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CNAPTERTHREE Enulronmental Consequences • 3.2.2 Unavoidable Adverse Impacts The Agency Preferred Altemative would result in some unavoidable soil loss due to erosion, interruption of natural soil development and structure, and loss of soil productivity because of the prevalence of fragile soils and the necessary vegetation clearing and soil disturbance during construction. Fragile soils aze predominant throughout the study azea and cannot be avoided, but use of erosion control best management practices and other reclamation procedures described in the Reclamation Plan would minimize potential impacts. Long-term adverse impacts to soils resources could occur if the reclamation procedures aze not applied appropriately or aze otherwise unsuccessful, but inspections and maintenance could prevent most impacts 3.3 SURFACE WATER AND SURFACE WATER DRAINAGES 3.3.1 Direct and Indirect Impacts The types of impacts to surface water resources from implementing the Agency Preferred Alternative would be similaz to those described for the Proposed Action. However, the development and implementation of mitigation and monitoring plans, as well as project modifications, have reduced the likelihood of adverse impacts occurring. Piceance Site The types of impacts would be similaz to those under the Proposed Action; however, potential adverse impacts should be minimized. Under the Proposed Action, a portion of the surface runoff from the initial processing facility would be diverted to the evaporation pond. Under the Agency Preferred Alternative, a stormwater retention pond would be added to the Piceance Site to control runoff. The pond is designed to contain the 100-yeaz, 24-hour precipitation event, plus an additiona150 percent of the precipitation event, plus the volume of the lazgest on-site storage container. Solids would be allowed to settle in the retention pond, and decant water would be discharged upon visual inspection into intermittent channels tributary to Piceance Creek in accordance with a CDPS stormwater discharge permit. A more detailed erosion control plan has been developed by American Soda (Appendix H). The plan identifies BMPs to control stormwater runoff, reduce the exposure for erosion to occur, and reclaim disturbed azeas. The plan also includes provisions for routine inspections to ensure that erosion control and water treatment structures aze functioning properly. A Well Field Spill Response Plan has been developed to address accidental spills or releases that could occur in the well field area due to piping failures. A preliminary Response Plan has been developed to address accidental spills and other emergency situations at the initial processing facilities azea. A surface water monitoring program would be implemented to detect any changes in water • quality in Piceance Creek, and spring and seeps neaz the Piceance Site. The plan was prepazed in consultation with the BLM, CDMG, USGS, EPA, Rio Blanco County, and American Soda. (Refer to Appendix G for details.) Surface Water and Surtace Water Drainages 3-3