ILLICIT DISCHARGE CONTROL ACTIVITIES
ILLICIT DISCHARGE CONTROL ACTIVITIES
QUALITATIVE RESULTS
Municipality: City of Lafayette
Permit Year: (2007/2008)
Introduction:
The City of Lafayette’s goals and objectives of its IDCA Program are to reduce illicit
discharges to the municipal storm drain system, to inspect priority areas for illicit
discharges, and respond to complaints and spill reports in order to reduce illicit
discharges to the City’s storm drain system.
There have historically been no high-priority illicit discharge areas within the City of
Lafayette. Each year the City responds to all calls about potential illicit discharge and
considers them to be a priority for immediate investigation at the time of the call. The
area is investigated for discharge and the responsible discharger is notified to clean up
and cease discharge of illicit materials. If the discharger cannot be identified, City
maintenance crews clean up the discharge and follow up to be sure discharge does not
continue. These incidents have not been reoccurring, so they are not designated as ongoing priority areas. Details of this year’s investigated incidents follow in the next
subsection, Implementation & Evaluation.
City call-response spill procedures are updated as necessary. Detailed requests and
suggestions from the Regional Water Quality Control Board and Contra Costa County
Hazardous Materials training staff have been incorporated into the City’s spill response
charts including Emergency & Environmental Management Phone Numbers, General
Overview of Spill Response Process for Any Spill Type, HazMat Flowchart and
Municipal Field Response to Non-Hazardous Spills as shown in Attachments E, F, G,
and H of the PEIO section of the 2003/2004 annual report. These charts have been
distributed to key staff members who receive calls from the public about potential spills
and to Community Development staff members who are working throughout the City on
projects or inspections so they can identify any illicit discharge incidents as they are
conducting their regular activities. Charts have also been forwarded to the City Police
Department, the Contra Costa Fire District and inspectors contracted through the
Central Contra Costa Sanitary District.
Screening for illicit discharges within the City is performed in conjunction with inspection
of City creeks and with storm patrol priority areas each year. As the City Engineering
Technician/Public Works Inspector inspects portions of the creeks, he identifies any
creek blockages or materials which may enter creeks or creek banks and screens for
illicit discharges.
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The City maintenance crew inspects storm patrol priority identified locations for
blockage of storm drains and creeks before and after each major storm occurrence. At
the same time, any illicit discharge to these areas are identified and followed up. Most
problems identified during the storm patrol inspections are fallen trees and natural
material debris that are blocking creeks or storm drains. This patrol for creek and storm
drain blockages significantly reduces the incidence of storm flooding within the City.
Evidence of effectiveness is significant reduction in flooding incidents during severe
storms throughout the year.
Inspection and follow up may also be performed by contracted employees, Central
Contra Costa Sanitary District (See Volume 1, Section 6 for a copy of the current
contract agreement with the CCCSD.), the Contra Costa Building Inspection
Department, and the Contra Costa County Health Department. Agency-wide, there is
approximately ten staff responsible for implementation of these Performance Standards.
See Attachment B in the 2001/2002 Annual Report (NDCC Section) for details of the
City’s Stormwater Management and Discharge Control Requirements and Attachment
AA in the 2001/2002 Annual Report for the City’s Creek Setback Requirements
See Attachment ID-1 for a summary of a settlement reached by the Contra Costa
County Office of the District Attorney regarding illicit discharge of pesticides within the
City during the 2006-2007 fiscal year.
The City’s goals are being met by reporting and inspections. The City’s updated illicit
discharge control plan and stormwater ordinance passed in 2004/2005 provides the
basis for reporting, inspections, and enforcement.
The Central Contra Costa Sanitary District also responds to call outs for spills. These
employees receive extensive training in the area of inspections and response for calls.
See details in the Program’s Volume I.
Implementation & Evaluation:
Illicit Discharge Control Inspection Program
The City’s implementation of the Illicit Discharge Control Activities Performance
Standards follows the City of Lafayette Illicit Discharge Control Activities Plan. See
Attachment N in the City of Lafayette 2003/2004 annual report.
Proactive: Field Screening Program
The City has developed accurate maps of the City’s storm drain system, and conducts
field investigations that include inspecting portions of the storm drain system for
potential sources of illicit discharges
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The City annually inspects portions of its six major creeks, which flow primarily through
residential areas, although small segments of three of these creeks flow through the
commercial district. These inspections are performed as part of the summer flood
prevention inspections that ensure obstructions are removed before the rainy season.
Photographs of creeks within the City are included in Attachment ID-2. Photographs are
Lafayette Creek near Leigh Creekside Park at the East Bay Regional Parks District
Trail, Lafayette Creek at the Gazebo in the City’s downtown Core Area, and of Las
Trampas Creek near Pleasant Hill Road and Olympic Boulevard.
The City of Lafayette has not historically experienced any significant incidence of illicit
discharge. During the City’s inspection of creeks and storm drain systems, problems
identified include some occurrences of construction and household debris on creek
banks and in creeks. Annual inspections primarily identify debris, tree branches, and
trees that need to be cleared and removed from the creeks before the rainy season.
Annual creek inspections and abatement letters are typically effective in getting property
owners to clean debris from their creek streambed prior to the rainy season. These
inspections, as well as immediate response to any calls identifying creeks concerns or
illegal dumping, have proven to be the best way of making the City aware of problems in
or near the creeks so that appropriate action can be taken prior to the rainy season.
Priority storm patrol areas listed in the Municipal Maintenance section of the annual
report refer to areas checked before the rainy season and before and after each major
storm, as necessary. These are priority areas based mainly on flood control criteria. As
the areas are inspected for tree branches and anything obstructing storm drains and
creeks, they are also inspected for illicit discharge of any other materials. Any problems
in these areas are typically natural materials that may cause blockages to flowing
waters during a major storm event. Precautions are taken to clear these materials from
the storm drain inlets and creeks to prevent the material from washing into other
waterways and to prevent flooding hazards within the City.
The City’s plan for inspections over the next five years will concentrate each year on a
different section of private and public portions of the City’s creeks. Again inspections
will concentrate on any illicit discharges as well as identify any areas needing clearing of
vegetation and debris. Residents will be notified to clear problem areas, as needed. All
call-outs or areas of concern pointed out throughout the year will be investigated and
prioritized as appropriate.
To date, it has not been considered appropriate or necessary to utilize electronic
information (databases) on significant storm drainage facilities and screening points to
track illicit discharges that could possibly enter the City’s storm drain system from
neighboring jurisdictions since no such discharges have yet to occur in the City. If a
discharge does occur testing, tracking, and clean up of the discharge will be performed
at that time.
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The City’s inspectors have the knowledge and skills necessary to conduct effective field
investigations, with guidance from the Program and the Regional Board staff. At least
one representative is sent to Program workshops each year to obtain additional training
and to share their experiences with other agencies. This last fiscal year, the Program’s
Construction-site Stormwater Quality Workshop on was attended by City employees,
Christine Sinnette, Senior Planner; Aziz Aineb, Engineer/Public Works Inspector; and
Donna Feehan, Public Works Administrative Analyst. Training activities in illicit
discharge control are summarized in the Quantitative Results Table at the end of this
section. These training activities have been effective in educating staff in the various
types of illicit discharges they may encounter and the appropriate corrective actions
necessary to reduce potential pollution of the storm drain system.
Reactive: Investigate Spill Reports/Complains
The Public Works staff continues to investigate calls or reports from City residents
regarding any illegal dumping or related creek questions. The Community Services
Officer in the Police Department continues to deal with vehicle abatement matters.
During the year the City responded to calls for spilled paint on City roads, one report
from the Contra Costa Health Services department regarding contractors washing
cement slurry into storm drains, incidences of litter needing clean up, two discharges of
pool water into storm drains and several East Bay Mud water main line breakages. The
City with the assistance of Central Contra Costa Water District, the County Health
Department, and Fish and Game continue investigation into the possible discharge of
gray water to storm drains/creek areas on Hunsinger Canyon Road by a business
located there.
Investigation of spill incidents in the City of Lafayette also occurs through coordination
with the Clean Water Program and the Contra Costa County Health Department,
Hazardous Materials Program, which provides reports on each spill incident to the City.
(See the Program’s Volume I of the Annual Report for the agreement between these
two agencies for these services.) The City’s role is to alert the appropriate responders
and contain the situation until the arrival of a HazMat team.
As requested by the Regional Water Quality Control Board, a revised model of activities
response plan has been developed with the Contra Costa Clean Water Program.
Training and spill procedures have been refined during this fiscal year and will continue
to be evaluated for their effectiveness.
Inspectors from the Health Department and the City are familiar with the existing spill
response and clean-up programs that cover the City’s jurisdiction, and coordinate illicit
discharge program activities with these existing programs. Through internal
communication and public education, the use of “911" is encouraged to report large or
hazardous spills. Inspectors from both agencies ensure that adequate spill response
supplies are available.
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Inspectors investigate spill reports and/or complaints within their jurisdiction and record
their activities. An Incident, Notification, and Complaint Report Form (See Volume I,
Section 7) containing information about spill incidents is used by the Health Department
so that source identification and follow-up actions can be conducted. To date, no spills
have entered the City’s storm drain system from neighboring jurisdictions; however, if a
spill does enter from another jurisdiction, the procedure established in the Program’s
agreements with the Contra Costa Health Department, Hazardous Material Program will
be followed. (See the Program’s Volume I.)
The spill response procedures implemented by the City of Lafayette have been effective
in reducing illicit discharges to the storm drain system. A summary of quantitative data
is provided at the end of the Illicit Discharge Control Activities section.
Follow-Up, Enforcement, and Reporting
The City’s inspectors are given sufficient authority to initiate enforcement procedures.
The City’s work plan includes established administrative processes.
If a discharge is traced to a residential source, inspectors conduct the following activities
or coordinate the following activities with the appropriate agency:
A. Continue inspection and follow-up activities until compliance is achieved. Record
activities.
B. Meet with the responsible party to discuss methods of eliminating the illicit
discharge, including disposal options, recycling and possible discharge to the
sanitary sewer, as appropriate. Provide Program information to the responsible
party.
C. Begin enforcement procedures, if appropriate.
The number and types of field investigations and incidents, and any enforcement and
follow-up activities are summarized in the Quantitative Results Table at the end of this
section of the Annual Report. A sample of a completed inspection form is shown in
Attachment V in the 2001/2002 annual report. This last fiscal year, 19 medium and low
priority field screening areas were identified within the City’s drainage area. The City
was involved in seven incidents that resulted in the elimination of illicit discharges/illegal
connections, and performed seven enforcement activities.
An evaluation of the illicit discharge inspection results from this year shows that
discharges EBMUD water main breaks and discharges from pools were the most
prevalent types of discharges to the City’s storm drains. Response to investigate
potential discharge into City creeks were performed as calls were received at the City.
Follow up into the potential discharge on Hunsinger Canyon Road will continue into the
next fiscal year. .
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The City’s IDCA Plan has been effective in reducing and minimizing illicit discharges to
the storm drain system.
Modifications:
There have been no new or modified IDCA Performance Standards this year, nor are
any anticipated to be added or modified next year.
Fiscal Year 2008/2009 Goals:
The City of Lafayette has identified the following improvements and goals for its IDCA
Program for next fiscal year:
1) Continue responding to all calls regarding potential illicit discharge; and,
2) Track calls about potential illicit discharges and continue follow up on all
necessary clean up and response.
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ILLICIT DISCHARGE CONTROL ACTIVITIES – QUANTITATIVE RESULTS
Commercial
Areas
Residential
Areas
Total number of field screening areas identified
within the Agency’s entire drainage area
13
6
19
Total number of field screening areas identified in
the Annual Illicit Discharge Control Plan
1
6
7
Description
Industrial
Areas
Total
Field Screenings
All callouts
during the
year are
investigated
Number of priority field screening areas
inspected
Number of medium and low priority areas
inspected.
Number of illicit connections/illegal discharges
eliminated
6
Number of incidents that involved removal of the following materials
Construction materials/debris
2
Sewage
Food wastes
Automotive fluids
1
Yard wastes
Other
3
Other
Enforcement Activities
Number of Enforcement Actions Taken
Written corrective measures
2
Notices to comply
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Description
Industrial
Areas
Commercial
Areas
Residential
Areas
Total
Stop work orders
Notices of violation
Fines
Other
Number of enforcement referrals (e.g., to code
enforcement, City or District Attorney, other
agencies, Regional Board, etc.)
2
Education/Outreach Activities
Numerous
through
CCCSD
inspectors
and City staff
Number of illicit discharge control education
materials distributed
Number of employees attending illicit discharge
control training workshops
1
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