Town of Waterford Stormwater Management Plan (PDF)

Stormwater Management Plan 
for 
Town of Waterford 
15 Rope Ferry Road 
Waterford, CT 06385 
September 2017 
Prepared By:
41 Sequin Drive 
Glastonbury, CT  06033 
T: 860.633.8770 
F: 860.633.5971 


 
 
 
Stormwater Management Plan 
Town of Waterford 
 
TABLE OF CONTENTS 
 
Section  
 
 
 
 
 
 
 
 
 
 
     Page 
 
I. 
GENERAL PERMIT AUTHORIZATION AND ELIGIBLE ACTIVITIES ..................... 1 
II. 
BACKGROUND AND DEVELOPMENT OF THE PLAN ................................................ 2 
A. Overview of the Town ................................................................................................................................ 3 
B. Overview of Selected Components ........................................................................................................... 4 
C. SMP Implementation Team ..................................................................................................................... 5 
D. Coastal Management ................................................................................................................................... 5 
E. Endangered or Threatened Species .......................................................................................................... 6 
F. Aquifer Protection Areas ........................................................................................................................... 6 
G. Record Keeping ............................................................................................................................................ 6 
III. MINIMUM CONTROL MEASURES (MCM) ....................................................................... 6 
MCM 1 – PUBLIC EDUCATION .................................................................................................... 6 
BMP 1-1 – Implement Public Education Program ..................................................................................... 6 
BMP 1-2 – Address Education/Outreach for Pollutants of Concern ...................................................... 7 
BMP 1-3 – Town Website ............................................................................................................................... 8 
BMP 1-4 – Catch Basin Stenciling .................................................................................................................. 8 
BMP 1-5 – Household Hazardous Waste (HHW) Collection Days ..................................................... 8 
MCM 2 – PUBLIC PARTICIPATION ............................................................................................ 8 
BMP 2-1 – Comply with Public Notice Requirements for the SMP and Annual Reports ................. 9 
BMP 2-2 – Community Group Engagement ................................................................................................ 9 
BMP 2-3 – Interagency Meetings .................................................................................................................... 9 
MCM 3 – ILLICIT DISCHARGE DETECTION AND ELIMINATION (IDDE) .................. 10 
BMP 3-1 – Develop Written IDDE Program ............................................................................................ 10 
BMP 3-2 – Develop List and Maps of all MS4 Stormwater Outfalls in Priority Areas ..................... 10 
BMP 3-3 – Develop Citizen Reporting Program ....................................................................................... 11 
BMP 3-4 – Establish Legal Authority to Prohibit Illicit Discharges ...................................................... 11 
BMP 3-5 – Develop Record Keeping System for IDDE Tracking......................................................... 11 
BMP 3-6 – Address IDDE in Areas with Pollutants of Concern ........................................................... 12 
MCM 4 – CONSTRUCTION SITE RUNOFF CONTROL ....................................................... 12 
BMP 4-1 – Implement, Upgrade, and Enforce Land Use Regs or Other Legal Authority ................ 12 
BMP 4-2 – Develop/Implement Plan for Coordination in Site Plan Review and Approval ............. 13 
BMP 4-3 & 4-4 – Review Site Plans/Conduct Site Inspections for Stormwater Quality Concerns 13 
BMP 4-5 – Implement Procedure to Allow Public Comment on Site Development ......................... 13 
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Stormwater Management Plan 
Town of Waterford 
 
TABLE OF CONTENTS 
 
Section  
 
 
 
 
 
 
 
 
 
 
     Page 
BMP 4-6 – Notify Developers about DEEP Construction Stormwater General Permit .................. 13 
MCM 5 – POST-CONSTRUCTION STORMWATER MANAGEMENT ............................. 14 
BMP 5-1 – Establish and/or Update Legal Authority and Guidelines Regarding LID and Runoff 
Reduction in Site Development Planning .................................................................................................... 14 
BMP 5-2 – Enforce LID/Runoff Reduction Requirements for Development and Redevelopment 15 
BMP 5-3 – Long-Term Maintenance Plan for Stormwater Basins and Treatment Structures ........ 15 
BMP 5-4 – DCIA Mapping ........................................................................................................................... 15 
BMP 5-5 – Address Post-Construction Issues in Areas with Pollutants of Concern ......................... 16 
MCM 6 – POLLUTION PREVENTION/ GOOD HOUSEKEEPING .................................... 16 
BMP 6-1 – Develop/Implement Formal Employee Training Program ................................................. 16 
BMP 6-2 – Implement MS4 Property and Operations Maintenance .................................................... 16 
A 
Parks and Open Space ................................................................................................................. 16 
B 
Pet Waste Management .............................................................................................................. 17 
C 
Waterfowl Management ............................................................................................................. 17 
D 
Buildings and Facilities ................................................................................................................ 18 
E 
Vehicles and Equipment ............................................................................................................. 18 
F 
Leaf Management ......................................................................................................................... 19 
BMP 6-3 – Implement Coordination with Interconnected MS4s .......................................................... 19 
BMP 6-4 – Develop/Implement Program to Control Other Sources of Pollutants to the MS4 ..... 20 
BMP 6-5 – Evaluate Additional Measures for Discharges to Impaired Waters .................................. 20 
BMP 6-6 – Track Projects that Disconnect DCIA ................................................................................... 20 
BMP 6-7 – Develop/Implement Infrastructure Repair/Rehab Program .............................................. 21 
BMP 6-8 – Develop/Implement Plan to Identify/Prioritize Retrofit Projects .................................... 21 
BMP 6-9 – Develop/Implement Street Sweeping Program .................................................................... 21 
BMP 6-10 – Develop/Implement Catch Basin Cleaning Program ........................................................ 22 
BMP 6-11 – Develop/Implement Snow Management Practices ............................................................ 22 
A 
De-Icing Material Management ................................................................................................. 22 
B 
Snow and Ice Control Practices ................................................................................................. 22 
IV. SHARING RESPONSIBILITY .............................................................................................. 23 
A. Qualifying Local Program ...................................................................................................................... 23 
B. Qualifying State or Federal Program .................................................................................................. 23 
C. Coordination of Permit Responsibilities ........................................................................................... 24 
V. 
PROPER OPERATION AND MAINTENANCE ............................................................... 24 
VI. SIGNATURES AND PLAN MAINTENANCE .................................................................. 24 
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Stormwater Management Plan 
Town of Waterford 
 
TABLE OF CONTENTS 
 
Section  
 
 
 
 
 
 
 
 
 
 
     Page 
VII. KEEPING PLAN CURRENT ................................................................................................. 24 
VIII.WATER QUALITY MONITORING ................................................................................... 25 
A. Impaired Waters Outfall Investigation and Monitoring .................................................................... 25 
B. Impaired Waters Outfall Follow-up Investigations ............................................................................ 25 
C. Monitoring .................................................................................................................................................. 25 
D. Results Reporting ...................................................................................................................................... 25 
IX. DISCHARGES TO IMPAIRED WATERS OR WATER BODIES SUBJECT TO A 
POLLUTANT LOAD REDUCTION WITHIN A TMDL ......................................................... 26 
X. 
STORMWATER MANAGEMENT PLAN ENGINEERING CERTIFICATION ......... 27 
XI. SIGNATURE AND PLAN REVIEW .................................................................................... 28 
 
 
APPENDICES 
 
A 
Abbreviations and Definitions 
B 
MS4 Permit Registration Form, USGS Town Map, DEEP General Permit  
C 
Factsheet for the Town of Waterford Water Quality and Stormwater Summary 
D 
Pollution Prevention Team Members 
E 
Key Maps 
Subregional Drainage Basin Map with Impaired Water Bodies 
Connecticut Aquifer Protection Areas Map 
DEEP Natural Diversity Data Base Areas Map 
F 
MCM Timeline 
G 
IDDE Timeline 
H 
DEEP’s BMPs for Disposal of Snow Accumulation from Roadways and Parking Lots 
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Stormwater Management Plan 
Town of Waterford 
I. 
GENERAL PERMIT AUTHORIZATION AND ELIGIBLE ACTIVITIES 
The Connecticut Department of Energy and Environmental Protection’s (DEEP or “the Department”) 
General Permit for the Discharge of Stormwater from Small Municipal Separate Storm Sewer Systems (MS4 
General Permit or General Permit) authorizes the discharge of stormwater from or associated with a 
Small MS4, provided the requirements of Section 3.(b) of the General Permit are satisfied and the 
activity is conducted in accordance with the conditions listed in Section 5 of the General Permit to the 
Maximum Extent Practicable (MEP).  
The General Permit also authorizes certain non-stormwater discharges provided they are controlled to 
the MEP as required, they do not contribute to a violation of water quality standards, and they are 
documented in the Stormwater Management Plan (SMP) and are not significant contributors of 
pollutants to any identified MS4.  These permitted non-stormwater discharges include:   
 
• Uncontaminated groundwater discharges including, but not limited to, pumped groundwater, 
foundation drains, water from crawl space pumps and footing drains 
• Irrigation water including, but not limited to, landscape irrigation and lawn watering runoff 
• Residual street wash water associated with sweeping 
• Discharges or flows from firefighting activities (except training) 
• Naturally occurring discharges such as rising groundwaters, uncontaminated groundwater 
infiltration as defined in 40CFR 35.2005(20), springs, diverted stream flows and flows from 
riparian habitats and wetlands 
 
Per Section 3.(b) of the General Permit, the Town will remain authorized under the General Permit, 
given the activities are consistent with the following: 
 
(1) Coastal Management Act 
(2) Protections given to Endangered and Threatened Species 
(3) Regulations for Aquifer Protection Areas pursuant to Section 22a-354i of the Connecticut 
General Statutes 
(4) Stormwater is not discharged to a Publicly Owned Treatment Works (POTW) 
(5) Stormwater is not discharged entirely to groundwater 
(6) New or increased discharges to High Quality Waters will be evaluated and implemented with 
the MEP practices 
(7) Stormwater discharges to impaired waters in categories 5 or 4b of the most recent Connecticut 
Integrated Water Quality Report will not be increased 
 
 
 
 
 
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Stormwater Management Plan 
Town of Waterford 
 
II. 
BACKGROUND AND DEVELOPMENT OF THE PLAN 
The Town of Waterford (hereafter “Waterford”, “Town”, or “Municipality”) is registered under the 
DEEP’s General Permit.  This General Permit is effective from July 1, 2017 to June 30, 2022.  The 
Town was previously registered under the DEEP’s former General Permit for the Discharge of 
Stormwater from Small Municipal Separate Storm Sewer Systems, permit number GSM000023, 
which was effective from January 9, 2004 to June 30, 2017. 
 
The General Permit is applicable to any municipality or any state or federal institution that initiates, 
creates, originates or maintains a discharge authorized by the General Permit and that has filed a 
registration pursuant to Section 4 of the General Permit.  Municipal separate storm sewer system 
(MS4) means conveyances for stormwater (including roads with drainage systems, streets, catch basins, 
curbs, gutters, ditches, man-made channels or storm drains) owned or operated by any municipality or 
by any state or federal institution and discharging to surface waters of the state.  Small MS4, as 
referenced in the General Permit and this Stormwater Management Plan (SMP or “the Plan”), means 
any municipally-owned or -operated MS4 including all those located partially or entirely within an 
Urbanized Area (UA) that have at least 1,000 residents in the Urbanized Area (as determined by the 
2000 or 2010 census) and all state- and federally-operated MS4s (except DOT) and any other MS4s 
located outside an Urbanized Area as may be designated by the Commissioner of the DEEP.   
 
The General Permit requires many actions to reduce pollution coming from stormwater.  Common 
water pollutants include, but are not limited to: pesticides, fertilizers, oils, salt, litter, debris, and 
sediment.  These pollutants can cause water bodies to become impaired.  Another concern is the 
possible illicit connections from sanitary sewers and other sources which can transport harmful bacteria 
and other pollutants to water bodies. 
 
One requirement of the General Permit is the preparation of and compliance with this SMP.  This 
SMP was developed in accordance with the General Permit issued under the authority of Section 22a-
430b of the Connecticut General Statutes (CGS).  This SMP provides a framework for the rest of the 
conditions and actions required by the General Permit.   
 
This plan requires the development of Best Management Practices (BMPs) for each of the following 
Minimum Control Measures (MCM) of the Plan: 
• MCM 1 – Public Education 
• MCM 2 – Public Participation 
• MCM 3 – Illicit Discharge Detection and Elimination (IDDE) 
• MCM 4 – Construction Site Runoff Control 
• MCM 5 – Post-Construction Stormwater Management 
• MCM 6 – Pollution Prevention/Good Housekeeping 
 
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Stormwater Management Plan 
Town of Waterford 
 
Following the discussion of minimum control measures and their BMPs are sections discussing sharing 
of the responsibilities with other MS4s, water quality monitoring requirements, and the plan 
certifications.  
 
The Town is required to develop an implementation schedule with measurable goals through the five-
year permit period.  A timeline of the MCM for the Town is provided in Appendix F.  The Town is 
required to submit annual progress reports, and is subject to enforcement action as described in the 
Clean Water Act for failure to implement the BMPs they have selected.  The goals and implementation 
schedule provided in the Plan will meet the requirements of the General Permit subject to modification 
based on performance, review, and funding. 
 
A copy of the Town’s General Permit registration forms, a USGS map of the Town and a copy of the 
General Permit are provided in Appendix B. 
 
A. Overview of the Town 
The Town covers an area of approximately 44.6 square miles, located in Southeastern Connecticut, in 
New London County, as shown on the USGS Town Map, provided in Appendix B.  The approximate 
population of the town is 18,638 residents.  There is approximately 120 miles of Town-owned and -
operated roadway, with approximately 3,300 catch basins in operation.  Approximately two-thirds of 
the Town of Waterford is classified as an Urbanized Area; the northwest third of the Town is not 
considered to be urbanized.   
 
The Connecticut Department of Transportation (DOT) operates an MS4 on state highways located in 
the Town.  This system is regulated under the CT DOT’s General Permit.   
 
There may be a small interconnection with the City of New London’s MS4.  The Town is investigating 
this potential interconnection.  Implementation of the BMPs identified in this SMP will be coordinated 
between the Town, the CT DOT, and New London, and others, as applicable.    
 
The following drainage basins are located within the Town of Waterford:   
 
Subbasin # 
 
Name 
2000 
 
 
Southeast Shoreline, Long Island Sound (including Fenger Brook)* 
2201 
 
 
Jordan Brook 
2202 
 
 
Latimer Brook* 
2203 
 
 
Oil Mill Brook 
2204 
 
 
Niantic River (including Stony Brook)* 
3000 
 
 
Thames River* 
3004 
 
 
Oxoboxo Brook* 
3006 
 
 
Hunts Brook* 
 
*Sections of this waterbody may be impaired 
 
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Stormwater Management Plan 
Town of Waterford 
 
Latimer Brook and Oxoboxo Brook are not actually located within the Town limits.  A table of 
impaired waterways and a map showing drainage basins and impaired waters are presented in Appendix 
E.   
 
Additional information regarding the water quality for the Town was developed by the DEEP and is 
provided in the Factsheet: Town of Waterford Water Quality and Stormwater Summary, provided in 
Appendix C.  This document was created for each town that has submitted monitoring data under the 
current MS4 General Permit.  This document includes information on how stormwater can affect 
water quality in streams and rivers and a summary of data submitted by the Town to the DEEP.  This 
factsheet is intended to help the Town interpret their monitoring results and assist in compliance with 
the MS4 program. 
 
B. Overview of Selected Components 
A brief overview of some of the most important components of the SMP and the reasons they are 
critical is provided below. 
 
i. 
Annual Report 
By April 1, 2019, and annually thereafter by April 1, the Town will submit an Annual Report for the 
preceding calendar year electronically to the Department.  The report will include a written discussion 
of the status of compliance with the General Permit including but not limited to: a listing and brief 
description of all BMPs within each MCM; implementation schedules and overall status for each BMP; 
a discussion of the progress and status of the MS4 IDDE program; a discussion of measures to control 
discharges to impaired waters; a discussion of the MS4 stormwater monitoring program; and all 
monitoring data and information collected over the year.  A more detailed description of these 
requirements can be found within the General Permit, and goals on fulfilling these requirements before 
submitting the Annual Report can be found in this SMP. 
 
ii. 
Public Education and Involvement 
The Town’s residents can contribute to the pollution transported via stormwater by applying lawn 
pesticides, herbicides and fertilizers, littering, dumping pollutants into storm drains, failing to properly 
dispose of pet waste, and other actions which can be detrimental to the quality of stormwater 
discharging into water bodies.  Many people are unaware that they are polluting when engaged in these 
activities.  Therefore, public education and outreach and public involvement and participation will help 
minimize the amount of pollution contributed to the Town’s water bodies by residents.  Also, public 
education and outreach coupled with public involvement and participation allows the Town’s residents 
to have a voice regarding stormwater. 
 
iii. 
IDDE 
Illicit Discharge Detection and Elimination (IDDE) will lessen the amount of pollutants discharging to 
local water bodies.  Some people unknowingly dump pollutants into the storm drain or have illegal 
connections to the storm drainage system.  Once pollutants are present in a water body, or after a 
receiving water body’s physical structure and habitat have been altered, it is much more difficult and 
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Stormwater Management Plan 
Town of Waterford 
 
expensive to restore it to its previous condition.  Therefore, the use of a management system that relies 
first on preventing degradation of receiving waters is recommended. 
 
iv. 
Construction Site Stormwater Runoff Control 
Construction site runoff and post-construction site runoff should be reduced so that water bodies are 
not receiving additional pollutants or sediment.  Sediment causes water bodies to become physically and 
biologically altered.  Decreases in habitat quality can result from significant amounts of sediment 
covering these habitat areas. 
 
v. 
Pollution Prevention/Good Housekeeping 
Pollution prevention and good housekeeping is a critical MCM because it concentrates on municipal 
operations including the maintenance of other control measures.  These activities can make an 
immediate difference with local water body pollutant levels.  Street sweeping and other maintenance 
activities prevent sediment, salt and pollutants from entering the drainage system thereby minimizing 
pollutant loads to local water bodies. 
 
C. SMP Implementation Team 
The General Permit requires the Town to designate specific team members to be responsible for 
implementing each MCM.  This section outlines the responsibilities of designated team members for 
each BMP.  Town personnel may be responsible for more than one team member position.  Current 
team member names and contact information are included in the table provided in Appendix D.  
Changes in team members will be documented by updating this table, as necessary. 
 
The SMP Implementation Team for the Town of Waterford includes the following personnel: 
 
Director of Public Works 
 
Planning Director 
 
Recreation & Parks Director 
 
Utility Commission Chief Engineer 
 
Board of Education Facilities Manager 
 
Fire Services Administrator 
 
D. Coastal Management 
The Town will comply with the State of Connecticut Coastal Management Act (CCMA), CGS 
Section 22a-90 through 22a-112.  The Town will regulate development of the shoreline through 
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Stormwater Management Plan 
Town of Waterford 
 
municipal planning and the zoning boards and commissions.  Due to the low impact nature of work 
performed by the Town, the Town does not anticipate a conflict to occur. 
 
E. Endangered or Threatened Species 
The Town will comply with the State of Connecticut Endangered Species Act, CGS Section 26-
310(a).  The Town will conserve endangered and threatened species and their essential habitats and 
shall ensure that any action authorized, funded or performed by the Town does not threaten the 
continued existence of any endangered or threatened species unless the Town has been granted 
exemption by the DEEP.  Due to the low impact nature of work performed by the Town, the Town 
does not anticipate a conflict to occur.  A map detailing the locations in the Town that may contain 
endangered or threatened species is provided in Appendix E. 
 
F. Aquifer Protection Areas 
There are no aquifer protection areas identified in the Town of Waterford. 
 
G. Record Keeping 
The Town shall keep records required by the MS4 General Permit for at least five years following its 
expiration, or longer if requested by the Commissioner of the DEEP in writing.  Such records, 
including the SMP, shall be available to the public at reasonable times during regular business hours. 
 
 
III. 
MINIMUM CONTROL MEASURES (MCM) 
A copy of the DEEP’s MCM timeline is provided in Appendix F. 
 
MCM 1 – Public Education 
Public education is a key component of effective stormwater management.  By informing the public of 
potential risks to water quality caused by common activities, the potential for stormwater impacts can 
be reduced.  The goals of this MCM are: 
 
• To raise awareness that polluted stormwater runoff is the most significant source of water 
quality problems;  
• To motivate residents to use BMPs, which reduce polluted stormwater runoff; and 
• To reduce polluted stormwater runoff as a result of increased awareness and utilization of 
BMPs. 
 
BMP 1-1 – Implement Public Education Program  
Per Section 6.(a)(1)(A) of the General Permit, the Town will implement a Public Education Program 
by June 30, 2018. 
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Stormwater Management Plan 
Town of Waterford 
 
Educational articles will continue to be published in local publications such as the Recreation and Park 
Bulletin and the Senior Newsletter.  Fact sheets will continue to be available. 
 
The Town website (http://www.waterfordct.org) will provide links to promote the availability of these 
materials.  Currently, the Planning Department distributes educational material through annual 
mailings, newspaper article publications, and by including fact sheets with every permit application.  
The Town will also provide materials in a printed format to be on display in public locations at the 
town hall.   
 
Additional targeted outreach efforts will be completed by the Town to educate citizen developers on 
particular aspects of stormwater management.  The Town will coordinate with appropriate contractors 
where applicable to ensure that all required topics listed in this plan are covered and tracked on an 
annual basis. 
 
BMP 1-2 – Address Education/Outreach for Pollutants of Concern 
Per Section 6.(a)(1)(C) of the General Permit, the Town will acquire and/or develop and distribute 
associated stormwater educational materials that, at a minimum, address the impacts of phosphorus, 
nitrogen, bacteria, and mercury impairments and how they might relate to water quality.  Some of the 
areas of concern may include: 
 
• sources of stormwater 
• pet and farm (manure) waste 
• impact of stormwater on water bodies 
• waterfowl 
• steps residents can do to reduce pollutants 
• impervious cover 
• septic systems 
• use of fertilizers, pesticides, and herbicides 
• grass clippings and leaves management 
• mercury disposal and recycling 
• detergent use 
• illicit discharges and cross connections 
• sediment discharge 
• improper disposal of wastes into the MS4 
 
The Town will identify locations where their MS4 discharges into impaired waters and will provide 
educational outreach specific to the sources of that impairment.  Targeted outreach efforts may include 
K-12 students, agricultural areas, commercial businesses, developers, homeowners, etc. 
 
Currently, the Town distributes information on common sources of phosphorus, nitrogen, bacteria, 
and mercury pollution and how to prevent or reduce the amount reaching the MS4 and discharging 
into waterways since the beginning of the existing 2004 General Permit, and will continue these efforts 
under the new General Permit. 
 
Examples of public education conducted and to be continued include but are not limited to:  
• Brochure distribution featuring topics such as “Don’t Trash the Grass”, “Step by Step” produced by 
the Long Island Sound Study, “10 Things You Can Do to Prevent Stormwater Runoff Pollution”, 
and more;  
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Stormwater Management Plan 
Town of Waterford 
 
• Visitation to Waterford elementary schools by the “Windows on the Waters” van to demonstrate 
how stormwater enters watersheds;  
• Household Hazardous Waste collection days (Qualifying Local Program); and  
• Catch basin stenciling in recreational and high pedestrian areas (completed in 2007).  
 
BMP 1-3 – Town Website  
The Town will update its website to include additional stormwater-related information.  Copies of the 
SMP, annual stormwater reports, recent stormwater monitoring results, the requirements to determine 
if a proposed development/construction activity is subject to authorization under the DEEP’s General 
Permit for the Discharge of Stormwater and Dewatering Wastewaters Associated with Construction Activities 
(Construction Stormwater General Permit), a link to the DEEP’s General Permit for the Discharge of 
Stormwater Associated with Industrial Activities (Industrial Stormwater General Permit), and links to 
stormwater educational materials discussed with BMP 1-1 and 1-2 will be presented on the website.  In 
addition, the annual schedule for regional household hazardous waste collection days and leaf pickups 
will be posted on the Town’s website.   
 
Links to the stormwater webpage will be provided from both the Public Works and the Planning & 
Development pages on http://www.waterfordct.org. 
 
BMP 1-4 – Catch Basin Stenciling 
The Town will continue an on-going stenciling program in which catch basins in the Town are 
prioritized and stenciled.  Currently, the highest priority 10% and an additional 20% of catch basins 
have been stenciled.  A working map of the prioritized and completed catch basins will be kept updated 
and on file with the Public Works Department.  Catch basin stenciling is currently completed.  The 
Town will continue stenciling new catch basins, as necessary. 
 
BMP 1-5 – Household Hazardous Waste (HHW) Collection Days 
The Town will continue to coordinate and advertise this Qualifying Local Program to raise public 
awareness on methods for use and disposal of common household pollutants wastes. The town will 
publish an article and schedule for the regional HHW Collection Days annually. Collections will be 
coordinated through the Southeastern Connecticut Regional Resource Recovery Authority 
(SCRRRA) and performed by a private contractor at various locations in Southeastern Connecticut, 
including one per year in Waterford. Town residents may also utilize HHW Collection Days hosted 
by other participating municipalities. 
MCM 2 – Public Participation 
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Stormwater Management Plan 
Town of Waterford 
 
Public participation is a key component of effective stormwater management.  By involving the public in 
management of water quality affected by common activities, the potential for stormwater impacts can be 
reduced.  The goals of this MCM are to: 
 
• Involve the community in planning and implementing the Town’s stormwater management 
activities. 
• Provide a minimum 30-day notice to the public for this plan and annual reports. 
 
BMP 2-1 – Comply with Public Notice Requirements for the SMP and Annual Reports 
Per Section 6.(a)(2) of the General Permit, the Town will publish a public notice on its website 
(http://www.waterfordct.org/) and in the local newspapers to inform the public of the SMP and the 
Annual Report, and to solicit comments on the SMP and Annual Report.  The notice will provide a 
contact name (with phone number, address, and email) to whom the public can send comments and a 
publicly accessible location on the web and in the town hall and/or library where the SMP and Annual 
Report are available for public review. The public notices will allow for 30-day comment periods, at a 
minimum.  The Town will publish the public notice for this SMP in April 2017.  The Town will 
publish the public notice for the Annual Reports annually, no later than January 31. 
 
A hard copy of the SMP and the Annual Reports will be available for public review at the Public 
Works Department, the Planning and Zoning office, the Library, and the Town Clerk’s office. 
 
BMP 2-2 – Community Group Engagement 
The Town will identify and reach out to local organizations, such as The Niantic River Watershed 
Committee, Eastern Connecticut Conservation District, Waterford Land Trust, and scout troops, that 
may want to participate in the review and implementation of this SMP.   
 
The Town will also reach out to SCRRRA on partnering on both public participation and public 
education activities.   
 
BMP 2-3 – Interagency Meetings 
The Town will continue to facilitate a panel of staff and volunteers in order to annually review and 
update the SMP. 
 
 
 
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Stormwater Management Plan 
Town of Waterford 
 
MCM 3 – Illicit Discharge Detection and Elimination (IDDE) 
This MCM outlines a program to detect and eliminate current illicit discharges to the MS4 and prevent 
further illicit discharges in the future.  All activities for this measure will be completed in the Town’s 
Priority Areas (urbanized area, catchment areas with directly connected impervious area (DCIA) 
>11%, and outfalls that discharge to impaired waters).  The goals of this MCM are: 
• Find the source of any illicit discharges. 
• Eliminate those illicit discharges. 
• Ensure ongoing screening and tracking to prevent and eliminate future illicit discharges. 
 
BMP 3-1 – Develop Written IDDE Program 
Per Section 6.(a)(3) of the General Permit, the Town will develop a written IDDE Program to detect, 
locate and eliminate illicit discharges (to the maximum extent practicable) from the MS4 within the 
Town’s priority areas by June 30, 2018.  The IDDE Program will provide enforceable legal authority to 
eliminate illicit discharges, assign responsibilities, and develop a citizen reporting program.  The IDDE 
Program will also outline the outfall screening and IDDE protocols consistent with Appendix B of the 
General Permit to identify, prioritize, and investigate MS4 catchments for suspected illicit discharge of 
pollutants.  Also, the IDDE Program will outline follow-up screening and illicit discharge prevention 
procedures. 
 
The Town will develop and implement an IDDE Program, that complies with Appendix B of the 
General Permit in accordance with the timeline provided in Appendix G. 
 
BMP 3-2 – Develop List and Maps of all MS4 Stormwater Outfalls in Priority Areas 
The Town will develop an outfall and interconnection inventory that identifies each outfall and 
interconnection discharging from the MS4, records its location and condition, and provides a 
framework for tracking inspections, screenings and other activities under the Town’s IDDE Program 
by June 30, 2019.  Additional requirements regarding this BMP are provided in Section 6.(a)(3)(C) of 
the General Permit.  The Town will complete a database of all stormwater discharges from a pipe or 
conduit located within and owned or operated by the municipality and all interconnections with other 
MS4s.   
 
The Town is well underway to completing this task and has mapped approximately all outfalls 15” and 
wider in the town, and all outfalls 12” and wider in the UA to date.  The Town will continue to comply 
with this BMP to meet the required deadlines established in the General Permit and this SMP.   
 
 
 
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Town of Waterford 
 
BMP 3-3 – Develop Citizen Reporting Program 
Per Section 6.(a)(3)(A)(iii), the Town will develop and implement a citizen’s reporting program for 
illicit discharges.  Currently, citizens call the Public Works Department to report suspected illicit 
discharges into the stormwater system.  An updated system will be developed to include use of Municity 
Software for submitting a report.  This information will be posted on the town’s website per BMP 1-3.  
 
The Town will affirmatively investigate and eliminate any illicit discharges for which a time and 
location of discharge are provided.  The Town will promptly inspect the reported outfall or manhole 
and proceed according to the requirements of the written IDDE program.   
 
All citizen reports and responses will be included in the Town’s Annual Report.  
 
BMP 3-4 – Establish Legal Authority to Prohibit Illicit Discharges 
Per Section 6.(a)(3)(B) of the General Permit, the Town will update the necessary and enforceable legal 
authority by statute, ordinance, rules and regulations, permit, easement, contract, order or any other 
means, to eliminate illicit discharges.  
 
Chapter 13.16 of the Town Ordinances addresses Stormwater Quality Management and Discharge 
Control.  “The purpose and intent of this chapter is to ensure the health, safety, and general welfare of the 
citizens, and protect and enhance the water quality of watercourses and water bodies in a manner pursuant to 
and consistent with the Federal Clean Water Act by reducing pollutants in stormwater discharges to the 
maximum extent practicable and prohibiting non-stormwater discharges to the municipal storm street drainage 
system.”  This ordinance generally meets the requirements for this BMP.  The entire ordinance will be 
reviewed and updated by June 30, 2018.  Specific areas to be reviewed include the list of discharges from 
certain activities that are not considered a source of pollutants to the storm drain system (such as 
dechlorinated swimming pool discharges) and the authorization of fines and penalties.   
 
BMP 3-5 – Develop Record Keeping System for IDDE Tracking 
Per Section 6.(a)(3)(A)(v), the Town will keep a record of illicit discharge abatement activities 
including location (latitude and longitude or address), description, date(s) of inspection, sampling data 
(if applicable), action(s) taken, date of removal or repair and responsible party.  
 
 
 
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Stormwater Management Plan 
Town of Waterford 
 
BMP 3-6 – Address IDDE in Areas with Pollutants of Concern 
The Town will identify which areas in town are most likely to contribute nitrogen, phosphorus, and 
bacteria to the MS4.  This assessment will consider: historic on-site sanitary system failures, proximity 
to bacterial impaired waters, low infiltrative soils, and shallow groundwater.  Any areas determined to 
have a high potential for septic system failure will be reported to the Health Department for corrective 
action. 
 
Sanitary sewers are available to the majority of residences and businesses in Town.  All residences 
within 200 feet of a public road equipped with sewers are required to be connected.  Houses within 100 
feet of a waterbody are required to be connected to the sewer system, even if they are more than 200 feet 
from a public road equipped with sewers.  The Town Utility Commission maintains a list of a residence 
that are not connected to the sanitary sewer system.  The majority of these residences are not located 
within the UA.  The Town will identify areas where structures that are not connected to the sanitary 
sewer system and are located near the MS4 by June 30, 2018.  These areas will be prioritized for 
screening in the IDDE program.   
 
MCM 4 – Construction Site Runoff Control 
This MCM outlines procedures for minimizing polluted stormwater runoff from activities that disturb 
one or more acres of land. The goal of this MCM is to minimize polluted stormwater runoff from 
construction sites and prevent it from carrying sediment into waterways via MS4 infrastructure. 
 
BMP 4-1 – Implement, Upgrade, and Enforce Land Use Regs or Other Legal Authority 
Per Section 6.(a)(4)(A) of the General Permit, the Town will revise its land use regulations to establish 
the legal authority to control stormwater runoff from construction sites by June 30, 2019.  Additional 
requirements for establishing legal authority can be found in Section 6.(a)(4)(A) of the General Permit. 
 
The General Permit addresses projects with one acre or more of soil disturbance, but current zoning 
regulations call for approved erosion and sediment control plans for any site where the area of 
disturbance is cumulatively greater than 0.5 acre per section 25.5 of the Waterford Zoning Regulations.  
Per the existing 2004 General Permit, revisions have been made to the Waterford Zoning Regulations 
to reduce the impact of development.   
 
The Town will review the existing regulations within six months for compliance with The General 
Permit.  The regulations will be updated by June 30, 2019.  
 
 
 
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Town of Waterford 
 
BMP 4-2 – Develop/Implement Plan for Coordination in Site Plan Review and Approval 
In accordance with Section 6.(a)(4)(B) of the General Permit, the Town coordinates the functions of 
all the departments and boards involved in the review, permitting, or approval of land disturbance and 
development projects within the MS4. Applications are received by the Department of Planning 
Development.  Applications are then routed through the Planner, Environmental Planner, Director of 
Public Works, Utility Commission, and Fire Marshal for technical review and comment.  The Town’s 
regulations provide for third party technical review, as needed.   
 
BMP 4-3 & 4-4 – Review Site Plans/Conduct Site Inspections for Stormwater Quality Concerns 
Per Section 6.(a)(4)(C) of the General Permit, the Town will conduct site plan reviews that incorporate 
consideration of stormwater controls or management practices to prevent or minimize impacts to water 
quality.   
 
The Town conducts site inspections during installation of drainage and stormwater management 
system as well as during times when land disturbances are occurring.  The purpose of these routine 
inspections is to assess the adequacy of the installation, maintenance, operation, and repair of 
construction and post-construction control measures and take enforcement action when necessary.  
 
BMP 4-5 – Implement Procedure to Allow Public Comment on Site Development 
Per Section 6.(a)(4)(D) of the General Permit, the Town’s procedure for public involvement in 
proposed and on-going development and land disturbance activities is as follows:  
 
The Town follows all State of Connecticut public notice and public hearing requirements on 
applications for planning and zoning, subdivision, wetlands applications, etc.  The Town follows up on 
all public comments or complaints received concerning on-going land disturbance and development 
activities.  
 
BMP 4-6 – Notify Developers about DEEP Construction Stormwater General Permit 
Per Section 6.(a)(4)(E) of the General Permit, the Town will notify developers and contractors of their 
potential obligation to obtain authorization under DEEP’s Construction Stormwater General Permit if 
their project disturbs more than one acre of land and results in a point source discharge to Connecticut 
surface waters directly or through the Town’s MS4.  The Town will also require a copy of the Storm 
Water Pollution Control Plan be made available to the Town on request.  
 
Town ordinance currently requires all developers to comply with State requirements for stormwater 
discharges from construction activities and from industrial activities. The Town will update its 
application forms to include a line item on the application checklist to include determining if an 
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Town of Waterford 
 
authorization is required under the DEEP’s Construction Stormwater General Permit by July 1, 2017. 
In addition, the Town will add a note relative to this requirement on the webpage identified in BMP 1-
3. 
 
MCM 5 – Post-Construction Stormwater Management 
This MCM outlines the Town’s program to address stormwater runoff from new or re-development 
projects that disturb one or more acres of land.  The goal of this MCM is to mitigate the long-term 
impacts of new and re-development projects on water quality through proper use of low impact 
development (LID) and runoff reduction practices. 
 
BMP 5-1 – Establish and/or Update Legal Authority and Guidelines Regarding LID and Runoff 
Reduction in Site Development Planning 
Per Section 6.(a)(5) (LID) of the General Permit, by June 30, 2021, the Town shall implement and 
enforce a program to address construction and post-construction stormwater discharges from land 
disturbing activities and after site stabilization has been achieved.  This shall be based on the 
Connecticut Guidelines for Soil Erosion and Sediment Control (latest edition) and the Connecticut 
Stormwater Quality Manual (as amended).   
 
The Town will establish or update the existing legal authority by ordinance, bylaw, regulation, standard 
condition of approval, or other means to require, to the MEP, developers and contractors seeking the 
Municipality’s approval to consider the use of LID and runoff reduction site planning and development 
practices that meet or exceed those LID and runoff reduction practices in the CT Stormwater Quality 
Manual prior to other stormwater management practices allowed in the Town’s land use regulations, 
guidance or construction project requirements.  
 
Refer to Section 6.(a)(5) of the General Permit for additional information regarding the requirements 
for establishing legal authority in site development planning. 
 
Currently, Section 25.5 of the Waterford Zoning Regulations requires an approved erosion and 
sediment control plan for any site plan application where area of disturbance is cumulatively greater 
than 0.5 acre.  The approved plan must include design criteria, construction details, 
application/installation procedures, and an operation and management (O&M) plan for stormwater 
management facilities. 
 
The Planning & Zoning Commission is in the process of revising the Subdivision Regulations to 
incorporate green infrastructure, LID techniques, and stormwater design specifications into 
Waterford’s infrastructure specifications.  The Commission will finalize these amendments and bring 
them to a public hearing for adoption in 2017.  The Commission has also begun work to amend 
sections 25.5 and 1 [Definitions] of the Zoning Regulations to integrate standards from the new 
subdivision regulations into the Zoning Regulations.  
 
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Town of Waterford 
 
In addition, the Town will review its current regulations including site planning requirements, zoning 
regulations, street design regulations, and infrastructure specifications with minimum size criteria for 
impervious cover, to identify and, where appropriate, reduce or eliminate existing regulatory barriers to 
implementation of LID and runoff reduction practices to the MEP.   
 
BMP 5-2 – Enforce LID/Runoff Reduction Requirements for Development and Redevelopment 
Per Section 6.(a)(5)(A) of the General Permit, the Town will review its current regulations including 
site planning requirements, zoning regulations, street design regulations, and infrastructure 
specifications with minimum size criteria for impervious cover, to identify and, where appropriate, 
reduce or eliminate existing regulatory barriers to implementation of LID and runoff reduction 
practices to the MEP.   
 
BMP 5-3 – Long-Term Maintenance Plan for Stormwater Basins and Treatment Structures 
Per Section 6.(a)(5)(D) & (B) of the General Permit, the Town will 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 Town’s Priority Areas to ensure their long-term 
effectiveness.  
 
The Town maintains a list of retention/detention basins and stormwater treatment structures, and will 
update the list, as needed.  The Town will perform an annual inspection of those retention/detention 
ponds and stormwater treatment structure