ILLICIT DISCHARGE CONTROL ACTIVITIES
2007 - 2008
ILLICIT DISCHARGE CONTROL ACTIVITIES
QUALITATIVE RESULTS
Municipality: City of Brentwood
Permit Year: (2007/2008)
Introduction:
The City of Brentwood’s goal is to minimize any illicit discharges that may affect our
city’s storm drain system. Our objective to achieve this goal is to provide readily
available educational outreach opportunities and material to the citizens of Brentwood,
commercial businesses, dischargers from unincorporated Contra Costa County, the
development/construction community, and farmers in and around the City’s sphere of
influence.
Currently we have approximately six (6) city employees responsible for implementation
of the Illicit Discharge Control Activities Performance Standards. This includes the
Public Works, Engineering and Community Development Departments (not necessarily
including receivers of phone calls). The City’s primary contact person for permit
compliance is Jeff Cowling, Stormwater Coordinator, (925) 516-5165. Enforcement and
documentation for reporting and follow-up is handled by Laurie Monte, Code
Enforcement Officer, at (925) 516-5405.
The City has procedures in place that apply to illicit discharges. City of Brentwood
Police Department and Contra Costa County Hazardous Materials Departments are
included in the procedural sequence along with City Public Works personnel, Code
Enforcement. Depending on the nature of the discharge, the violator may be given the
opportunity to immediately remediate the affected area in a timely manner meeting and
to the satisfaction of City Personnel. Any remediation efforts from the City or County
would be billed back to the violator, property owner or facility manager. Refer to Volume
1, Section 7 for a detailed discussion regarding the Program’s revised model plan and
amended Performance Standards. Any illicit discharge is documented in the stormwater
electronic data base.
Implementation & Evaluation:
Development of IDCA Program
The Contra Costa Clean Water Program’s Stormwater Management Plan is the
mechanism used by Program co-permittees to implement its joint municipal National
Pollutant Discharge Elimination System (NPDES) permit. This Plan includes a
requirement that co-permittees prepare and utilize a written Illicit Discharge Control
Activities (IDCA) Plan to demonstrate a commitment to take specific steps to control
illicit discharges (Performance Standard IDCA-1). This plan satisfies the performance
standard and forms a basis for The City of Brentwood to conduct an effective illicit
discharge controlled activities.
IDCA - 1
The types of non stormwater discharges most prevalent in the city are agricultural
irrigation runoff. This becomes a challenge to enforce due to the city’s rich agricultural
heritage and the existence of the county agricultural discharge exemption program. The
City currently has 42 active farms selling fruits and vegetables during harvest time, at
farmers’ markets and through retailers in many different regions. Although many of
these locations are outside of the city limits, the upstream discharges still impact Marsh
Creek which continues through the city limits.
Our inspectors provide facility representatives with appropriate BMP information,
educational materials, and inter/intra-agency referrals, as appropriate. During the past
fiscal year we continued our education for inspectors and enforcement staff by sending
appropriate representatives to various classes.
The City has approximately (6) six employees who may participate with illicit discharge
activities at any given time. They include workers from our Public Works Division;
Wastewater, Engineering Division and Community Development Departments.
Inspections are identified by the individual receiving the complaint followed by the final
inspection of a Code Enforcement Officer. The officer will recommend the appropriate
type of enforcement that is needed for each individual situation. All illicit discharge
enforcement actions are tracked and monitored electronically in our data base.
Proactive: Field Screening Program
Visual inspections of discharge points, including catch basins, drain inlets, ditches and
creeks within high priority areas are conducted. The observations are noted on a
standardized inspection form. If an active illicit discharge is identified an attempt will be
made to trace the source of the discharge and eliminate it. Inspection methods may
include inspection of manholes upstream of the discharge site, video surveillance of the
storm drain system and collection of samples.
If a responsible party is identified for the discharge, the IDCA inspector will educated the
party on the impacts of his/her actions, explain the city’s Stormwater Ordinance
requirements and provide BMPs, as needed. The inspector may initiate immediate
action to contain/abate the discharge and recommend follow-up and/or enforcement
procedures. A “non-emergency” illicit discharge from an industrial or commercial
business will be referred to the business inspection coordinator and/or Code
Enforcement Officer, and/or any outside agency that may have jurisdiction for the
nature/location of discharge. If an immediate threat to human health and the
environment is present, emergency service personnel will be notified immediately.
Business types that are identified as having high potential to cause stormwater pollution
in the City of Brentwood’s jurisdiction includes manufacturing facilities, industrial
facilities, food service facilities, vehicle service facilities, retail fuel outlets, and
nurseries. The City of Brentwood goal is to inspect all identified/targeted businesses
within its jurisdiction at least once every five (5) years. However, activity within the City
of Brentwood is currently very light with respect to manufacturing and industrial facilities.
IDCA - 2
The City of Brentwood reviews its business license database by Standard Industrial
Code (SIC), and/or POTW permitted facility databases, and/or Contra Costa County
Watershed Program Clean Water Database, and/or Hazardous Materials Inspection
Facility Database and Notice of Intent listings (NOI) to keep Identified/Targeted
business listings current.
The highest priority businesses for the City of Brentwood staff to conduct inspections
include automotive service facilities, automobile body repair shops, restaurants and car
washes. All of these businesses have the potential to discharge POC. Three types of
inspections will be conducted; routine inspections, priority inspections and “call-out”
inspections. “Routine” inspections are conducted at Identified/Targeted Businesses at a
minimum of once every five (5) years. If a business shows evidence of active nonstormwater pollutant discharges during a routine inspection, it is subject to “priority”
inspection at least once the following year after compliance is achieved. “Call-out”
inspections are conducted as needed following reported or referred non-stormwater
discharge or pollutant exposure.
Reactive: Investigate Spill Reports/Complaints
Notices about illicit discharges are received in a variety of ways. These include calls to
the Program’s “1-800-NO-DUMPING” telephone number, referrals from law
enforcement officials, anonymous tips, referrals from the County Health Department,
etc. (Attachment ID-1)
Notification of an illicit discharge will be directed to the Stormwater Program Coordinator
and/or the Code Enforcement. Information about the reported discharge will be
compiled. The Stormwater Program Coordinator, Code Enforcement Officer, designee
or IDCA inspector will visit the reported discharge location and conduct an inspection.
The responsible party, if identified, will be required to contain/abate the illicit discharge.
If the responsible party is not identified or if the responsible party so chooses and the
discharge can be contained and/or abated, the City of Brentwood will contain/abate the
discharge at the earliest possible opportunity.
All costs associated with
containment/abatement and fines will be borne by the responsible party. Each
response to reported illicit discharges will be documented on our data base per location.
Modifications:
No Performance Standards have been modified or added during the current reporting
period.
Fiscal Year 2008/2009 Goals:
1) The City intends to continue to monitor the following areas and activities on a regular
basis:
• Agricultural Activities
• Outdoor process/manufacturing areas
IDCA - 3
• Outdoor material storage areas
• Outdoor waste storage and disposal areas
• Outdoor vehicle and heavy equipment storage and maintenance areas
• Outdoor parking areas and access roads
• Rooftop down spouts
• Outdoor wash areas
• Outdoor drainage from indoor areas
• Response/tracking from the Fire Department
2) Develop a coordinated procedure for stormwater conveyance system maintenance
and emergency response practices;
3) Continue an illicit discharge inspection program to include medium and low priority
areas based on investigations;
4) Continue higher and extensive education of contractors; working in conjunction with
the State Contractors License Board to license and educate all contractors;
5) Continue refining the City of Brentwood’s Illicit Discharge Control Activities Plan to
individually suit our ever-changing needs and characteristics;
These goals will be modified, as necessary, based upon the requirements of the new
MRP.
IDCA - 4
ILLICIT DISCHARGE CONTROL ACTIVITIES – QUANTITATIVE RESULTS
Description
Industrial
Areas
Commercial
Areas
Residential
Areas
Total
Field Screenings
Total number of field screening areas identified
within the Agency’s entire drainage area
2
500
-
502
Total number of field screening areas identified in
the Annual Illicit Discharge Control Plan
-
16
45
61
Number of priority field screening areas
inspected
-
2
4
6
Number of medium and low priority areas
inspected.
-
10
22
32
Number of illicit connections/illegal discharges
eliminated
0
1
0
0
Number of incidents that involved removal of the following materials
Construction materials/debris
7
181
304
492
Sewage
0
36
5
41
Food wastes
0
28
4
32
Automotive fluids
0
22
44
66
Yard wastes
0
4
165
169
1
231
216
448
0
0
0
0
Written corrective measures
0
46
43
89
Notices to comply
0
8
5
13
Other; concrete, gunite, mortar, garbage,
paint, silt laden water
Other
Enforcement Activities
Number of Enforcement Actions Taken
IDCA - 5
Description
Industrial
Areas
Commercial
Areas
Residential
Areas
Total
Stop work orders
0
0
0
0
Notices of violation
0
12
18
30
Fines
0
26
20
46
Other
0
0
0
0
0
0
0
0
Number of illicit discharge control education
materials distributed
0
192
200
392
Number of employees attending illicit discharge
control training workshops
0
4
4
4
Number of enforcement referrals (e.g., to code
enforcement, City or District Attorney, other
agencies, Regional Board, etc.)
Education/Outreach Activities
IDCA - 6