2022 Annual MS4 Report_Permit No GSM000023

41 Sequin Drive 
Glastonbury, CT  06033 
T: 860.633.8770 
F: 860.633.5971 
 
 
 
 
2022 ANNUAL REPORT 
 
General Permit for the Discharge of Stormwater from  
Small Municipal Separate Storm Sewer Systems (MS4) 
 
Registration No. GSM000023 
 
for 
 
Town of Waterford, CT 
15 Rope Ferry Road 
Waterford, CT 06385 
 
 
 
 
 
 
 
 
Prepared By: 
 
 
 

 
Town of Waterford 2022 Annual Report 
Page 1 of 27 
Permit Number GSM000023 
Barton & Loguidice, LLC 
MS4 General Permit 
Town of Waterford 2022 Annual Report 
Existing MS4 Permittee 
Permit Number GSM000023 
January 1, 2022 – December 31, 2022 
Primary MS4 Contact:  Gary J. Schneider; Director of Public Works; (860) 444-5864; gschneider@waterfordct.org 
 
 
This report documents the Town of Waterford’s efforts to comply with the conditions of the MS4 General Permit to the maximum extent practicable (MEP) from 
January 1, 2022 to December 31, 2022. 
 
Executive Summary 
Submission of this report by the Town Waterford maintains compliance with the reporting requirements and registration (no. GSM000023) under the General Permit 
for the Discharge of Stormwater from Small Municipal Separate Storm Sewer Systems (MS4), submitted to the State of Connecticut Department of Energy and 
Environmental Protection (‘CT DEEP’) Commissioner for activities located within the Town of Waterford.  The Town of Waterford certifies by this report that the 
terms and conditions of the General Permit are being met to the maximum extent practicable (MEP).  
 
The Town of Waterford, hired a Professional Engineering Consultant, Barton & Loguidice, LLC (B&L), who has completed much of the dry weather screening and 
sampling of the Town’s existing and newly identified outfalls (376 municipally-owned).  Through the efforts of B&L, the Town continues working toward the 
completion of all dry weather outfall Illicit Discharge Detection and Elimination (IDDE) screening and sampling, and wet weather impaired outfall sampling efforts for 
all of the municipally-owned outfalls identified in the Town to the MEP. 
 
In 2021 and 2022, the Town made significant updates to the MS4 system mapping based on street map as-built drawings and field observations made by B&L.  
Through the field investigation process, large areas of the MS4 system that were previously mapped in GIS were identified as needing significant updates based on 
actual field conditions.  These areas of the Town’s system mapping were able to be resolved by adding missing structures and correcting piping to match the true 
conditions.  B&L also identified several large areas in Waterford that were missing mapping entirely and meetings were conducted with the Waterford DPW to locate 
“as-built” drawings for the missing areas.  This is a long and tedious process that exhausts a lot of resources but, large questionable areas of the Town’s system 
mapping were able to be resolved, missing structures added, and piping corrected to match the true conditions.  B&L’s efforts assisted in reducing the burden on the 
Town for mapping locations that could be resolved in the field allowing the Town to focus on other aspects of the MS4 permit.  By performing the actions listed 
above, B&L located approximately 150 new outfalls, including 17 new drop down catch basins (catch basins that discharge directly into a waterway with no other 
piping connected to the system).  These newly identified outfalls have been updated in the databases and catchment ranking tables.  In 2023 efforts will continue to 
be made to complete all identified errata points. 
 
Since the primary focus of 2021 and 2022 was to update the Town’s mapping, B&L did not screen any additional outfalls during dry weather events in 2021 or 2022.  
To date, dry weather screening and sampling efforts were completed at 228 Town-owned outfalls and a total of 54 samples were collected.  Eight of the previously 
sampled outfalls were identified with suspected illicit discharges and were ranked at the top of the high priority category for further investigations.   
 

 
Town of Waterford 2022 Annual Report 
Page 2 of 27 
Permit Number GSM000023 
Barton & Loguidice, LLC 
In 2021 and 2022, B&L initiated efforts on the 12 highest priority ranked outfalls for IDDE investigations.  During these efforts, two catchments were screened 
completely, three catchments are awaiting assistance for further investigation, and seven catchments were unable to be completed because they were dry during 
the follow-up screening events.  More attempts will be made for the incomplete investigations, most likely during the spring season of 2023, when the groundwater 
levels are higher.  For the investigations completely screened, reports are in there final stages of being drafted. 
 
As a result of the significant mapping updates in 2021 and 2022, B&L was not able to sample many outfalls during wet events during these years.  In 2022, three 
additional samples were collected and all three were identified with suspected illicit discharges.  To date, wet weather screening and sampling efforts were completed 
at 27 of the 61 known impaired outfall locations.  The previous number of outfalls discharging to impaired waters was 29, which has been increased during the 
mapping updates.  Of the 27 outfalls sampled, 19 were identified with suspected illicit discharges and were ranked at the top of the high priority category for further 
investigations.  Due to the limited amount of qualifying storm events and the fact that most of the outfalls are tidally influenced, in 2023, B&L is focusing on collecting 
wet weather samples from the remaining outfalls and from the most upgradient structure from the waterbody as possible.  B&L will continue to attempt to collect 
wet weather samples from the impaired outfalls until all known locations are sampled.  Due to the limited amount of qualifying storm events and the fact that most 
of the outfalls are tidally influenced, no annual samples were able to be completed in 2022 and will be resumed to the maximum extent practicable in 2023. 
 
In 2021, B&L conducted inspections at 35 municipal stormwater treatment structures.  B&L has since identified five new stormwater treatment structures.  B&L will 
continue to review the existing structures against available mapping to accurately map all known treatment structures for the Town and will update the mapping and 
list of structures accordingly.  It is anticipated that B&L will complete the reporting for the previously inspected stormwater treatment structures in the spring of 2023 
and will continue to inspect any new structures identified in 2023.  In 2021, B&L provided the Town with a spreadsheet of all structures inspected with the conditions 
of each structure listed and estimated costs for annual maintenance for each of the municipal structure inspected. 
 
In 2021, B&L identified the top 40 Town-owned properties with the greatest amount of impervious area.  These sites were then evaluated to determine whether or 
not runoff from the impervious areas discharge to the MS4.  There are currently 21 Town-owned properties that have been identified as potential candidate sites for 
retrofit projects.  The next phase of the desktop analysis is to confirm the presence of directly connected impervious areas (DCIA) at each site, as well as determine 
the suitability and capacity of site soils for supporting the implementation of retrofit projects.  A new DCIA tracking worksheet was prepared by B&L in 2021 for 
inclusion in the Town’s land development applications.  The worksheet would confirm compliance of applicants with site stormwater runoff retainage requirements, 
as well as determine the total change in site DCIA. The change in site DCIA would then be incorporated into the Town’s overall DCIA tracking spreadsheet for 
determining progress towards the Town’s DCIA disconnection goal. The Town is in the process of reviewing and implementing the new DCIA tracking worksheet. 
 
In 2021, B&L identified all industrial and commercial facilities within the Town that likely needed to be registered for CT DEEP’s Industrial and Commercial Stormwater 
General Permits, who are not currently registered.  B&L then prepared educational brochures regarding these stormwater permits, which the Town mailed to all of 
the applicable industrial facilities in 2021 and is anticipating on distributing to the commercial facilities in 2023. 
 
In 2021, B&L started to prepare an MS4 Pollution Prevention and Good Housekeeping Protocols document for the Town and it is anticipated that this will be completed 
in 2023.  This document will optimize some of the best management practices (BMPs) that are currently being carried out by the Department of Public Works to 
minimize the discharge of pollutants to the Town’s MS4 and waters of the State.  BMPs for the following protocols are covered in this document: cleaning and 
maintenance of vehicles and equipment, leaf management, streets and parking lot sweeping, catch basin inspection and cleaning, and snow management. 
 
B&L evaluated the Town’s land use regulations in 2021 with respect to construction stormwater runoff control and post-construction stormwater management.  A 
report was prepared comparing existing regulations to MS4 General Permit requirements.  Recommended regulatory revisions were included in this report.  The 
Town intends to review its regulations and revise the in 2023, as necessary, to improve permit compliance. 
 

 
Town of Waterford 2022 Annual Report 
Page 3 of 27 
Permit Number GSM000023 
Barton & Loguidice, LLC 
Part I: Summary of Minimum Control Measure Activities  
 
1. PUBLIC EDUCATION AND OUTREACH (Section 6 (a)(1) / page 19) 
 
1.1 BMP Summary 
 
BMP 
Activities in current reporting period 
Sources Used  
(if applicable) 
Method of Distribution 
Audience (and 
number of 
people 
reached) 
Measurable goal 
Department/ 
Person 
Responsible 
Additional 
details 
1-1 Implement 
public education 
and outreach 
Link was created for accessing the 
Town’s Stormwater Regulations 
website.  Links were added discussing 
Stormwater & Water Quality, 
Impervious Cover, Urban Runoff, the 
NPDES Program and Save the Sound.  
Planning & Development and 
Recreation & Parks added a webpage 
link to the Stormwater. Informational 
material is also present at Town 
offices.  
CT DEEP, NRDC, 
UConn NEMO, 
NOFA, NH DES, 
Clemson 
Cooperative 
Extension, 
Minnesota PCA, 
Long Island 
Sound Study, 
Save the Sound, 
Connecticut 
Conservation 
Districts, EPA 
Town Offices and Webpage: 
www.waterfordct.org/public-
works/pages/stormwater-
regulations 
General Public 
Continue 
distributing 
educational 
brochures as bill 
inserts, mailings, 
and fact sheets at 
town offices and 
with building 
permits, and on the 
town website. 
Department of 
Public Works 
 
1-2 Address 
education/ 
outreach for 
pollutants of 
concern* 
Weblinks regarding nitrogen, 
phosphorus, turbidity and bacteria 
are available on the Town’s 
Stormwater webpage. What 
residents can do to mitigate these 
pollutants is also discussed on the 
Stormwater webpage. 
 
 
 
Develop and 
Distribute 
Information on 
Nitrogen and 
Bacteria Pollution 
 
 
1-3 Town 
Website 
The SMP and draft Annual Report are 
also available through the Town’s 
website.  Public educational 
documents are available on the 
Town’s Stormwater Regulations 
webpage (see BMP 1-1 and BMP 1-2).  
A notification/link for the 
Construction Stormwater General 
Permit is also available on the Town’s 
Stormwater Regulations webpage 
(see BMP 4-6). 
See BMP 1-1 / 
BMP 1-2 
Town Webpage: 
www.waterfordct.org/public-
works/pages/stormwater-
regulations 
General Public 
Update website to 
include additional 
stormwater 
information.  
Department of 
Public Works 
 

 
Town of Waterford 2022 Annual Report 
Page 4 of 27 
Permit Number GSM000023 
Barton & Loguidice, LLC 
BMP 
Activities in current reporting period 
Sources Used  
(if applicable) 
Method of Distribution 
Audience (and 
number of 
people 
reached) 
Measurable goal 
Department/ 
Person 
Responsible 
Additional 
details 
1-4 Catch Basin 
Stenciling/Badges 
All catch basins have been stenciled.   
Not Applicable 
Not Applicable 
General Public 
Continue an on-
going stenciling 
program in which 
basins in Town are 
prioritized and 
stenciled. 
Department of 
Public Works 
The Town will 
continue its 
catch basin 
stenciling 
program, as 
needed. 
1-5 Household 
Hazardous Waste 
Collection Days 
HHW Collections Days were 
conducted on 4/2/22, 5/7/22, 
6/4/22, 6/19/22, 7/9/22, 8/6/22, 
9/17/22, 10/8/22, and 11/5/22.   
Southeastern 
Connecticut 
Regional 
Resources 
Recovery 
Authority 
(SCRRRA) 
Town Webpage: 
www.waterfordct.org/public-
works/pages/hazardous-
household-waste-paper-
shredding 
 
SCRRRA provided fliers. 
General Public 
Continue program 
in an effort to 
remove household 
hazardous waste 
safely from the 
waste stream using 
a Qualifying Local 
Program 
Department of 
Public Works 
 
 
1.2 Describe any Public Education and Outreach activities planned for the next year, if applicable 
 
Continue to update the Town’s Stormwater webpage with new/updated stormwater related information  
 
Continue distributing educational brochures 
 
Attempt to coordinate efforts with local schools for presentation on stormwater management 
 
Continue the catch basin stenciling/badges program, as needed 
 
Continue to coordinate HHW program 
  
2. PUBLIC INVOLVEMENT/PARTICIPATION (Section 6(a)(2) / page 21) 
 
2.1 BMP Summary 
BMP 
Status 
Activities in current reporting 
period 
Measurable goal 
Department/ 
Person 
Responsible 
Date 
completed/ 
projected 
Location Posted 
Additional details 
2-1a Final 
Stormwater 
Management Plan 
publicly available  
Complete 
Notice of the SMP was published in 
The Day newspaper and on Town’s 
Stormwater website.   
Notify public of 
published SMP and 
document comments 
received. 
Department of 
Public Works 
April 1, 2017 
 
The Day, Planning & 
Development and Town Clerk’s 
Offices, Department of Public 
Works Complex, the Library and 
www.waterfordct.org/sites/wat
erfordct/files/file/file/20170912
_waterford_bmp_smp_2017.pdf  
The Stormwater 
Management Plan 
will be reviewed 
periodically and 
updated, as 
necessary. 

 
Town of Waterford 2022 Annual Report 
Page 5 of 27 
Permit Number GSM000023 
Barton & Loguidice, LLC 
BMP 
Status 
Activities in current reporting 
period 
Measurable goal 
Department/ 
Person 
Responsible 
Date 
completed/ 
projected 
Location Posted 
Additional details 
2-1b Comply with 
public notice 
requirements for 
Annual Reports 
(annually by 2/15) 
Complete 
Notice of the draft 2021 Annual 
Report was posted on the Town’s 
website on 1/20/22 and the report 
was available on the Town’s 
website from 2/14/22 through 
3/28/22. 
 
Notify public of draft 
Annual Report and 
document comments 
received. 
Department of 
Public Works 
2021 Report: 
Feb 14, 2022 
 
2022 Report: 
Feb 15, 2023 
Planning & Development and 
Town Clerk’s Offices, 
Department of Public Works 
Complex, the Library and 
www.waterfordct.org/public-
works 
Notice of the draft 
2022 Annual Report 
was posted in The 
Day newspaper on 
2/7/23 and the 
report was available 
on the Town’s 
website from 
2/15/23 through 
3/28/23. 
2-2 Community 
Group 
Engagement 
Complete 
The Planning Department and 
Public Works department continue 
to work with the Niantic River 
Watershed Committee in 
implementation of educational 
programs, and installation of LID 
measures within the Niantic 
Watershed.  
Identify and reach 
out to local 
organizations that 
may want to 
participate in review 
and implementation 
of this SMP. 
Department of 
Public Works 
On-going 
 
 
2-3 Interagency 
Meetings 
Complete 
Meetings were held throughout the 
year with Public Works and 
Planning & Development. 
Continue to facilitate 
a panel of staff and 
volunteers. 
Department of 
Public Works 
On-going 
Not Applicable 
 
 
2.2 Describe any Public Involvement/Participation activities planned for the next year, if applicable.  
 
Continue to provide notice of updated SMPs and draft Annual Reports 
 
Continue to engage Community Groups 
 
Continue interagency meetings 
 
 
 

 
Town of Waterford 2022 Annual Report 
Page 6 of 27 
Permit Number GSM000023 
Barton & Loguidice, LLC 
3. ILLICIT DISCHARGE DETECTION AND ELIMINATION (Section 6(a)(3) and Appendix B / page 22) 
 
3.1 BMP Summary  
BMP 
Status 
Activities in current reporting period 
Measurable goal 
Department/ 
Person 
Responsible 
Date 
completed/ 
projected 
Additional details 
3-1 Develop written IDDE 
program (Due 7/1/19) 
Complete 
The Town finalized its IDDE program. 
Development and 
implement an IDDE Program  
Department of 
Public Works 
Apr 29, 2020 
 
3-2 Develop list and maps 
of all MS4 stormwater 
outfalls in priority areas 
(Due 7/1/20) 
Substantially 
Complete 
In 2021 and 2022, with assistance from 
the Town’s consultant, Barton & 
Loguidice, the Town conducted 
significant efforts to confirm and locate 
additional outfalls in priority areas that 
were either incorrect or not previously 
identified. 
Finalize mapping of all MS4 
Outfalls 
Department of 
Public works 
June 2023 
In 2023, the Town will 
continue to update its 
mapping as new 
information is gathered. 
3-3 Implement citizen 
reporting program  
(On-going) 
In Progress/ 
On-going 
Currently, citizens can call the 
Department of Public Works to report 
any activities. An updated system will 
be developed to include use of Municity 
Software.  
Develop an online method 
for citizens to report spills 
and illicit dischargers 
Department of 
Public Works  
June 2023 
The Town will add an 
email and phone contact 
on the stormwater page 
for reporting illicit 
discharges.  
3-4 Establish legal authority 
to prohibit illicit discharges 
(Due 7/1/19) 
Substantial 
Complete 
Current ordinance generally meets 
requirements.  The Town reviewed its 
ordinance against the template 
provided by UConn CLEAR and will be 
making slight changes to be more 
consistent with the template. 
Review and update 
ordinances. 
Department of 
Public Works  
December 
2023 
 
3-5 Develop record keeping 
system for IDDE tracking 
(Due 7/1/17) 
Complete 
The Town currently uses excel and 
access spreadsheets, along with GIS, for 
IDDE tracking.   
Record illicit discharge 
abatement activities.  
Develop and maintain an 
SSO inventory.  
Department of 
Public Works 
Jul 1, 2017 
On-going 
The Town started 
developing a recording 
system for IDDE tracking 
using the Municity 
Software. 
3-6 Address IDDE in areas 
with pollutants of concern 
In Progress 
In 2021 and 2022, B&L continued IDDE 
investigations for catchment areas that 
discharge to impaired waters.  It is 
anticipated that B&L will complete the 
initial investigations started and will 
continue to investigate additional 
suspected illicit discharges in 2023 to 
the maximum extent practicable. 
Identify which areas in Town 
are most likely to contribute 
nitrogen phosphorous, and 
bacteria to the MS4 (IDDEs). 
Department of 
Public Works 
On-going 
The Town continues to 
identify structures that 
are not connected to the 
sanitary sewer system 
which are located near 
the MS4. 

 
Town of Waterford 2022 Annual Report 
Page 7 of 27 
Permit Number GSM000023 
Barton & Loguidice, LLC 
BMP 
Status 
Activities in current reporting period 
Measurable goal 
Department/ 
Person 
Responsible 
Date 
completed/ 
projected 
Additional details 
3-7 Map MS4 System in 
Priority Areas 
In Progress 
In 2021 and 2022, with assistance from 
B&L, the Town conducted significant 
efforts to confirm and locate additional 
outfalls in priority areas that were 
either not mapped correctly or were 
not previously identified.  The Town 
also conducted efforts for updating the 
mapping for catch basins, piping and 
stormwater structures in priority areas. 
Map Priority Areas 
Department of 
Public Works 
On-going 
In 2023, the Town will 
continue to update its 
mapping as new 
information is gathered. 
 
3.2 Describe any IDDE activities planned for the next year, if applicable. 
 
Post IDDE Program to the Stormwater webpage and include link in next year’s Annual Report 
 
Post an Illicit Discharge Reporting link on the Stormwater webpage 
 
Continue updating the MS4 outfall and system mapping 
 
Maintain master IDDE tracking system 
 
Continue to investigate illicit discharges in areas with pollutants of concern 
 
3.3 Provide a record of all citizen reports of suspected illicit discharges and other illicit discharges occurring during the reporting period and 
SSOs occurring July 2017 through end of reporting period using the following table.  
Location 
(Lat long/ street crossing 
/address and receiving 
water) 
Date and 
duration of 
occurrence 
Discharge to 
MS4 or 
surface water  
Estimated 
volume 
discharged 
Known or suspected cause / 
Responsible party 
Corrective measures planned and 
completed (include dates) 
Sampling data (if 
applicable) 
No citizen reports of suspected illicit discharges were reported during 2022 
No other illicit discharges were reported during 2022 
No SSOs were reported from 2017 through 2020 and none were reported in 2022 
Magonk Point Road 
Started 8/31/21 
Ended 9/1/21 
No 
51-500 
gallons 
Pump station equipment failure 
(reported by neighbor) / 
Utility Commission Office 
Force main was drained, tanker was used 
to by-pass the pump station, and 
staff/contractor repaired the pipe. 
N/A 
Cross Road 
Started 9/26/21 
Ended 9/27/21 
No 
51-500 
gallons 
Sewer Line Blockage – A spill out a 
manhole located on a large grass area 
outside BJs in Waterford was reported 
by BJs property manager.   
Cleared the backup and cleaned the 
pipe.  It appears that non-flushable 
materials are being discharged into the 
collection system. 
N/A 
 
 

 
Town of Waterford 2022 Annual Report 
Page 8 of 27 
Permit Number GSM000023 
Barton & Loguidice, LLC 
3.4 Provide a summary of actions taken to address septic failures during the Reporting Period using the table below. 
Method used to track illicit 
discharge reports 
Location and nature of structure with 
failing septic systems 
Actions taken to respond to and address the 
failures 
Impacted waterbody or 
watershed, if known 
Dept. / Person 
responsible 
Septic Installation Log 
39 Braman Rd 
Failing septic system  
Action initiated by septic installer. Permit for septic 
repair approved on 7/21/2022. 
Unknown 
Ledge Light Health 
District 
 
3.5 Briefly describe the method and effectiveness of said method used to track illicit discharge reports.  
Currently, phone calls and emails are received by the Department of Public Works from citizen’s reporting possible illicit discharges.  The Town will continue tracking illicit discharges using an 
excel table.  The Town is working towards tracking reports and responses using the Municity Software program. 
 
3.6 IDDE reporting metrics 
Metrics 
Estimated or actual number of MS4 outfalls 
376 (increased from 262 in 2020 and decreased from 387 in 2021) 
Estimated or actual number of interconnections 
21 
Outfall mapping complete 
90% 
Interconnection mapping complete 
50% 
System-wide mapping complete (detailed MS4 infrastructure)  
75% 
Outfall assessment and priority ranking 
376 outfalls have initial rankings (increased from 250 in 2021) 
Dry weather screening of all High and Low priority outfalls complete 
228 of 376 
Catchment investigations complete 
5 investigations were initiated in 2021 
Estimated percentage of MS4 catchment area investigated 
Approximately 5% 
 
3.7 Briefly describe the IDDE training for employees involved in carrying out IDDE tasks including what type of training is provided and how 
often is it given (minimum once per year). 
An MS4 and IDDE training program was developed for presentation to all Town personnel that may come into contact with stormwater or that may review applications and plans that impact 
stormwater quality.  Typically, this training is conducted on an annual basis for members of Public Utility, Board of Education, Department of Public Works, Parks and Recreation, Police 
Department, and Fire Department.  A virtual training was provided to select personnel from Public Works and the Conservation Commission on May 15, 2022.  Many IDDE topics are 
discussed during the Town’s annual SPCC and SWPPP training events.   
 
 
 

 
Town of Waterford 2022 Annual Report 
Page 9 of 27 
Permit Number GSM000023 
Barton & Loguidice, LLC 
4. CONSTRUCTION SITE RUNOFF CONTROL (Section 6(a)(4) / page 25) 
 
4.1 BMP Summary  
BMP 
Status 
Activities in current reporting 
period 
Measurable goal 
Department/ 
Person 
Responsible 
Date 
completed/ 
projected 
Additional details 
4-1 Implement, upgrade, 
and enforce land use 
regulations or other 
legal authority to meet 
requirements of MS4 
general permit  
(Due 7/1/20) 
Complete 
P&Z updated the Subdivision and 
Zoning Regulations to incorporate 
LID, green infrastructure, and 
stormwater design requirements.  
B&L, the Town’s consultant, 
evaluated the Town’s land use 
regulations in 2021 and made 
recommendations towards 
improving compliance with the MS4 
General Permit.  
Review and update the 
regulations to be consistent 
with the requirements of 
the permit. 
 
Planning 
April 2018 
In 2023, the Town will 
continue to review its 
stormwater management 
regulations and revise if 
necessary to meet MS4 
general permit 
requirements. 
4-2 Develop/Implement 
plan for 
interdepartmental 
coordination in site plan 
review and approval 
(On-going) 
Complete 
Site applications are forwarded to 
Town Officials for review and 
comment during application 
process. Plans are not signed by 
commission until all departments 
have signed off on project plan.  
Document Current 
Procedure 
Planning 
Jul 1, 2017 
On-going 
 
4-3 Review site plans for 
stormwater quality 
concerns  
(On-going) 
Complete 
Commercial and residential site 
plans involving greater than 0.5 
acre of land disturbance were 
reviewed for stormwater quality 
control measures. 
Continue to review all 
design plans for consistency 
with town and state 
guidelines for erosion and 
sediment control. 
Planning 
Jul 1, 2017 
On-going 
Application review checklists 
have been revised to include 
stormwater management 
regulation requirements  
4-4 Conduct site 
inspections  
(On-going) 
Complete 
Zoning and Inland Wetland 
enforcement staff verify site 
development practices are in 
accordance with approved plans. 
Planning staff employ an inspection 
checklist to document compliance 
and to identify measures requiring 
repair/additional control measures. 
Inspections occur after every 
significant rainfall event.  
Document Inspections 
Performed 
Continue existing program 
of construction inspections. 
Planning 
Jul 1, 2017 
On-going 
 

 
Town of Waterford 2022 Annual Report 
Page 10 of 27 
Permit Number GSM000023 
Barton & Loguidice, LLC 
BMP 
Status 
Activities in current reporting 
period 
Measurable goal 
Department/ 
Person 
Responsible 
Date 
completed/ 
projected 
Additional details 
4-5 Implement 
procedure to allow 
public comment on site 
development  
(On-going) 
Complete 
All agendas and minutes are noticed 
in compliance with State 
requirements for public notice. 
Public hearings announced in 
newspaper. Complaints regarding 
land-disturbance are forwarded to 
Planning and Development 
Department. 
Document Public 
Comments 
Planning 
Jul 1, 2017 
 
4-6 Implement 
procedure to notify 
developers about DEEP 
construction stormwater 
permit  
(On-going) 
Complete 
Town agencies notify developers of 
stormwater requirements. When 
applicable, developers submit 
notification of registration to State.  
P&Z application checklist was 
revised to require applicant’s 
determination if a Construction 
Stormwater GP is required. 
Update application forms 
to include determining if 
Construction Stormwater 
GP is required.  Updated 
webpage.  
Planning 
Jul 1, 2019 
A note was added to the 
website regarding need for a 
Construction Stormwater GP: 
www.waterfordct.org/public-
works/pages/stormwater-
regulations 
 
 
4.2 Describe any Construction Site Runoff Control activities planned for the next year, if applicable. 
 
Continue to update land use regulations to improve compliance with MS4 General Permit. 
 
Continue to review all design plans for consistency with Town and State guidelines for erosion and sediment control. 
 
Continue existing program for construction inspections. 
 
Continue to follow all State public notice and hearing requirements and follow up on all comments and complaints received. 
 
 
 

 
Town of Waterford 2022 Annual Report 
Page 11 of 27 
Permit Number GSM000023 
Barton & Loguidice, LLC 
5. POST-CONSTRUCTION STORMWATER MANAGEMENT (Section 6(a)(5) / page 27) 
 
5.1 BMP Summary 
BMP 
Status 
Activities in current reporting period 
Measurable goal 
Department/ 
Person 
Responsible 
Date 
completed/ 
projected 
Additional details 
5-1 Establish and/or 
update legal authority 
and guidelines 
regarding LID and 
runoff reduction in site 
development planning 
(Due 7/1/22) 
Complete 
P&Z updated the Subdivision and 
Zoning Regulations to incorporate 
LID, green infrastructure, and 
stormwater design requirements.   
B&L, the Town’s consultant, 
evaluated the Town’s land use 
regulations in 2021 and made 
recommendations towards 
improving compliance with the MS4 
General Permit. 
Review and update the 
regulations to be consistent 
with the requirements of the 
Permit. 
Planning 
April 2018 
The Town continues to 
review its stormwater 
management regulations 
for effective LID 
implementation and run-
off reduction. 
5-2 Enforce LID/runoff 
reduction requirements 
for development and 
redevelopment 
projects  
(Due 7/1/22) 
Complete 
Section 25.6 Stormwater 
Management regulations require LID, 
run-off control and stormwater 
treatment to the maximum extent 
practicable for all new development 
>0.5 acre.   
B&L, the Town’s consultant, 
evaluated the Town’s LID/runoff 
reduction requirements in 2021 and 
made recommendations towards 
improving compliance with the MS4 
General Permit. 
Review current regulations 
to identify and, where 
appropriate, reduce or 
eliminate existing regulatory 
barriers to implementation 
of LID and runoff reduction 
practices to the MEP. 
Planning 
April 2018  
On-Going 
The Town continues to 
review its regulations 
requiring run-off 
reduction for 
development and 
redevelopment projects 
and revise requirements 
affecting impervious 
surface area. 
5-3 Identify retention 
and detention ponds in 
priority areas  
(Due 7/1/20) 
Substantially 
Complete  
Known ponds under the control of 
the Town have been mapped.  In 
2021 and 2022, B&L continued to 
review the mapping and made 
updates to the ponds, as necessary. 
Inventory Town retention/ 
detention ponds 
Department of 
Public Works 
Mar 23, 2018 
 

 
Town of Waterford 2022 Annual Report 
Page 12 of 27 
Permit Number GSM000023 
Barton & Loguidice, LLC 
BMP 
Status 
Activities in current reporting period 
Measurable goal 
Department/ 
Person 
Responsible 
Date 
completed/ 
projected 
Additional details 
5-4 Implement long-
term maintenance plan 
for stormwater basins 
and treatment 
structures  
(On-going) 
Complete/ 
On-going 
Inspection reports and water quality 
monitoring for stormwater and 
treatment basins continue to be 
completed. Town maintains an 
inventory of required stormwater 
management control practices for 
completed site developments.  
Documentation of inspection and 
maintenance of stormwater 
treatment is requested as part of 
land use and building permit 
approvals.  Town employees receive 
instruction on maintenance for rain 
gardens, stormwater detention 
/treatment systems. 
All basins and structures are 
inspected and maintained at least 
annually.  
Develop a maintenance plan 
for retention/ detention 
ponds and stormwater 
treatment structures that it 
owns or over which it holds 
an easement or other 
authority and that are 
located in the Permittee’s 
priority areas to ensure their 
long-term effectiveness. 
Planning 
Feb 15, 2018 
On-going 
A draft plan for routine 
inspections and 
maintenance for the 
Town’s basins and 
structures is currently 
being reviewed by the 
Town.  In 2021, B&L 
conducted stormwater 
structure inspections for 
all ~40 stormwater 
treatment structures 
identified and started 
drafting reports and 
recommendations for 
maintenance.  Based on 
the inspections 
conducted, B&L provided 
the Town with a cost 
spreadsheet for budgeting 
annual maintenance. 
5-5 DCIA mapping  
(Due 7/1/20) 
Substantially 
Completed 
The DCIA for the priority areas have 
been calculated using the available 
impervious cover layers. 
Calculate DCIA 
Department of 
Public Works 
Jul 1, 2020 
On-going 
The DCIA mapping will be 
updated, as necessary, to 
include retrofit, 
development and 
development projects. 
5-6 Address post-
construction issues in 
areas with pollutants of 
concern 
Not Started 
None 
Document issues identified 
and address. 
Prioritize areas for the DCIA 
retrofit program under 
MCM-6 
Department of 
Public Works 
On-going 
 
 
5.2 Describe any Post-Construction Stormwater Management activities planned for the next year, if applicable. 
 
Continue to review and update land use regulations to improve compliance with MS4 General Permit. 
 
Continue to enforce LID/runoff reduction requirements for development and redevelopment projects. 
 
Review Stormwater Structures Management Plan for areas of optimization. 
 
Continue to conduct inspections and water quality monitoring for stormwater and treatment basins. 
 
Continue updating the DCIA mapping, as necessary. 
 
 
 

 
Town of Waterford 2022 Annual Report 
Page 13 of 27 
Permit Number GSM000023 
Barton & Loguidice, LLC 
5.3 Post-Construction Stormwater Management reporting metrics 
Metrics 
Baseline (2012) Directly Connected Impervious Area (DCIA) 
240 
acres 
DCIA disconnected (redevelopment plus retrofits) 
Unknown 
acres this year / acres total 
Retrofits completed 
Unknown 
# 
DCIA disconnected 
TBD 
% this year / % total since 2012 
Estimated cost of retrofits 
Unknown 
$ 
Stormwater treatment structures identified (including detention/retention ponds, 
oil water separators, hydrodynamic separators, green infrastructure, etc.) 
45 total treatment structures  
13 retention/detention ponds 
# total 
 
5.4 Briefly describe the method to be used to determine baseline DCIA. 
 
To calculate the baseline DCIA for the Town of Waterford, the Town used the process found on the CT NEMO website.  CT NEMO developed 5 formulas to calculate the DCIA and 
Impervious Cover (IC) independently for each basin in the Town using the percent DCIA for the basin with the state DCIA removed from the equation.  The Town took the formulas and 
created a bell curve to input the calculated percent of DCIA for each basin and calculate the total DCIA and IC amounts for the Town.  Each basin value was added together to create the 
baseline for the DCIA and IC for the Town. 
 
 
6. Pollution Prevention/Good Housekeeping (Section 6(a)(6) / page 31) 
 
6.1 BMP Summary  
BMP 
Status 
Activities in current reporting 
period 
Measurable goal 
Department/ 
Person 
Responsible 
Date 
completed/ 
projected 
Additional details 
6-1 Develop/implement 
formal employee 
training program  
(On-going) 
Complete/ 
On-going 
A training program has been 
developed.   
A virtual training was provided to 
select personnel from Public Works 
and the Conservation Commission 
on May 15, 2022. 
Track Town employee 
training 
DPW, Parks and 
Rec., Utility 
Commission, 
Waterford 
Buildings and 
Grounds, and 
Waterford BOE.  
On-going 
 
6-2 Implement MS4 
property and operations 
maintenance  
(On-going) 
Complete/ 
On-going 
Salt piles are stored under cover and 
on impervious surfaces.  Town 
industrial stormwater discharges are 
monitored.  Vehicle maintenance is 
performed undercover. 
Continue the pattern of MS4 
property and operations 
maintenance in accordance 
with the Permit. 
Depart of Public 
Works, Police 
Depart, Fire 
Depart, Board of 
Ed, Parks and Rec 
Jul 1, 2017 
On-going 
The Town continues 
reviewing current 
practices and looking for 
areas for optimization. 

 
Town of Waterford 2022 Annual Report 
Page 14 of 27 
Permit Number GSM000023 
Barton & Loguidice, LLC 
BMP 
Status 
Activities in current reporting 
period 
Measurable goal 
Department/ 
Person 
Responsible 
Date 
completed/ 
projected 
Additional details 
6-3 Implement 
coordination with 
interconnected MS4s 
In Progress 
Through the outfall identification 
process, the Town has identified 
several interconnections with the 
neighboring towns/cities. 
Coordinate pollution 
prevention activities with 
interconnected MS4s. 
Department of 
Public Works 
On-going 
 
6-4 Develop/implement 
program to control 
other sources of 
pollutants to the MS4 
Substantially 
Complete 
The Town has identified industrial 
and commercial facilities not 
registered under DEEP’s Industrial 
Stormwater General Permit and 
Commercial Stormwater General 
Permit, respectively. Educational 
brochures were mailed to the 
industrial facilities in 2021, notifying 
them of their potential obligation to 
register. 
Develop and implement a 
program to control the 
contribution of pollutants to 
the MS4. 
Department of 
Public Works 
Aug 2021 
Spring 2022 
 
Commercial brochures 
will be mailed to these 
facilities in 2023, notifying 
them of their potential 
obligation to register. 
6-5 Evaluate additional 
measures for discharges 
to impaired waters* 
To be Started 
None 
Identify potential project 
locations. 
Department of 
Public Works 
 
 
6-6 Track projects that 
disconnect DCIA  
(On-going) 
In Progress 
A table was created for tracking 
disconnected DCIA. The Town has 
started filling out the DCIA tracking 
table with completed development 
projects dating back to 2012. 
In 2021, B&L reviewed all Town 
approved projects since 2012 to 
identify all potential projects 
completed during that time.  In 
2021, B&L created a DCIA tracking 
form to be completed for each new 
project, which is being reviewed by 
the Planning Department before 
implementing. 
Annually track acreage of 
DCIA disconnected as a 
result of redevelopment/ 
retrofit projects within the 
Town.  
Department of 
Public Works 
Jul 1, 2019 
On-going 
The Town will maintain a 
record of all disconnected 
DCIA projects.   

 
Town of Waterford 2022 Annual Report 
Page 15 of 27 
Permit Number GSM000023 
Barton & Loguidice, LLC 
BMP 
Status 
Activities in current reporting 
period 
Measurable goal 
Department/ 
Person 
Responsible 
Date 
completed/ 
projected 
Additional details 
6-7 Implement 
infrastructure repair/ 
rehab program  
(Due 7/1/21) 
On-going 
In 2022, the Town installed a new 
catch basin in line with an already 
existing pipe at the corner of Leary 
Drive and Quarry Road. The Town 
replaced some piping on Gardiners 
Wood Road and also replaced two 
pipes and one center line catch basin 
top on Lakes Pond Road. 
The Town replaced numerous catch 
basin tops on Butlertown Road prior 
to paving. 
Identify MS4 structures to 
repair, rehabilitate, or 
upgrade to reduce pollutant 
discharge.  
Department of 
Public Works 
December 
2022 
On-going 
The Town will review 
current practices and look 
for areas for optimization. 
6-8 Develop/implement 
plan to identify/ 
prioritize retrofit 
projects  
(Due 7/1/20) 
In Progress 
In 2021 and 2022, with the 
assistance of B&L, Town-owned sites 
with the greatest amount of 
impervious area were identified as 
potential candidates for retrofit 
projects. 
 
Develop a retrofit project 
plan to identify and prioritize 
DCIA connection projects 
Department of 
Public Works 
December 
2023 
On-going 
In 2023, the Town will 
continue working with its 
consultant to identify and 
prioritize potential 
projects for the Retrofit 
Program to the maximum 
extent practicable. 
6-9 Implement retrofit 
projects to disconnect 
2% of DCIA  
(Due 7/1/22) 
In Progress 
In 2021 and 2022, with the 
assistance of B&L, Town-owned sites 
with the greatest amount of 
impervious area were identified as 
potential candidates for retrofit 
projects. 
Implement retrofit projects 
Planning  
Jul 1, 2023 
On-going 
In 2023, the Town will 
continue working with its 
consultant to identify and 
prioritize potential 
projects for the Retrofit 
Program to the maximum 
extent practicable. 
6-10 Develop/ 
implement street 
sweeping program  
(On-going) 
Complete/ 
On-going 
Typically, all Town-owned roads are 
swept every year, starting after the 
last snow melt.  The Town had 
maintenance issues with their 
sweepers in 2021 and 2022 but, 
were able to sweep most of the 
town in 2022 and will continue their 
sweeping program in 2023. 
Continue sweeping all 
streets at least once per 
year, as soon as possible 
after snowmelt. 
Department of 
Public Works 
Jul 1, 2017 
On-going 
The Town continues 
reviewing current 
practices and looking for 
areas for optimization. 
6-11 Develop/ 
implement catch basin 
cleaning program  
(On-going) 
Complete/ 
On-going 
The Town cleans approximately 1/3 
of all of the catch basins annually.  
Continue current 
maintenance program in 
accordance with the Permit. 
Department of 
Public Works 
Jul 1, 2019 
On-going 
The Town continues 
reviewing current 
practices and looking for 
areas for optimization. 

 
Town of Waterford 2022 Annual Report 
Page 16 of 27 
Permit Number GSM000023 
Barton & Loguidice, LLC 
BMP 
Status 
Activities in current reporting 
period 
Measurable goal 
Department/ 
Person 
Responsible 
Date 
completed/ 
projected 
Additional details 
6-12 Develop/ 
implement snow 
management practices  
(Due 7/1/18) 
Complete/ 
On-going 
DEEP Guidelines on snow 
management provided to Town.  The 
Town streets and municipal lots 
were plowed, as necessary.  Roads 
were treated with salt (no sand), as 
necessary. 
Develop/implement snow 
management practices 
Department of 
Public Works 
Jul 1, 2017 
On-going 
The Town continues 
reviewing current 
practices and looking for 
areas for optimization. 
 
6.2 Describe any Pollution Prevention/Good Housekeeping activities planned for the next year, if applicable. 
 
Conduct annual MS4 training events. 
 
Continue to review MS4 property and operations maintenance practices and look for areas for optimization. 
 
Notify commercial facilities of their requirements to register under the Industrial Stormwater GP. 
 
Continue tracking disconnected DCIA using the table created. 
 
Continue efforts to identify and prioritize potential projects for the Retrofit Program to the maximum extent practicable. 
 
Continue street sweeping, catch basin cleansing and snow management practices. 
 
6.3 Pollution Prevention/ Good Housekeeping reporting metrics 
Metrics 
Employee training provided for key staff  
Yes – 5/15/22 
Street sweeping 
 
Curb miles swept 
~80 miles were swept in 2022 – ~1/3 of the Town experienced 
maintenance issues with the sweepers in 2022. 
Volume (or mass) of material collected 
~200 CY 
Catch basin cleaning 
 
Total catch basins in priority areas 
~3,000 
Total catch basins in MS4 
~3,000 
Catch basins inspected 
905 
Catch basins cleaned 
905 
Volume (or mass) of material removed from all catch basins 
~600 CY 
Volume removed from catch basins to impaired waters (if known) 
Unknown 
Snow management 
 
Type(s) of deicing material used 
Salt 
Total amount of each deicing material applied 
~2,290 tons 
Type(s) of deicing equipment used 
Truck/spreader 
Lane-miles treated 
242 miles 
Snow disposal location 
N/A 
Staff training provided on application methods & equipment 
Yes – as necessary 

 
Town of Waterford 2022 Annual Report 
Page 17 of 27 
Permit Number GSM000023 
Barton & Loguidice, LLC 
Municipal turf management program actions (for permittee properties in basins with N/P 
impairments) 
 
Reduction in application of fertilizers (since start of permit) 
Unknown 
Reduction in turf area (since start of permit) 
Unknown 
Lands with high potential to contribute bacteria (dog parks, parks with open water, & sites with 
failing septic systems) 
 
Cost of mitigation actions/retrofits 
N/A 
 
6.4 Catch basin cleaning program  
Provide any updates or modifications to your catch basin cleaning program. 
Catch basins have been inspected and cleaned out and the sumps have been measured.  The Town continues to clean and inspect approximately 1/3 of all of the catch basins annually, and 
the amount of material removed is recorded.  A list will be generated and the catch basins with the most material present will be put on a more frequent cleaning schedule to ensure that the 
50% design capacity for the sump is not exceeded. 
 
6.5 Retrofit program 
Briefly describe the Retrofit Program identification and prioritization process, the projects selected for implementation, the rationale for the selection of those projects and the total DCIA 
to be disconnected upon completion of each project. (Due 7/1/20) 
In 2021 and 2022, with the assistance of B&L, Town-owned sites with the greatest amount of impervious area were identified as potential candidates for retrofit projects.   
 
In 2022, as part of the Niantic River Watershed 4-Town Bio-Infiltration, Filtration & Water Collection Project, in cooperation with the Eastern CT Conservation District and funded by a Section 
319 grant, the Town of Waterford installed 20 catch basin smart sponge inserts (storm drain filters) in the neighborhood around the avenues east of Niantic River and 2 tree filters were 
installed on Scenic View Drive, all to treat run-off draining to Niantic River.  Operation & Maintenance Plans were also created for both the storm drain filters and for the tree filters (wells) to 
assist with the inspection and maintenance of the filters.   
 
The catch basin filter inserts that were installed were specially designed and installed to capture and filter stormwater runoff from impervious surfaces in the neighborhood around the 
avenues east of Niantic River to protect and improve water quality in an un-named brook and Niantic River.  These catch basin filter inserts provide the following benefits: reduces the 
frequency of maintenance required for BMPs downstream of the storm drain filters; captures trash, debris, and sediment, as well as removes fine sediment (TSS); removes phosphorous, 
hydrocarbons and oil; and, some filter media can remove heavy metals as well.  These catch basin filter inserts will filter stormwater runoff from the roadway and parking lots, removing up to 
99% of common NPS pollution, prior to its discharge to Niantic River. 
 
The tree wells installed are a Low Impact Development (LID) bio-retention practice that is used to capture and infiltrate stormwater.  The tree well plants absorb some of the water that flows 
into the unit and utilize some of the nutrients as well.  The top soil contains micro-organisms that are capable of breaking down a wide variety of common contaminants including 
hydrocarbons, fecal bacteria, pesticides, herbicides and fertilizer. The bark mulch provides carbon-rich organic material for both soil biota and the tree well plants.  The 2 tree well systems 
installed on Scenic View Drive intercept stormwater runoff from the roadway.  The Scenic View Drive tree wells are designed to infiltrate stormwater, preventing contaminated runoff from 
entering Niantic River and Bay via storm drain discharge.  Native ornamental grasses (PANICUM VIRGATUM `RUBY RIBBONS`) was installed in the tree wells, which are drought-tolerant. 
 
In 2023, the Town will continue working with its consultants to identify and prioritize potential projects for the Retrofit Program to the maximum extent practicable. 
 
Describe plans for continuing the Retrofit program and how to achieve a goal of 1% DCIA disconnection annually in future years.  (Due 7/1/22) 
In 2021 and 2022, with the assistance of B&L, Town-owned sites with the greatest amount of impervious area were identified as potential candidates for retrofit projects.  In 2023, the Town 
will continue working with its consultant to identify and prioritize potential projects for the Retrofit Program to the maximum extent practicable. 

 
Town of Waterford 2022 Annual Report 
Page 18 of 27 
Permit Number GSM000023 
Barton & Loguidice, LLC 
Part II: Impaired waters investigation and monitoring  
 
1. Impaired waters investigation and monitoring program 
 
1.1 Indicate which stormwater pollutant(s) of concern occur(s) in your municipality or institution.  
 
Nitrogen/ Phosphorus 
 
Bacteria  
 
Mercury  
 
Other Pollutant of Concern   
 
 
1.2 Describe program status. 
 
Discuss 1) the status of monitoring work completed, 2) a summary of the results and any notable findings, and 3) any changes to the Stormwater Management Plan based 
on monitoring results.  
Barton & Loguidice, LLC, the Town’s consultant, attempted to collect samples during multiple rain events during 2020, 2021, and again during 2022.  Due to the impaired outfalls 
proximity to the coast, most of the outfalls in the Town are impacted by tide levels and storm surges.  To date, wet weather samples were collected from 27 of the known 61 
outfalls that discharge to impaired waters.  Previously, there were 29 outfalls directly discharging to impaired waters and as part of the recent mapping updates, B&L has now 
located a total of 62 outfalls discharging to impaired waters.  Of the 27 outfall samples collected during wet weather events, 19 samples exceeded pollutant thresholds and require 
follow-up investigations.  Due to the limited number of qualifying storm events and the fact that most of the outfalls are tidally influenced, in 2023, B&L will continue focusing on 
collect