precipitation in Gunlock is 14.6 inches (TWC 2016). The average annual maximum temperature in Gunlock ranges from 55° F to 101° F, and the average annual minimum temperature ranges from 29° F to 68° F (TWC 2016). The area of the proposed ROW is at an elevation of approximately 3,360-3,520 feet. The unique blend of geologic landforms creates varying landscapes, open vistas, and spectacular scenery within the county.
Gunlock Arsenic Treatment Plant page 17 Environmental Assessment
The proposed project area is located near the western edge of the Beaver Dam Range physiographic section of the Basin and Range-Colorado Plateau Region subdivision of southwestern Utah (Stokes 1987) at an elevation of approximately 3,360-3,520 feet above sea level. Vegetation in and around the area is transitional between the Lower Sonoran vegetation life zone and Upper Sonoran vegetation life zone covering both the Pinyon-Juniper Community and Blackbrush Community. The surface geology of the proposed project area consists of Lower Jurassic, Holocene to middle Pleistocene, Holocene to upper Pleistocene, and Holocene aged deposits within five units. Soils in the area consist of fine reddish-tan Aeolian sands with numerous river cobbles composed of sandstone, basalt, and quartzite along bench slopes. Sandstone outcrops are also present in areas as are basalt boulders along the edges of the Red Mountains.
3.3 Resources Brought Forward for Analysis These elements and resources have been determined to be potentially impacted by this project.
3.3.1. Water Resources/Quality (drinking/surface/ground) Current EPA standards outlined in the “Arsenic and Clarifications to Compliance and New Source Monitoring Rule” restrict amounts of arsenic in drinking water. The Proposed Action is put forth to treat the water and meet current requirements. Also, construction of the site will alter the natural surface conditions which will potentially disturb the natural surface water quality.
3.3.2. Cultural Resources In compliance with “The National Historic Preservation Act of 1966 (54 USC 300101)” a cultural resource inventory was completed as part of the evaluation of the Area of Potential Effect (APE) for the project. This included a file search for previous projects and documented sites within a 1 mile radius of the area. This was followed by a field examination of the proposed project area that resulted in the identification and documentation of three new cultural sites (42WS6114, 42WS6115, 42WS6129) and updated recordings on three previously recorded cultural sites (42WS1698, 42WS1699, 42WS1963/42WS5280).
Site 42WS6114 was newly recorded and represents two abandoned segments of the county road to Gunlock that are related to realignments of a curve in the county road. Segment 1 dates from at least the 1930s while Segment 2 dates from at least the 1950s and remained in use until the 1980s. The road represents an important transportation corridor utilized during early-mid 20th century, with significant ramifications for the settlement and history of the area as they served as part of the main transportation corridor to the south of Gunlock. Improvements to the road were also completed by the CCC. As such, Segment 1 of the site is recommended eligible for the NRHP under Criterion A while Segment 2 is recommended non-significant and not eligible. (Gourley 2016).
Gunlock Arsenic Treatment Plant page 18 Environmental Assessment
Site 42WS6115 was newly recorded and represents two historic telephone pole locations related to the “Telephone Line St. George to Gunlock”. The phone line is depicted on the GLO map of the area dating from 1912 and was abandoned by 1950. The line served as an important communication link between the communities of St. George and Gunlock, as well as other small settlements in the area stretching from Moapa, Nevada to Enterprise, Utah. As such, it has been recommended eligible for the NRHP under Criterion A (Gourley 2016).
Site 42WS6129 was newly recorded and consists of a small aboriginal open habitation of Virgin Anasazi Pueblo II-III cultural affiliation and historic trash scatter dating from the early- mid 20th century. The site has the potential to provide additional information important to understanding the prehistory of the area and therefore has been determined eligible for the NRHP under Criterion D (Gourley 2016).
Site 42WS1698 was originally documented by the BLM in 1983 as the remains of what was likely a small aboriginal open habitation of Virgin Anasazi Pueblo II-III cultural affiliation. The site was revisited in 2016 and was found to be consistent as previously described. However, the documentation was updated due to additional prehistoric material and an isolated historic artifact dating from the mid-20th century. The site has the potential to provide additional information important to understanding the prehistory of the area and therefore has been determined eligible for the NRHP under Criterion D (Gourley 2016).
Site 42WS1699 was originally documented by the BLM in 1983 as a small aboriginal open habitation of Virgin Anasazi Pueblo II-III cultural affiliation. The site was revisited in 2016 and its documentation was updated. The site has the potential to provide additional information important to understanding the prehistory of the area and therefore has been determined eligible for the NRHP under Criterion D (Gourley 2016).
The area surrounding the proposed action, and noted within the Class I, also included five historic properties containing rock art that encompassed 42WS42, 42WS1695, 42WS1963, 42WS1707, and 42WS1709. Site 42WS42 is a grouping of petroglyphs on a basalt boulder just below a small rock shelter. Site 42WS1695 is a small aboriginal open habitation of Virgin Anasazi Pueblo II cultural affiliation. Rock art panels on the site are located on basalt boulders overlooking the Santa Clara River. Site 42WS1963 is a small aboriginal open campsite of undetermined age and cultural affiliation. Rock art panels on the site are present on the southern end of an exposed sandstone formation. Site 42WS1707 is a small prehistoric open village with rock art panels of Virgin Anasazi Pueblo II cultural affiliation. Site 42WS1709 is a small aboriginal rock art panel of undetermined age and cultural affiliation.
As a result of these findings, both the pipeline and treatment plant facilities were redesigned to avoid all historic properties and visual impacts with the exception of one section of site
Gunlock Arsenic Treatment Plant page 19 Environmental Assessment
42WS6114. Redesigning of the treatment plant resulted in avoidance of sites 42WS1698, 42WS1699, and 42WS6129, while a proposed section of pipeline that was to extend to the west and across the Santa Clara River was dropped to avoid impacts to sites 42WS1963/5280 and 42WS6115.
As cultural sites and rock art panels are present within one mile of the treatment facility, visual effects will be minimal. This will be completed by taking measures, including painting the structure a Beatle Green color that matches the surrounding juniper vegetation, to minimize effects for sites 42WS42, 42WS1707, and 42WS1709.
Documentation resulting from the field inventory, which included a Cultural Resource Inventory report and new site form documentation, was submitted to, and reviewed by, the BLM. After review, the BLM will make determinations regarding site eligibility and effects to historic properties. BLM will then consult with Tribes and the Utah Rock Art Research Association, after which time the report will be sent to SHPO and reviewed before the EA is finalized.
3.3.3. Soils The Proposed Action has the potential to disturb 8.5 acres of soil that would be excavated, compacted and graded during construction. Soils in the project area are designated RO and SY, which correspond to Rock Land and Stony Colluvial Land, for which properties of these soil types are highly variable. In the short-term, during and immediately following construction, erosion and sedimentation may increase.
3.3.4. Fish and Wildlife Resources (excluding USFWS Designated Species) The following BLM Sensitive wildlife species may occur in the proposed project area depending on season and time of day: Arizona toad (permanent resident, fairly common), bald eagle (winter visitor, fairly common), burrowing owl (permanent resident, uncommon), ferruginous hawk (permanent resident, fairly common), Lewis’s woodpecker (permanent resident, rare), Northern goshawk (permanent resident, rare), short-eared owl (transient, rare), big free-tailed bat (summer resident, rare), fringed myotis (permanent resident, rare), kit fox (permanent resident, uncommon), spotted bat (permanent resident, rare), Townsend’s big- eared bat (permanent resident, fairly common), Western red bat (permanent resident, extremely rare), Desert sucker (permanent resident, fairly common), Virgin spinedace (permanent resident, fairly common), common chuckwalla (permanent resident, uncommon), Gila monster (permanent resident, rare), sidewinder (permanent resident, fairly common), Western banded gecko (permanent resident, uncommon), Western threadsnake (permanent resident, rare), and zebra-tailed lizard (permanent resident, fairly common).
Gunlock Arsenic Treatment Plant page 20 Environmental Assessment
General wildlife occurring in the project area include: badger, antelope ground squirrels, kangaroo rats, deer mice, desert wood rats, Gambel’s quail, mourning doves, common ravens, wrens, house finches, side-blotched lizards, and Western whiptails. Also, larger animals such as raptors, coyotes, gray fox, and mule deer may pass through the area (Appendix A).
Field studies conducted during the fall of 2015, winter and spring of 2016, and spring 2017 within the proposed project area, noted the presence (through observation or sign) of the following species: ferruginous hawk, sidewinder, zebra-tailed lizard, antelope ground squirrels, deer mice, Gambel’s quail, mourning doves, house finches and common ravens. Under the Proposed Action, the pipeline is running along the Gunlock road and not crossing the Santa Clara River as was originally described in the Plan of Development that was reviewed for resource impacts. As a result, the Santa Clara River was not surveyed for aquatic species as no impacts to the river or riparian area are expected.
The Proposed Action will result in the permanent loss of approximately 5.9 acres of general terrestrial habitat for wildlife in the area.
3.3.5. Migratory Birds Migratory bird species (e.g., raptors, songbirds, and shorebirds) are protected under the Migratory Bird Treaty Act (MBTA) of 1918, Executive Order 13186, and the Bald and Golden Eagle Protection Act (BGEPA). The MBTA protects species or families of birds that live, reproduce, or migrate within or across international borders during their life cycle. Under authority of the MBTA, it is unlawful to take, kill, or possess migratory birds, their parts, nests, or eggs—including the disturbance or destruction of a migratory bird nest that results in the loss of eggs or young. Executive Order 13186 was enacted, in part, to ensure that environmental analyses of federal actions evaluate the impacts of actions and agency plans on migratory birds. It also states that emphasis should be placed on species of concern, priority habitats, and key risk factors and it prohibits the take of any migratory bird without authorization from the USFWS. The BGEPA makes it illegal to take (e.g., disturb, molest), possess, sell, purchase, barter, or transport any Bald or Golden eagle, alive or dead, or any part, nest, or egg thereof.
The decline of Neotropical migratory birds (NTMBs; i.e., landbirds that breed north of Mexico and then migrate to Mexico, Central and South America, and the Caribbean) in North America is well documented. Partners in Flight (PIF) is a cooperative partnership program involving Federal and State Governmental agencies (e.g., BLM, USFWS, Utah Division of Wildlife Resources; UDWR) that focuses on the conservation of migratory birds (e.g., NTMBs) and maintains a PIF High-Priority Bird Species list. The USFWS maintains a list of Birds of Conservation Concern for each Bird Conservation Region in the United States. Washington
Gunlock Arsenic Treatment Plant page 21 Environmental Assessment
County is in USFWS Bird Conservation Region 6, the Mountain-Prairie Region. In cooperation with the UDWR, Utah-BLM maintains an avian Sensitive Species list, which can be viewed at http://dwrcdc.nr.utah.gov/ucdc/ ViewReports/SS_List.pdf.
The BLM provided the applicant a list of birds found in Washington County that were protected by the MBTA. The list was compiled in 2007 by Rick Fridell (Utah Division of Wildlife Resources) and Kristen Comella (Utah Division of Parks and Recreation). The list contains over 350 birds, many of which are known to frequent the Proposed Project area. It is estimated that the Proposed Project would potentially result in the permanent loss of 5.9 acres of general terrestrial habitat for birds. However, since adjacent habitat is similar to the habitat within the project area, it is likely that any wildlife impacted by construction and/or operation of the proposed project will relocate to these adjacent habitats.
3.3.6. Visual Resources The project area would occur within areas designated as Visual Resource Management (VRM) Class III. To ensure that the Proposed Action meets Class III Objectives, a Visual Contrast Rating was performed by the BLM St. George Field Office (Appendix D). The Key Observation Points (KOP) chosen to complete the rating was taken along the fronting highway. The Class III Objectives are to partially retain the existing character of the landscape, including: (1) The level of change to the landscape can be moderate; (2) Management activities may attract attention, but should not dominate the view of the casual observer and; (3) Any changes should repeat the basic elements found in the natural landscape-form, line, color, and texture (Appendix A).
Figures 3-1 and 3-2 show a view of the proposed building and access road as viewed from the fronting Gunlock Road. The Key Observation Point (KOP) (Travel Route) in Figure 3-1 is along Gunlock Road where the proposed access road is shown in relation to the proposed building. The KOP (Travel Route) in Figure 3-2 is along Gunlock Road perpendicular from the proposed building to the road.
As presented in Appendix D, the BLM concluded that the structure as designed and portrayed in the visual simulation meets Visual Resource Management objectives for Class III, which is the designation for this site and the entire surrounding landscape. This conclusion is dependent on the correct application of the following mitigation measure: all vertical structures should be painted Beetle Green as shown on the BLM Standard Environmental Colors Chart CC-001.
Gunlock Arsenic Treatment Plant page 22 Environmental Assessment
Figure 3-1 Existing view (upper) of proposed project from Gunlock Road (Travel Route KOP)
Figure 3-2 Existing view (lower) of proposed project from Gunlock Road (Travel Route KOP) 3.3.7. National Historic Trails (Old Spanish Trail) In December of 2002 the Old Spanish Trail became the 15th designated National Historic Trail by the U.S. Congress. In doing so, Congress placed the Old Spanish Trail under the purview of the National Trail System Act (NTSA). Currently, both the BLM and National Parks Service (NPS) jointly administer the Old Spanish Trail routes located on federal lands and as such require a visual Impacts assessment be conducted where the legislatively depicted routes occur. The legislatively-depicted route of the Old Spanish Trail National Historic Trail (Northern Route) is believed to follow the west side of the Santa Clara River, approximately ¼ mile to the west of the Proposed Arsenic Treatment Plant (Appendix A).
Gunlock Arsenic Treatment Plant page 23 Environmental Assessment
4.0 ENVIRONMENTAL IMPACTS 4.1 Introduction This section describes the existing environment of the proposed project area that would affected by the No Action Alternative or the Proposed Action, and discloses the potential impacts of these alternatives. The issues and resources analyzed are discussed, including analysis assumptions and guidelines to assist in defining the limits of analysis. A summary of the issues and resources analyzed include:
Water Resources/Quality (drinking/surface/ground) Cultural Resources Soils Fish and Wildlife Resources Migratory Birds Visual Resources National Historic Trails
4.2 General Analysis Assumptions and Guidelines Environmental data collected on the tract has been used to describe the affected environment and to predict environmental effects that could result from the Proposed Action or the No Action Alternative. A level of uncertainty is associated with any dataset when predicting outcomes, especially when natural systems are involved. The predictions described in this analysis are intended to allow comparison of alternatives while providing a method to determine whether activities proposed by the applicant would be expected to comply with applicable federal, state, and local regulations. The analyses of impacts have been quantified to the extent possible and are based on available data through coordination with the different agencies and through site observation. As more detailed design of the treatment plant is completed and in the event that additional information is discovered, coordination with the necessary agencies will be completed to maintain compliance with applicable regulations.
4.3 Direct and Indirect Impacts This chapter describes the potential environmental consequences to the affected environment described in Chapter 3 from implementing the Proposed and No Action alternatives described in Chapter 2. Environmental consequences are described using the terms “effect” and “impact,” which are synonymous under NEPA. Effects may be direct, indirect, or cumulative in nature.
• Direct effects occur at the same time and place as the action.
• Indirect effects are reasonable foreseeable effects that occur later in time or are removed in distance from the action.
Gunlock Arsenic Treatment Plant page 24 Environmental Assessment
• Cumulative effects are those impacts to the environment that result from the incremental impacts of an alternative when added to other past, present, and reasonably foreseeable future actions.
NEPA also requires that effects be discussed in terms of context and intensity. In this EA, context refers to the location, type, or size of the area to be affected and intensity refers to the severity or level of magnitude of impact. In this EA, the intensity of effects are defined as Major, Moderate, Minor, or Negligible. In addition, the duration of effects can be temporary, short-term, or long- term. These terms are described more specifically in Table 4-1.
Table 4-1 Terms Used to Describe the Environmental Effects Attribute of Effect Description Magnitude (Intensity) Negligible No measurable change in current conditions. Minor A small, but measurable change in current conditions. Moderate A moderate, measurable change in current conditions. Major A big, easily measurable change in current conditions. Duration Temporary Short-lived (i.e., during construction) Short-term 10 years or less Long-term More than 10 years
4.3.1. Alternative A – Proposed Action 4.3.1.1. Water Resources/Quality (drinking/surface/ground) Direct Effects As current levels of arsenic in water coming from the Gunlock Well Field exceed the MCL and pursuant to the EPA’s “Arsenic and Clarifications to Compliance and New Source Monitoring Rule”, construction and operation of the Proposed Action would bring the arsenic MCL to less than 10 ppb.
Construction of the treatment plant and surrounding site will alter ground cover conditions for the majority of the 9.3 acre site. The building creates an impervious cover that will generate additional runoff. This impervious area is not directly connected with any drainage features and the overall increase in runoff will be negated by the surrounding pervious area.
Indirect Effects Implementation of the Proposed Action would have no indirect effects on water resources or quality.
Ground Water
Gunlock Arsenic Treatment Plant page 25 Environmental Assessment
The Proposed Action will treat water after it is pumped from the Gunlock Well Fields. There would be negligible direct or indirect impacts to ground water.
4.3.1.2. Cultural Resources Project implementation affects an historic property, or sites determined eligible for the NRHP, if it alters any characteristic that qualifies it for NRHP inclusion. As outlined in 36 CFR 800.5, factors considered in determining whether the project would have adverse cultural resource impacts include the extent or degree to which its implementation would result in:
1) Damage to, or loss of, a site of archaeological, Tribal, or historical value that is listed, or eligible for listing, in the NRHP.
2) Loss or degradation of a traditional cultural property or sacred site, or if the property or site is made inaccessible for future use.
3) Disturbance to any human remains, including those interred outside formal cemeteries
4) Isolation of cultural resources from the context considered significant.
5) An effect to project elements that would be out of character with the property or site and its setting.
6) Visual effects that could diminish the property’s integrity and negatively affect its historic significance and hence its eligibility for listing in the NRHP.
Direct Effects
As a result of the cultural resource literature review, and survey, one historic property has been identified within the redesigned project area. The single site identified within the project area, 42WS6114, or a segment of an historic road that qualifies as a historic property (Gourley 2016). Construction of the project will impact this historic property with a new water pipeline crossing. Sites 42WS1698, 42WS1699, and 42WS6129 have been avoided by careful design of the treatment plant facility. Barricading and cultural monitoring of these historic properties will be completed to ensure no adverse effects during construction activities. In the unlikely event that additional archaeological or historic materials and/or features are encountered during project construction, all activities in the immediate vicinity should cease and a representative of the BLM should be contacted within 24 hours of the inadvertent discovery to evaluate the find as outlined in 36 CFR § 800.13, followed up with recommendations of procedure. Sites 42WS1963/5280 and 42WS6115 have been avoided by dropping the proposed pipeline crossing to the west.
Gunlock Arsenic Treatment Plant page 26 Environmental Assessment
Indirect Effects
Indirect effects to historic properties adjacent to the project area include the potential for an increase by visitors that could cause damage to sites. The potential for increased visitation to these sites is to be offset by a chain link fence that is to be installed around the new treatment plant facility that will discourage city workers and others visiting the facility from wandering onto the sites. Additionally, as previously mentioned, visual effects to rock art panels present within one mile of the treatment facility would be minimized by painting the plant facility a Beatle Green color that matches the surrounding juniper vegetation.
4.3.1.3. Soils Direct Effects
The Proposed Action will result in the permanent loss of 5.9 acres of habitat that would be excavated, compacted and graded during construction. During construction and in the short- term immediately following construction, soil would be disturbed and possibly lost from the site due to wind and water erosion. BLM BMPs (Appendix C) would be employed to minimize the potential impacts from erosion and sedimentation. Slopes would be kept to a reasonable grade to reduce water erosion, and during construction, soil at the site would be kept moist to reduce wind erosion.
All areas subject to temporary ground disturbance would be restored to original contours to the extent determined by the BLM. Temporarily disturbed areas (approximately 3.4 acres) would be seeded using a certified weed-free seed mix approved by the BLM. Seed would be hand broadcasted and lightly covered with soil by hand using a rake or by pulling a chain-link fence with an all-terrain vehicle. All soil removed during construction would be reused. Vegetation removal would be kept to that necessary to install the treatment plant and waterline. Any brush removed during construction would be used as mulch after reclamation activities. Over the long-term the soil would return to pre-project condition once vegetation is established. A total of approximately 5.9 acres of previously partially disturbed soil would be permanently removed from production.
There will be direct impacts to 5.9 acres of soil that will be permanently disturbed during construction of the water treatment facility and the access road to it. Much of this area has already been disturbed by vehicular access. Potentially 3.4 acres of soil will be temporarily disturbed during construction however, these areas will be restored to pre-project conditions as described above.
Gunlock Arsenic Treatment Plant page 27 Environmental Assessment
Indirect Effects
Implementation of the Proposed Action would have long-term and negligible indirect impacts on soils.
4.3.1.4. Fish and Wildlife Resources (excluding USFWS Designated Species) Direct Effects Construction of the project would result in the permanent loss of 5.9 acres and temporarily disturb approximately 3.4 acres of wildlife habitat, portions of which are already disturbed by vehicular traffic. Minimal direct impacts to some small, less mobile individuals (e.g., lizards, rodents, etc.) would likely occur as they could be forced to disperse from the immediate area due to noise and human presence or may be killed or injured during construction activities. Large and/or more mobile wildlife, including birds, predators, and deer, in the area would likely be displaced temporarily from Project and adjacent areas into nearby, suitable habitat. Overall, wildlife populations, including some Sensitive species, may be affected on a short term basis. Once construction activities are complete, wildlife could return to the areas that were only temporarily disturbed during construction. Short-term disturbance-related impacts would be negligible and would last only as long as construction activities are being conducted. Long-term there would only be a permanent loss of approximately 5.9 acres of wildlife habitat, including that for some Sensitive species, adjacent to the Santa Clara River. Given the size of the project in comparison to the amount of adjacent similar and suitable habitat, and that most individuals would make way for construction equipment, potential direct impacts to wildlife, including some Sensitive species, would be negligible.
Indirect Effects
Future plant activity could impact wildlife, including some Sensitive species, in the ways described above for construction, but to a much lesser extent. Indirect impacts would be long term and negligible. In order to minimize these indirect impacts, a source water pollution protection plan (SWPPP) will be developed to prevent erosion of sediment from the site. The SWPPP will include erosion/sediment runoff BMP measures during construction and operation of the project.
Fish
The project does not involve any work in live water. There would be negligible direct or indirect impacts to fish. To prevent any possibility during construction of erosion/sediment runoff crossing the road and entering the Santa Clara River, a SWPPP (described above) will be developed.
Gunlock Arsenic Treatment Plant page 28 Environmental Assessment
4.3.1.5. Migratory Birds Direct Effects Biological surveys were conducted by the project biologist during fall 2015, spring 2016, summer 2016 and spring 2017 to determine presence of wildlife, including migratory birds. No migratory bird nests were observed within or adjacent to the treatment plant site. Very few trees that would provide ideal habitat for nests are located within the project site. Most of the nesting habitat occurs along the riparian zone of the Santa Clara River. Some areas in the rock cliffs above the project site could provide nesting habitat for some species of migratory birds, however, none were observed above the treatment plant site during the surveys conducted in 2015 through 2017. Also, no raptors or nests were observed within the project area during the surveys. Large quantities of raptor habitat for nesting, roosting and foraging exists in the cliff areas above and below the project site. Any raptors that may use the cliffs above the project site during construction could relocate to these adjacent habitats. Since operation of the project is unlikely to impact any raptors, they would be able to utilize the cliffs above the project to carry out life cycle requirements post construction. Various songbird species were noted in the pinion–juniper trees within the project site. Numerous migratory birds were observed during the surveys (and at other times) flying over the project site. These include various species of songbirds, hawks, gulls, geese, waterfowl and bats. Most of the geese, gulls and other waterfowl were flying to and from Gunlock Reservoir. Several species of waterfowl were observed in the Santa Clara River, especially upstream of the project site.
The Proposed Action may have minor short-term direct effects to migratory birds. Potential direct effects would include 5.9 acres of permanent habitat loss and short-term disturbance related to noise and human presence during construction. Migratory birds, including raptors, would give way to construction equipment and would avoid being killed or injured. During project construction, small birds may be disturbed and their nests destroyed causing short-term impacts; but not effecting local populations over the long-term. During construction, larger birds (such as raptors) may be disturbed and/or displaced to adjacent habitats causing short- term impacts; but birds should return to the general area once construction activities cease. The construction and operation of the treatment plant should have little to no impact to bird species foraging along the Santa Clara River. There is the potential for indirect construction noise to disturb and cause some migratory birds to move to foraging habitat up or downstream. However, these species should return once construction activities cease.
Gunlock Arsenic Treatment Plant page 29 Environmental Assessment
Indirect Effects
Potential indirect effects to migratory birds, including raptors, would be temporary relocation during construction activities. Similar and suitable nesting and foraging habitat is available in the area adjacent to the proposed project. Potential indirect impacts would not be long term and likely negligible.
4.3.1.6. Visual Resources Direct Effects The form, line, color, and texture of the Proposed Action would contrast slightly with the characteristic visual landscape. The most noticeable contrast would be the building and site fencing. Form, line, color and texture will be designed to blend into the surrounding landscape. These elements may attract attention, but would not dominate the landscape.
The Proposed Action would not exceed the VRM Class III objective of moderate change and partial retention of the characteristic landscape (Appendix D, Visual Contrast Rating Worksheet).
Overall impacts to visual resources would be short-term reductions in scenic quality from construction-related surface disturbances, vegetation removal along the ROW, construction vehicles, and construction infrastructure. Following construction, temporarily disturbed areas would be reseeded. Long-term visual impacts would be related to the treatment plant site and would be minor.
Indirect Effects Implementation of the Proposed Action would have no indirect effects on visual resources.
4.3.1.7. National Historic Trails (Old Spanish Trail) Direct Effects Under the Proposed Action, the pipeline is running along the Gunlock road and not crossing the Santa Clara River as was originally described in the Plan of Development (Appendix B) that was reviewed for resource impacts. The legislative-depicted route of the Old Spanish Trail (Northern route) follows the west side of the Santa Clara River, approximately ¼ mile to the west of the proposed project facilities (Appendix A). Two photographs were taken. The picture shown in Figure 4.1 is taken from the West side of the Santa Clara River looking towards the project site. Figure 4.2 is taken approximately 30 feet up on the hillside above the project site looking towards the Santa Clara River.
Gunlock Arsenic Treatment Plant page 30 Environmental Assessment
Figure 4.1 Existing view of proposed project site due west of site from West side of Santa Clara River
Figure 4.2 Existing view approximately 30 feet above project site looking Northeast towards Santa Clara River
From these observation points it is apparent that the project site will not be visible from the where the Old Spanish Trail is believed to have run through the area. Though no visible trail
Gunlock Arsenic Treatment Plant page 31 Environmental Assessment
remains at these observation points, the vertical bank on the East side of the Santa Clara River prohibits viewing the project site from the approximate, legislatively-depicted, trail location. Only the hillside above the project site can be seen. The same is true looking from a vantage point above the project site that is higher than the tallest structure anticipated for the project and looking back towards the river.
Indirect Effects Implementation of the Proposed Action would have negligible indirect effects on national historic trails.
4.3.1.8. Monitoring and/or Compliance Monitoring and/or compliance with NEPA actions would be completed for the project. Compliance will evaluate the quality of the actions outlined in this EA, and monitoring will be performed to ensure compliance and successful application of the stipulations. All issues and resources identified in Chapter 3 will be monitored regularly as they are impacted by the construction and operation of the proposed project. The monitoring will be conducted by the owner and aided by the BLM.
4.3.2. Alternative B – No Action 4.3.2.1. Water Resources/Quality (drinking/surface/ground) Under the No Action Alternative there would be no effects to water resources or quality. The proposed ROW would not be granted and the treatment plant would not be constructed. Water from the Gunlock Well Field would continue to be noncompliant with EPA standards.
4.3.2.2. Cultural Resources Under the No Action Alternative, there would be no foreseeable impacts to cultural resources. The proposed ROW would not be granted and the treatment plant would not be constructed.
4.3.2.3. Soils Under the No Action Alternative there would be no adverse effects to soil, erosion and sedimentation. Soil erosion from water, wind and recreational activities would continue in the area at the current rate. The proposed ROW would not be granted and the treatment plant would not be constructed.
4.3.2.4. Fish and Wildlife Resources (excluding USFWS Designated Species) Wildlife habitat would remain in its current condition experiencing no predictable gains or losses from the No Action Alternative. The proposed ROW would not be granted and the treatment plant would not be constructed.
Gunlock Arsenic Treatment Plant page 32 Environmental Assessment
4.3.2.5. Migratory Birds The No Action Alternative would have no impact on migratory birds in the area. The proposed ROW would not be granted and the treatment plant would not be constructed.
4.3.2.6. Visual Resources There would be no impacts on the visual resources within the project area. The proposed ROW would not be granted and the treatment plant would not be constructed.
4.3.2.7. National Historic Trails (Old Spanish Trail) Under the No Action Alternative there would be no impacts to the National Historic Trails (Old Spanish Trail). The proposed ROW would not be granted and the treatment plant would not be constructed.
4.4 Cumulative Impacts Analysis As defined in 40 CFR 1508.7 (CEQ regulations for implementing NEPA), cumulative impacts on the environment result from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions (RFFAs), regardless of which agency (federal or non- federal) or person undertakes such other actions. The cumulative impact area considered in this analysis includes the immediate construction area needed to construct the proposed treatment plant site and new pipelines, and where applicable, any areas within the view shed.
4.4.1. Past and Present Actions As the project is located near the Santa Clara River, flooding of the river has occurred historically affecting some or all of the same environmental resources as the proposed and alternative actions would affect. Additionally, the construction and use of the adjacent highway would be considered to have affected some or all of the same environmental resources.
4.4.2. Reasonably Foreseeable Action Scenario (RFAS) The applicant is unaware of any planned or proposed projects that would affect the same environmental resources as the proposed action. However, there is potential for future flooding and/or consequential improvements to the natural Santa Clara River channel. Additionally, the adjacent highway may undergo improvements to maintain or improve its level of service. These items could potentially affect the some or all of the same environmental resources as the proposed and alternative actions would affect.
4.4.3. Cumulative Impacts It has been determined that cumulative impacts would be negligible as a result of the proposed action or alternatives because such cumulative impacts and actions occur naturally or the interaction and nature of such actions are unforeseeable.
Gunlock Arsenic Treatment Plant page 33 Environmental Assessment
4.4.3.1. Water Resources/Quality (drinking/surface/ground) There would be no additional affects to water resources or quality due to cumulative impacts as there are no other foreseeable actions in the vicinity of the proposed project site.
4.4.3.2. Cultural Resources There will be no cumulative impacts to cultural resources from past, present, and reasonably foreseeable future actions. The potential for increased visitation is to be offset by a chain link fence that is to be installed around the new treatment plant facility that will discourage city workers and others visiting the area from wandering onto the sites. The presence of the facility will also reduce site visitation by campers on BLM land that is currently occurring.
4.4.3.3. Soils There would be no additional affects to soils due to cumulative impacts as there are no other foreseeable actions in the vicinity of the proposed project site from the past, or present and reasonably foreseeable future.
4.4.3.4. Fish and Wildlife Resources (excluding USFWS Designated Species) There would be no additional affects to fish and wildlife resources due to cumulative impacts as there are no other foreseeable actions in the vicinity of the proposed action.
4.4.3.5. Migratory Birds There would be no additional affects to migratory birds due to cumulative impacts as there are no other foreseeable actions in the vicinity of the proposed project site from the past or present and reasonably foreseeable future.
4.4.3.6. Visual Resources There would be no additional affects to visual resources due to cumulative impacts as there are no other foreseeable actions in the vicinity of the proposed action.
4.4.3.7. National Historic Trails (Old Spanish Trail) There would be no additional affects to National Historic Trails due to cumulative impacts as there are no other foreseeable actions in the vicinity of the proposed action.
5.0 CONSULTATION AND COORDINATION
5.1 Introduction The issue identification section of Chapter 1 identifies those issues analyzed in detail in Chapter 4. Appendix A provides the rationale for issues that were considered but not analyzed further. The
Gunlock Arsenic Treatment Plant page 34 Environmental Assessment issues were identified through the public and agency involvement process described in sections 5.2 and 5.3 below.
BLM’s Public involvement process presents the public and agencies with opportunities to obtain information about a given project and allows interested parties to participate in the project through written comments. The key objective is to create and maintain a well-informed, active public that assists decision makers throughout the process, culminating in the implementation of an alternative. This section of the EA discusses agency public involvement activities undertaken to date for the proposed action.
The applicant and their consultants have met with the BLM on numerous occasions both at their St. George Field Office and at the proposed project site. The BLM has provided the applicant with scoping comments.
5.2 Persons, Groups, and Agencies Consulted Table 5-1 reflects the entities that were consulted in preparation of this EA.
Table 5-1: List of all Persons, Agencies and Organizations Consulted for Purposes of this EA Person, Agency, or Organization Reason City of St. George Applicant US Bureau of Land Management Right-of-Way Acquisition Coordination with historic properties, Plan approval of State Historic Preservation Office treatment system Washington County Water Coordination with regional water supply system Conservancy District Utah State Division of Drinking Water Plan approval of treatment system Shivwits Band of the Paiute Indian Plan approval of treatment system Tribe Old Spanish Trail Association Plan approval of treatment system
National Park Service Plan approval of treatment system
5.3 Summary of Public Participation Will be added after public comment period.
5.3.1. Comment Analysis If applicable
Gunlock Arsenic Treatment Plant page 35 Environmental Assessment
5.3.2. List of Commenters If applicable
5.3.3. Response to Public Comment If applicable
5.4 List of Preparers Table 5-2 provides a list of the consultants and agency representatives who participated in the preparation of the EA.
Table 5-2: List of Staff Used in the Preparation of this EA Name Title/Position Role BLM Natural Resource Specialist, Dave Corry Air Quality, Soils, Water BLM, St. George Outdoor Recreation Planner David Kiel Recreation and Visual Resources BLM, St. George Outdoor Recreation Planner, Paleontology, Geology, Visual Kyle Voyles BLM, St. George Resources Cultural and Native American Lori Hunsaker Archaeologist, BLM Religious Concerns Document Review, Old Spanish Dawna Ferris-Rowley NCA Manager, BLM, St. George Trail Realty Specialist, BLM, St. Project Lead Teresa Burke George Document Review Wildlife Biologist, BLM, St. John Kellam Document Review George; NEPA coordinator. Wildlife Biologist, St. George Robert Douglas Wildlife Resources Field Office, BLM Non-BLM Scott Taylor City of St. George Applicant Kade Bringhurst Project Engineer, Alpha Brent E. Gardner, P.E. Project Manager Engineering, Inc. EA Preparation Terry J. Hickman Biological Consulting Biological Field Surveys Archaeologist, Cultural Resource Dale Gourley Cultural Resources Consulting. Bighorn Archaeology Archaeologist, Cultural Resource Aaron Jordan Consulting. Bighorn Cultural Resources Archaeological Consultants, LLC
Gunlock Arsenic Treatment Plant page 36 Environmental Assessment
6.0 REFERENCES, GLOSSARY AND ACRONYMS 6.1 References Cited Alder, Douglas D., and Karl F. Brooks.1996. A History of Washington County. Utah Centennial county History Series. Utah State Historical Society, Salt Lake City, Utah.
Gourley, Dale R. 2016. A Cultural Resource Inventory of the Gunlock Arsenic Treatment Plant, Washington County, Utah. Bighorn Archaeological Consultants, LLC. Report No. 16-10. Prepared for the U.S. Bureau of Land Management, City of St. George and Alpha Engineering.
Stokes, William Lee. 1987. Geology of Utah. Occasional Paper No. 6 of the Utah Museum of Natural History. Utah Museum of Natural History and the Utah Geological and Mineral Survey, Department of Natural Resources, Salt Lake City, Utah.
The Weather Channel (TWC). 2016. Gunlock, Utah, Monthly Average Record Temperatures. Available at https://weather.com/weather/monthly/l/USUT0098:1:US. Accessed June 29, 2016.
U.S. Bureau of Land Management. 1999. Land Use Management Plan. St. George, Utah Field Office.
6.2 List of Acronyms Used in this EA ACEC Area of Critical Environmental Concern APE Area of Potential Effect BLM United States Bureau of Land Management DR Dimension Ratio (pipe durability rating) EPA United States Environmental Protection Agency EA/EIS Environmental Assessment/Environmental Impact Study FONSI Finding of No Significant Impact GATP Gunlock Arsenic Treatment Plant MCL Maximum Contaminant Level MGD Million Gallons per Day NEPA National Environmental Policy Act NRHP National Register of Historic Places ppb Parts per Billion RFAS Reasonably Foreseeable Action Scenario
Gunlock Arsenic Treatment Plant page 37 Environmental Assessment
RMP Resource Management Plan ROW Right-of-Way SGFO BLM St. George Field Office SHPO State Historic Preservation Office TCLP Toxic Characteristic Leaching Procedure WCWCD Washington County Water Conservancy District
Gunlock Arsenic Treatment Plant page 38 Environmental Assessment
APPENDIX A
INTERDISCIPLINARY TEAM CHECKLIST
Project Title: City of St. George Arsenic Treatment Plant UTU-91486
NEPA Log Number: DOl-BLM-UT-C030-2016-000l-EA
File/Serial Number: UTU-91486
Project Leader: Teresa Burke/Kendra Thomas
Project Description: The City of St. George is proposing to build an Arsenic Treatment Plant on BLM administered land south ofGunlock Reservoir. The treatment plant would treat water from 11 wells that are located on BLM land in the area and transport the treated water into the existing water transmission system. The plant is needed in order to comply with new EPA standards for maximum contamination levels. New facilities would include the treatment plant, drying beds, access roads and appurtenant waterlines. The City of St. George currently has 5 separate right-of ways for the 11 we11s and multiple pipelines and power Jines in this area. They would like to consolidate these rights-of-way under one grant which will be easier to administer. The new right-of-way for the treatment plant would encompass the existing facilities along with the proposed new facilities.
The Plan of Development for this project can be found at:
S:\SGFO\NEPA \Current Projects\Lands\City of St. George Arsenic Treatment Plant
DETERMINATION OF STAFF: (Clloose one oft/1e following abbreviated options for tile left column) NP = not present in the area impacted by the proposed or alternative actions NI= present, but not affected to a degree that detailed analysis is required Pl = present with potential for relevant impact that need to be analyzed in detail in the EA NC= (DNAs only) actions and impacts not changed from those disclosed in the existing NEPA documents cited in Section D ofthe DNA form. The Rationale column may include NI and NP discussions.
Determi- Resource Rationale for Determination* Signature Date nation
RESOURCES AND ISSUES CONSIDERED (INCLUDES SUPPLEMENTAL AUTHORITIES APPENDIX 1 H-1790-1) lfBLM BMPs identified in the POD are implemented the Air NI Air Quality Quality in the area should not be impacted by the proposed Dave Corry 10/29/ 15 action. Greenhouse Gas Greenhouse Gas Emissions should not be impacted by the NI Dave Corry I0/29/ 15 Emissions** tproposed action. Wastes rrhe Plan of Development (POD) addresses this issue. If NI Dave Corry I0/29/ 15 (hazardous or solid) closely followed this should not be an issue. The Santa Clara river is located just to the west ofthe project ~reatment plant, if BLM BMPs identified in the POD are implemented to control sediment and erosion; the chance that isediment, caused by the construction ofthe proposed Water Resources/Quality Pl reatment plant, would reach the Santa Clara river would be Dave Corry 10/29/15 (drinking/surface/ground) greatly reduced. However sediment resulting from the construction ofthe proposed new water transmission pipeline would access the Santa Clara River drainage and could impact the quality of water in the drainage.
The proposed Treatment Plant would be located within a 300 Areas of Critical foot wide designated utility corridor that bisects the Santa NI D. Kiel 11 /5/2015 Environmental Concern Clara-Gunlock ACEC. This 1,998 acre ACEC was administratively designated in 1999 to provide special Determi Resource Rationale for Determination* Signature Date nation
management attention to the riparian values ofthe Santa Clara River, habitat for native fish and other wildlife, and a high concentration of prehistoric archeological sites. K:onstruction and operation ofthe proposed Treatment Plant as described in the Plan of Development would not directly or indirectly impact the relevance and importance values ofthe IACEC. IA literature review was conducted ofthe CURES database tmaintained by the Utah State Historic Preservation Office and he cultural resource database maintained by the St. George Field Office to identify whether any National Register of !Historic Places eligible or listed sites (aka historic properties), [occur within the Area of Potential Effect (APE) for the proposed Treatment Plant. Prior Class Ill inventories conducted by BLM and others along the Santa Clara River overed the APE for this current project. The Treatment Plant Pl Cultural Resources APE will be fenced in order to avoid known cultural resource G. McEwen 11118/15 sites in the vicinity. A separate Class 111 inventory will need o be completed if any new road alignment/grading take place in the vicinity of Pump House #4. The proposed undertaking would have no effect on historic properties, if conducted as described in the Plan of Development. The Plan of Development (POD) addresses the procedures that would be followed should inadvertent discoveries of subsurface cultural deposits or human remains occur during construction activities. 'fhe proposed project will not limit access to or interfere with Native American ~he ceremonial use of any known native American sacred NI G. McEwen 11/18115 Religious Concerns sites or religious activities; nor, will it adversely affect the physical integrity ofany known such sites.
rrhere are no known or recorded paleontological sites in the nroje_ct_ar_ea...Ihe _nearestrecorded_paleo_resources_are2.3 tmiles to the west , 2.1 miles to the north and 2.9 miles to the NI Paleontology ~outh. These sites consist ofvertebrate microfossils, K. Voyles 12/3/15 Pentacrinus, and worm tubes. This project will have no ~egative impacts on any known paleontological resource and impacts on new localities will be minimal. Geology I Mineral rrhere are no mineral pits, resources or unique geologic Resources/Energy K. Voyles 12/3/15 features in or around the project area. Production !According to the EPA Region VIII, State of Utah, !Environmental Justice Map, the region has been categorized iiis a minority population area of I 0-20% and a poverty population area of I 0-20%. 5-10% of the population speaks English "Less than Well". This data shows that low income and high minority populations are generally located in the St. NI Environmental Justice George/Santa Clara/Washington areas in locations not D. Kiel 11/16/15 ~djacent to BLM managed lands. (see lhttp:l/epamap 14.epagov/ejmap/entry.html, 11/29/I2 ).
No disproportionately high or adverse health or environmental effects would result to minority or low income populations as a result of implementing the Proposed Action. There would be very little impact to the socio-economic NI Socio-Economics D. Kiel 11116/15 health of Washington County. What effects that may occur Determi Resource Rationale for Determination* Signature Date nation
~ould be positi~e via the contracting of outside sources to implement this project. The project would also expand the ~xisting water supply which would contribute to the long lterm economic health of the countv. Farmlands (Prime or NP D.Corry 10/29/15 Unique) According to the POD, approximately 23 acres ofsoil could possibly be disturbed during construction of the proposed Pl Soils D.Corry 10/29/15 action. Potential impacts on soils should be disclosed and analyzed in the EA.
NP Floodplains D.Corry 10/29/15
The treatment plant alone would not impact riparian values nowever the proposed transmission pipeline would impact Pl Wetlands/Riparian Zones D.Corry 10/29/15 riparian resources at locations where the pipeline crosses or contacts the Santa Clara River. rrhe following BLM Sensitive species may occur in the project area: Arizona toad (permanent resident, fairly ~ommon) , bald eagle (winter visitor, fairly common), ~urrowing owl (permanent resident, uncommon), ferruginous hawk (permanent resident, fairly common), Lewis's ~oodpecker (permanent resident, rare), Northern goshawk (permanent resident, rare), short-eared owl (transient, rare), big- free-tailed bat (summer resident, rare), fringed myotis (permanent resident, uncommon), kit fox (permanent resident, uncommon), spotted bat (permanent resident, rare), lrownsend's big-eared bat (permanent resident, fairly ~ommon) , Western red bat (permanent resident, extremely l"are), Desert sucker (permanent resident, fairly common), ~irgin spinedace (permanent resident, fairly common), ~ommon chuckwalla (permanent resident, uncommon), gila monster (permanent resident, rare), sidewinder (permanent 11 esident;-fairly-common)-;Western·banded-gecko-(permanenr resident, uncommon), Western threadsnake (permanent resident, rare) and zebra-tailed lizard (permanent resident, Fish and Wildlife fairly common). Desert suckers and Virgin spinedace both Pl Excluding USFW occur in the Santa Clara River and could potentially be B. Douglas 12/01115 Designated Species impacted during installation ofthe pipeline crossing the Santa tiara River. It's recommended that the pipeline be installed '1uring a period of low flow (late summer or early fall). It's tpossible that St. George City could coordinate with the Virgin River Program to reduce flows in the Santa Clara River for he short period required to install pipeline. The Santa Clara River below Gunlock Reservoir is considered Important Migratory Bird Habitat. For BLM Sensitive bird species, refer o the Migratory Bird section in this checklist. General wildlife found in the project area include: badgers, antelope ground squirrels, kangaroo rats, deer mice, desert wood rats, Gambel's quail, mourning doves, common ravens, wrens, house finches, side-blotched lizards, and Western whiptails. Infrequently, larger animals such as raptors, coyotes, gray fox, and mule deer may pass through the area. During project onstruction, small mammals, reptiles, and birds maybe disturbed and/or killed, and their nests, or dens destroyed ...ausing short-term impacts; but not effecting local populations over the long term. Also, during project construction, larger animals mavbe disturbed and/or displaced Determi- Resource Rationale for Determination* Signature Date nation
o adjacent habitats causing short-term impacts, but would return to the general area once disturbances cease. Once completed, the project will result in permanent loss of 15 acres general terrestrial habitat for BLM Sensitive species anc lgeneral wildlife in the area. ~list of birds (Protected by the Migratory Bird Treaty Act) found in Washington County is attached. During project construction, small birds maybe disturbed and/or killed, and ~heir nests destroyed causing short-term impacts; but not ~ffecting local populations over the long term. Also, during ~roject construction, larger birds (such as raptors) maybe k:listurbed and/or displaced to adjacent habitats causing short- Pl Migratory Birds ~erm impacts; but birds should return to the general area once B. Douglas 12/01/15 disturbances cease. Nesting generally occurs in the spring and ~ummer (March 1 to August 31) so construction outside this ~eriod would reduce impacts to birds during the initial K:onstruction phase. Once completed, the project would result in permanent loss of 15 acres general terrestrial habitat for birds. It's recommended that all power lines in the project be ··raotor safe". Threatened, Endangered !No threatened, endangered or candidate plant species are NP or Candidate Plant B. Douglas 12/01/15 Kllown to occur in the project area. Species In the past, the U.S. Fish and Wildlife Service have conducted telemetry studies on California condor movement here in Washington County and no "fly-over use" by California condors has been recorded near the project area. Presently, no nests, roosts, or other special use areas for ..ondor have been identified in the project area. The project area is considered unsuitable habitat for California condors. The likelihood ofCalifornia condors using the project area is extremely low do to the lack of suitable habitat. The proposed Threatened, Endangered action would have "no effect" on California condors. NP or Candidate Animal B. Douglas 12/01115 Species In the past, the Santa Clara River below Gunlock has provided some habitat opportunities for Southwestern willow flycatchers and Yellow-billed cuckoos. However, due to recent flooding along the Santa Clara River, habitat nesting "Onditions for these species is poor in the project area. Due to lack of nesting habitat in the project area, the project should have no effect on Southwestern willow flycatchers or yellow oilled cuckoos. No other threatened, endangered or candidate animal soecies are known to occur in the oroiect area. Vegetation Excluding Pl No BLM Sensitive plant species are known to occur in the Bob Douglas, or Dave USFW Designated 12/01115 NP project area. Corry Species There are a few isolated pinyon and juniper trees that will be NI Woodland I Forestry removed during construction however, this impact would be D. Corry I0/29/ 15 minimal to the overall woodland resources. The proposed action is not expected to impact Fuel or Fire NI Fuels/Fire Management D. Corry I0/29/ 15 Management. Invasive Species/Noxious ifhe POD provides measures to prevent the introduction or NI D. Corry I0/29/ 15 Weeds (EO 13112) spread of noxious weeds and invasive species. The proposed project will intersect with several other Right- NI Lands/ Access of-Ways that the City of St. George holds including: UTU K. Thomas I 1/4/15 p0068 (Citv of St. Geonze underground/overhead power line), Determi Resource Rationale for Determination* Signature Date nation
UTU-80273 (City of St. George water pipeline & 2 water .vell sites), UTU-75168 (Washington County Conservancy District water pipeline, filtration building, and sediment pond), UTU-73376 (City ofSt. George 2 water wells, water pipelines, and a power line), UTU-34757 (City ofSt. George well site, roadway, pipeline, power line, bridge, and access oad), UTU-14372 (City of St. George culinary water pipeline, well and power transmission line). If this will affect the WCWCD water facilities then notification to WCWCD will be required and WCWCD should sign an encroachment permit. Encroachment permits to enter the County Road (RS 24 77) may be necessary. The proposed treatment facility is located within the Gunlock Federal Grazing Allotment. Although some vegetation would NI Livestock Grazing oe lost during construction this impact is expected to be D.Corry 10/29/15 minimal. 15 acres of disturbance would result in aooroximately .5 AUMs being impacted by the project. Rangeland Health NI No Impact D.Corry 10/29/15 Standards
lrhere may be some temporary disruption to recreational A TV NI Recreation ~raffle, but the impacts would be short-term and negligible. K. Voyles 11/16/15 ~nalysis in the EA is not required. rrhe project is entirely within VRM Class III and would likely meet VRM Class III objectives.
Class III Obiectives: To nartiallv retain the existing character ()f the landscane I) The level of change to the landscape can be moderate. ~) Management activities may attract attention, but should ~ot dominate the view ofthe casual observer. ~) Any changes should repeat the basic elements found in the "'aturaHandscape-=-form,.line,.color,.&-tcxture. Pl/NI Visual Resources D.Kiel 11/16/15 lro ensure the project meets Class III objectives, a visual contrast rating would be performed by SGFO staff and attached to the EA as an appendix. In order to perform an ~ccurate contrast rating, the vertical profile of the building, as seen from the highway, would be required. With this in place, IVRM could be then listed as considered, but not necessary to ~alyze and this checklist section would be amended to No Impact (NI). A preferred color for the building would also be ~upplied by the SGFO. This can be in the form of a paint chip K>r color mix numbers. NLCS National Conservation rrhe proposed action would not impact National Conservation NP D.Kiel 11 / 16/ 15 Areas !Areas. lrhe legislatively-depicted route of the Old Spanish Trail National Historic Trails !National Historic Trail (Northern Route) follows the west Pl D. Ferris-Rowley I 1/6/2015 (Old Spanish Trail) side of the Santa Clara River, approximately Y. of mile to the rwest of the proposed Treatment Plant. National Recreational The proposed action would not impact the Gooseberry Mesa NP K. Voyles 11 /1 6/1 5 Trails (Gooseberry) [National Recreation Trail. Deter mi- Resource Rationale for Determination* Signature Date nation
There are no Wild and Scenic.River segments, either eligible, NP Wild and Scenic Rivers K. Voyles 11 /16/1 5 suitable, or designated, affected by the proposed action. !There are no designated wilderness areas or wilderness study NP Wilderness/WSA K. Voyles 11 /1 6/ 15 areas affected by the proposed action. rhe proposed action is adjacent to an area where a recent Lands with Wilderness NP inventory has determined that wilderness characteristics exist. D.Kiel 11116/15 Characteristics•• Those characteristics would not by impacted.
FINAL REVIEW:
Reviewer Title Comments
Environmental Coordinator
Authorized Officer APPENDIX B
Plan of Development Gunlock Arsenic Treatment Plant
Submitted to Submitted by Bureau of Land Management City of St. George St George Field Office 175 E 200 N 345 E Riverside Drive St George, Utah 84770 St George, Utah 84790
Updated January 2017
Table of Contents
Table of Contents ...... i Part I. Introduction and Background ...... 1 Part II. Purpose and Need for Facility ...... 3 A. Purpose ...... 3 B. Need ...... 3 Part III. Right‐of‐Way Location ...... 4 A. Government Agencies Involved ...... 5 Part IV. Facility Design and Construction ...... 5 A. Construction of Facilities ...... 5 i. Schedule ...... 5 ii. Pipeline Construction ...... 5 iii. Arsenic Treatment Plant Construction ...... 6 B. Resource Values and Environmental Concerns ...... 7 C. Operation and Maintenance ...... 10 D. Termination and Restoration ...... 11
List of Figures Figure 1. Project Components ...... 2
List of Tables Table 1. New Surface Disturbance Summary ...... 4 Table 2. Estimated Personnel & Equipment Required for Project ...... 7 Table 3. Estimated Personnel & Equipment Required for Operation & Maintenance ...... 10
Appendices Appendix A – Exhibits Appendix B – Best Management Practices
i
Part I. Introduction and Background
The City of St. George, located in southwest Utah, supplies water to the cities of St. George, Santa Clara, and Ivins. The City of St. George currently obtains its culinary water supply from Pine Valley Mountain Springs, eleven wells located in the Gunlock area, five wells located in the Snow Canyon area, two wells located in the Mill Creek area, one well located in City Creek and from the Virgin River through the Quail Creek Water Treatment Plant. In January 2001, the Environmental Protection Agency (EPA) implemented the “Arsenic and Clarifications to Compliance and New Source Monitoring Rule”, which changed the arsenic Maximum Contaminant Level (MCL) from 50 ppb to 10 ppb. With the promulgation of the new arsenic rule, the City of St. George started evaluating arsenic treatment at the Gunlock Well Field. Arsenic above the new maximum contaminant level (MCL) of 10 ppb has been detected in the Gunlock, Snow Canyon, and City Creek wells. The purpose of this project is to assist the City of St. George in planning to comply with the new arsenic regulatory requirements at the Gunlock Well Field. The City plans to install a new pipeline, and a new arsenic treatment plant, with associated appurtenances to be known as the Gunlock Arsenic Treatment Plant (GATP). The GATP will be located on lands administered by the Bureau of Land Management (BLM), St. George Field Office. Figure 1 shows the proposed location of the arsenic water treatment plant. The project would also involve the installation of approximately 4,800 feet of a culinary water pipeline parallel along Gunlock road and within already designated BLM right‐of ways (ROW’s). This Plan of Development (POD) includes descriptions of and guidelines for the design, construction, operation, maintenance, and reclamation associated with this project. The City of St. George would construct and operate the project in conformity with the approved POD.
1
Figure 1. Vicinity Map
2
Part II. Purpose and Need for Facility
Purpose The purpose of the project is to remove arsenic from the culinary water well sources in the Gunlock Well Field area to meet EPA standards. The existing wells, piping system, and power lines associated with the Gunlock Well Field, which were approved as part of multiple BLM right‐of‐ way (ROW) grants, are shown on Figure 2‐1 Appendix A. It is proposed to combine all BLM ROW grants associated with this project in one ROW grant. The existing wells, piping system, and power lines as well as access roads that would be included in the overall project are shown in Figure 2‐2 Appendix A. In addition to the existing facilities, it will be necessary to parallel portions of existing transmission lines with new transmission lines to convey untreated and treated water to and from the new GATP facility. Need The Gunlock Well field is located approximately 15 miles northwest of the City of St. George. The well field consists of eleven wells, three of which have been drilled recently in 2002‐2003. The wells pump from the highly productive Navajo Sandstone formation which has historically produced water of high quality. Water from the well field is p umped into the Gunlock tank, which then gravity feeds to the City via 18‐inch and 20‐inch transmission pipelines. Potable water is also supplied to the Shivwits Band of the Piute Indian Tribe (Shivwits) from an 8‐inch line connected directly to the Gunlock Tank. In January 2001, the Environmental Protection Agency (EPA) implemented the “Arsenic and Clarifications to Compliance and New Source Monitoring Rule”, which changed the arsenic Maximum Contaminant Level (MCL) from 50 ppb to 10 ppb. The objective of the arsenic treatment is to reduce arsenic levels in the source water to less than 10 ppb. The water from the wells needs to be treated prior to delivery to the Shivwits. In order to meet this requirement, the City has determined that the best location of the treatment facility would be near the source of water, which would place the treatment facility on BLM land. The implementation of this project will allow the City to provide water from the Gunlock Well Field meeting current culinary water standards to the Shivwits as well as other the other communities it currently serves. The proposed action and BLM decision is to grant a right‐of‐way pursuant to 43 CFR 2800 to authorize the construction, operation and maintenance of an arsenic treatment plant, subject to mitigation measures and operational stipulations. The specific public lands to be granted will be described in detail.
3
Part III. Right‐of‐Way Location
The proposed facility components would be located on lands administered by the BLM (see Appendix A – Figure 2‐ 4) generally located below Gunlock Reservoir. The GATP would be located in Section 8, Township 41 South, Range 17 West. The GATP would be accessed from Gunlock Road in two locations as shown on Figure 2‐4 – Appendix A. Pipelines from Gunlock Road to the treatment plant would be installed within these access road ROWs. The plant will initially be sized to treat 6 million gallons per day (MGD) with an additional future expansion of 6 MGD (see Appendix A ‐ Figure 2‐3). During construction, a temporary 100‐foot ROW will be required for grading, vehicle passage and pipe assemblage to access the treatment plant site which would require 1.64 acres. After construction, the permanent ROW will be reduced a 50‐foot width, totaling 0.82 acres. The treatment plant would require a 5.05 acre permanent ROW. With the future expansion it will also be necessary to parallel the existing transmission line in Gunlock Road with an additional water transmission line to be able to convey the additional treated water. This line will be approximately 5,631 feet in length and be constructed parallel to existing transmission lines within the Gunlock Road ROW (see Figure 2‐4 Appendix A). An additional 20‐foot temporary ROW will be required during construction for grading, vehicle passage and pipe assemblage. After construction of the water transmission line, the ROW will revert to the existing Gunlock Road ROW. Table 1 provides length and acreages for the new disturbance from the various project components. Table 1. New Surface Disturbance Summary Linear Feet Land Temporary New Surface Permanent New Surface of New Surface Ownership Disturbance ROW (Acres) Disturbance ROW (Acres) Disturbance Access Road and Pipeline (From Gunlock Road to Treatment Plant)
BLM ‐ 0.82 0.82
Arsenic Treatment Plant
BLM ‐ 0.00 5.05 Transmission Line (Parallels Gunlock Road within existing ROW); Temporary New Surface Disturbance ROW [20 feet] BLM 5,631 2.59 0.00 GRAND TOTAL 5,631 3.41 5.87
4
Government Agencies Involved The government agencies potentially involved with the proposed project are: Bureau of Land Management (BLM) Washington County Water Conservancy District (WCWCD) City of St. George Army Corp. of Engineers Utah State Division of Drinking Water Utah State Division of Water Rights
Part IV. Facility Design and Construction
Construction of Facilities
i. Schedule Construction would commence as soon as necessary rights‐of‐way and permits are obtained and all plans are finalized. Construction of the GATP, including site improvements and pipeline, is estimated to take up to 12 months to complete. Construction of the phase 1 pipeline and treatment plant would occur simultaneously. The expansion of the treatment plant would be constructed simultaneously with the parallel transmission lines.
ii. Pipeline Construction The proposed pipeline will be sized to properly convey design flows from the Gunlock Road to the treatment plant. The pipeline will be provided with tracer wire for locating the underground piping. Pipeline installation activities would include survey staking for alignment and grade, clearing and grubbing, access road construction, trenching, hauling equipment and materials, pipeline assembly and installation, and backfill, in this order. The approximate number of workers and typical types of equipment used for this type of construction are provided in Table 2. Prior to construction, the exact centerline of the pipeline ROW would be staked. The ROW boundaries will also be flagged. Following staking, vegetation within the ROW would be cleared and grubbed to the extent necessary to provide for equipment clearance, construction, and maintenance operations. It is anticipated that the alignment and trench for the pipeline would be excavated using CAT D10 (or smaller) bulldozers and/or CAT 345 (or smaller) track hoes. Grading will be designed and performed to balance the cut and fill quantities, thus eliminating the need
5
to import or export material. The pipeline would be bedded and buried to a minimum depth of 3 feet to the top of pipe. The trench will generally be 2 feet wider than the pipe. A typical installation for the pipe would require four to six feet of width by five to seven feet of depth. Where the pipeline would be installed under existing asphalt or where it would cross paved roads, asphalt would be replaced according to the governing agency’s recommended specifications and requirements. iii. Arsenic Treatment Plant Construction It is proposed to construct an arsenic treatment plant on lands administered by the BLM. This would also include the installation of supply, drain and overflow pipes buried a minimum of 3 feet below ground surface. The components of the treatment plant would include the following: Building 6 MGD Building – 75’ x 90’ Block Building Future 6 MGD Building Addition – 50’ x 70’ Building wall height approximately 14 feet Building Roof with standard 3/12 roof pitch would be approximately 11 feet high. Overall height of building at roof peak would be 25 feet (this dimension can be reduced using flatter roof slope).
Outside Tanks Two metal tanks to be located outside as shown on plan approximately 25 feet in diameter and 20 feet high (to be placed immediately behind building to avoid visibility)
Settling Ponds There will be 4 drying beds initially which would be expanded to 8 drying beds in the future. They will be constructed of reinforced concrete and be approximately 30 feet wide and 200 feet long and approximately 6 feet deep. Most of the structure will be below ground.
Treatment Process The building will house coagulation/filtration pressure vessels provided with media and chemical feeds that are effective in removing arsenic. The outside tanks are used to store water for back wash of the filters. The drying beds are used to settle solids from the back wash. When dry, materials will be removed and disposed of at an approved landfill.
The plant construction activities would include survey staking of the building and rights‐ of‐ways, clearing and grubbing, excavation, hauling equipment and materials, trenching, backfill, compaction, pipeline installation, concrete work (forming, pouring, and curing), and site cleanup. The number of workers and type of equipment expected to be used to construct the treatment plant are provided in Table 2.
6
Table 2. Estimated Personnel & Equipment Required for Project Number of Task Equipment People Survey and Staking 2 1 ‐ Pickup Truck Trenching 1 1 ‐ Track Hoe (CAT 345) 1 ‐ Semi‐Truck w/ Flatbed Trailer Materials Hauling 2 1 ‐ Forklift/Loader 1 – Dump Truck 1 – Mechanical Screen or Crusher 2 ‐ Track Hoe (CAT 345) Pipeline Installation 6 1 ‐ Loader and Burial 2 ‐ Pickup Trucks Compaction Equipment 1 ‐ Water truck 1 ‐ Bulldozer (CAT D10) Road Construction 2 1 ‐ Blade 1 ‐ Water truck 1 ‐ Loader 1 ‐ Dump Truck 1 ‐ Blade 1 ‐ Compactor Treatment Plant 10 3 ‐ Concrete Trucks Construction 1 ‐ Track Hoe (CAT 345) 1 ‐ Concrete Pump Truck 1 ‐ Crane 3 ‐ Pickup Trucks Clean‐up 2 1 ‐ Pickup Truck Resource Values and Environmental Concerns The City has contracted the services of Alpha Engineering and their consultants, to prepare relevant resource surveys as required by the National Environmental Policy Act. The location of the pipeline and treatment plant avoids all known cultural resources. Cultural resources that would be directly or indirectly impacted would be subject to evaluation and determination through Section 106 consultation (under the National Historic Properties Act). The City would work with BLM archaeologists to avoid or minimize impacts to any identified cultural resources. As necessary, specific mitigation measures for biological resources would also be developed as part of the Environmental Assessment and if necessary, additional surveys and Section 7 consultation (under the Endangered Species Act) would be conducted. Implementation of the project would comply with all applicable federal and state laws and any local zoning and building ordinances during all phases of the Project. Potential impacts to the environment are expected to be minimal as standard Best Management Practices (BMPs) would be followed (Appendix B) and the Environmental Protection Measures (EPMs) listed below would
7
be implemented. EPMs would also apply to operation and maintenance of the completed facility. The BLM is expected to inspect the Project both during and after Project completion to ensure compliance with EPMs and other requirements. Air Resources: The generation of fugitive dust from surface activities, including earth moving and hauling and handling of materials, would be controlled by implementing BLM BMPs. When needed, water would be applied during construction to control fugitive dust levels on access roads and construction sites. Water Resources: BMPs would be used as needed to control storm water discharges. These practices would include material handling and temporary storage procedures that minimize the exposure of potential pollutants to storm water, spill prevention and response, sediment and erosion controls, and physical storm water controls. Site runoff would be controlled and managed in accordance with regulation. A Storm Water Pollution Prevention Plan would be prepared prior to construction and followed during construction. Hazardous Materials and Wastes: Construction sites, staging areas, and access roads would be kept in an orderly condition throughout construction. Refuse and trash, including stakes and flags, would be removed and disposed. Covered dumpsters located in the Project Area would contain all refuse. Refuse would be removed on a regular basis to an approved disposal facility. No open burning of construction trash would occur. Portable toilets would be used on site, and would be maintained on a regular schedule. No construction equipment oil or fuel would be drained on the ground. Oils or chemicals would be hauled to an approved site for disposal. The only significant sources of potential petroleum or other hazardous material spills are from mobile equipment. If a fuel/oil or other hazardous material spill were to occur, the BLM and other required regulatory agencies would be contacted as soon as possible, and actions would be taken to minimize the amount and spread of the spill material. Such measures may include straw bale plugs, earthen berms, or use of other absorbent materials. If necessary, soil remediation would be conducted and would include the removal of contaminated soils to an approved facility and a soil sample(s) would be taken to verify the success of the site remediation. In addition, the City would follow any other local, state, or Federal regulations related to the use, handling, storing, transporting, and disposing of hazardous materials. Fire Prevention and Protection: All construction personnel would have fire tools and extinguishers available at all times for use if the occasion arises. Construction staff would adhere to any BLM fire prevention and suppression requirements. Cultural Resources: If, during any Project activities, cultural, historical, or prehistoric resources, including any of Native American religious interest, are inadvertently discovered, the BLM Authorized Officer would be notified, and all work in the area would cease. A professionally trained archeologist would work with the State Historic Preservation Office (SHPO) and affiliated or interested Tribes to determine eligibility for the National Register of Historic Places. If needed, a mitigation plan would be developed in consultation with the SHPO, the City, construction crews, and interested Tribes. Construction personnel would be instructed to watch for cultural artifacts
8
while working on the Project. In the event significant vertebrate paleontological resources are discovered, including human remains, the BLM authorized officer would be notified. Human Health and Safety: Should blasting be required, the contractor performing blasting would comply with applicable regulations and standards established by the regulatory agencies, codes, and professional societies, including the rules and regulations for storage, transportation, delivery, and use of explosives. Whenever blasting operations are in progress, explosives would be stored, handled, and used as provided by law, including safety and health regulations for construction. No explosives would be stored on the Project Area. Construction sites would be managed to prevent harm to any person and property. During construction, all employees, project managers, supervisors, inspectors, contractors, and subcontractors would be required to conform to contractor safety procedures. All personnel would be adequately trained to perform their tasks. Heavy equipment would be outfitted with Occupational Safety and Health Administration (OSHA) required safety devices such as backup warnings and seat belts. Hard hats, safety boots, ear and eye protection, and other personal safety equipment would be available to any personnel requesting it. All accidents and injuries would be reported to the appropriate contractor safety officer. Noxious Weeds/Invasive Species: All equipment, including pickup trucks and passenger vehicles, would be cleaned of soils, seeds, vegetative matter, or other debris or matter that could contain or hold noxious seeds prior to entering the Project Area. The cleaning of equipment would also be done any time thereafter if the equipment leaves the Project Area, is used on another Project, and reenters the Project Area. The City would follow any regulations pertaining to control of noxious weeds on BLM‐administered land. Vegetation in the Project Area would be monitored periodically for the establishment of noxious weeds or undesirable plant species. The City would be responsible for any future weed control work, within the permanent easement, if needed, as a result of the implementation of this Project. Any use of herbicides would comply with BLM requirements. Stabilization and Rehabilitation: All areas subject to temporary ground disturbance would be restored to original contours to the extent determined by the BLM. Temporarily disturbed areas would be seeded using a certified weed‐free seed mix approved by the BLM. Seed would be hand broadcasted and lightly covered with soil by hand using a rake or by pulling a chain‐link fence with an all‐terrain vehicle. All soil removed during construction would be reused. Vegetation removal would be kept to that necessary to install the line. Any brush removed during construction would be used as mulch after reclamation activities. Raptors and Migratory Birds: In order to avoid or reduce impacts on nesting success of raptors, activities would not occur within recommended spatial and seasonal buffers, and would follow Utah BLM BMPs for Raptors and Their Associated Habitats in Utah (August 2006). If existing topography limits actual line‐of‐sight of between an active nest (i.e., the nest has eggs or young) and construction activities, the spatial and seasonal buffer may be reduced. To avoid or minimize potential short‐term and long‐term impacts to migratory birds, construction activities would be either limited during the migratory bird nesting period (generally defined as 15 May – July 15 [BLM 2008], but could start as early as March/April depending on elevation and
9
latitude), or a migratory bird nesting survey would be completed in areas proposed for disturbance during this time period. If an active nest were discovered, the appropriate agency biologist would be notified and an appropriate buffer area around the nest would be established to prevent nest abandonment until after the migratory bird nesting period is over and/or young have fledged. Wildlife: No firearms, air guns, or archery equipment would be allowed on the project sites. No pets would be permitted on project sites. To prevent entrapment of wildlife during construction, any open pits or trenches would be monitored throughout the construction day. Excavated pits and trenches more than 2 feet deep would be covered at the close of each day. Alternatively, fencing may be erected around open pits or trenches. At the beginning of the construction day and before pits or trenches are filled, they would be inspected for trapped animals. If any animals are found, they would be moved out of harm’s way. No rodenticides would be used on project sites. Encounters with a protected species (e.g., raptors, migratory birds, or listed or sensitive species) would be reported to the BLM and/or the appropriate oversight agency (e.g., USFWS). Any contractor or employee who inadvertently kills or injures a protected species would immediately report the incident to the BLM and/or the appropriate oversight agencies. Waters of the U.S.: This project is located near an area with portions delineated as Waters of the U.S. as set forth by the U.S. Army Corps of Engineers (USACE) but should not require a Waters of the U.S. Delineation Report. Operation and Maintenance It is anticipated that routine maintenance would include the following (summarized in Table 3): The treatment plant will be inspected and maintained weekly to meet EPA requirements. Equipment and products will be replaced as needed to meet the EPA standards. The pipeline system is estimated to have a 50‐year life before major pipeline repair would be required.
Table 3. Estimated Personnel & Equipment Required for Operation & Maintenance Number of Task Equipment People Flushing Pipeline 2 1 ‐ Pickup Truck 1 ‐ Pickup Truck Pipeline Maintenance 2 1 ‐ Track Hoe (CAT 345) Compactors 1 ‐ Crane Treatment Plant 1 ‐ Pickup Truck 2 Maintenance 1 ‐ Tanker Truck (Quarterly Basis) 1 ‐ Septage Hauler (Quarterly Basis)
10
Termination and Restoration If the project is to be terminated or abandoned, a joint inspection would be held with the authorized officer(s) of the BLM prior to termination. The joint inspection would be conducted to agree upon an acceptable rehabilitation plan for the area.
11
Appendix A. Exhibits
04 09 16 21 # * # * # * # * # * 05 # * # *
# * 08 T41S R17W # * 17 # * # * # * 20 # * # * # * # * # * # * # * # * # *
06 07 18 19 # * # * # *
0 500 1,000 2,000 Switch OHP Secondary Municipalities Gunlock Well Field Feet Power Pole UGP Primary PLSS Section Lines *# Transformer UGP Secondary PLSS Township Lines Existing BLM ROWs
Water Main O Spatial Reference: Utah State Plane NAD 83, feet OHP Primary Drawn By: JRH Scale: 1" = 1,000 ' Figure 2-1 Date: MAY 2, 2016 04 09 16 21 # * # *
Well 7 # * Well 8 Well 11 # * # * 05 Well 10 Well 4 # * # *
# * 08 T41S R17W # * 17 20 # * # *
Well 5 # *
Well 9 # * # * Well 1 # * # * # * # * Well 3 # * # * # * Well 6 06 07 18 19 # * # * # * Well 2
0 500 1,000 2,000 Existing Switch Existing OHP Primary Federal Land Gunlock Well Field Feet Existing Power Pole Existing OHP Secondary Private Land *# Existing Transformer Existing UGP Primary State Land Existing Conditions Existing Access Road Existing UGP Secondary PLSS Section Lines
O Spatial Reference: Utah State Plane NAD 83, feet Existing Water Line PLSS Township Lines Drawn By: JRH Scale: 1" = 1,000 ' Figure 2-2 Date: May 2, 2016 DATE BY DESCRIPTION NO. REVISIONS WCWCD SITE PLAN GUNLOCK WELLS ARSENIC TREATMENT TITLE PROJECT
PROJECT # 041-114
NAME RKB
DATE MAY 22, 2017
SCALE AS NOTED
SHEET FIGURE 2-3 1 OF 1 FILE rbeazer, DWG To PDF.pc3 DWG To rbeazer, P:\041-114 Gunlock Arsenic Treatment\Drawings\Exhibit Drawings\041-114 EXH.dwg, UPPER2, 5/22/2017 9:32:11 AM, 9:32:11 5/22/2017 UPPER2, EXH.dwg, Drawings\041-114 Treatment\Drawings\Exhibit Arsenic Gunlock P:\041-114 041-114 EXH.dwg 04 09 16 21 # * # * # *
Well 11 Well 7 # * Well 8 # * 05 Well 10 # * # * # * 08 Well 4 T41S R17W # * 17 20 ## ** Well 5 # * Well 9 # * ## ** Well 1 # * # * # * Well 3
# * # * # * Well 6 06 07 18
19 # * # * # * Well 2
0 500 1,000 2,000 New Site Existing OHP Primary Federal Land Gunlock Well Field Feet Existing Power Pole Existing OHP Secondary Privat e Land *# Existing Transformer Existing UGP Primary State Land New Water Lines New Water Lines Existing UGP Secondary
O Spatial Reference: Utah State Plane NAD 83, feet ExWater PLSS Section Lines Drawn By: JRH Existing Access Road PLSS Township Lines Scal e: 1" = 1,000'
P:\041-114 Gunlock Arsenic Treatment\Drawings\GIS\041-114 New Transmission Lines.mxd, Transmission New Treatment\Drawings\GIS\041-114 Arsenic PM 2:02:36 10/12/2016 Gunlock P:\041-114 jheward Figure 2-4 Date: October 12, 2016
Appendix B. Best Management Practices
Best Management Practices As part of standard operating procedures, standard BMPs would be implemented throughout the project in order to reduce potential adverse environmental impacts. Most of the impacts are short term and generally occur during the construction period. Project design and implementation of site‐specific or selectively recommended BMPs would minimize the effect of the project where the potential for long‐ term, adverse impacts may occur. STANDARD BMPs 1. All construction vehicle movement outside of the right‐of‐way would be restricted to pre‐designated access, contractor acquired access, or public roads. 2. The limits of construction activities would be predetermined, with activity restricted to and confined within those limits. No paint or permanent discoloring agents would be applied to rocks or vegetation to indicate survey or construction activity limits. The right‐of‐way boundary would be flagged in environmentally sensitive areas described in the plan of development to alert construction personnel that those areas would be avoided. 3. In construction areas where re‐contouring is not required, vegetation would be left in place wherever possible to avoid excessive root damage and allow for re‐sprouting. 4. In construction areas where ground disturbance is significant or where re‐contouring is required, surface restoration would occur as required by the landowner or land management agency. The method of restoration typically would consist of returning disturbed areas to their natural contour (to the extent practical) and reseeding or re‐vegetating with native plants. Seed viability would be tested and seed mixes would be certified to contain no noxious weeds. 5. Prior to construction, all construction personnel would be instructed on the protection of cultural, paleontological, and ecological resources. To assist in this effort, the construction contract would address (a) federal and state laws regarding antiquities, fossils, and plants and wildlife, including collection and removal; and (b) the importance of these resources and the purpose and necessity of protecting them. 6. An initial intensive cultural resource inventory survey would be conducted prior to construction. Impact avoidance and mitigation measures developed in consultation with appropriate land management and regulatory agencies and other interested parties would be implemented subsequent to the completion of the NEPA compliance document. 7. Any cultural and/or paleontological resource discovered during construction by the City or any person working on their behalf on public or federal land would be reported immediately to the authorized officer. The City would suspend operations in the area until an evaluation is completed to prevent the loss of cultural or scientific values. 8. All construction and maintenance activities would be conducted in a manner that would minimize disturbance to vegetation, drainage channels, and intermittent and perennial stream banks. In addition, dust‐control measures would be utilized as necessary during construction in sensitive areas. Any used existing roads would be left in a condition equal to or better than their condition prior to construction. 9. All requirements of those entities having jurisdiction over air quality matters would be adhered to and any necessary permits for construction activities would be obtained. Open burning of construction trash (cleared trees, etc.) would not be allowed on BLM lands. 10. Fences and gates, if damaged or destroyed by construction activities, would be repaired or replaced to their original pre‐disturbed condition as required by the landowner or the land management agency. Temporary gates would be installed only with the permission of the landowner or the land management agency.
STANDARD BMPs 11. Totally enclosed containment would be provided for all hazardous materials (if needed) and trash. All construction waste including trash, litter, garbage, other solid waste, petroleum products, and other potentially hazardous materials would be removed to a disposal facility authorized to accept such materials. 12. Third‐party environmental contractors would be used throughout the construction effort, from clearing through rehabilitation. 13. The City would trim trees in preference to cutting trees, and would cut trees in preference to bulldozing them. 14. Construction holes left open overnight would be covered to prevent livestock or wildlife from harm. 15. The contractor would clean off‐road equipment (power or high‐pressure cleaning) of all mud, dirt, and plant parts prior to moving equipment onto public land.
ADDITIONAL STIPULATIONS The following additional stipulations would be implemented throughout the construction and operation of the project and would be included as part of the standard operating procedures.
STIPULATIONS – STANDARD OPERATING PROCEDURES 1. The City would construct, operate, and maintain the facilities, improvements, and structures within this ROW in strict conformity with the plan of development as it is approved. Any relocation, additional construction, or use that is not in accord with the approved plan of development would not be initiated without the prior written approval of the authorized officer. A copy of the complete ROW grant or acknowledgment, including all stipulations and approved plan of development, would be made available on the ROW area during construction, operation, and maintenance to the authorized officer. Noncompliance with the above shall be grounds for an immediate temporary suspension of activities if it constitutes a threat to public health and safety or a material threat to the environment. 2. This plan of development describes in detail the construction, operation, maintenance of the ROW and its associated improvements and/or facilities. An approved plan of development may be referred to for interpretation of the right‐of‐way grant. 3. The City would contact the authorized officer at least 10 days prior to the anticipated start of construction and/or any surface‐disturbing activities. The authorized officer may require and schedule a preconstruction conference with the City prior to commencement of construction and/or surface‐disturbing activities on the ROW. The City, its contractor(s), or agents involved with the construction and/or surface‐disturbing activities on the ROW should attend this conference to review the stipulations of the grant and the plan(s) of development. 4. The City would designate a representative(s) who would have the authority to act upon and implement instructions from the authorized officer within a reasonable time when construction or other surface‐ disturbing activities are underway. 5. The holder would protect all survey monuments found within the right‐of‐way. Survey monuments include but are not limited to General Land Office and BLM Cadastral Survey Corners, reference corners, witness points, U.S. Coastal and Geodetic benchmarks and triangulation stations, military control monuments, and recognizable civil (both public and private) survey monuments. In the event of obliteration or disturbance of any of the above, the City would immediately report the incident, in writing, to the authorized officer and the respective installing authority, if known. Where General Land Office or BLM ROW monuments or references
STIPULATIONS – STANDARD OPERATING PROCEDURES are obliterated during operations, the City shall secure the services of a registered land surveyor or a BLM cadastral surveyor to restore the disturbed monuments and references using surveying procedures found in the Manual of Surveying Instructions for the Survey of the Public Lands of the United States, latest edition. The City shall record such survey in the appropriate county and send a copy to the authorized officer. If the BLM cadastral surveyors or other federal surveyors are used to restore the disturbed survey monument, City would be responsible for the survey cost. 6. The holder of the ROW grant or the holder’s successor in interest shall comply with Title VI of the Civil Rights Act of 1964 (42 U.S.C. 2000d et. seq.) and the regulations of the Secretary of Interior issued pursuant hereto. 7. The City would mark the exterior boundaries of the ROW with a stake and/or lath. The intervals may be varied at the time of staking at the discretion of the authorized officer. The tops of the stakes and/or laths would be painted and the laths flagged in a distinctive color as determined by the holder. The survey station numbers would be marked on the boundary stakes and/or laths at the entrance to and exit from public land. Holder would maintain all boundary stakes and/or laths in place until final cleanup and restoration are completed and approved by the authorized officer. The stakes and/or laths would then be removed at the direction of the authorized officer. 8. The holder would conduct all activities associated with the construction, operation, and maintenance of the right‐of‐way within the authorized limits of the ROW and approved plan of development. 9. The holder would survey and clearly mark the centerline and/or exterior limits of the ROW, as determined by the authorized officer. 10. All design, material, and construction, operation, maintenance, and termination practices would be in accordance with safe and proven engineering practices. 11. The holder would inform the authorized officer within 48 hours of any accidents on federal lands that require reporting to the Department of Transportation as required by 49 CFR Part 195. 12. During conditions of extreme fire danger, operations may be suspended or limited in certain areas. 13. The holder would be liable for damage or injury to the United States to the extent provided by 43 CFR Sec. 2803.1‐4. The holder would be held to a standard of strict liability for damage or injury to the United States resulting from fire or soil movement (including landslides and slumps as well as wind and water‐caused movement of particles) caused or substantially aggravated by any of the following within the ROW or permit area:
Activities of the holder including but not limited to construction, operation and maintenance of the facility.
Activities of other parties acting under color of authority from the City, including but not limited to: - land clearing - earth‐disturbing and earth‐moving work 14. Within 30 days of completion, the holder would submit to the authorized officer, as‐built drawings and a certification of construction verifying that the facility has been constructed (and tested) in accordance with the design, plans, specifications, and applicable laws and regulations. 15. Construction sites would be maintained in a sanitary condition at all times; waste materials at those sites would be disposed of promptly at an appropriate waste disposal site. “Waste” means all discarded matter including but not limited to human waste, debris, garbage, refuse, oil drums, petroleum products, ashes, and equipment.
STIPULATIONS – STANDARD OPERATING PROCEDURES 16. Prior to preconstruction activities on the subject parcel, the lessee would identify all noxious weeds present. A list of the weeds would be provided to the authorized officer. A determination would be made by the authorized officer of any noxious weeds that may require flagging for treatment. The lessee shall treat the noxious weeds as required by the authorized officer. 17. The lessee would clean off‐road equipment (power or high‐pressure cleaning) of all mud, dirt, and plant parts prior to moving equipment onto public land authorized under this lease. 18. Gravel and/or fill material to be placed in relatively weed‐free areas must come from weed‐free sources. Prior to obtaining gravel and/or fill material, the authorized officer would inspect the source for weeds and determine adequacy of site. 19. The lessee would identify a road maintenance program, which would include monitoring for noxious weeds. If lessee identifies any noxious weeds, the lessee would notify the authorized officer immediately. A treatment program would be identified and the lessee would be responsible for weed abatement.
APPENDIX C
Best Management Practices As part of standard operating procedures, standard BMPs would be implemented throughout the project in order to reduce potential adverse environmental impacts. Most of the impacts are short term and generally occur during the construction period. Project design and implementation of site-specific or selectively recommended BMPs would minimize the effect of the project where the potential for long-term, adverse impacts may occur. STANDARD BMPs 1. All construction vehicle movement outside of the right-of-way would be restricted to pre-designated access, contractor acquired access, or public roads. 2. The limits of construction activities would be predetermined, with activity restricted to and confined within those limits. No paint or permanent discoloring agents would be applied to rocks or vegetation to indicate survey or construction activity limits. The right-of-way boundary would be flagged in environmentally sensitive areas described in the plan of development to alert construction personnel that those areas would be avoided. 3. In construction areas where re-contouring is not required, vegetation would be left in place wherever possible to avoid excessive root damage and allow for re-sprouting. 4. In construction areas where ground disturbance is significant or where re-contouring is required, surface restoration would occur as required by the landowner or land management agency. The method of restoration typically would consist of returning disturbed areas to their natural contour (to the extent practical) and reseeding or re-vegetating with native plants. Seed viability would be tested and seed mixes would be certified to contain no noxious weeds. 5. Prior to construction, all construction personnel would be instructed on the protection of cultural, paleontological, and ecological resources. To assist in this effort, the construction contract would address (a) federal and state laws regarding antiquities, fossils, and plants and wildlife, including collection and removal; and (b) the importance of these resources and the purpose and necessity of protecting them. 6. An initial intensive cultural resource inventory survey would be conducted prior to construction. Impact avoidance and mitigation measures developed in consultation with appropriate land management and regulatory agencies and other interested parties would be implemented subsequent to the completion of the NEPA compliance document. 7. Any cultural and/or paleontological resource discovered during construction by the FIC or any person working on their behalf on public or federal land would be reported immediately to the authorized officer. The FIC would suspend operations in the area until an evaluation is completed to prevent the loss of cultural or scientific values. 8. All construction and maintenance activities would be conducted in a manner that would minimize disturbance to vegetation, drainage channels, and intermittent and perennial stream banks. In addition, dust-control measures would be utilized as necessary during construction in sensitive areas. Any used existing roads would be left in a condition equal to or better than their condition prior to construction. 9. All requirements of those entities having jurisdiction over air quality matters would be adhered to and any necessary permits for construction activities would be obtained. Open burning of construction trash (cleared trees, etc.) would not be allowed on BLM lands. 10. Fences and gates, if damaged or destroyed by construction activities, would be repaired or replaced to their original pre-disturbed condition as required by the landowner or the land management agency. Temporary gates would be installed only with the permission of the landowner or the land management agency. 11. Totally enclosed containment would be provided for all hazardous materials (if needed) and trash. All construction waste including trash, litter, garbage, other solid waste, petroleum products, and other potentially hazardous materials would be removed to a disposal facility authorized to accept such materials.
STANDARD BMPs 12. Third-party environmental contractors would be used throughout the construction effort, from clearing through rehabilitation. 13. The FIC would trim trees in preference to cutting trees, and would cut trees in preference to bulldozing them. 14. Construction holes left open overnight would be covered to prevent livestock or wildlife from harm. 15. The contractor would clean off-road equipment (power or high-pressure cleaning) of all mud, dirt, and plant parts prior to moving equipment onto public land.
APPENDIX D
Form8400 -4 (September 1985) Date 7/27/2016 UNITED STATES DEPARTMENT OF THE INTERIOR District Color Country BUREAU OF LAND MANAGEMENT
Field Office St. George VISUAL CONTRAST RATING WORKSHEET Activity (program) Lands and Realty
SECTION A. PROJECT INFORMATION 1. Project Name 4. Location 5. Location Sketch City of St. George Arsenic Treatment Plant Township 41S 2. Key Observation Point See site map and simulations in the plan of Observation Point #1 Range 17W development and environmental assessment
3. VRM Class Section 8 Visual Resource Management Class III
SECTION B. CHARACTERISTIC LANDSCAPE DESCRIPTION 1. LAND/WATER 2. VEGETATION 3. STRUCTURES
Large, steep, and vertical backdrop, with a flat, Circular, conical pinyon-juniper trees Simple, boxy and square simple, concave foreground interspersed with flat, symmetrical low shrubs FORM
Angular, jagged lines in and around the basalt Bold, angular lines with a mix of horizontal, Horizontal and vertical lines produced flow, mixed with geometric shapes formed by
LINE vertical, and diagonal patterns by simple box structures the trees
Glaringly dark hues that mix black basalt rock Warm, vivid greens formed by the grasses and Two buildings have warm red-brown with dark green pinyon. Lighter, luminous low shrubs, mixed with cooler, darker greens earthtones making them highly visible.
COLOR grasses highlight the foreground from the trees A third building is a dark, subtle green
Smooth along the level foreground. Dense and Smooth to mildly coarse on the flats to very Smooth and uniform TEX -
TURE coarse across the hills clumped and coarse on the hills
SECTION C. PROPOSED ACTIVITY DESCRIPTION 1. LAND/WATER 2. VEGETATION 3. STRUCTURES
Vegetation would be removed. Remaining Flat, simple, and rectangular shapes created by Simple, rectangular, and boxy, with a vegetation would be the same as described construction grading conical roof line FORM above
Straight, simple, and parallel lines created by Bold and angular, created by vegetation Straight, geometric, and parallel
LINE construction grading removal
Vegetation would be removed. Remaining Light to dark gray from applied gravel vegetation would be the same as described Cool, dark, gray/green hue
COLOR above
Vegetation would be removed. Remaining Smooth and granular vegetation would be the same as described Smooth and uniform TEX - TURE above SECTION D. CONTRAST RATING SHORT TERM X LONG TERM 1. FEATURES 2. Does project design meet visual resource LAND/WATER management objectives? X Yes No VEGETATION STRUCTURES DEGREE BODY (Explain on reverse side) (2) (3) (1) OF 3. Additional mitigating measures recommended? CONSTRAST X Yes No (Explain on reverse side)
Strong Moderate Weak None Strong Moderate Weak None Strong Moderate Weak None Evaluator’s Names Date
Form X X X Dave Kiel 7/28/2016 Line X X X Vanessa Ballard Color X X X
ELEMENTS Texture X X X SECTION D. (Continued) Comments from item 2.
Proposed project is for the installation of an Arsenic Treatment Plant, which consists of a single, large, rectangular building with two vertical tanks. The tanks are placed behind the building and would not be visible from the KOP or anywhere the building is visible from the Gunlock Road. Also included are two drying beds which lie flat on the ground with no vertical relief. The ponds would not be visible from any location.
The structure would be visible from the Gunlock Road for drivers headed south. After rounding a left hand bend the structure would be visible for approximately 0.2 miles. Given the average speeds on the Gunlock Road, the amount of time the structure is visible is very brief, less than a minute.
The structure would be less visible for drivers headed north. The entire development sits on a bench that is slightly higher than the Gunlock Road partially shielding it from northbound drivers. Drivers would have to look to the right and slightly backwards to see anything from this direction.
The structure as designed and portrayed in the visual simulation meets Visual Resource Management objectives for Class III, which is the designation for this site and the entire surrounding landscape. This conclusion is dependent on the correct application of the mitigation measures listed below.
Additional Mitigating Measures (See item 3)
All vertical structures should be painted Beetle Green as shown on the BLM Standard Environmental Colors Chart CC-001
U.S. GOVERNMENT PRINTING OFFICE: 1985‐461‐988/33094