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Environmental Information Document City of Bloomfield, San Juan County, New Mexico Water Reclamation Facility Rehabilitation and Upgrades

Lead Agency:

The City of Bloomfield

Cooperating Agencies and Partners:

Bohannan-Huston, Inc. Epsilon Systems Solutions, Inc.

Prepared for: Bohannan-Huston Inc. Las Cruces, NM 88011

Prepared by:

December 2019

Environmental Information Document Draft Final Bloomfield Water Reclamation Plant, San Juan County, New Mexico December 2019

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Environmental Information Document

Water Reclamation Plant Rehabilitation and Upgrades

City of Bloomfield, San Juan County, New Mexico

Draft Final

Submitted to:

Submitted by:

Epsilon Systems Solutions, Inc. and

Bohannan-Huston, Inc.

December 2019


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Table of Contents

Acronyms and Abbreviations .................................................................................................................... viii

Chapter 1 Introduction ............................................................................................................................... 1-1

1.1 Scope of the Environmental Information Document ................................................................. 1-1

1.2 Document Organization ............................................................................................................. 1-1

1.3 Regulatory Drivers and Guidance .............................................................................................. 1-3

1.3.1 The National Environmental Policy Act ............................................................................ 1-3

1.3.2 The Clean Air Act .............................................................................................................. 1-3

1.3.3 The Clean Water Act .......................................................................................................... 1-4

Chapter 2 Purpose and Need for the Proposed ACtion .............................................................................. 2-1

2.1 Project Description ..................................................................................................................... 2-1

2.2 Purpose and Need for the Proposed Action ............................................................................... 2-1

Chapter 3 Alternatives ............................................................................................................................... 3-1

3.1 Reclamation Facility Improvements Alternatives Considered................................................... 3-1

3.1.1 Comparison of Alternatives ............................................................................................... 3-2

3.2 Reclaimed Water System Description ....................................................................................... 3-3

3.3 Description of the Preferred Alternative (Preferred Alternative)............................................... 3-3

3.4 Alternative Considered but Eliminated from Further Consideration ......................................... 3-4

Chapter 4 Affected Environment and Environmental Consequences ........................................................ 4-1

4.1 Land Use .................................................................................................................................... 4-1

4.1.1 Affected Environment ........................................................................................................ 4-1

4.1.2 Environmental Consequences ............................................................................................ 4-1

4.2 Soils............................................................................................................................................ 4-1



4.3 Floodplains ................................................................................................................................. 4-2



4.4 Wetlands .................................................................................................................................... 4-3



4.5 Water Resources ........................................................................................................................ 4-3



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4.6 Coastal Resources ...................................................................................................................... 4-5

4.7 Air Quality and Climate ............................................................................................................. 4-5



4.8 Biological Resources ................................................................................................................. 4-9


4.8.2 Environmental Consequences .......................................................................................... 4-10

4.9 Archaeological, Cultural, and Historic Resources ................................................................... 4-10

4.9.1 Affected Environment ...................................................................................................... 4-11


4.10 Socioeconomics and Environmental Justice ............................................................................ 4-11

4.10.1 Affected Environment ...................................................................................................... 4-11


4.11 Other Resources ....................................................................................................................... 4-12

4.12 Cumulative Effects ................................................................................................................... 4-14

Chapter 5 Summary of Mitigation Measures ............................................................................................. 5-1

Chapter 6 Consultation, Coordination, and Public Involvment ................................................................. 6-1

Chapter 7 List of Preparers ........................................................................................................................ 7-1

Chapter 8 References ................................................................................................................................. 8-1

Appendix A Agency Coordination .......................................................................................................... A-1

Appendix B Tribal Communications ....................................................................................................... B-1

Appendix C Public Involvement .............................................................................................................. C-1


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List of Figures

Figure Page

Figure 1 Project Area and Local Land Use ............................................................................................... 1-2

List of Tables

Table Page

Table 1 Soil Units Present at the WRF Site .............................................................................................. 4-2

Table 2 National and State of New Mexico Ambient Air Quality Standards ........................................... 4-6

Table 3 Bloomfield Climate Summary ..................................................................................................... 4-8

Table 4 Demographic Characteristics ..................................................................................................... 4-12

Table 5 Summary of Correspondence and Responsiveness Summary ..................................................... 6-1


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ACRONYMS AND ABBREVIATIONS

μg/m3 micrograms per cubic meter NAAQS National Ambient Air Quality Standards AAQS Ambient Air Quality Standards NHPA National Historic Preservation Act AO Administrative Order NMAC New Mexico Administrative Code AQB Air Quality Bureau NMDGF New Mexico Department of Game and Fish BHI Bohannan-Huston Incorporated NMED New Mexico Environment Department BMP best management practices NMRPC New Mexico Rare Plants Technical Council BOD biological oxygen demand NO2 nitrogen dioxide CAA Clean Air Act NPDES National Pollutant Discharge Elimination System CEQ Council on Environmental Quality NRCS Natural Resources Conservation Service CGP Construction General Permit O3 ozone CH4 methane O&M operation and maintenance CO carbon monoxide PER preliminary engineering report CO2 carbon dioxide PLC programmable logic controller CO2e CO2-equivalent PM2.5 particulate matter less than 2.5 microns in diameter CWA Clean Water Act PM10 particulate matter less than ten microns in diameter EA environmental assessment ppm parts per million EIS environmental impact statement RAS return activate sludge EPA U.S. Environmental Protection Agency SHPO State Historic Preservation Officer FEMA Federal Emergency Management Agency SIP state implementation plan FIRM Flood Insurance Rate Map SO2 sulfur dioxide FONSI finding of no significant impact SRT solids retention time GHG greenhouse gas SWPPP storm water pollution prevention plan H2S hydrogen sulfide TSP total suspended particulates IFAS integrated fixed-film/activated sludge U.S. United States IPaC USFWS Information, Planning, and Consultation U.S.C. United States Code MBR membrane bioreactor retrofit USDA United States Department of Agriculture MBTA Migratory Bird Treaty Act USFWS U.S. Fish and Wildlife Service mg/L milligrams per liter VOC volatile organic compound MLSS mixed liquor suspended solids WRF Water Reclamation Facility


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CHAPTER 1 INTRODUCTION 1 1.1 SCOPE OF THE ENVIRONMENTAL INFORMATION DOCUMENT 2

The City of Bloomfield (the City) proposes to implement upgrades and expansion of their current Water 3 Reclamation Facility (WRF), located at 1176 South Church Street, west of Highway 550 and north of the 4 San Juan River (Figure 1). The WRF treats wastewater collected from the sewer service area located 5 generally within the city limits. Treated effluent is discharged to the San Juan River. 6

Improvements to the facility have now become imperative due to challenging conditions resulting in the 7 issuance of an Administrative Order (AO) by the United States (U.S.) Environmental Protection Agency 8 (EPA). The AO required completion of a preliminary engineering report (PER) by March 9, 2018. The 9 purposes of this PER were to update the previously generated information, such as population growth and 10 planned development, address issues at the WRF that have come up in recent years, evaluate alternatives 11 for repairing and/or replacing the deteriorated portions of the WRF, and consider reclaimed water as an 12 alternative water supply for irrigation purposes at sites adjacent to the WRF (Jacobs 2018). A PER was 13 delivered by Jacobs (formerly CH2M) in February 2018. 14

A technical memorandum was developed by Bohannan-Huston, Inc. (BHI) that finalizes the design basis 15 for the Bloomfield WRF improvements. The memorandum also reviews flow rates, coordinates with 16 equipment manufacturers, establishes process design details, estimates capital costs, and performs other 17 tasks (BHI 2019). 18

The purpose of this environmental information document (EID) is to document and disclose the 19 environmental impacts that would result from implementation of the proposed action. Relevant resources 20 include water resources, cultural resources, natural resources, socioeconomics, and land use. 21

1.2 DOCUMENT ORGANIZATION 22

The organization of this EID is as follows: 23

• Chapter 1 provides an overview of the EID. 24 • Chapter 2 describes the purpose and need for the proposed action. 25 • Chapter 3 summarizes the alternatives considered in the EID. 26 • Chapter 4 provides the affected environment and environmental consequences associated with 27

implementation of the preferred alternative and the no-action alternative. Cumulative impacts are 28 also provided in this chapter. 29

• Chapter 5 summarizes proposed mitigation measures. 30 • Chapter 6 lists agencies consulted during the EID process. 31 • Chapter 7 provides a list of preparers of the EID. 32 • Chapter 8 lists references cited in the EID. 33 • Appendix A provides information gathered to analyze potential impacts associated with the 34

proposed action. 35 • Appendix B provides governmental agency correspondence conducted for the EID. 36 • Appendix C summarizes the public involvement process conducted for the EID. 37


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1.3 REGULATORY DRIVERS AND GUIDANCE 1

1.3.1 The National Environmental Policy Act 2

The National Environmental Policy Act [(NEPA), 40 Code of Federal Regulations (CFR) Parts 1500-1508] 3 was signed into law on January 1, 1970. NEPA establishes national environmental policy and goals for the 4 protection, maintenance, and enhancement of the environment and provides a process for implementing 5 these goals within the federal agencies. NEPA also establishes the Council on Environmental Quality 6 (CEQ). 7

In 1978, CEQ promulgated regulations implementing NEPA, which are binding on all federal agencies. 8 The regulations address the procedural provisions of NEPA and the administration of the NEPA process. 9 To date, the only change in the NEPA regulations occurred on May 27, 1986, when CEQ amended Section 10 1502.22 of its regulations to clarify how agencies are to carry out their environmental evaluations in 11 situations where information is incomplete or unavailable. 12

The NEPA process consists of an evaluation of the environmental effects of a federal undertaking including 13 its alternatives. There are three levels of analysis: categorical exclusion determination; preparation of an 14 environmental assessment (EA) and finding of no significant impact (FONSI); and preparation of an 15 environmental impact statement (EIS). 16

In support of the NEPA process, an EID may be written to support federal grant applications or international 17 projects between the U.S. and Mexico or Canada. As defined by 40 CFR Section 6.102(b)(4), an EID is a 18 written analysis prepared by the applicant that provides enough information for the Responsible Official to 19 undertake an environmental review and prepare either an EA and FONSI or an EIS and Record of Decision 20 for the proposed action. An EID includes basic project information, including a description of the proposed 21 project, and evaluates the environmental impacts of the project and alternatives to the proposed project. 22

1.3.2 The Clean Air Act 23

The Clean Air Act [(CAA), 42 United States Code (U.S.C.) §7401 et. seq.] is the comprehensive federal 24 law that regulates air emissions from stationary and mobile sources. Among other things, this law authorizes 25 the EPA to establish National Ambient Air Quality Standards (NAAQS) to protect public health and public 26 welfare and to regulate emissions of hazardous air pollutants. The standards are expressed in micrograms 27 per cubic meter (μg/m3) or parts per million (ppm), over a specified time period. The six categories of 28 pollutants include sulfur dioxide, nitrogen dioxide, ozone, carbon monoxide, lead, and particulate matter, 29 including less than 10 microns and less than 2.5 microns in diameter (PM10 and PM2.5). 30

One of the goals of the CAA was to set and achieve NAAQS in every state by 1975 in order to address the 31 public health and welfare risks posed by certain widespread air pollutants. The setting of these pollutant 32 standards was coupled with directing the states to develop state implementation plans (SIPs), applicable to 33 appropriate industrial sources in the state, in order to achieve these standards. The New Mexico 34 Environment Department (NMED) Air Quality Bureau (AQB) is in place to protect the inhabitants and 35 natural beauty of New Mexico by preventing the deterioration of air quality. The AQB ensures that all 36 NAAQS are met through strategic planning, construction, and operating permits throughout New Mexico. 37


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1.3.3 The Clean Water Act 1

The Clean Water Act [(CWA), 33 U.S.C. §1251 et. seq.] establishes the basic structure for regulating 2 discharges of pollutants into the waters of the United States and regulating quality standards for surface 3 waters. The basis of the CWA was enacted in 1948 and was called the Federal Water Pollution Control Act, 4 but the Act was significantly reorganized and expanded in 1972. “Clean Water Act” became the Act's 5 common name with amendments in 1972. 6

Section 402 of the CWA made it unlawful to discharge any pollutant from a point source into navigable 7 waters, unless a permit was obtained. The EPA's National Pollutant Discharge Elimination System 8 (NPDES) permit program controls discharges. Point sources are discrete conveyances such as pipes or man-9 made ditches. Individual homes that are connected to a municipal system, use a septic system, or do not 10 have a surface discharge do not need an NPDES permit; however, industrial, municipal, and other facilities 11 must obtain permits if their discharges go directly to surface waters. 12

NPDES permits must incorporate the applicable effluent controls and normally require a storm water 13 pollution prevention plan (SWPPP) for any construction activity disturbing more than one acre of land, and 14 best management practices (BMP) for sediment control. In the State of New Mexico, compliance with 15 Section 402 includes coordination with the NMED in the form of a Water Quality Certification for the 16 NPDES permit. 17


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CHAPTER 2 PURPOSE AND NEED FOR THE PROPOSED ACTION 1 2.1 PROJECT DESCRIPTION 2

The City proposes to implement upgrades to their current WRF that will include the construction of new 3 aeration basins and digesters, as well as to install a new chlorine contact chamber. This proposed action 4 provides a combination of upgrading the plant process to both meet permit limits and increase operator 5 flexibility. This action would also lower operation and maintenance (O&M) costs. The proposed action also 6 includes upgrades to the headworks grease removal and upgrades to existing equipment. As part of the 7 proposed action, the City would construct a reclaimed water pump station and a reclaimed water storage 8 tank within the boundaries of the WRF property. 9

2.2 PURPOSE AND NEED FOR THE PROPOSED ACTION 10

The purposes of the WRF upgrades are to: 11

1. Improve the water quality of the WRF effluent; 12 2. Increase the capacity of the WRF; and 13 3. Provide a reclaimed water system that will use effluent water for soil compaction and backfill, dust 14

control, concrete mixing, and irrigation of roadway median landscaping and non-food crops. 15

The project is needed to meet effluent permit limits that are expected to become more stringent in the future, 16 as water quality standards for rivers and streams are further developed in accordance with the CWA to 17 protect aquatic wildlife and river uses. The proposed action would also meet future demands as the local 18 population increases over the next 20 years. 19


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CHAPTER 3 ALTERNATIVES 1 This chapter summarizes the process used to develop alternatives to the proposed action and describes these 2 alternatives in detail. Environmental impacts of alternatives other than the proposed action were evaluated 3 in the PER but eliminated from further consideration due to high costs and/or other design constraints. 4

3.1 RECLAMATION FACILITY IMPROVEMENTS ALTERNATIVES CONSIDERED 5

There are five alternatives considered in this EID; the no-action alternative and four action alternatives. The 6 four action alternatives focus on the secondary treatment process, following the primary filtration and 7 sedimentation processes. The alternatives are as follows: 8

• Alternative 1 (No-Action Alternative) – Under this alternative, no construction would occur at 9 the WRF. This alternative would not meet the need to optimize the existing WRF, even if the 10 structure could be reliably repaired because there is inadequate basin volume to support the required 11 solids retention time (SRT) for year‐round nitrification that is necessary to meet the 10 mg/L total 12 nitrogen standard and provide for stable year‐round operation. 13

• Alternative 2 (SEQUOX Process) – The SEQUOX Process originally invented in response to 14 failing package plant clarifiers by a professor at Kansas State University. The clarifier used in the 15 process is placed within rectangular basins constructed with common walls with the bioreactors. It 16 is of stainless-steel construction and consists of no moving parts. Mixed liquor from the bioreactors 17 is introduced along the entire length and at the bottom of the clarifier and therefore has the lowest 18 entrance velocity of any other available flow-through clarifier. The settled, thickened mixed liquor 19 is returned to the bioreactors using air lifts distributed along the entire length of the clarifier. The 20 clarifier is equipped with an effluent orifice weir to limit peak diurnal flows through the clarifier, 21 resulting in equalization of the peak flows in the bioreactors. 22

• Alternative 3 (Integrated Fixed-Film/Activated Sludge Retrofit) – The integrated fixed-23 film/activated sludge (IFAS) process modifies the existing aeration basins by equipping them with 24 floating media that makes up for the lack of volume in the basins by providing additional biomass 25 in the form of fixed film that grows on the media. IFAS is a process that has two SRT, one SRT for 26 the suspended growth and one SRT for the fixed film growth. As a result, the suspended growth 27 SRT is shorter than the other processes. 28

• Alternative 4 (Membrane Bioreactor Retrofit) – Under the membrane bioreactor retrofit (MBR) 29 alternative, existing aeration basins would be converted by equipping them with fine bubble 30 diffusers. The final clarifiers are replaced with new membrane tanks with submerged ultrafiltration 31 membranes, providing both clarification and a high degree of filtration of the effluent. The 32 membranes can operate at up to 12,000 mg/L mixed liquor suspended solids but the design value 33 is 10,000 mg/L. Returning this concentrated 1 percent return activate sludge (RAS) to the aeration 34 basins results in an operating mixed liquor suspended solids (MLSS) concentration of 8,000 mg/L 35 in the aeration basins. This is two to three times higher than a conventional activated sludge process, 36 thereby making up for the lack of volume in the existing basins to allow complete nitrification at 37 10˚C. 38

• Alternative 5 (Sequencing Batch Reactor) – In the sequencing batch reactor (SBR) process, all 39 biological and settling reactions are carried out in the same tank. Anaerobic cycles for phosphorus 40


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removal, anoxic cycles for nitrogen removal and aeration cycles for biological oxygen demand 1 (BOD) removal and nitrification are accomplished by turning the air on and off using 2 programmable logic controllers (PLCs). Settling of the biomass is done in a quiescent environment, 3 eliminating the issues associated with density currents in flow‐through clarifiers. 4

3.1.1 Comparison of Alternatives 5

In the 2018 PER, a decision model was developed by the City and the consultant to compare and evaluate 6 the monetary and non‐monetary benefits of each treatment alternative considered for the WRF 7 improvements. 8

The decision analysis process used to evaluate alternatives considered in the 2018 PER involved the 9 development of non‐monetary evaluation criteria, and the assignment of weight to each criterion by 10 individual City staff members. The individual criterion weighting was averaged to determine an overall 11 City staff weighting. Each alternative was then ranked using each non‐monetary criteria. Cost criteria were 12 used in a detailed and non‐biased benefit/cost analysis. Both cost and non‐monetary criteria were combined 13 in a multi‐attribute analysis spreadsheet model to develop relative benefit rankings for the wastewater 14 treatment alternatives under evaluation. The relative benefit rankings for each alternative was plotted and 15 reviewed. These non‐monetary criteria ranking combined with overall present worth costs to review and 16 select the best alternative. 17

The four non‐monetary criteria used in the evaluation of wastewater treatment alternatives are: 18

• Reliability/Redundancy: This criterion is used to evaluate the reliability of the wastewater 19 treatment and solids processing facilities. It encompasses issues such as mechanical reliability, 20 planned downtime, and consistent operation of equipment. It also addresses potential operational 21 limitations such as weather and security‐related issues. For this analysis, reliability is defined as 22 the tendency for minimal mechanical equipment failure resulting in downtime. 23

• Operational Flexibility/Adaptability: This criterion is used to rank the ability of the wastewater 24 treatment and solids processing equipment to accommodate changes in wastewater and solids 25 quantity and quality, including daily flow and loading variations. It also includes how the processes 26 can be adapted to changes in regulatory requirements, land use changes, and public opinion. 27

• Best Use of Existing Facilities: This criterion focuses on alternatives that use existing facilities to 28 reduce the overall capital costs. This is a benefit to the City. 29

• Maintenance Requirements: This criterion addresses the amount of time required for 30 maintenance personnel to keep the wastewater treatment and solids processing equipment running 31 properly and efficiently. It includes regular preventative maintenance, as well as unscheduled, 32 emergency efforts. It also addresses the complexity of the maintenance, in the terms of the amount 33 of parts involved, the amount of specialized equipment, and number of steps needed to perform the 34 work. 35

A workshop with City staff was held to review, analyze, and evaluate the alternatives. The decision model 36 tool was utilized to evaluate each alternative with the non‐monetary criteria and develop a comparison of 37 alternatives against one another. The scores are provided in detail in the 2018 PER. 38


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Alternative 1 – the no-action alternative was deemed impractical, since this alternative will not address the 1 following: 1) issues with the WRF nearing its treatment capacity, 2) ability of the City to continue to comply 2 with the discharge permit, 3) high O&M costs, and 4) improvements that are needed at the WRF. 3

Alternative 3 – IFAS was not recommended since this option has only one treatment train so there is no 4 redundancy. As part of a 2009 PER, the IFAS alternative had two parallel treatment trains; however, the 5 alternative required construction of new digester tanks as well as a third secondary clarifier. The 2018 PER 6 has a lower design flow than the 2009 PER, so the current alternative retains two of the digester tanks and 7 does not need the third clarifier. The concept as presented during the evaluation workshop could be 8 modified to have two parallel trains, but it would require either building two additional walls in the 9 repurposed digester tanks to split it into an anoxic/oxic configuration or operating that cell in an alternating 10 aeration mode. 11

The City staff expressed concern over oil discharges from nearby oil fields that get into sewer system and 12 would affect membranes for Alternative 4 – MBR. This alternative may not be feasible since these oil type 13 discharges would plug the fine screen and then affect the membranes. Additionally, there is a concern over 14 storm surges that the WRP experiences. The membranes would have to be sized to accommodate the peak 15 flowrate, and so the MBR alternative was determined to not have enough flexibility as required for the City. 16

Thus, Alternative 2 – Aeromod and Alternative 5 – SBR were deemed to be the most advantageous for the 17 City. In Fall 2017, City staff visited several installations in New Mexico for both treatment technologies. 18 Consultations with operations staff of both types of systems and consideration for City priorities, the City 19 preferred the SBR treatment technology. Based upon the advantages and disadvantages included in the 20 2018 PER, Alternative 5 – SBR was determined to be the preferred WRF improvement alternative. 21

3.2 RECLAIMED WATER SYSTEM DESCRIPTION 22

Reclaimed water will be diverted from the effluent pipe downstream of the chlorine contact chamber and 23 prior to the effluent flow meter and dechlorination station. From this point water will be pumped to the tank 24 for storage. A fill pump station will be located next to the storage tank and pump water to the bulk truck 25 fill stand. These facilities will be located on the west side of the WRF adjacent to the existing potable water 26 fill drive path. The existing fence will be relocated adjacent to the sludge beds to widen the existing 27 driveway to accommodate both potable and reclaimed water fill stations. 28

If in the future, Class 1A effluent quality is desired, a tertiary filter can be installed after the SBR basins 29 and before the chlorination basin. The tertiary filter will need to be a non-pressurized filtration system such 30 as a cloth filter, in order to avoid additional pumping. A maximum headloss of 2 feet was allocated in the 31 hydraulic profile for this purpose. 32

The Class 1A effluent reclaimed water system could involve installation of a distribution system outside 33 the WRF property boundaries. However, this is beyond the scope of this EID and would require further 34 environmental review should this be proposed in the future. 35

3.3 DESCRIPTION OF THE PREFERRED ALTERNATIVE (PREFERRED ALTERNATIVE) 36

The preferred alternative would involve the installation of three parallel SBR trains and would consist of 37 the following process modifications: 38


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• Construction of a new equipment enclosures at the headworks, providing protection from freezing 1 temperatures. 2

• Construction of a new skimmers in the head works pump wet well to capture grease. 3 • Adding hydrocyclone to grit classifier to allow operation of grit pump at full speed. 4 • Modification of headworks effluent pumps discharge piping to convey screened, de-gritted influent 5

to SBR. 6 • Construction of three new SBR tanks and equipping with aeration diffusers, mixers, effluent 7

decanters and submersible pumps to pump waste activated sludge from SBR to the digesters. 8 • Abandonment of both existing aeration basins. 9 • Conversion of one existing clarifier to a toxic flow containment tank. 10 • New digested sludge pumps would be installed. 11 • Abandonment of existing RAS pump station. 12

Full description of these processes is provided in the 2018 PER and the 2019 design basis technical 13 memorandum (Jacobs 2018, BHI 2019). 14

3.4 ALTERNATIVE CONSIDERED BUT ELIMINATED FROM FURTHER CONSIDERATION 15

In a 2009 PER, construction of a new WRF was considered as an alternative to improvements to the 16 secondary wastewater treatment basins. This alternative was eliminated from further consideration due to 17 much higher capital costs with limited benefits over the other alternatives. 18


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CHAPTER 4 AFFECTED ENVIRONMENT AND ENVIRONMENTAL 1 CONSEQUENCES 2

The City of Bloomfield, located in northwest New Mexico, is a community with less than 10,000 persons 3 that relies on the San Juan River for its drinking water and as a receiving stream for its treated wastewater 4 effluent. The Bloomfield WRF is located at 1176 South Church Street, west of Highway 550 and north of 5 the San Juan River. The WRF treats wastewater collected from the sewer service area located generally 6 within the City limits, which encompasses over 3,200 acres. Treated effluent is discharged to the San Juan 7 River. 8

4.1 LAND USE 9

4.1.1 Affected Environment 10

The WRF is located on a 13.75-acre fenced parcel of land owned by the City that is shared by the Municipal 11 Operations Center. The WRF is located on the northern half of the parcel, with the MOC to the south. All 12 actions associated with the preferred alternative would be conducted within the northern half of this parcel. 13 Most land in the vicinity of the WRF is privately owned and zoned for residential purposes. Figure 1 14 provides an overview of the land ownership near the Bloomfield WRF, and a San Juan County Assessor’s 15 Office map of the area is provided in Appendix A. 16

A search for formally classified lands within the vicinity of the Bloomfield WRF was conducted using a 17 variety of state and federal agency websites. The project area is located approximately 9 miles south of the 18 Aztec Ruins National Monument (NPS 2019). Navajo Lake State Park is located approximately 22 miles 19 northeast of the WRF (EMNRD 2019). No other state or national parks, designated wild and scenic rivers, 20 or national grasslands are located within the vicinity of the Bloomfield WRF (EMNRD 2019, IWSRC 2019, 21 NPS 2019, USFWS 2019). 22

4.1.2 Environmental Consequences 23

4.1.2.1 Preferred Alternative 24

Under the preferred alternative, no changes to area land use would occur. There would be no long-term 25 impacts to residential or agricultural land use as a result of the proposed action. No displacement of the 26 local population or long-term alteration of the physical residential environment would occur. No impacts 27 to formally classified lands would be impacted by implementation of the preferred alternative. 28

4.1.2.2 No-Action Alternative 29

No impacts to land use would occur as a result of the no-action alternative. 30

4.2 SOILS 31


The United States Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) 33 Web Soil Survey was queried to identify the soils in the vicinity of the Bloomfield WRF. NRCS soil reports 34


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for the WRF property are provided in Appendix A. Four soil units were identified for the project area. Table 1 1 provides a summary of the soils in the area. 2

Table 1 Soil Units Present at the WRF Site 3 Soil Unit Name Farmland Classification Percent of Area of Interest

Apishapa clay loam Farmland of statewide importance 10% Green River fine sandy loam Farmland of statewide importance 56% Walrees loam Farmland of statewide importance 14% Werlog loam, saline-alkali Farmland of statewide importance 20%

Source: NRCS 2019. 4

The WRF soils are somewhat poorly drained, except for the Apishapa clay loam which is poorly drained 5 (NRCS 2019). The soils are classified as “farmland of statewide importance.” This classification indicates 6 the land does not meet the criteria for prime or unique farmland but can be used for the production of food, 7 feed, fiber, forage, and oilseed crops (NRCS 2019). During construction of the Headworks Facility in 2005, 8 some limestone rock was encountered that required some adjustments in construction (Jacobs 2018). 9



The Bloomfield WRF property is entirely on disturbed land. Although the underlying soils are considered 12 “farmland of statewide importance,” the proposed action would not result in the conversion of agricultural 13 land to non-agricultural purposes. No soil impacts or impacts to prime/unique farmland would result 14 through implementation of the preferred alternative. 15


No impacts to soils or prime/unique farmland would occur as a result of the no-action alternative. 17

4.3 FLOODPLAINS 18


The Bloomfield WRF is designated as Zone X by the Federal Emergency Management Agency (FEMA) 20 Flood Insurance Rate Map (FIRM) No. 35045C1055F. Zone X consists of areas determined to be outside 21 the 1 percent and 0.2 percent annual chance of flooding. Adjacent to the south portions of the MOC is 22 within Zone A, which includes areas inundated by 1 percent chance of annual flooding, for which no flood 23 elevations have been determined (FEMA 2008). Appendix A provides a portion of the FEMA FIRM 24 including the Bloomfield WRF. 25



The WRF project area is outside the 100-year floodplain. As such, there are no potential erosion impacts 28 and impacts to floodplain areas. 29


No floodplain impacts would be associated with the no-action alternative. 31


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4.4 WETLANDS 1

Wetlands are lowland areas inundated or saturated with water for a sufficient time to allow a prevalence of 2 hydrophytic vegetation to develop. Jurisdictional wetlands, those protected from unauthorized dredge-and-3 fill activities under Section 404 of the CWA and Executive Order 11990, have the following three essential 4 characteristics: dominance by hydrophytic vegetation, hydric soils, and wetland hydrology. Hydrophytic 5 vegetation requires inundated or saturated soil for its existence. Hydric soils are ponded or flooded for a 6 sufficient time during the growing season to develop anaerobic conditions. Wetland hydrology is the 7 availability of surface water or ground water to create the wetland environment. 8


The U.S. Fish and Wildlife Service (USFWS) National Wetlands Inventory was reviewed for information 10 regarding wetlands within the vicinity of the Bloomfield WRF. There is a small tamarisk wetlands area 11 outside the WRF boundaries, northwest of the fenced area. A larger tamarisk wetlands along the San Juan 12 River, south of the WRF property (USFWS 2019). 13



The proposed project is in near proximity to the San Juan River and its associated wetlands. However, there 16 are no wetlands within the WRF property. No impacts to wetlands would result through implementation of 17 the proposed action. 18


There would be no wetlands impacts associated with the no-action alternative. 20

4.5 WATER RESOURCES 21


This section provides a summary of the major aquifers, surface water resources, and groundwater resources 23 in the vicinity of the Bloomfield WRP. 24

4.5.1.1 Surface Water 25

The EPA governs surface water discharges as mandated by the CWA under their NPDES and typically 26 require Construction General Permit (CGP) coverage for stormwater discharges from construction projects 27 resulting in the disturbance of 1 or more acres of total land area. The CGP will include a SWPPP. The San 28 Juan River is approximately 150 feet south of the Bloomfield WRF. The Bloomfield area is located within 29 the Upper San Juan Watershed, as defined by the NRCS (NRCS 2002). There are no other waterways, 30 arroyos, irrigation ditches, or laterals within the WRF vicinity. 31

4.5.1.2 Groundwater 32

A declared groundwater basin is an area of the state proclaimed by the State Engineer to be underlain by a 33 groundwater source having reasonably ascertainable boundaries. By such proclamation the State Engineer 34 assumes jurisdiction over the appropriation and use of groundwater from the source. The New Mexico 35 portion of the Upper San Juan watershed is completely within the San Juan Underground Water Basin. The 36


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surface watershed within the state covers 1,150,430 of the approximately 6.25 million acres of the 1 underground water basin in New Mexico (NRCS 2002). Depth to groundwater is shallow, typically 6 to 9 2 feet below ground surface, due to the site’s proximity to the San Juan River (Jacobs 2018). 3



During construction runoff from the Bloomfield WRF could reach the San Juan River. Protective measures 6 as specified in the CGP and SWPPP will be implemented to minimize impacts to surface water resources 7 during the construction phase. Once operational, the preferred alternative will result in better water quality 8 effluent and will have positive surface water effects downstream. 9

The shallow water table will be encountered during construction at the Bloomfield WRF. These resources 10 are not used for drinking water, and BMPs will be implemented to minimize any contaminant migration to 11 the San Juan River. 12


Under the no-action alternative, no new impacts to water resources would occur. However, the treated 14 effluent may not meet future NPDES standards. 15

4.5.2.3 Mitigations 16

Because the proposed project would disturb more than 1 acre, appropriate NPDES permit coverage is 17 required prior to beginning construction. As required by the EPA all “operators” must obtain NPDES permit 18 coverage for construction projects. Generally, this means that at least two parties will require permit 19 coverage. The owner/developer of this construction project (the City) who has operational control over 20 project specifications and the general contractor who has day-to-day operational control of those activities 21 at the site, which are necessary to ensure compliance with the SWPPP and other permit conditions, and 22 possibly other “operators” will require appropriate NPDES permit coverage for this project. 23

Temporary construction-related impacts to surface water quality will be avoided or minimized by 24 complying with the NPDES permit requirements and implementing a SWPPP. Appropriate BMPs would 25 be implemented and maintained both during and after construction to prevent, to the extent practicable, 26 pollutants (primarily sediment, wastewater, oil and grease, and construction materials) in stormwater runoff 27 from entering waters of the U.S. 28

Construction contractors will ensure that groundwater contamination would be avoided through proper 29 handling and storage of petroleum products, chemicals, toxic substances, and hazardous materials. 30 Accidental discharges would be reported to NMED in compliance with 20.6.2.1203 New Mexico 31 Administrative Code (NMAC). 32

As the proposed action would result in increased design capacity, the WRF NPDES permit will require that 33 an Antidegradation Review be conducted, as specified in the State Water Quality Standards (20.6.4 34 NMAC). 35


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4.6 COASTAL RESOURCES 1

There are no coastal resources in New Mexico as defined by the Coastal Zone Management Act (16 U.S.C 2 §§1451-1646). As such, this resource area is not discussed further in this EID. 3

4.7 AIR QUALITY AND CLIMATE 4

The principal framework of national, state, and local efforts to protect air quality in the United States is the 5 Clean Air Act (42 U.S.C. § 7401 et seq., [CAA]). Under the CAA, the EPA has set health-based standards 6 known as National Ambient Air Quality Standards (NAAQS) for six criteria pollutants considered to be 7 key indicators of air quality: carbon monoxide (CO), nitrogen dioxide (NO2), ozone (O3), sulfur dioxide 8 (SO2), lead (Pb), and two categories of particulate matter—namely particulate matter with an aerodynamic 9 diameter of 10 microns or less (PM10) and particulate matter with an aerodynamic diameter of 2.5 microns 10 or less (PM2.5) (40 CFR Part 50). 11

The primary NAAQS define levels of air quality, with an adequate margin of safety that sets limits to protect 12 the public health (i.e., “health-based”). The secondary NAAQS define levels of air quality judged necessary 13 to protect the public welfare from any known or anticipated adverse effects of a pollutant, including 14 protection against decreased visibility and damage to animals, crops, vegetation, and buildings (i.e., 15 “welfare-based”). 16

The EPA is responsible for ensuring that all air quality standards are met or attained in cooperation with 17 state, tribal, and local governments through national strategies to control air pollutant emissions. Under the 18 CAA, state and local agencies may establish state Ambient Air Quality Standards (AAQS) of their own, 19 provided these are at least as stringent as the Federal requirements. As delegated by the EPA, the State of 20 New Mexico is responsible for protecting New Mexico’s air quality. In turn, NMED AQB is responsible 21 for interpreting and implementing those statutes that pertain to air pollution control. The State of New 22 Mexico has thereby established its own AAQS equivalent to the NAAQS for PM10, O3, and Pb. The State 23 of New Mexico’s AAQS are more restrictive than Federal NAAQS for these three air pollutants: CO, NO2, 24 and SO2. In addition, New Mexico regulates emissions of total suspended particulates (TSP), hydrogen 25 sulfide (H2S), and total reduced sulfur, three pollutants for which there are no Federal standards. Pertinent 26 State regulations are found in Title 20, Chapter 2, Part 3 of the NMAC 20.2.3.1 to 20.2.3.11 issued by the 27 Environmental Improvement Board on September 6, 2006. Federal NAAQS and State of New Mexico 28 AAQS are shown in Table 2. 29


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Table 2 National and State of New Mexico Ambient Air Quality Standards 1

Pollutant NAAQS New Mexico State AAQS Standard Type1 Carbon monoxide (CO)

8-hour average2 9 ppm Primary 8.7 ppm 1-hour average2 35 ppm Primary 13.1 ppm

Nitrogen dioxide (NO2) Annual arithmetic mean 0.053 ppm Primary & Secondary 0.05 ppm

24-hour average None None 0.10 ppm Ozone (O3)

8-hour average3 0.075 ppm Primary & Secondary None4 Lead (Pb)

Quarterly average 1.5 μg/m3 Primary & Secondary None4 Fine particulate matter (PM2.5) Annual arithmetic mean5 15 μg/m3 Primary & Secondary None4

24-hour average6 35 μg/m3 Primary & Secondary None4 Particulate matter (PM10)

24-hour average7 150 μg/m3 Primary & Secondary None4 Sulfur Dioxide (SO2) Annual arithmetic mean 0.03 ppm Primary 0.02 ppm8

24-hour average 0.14 ppm Primary 0.10 ppm8 3-hour average 0.50 ppm Secondary None4

Hydrogen Sulfide (H2S) 1-hour average9 None None 0.10 ppm Total Reduced Sulfur

Half-hour average10 None None 0.003 ppm Total Suspended Particulates (TSP) Annual arithmetic mean None None 60 μg/m3

30-day average None None 90 μg/m3 7-day average None None 110 μg/m3

24-hour average None None 150 μg/m3 1. Primary Standards are “health-based,” and Secondary Standards are “welfare-based.” 2 2. Not to be exceeded more than once per year. 3 3. To attain this standard, the three-year average of the fourth-highest daily maximum eight-hour average ozone concentrations measured 4

at each monitor within an area over each year must not exceed 0.075 ppm. 5 4. When no state AAQS exists, the NAAQS applies. 6 5. To attain this standard, the three-year average of the weighted annual mean PM2.5 concentrations from single or multiple community-7

oriented monitors must not exceed 15.0 μg/m3. 8 6. To attain this standard, the three-hour average of the 98th percentile of 24-hour concentrations at each population-oriented monitor 9

within an area must not exceed 35 μg/m3. 10 7. Not to be exceeded more than once per year on average over three years. 11 8. For the entire State of New Mexico except for the area within 3.5 miles of the Chino Mines Company smelter furnace stack near Hurley 12

where higher levels (same as NAAQS) apply. 13 9. 1-hour average not to be exceeded more than once a year. For the entire State of New Mexico, except for those parts of the Pecos-14

Permian Basin Intrastate Air Quality Control Region where higher levels apply. 15 10. Total reduced sulfur does not include H2S. Applies to the entire State of New Mexico except for those parts of the Pecos- Permian Basin 16

Intrastate Air Quality Control Region where higher levels are in effect. 17 Sources: 40 CFR Part 50, NMAC 20.2.3.1 to 20.2.3.11 18

Greenhouse gases (GHGs) are pollutants of concern for air quality and climate change. GHGs include water 19 vapor, carbon dioxide (CO2), methane (CH4), NO2, O3, and several chlorofluorocarbons. Water vapor is a 20 naturally occurring GHG and accounts for the largest percentage of the greenhouse effect. Next to water 21 vapor, CO2 is the second-most abundant GHG and is typically produced from human related activities. The 22 largest source of CO2 emissions globally is the combustion of fossil fuels such as coal, oil, and gas in power 23


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plants, automobiles, industrial facilities, and other sources. Additionally, a number of specialized industrial 1 production processes and product uses such as mineral production, metal production and the use of 2 petroleum-based products can also lead to CO2 emissions. 3

Although regulatory agencies are taking actions to address GHG effects, there are currently no state or 4 federal standards or regulations limiting CO2 emissions and concentrations in the ambient air. In response 5 to the FY2008 Consolidated Appropriations Act (House Bill 2764; Public Law 110–161), EPA issued the 6 Final Mandatory Reporting of Greenhouse Gases Rule (GHG Reporting Rule), which became effective on 7 December 29, 2009. The GHG Reporting Rule requires annual reporting of GHG emissions to EPA from 8 large sources and suppliers in the U.S., including suppliers of fossil fuels or industrial GHG; manufacturers 9 of vehicles and engines; and facilities that emit greater than 25,000 metric tons per year (27,558 tons per 10 year) each of CO2 and other GHGs. The intent of the rule is to collect accurate and timely emissions data 11 to inform future policy decisions and programs to reduce emissions, as well as fight against the effects of 12 climate change. 13

In a draft guidance document, the CEQ proposes that federal agencies consider, in scoping their NEPA 14 analyses, whether analysis of the direct and indirect GHG emissions from their proposed actions may 15 provide meaningful information to decision makers and the public. Specifically, if a proposed action would 16 be reasonably anticipated to cause direct emissions of 25,000 metric tons per year or more of CO2-17 equivalent (CO2e) GHG emissions, agencies should consider this an indicator that a quantitative and 18 qualitative assessment may be meaningful to decision makers and the public. For long-term actions that 19 have annual direct emissions of less than 25,000 metric tons of CO2e, the CEQ encourages federal agencies 20 to consider whether the action’s long-term emissions should receive similar analysis. Furthermore, the CEQ 21 does not propose this as an indicator of a threshold of significant effects, but rather as an indicator of a 22 minimum level of GHG emissions that may warrant some description in the appropriate NEPA analysis for 23 agency actions involving direct emissions of GHGs. This guidance was revised in 2014, with the same 24 guidance recommendations (CEQ 2014). 25

Federal agencies are, on a national scale, addressing emissions of GHGs by reductions mandated in federal 26 laws and Executive Orders, most recently, Executive Order 13514. Several states have promulgated laws 27 as a means to reduce statewide levels of GHG emissions. In particular, the California Global Warming 28 Solutions Act of 2006 directs the State of California to reduce statewide GHG emissions to 1990 levels by 29 the year 2020. In addition, groups of states formed regionally based collectives to jointly address GHG 30 pollutants. 31

GHG emissions for an action can be inventoried, based on methods prescribed by state and federal agencies. 32 However, the specific contributions of a particular project to global or regional climate change generally 33 cannot be identified based on existing scientific knowledge, because individual projects typically have a 34 negligible effect. Also, climate processes are understood at only a general level. 35


4.7.1.1 Attainment Status 37

All of San Juan County, including Bloomfield, is in an attainment area for all criteria air pollutants. The 38 New Mexico portion of the Four Corners Interstate Air Quality Control Region 014 is composed of San 39 Juan County in its entirety, that portion of McKinley County west of the Continental Divide, that portion 40


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of Rio Arriba County lying west of the Continental Divide, all areas of the Jicarilla Apache reservation, and 1 that portion of Valencia County lying within the Zuni and Ramah Navajo Reservation. 2

4.7.1.2 Regional Meteorology 3

Air quality is closely intertwined with day-to-day meteorological weather conditions and the influences of 4 longer-term climate. Concentrations of atmospheric air pollutant gases/species can be influenced by 5 meteorological variables, e.g., wind speed which affects dispersion of particulates from soils; wind direction 6 and speed which affects transportation; mixing depths and stability which affect dispersion; and 7 temperature, humidity, sunlight, and cloud water which can play a role in the chemical formation of certain 8 air pollutants. Table 3 provides a summary of the Bloomfield area climate. 9

Table 3 Bloomfield Climate Summary 10

Averages Month

Annual Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Max Temp1 41.1 48.4 57.7 67.4 77.4 88.0 92.1 89.1 81.7 69.3 54.8 43.1 67.5 Min Temp1 16.3 22.2 27.9 34.8 43.4 51.8 59.4 57.8 49.2 37.4 25.6 17.8 37.0 Precipitation2 0.57 0.59 0.66 0.63 0.51 0.37 1.00 1.28 0.95 0.95 0.62 0.59 8.71 Snowfall2 3.8 2.8 1.1 0.4 0.0 0.0 0.0 0.0 0.0 0.1 0.6 3.5 12.3

1. In degrees Fahrenheit 11 2. In inches 12

Source: WRCC 2019 13



Dust and exhaust emissions produced by construction equipment and vehicles would result in temporary 16 and minor increases in CO, NO2, SO2, and volatile organic compounds (VOCs). Increased dust and locally 17 elevated levels of particulate matter may be created downwind of construction activities. The project would 18 not affect the attainment status for San Juan County and the greater region. No emissions would be 19 generated at levels that would require a permit from NMED. No violations of NAAQS would occur as a 20 result of project construction. 21


No impacts to climate or air quality would be associated with the no-action alternative. 23


To minimize air pollution impacts during construction, construction contractors would ensure that the 25 following practices are implemented: 26

• Exposed and disturbed soils will be watered at a frequency sufficient to avoid fugitive dust; 27 • Earthmoving and other dust-producing activities will be suspended during periods of high winds, 28

when dust control efforts are unable to prevent fugitive dust; 29 • All stockpiles of debris, soil, sand, or other materials will be watered or covered; 30 • Construction areas and adjacent roads will be swept or cleared of mud and debris; 31 • Materials transported on-site by truck will be covered; and 32


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• All construction equipment will be required to use approved emission control devices and limit 1 unnecessary idling. 2

If a standby electrical generator is used at the facility, it should be kept of the hours of operation of the 3 generator. An application for a construction permit must be submitted for stand by generators used 500 4 hours per year or more. 5

All asphalt, concrete, quarrying, crushing, and screening facilities contracted in conjunction with the 6 proposed project must have current and proper air quality permits. 7

4.8 BIOLOGICAL RESOURCES 8


The Bloomfield WRF is located within the Colorado Plateau Mixed Grass Plains Unit of the Colorado 10 Plateau Province, which is characterized by flat to gently dipping sedimentary rocks eroded into plateaus, 11 valleys and deep canyons. Volcanic fields occur in places. Elevations range from 5,100 to 6,000 feet. 12 Precipitation averages 10 to 14 inches per year. The soil temperature regime is mesic. The soil moisture 13 regime is ustic aridic (NRCS 2002). 14

4.8.1.1 Vegetation 15

Vegetation of the Colorado Plateau Mixed Grass Plains Unit includes stipa (Stipa spp.), Indian rice grass 16 (Achnatherum hymenoides), blue grama (Bouteloua gracilis), fourwing saltbush (Atriplex canescens), and 17 scattered juniper (Juniperus monosperma) (NRCS 2002). Along the San Juan River near the WRF, tamarisk 18 is the dominant species present. 19

The Bloomfield WRF property is denuded of vegetation. 20

4.8.1.2 Wildlife 21

Some of the common wildlife species that can be found in the Bloomfield area are elk (Cervus canadensis), 22 mule deer (Odocoileus hemionus), pronghorn antelope (Antilocapra Americana), mountain lion (Puma 23 concolor), coyote (Canis latrans), fox, bobcat (Lynx rufus), badger (Taxidea taxus), skunk, rabbit, prairie 24 dog (Cynomys spp.), bats, eagles, hawks, owls, crow (Corvus spp.), woodpecker, bluebird, and swallow. 25 Given the urban nature of Bloomfield and the fact that the project site is fenced in, only small burrowing 26 mammals are the only mammals likely to be found within the WRF property boundaries. 27

4.8.1.3 Threatened and Endangered Species 28

Three agencies have primary responsibility for protecting and conserving plant and animal species within 29 the proposed project area. The USFWS, under authority of the Endangered Species Act of 1973 (16 U.S.C. 30 1531), as amended, has the responsibility for federally listed species. The New Mexico Department of 31 Game and Fish (NMDGF) has the responsibility for state-listed wildlife species. The New Mexico Rare 32 Plants Technical Council (NMRPTC) has responsibility for state-listed endangered plant species. Each 33 agency maintains a continually updated list of species that are classified, or are candidates for classification, 34 as protected based on their present status and potential threats to future survival and recruitment into viable 35 breeding populations. These types of status rankings represent an expression of threat level to a given 36 species’ survival as a whole and/or within local or discrete populations. 37


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A query of the USFWS Information, Planning, and Consultation (IPaC) system indicates that seven 1 threatened or endangered animal species and three threatened or endangered species have the potential to 2 occur within the project area vicinity. NMDGF lists five endangered and eight threatened animal species 3 occurring in San Juan County. The New Mexico Rare Plant List identifies 19 plant species that potentially 4 occur in San Juan County. None of the listed plant or animal species are expected within the project area 5 due to existing development, lack of habitat, and human activities. Threatened and endangered species lists 6 are provided in Appendix A. 7

The Migratory Bird Treaty Act [(MBTA), 16 U.S.C. §§ 703-712], as amended, prohibits taking of any 8 migratory bird, parts, nests, or eggs unless authorized under a permit issued by USFWS. The MBTA 9 protects birds from harm and harassment. The Bald and Golden Eagle Protection Act (16 U.S.C. § 668-10 668c), as amended, prohibits anyone, without permit issued by the Secretary of the Interior, from “taking” 11 bald or golden eagles, including their parts, nests, or eggs. 12

Correspondence with NMDGF indicates that the agency “does not anticipate significant impacts to wildlife 13 or sensitive habitats” within the project area. Special status species that that potentially occur in San Juan 14 County and may occur near the proposed project area are listed in “New Mexico Wildlife of Concern.” 15 Correspondence with the USFWS, NMDGF, and NMRPTC is provided in Appendix B. 16



The Bloomfield WRF is denuded of vegetation. Implementation of the preferred alternative would not result 19 in the loss of any vegetation or habitat for sensitive species. Migratory birds may transit the WRF and nest 20 in some of its structures. It is recommended that surveys for migratory birds and nests be conducted prior 21 to construction activities. 22

Impacts to threatened and endangered wildlife species would be highly localized and temporary, as animal 23 species that live or transit the San Juan River area would be impacted by increased noise due to construction 24 activities. No threatened and endangered plant species would be affected by the preferred alternative, as 25 none are present within the Bloomfield WRF boundaries. 26


The no-action alternative would not affect area biological resources. 28


If ground disturbance is scheduled to occur during the nesting season, a preconstruction nest survey is 30 recommended to determine whether occupied nests are present. If occupied nests would be taken by project 31 activities, a USFWS permit would be required prior to construction. 32

4.9 ARCHAEOLOGICAL, CULTURAL, AND HISTORIC RESOURCES 33

Potential impacts on cultural resources are assessed through the Section 106 process of the National Historic 34 Preservation Act (NHPA) of 1966. Cultural resources are evaluated in consultation with the State Historic 35 Preservation Officer (SHPO) at the New Mexico Historic Preservation Division. The consultation process 36


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identifies historic properties that could be potentially affected by the project, and determines approaches to 1 avoid, minimize, or mitigate any adverse effects. 2


The proposed action would be conducted entirely within the property boundaries of the Bloomfield WRF, 4 which is an extremely disturbed area. Due to the disturbed nature of the property, no cultural resource 5 survey was conducted of the WRF, and SHPO was contacted for confirmation that surveys were not 6 warranted at this time. 7



No effects to historic properties are anticipated due to implementation of the preferred alternative. However, 10 if the project falls under Section 106 of the NHPA, it is recommended that the funding proponent initiate 11 formal consultation with the SHPO. 12


Cultural resources would not be affected under the no-action alternative. 14

4.10 SOCIOECONOMICS AND ENVIRONMENTAL JUSTICE 15


For the purposes of this EID, socioeconomics refers to the social and economic environment of Bloomfield 17 and San Juan County, including growth rate, labor force, employment, income, and other economic 18 indicators. The region of potential impact for socioeconomics is the area where the direct and indirect 19 effects of activities associated with the proposed action would occur. Analysis of social impacts includes 20 factors such as disproportionate impacts on particular population groups, loss of community cohesion, 21 changes in accessibility of facilities and services, and displacement of people. Economic impacts include 22 effects on business and employment, the local tax base, and other factors such as residential development 23 in relation to local economic conditions. 24

In 2017, the average per-capita income of Bloomfield was $21,462, and San Juan County had an average 25 per-capita income of $22,665. Both of these were lower than the statewide average of $25,257. The 26 estimated median household income for Bloomfield in 2017 was $55,372 and $49,686 for San Juan County. 27 Both were also higher than the median household income state average of $46,718. In addition, 28 approximately 20 percent of Bloomfield’s population lives below the poverty threshold. Table 4 provides 29 summarized data on population groups and economic status at state, county, and Bloomfield levels from 30 the 2010 Census and 2017 projections (USCB 2019). 31



Under the preferred alternative, no residents or businesses would be relocated. No adverse effects would 34 occur for residents within any of the census tracts. The proposed project would provide a higher quality 35 treated effluent for residents of Bloomfield, without favoritism or discrimination. The proposed project is 36 considered consistent with environmental justice policies and would be expected to benefit residents. 37


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Under the no-action alternatives, there would be no improvements to the Bloomfield WRF, which would 2 possibly not meet future NPDES permit limits and would not meet higher wastewater treatment demands 3 associated with population growth projections. 4

Table 4 Demographic Characteristics 5 New Mexico San Juan County Bloomfield

Total Population 1 2,088,070 126,962 7,956 Racial and Age Characteristics 2 New Mexico San Juan County Bloomfield White 82.2% 54.9% 63.6% Black 2.5% 0.8% 0.0% American Indian/Alaska Native 10.9% 40.9% 26.0% Asian 1.7% 0.6% 0.3% Native Hawaiian/Other Pacific Islander 0.2% 0.1% 0.0%

Hispanic or Latino Origin 48.8% 20.2% 37.4% Other/Two or More Races 2.5% 2.8% 2.4% White Persons not Hispanic 37.5% 38.4% 36.2% Persons under 5 Years 6.1% 7.0% 10.5% Persons under 18 Years 23.4% 27.1% 32.0% Persons 65 Years and Over 16.9% 14.3% 13.3% Income Statistics 3 New Mexico San Juan County Bloomfield Per capita Money Income (2017) $25,257 $22,665 $21,462 Persons per Household 2.65 3.01 3.12 Median Household Income $46,718 $49,686 $55,372 Persons Below Poverty Level 19.7% 23.1% 19.6%

Source: USCB 2019. 6 Notes: 7

1. Based upon projections for 2017. 8 2. Based upon Census 2010 data. 9 3. Based on 2013-2017 data. 10

4.11 OTHER RESOURCES 11

4.11.1.1 Public Health and Safety 12

Affected Environment 13

Residential neighborhoods are located within the vicinity of the Bloomfield WRF. The WRF is surrounded 14 by security fencing, and access to the site is controlled. The Bloomfield WRF meets current NPDES permit 15 standards. 16

Environmental Consequences 17

Preferred Alternative 18 Under the preferred alternative, all construction activities would be conducted within the Bloomfield WRF 19 property boundaries. Access to the site will be controlled, ensuring that no unauthorized access to the site 20 is allowed. Once operational, the improvements and upgrades will result in better quality effluent and will 21 lead to positive human health and safety. 22


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No-Action Alternative 1 Under the no-action alternative, no improvements or upgrades to the Bloomfield WRF would occur. 2 Negative impacts to public health and safety could occur should increased demand exceed the WRF 3 wastewater treatment capacity. 4

4.11.1.2 Energy Resources 5


Irreversibly and irretrievably committed resources associated with the project are primarily the materials 7 needed for construction of the project and fossil fuels and energy resources needed to operate and maintain 8 the Bloomfield WRF. 9


Preferred Alternative 11 Temporary increases in fossil fuel consumption and electricity usage would occur during construction 12 activities associated with the preferred alternative. Implementation of the SBR secondary treatment process 13 will result in much lower energy consumption and would lead to positive energy resources impacts (Jacobs 14 2018). 15

No-Action Alternative 16 The no-action alternative would result in no impact on energy resources. 17

4.11.1.3 Transportation 18


The Bloomfield WRF is accessed by Church Street, which is adjacent to the project area on the west side 20 of the WRF. Church Street merges into Calle del Rio, as it turns east along the south side of the City 21 property, where the WRF is located. Highway 550 is a major north-south thoroughfare, approximately one-22 quarter mile east of the WRF. 23


Preferred Alternative 25 The preferred alternative will be conducted within the fenced property of the Bloomfield WRF. 26 Construction vehicles will access the site via Church Street, which will have negligible effects on the local 27 transportation network. There will be no effect to Highway 550 traffic. 28

No-Action Alternative 29 No transportation impacts would be associated with the no-action alternative. 30

4.11.1.4 Visual Resources 31


The project area is industrial in nature, and the visual character is dominated by the wastewater treatment 33 basins and block buildings. The project vicinity outside the WRF is a sparsely populated residential area. 34


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Preferred Alternative 1 There would be minor, short-term changes to the visual resources during the construction phase of the 2 preferred alternative, as construction equipment will be visible. There would be no visual resources impacts 3 as the project becomes operational. 4

No-Action Alternative 5 There would be no visual resource impacts associated with the no-action alternative. 6

4.11.1.5 Noise 7


Noise-sensitive areas include residences, schools and day care facilities, hospitals, long-term care facilities, 9 places of worship, libraries, and parks and recreational areas specifically known for their solitude and 10 tranquility, such as wilderness areas. The Charlie Y. Brown School is located approximately one quarter 11 mile from the project site, on the far (east) side of Highway 550. Other potential receptors include the 12 residents within the vicinity of the project area. 13

The primary sources of noise associated with the preferred alternative include construction equipment and 14 motor vehicles used by the construction crews. 15


Preferred Alternative 17 During construction of the Proposed Action Alternative, noise levels would be higher than normal due to 18 the operation of construction equipment. During construction, noise levels could substantially, but 19 temporarily, increase. Construction-related noise would be a temporary impact ending when the 20 construction is completed. Once operational, the project would yield no new noise impacts to the area. 21

This construction noise is not expected to lead to significant noise impacts at the Charlie Y. Brown School, 22 as traffic noise from Highway 550 is expected to be the predominant source of noise at the school. 23

No-Action Alternative 24 No noise impacts would occur under the no-action alternative. 25

4.12 CUMULATIVE EFFECTS 26

CEQ regulations implementing the procedural provisions of NEPA define cumulative impacts as: 27

…the impact on the environment which results from the incremental impact of the action 28 when added to other past, present, and reasonably foreseeable future actions regardless of 29 what agency (federal or non-federal) or person undertakes such other actions. Cumulative 30 impacts can result from individually minor but collectively significant actions taking place 31 over a period of time. (40 CFR 1508.7). 32

Each resource, ecosystem, and human community must be analyzed in terms of its ability to accommodate 33 additional effects, based on its own time and space parameters. 34


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Cumulative environmental impacts from this project may include temporary disruptions to traffic flows; 1 area wetlands, waterways, and floodplains; and migratory birds. 2


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CHAPTER 5 SUMMARY OF MITIGATION MEASURES 1 This chapter provides a summary of the mitigation measures identified during the environmental review 2 process of the proposed action. 3

5.1 LAND USE 4

No land use impacts are expected as a result of the proposed action. No mitigation measures are required. 5

5.2 SOILS 6

No soil impacts or impacts to prime/unique farmland would result through implementation of the preferred 7 alternative. No mitigation measures are required. 8

5.3 FLOODPLAINS 9

The WRF project area is outside the 100-year floodplain. As such, there are no potential erosion impacts 10 and impacts to floodplain areas associated with the proposed action. No mitigation measures are required. 11

5.4 WETLANDS 12

No impacts to wetlands would result through implementation of the proposed action. No mitigation 13 measures are required. 14

5.5 WATER RESOURCES 15

Because the proposed project would disturb more than 1 acre, appropriate NPDES permit coverage is 16 required prior to beginning construction. As required by the EPA all “operators” must obtain NPDES permit 17 coverage for construction projects. Generally, this means that at least two parties will require permit 18 coverage. The owner/developer of this construction project (the City) who has operational control over 19 project specifications and the general contractor who has day-to-day operational control of those activities 20 at the site, which are necessary to ensure compliance with the SWPPP and other permit conditions, and 21 possibly other “operators” will require appropriate NPDES permit coverage for this project. 22

Temporary construction-related impacts to surface water quality will be avoided or minimized by 23 complying with the NPDES permit requirements and implementing a SWPPP. Appropriate BMPs would 24 be implemented and maintained both during and after construction to prevent, to the extent practicable, 25 pollutants (primarily sediment, wastewater, oil and grease, and construction materials) in stormwater runoff 26 from entering waters of the U.S. 27

Construction contractors will ensure that groundwater contamination would be avoided through proper 28 handling and storage of petroleum products, chemicals, toxic substances, and hazardous materials. 29 Accidental discharges would be reported to NMED in compliance with 20.6.2.1203 NMAC. 30

5.6 AIR QUALITY AND CLIMATE 31

To minimize air pollution impacts during construction, construction contractors would ensure that the 32 following practices are implemented: 33


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• Exposed and disturbed soils will be watered at a frequency sufficient to avoid fugitive dust; 1 • Earthmoving and other dust-producing activities will be suspended during periods of high winds, 2

when dust control efforts are unable to prevent fugitive dust; 3 • All stockpiles of debris, soil, sand, or other materials will be watered or covered; 4 • Construction areas and adjacent roads will be swept or cleared of mud and debris; 5 • Materials transported on-site by truck will be covered; and 6 • All construction equipment will be required to use approved emission control devices and limit 7

unnecessary idling. 8

If a standby electrical generator is used at the facility, it should be kept of the hours of operation of the 9 generator. An application for a construction permit must be submitted for stand by generators used 500 10 hours per year or more. 11

All asphalt, concrete, quarrying, crushing, and screening facilities contracted in conjunction with the 12 proposed project must have current and proper air quality permits. 13

5.7 BIOLOGICAL RESOURCES 14

If ground disturbance is scheduled to occur during the nesting season, a preconstruction nest survey is 15 recommended to determine whether occupied nests are present. If occupied nests would be taken by project 16 activities, a USFWS permit would be required prior to construction. 17

5.8 ARCHAEOLOGICAL, CULTURAL, AND HISTORIC RESOURCES 18

Cultural resources would not be affected under the no-action alternative. No mitigation measures are 19 required. 20

5.9 SOCIOECONOMICS AND ENVIRONMENTAL JUSTICE 21

Under the preferred alternative, no residents or businesses would be relocated. No adverse effects would 22 occur for residents within any of the census tracts. The proposed project would provide a higher quality 23 treated effluent for residents of Bloomfield, without favoritism or discrimination. The proposed project is 24 considered consistent with environmental justice policies and would be expected to benefit residents. No 25 mitigation measures are required. 26


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CHAPTER 6 CONSULTATION, COORDINATION, AND PUBLIC 1 INVOLVEMENT 2

Persons and entities on the local, state, and federal level with possible interest in the proposed project were 3 contacted for their comments on potential environmental and cultural impacts resulting from the proposed 4 project. Native American consultation was conducted as well. Table 5 below summarizes the contacted 5 agencies and their responses. A copy of the original project consultation letter and the responses received 6 are included in Appendix B. 7

Table 5 Summary of Correspondence and Responsiveness Summary 8 Agency Contacted Date Agency Comment Sent Reply

Federal Agencies Mr. Wyatt Medley US Army Corps of Engineers Regulatory Project Manager for Northwestern New Mexico 1970 East 3rd Avenue, Suite 109 Durango, CO 81301

20 Mar 19 26 Mar 19 No significant impact anticipated, if the proposed action remains within current WRF boundaries.

Ms. Susan Millsap, Field Supervisor US Fish and Wildlife Service NM Ecological Services Field Office 2105 Osuna Road NE Albuquerque, NM 87113 (505) 761-4781

20 Mar 19 20 Nov 19 No response received.

Ms. Kate Hammond US Dept. of the Interior National Park Service Intermountain Region 12795 Alameda Pkwy Denver, CO 80225 (303) 969-2500

20 Mar 19 20 Nov 19

Electronic copy of the EID is requested to be delivered via e-mail, [email protected]

Mr. Robert Houston Compliance Assurance & Enforcement US Environmental Protection Agency Region 6 Mail Code 6EN-XP 1445 Ross Avenue Dallas, TX 75202 (214) 665-3114


Ms. Sandy Keefe, Director Mitigation Division Federal Emergency Management Agency Region VI FRC 800 North Loop 288 Denton, TX 76209-3698 (940) 898-5559

20 Mar 19 25 Mar 19

We would request that the community floodplain administrator be contacted for the review and possible permit requirements for this project. If federally funded, we would request project to be in compliance with EO 11988 & EO 11990.

Mr. J. Xavier Montoya State Conservationist US Department of Agriculture NRCS State Office

20 Mar 19 No response received.

mailto:[email protected]


6-2

100 Sun Ave. NE, Suite 602 Albuquerque, NM 87109 (505) 761-4400 Ms. Victoria Barr, District Manager Bureau of Land Management Farmington District 6251 College Blvd., Suite A Farmington, NM 87402 (505) 564-7600


Tribal Consultation Mr. Todd Scissons, THPO Acoma Pueblo PO Box 309 Pueblo of Acoma, NM 87034

17 Oct 19 17 Dec 19 No response received.

Mr. Stewart Koyiyumptewa, THPO Hopi Tribe PO Box 123 Kykotsmovi, AZ 86309

17 Oct 19 18 Nov 19 29 Oct 19 Notify if prehistoric sites are identified.

Mr. Richard Smith, Sr., THPO Laguna Pueblo PO Box 194 Laguna Pueblo, NM 87026


Ms. Kellie J. Poolaw, THPO Kiowa Tribe of Oklahoma PO Box 50 Carnegie, OK 73015


Mr. Richard M. Begay, THPO Navajo Nation HPD PO Box 4950 Window Rock, AZ 86515

17 Oct 19 17 Dec 19 17 Dec 19 No comments.

Governor Ron Lovato Ohkay Owingeh Pueblo PO Box 1099 San Juan Pueblo, NM 87566


Christine Sage, Chairman Southern Ute Indian Tribe PO Box 737 356 Ouray Drive Ignacio, CO 81137 (970) 563-0100


Mr. Mark Mitchell, THPO Tesuque Pueblo Route 42, Box 360-T Santa Fe, NM 87506

17 Oct 19 30 Oct 19 Will notify NMED if there are additional questions.

Mr. Terry Knight, Sr., THPO Ute Mountain Tribe PO Box JJ Towaoc, CO 81334-0248


Mr. Francisco Toribio, THPO Zia Pueblo 135 Capitol Square Drive Zia Pueblo, NM 87053-6013

17 Oct 19 17 Dec

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