CITY OF POMONA
POMONA GROUNDWATER TREATMENT
WELL 34 PROJECT
Prepared for:
City of Pomona
Water Resources Department
148 North Huntington Street
Pomona, California 91768
Prepared by:
Tom Dodson & Associates
P.O. Box 2307
San Bernardino, California 92406
October 2023
ATTACHMENT 02
Page ii
Table of Contents
Proposed Action ................................ ................................ ................................ ................ 1
Proposed Categorical Exclusion for the Proposed Action ................................ .................. 1
Potential for Extraordinary Circumstances to Occur ................................ .......................... 2
Conclusion ................................ ................................ ................................ ........................ 5
Exhibits
Exhibit 1 Regional Location
Exhibit 2 Aerial Map (Well 34)
Exhibit 3 4.30-Acre City Water Department Site and Exact Location of Well 34
CITY OF POMONA
POMONA GROUNDWATER TREATMENT WELL 34 PROJECT
Proposed Action
The City of Pomona (City), situated in Los Angeles County, California, is committed to ensuring its 154,000 residents, have access to safe and clean drinking water. This is especially important as many of Pomona’s residents reside in disadvantaged communities (DAC) and do not have other means to ensure their drinking water is safe to drink. To address this essential need, the City is embarking on a crucial groundwater treatment project.
This project involves the installation of a granular activated carbon (GAC) groundwater treatment facility, designed to remove 1,2,3-TrichloroPropane (1,2,3-TCP) and PFAS contaminants in groundwater to meet safe drinking water standards. This project is located in the City’s existing water department yard, located at 1790 E. First St., Pomona, CA 91766. The primary objective of this project is to treat the groundwater produced from the City’s Well 34, bringing it int o compliance with current, and future PFAS, drinking water standards, and subsequently, returning the well to active service. Notably, this project carries the added benefit of shifting away from reliance on imported water purchases (State Water Project, “SWP”), which was used as the replacement source after Well 34 was taken offline in October 2021 due to water quality.
Federal funding will be allocated towards the design and construction of the GAC treatment facility. In October 2021, the City’s Well 34 experienced a sudden increase in 1,2,3-TCP, exceeding safe drinking water thresholds. The City removed Well 34 from service and increased imported water purchases SWP to offset the loss. Well 34 produces on average 1,300 Acre-Feet Per Year (AFY), or nearly 10% of the City’s annual groundwater production.
The unanticipated construction costs and higher than budgeted imported water purchases are creating a financial burden on the City and its customers in the DAC, whom are already burdened with the impacts of the pandemic and inflation.
Under this proposal, the necessary GAC treatment units will be brought to Well 34 site to treat a comparable amount of water as was produced in previous years (about 1,300 AFY) and this groundwater will be deliver the City’s customers. The required improvements include site piping, valves, telemetry, and GAC vessels. It is anticipated th ese improvements will be installed within a six-month timeframe and in accordance with the engineered plans.
The project location is shown on Exhibit 1. An aerial photo of the Well 34 site is provided as Exhibit 2. Exhibit 3 shows the 4.3-acre City water department site and the exact location of Well 34. All three exhibits are attached herewith. As seen on the two aerial photos, Well 34 site is located on a fully utilized, engineered City yard facility, the site has a relatively flat terrain, has no natural habitat, and is surrounded by industrial uses.
Proposed Categorical Exclusion for the Proposed Action
The City has reviewed the available Categorical Exclusions and recommends that the Environmental Protection Agency (EPA) utilize Categorical Exclusion 6.204(a)(1)(ii) for the proposed action. Attachment 2 contains a copy of EPA Categorical Exclusions (CatEx). The recommended CatEx applies to “existing infrastructure systems,” including “drinking water supply systems.” The activities covered under this CatEx include “minor upgrading, or minor expansion of system capacity or rehabilitation (including functional replacement) of the existing system and system
components...” The proposed project exactly fits this definition. The Well 34 treatment syste m includes a minor expansion (installation of the GAC treatment units) that will rehabilitate the existing well and place it back into production with no proposed expansion of Well 34’s production capacity.
Prohibited actions under this CatEx include:
• “involve new or relocated discharges to surface or ground water.” This proposed action (project) does not include such discharges
• “will likely result in the substantial increase in the volume or the loading of pollutant to the receiving water.” This project does not include any increase in pollutant loading. In fact, it will remove 1,2,3-TCP pollutants from groundwater.
• “will provide capacity to serve a population 30% greater than the existing population.” The project area is fully developed and the new water distribution system cannot supply a greater population in the service area.
• “are not supported by the state, or other regional growth plan or strategy.” The project area is fully developed in accordance with the C ity’s land use plan and its continued functioning as a mixed-use urban area will be supported by implementing the proposed action.
• “or directly or indirectly involve or relate to upgrading or extending infrastructure systems primarily for the purposes of future development.” This project is designed to meet the demands of the existing City residents, and will not induce any growth within the service area.
Potential for Extraordinary Circumstances to Occur
To qualify for a Categorical Exclusion 6.204 (a) (1) ( (ii), an evaluation of potential for the project to be affected by “extraordinary circumstances” is required. Extraordinary circumstances are listed in paragraphs (b)(1) through (b)(10) of 40 CFR 1508.4. An evaluation of the potential to be affected by “extraordinary circumstances” is presented in the following text. But first it is important to understand the environmental setting of the area encompassed by the proposed action.
Environmental Setting
The project location is shown on Exhibit 1 of this document. An aerial photo of the Well 34 site is provided as Exhibit 2. Exhibit 3 shows the 4.30-acre City Water Resources Department site and the location of the Well 34 site within the Water Department ’s compound. As these two aerial photos show, the Well 34 site is located on a graded, engineered City compound, on flat terrain, with no natural habitat, and surrounded by urban uses. The key point of seeing the proposed Well 34 location on the aerial p hotos is that the location proposed for the GAC treatment unit location is totally within a compound with no natural habitat and on a flat, engineered fill site.
Additionally, the project site is within an urbanized portion of the City of Pomona.
Extraordinary Circumstances
(b)(1) The proposed action is known or expected to have potentially significant environmental impacts on the quality of the human environment either individually or cumulatively over time.
The proposed action consists of three primary components: installing the GAC water treatment unit; reinitiating water production at Well 34; and periodic maintenance of the well and treatment system, including removal and replacement of the treatment media for regeneration. All of these activities will occur within the existing engineered Well 34 operating area. Since the whole of this proposed action is intended to bring this well back into production of potable water, it has no known or expected signific ant environ- mental impacts on the quality of the human environment either individually or cumulative now or in the future.
(b)(2) The proposed action is known or expected to have disproportionately high or adverse human health or environmental effects on any community, including minority com - munities, low-income communities, or federally-recognized Indian tribal communities.
The project area is a low -income community with a moderate proportion of minority residents. However, the proposed action is being implemented to enhance water production reliability and resilience, including reducing overall costs of water delivery by eliminating the purchase and delivery of State Project Water. This considered a positive benefit to this community. Well 34 is located adjacent to a mobile home residential community and the pump to transfer water from the well to the GAC unit will be the well pump and located within the well and will have no adverse noise impact the adjacent residents. Note that the GAC unit does not have a motor or moving parts so it is essentially silent. With incorporation of this design measure, no disproportionately high and adverse (negative) human health or environmental impacts will occur either during construction or future operations of the proposed facilities.
(b)(3) The proposed action is known or expected to significantly affect federally listed threatened or endangered specific or their critical habitat.
The project area consists of a warehouse building, vehicle storage, and one active well, one abandoned well, and Well 34 within the highly urbanized portion of the City of Pomona. This area is urban in character, and contains no habitat with the primary constituent elements to support any endangered or otherwise sensitive floral or faunal species. For the same reasons, the project area does not contain any designated critical habitat.
(b)(4) The proposed action is know n or expected to significantly affect national natural landmarks or any property with nationally significant historic, architectural, prehistoric, archaeological, or cultural value including but not limited to, property listed on or eligible for the National Register of Historic Places.
The project area has been fully engineered to support the City’s water production and facility maintenance activities. Based on a field review, the area that will be affected by this proposed project is vacant except for the existing Well 34 facilities. There are no natural landmarks or any properties with national significance within the project area of potential effect (APE). Minimal ground disturbance is required to install the GAC unit.
For example, no structures within the project area will be impacted, directly or indirectly, by the installation of the new treatment unit and re-activation of Well 34.
(b)(5) The proposed action is known or expected to significantly affect environmentally important natural resource areas such as wetlands, floodplai ns, significant agricultural
lands, aquifer recharge zones, coastal zones, barrier islands, wild and scenic rivers, and significant fish or wildlife habitat.
The project area does not include any environmentally important natural resources.
There are n o streams or waters of the United States or State of California within the project area ; the project site is not within a 100 -year floodplain (FEMA Firm Panel 06071C8615H); no significant agricultural occurs within the project area; the site is not located within the coastal zone; and the site itself does not contain an aquifer recharge zone.
(b)(6) The proposed action is known or expected to cause significant air quality effects.
The City will bring in the GAC treatment unit(s) already assembled and connect it/them to Well 34. The GAC unit uses electricity, but does not generate any pollutants as the media used for treatment will trap the 1,2,3-TCP. The media will be changed periodically and the old media will be removed to a treatment facility that will remove the pollutant and regenerate the media for reuse. By relying on electricity to operate the GAC unit and the well, minimal emissions will be generated. Southern California Edison (SCE) is the electricity provider and is currently generating about 35% of its energy from renewable energy sources. Overall emissions during installation and operations will be minimal.
(b)(7) The proposed action is known or expected to have a significant effect on the pattern and type of land use (industrial, commercial, agricultural, recreational, residential) or growth and distribution of population including altering the character of existing residential areas, or may not be consistent with state or local government, or federally-recognized Indian tribe approved land use plans or federal land management plans.
The provision of a more reliable and resilient water supply source to the existing City population has no potential to impact the existing land uses or the existing pattern of land uses. The new water system is designed to restore the City’s ability to meet existing demand and the proposed action has no potential to cause a change in the existing land uses.
(b)(8) The proposed action is known or expected to cause a significant public controversy about a potential environmental impact of the proposed action.
This proposed action will enhance the reliability and resiliency of water supply to the existing City residents. Aside from the very short-term installation activity related to the GAC unit, the community will continue to function with a better water system and minimal impact on the normal living conditions. No public controversy is known to exist in relation to the proposed project.
(b)(9) The proposed action is known or expected to be associated with providing financial assistance to a federal agency through an interagency agreement for a project that is known or expected to have potentially significant environmental impacts.
This proposed action is focused on an existing City’s water supply with the goal of providing a more reliable and resilient supply of potable water that meets current drinking water standards. No intergovernmental agreement involving any other federal agency is proposed.
(b)(10) The proposed action is known or expected to conflict with federal, state or local government, or federally-recognized Indian tribe environmental, resource protection, or land-use laws or regulations.
Based on the existing land use within the project site and immediate area, installation and re -operation of Well 34 has no known or expected conflict with any resource protection or land use laws or regulations. The existing us e of the area will remain the same after the new water treatment system is installed and in operation.
Conclusion
As the preceding analysis indicates, the proposed action is a simple infrastructure improvement that will support a better water supply system for an existing well that has encountered a pollutant subject to treatment. Based on the location of the proposed water system improvements and lack of significant environmental resources within the project area, no potential to cause any significant environmental impacts or to violate any extraordinary circumstances has been i dentified that would remove the proposed action from qualifying with a Categorical Exclusion 6.204(a)(1)((ii).
On behalf of the City of Pomona, we request concurrence with this finding and authorization of the funding from the EPA.
EXHIBITS
EXHIBIT 1
Tom Dodson & Associates
Environmental Consultants Regional Location Map
EXHIBIT 2
Tom Dodson & Associates
Environmental Consultants Aeria Map (Well 34)
Well 34
EXHIBIT 3
Tom Dodson & Associates
Environmental Consultants 4.30-Acre City Water Department Site and Exact Location of Well 34