NCS000558_Self Audit_20210714

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM SELF AUDIT REPORT
Part II
Section B: Public Education and Outreach
Section C: Public Involvement and Participation
Section E: Construction Site Runoff Controls
NPDES PERMIT NO. NCS000558
Town of Benson, NC
303 East Church Street
Benson, NC 27504
Audit Date: May 2021
Report Date: June 2, 2021
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

MS4 Permit Self Audit Report
Town of Benson, NC: NPDES Permit No. NCS000558
TABLE OF CONTENTS
AuditDetails..................................................................................................................................................1
PermitteeInformation..................................................................................................................................2
SupportingDocuments..................................................................................................................................3
Public Education and Outreach.....................................................................................................................4
Public Involvement and Participation...........................................................................................................7
ConstructionSite Runoff Controls.................................................................................................................9
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.
Audit Date: May 2021 ii

MS4 Permit Self Audit Report
Town of Benson, NC: NPDES Permit No. NCS000558
Audit Details
Audit ID Number:
Audit Date(s):
May 2021
Minimum Control Measures Evaluated:
❑ Program Implementation, Documentation & Assessment
❑x Public Education & Outreach
❑x Public Involvement & Participation
❑ Illicit Discharge Detection & Elimination
❑ Construction Site Runoff Controls — No delegated Sediment and Erosion Control Program
❑x Construction Site Runoff Controls — Delegated Sediment and Erosion Control Program —Johnston County
❑ Post -Construction Site Runoff Controls
❑ Pollution Prevention and Good Housekeeping for Municipal Operations
❑ Total Maximum Daily Loads (TMDLs)
Field Site Visits:
❑ Municipal Facilities. Number visited: Choose an item.
❑ MS4 Outfalls. Number visited: Choose an item.
❑ Construction Sites. Number visited: Choose an item.
❑ Post -Construction Stormwater Runoff Controls. Number visited: Choose an item.
❑ Other: Number visited: Choose an item.
❑ Other: Number visited: Choose an item.
Inspector(s) Conducting Audit
Name; Title
C►mnization
Beth McLaughlin, Consultant
McLaughlin Consulting
Audit Report Author:
Date:
Signature
Audit Report Author:
Date
Signature
Audit Date(s): May 2021 Page 1 of 11

MS4 Permit Self Audit Report
Town of Benson, NC: NPDES Permit No. NCS000558
Permittee Information
MS4 Permittee Name:
Town of Benson
Permit Effective Date:
2/1/2018
Permit Expiration Date:
1/31/23
City, State, ZIP:
303 East Church St, Benson NC 27504
Date of Last MS4 Inspection/Audit:
12/28/2019
Co-permittee(s), if applicable:
N/A
Permit Owner of Record:
Fred Nelson, Town Manager
Kimberly Pickett, Assistant Town Manager
Tim Robbins, Public Utilities Director
Primary MS4 Representatives Participating in Audit
Name, Title
Organization
Tim Robbins, Public Utilities Director
Town of Benson
Matt Smith, Parks and Recreation
Town of Benson
Erin Joseph, Planning Director
Town of Benson
Jessica Batten, Stormwater Manager
Johnston County
MS4 Receiving Waters
Waterbodv
Classification
Impairments
Audit Date(s): May 2021 Page 2 of 11

MS4 Permit Self Audit Report
Town of Benson, NC: NPDES Permit No. NCS000558
Supporting Documents
Item
Number
Document Title
When Provided
(Prior to/During/After)
1
Agreement between Town of Benson and Johnston County
During
2
Town of Benson Facebook page
During
3
Town of Benson website
Prior
4
CWEP payments FY14-FY20
After
5
Town of Benson 2018 MS4 Permit NCS000558
Prior
5
Town of Benson January 2013 MS4 permit application and SWMP
Prior
7
CWEP annual reports 2017 - 2021
After
8
Town of Benson Unified Development Code
After
9
Johnston County Erosion control ordinance
Prior
10
Johnston County Stormwater BMP Manual
Prior
11
Johnston County Erosion Control Plan approval template
Prior
Audit Date(s): May 2021 Page 3 of 11

MS4 Permit Self Audit Report
Town of Benson, NC: NPDES Permit No. NCS000558
Public Education and Outreach
Staff Interviewed:
Tim Robbins, Public Utilities Director
(Name, Title, Role)
Matt Smith, Parks and Recreation Director
Erin Joseph, Planning Director
Permit Citation
Program Requirement Status Supporting
Doc No.
11.B.2.a
The permittee defined goals and objectives of the Local Public Education and
Goals and
Yes 6
Outreach Program based on community wide issues.
Objectives
Comments (Generally describe process for establishing goals/objectives)
The Town outlined goals and objectives for public education in its application and Stormwater Management Plan dated January 13,
2013, The SWMP identified targeted pollutants (nutrients, sediment, trash, and household and landscape chemicals) and audiences
(business owners and local citizens). The SWMP also listed measurable goals.
II.B.2.16
The permittee maintained a description of the target pollutants and/or stressors and
Target Pollutants
likely sources.
Yes
6
Comments (List target pollutants, note any that are missing or not appropriate)
As identified in the 2013 application and SWMP, sediment, nutrients, trash and household and yard chemicals are targeted
pollutants.
II.B.2.c
The permittee identified, assessed annually and updated the description of the target
Not
Target Audiences
audiences likely to have significant storm water impacts and why they were selected.
Applicable
6
Comments (Describe any changes made, if applicable)
II.13.2.c of the Town's permit states the following:
c. Describe target audiences
The permittee shall maintain a description of the target
audiences likely to have significant storm water impacts and
why they were selected.
The Town did maintain a list of the target audiences, as outlined in their January 2013 application.
Audit Date(s): May 2021 Page 4 of 11

MS4 Permit Self Audit Report
Town of Benson, NC: NPDES Permit No. NCS000558
Public Education and Outreach
11.B.2.d Residential
The permittee described issues, such as pollutants, the likely sources of those
and Industrial/
pollutants, potential impacts, and the physical attributes of stormwater runoff in
Yes
1 7
Commercial Issues
their education/outreach program.
Comments (Generally describe the residential/industrial/commercial issues addressed)
The Town of Benson has relied upon the Clean Water Education partnership since 2014 to provide general public education on
water quality.
II.B.2.e
The permittee promoted and maintained an internet web site designed to convey the
Informational
program s message.
Yes
7, 3
Web Site
Comments (list web page address and general contents, or attach screen shot of landing page)
The Town partners with CWEP, who maintains a website with water quality information in it. The Town also has a stormwater
section of their website which directs people to the CWEP website.
II.B.2.f
The permittee distributed stormwater educational material to appropriate target
Public Education
Yes
2, 3, 7
Materials
groups.
Comments (List distributed materials and quantity, message, distribution mechanism, target audience for each if not included in
program documentation/annual reporting)
Through CWEP, water quality information is distributed to all ages. Also, the Town has organized and participated in a town litter
cleanup and beautification in April of every year since 2013 (except for 2020 during the pandemic). All age groups have been
involved.
Audit Date(s): May 2021 Page 5 of 11

MS4 Permit Self Audit Report
Town of Benson, NC: NPDES Permit No. NCS000558
Public Education and Outreach
II.13.2.g
The permittee promoted and maintained a stormwater hotline/helpline for the
Hotline/Help Line
purpose of public education and outreach.
Partial
F 3
Comments (Note hotline contact information and method(s) for advertising it)
The Town has a web page directing people to the phone numbers for stormwater complaints.
https://www.townofbenson.com/2282/Stormwater
II.13.2.1h
The permittee's outreach program, including those elements implemented locally or
Public Education
through a cooperative agreement, included a combination of approaches designed to
Yes
2,7
and Outreach
reach the target audiences.
Program
For each media, event or activity, including those elements implemented locally or
through a cooperative agreement the permittee estimated and recorded the extent
Partial
2,7
of exposure.
Comments (Generally describe approaches, extent of exposure. Note any cooperating entities, agreements and scope of services,
or reference comments in Section II.A.6. above.)
The Town has documented all of the clean up events through Facebook posts (further increasing the audience) and has
documented educational activities provided through CWEP. However, an estimate of the extent of exposure was not collected. In
additional, the Town conducts monthly safety meetings with all Town staff. These meetings have addressed materials management
and spill cleanup; however, the agendas for these meetings was not documented, nor was attendance.
Additional
Comments:
Audit Date(s): May 2021 Page 6 of 11

MS4 Permit Self Audit Report
Town of Benson, NC: NPDES Permit No. NCS000558
Public Involvement and Participation
Staff Interviewed:
Tim Robbins, Public Utilities Director
(Name, Title, Role)
Matt Smith, Parks and Recreation Director
Angie Thornton, Town Clerk
Permit Citation
Program Requirement Status Supporting
Doc No.
II.C.2.a Volunteer
Community
The permittee included and promoted volunteer opportunities designed to promote
Involvement
Yes 2
ongoing citizen participation.
Program
Comments (Note opportunities promoted and date(s) of volunteer events)
The Town coordinated and participated in litter sweeps and Town beautification events each April from 2013 — 2021 (except for
2020 during the pandemic).
II.C.2.b
Mechanism for
The permittee provided and promoted a mechanism for public involvement that
Public
provides for input on stormwater issues and the stormwater program.
No
Involvement
Comments (Note mechanism(s) for input and how promoted)
II.C.2.c
The permittee promoted and maintained a hotline/helpline for the purpose of public
Hotline/Help Line
involvement and participation.
Yes
3,2
Comments (Note hotline contact information and how it is promoted)
The Town maintains a Facebook page and accepts comments and complaints through that page. The Town also has a phone
number listed on their stormwater website for people to call with concerns.
Audit Date(s): May 2021 Page 7 of 11

MS4 Permit Self Audit Report
Town of Benson, NC: NPDES Permit No. NCS000558
Audit Date(s): May 2021 Page 8 of 11

MS4 Permit Self Audit Report
Town of Benson, NC: NPDES Permit No. NCS000558
Construction Site Runoff Controls
Staff Interviewed:
Erin Joseph, Planning Director
(Name, Title, Role)
Jessica Batten, Johnston County Stormwater Manager
*The Town of Benson relies upon Johnston County —who has a delegated erosion and sediment control
program — for construction site runoff control activities.
Program Delegation Status:
❑X The permittee has a delegated Sediment and Erosion Control Program and implements the North Carolina
Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure (complete the permit
citation and SPCA citation sections).
❑ The permittee does not have a delegated Sediment and Erosion Control Program and relies on DEMLR to comply
with the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure
(complete only the permit citation section).
Permit Citation Program Requirement Status Supporting
Doc No.
II.E.3 Construction
Site Runoff Controls The permittee provides and promotes a means for the public to notify the
(NPDES Permit No. appropriate authorities of observed erosion and sedimentation problems (e.g., Partial ---
NCS000435] promoting the existence of the DEQ DEMLR "Stop Mud" hotline).
Comments (Describe how provided and promoted)
The Town routes complaints to Town Hall through their website. https://www.townofbenson.com/2282/Stormwater The
complaint note on the website is specific to stormwater and not construction site runoff.
SPCA Citation
Delegated Program Requirement
Status
supporting
Doc No.
113A-60 Local
erosion and
The permittee has adopted an ordinance or other regulatory mechanism to enforce
Yes
g
sedimentation
the erosion and sedimentation control program.
control programs (a)
If yes, the ordinance meets or exceeds the minimum requirements of the
SPCA.
Yes
9
If yes, the ordinance applies throughout the corporate limits of the permittee.
[Permit Part LD]
Yes
1
Comments (Provide regulatory mechanism reference or Supporting Documentation number)
The Town has a MCA with the County related to erosion and sediment control. The County has a delegated local erosion control
program and is in good standing. The County handles plans review, inspection and enforcement within the Town's limits and ETJ.
§ 113A-60 Local
erosion and
The permittee collects a fee paid by each person who submits an erosion and
sedimentation
sedimentation control plan.
Yes
1
control programs (d)
Audit Date(s): May 2021 Page 9 of 11

MS4 Permit Self Audit Report
Town of Benson, NC: NPDES Permit No. NCS000558
Construction Site Runoff Controls
Comments (indicate the fee amount, if applicable)
The County collects the fees as they are reviewing, inspecting and enforcing.
113A-60 Local
Has any person initiated a land -disturbing activity (within the permittee's
erosion and
jurisdiction) for which an erosion and sedimentation control plan is required in the
No
---
sedimentation
absence of an approved plan?
control programs (e)
If yes, the permittee has notified the North Carolina Sedimentation Control
Not
Commission of all such cases.
Applicable
---
Has the permittee determined that a person engaged in a land -disturbing activity
has failed to comply with an approved erosion and sedimentation control plan?
No
---
If yes, has the permittee referred any such matters to the North Carolina
Not
Sedimentation Control Commission for inspection and enforcement?
Applicable
Comments
The County handles enforcement within the Town's jurisdiction and ETJ. To date, given the few new development projects within
the Town's jurisdiction, enforcement has primarily consisted of corrective actions through inspection reports.
113A-61 Local
The permittee reviews each erosion and sedimentation control plan submitted to
approval of erosion
them and notifies the person submitting the plan that it has been approved,
Yes
9
and sedimentation
approved with modification, or disapproved within 30 days of receipt.
control plans
The permittee only approves an erosion and sedimentation control plan upon
determining that it complies with all applicable State and local regulations.
Yes
9,10
The permittee has disapproved of an erosion and sedimentation control plan in
order to protect riparian buffers along surface waters.
No
---
If yes, the permittee notified the Director of the Division of Energy,
Not
Mineral, and Land Resources within 10 days of the disapproval.
Applicable
---
Comments
The County has not disapproved any plans within the Town's limits in order to protect riparian buffers.
§ 113A-61.1
Inspection of land-
The certificate of approval of each erosion and sedimentation control plan
disturbing activity;
approved by the permittee includes a notice of the right to inspect.
Yes
11
notice of violation
(a)
The permittee provides for inspection of land -disturbing activities to ensure
compliance with the SPCA and to determine whether the measures required in an
Yes
9
erosion and sedimentation control plan are effective.
Comments
Audit Date(s): May 2021 Page 10 of 11

MS4 Permit Self Audit Report
Town of Benson, NC: NPDES Permit No. NCS000558
Construction Site Runoff Controls
§ 113A-61.1
When the permittee determines that a person engaged in land -disturbing activity
Inspection of land-
has failed to comply with the SPCA, the Permittee immediately issues a notice of
Yes
disturbing activity;
violation upon that person.
notice of violation
Each notice of violation issued by the permittee specifies the date by which the
(c)
person must comply.
Yes
Each notice of violation issued by the permittee informs the person of the actions
that need to be taken to comply.
Yes
Comments
The County inspects projects within the Town's ETJ and issues inspections reports and NOVs. However, the County has not had a
need to issue a NOV within the Town's ETJ since the 2013 application. There has been very little new development in the Town's
ETJ.
113A-64 Penalties
Does the permittee issue civil penalties as part of the erosion and sedimentation
program?
Yes
9
Comments (indicate when/why a civil penalty is issued, and the amount, if applicable)
The County has not issued any NOVs or penalties within the Town's ETJ.
Audit Date(s): May 2021 Page 11 of 11