ILLICIT DISCHARGE CONTROL ACTIVITIES
ILLICIT DISCHARGE CONTROL ACTIVITIES
QUALITATIVE RESULTS
Municipality: Town of Moraga Permit Year: (2008/2009)
Introduction:
The Town of Moraga maintains 858 drainage inlets and 52.5 miles of roadway within an area of 9.5 square miles. With limited development, there has been no change since 2005-06. All drainage facilities are inspected a minimum of once a year. Town Public Works staff members are instructed to respond to and report any illicit discharge. The routine daily travels of maintenance personnel provide opportunities to observe any illegal discharges. Formal, scheduled inspections as well as informal and unscheduled drive by observation activities have been incorporated into the Public Works and Parks maintenance standard operating procedures.
The goal of the Town’s program is to be free of illicit discharges. This is accomplished by maintaining a high level of resident community pride, keeping the community, both residential and business, well informed of the need to respect our watersheds and waterways and dispose of pollutants properly, vigilance by staff investigating any suspicious stains on pavement or liquids in the gutters or drain inlets, and enforcement through regular inspection by Central Contra Costa Sanitary District Staff (CCCSD).
The combined resources of Public Works, and our CCCSD contract inspections gives the Town seven people responsible for implementing the program. The primary contact for the stormwater program is Frank Kennedy. He can be reached at (925) 932-7857 and by e-mail: .
A multi-jurisdiction emergency response plan was developed in fiscal year 2004-2005 and has been effectively used in the management of illicit discharges. Staff also has material available to respond to automotive fluid leaks from auto accidents.
Implementation & Evaluation:
Illicit Discharge Control Inspection Plan
The IDCA plan for this past year was to continue inspection in accordance with the existing Plan[a]. The Town effectively responds to illicit discharges by following the plan. Because of the recent successful experience in the application of the Illicit Discharge Activities Plan, Moraga’s IDCA inspection practices are unchanged and are similar to those in the Industrial and Commercial Inspection Plan.
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A goal for 2009-2010 will be to review and revise as necessary the 2001 Illicit Discharge Control Activities Plan to include a strategy and enforcement flow chart in the context of the anticipated MRP. A preliminary requirement of the MRP is the development of an Emergency Response Plan (ERP). The anticipated date for the ERP is April 2010.
The initial call out and evaluation is performed by Town staff. CCCSD assists in call outs and issues Warning Notices and Notices of Violations. Issuance of Warning Notices and Notices of Violation has continued in the last year. For 2009-10 the Town has been looking into the feasibility of giving the Town’s Public Works inspector the authorization to issue citations with civil and criminal assessments. While CCCSD field inspectors remain the lead representative for IDCA callout matters, the Town has made significant progress in educating and training the Public Works inspector as a dedicated IDCA field response inspector. CCCSD personnel, under a contract with the Program, perform inspections and initiate corrective actions on behalf of the Town. The authority to enforce IDCA and other stormwater violations is in Title 13, Chapter 4 of the Municipal Code. The specific citations are 13.04.070, 13.04.170 and 13.04.180 and include the authority to enforce illicit discharge violations. A copy of the Central Contra Costa Sanitary District contract is included in Section 6 Volume I. Currently, Town staff issue “stop work” and “abatement” orders.
The Commercial/Industrial inspection data continues to be entered into the Town’s database through collective efforts by CCCSD field inspectors, who forward inspection data, and also by Town staff who keep the database up to date[b]. Routine field screening investigations again revealed that uncovered “Food Service” waste areas are the most prevalent potential non-stormwater discharge. It is on this premise that “Food Service” field screening inspections comprise 50% of the programs scheduled inspections. It is on the positive side of things that we have made progress in reducing the Food Service related Illicit Discharges to only (1) Warning Notices and (5) Notice of Violations in this reporting year. The low number of Warning Notices and Notices of Violation indicate that the level of inspection is effective because it is anticipated by business managers, and that the enforcements have had the required effect in minimizing the illicit discharges.
Now that the Town has all inspection and enforcement actions in a database, we more easily identify and act to enforce where there may be repeat violations that are many months, or years apart. Currently CCCSD incorporates their own system into their field screenings to ensure to the Clean Water Program that follow-up inspections are performed on previously noted “hot-spots” and businesses found in violation of the Municipal Code. This can lead to earlier higher enforcement, and/or targeted educational activities. During this reporting year CCCSD field inspectors performed 19 follow up inspections at sites to ensure that no repeat violations would happen. A goal for 2009-10 will be to continue to fully implement and use the database in conjunction with the ERP for analysis and annual reporting of all inspection activities to the Clean Water Program.
Pro-active: Field Screening Program
Moraga’s storm drainage mapping system is used as an integral part of the IDCA plan. Also, the Town continues to have a maintenance superintendent routinely assigned to weekend duties ensuring daily observation and emergency response inspection capability.
Clean Water Program “Car Wash Kits”
The Town website contains information on the proper procedure for washing your car[c]. This was a goal for the year. This material was to be distributed to the schools and organizations that have put on such events and to the locations that have hosted them. Together with the Program, the Town is participating in an outreach program that utilizes a community car wash “kit” that groups can use for free when conducting community car wash fund raisers. The kits have been received and a promotional program is being developed. These kits are simple to use and effective at keeping runoff from car wash activities from getting into the creeks and watersheds via the storm drain system. Youth groups, especially Scouts, have developed their own very effective kits so the Town kits have not been used many times. A catch basin liner and sump pump are used to capture the water then pump it to a sanitary sewer drain for proper disposal.
Reactive: Investigate Spill Reports/Complaints
The Town’s Illicit Discharge Control Activities Plan details the elements of the Town’s reactive plan. The public has been made aware of the 1-800-NO-DUMPING number to call. Again through the “Branding” efforts of the Programs PEIO group, the Town anticipates heightened awareness and affiliation with the 1-800-NO-DUMPING number and the protection of the Towns creeks and watershed[d]. They may also call the Town directly or the Police Department. The Storm Water Coordinator or the designee will respond to the report, implement the necessary corrective measures immediately, or call for support from a contract hazardous materials handler. The discharge will be traced, to the extent possible, to the source and abated. When the responsible party has been discovered, the appropriate enforcement action will be taken based on the inspector’s judgment.
The Illicit Discharge Control Activities Plan has been effective in that the Town is pleased to report that there was no evidence of unreported discharges or connections.
The Town has Parks personnel do trash pick-up every weekend along the main roads in Moraga. It seems that much as unaddressed graffiti will encourage more graffiti, trash will seem to have the same affect. We believe that an aggressive program to keep the main thoroughfare clear of trash reduces the total amount of trash illegally disposed of.
Follow-Up, Enforcement, and Reporting
Once an emergency has been addressed, and the appropriate enforcement action taken, such as a Verbal Warning, Warning Notice, Notice of Violation or citation, the site is “flagged” for an unscheduled follow-up by the Central Contra Costa Sanitary District inspector and the Public Works Inspector. The required forms for all of these activities are logged in the database and filed for annual reporting. The violation location may be added to the priority list if appropriate. As previously mentioned 19 “follow-up” inspections were performed at various locations that had been “flagged”.
Modifications:
No modifications to Performance Standards were proposed or implemented in the last year.
Fiscal Year 2009/2010 Goals:
Of the 2008-2009 goals that we set forth, we did not review or revise the IDCA activities plan. This will be a goal for fiscal year 2009-2010 in conjunction with the MRP implementation. We also did not complete preparation of the material for community car washes although a flyer about the effects of soapy car wash water is on the Town website. Those goals will remain on the goal list. Therefore, the goals for 2009-2010 are as follows:
1. Review and revise as necessary the 2001 Illicit Discharge Control Activities plan.
2. Continue to enter all of the field inspection data into the database and use the database for analysis and action planning.
3. Continue to use the Town Crier as a successful means to educate the public on the damaging effects of illicit discharges, and how the residents can report any suspect behavior to the 1-800-NO-DUMPING hotline.
4. Provide car wash kits and outreach information to community groups about the proper procedures to use when conducting community car washes.
5. Inspect all drainage system facilities a minimum of once and to identify where necessary possible sources of illicit discharges.
Effectiveness will be measured by:
1. Reviewing and reissuing for 2009-10 the Illicit Discharge Control Activities Plan.
2. Use the database with the new information as part of an analysis of this year’s information to measure change.
3. Publish an article on how the residents can assist with illicit discharges and include a case history on this year’s event.
4. The number of applicants wanting to use the car wash “kits” provided free of charge by the Town.
5. Complete drainage facility inspection prior to the rainy season.
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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 / 14 / 16
Total number of field screening areas identified in the Annual Illicit Discharge Control Plan / 2 / 14 / 16
Number of priority field screening areas inspected / 0
Number of medium and low priority areas inspected. / 2 / 14 / 16
Number of illicit connections/illegal discharges eliminated / 1 / 1
Number of incidents that involved removal of the following materials
Construction materials/debris / 9 / 9
Sewage
Food wastes / 15 / 15
Automotive fluids
Yard wastes
Other / 15 / 15
Other
Enforcement Activities
Number of Enforcement Actions Taken
Written corrective measures
Notices to comply
Stop work orders / 1 / 1
Notices of violation / 5 / 5
Fines
Other
Number of enforcement referrals (e.g., to code enforcement, City or District Attorney, other agencies, Regional Board, etc.)
Education/Outreach Activities
Number of illicit discharge control education materials distributed
Number of employees attending illicit discharge control training workshops / 5
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[a]See Town of Moraga Illicit Discharge Control Activities Plan (Attachment J of the 2003-2004 Annual Report)
[b] See attachment ID-1 Moraga Annual Total.pdf
[c] See attachment ID-3 carwash_flyer.pdf
[d] See attachment ID-2 NPDES_ Flier.pdf