NCS000558_Benson MS4 AUDIT REPORT_20200207

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000558
TOWN OF BENSON, NC
303 East Church Street
Benson, NC 27504
Audit Date: 12/18/2019
Report Date: 02/07/2020
North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 9th floor
1612 Mail Service Center
Raleigh, NC 27699-1612

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NC5000558 Benson M54 Audit 20191218

TABLE OF CONTENTS
Audit Details....................................................................................... ..............1
..............................................
PermitteeInformation..................................................................................................................................2
SupportingDocuments.......................................................,......................................................................... 3
Program Implementation, Documentation & Assessment.............................._..............................._............4
Illicit Discharge Detection and Elimination (I©DE)....... ...............::.............................:.... .:...:.._..............8
Post -Construction Site Runoff Controls ........... :........ :........ :............... :........................ :.............. :................. 11
Pollution Prevention and Good Housekeeping for Municipal Operations.................................................16
Site Visit Evaluation: Municipal Facility No. 1.............................................................................................10
Site Visit Evaluation: MS4 Outfall No. 1................. :........................................ :....... :............... i.............. :.... 21
Site Visit Evaluation: MS4 Outfall No. 2.........................._...........................................................................23
Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1 .......... :................................. 25
Site Visit. Evaluation: Post -Construction Stormwater Control Measure No. 2............................................28
Appendix A: Supporting Documents
DISCLAIMER
This audit consists of an evaluation of program compliance with the issued permit and implementation of
the approved Stormwater Management Plan. This audit report does not include a review of all program
components, and program deficiencies in addition to those noted may be present. The Permittee is
required to assess program progress and permit compliance, and to implement the approved Stormwater
Management Plan in accordance with the issued permit.
NCS000558 Benson MS4 Audit 20191218 ii

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NCS000558 Benson MS4 Audit 20191218

Audit Details
Audit ID Number:
Audit Date(s):
NCS000558—Benson M54 Audit_20191118
12/18/2019
Minimum Control Measures Evaluated.
0 Program Implementation, Documentation & Assessment
❑ Public Education & Outreach
❑ Public Involvement & Participation
® Illicit Discharge Detection & Elimination
❑ Construction Site Runoff Controls — No delegated Sediment and Erosion Control Program
❑ Construction Site Runoff Controls — Delegated Sediment and Erosion Control Program
X Post -Construction Site Runoff Controls
Z Pollution Prevention and Good: Housekeeping for Municipal Operations
❑ Total Maximum Daily Loads (TMDLs)
Field Site Visits:
M Municipal Facilities. Number visited: 1
® MS4 Outfalls. Number visited: 2
❑ Construction Sites. Number visited:
® Post -Construction Stormwater Runoff Controls. Number visited: 2
❑ Other: Number visited:l .'
❑ Other: Number visited:
Inspector(s) Conducting Audit
Name, Title
Organization
Thad Valentine, Raleigh Region Stormwater Inspector
NCDEQ-DEMLR-RRO
Natalie Norberg, Raleigh Region Stormwater Inspector
NCDECL DEMLR-RRO
Paul Clark, WSWP Coordinator
NCDEQ-DEMLR
Audit Report Author: Paul Clark
Signature 4 _
Date:
all �;Zo-�12 0
NCS0.00558—Benson MS4 Audit 20191218 Page 1 of 31

Permittee Information
MS4 Permittee Name:
Town of Benson
Permit Effective Date:
February 1, 2018
Permit Expiration Date:
January 31, 2023
State, ZIP: 303 East Church Street, Benson, NC 27504
Date of Last MS4 Inspection/Audit:City,
NA
Co-permittee(s), if applicable: NA
Permit Owner(s) of Record:
Frederick Nelson, Interim Town Manager
Kimberly Pickett, Assistant Town Manager
Timothy Robbins, Public Utilities Director
Primary MS4 Representatives Participating in Audit
Name. Title
Organization
Tim Robbins, Public Utilities Director
Town of Benson
Erin Joseph, Planning Director
Town of Benson
Fred Nelson, Interim Town Manager
Town of Benson
Kim Pickett, Assistant Town Manager
Town of Benson
Jerry Medlin, Mayor
Town of Benson
MS4 Receiving Waters
Waterbody
Classification
Impairments
Hannah Creek (Meuse RB)
C; NSW
Benthos, Dissolved Oxygen
Driving Branch (Neuse RB)
C; NSW
No data
Mingo Swamp (Cape Fear RB)
C; Sw
No data
East Mingo Swamp (Cape Fear RB)
C; Sw
No data
NCS000558_Benson MS4 Audit_20191218 Page 2 of 31

Supporting Documents
Item
Number
Document Tide
When Provided
(Prior to/During/After)
1
2019 Annual Report
Prior
2
Agreement between Town of Benson and County of Johnston Concerning
Stormwater Management (not signed)
Prior
3
Stormwater System Map. (Partial) Town of Benson - 2015
Prior
4
Municipal Facility Inventory
During
5
NCDA&CS — NC Pesticide Board — Pesticide Applicator Identifications
During
6
Unified Development Code (Sections of Articles Two and Six)
During
7
List of Developments with Stormwater Control Measures (2017-2019)
After
8
Charles Hardee Pest License (others viewed during audit)
After
9
Sanitary Sewer Overflow Response Plan
After
NCS.0.00558_Benson MS4 Audit_20191218 Page.3 of 31

Program Implementation, Documentation & Assessment
Staff Interviewed:
Tim Robbins, Utilities Director
(Name, Title, Role)
Erin Joseph, Planning Director
Fred Nelson, Interim Town Manager
Kim Pickett, Assistant Town Manager
Jerry Medlin, Mayer
Permit Citation
Program Requirement
Status
Supporting
Doc No.
H.A.1
The permittee maintained adequate funding and staffing to implement and manage
Staffing and
the provisions of the Stormwater Plan and meet all requirements of the permit.
V o
Funding
The Stormwater Plan identifies a specific position(s) responsible for the overall
coordination, implementation, and revision to the Plan.
Responsibilities for all components of the Stormwater Plan are documented and
position(s) assignments provided.
NO
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see stormwater e-payments on DEMLR MS4 web page).
Comments
Benson population is 3500. Benson does not have a current Stormwater Management Plan and there is no dedicated program
funding. The DEQ ePayment statement indicates that the permittee is current on all invoice payments as of 12/20/2019.
II.A.2 Stormwater
The permittee evaluated the performance and effectiveness of the program
Plan
components at least annually.
%,
Implementation
and Evaluation
If yes, the permittee used the results of the evaluation to modify the program
not
components as necessary to accomplish the intent of the Stormwater Program.
;.dVirah+P
Did the permitted MS4 discharges cause or contribute to non -attainment of an
applicable water quality standard?
If yes, did the permittee expand or better tailor its BMPs accordingly to address
Not
the non -attainment?
Applicable.
Comments
Benson does not evaluate program performance and effectiveness, but submitted a 2019 annual report utilizing the online BIMS
SWMPA.
Hannah Creek within Benson jurisdiction is impaired and Benson is discussing how to best address this with DEQ-DWR. The Benson
wastewater treatment plant has been determined to be a main cause of the impairment. DEMLR may also be involved in this
discussion because voluntary Stormwater efforts associated with TMDL may also be included.
NCS000558_Benson MS4 Audit_20191218 Page 4 of 31

Program Implementation, Documentation & Assessment
II.A.3
Keeping the
The permittee kept the Stormwater Plan up to date.
Jo
Stormwater Plan
Up to Date
The permittee notified DEMLR of any updates to the Stormwater Plan.
IN
cable
Comments
The permittee does not have a current Stormwater Management Plan.
11.A.4 Availability The permittee kept an up-to-date version of its Stormwater Plan available to the
of the Stormwater No
Division and the public online.
Plan
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
authority necessary to implement and enforce the requirements of the permit.
Comments
The permittee's Unified Development Code is online: http:J/townofbenson.com/DoeumentCenter/View/863/Unified-Development-
Ordinance-UDO and provides authority to implement a few stormwater requirements.
II.A.3 & II.A.5
Stormwater Plan
Did DEMLR require a modification to the Stormwater Plan?
No
Modifications
If yes, did the permittee complete the modifications in accordance with the
Not
established deadline?
kpplicabte
Comments
II.A.6 Sharing
Responsibility
Are any control measures implemented by an entity other than the permittee?
If yes, is there a written agreement in place?
1'
Comments
Benson has agreement with Triangle J Council of Government (TJCOG) to implement the public education measure, but Benson
needs to document this and other things they are doing that meet (or partially meet) minimum measures. Benson has an
agreement with Johnston County (JOCO) delegating authority for JOCO to ensure that new development and redevelopment within
Benson are subject to JOCO stormwater ordinance. Under this agreement, Benson gives authority to JOCO to administer the
construction and post construction measures of the MS4 Program.
II.A.7
The permittee maintained written procedures for implementing the. six minimum
Written
control measures.
Procedures
Written procedures identified specific action steps, schedules., resources and
responsibilities for implementing the six minimum measures.
NCS000558_Benson MS4 Audit 20191218 Page of 31

Program Implementation, Documentation & Assessment
Comments
Benson has agreement with Triangle J Council of Government (TJCOG) to implement the public education measure, but Benson
needs to document this and other things they are doing that meet (or partially meet) minimum measures,
III• A The permittee maintained documentation of all program components including, but
Program not limited to, inspections, maintenance activities, educational programs,
Documentation implementation of BMPs, enforcement actions etc., on file for a period of five years.
Comments
IILBB The permittee submitted annual reports to the Department within twelve months
Annual Report from the effective date of the permit. Xe5
Submittal
The permittee submitted subsequent annual reports every twelve months from the
scheduled date of the first annual report submittal.
The Annual Reports included appropriate information to accurately describe the progress, status, and results
of the permittee's Stormwater Plan, including, but not limited the following:
1. A detailed description of the status of implementation of the Stormwater Plan
as a whole. This will include information on development and implementation
of each major component of the Stormwater Plan for the past year and
schedules and plans for the year following each report.
2. An adequate description and justification of any proposed changes to the
Stormwater Plan. This will include descriptions and supporting information for
the proposed changes and how these changes will impact the Stormwater
Plan (results, effectiveness, implementation schedule, etc.).
3. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater
Plan.
4. A summary of data accumulated as part of the Stormwater Plan throughout
the year along with an assessment of what the data indicates in light of the :s
Stormwater Plan.
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement 'Yes w
actions.
Comments
Benson submitted a 2019 Annual Report through BIMS SWMPA, which meets permit requirements.
IV.B
Annual Reporting I The Annual Reports document the following:
1. A summary of past year activities, including where applicable, specific
Yes
quantities achieved and summaries of enforcement actions.
2. A description of the effectiveness of each program component.
NCS000558 Benson MS4 Audit 20191218
Page 6 of 31

Program Implementation, Documentation & Assessment
3. Planned activities and changes for the next reporting period, for each
-Yes.
program component or activity.
4. Fiscal analysis.
Yes
Comments
Benson submitted a 2019 Annual Report through BIMS SWMPA, which meets permit requirements
NC50.00558_Benson MS4 Audit_20191218 Page 7 of 31

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
Tim Robbins, Utilities Director
(Name, Title, Role)
Erin Joseph, Planning Director
Fred Nelson, Interim Town Manager
Kim Pickett, Assistant Town Manager
Jerry Medlin, Mayer
Permit Citation
Program Requirement Status supports ng
Doc No..
II.D.2.a
IDDE Program
The permittee maintained a written IDDE Program. !o
If yes, the written program includes provisions for program assessment and nt
evaluation and integrating program. -"
Comments
The permittee does not have a written IDDE Program.
The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that
II.D.2.b
provides the legal authority to prohibit illicit connections and discharges to the MS4.
Legal Authorities
If yes, the ordinance applies throughout the corporate limits of the permittee.
[Permit Part I.D]
a,: r'.fral:Ie
Comments
The permittee does not have an IDDE ordinance or other regulatory mechanism.
11. Q.2.c
The permittee maintained a current map showing major outfalls and receiving
Storm Sewer
�3,:-•-{
System Map
streams.
Comments
Benson has a stormwater system map that includes several culverts, ditches, swales, and some underground stormwater flow, but
does not indicate all major outfalls.
-*Major outfalls r: e d;r:ha :.s.. - rt ti 3G"dio..n 'ter Pip" 01, drajnnap areas of? 50 acres. lr areas raved fvr ir:dustrlal activiry, :nnjar ou��:li;
ore > 12" or drainur}e area > d arras.
II.D.2.d
The permittee maintained a program for conducting dry weather flow field
Dry Weather Flow
observations in accordance with written procedures.
part=ai
Program
Comments
Some outfalls are examined by the water department to identify potential water line leaks into system. Streets department also
checks outfalls to keep them clear of debris. A defined IDDE Program with written procedures, standard documentation and
tracking, and routine outfall inspections needs to be developed and implemented. Outfall checking needs to be improved and
documented under IDDE.
NCSOOOS58_Benson MS4 Audit_20191218 Page 8 of 31

illicit Discharge Detection and Elimination (IDDE)
1.1. D.2.e
The permittee maintained written procedures for conducting investigations of
investigation
identified illicit discharges:
Procedures
Comments
The permittee does not have written procedures for conducting IDDE investigations.
iI.D.21
For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the
Track and
following:
Document
Investigations 1
1. The dates) the illicit discharge was observed
-
2, The results of the investigation
vo
3. Any follow-up of the investigation
No
•--
4. The date the investigation was closed
Nn
Comments
Benson has a hotline where people can inform the Town of any type of problem. Work orders are prepared/implemented
associated with calls and go to Public Woks to be addressed. Some of these likely fall under IDDE, but this needs to be
documented as such.
I.I.D.2.s Employee
The permittee implemented and documented a training program for appropriate
Training
municipal staff who, as part of their normal job responsibilities, may come into
i ft;• i
contact with or otherwise observe an illicit discharge or illicit connection.
Comments
Benson stated that they conduct some training of their staff, but did not provide detail of type of training and it is not documented.
II.D.2.h
The permittee informed public employees of hazards associated with illegal
Public Education
discharges and improper disposal of waste.
The permittee informed businesses of hazards associated with illegal. discharges and
improper disposal of waste.
LL
The. permittee informed. the general public of hazards associated with illegal
discharges and improper disposal of waste.
Partial
Comments
Benson conducts some training of their staff (Fats, Oil and Grease, and some types of waste disposal), but does not document it.
NCS0.00558_Benson M$4 Audit_20191218 Page 9 of 31

Illicit Discharge Detection and Elimination (IDDE)
11'Q'2.1
The permittee promoted,
p p ,publicized, and facilitated a reporting mechanism for the
Public Reporting
public to report illicit discharges.
arti�i
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
to report illicit discharges.
aria.
The permittee established and implemented response procedures for citizen
requests/reports.
Comments
Benson has a hotline where people can inform the Town of any type of problem. Work orders are prepared/implemented
associated with calls and go to Public Works to be addressed.
ii.D.2.i
The permittee implemented a mechanism to track the issuance of notices of violation
Enforcement
and enforcement actions administered by the permittee.
If yes, the mechanism includes the ability to identify chronic violators for
initiation of actions to reduce noncompliance. ja '
Comments
The permittee has not implemented enforcement and does not have protocols and authority in place to do so.
NCS000558_Benson MS4 Audit_20191218 Page 10 of 31

Post -Construction Site Runoff Controls
Staff Interviewed:
Tim Robbins, Utilities Director
(`Name, Title, Role)
Erin Joseph, Planning Director
Fred Nelson; Interim Town Manager
Kim Pickett, Assistant Town Manager
Jerry Medlin, Mayer
Implementation (check all that apply):
❑ The permittee implements the components of this minimum measure.
The permittee relies upon another entity to implement the components of this minimum measure: Johnston County
❑ The permittee implements the following deemed -compliant program(s); which meet NPDES MS4 post -construction
requirements for the areas where implemented and in compliance with the specific program requirements as provided in 15A
NCAC and noted below (Complete Session Law 2006-246 section below):
❑ Water Supply Watershed I (WS-1) —15A NCAC 2B .0212.
❑ Water Supply Watershed II (WS--11) —15A NCAC 213.0214
❑ Water Supply Watershed III (WS-111) —15A NCAC 26 .0215
❑ Water Supply Watershed IV (WS-IV) —15A NCAC 2B .0216
❑ Freshwater High quality Waters (HQW) —15A NCAC 2H .1006
❑ Freshwater Outstanding Resource Waters (ORW) —15A NCAC 2H .1007
❑ Neuse River Basin Nutrient Sensitive (NSW) Management Strategy —15A NCAC 2B .0235
❑ Tar -Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy—15A NCAC 213.0258
❑ Randleman Lake Water Supply Watershed Nutrient Management Strategy —15A NCAC 213.0251
❑ Universal Stormwater Management Program —15A NCAC 2H .1020
Ordinance(s) (check all that apply):
The permittee utilizes the following ordinances and/or regulatory authority to fulfill post construction minimum measure program
requirements throughout the MS4 permitted area (check all that apply):
X DEQ model ordinance
0 MS4 designed post -construction practices that meet or exceed 15A NCAC 02H .1000.
❑ DEQ approved comprehensive watershed plan
❑ DEQ approved ordinance for a deemed -compliant Program (see list above).
Session Law 2006-
program Requirement
1
Status
1
suppotc`ng
1
246
Doc No.
NCS0.00558—Benson MS4 Au.d.it-20191218 Page 11 of 31

Post -Construction Site Runoff Controls
Deemed -Compliant
The permittee implements deemed -compliant Program requirements in
Program(s)
accordance with the applicable 15A NCAC rules.
i' :W
---
The permittee implements deemed -compliant Program requirements throughout
the entire MS4 area (If not, also complete the Permit Citation section below.)
P Aft
The permittee applies deemed -compliant Program requirements to all federal,
state and local government projects within the permitted MS4 area who do not
have their own NPDES stormwater permit.
The permittee included deemed -compliant Program reporting in their MS4 Annual
Reports.
The permittee included deemed -compliant Program implementation in their
Stormwater Management Plan. - -
i
Comments
Benson has an agreement with Johnston County (JOCO) delegating authority for JOCO to ensure that new development and
redevelopment within Benson are subject to JOCO stormwater ordinance. Under this agreement, Benson gives authority to JOCO
to administer the construction and post construction measures of the MS4 Program. The permittee could not demonstrate that
JOCO is meeting the permit requirements. 1OCO representative did not attend the audit making it difficult to accurately assess this
measure.
Permit Citation
Program Requirement
Status
Supporting
Doc No.
II.F.2.a
The permittee maintained an ordinance or other regulatory mechanism designed
Legal Authority
to meet the objectives of the Post -Construction Site Runoff Controls Stormwater
--
Management Program.
If yes, the ordinance applies throughout the corporate limits of the permittee
(Verify permit coverage area listed in Part I.D of permit and modify
_--
accordingly).
The permittee has the authority to review designs and proposals for new
development and redevelopment to determine whether adequate stormwater
- -
control measures will be installed, implemented, and maintained.
The permittee has the authority to request information such as stormwater plans,
inspection reports, monitoring results, and other information deemed necessary to
evaluate compliance with the Post -Construction Stormwater Management
Program.
The permittee has the authority to enter private property for the purpose of
inspecting at reasonable times any facilities, equipment, practices, or operations
- -
related to stormwater discharges.
Comments
NCS000558_Benson MS4 Audit_20191218 Page 12 of 31

Post -Construction Site Runoff Controls
II.F.2.b
Stormwater Control
The permittee utilizes strategies which include SCMs appropriate for the MS4.a
--
Measures (SCMs)
SCMs comply with 15A NCAC 02H .1000.
-
--
Comments
JOCO implements post construction (and construction) review under Benson/JOCO agreement. The permittee does not have
necessary documentation from Johnston County to demonstrate post construction stormwater control program implementation.
II.F.2.c
The permittee conducted site plan. reviews of all new development and
Plan Reviews
redeveloped sites that disturb greater than or equal to one acre (including sites
that disturb less than one acre that are part of a larger common plan of
No
development or sale).
If yes, the site plan reviews addressed how the project applicant meets the
performance standards.
No
If yes, the site plan reviews addressed how the project will ensure long-term
maintenance.
Comments
JOCO implements post construction (and construction) review under Benson/JOCO agreement. The permittee does not have
necessary documentation from Johnston County to demonstrate post construction stormwater control. program implementation.
II.F.2.d
The permittee maintained an inventory of projects with post -construction
Inventory of Projects
structural stormwater control measures installed and implemented at new.�5
development and redeveloped sites.
The inventory included both public and private sector sites located within the
permittee's corporate limits that are covered by its post -construction ordinance
Yes
-
requirements.
Comments
Benson maintains inventory of all development projects and provided a list of developments with stormwater control measures
(2017-2019).
II.F.2.c
The permittee provided mechanisms such as recorded deed restrictions and.
Deed Restrictions
protective covenants that ensure development activities will maintain the project
and Protective
consistent with approved plans.
Covenants
Comments
Benson Unified Development Code requires that Homeowners Associations have a maintenance agreement. The Final Plat has the
0&M Plan for SCMs.
ILF.2.f
The permittee implemented or required an operation and maintenance plan for
Mechanism to
the long-term operation oftheSCMs required by the program.
Require Long-term
Operation and
The operation and maintenance plan required the owner of each SCIVI to.perform
Maintenance
and maintain a record of annual inspectionsof each SCM.
No
NC50.00558_Benson MS4 Audit_20191218 Page 13 of 31

Post -Construction Site Runoff Controls
Annual inspection of permitted structural SCMs are required to be performed by a
qualified professional.
Comments
JOCO responsible for post construction (and construction) review under Benson/JOCO agreement. Benson should have gotten
necessary information from Johnston County who implements majority of post construction stormwater control measure program
II.F.2.e
The permittee conducted and documented inspections of each project site covered
Inspections of
under performance standards, at least one time during the permit term).
No
Structural
Stormwater Control
Before issuing a certificate of occupancy or temporary certificate of occupancy, the
Measures
permittee conducted a post -construction inspection to verify that the permittee's
performance standards have been met or a bond is in place to guarantee
completion.
The permittee developed and implemented a written inspection program for SCMs
installed pursuant to the post -construction program.
The permittee documented and maintained records of inspections.
The permittee documented and maintained records of enforcement actions.
--
Comments
JOCO conducts a technical inspection and then Benson conducts administrative inspection. If JOCO identifies problem(s) during
inspection, Benson holds Certificate of Occupancy until problem is corrected. JOCO responsible for post construction (and
construction) review under Benson/JOCO agreement. Benson should have gotten necessary information from Johnston County
who implements majority of post construction stormwater control measure program
Il.F.2.h
Educational
The permittee made available through paper or electronic means, ordinances,
Materials and
post -construction requirements, design standards checklists, and other materials
Training for
appropriate for developers.
Mµ~
Developers
Comments
JOCO responsible for post construction (and construction) review under Benson/JOCO agreement. Benson should have gotten
necessary information from Johnston County who implements majority of post construction stormwater control measure program
11.F.2.11 Enforcement
The permittee tracked the issuance of notices of violation and enforcement
actions.
No
If yes, the tracking mechanism included the ability to identify chronic violators
N*t
for initiation of actions to reduce noncompliance.
--
Comments
Neither JOCO or Benson issues violations or enforcement actions.
NCS000558_Benson MS4 Audit_20191218 Page 14 of 31

Post -Construction Site Runoff Controls
II.F.3.b
The permittee fully complies with post construction program requirements on its
N ,:
New Development
own, publicly funded construction projects.va���,.:
Comments
DECt-DEMLR reviews Benson publicly funded construction projects.
II.F.3.c
Does the MS4 have areas draining to Nutrient Sensitive Waters (NSW) pursuant to
Nutrient Sensitive
15A NCAC 02H .0150?
Waters
If yes, does the permittee use. SCMs that reduce nutrient loading. in order to
meet local program requirements.
No
If yes, does the permittee also still incorporate the stormwater controls
required for the project's density level.
No
If yes, does the permittee also require documentation where it is not feasible to
use SCMs that reduce nutrient loading.
Na
---
Comments
ILF.3.d
The permittee ensured that the design volumes of SCMs take into account the
Design Volume
runoff at build out -from all surfaces draining to the system.
vn
-
Where "streets" convey stormwater, the permittee designed SCMs to be sized to
treat and control stormwater runoff from all surfaces draining to the SCM including
:Yo
---
streets, driveways, and other impervious surfaces.
Comments
JOCO responsible for post construction (and construction) review under Benson/JOCO agreement. Benson should have gotten
necessary information from Johnston County who implements majority of post construction stormwater control measure program
NCS000558_Benson MS4 Audit_20191218 Page 15 of 31

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
Tim Robbins, Utilities Director
(Name, Title, Role)
Erin Joseph, Planning Director
Fred Nelson, Interim Town Manager
Kim Pickett, Assistant Town Manager
Jerry Medlin, Mayer
Permit Citation
Program Requirement Status supporting
Doc No.
Il.G.2.a.
The permittee maintained a current inventory of facilities and operations owned
Facility Inventory
and operated by the permittee with the potential for generating polluted YE
stormwater runoff.
Comments
Benson operates one public works facility, a wastewater treatment plan, and a dog park.
II.G.2.b
The permittee maintained and implemented an O&M program for municipally
Operation and
owned and operated facilities with the potential for generating polluted
Maintenance (O&M)
stormwater runoff.
for Facilities
If yes, the O&M program specifies the frequency of inspections.
If yes, the O&M program specifies the frequency of routine maintenance
requirements.
If yes, the permittee evaluated the O&M program annually and updated it as
necessary.
0
Comments
Benson does not regularly inspect facilities.
II.G.2.c
Spill Response The permittee had written spill response procedures for municipal operations. _..
Procedures
Comments
Benson has Safety Plan that includes a Spill Response section. Benson provided the Sanitary Sewer Overflow Response Plan.
Benson needs plan to include spills, etc. in addition to sanitary sewer overflows/spills.
II.G.2.d Streets,
The permittee evaluated existing and new BMPs that reduce polluted stormwater
Roads, and Public
runoff from municipally -owned streets, roads, and public parking lots within its
corporate limits annually.
NCS000558_Benson MS4 Audit_20191218 Page 16 of 31

Pollution Prevention and Good Housekeeping for Municipal Operations
Parking Lots
If yes, the permittee evaluated the effectiveness of existing and new BMPs
Maintenance
based on cost and the estimated quantity of pollutants removed.
Comments
Benson maintains its parking lots, but does not document evaluation of effectiveness of existing and new BMPs.
II.G,2,e
The permittee maintained and implemented an O&M program for the stormwater
O&M for Catch
sewer system including catch basins and conveyance systems that it owns and
Basins and
Conveyance Systems
maintains.
Comments
Benson identifies `hot spots' within the collection system that need to be cleaned or repaired. Benson uses a Jet Vac and street
sweeper to periodically clean sections of stormwater collection system. Benson needs to document this work.
ll.G.2.f
The permittee maintained a current inventory of municipally -owned or operated
Structural
structural stormwater controls installed for compliance with the permittee's post-
N`'t
Stormwater Controls
construction ordinance.
Comments
II.G.2.e
The permittee maintained and implemented an O&M program for municipally -
O&M for Structural
owned or maintained structural stormwater controls installed for compliance with
,-n-Atabie
Stormwater Controls
the permittee's post -construction ordinance. If yes, then:
The. O&M program specified the frequency of inspections and routine
Not
maintenance requirements.
r-nplicablc
The permittee documented inspections of all municipally -owned or maintained
of
structural stormwater controls.
iica
The permittee inspected all municipally -owned or maintained structural
. t
stormwater controls in accordance with the schedule developed by permittee.
Applicable.
The permittee maintained all municipally -owned or maintained structural
a „�
stormwater controls in accordance with the schedule developed by permittee.
.'ppiica...-
The permittee documented maintenance of all municipally -owned or
Not
maintained structural stormwater controls.
applicable
Comments
Benson doe's not have any municipally owned or maintained SCMs.
II.G.2.1h
The permittee ensured municipal employees are properly trained in pesticide,
herbicide and fertilizer application management..
Yes
---
NCS000558_Benson MS4 Audit_20191218 Page 17 of 31

Pollution Prevention and Good Housekeeping for Municipal Operations
Pesticide, Herbicide
The permittee ensured contractors are properly trained in pesticide, herbicide and
and Fertilizer
fertilizer application management.
ray
Application
Management
The permittee ensured all permits, certifications, and other measures for
applicators are followed.
Comments
Benson provided some certifications during audit and one after audit.
II.G.2.1
The permittee implemented an employee trainin
pg program for employees involved
Staff Training
in implementing pollution prevention and good housekeeping practices.
Comments
Benson stated that they conduct some training of their staff, but they did not provide detail of type of training and it is not
documented.
II.G.2.i The permittee described and implemented measures that prevent or minimize
Vehicle and contamination of stormwater runoff from all areas used for vehicle and equipment =i _--
Equipment Cleaning cleaning.
Comments
Most vehicles are washed offsite. Large chunks of dirt and associated material after removed from earth moving vehicles is taken
to landfill. Benson did not address generation and/or disposal of any washwater. Benson does not use awash bay.
NCS000558_Benson MS4 Audit_20191218 Page 18 of 31

Site Visit Evaluation: Municipal Facility No. 1
Facility Name:
Date and Time of Site Visit:
Benson Public Works Department (equipment storage, etc)
12/18/2019
5:30 —10.90 am
Facility Address:
Facility Type (Vehicle. Maintenance, Landscaping, etc.):
501 North Market. Street
Equipment Storage Yard
Benson, NC 27504
Name of MS4 inspectors) evaluated:
Most Recent MS4 Inspection (List date and name of inspector):
Tim Robbins
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name and Title.
Tim Robbins,. Utilities Director
Erin Joseph, Planning Director
'Fred Nelson, Interim Town Manager
Kim Pickett, Assistant Town Manager
Jerry Medlin, Mayer
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
No
What type of stormwater training do facility employees receive? How often?
Benson stated that they conduct some training of their staff, but they did not provide detail of type of training and it is not
documented.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Benson stated that they conduct some training of their staff, but they did not provide detail of type of training and it is not
documented.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Inspector has limited knowledge, but he wants to learn more.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good Housekeeping?
Inspector has limited knowledge; but he wants to learn more.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
No.
NCS.000558_13enson MS4 Aud.it_20191218 Page 19 of 31

Site Visit Evaluation: Municipal Facility No. 1
Does the MS4 inspector's process include taking photos?
No.
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
No, but the facility does not have a SWPPP.
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
Inspector has not inspected the facility, but he plans to begin inspecting it.
Did the MS4 inspector miss any obvious areas of concern? If so, explain;
There were a few locations where the stream beneath the facility is exposed. Inspector was told there should be protective
measures to prevent pollutants, etc. from entering stream in these locations. Generally, inspector looked toward state staff on
guidance on how to inspect facility.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Inspector has not inspected the facility, but he plans to begin inspecting it and presenting findings to facility contact.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
Benson agreed to stabilize exposed stream banks that are currently eroding (see Notes section).
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
No timeline was established for stream bank stabilization.
Notes/Comments/Recommendations
Driving Branch is culverted/piped under the facility. Hurricane Matthew flooding caused a few sections of culvert to become
dislodged, exposing the stream. Benson is working with FEMA to obtain money to correct this problem, but it is taking longer than
expected. State suggested at least stabilizing exposed stream banks, while waiting for additional work to be done. Cement blocks
partially cover other areas where the stream is partially exposed. State also recommended stabilizing these areas.
NCS000558_Benson MS4 Audit_20191218 Page 20 of 31

Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number:
Date and. Time of Site Visit:
12/18/2019
9:30-10:00am
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
Benson Public Utilities Yard
Not an official outfall, but area where Driving Branch flows.
through facility..
Receiving Water:
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Driving Branch
Sheen, Odor, Floatables/Debris, etc.):
Stream had flow, no obvious indicators of stormwater pollution
.
wereobserved.
Most Recent Outfall Inspection/Screening (Date):
Days Since Last Rainfall:
Inches:
Name of MS4 Inspector(s) evaluated:
Tim Robbins
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Inspector has not received outfall inspection training, but he is aware of some things other programs look for around outfalls. The
water department checks outfalls for water flow during dry periods because this could be an indication of water Line leaks. .The
roads crew clears debris around areas where pipes/outfalls pass beneath streets. All this was shared by word of mouth and is not
documented.
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Inspector had limited knowledge.
Inspection Procedures
Does the inspector's process includethe use of a checklist or other standardized form?
No
Does the inspector's process include taking photos?
No
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they? As
mentioned earlier, Benson identifies `hot spots' within the.collection system that need to be cleaned or repaired. Benson appears
to take a reactive approach responding to problems as they are reported by other Benson staff. Benson should be proactive.
NCS000558_Benson MS4 Audit 20191218 Page 21 of 31

Site Visit Evaluation: MS4 Outfall No. 1
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)?
No
Will a follow-up outfall inspection be conducted? If so, for what reason?
Inspection will ensure that exposed streambank areas are stabilized while Benson waits for approval/funding to repair broken
culvert sections or identify other options (i.e., keep portion of stream uncovered, but restore and protect it).
Notes/Comments/Recommendations
Benson will continue to ensure that exposed streambank areas are stabilized while Benson waits for approval/funding to repair
broken culvert sections or identify other options (i.e., keep portion of stream uncovered, but restore and protect it).
Inspector training is strongly recommended.
NCS000558_Benson MS4 Audit_20191218 Page 22 of 31

Site Visit Evaluation: MS4 Outfall No. 2
Outfall ID Number:
Date and Time of Site Visit. -
N/A
12/18/2019
11:00-11:30am
Outfall Location: Martin Street
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
Culvert passes beneath Martin street empties into ditch that flows
into Driving Branch.
Receiving Water: Culvert passes beneath Martin Street and
is Flow Present? if So, Describe (Color, Approximate Flow Rate,
empties into a ditch that flows into Driving Branch.
Sheen, Odor, Floatables/Debris, etc.):
Flow present.. No obvious indicators of stormwater pollution were
observed.
Most Recent Outfall Inspection/Screening (Date):
Days Since Last Rainfall:
Inches:
-24 hours
Name of MS4 Inspector(s):
Tim Robbins
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Inspector has not received outfall inspection training, but he is aware of some things other programs look for around outfalls. The
water department checks outfalls for water flow during dry periods because this could bean indication of waterline leaks. The
roads crew clears debris around areas where pipes/outfa Its pass beneath streets. All this was shared by word of mouth and is not
documented.
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Inspector had limited knowledge.
Inspection Procedures
Does the inspector's process include the use of a.checkiist or other standardized form?
No.
Does the inspector's process include taking photos?
No.
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
Inspector sought state input on inspection guidance. Inspector noted that the water department checks outfalls for potential leaks
and the street department also checks outfalls for debris, blockage; etc. Benson stated that these other departments could be
NC5000558_Benson MS4 Audit_20191218 Page 23 of 31

Site Visit Evaluation: MS4 Outfall No. 2
trained, so that they could potentially assist with outfall inspections. Benson needs to document activities that other departments
are doing that can be credited to meeting some MS4 permit requirements.
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)?
No.
Will a follow-up outfall inspection be conducted? If so, for what reason?
No.
Notes/Comments/Recommendations
Water department checks outfalls for potential leaks and the street department also checks outfalls for debris, blockage, etc.
Benson stated that these other departments could be trained, so that they could potentially assist with outfall inspections.
NCS000558_Benson MS4 Audit_20191218 Page 24 of 31

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
Site Name:
Date and Time of Site Visit::
Legacy Trace (apartment complex)
12/18/2019
10:00 -10:30 am
Site Address:
SCM Type:
1150 Berkley Belle Drive
Wet Detention Basin
Benson, NC 27504
Most Recent MS4 Inspection (include Date and Entity):
Name of MS4 inspector(s) evaluated:
Most Recent MS4 Enforcement Activity (Include Date):
Tim Robbins
Name(s) and Title(s) of Site Representative(s) Present During the Site visit:
Name
Title
Tim Robbins, Utilities Director
Erin Joseph, Planning Director
Fred Nelson, Interim Town Manager
Kim. Pickett, Assistant Town Manager
Jerry Medlin, Mayer
Observations
Site Documentation
Does the site have an operation and maintenance plan?
No. See Comments section.
Does the site have records of annual inspections? Are they performed by a qualified individual?
Benson had. no records nor indication if inspections are done by qualified individual. Benson should have gotten necessary
information from Johnston County who implements majority of post construction stormwater control measure program. See
Comments section.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Benson had no record of post construction training. Benson should have gotten necessary information from Johnston County who
implements majority of post construction stormwater control measure program. See Comments section.
Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls?
MS4 inspector had limited knowledge about MS4 requirements for post -construction site runoff controls. See Comments section.
NCS000558_Benson MS4 Audit_20191218 Page 25 of 32

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, O&M
requirements, etc.)?
MS4 inspector had limited knowledge about MS4 requirements for post -construction site runoff controls. See Comments section.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form? What format?
Benson did not demonstrate the use of checklist or other standardized form. Benson should have gotten necessary information
from Johnston County who implements majority of post construction stormwater control measure program. See Comments
section.
Does the MS4 inspector's process include taking photos?
Benson did not take photos during site visit. Benson should have gotten necessary information from Johnston County who
implements majority of post construction stormwater control measure program. See Comments section.
Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections?
Benson did not demonstrate that process includes reviewing the site's operation and maintenance plan and records of annual
inspections. Benson should have gotten necessary information from Johnston County who implements majority of post
construction stormwater control measure program. See Comments section.
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge?
No. Benson did not know what to examine. See Comments section.
Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain: No, but SCM was fairly well
maintained. See Comments section.
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing?
No. See Comments section.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
NA
If compliance issues were identified, what timeline for correction/follow-up was provided?
NA
Notes/Comments/Recommendations
NCS000558_Benson M54 Audit_20191218 Page 26 of 31

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
Benson has an agreement with Johnston County (JOCO) delegating authority for JOCO to ensure that new development and
redevelopment within Benson are subject to JOCO stormwater ordinance. Under this agreement, Benson gives. authority to JOCO
to administer the construction and post construction measures of the M54P.rogram. The permittee did not have a representative
from JOCO present, and was unable to confirm the implementation of a post -construction program for new development and
redevelopment within the jurisdictional area of Benson. As stated earlier in this section, Benson should have gotten necessary
information from Johnston County who implements majority of post construction stormwate.r control measure program.
NC5000558_Benson MS4 Audt_20191218 Page 27 of 31

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2
Site Name: Hampton Inn (hotel)
Date and Time of Site Visit:
12/18/2019
10:30 — 11:00 am
Site Address:
SCM Type:
100 Water Place Landing
Wet Detention Basin
Benson, NC 27504
Most Recent MS4 Inspection (Include Date and Entity):
Name of MS4 Inspector(s) evaluated:
Most Recent MS4 Enforcement Activity (Include Date):
Tim Robbins
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit.
Name
Title
Tim Robbins, Utilities Director
Erin Joseph, Planning Director
Fred Nelson, Interim Town Manager
Kim Pickett, Assistant Town Manager
Jerry Medlin, Mayer
observations
Site Documentation
Does the site have an operation and maintenance plan? No. See Comments section.
Does the site have records of annual inspections? Are they performed by a qualified individual? Benson had no records nor
indication if inspections are done by qualified individual. Benson should have gotten necessary information from Johnston County
who implements majority of post construction stormwater control measure program. See Comments section.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often? Benson had no record of post construction training.
Benson should have gotten necessary information from Johnston County who implements majority of post construction
stormwater control measure program. See Comments section.
Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls?
MS4 inspector had limited knowledge about MS4 requirements for post -construction site runoff controls. See Comments section.
NCS000558_Benson M54 Audit_20191218 Page 28 of 31

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2
Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, O&M
requirements, etc.)? IVIS.4 inspector had limited knowledge about MS4 requirements for post -construction site runoff controls. See
Comments section.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form? What format?
Benson did not demonstrate the use of checklist or other standardized form. Benson should have gotten necessary information
from Johnston County who implements majority of post construction stormwater control measure program. See Comments
section..
Does the MS4 inspector's process include taking photos?
Benson did not take photos duringsite visit. Benson should have gotten necessary information from. Johnston. County who
implements majority of post construction stormwater control measure program. See Comments section.
Does the MS4 inspector's process include reviewing the site's operation. and: maintenance plan and records of annual inspections?
Benson did not demonstrate that process includes reviewing the site's operation:and maintenance plan and records of annual
inspections, Benson should have gotten necessary information from Johnston County who implements majority of post
construction stormwater control measure program. See Comments section..
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge?
No. Benson did not know what to examine. See Comments section.
Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain.
No; but SCM was fairly well maintained, although there is a design issue, please see Comments. section.
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing?
No. See Comments section.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc:) did the inspection result in? NA
If compliance issues were identified, what timeline for correction/follow-up was provided? NA
Notes/Comments/Recommendation s
NCS000558_Benson MS4 Audit_20191218 Page 29 of 31

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2 1
Benson has an agreement with Johnston County (JOCO) delegating authority for JOCO to ensure that new development and
redevelopment within Benson are subject to JOCO Stormwater ordinance. Under this agreement, Benson gives authority to JOCO
to administer the construction and post construction measures of the MS4 Program. JOCO representative did not attend the audit
making it difficult to accurately assess this measure (including post construction inspection of Stormwater control measures). The
wet detention basin was designed so that all the inflows enter the pond on the same side causing the possibility of short circuiting.
There is also a dog park adjacent to hotel, but it does not drain into stormwater control measure.
NCS000558_Benson MS4 Audit_20191218 Page 30 of 31

APPENDIX A: SUPPORTING DOCUMENTS
THE SUPPORTING DOCUMENTS LISTED ON PAGE 3 CAN BE FOUND
►N THE NCDEQ DWR LASERFICHE PORTAL
NC5000558—Benson MS4 Au.d.it-20191218 Page 31 of 31