Operations and Maintenance Requirements
The Town’s system was completely mapped in 2011 along with the town-wide geographic information system (GIS) mapping effort for the wastewater collection system, which only shows the locations of pipes, catch basins, manholes, and outfalls. However, the condition of these structures is not well understood or documented except for anecdotal reports based on observations during catch basin cleaning operations, complaint investigation, and emergency response incidences which reveal significant problems with aging infrastructure, failed pipes, improper connections to sanitary sewer lines, deteriorated catch basins, and undersized pipes to adequately handle storm flows.
Department Organization and Responsibilities
The Department of Public Works (DPW) is tasked with the bulk of managing stormwater-related activities, including: cleaning streets, storm drains, and clogged drain lines and outfalls; repairing broken manholes, catch basins, and storm drain lines; repairing damaged streets from failed pipes – often on an emergency basis; investigation and removal of improper connections to storm drains; and budgeting, manpower allocation, and management of capital improvement activities.
Capitol project planning for stormwater controls is an activity shared among the Treasurer’s office, the Planning Department, and the DPW. Permit compliance and reporting for stormwater and wastewater are handled by the Community Development Department and the Water Pollution Control Department (WPC), respectively. The Community Development Department also assists other departments with grant writing tasks to obtain capital project funding and grant administration.
Since 2007, the Town (WPC) has been working under administrative orders with United States Environmental Protection Agency (US EPA) to address the issue of excessive flows to the WWTF as a result of pavement and roof runoff and high groundwater conditions that would otherwise cause flooding on private property and building basements that were diverted to the sanitary sewer system. The WPC Department has since embarked on an ambitious program to identify the locations of stormwater infiltration and inflow into the collection system and undertake necessary remedial actions, including: development of a hydraulic model of the collection systems, initiation of routine cleaning of all sewer lines, elimination of inflow from private property roof leaders and downspouts, extensive rehabilitation (slip-lining) of sewers, replacement of outmoded equipment at pump stations and the central treatment plant, measures to control the entry of sewer-clogging fats, oils and grease into the collection system, removal or relocation of extraneous flows from private sewer connections including groundwater infiltration, and public education. Find more information on the Water Pollution Control Facility Capacity, Management, Operation and Maintenance Program 2015 Annual Report here.
The majority of the Town is served drinking water by the Bristol County Water Authority which derives its water from sources outside the Town boundaries, while the majority of surface waters in and around the Town are designated Class A (Class SA – for sea water), which means that the waters should be suitable for shellfish harvesting for direct human consumption, primary and secondary contact recreational activities, and fish and wildlife habitat. The Kickemuit River estuary and Mt Hope Bay are operated as conditionally approved shellfishing waters and close for 7 days following rainfall in excess of ½ inch in 24 hours. RIDEM has monitored various stormwater outfalls to these tidal waters sufficiently to conclude that Bristol stormwater discharges are contributing to observed water quality impairments, and requires that stormwater discharges contributing to violations of water quality standards be addressed by those responsible – which includes the Town and RIDOT.
Phase II MS4 General Permit and Stormwater Management Program Plan
Prior to 2004, stormwater management was regulated primarily as a “development” related concern by the State’s Office of Water Resources and by the Town Community Development and Public Works Departments. Today, in accordance with the Clean Water Act, waterbodies identified as “impaired” (i.e. those waters that do not meet water quality standards) must be studied to determine necessary pollutant reductions to bring these waters into compliance with applicable water quality standards. These studies called “total maximum daily loads” (TMDLs) establish the acceptable amount of pollutants that may be discharged to a waterbody and still meet its designated uses and guide water quality restoration plans and activities.
In accordance with requirements established by the EPA, RIDEM issued a General Permit in 2004 to discharge stormwater to waters of the State from the Town of Bristol’s municipal separate storm sewer system (MS4s). In brief, this permit requires the Town to employ six Minimum Control Measures to manage stormwater and reduce water quality impacts, including: public education, public involvement, controls on new development stormwater impacts both during construction and following development, illicit discharge detection and elimination (IDDE), and pollution prevention and good housekeeping (e.g., street and catch basin cleaning). As required, the Town developed a Stormwater Management Program Plan in 2004 and updated in 2008, which describes all the activities necessary to comply with the permit. Find more information on the “Phase II Stormwater Management Program Plan” and MS4 General Permit here.
State Roads and RIDOT Consent Order Requirements
Approximately 10% of the roads in Bristol are maintained by the RIDOT, which are subject to the same permit requirements as municipalities with an MS4, including Bristol. As a result of chronic non-compliance, EPA and RIDOT entered into a consent decree in 2015 requiring RIDOT to undertake a set of specific actions to address stormwater pollutant conveyed through their storm drain system. In order to comply, RIDOT is planning to undertake extensive field work, soil testing, engineering assessments, and preliminary designs of controls to remedy pollutant discharges. Potential barriers and permitting obstacles must be identified, and periodic progress reports must be submitted to EPA.