HomeMy WebLinkAboutNCS000558_Benson Draft SWMP v2_20210714Draft Stormwater Management Plan
Town of Benson
NCS000558
July 1, 2021
Table of Contents
PART1: INTRODUCTION.........................................................................................................................4
PART 2: CERTIFICATION.........................................................................................................................5
PART 3: MS4 INFORMATION..................................................................................................................6
3.1 Permitted MS4 Area......................................................................................................................6
3.2 Existing MS4 Mapping.................................................................................................................6
3.3 Receiving Waters..........................................................................................................................7
3.4 MS4 Interconnection.....................................................................................................................7
3.5 Total Maximum Daily Loads(TMDLs)........................................................................................8
3.6 Endangered and Threatened Species and Critical Habitat.............................................................9
3.7 Industrial Facility Discharges........................................................................................................9
3.8 Non-Stormwater Discharges.........................................................................................................9
3.9 Target Pollutants and Sources.....................................................................................................10
PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION...................................12
4.1 Orgaiiizalional SIrUCIUre..............................................................................................................12
4.2 Program Funding and Budget......................................................................................................13
4.3 Shared Responsibility..................................................................................................................13
4.4 Co-Permittees..............................................................................................................................14
4.5 Measurable Goals for Program Administration..........................................................................14
PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM.........................................................16
PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM...........................................19
PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM..............................21
PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM...................................................24
PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM........................................26
PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS ................27
List of Tables
Table 1: Summary of MS4 Mapping
Table 2: Summary of MS4 Receiving Waters
Table 3: Summary of Approved TMDLs
Table 4: Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality
Table 5: NPDES Stormwater Permitted Industrial Facilities
Table 6: Non-Stormwater Discharges
Table 7: Summary of Target Pollutants and Sources
Table 8: Summary of Responsible Parties
Table 9: Shared Responsibilities
Table 10: Co-Permittee Contact Information
Table 11: Program Administration BMPs
Table 12: Summary of Target Pollutants & Audiences
Table 13: Public Education and Outreach BMPs
Table 14: Public Involvement and Participation BMPs
Table 15: Illicit Discharge Detection and Elimination BMPs
Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program
Table 17: Construction Site Runoff Control BMPs
Table 18: Qualifying Alternative Program(s) for Post -Construction Site Runoff Control Program
Table 19: Summary of Existing Post -Construction Program Elements
Table 20: Post Construction Site Runoff Control BMPs
Table 21: Pollution Prevention and Good Housekeeping BMPs
PART 1: INTRODUCTION
The purpose of this Stormwater Management Plan (SWMP) is to establish and define the means by which
the Town of Benson will comply with its National Pollutant Discharge Elimination System (NPDES)
Municipal Separate Storm Sewer System (MS4) Permit and the applicable provisions of the Clean Water
Act to meet the federal standard of reducing pollutants in stormwater runoff to the maximum extent
practicable.
This SWMP identifies the specific elements and minimum measures that the Town of Benson will
develop, implement, enforce, evaluate and report to the North Carolina Department of Environmental
Quality (NCDEQ) Division of Energy, Minerals and Land Resources (DEMLR) in order to comply with
the MS4 Permit number NCS000558, as issued by NCDEQ. This permit covers activities associated with
the discharge of stormwater from the MS4 as owned and operated by the Town of Benson and located
within the corporate limits of the Town of Benson.
In preparing this SWMP, the Town of Benson has evaluated its MS4 and the permit requirements to
develop a comprehensive 5-year SWMP that will meet the community's needs, address local water
quality issues and provide the minimum measures necessary to comply with the permit. The SWMP will
be evaluated and updated annually to ensure that the elements and minimum measures it contains
continue to adequately provide for permit compliance and the community's needs.
Once the SWMP is approved by NCDEQ, all provisions contained and referenced in this SWMP, along
with any approved modifications of the SWMP, are incorporated by reference into the permit and become
enforceable parts of the permit.
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 4
PART 2: CERTIFICATION
By my signature below I hereby certify, under penalty of law, that this document and all attachments were
prepared under my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate, and complete.
I am aware that there are significant penalties for submitting false information, including the possibility of
fines and imprisonment for knowing violations.
I am also aware that the contents of this document shall become an enforceable part of the NPDES MS4
Permit, and that both the Division and the Environmental Protection Agency have NPDES MS4 Permit
compliance and enforcement authority.
❑ I am a ranking elected official.
❑ I am a principal executive officer for the permitted MS4.
❑ I am a duly authorized representative for the permitted MS4 and have attached the authorization made
in writing by a principal executive officer or ranking elected official which specifies me as (check one):
❑ A specific individual having overall responsibility for stormwater matters.
❑ A specific position having overall responsibility for stormwater matters.
Signature:
Print
Name:
Q it r NUA i n
Title:
Signed this p day of 20
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 5
PART 3: MS4 INFORMATION
3.1 Permitted MS4 Area
This SWMP applies throughout the corporate limits of the Town of Benson, including all regulated
activities associated with the discharge of stormwater from the MS4. The map below shows the corporate
limits of Town of Benson as of the date of this document.
- Berisvn Parks.&
,Recreaiioii Dep'artinent-~
�'t4"
'w9 -Do dId`f.
x ice.
f �
F7 1a
1 ..
-E'D
3.2 Existing MS4 Mapping
The current MS4 mapping contains pipes, ditches, catch basins, flow direction, and outfalls. The map
was generated in 2015.
Table 1: Summary of MS4 Mapping
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 6
Percent of MS4 Area Mapped
100
%
No. of Major Outfalls* Mapped
29
total
*An outfall is a point where the MS4 discharges from a pipe or other conveyance (e.g. a ditch) directly
into surface waters. Major outfalls are required to be mapped to meet permit requirements. A major
outfall is a 36-inch diameter pipe or discharge from a drainage area > 50-acres; and for industrial zoned
areas a 12-inch diameter pipe or a drainage area > 2-acres.
3.3 Receiving Waters
The Town of Benson MS4 is located within the Neuse and Cape Fear River Basins and discharges
directly into receiving waters as listed in Table 2 below. Applicable water quality standards listed below
are compiled from the following NCDEQ sources:
o Waterbody Classification Map
o Impaired Waters and TMDL Map
o Most recent NCDEQ Final 303(d) List
Table 2: Summary of MS4 Receiving Waters
Receiving Water Name
Stream
Index / AU
Number
Water
Quality
Classification
303(d)'Listed Parameter(s)
of Interest
Drivin Branch (Neuse RB)
27-52-6-1
C; NSW
No Data
Mingo Swamp (Cape Fear RB)
18-68-12-2
C; Sw
No Data
Hannah Creek (Neuse RB)
27-52-6
C; NSW
Benthos, Dissolved OYygen(4mg/L, AL,
FW)
East Mingo Swamp (Cape Fear RB)
18-68-12-2-1
C; Sw
No Data
3.4 MS4 Interconnection
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 7
NCDOT owns several roadways within the Town's corporate limits. The map below identifies the
roadways owned and maintained by NCDOT. The storm drain system associated with these roadways is
interconnected with the Town's stormwater system.
3.5 Total Maximum Daily Loads (TMDLs)
The TMDL(s) listed in Table 3 below have been approved within the MS4 area, as determined by the map
and list provided on the NCDEQ Modeling & Assessment Unit web page. The table also indicates
whether the approved TMDL has a specific stormwater Waste Load Allocation (WLA) for any watershed
directly receiving discharges from the permitted MS4, and whether a Water Quality Recovery Program
has been implemented to address the WLA.
Table 3: Summary of Approved TMDLs
Water Body Name
TMDL Pollutant(s) of Concern
Stormwater
Water
Waste
Quality
Load
Recovery
Allocation
Program
(Y/N)
(Y
Neuse River
Nitrogen
Y
N
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 8
3.6 Endangered and Threatened Species and Critical Habitat
Significant populations of threatened or endangered species and/or critical habitat are identified within the
regulated MS4 urbanized area, as determined by a review of the Endangered and Threatened Species and
Species of Concern by County for North Carolina Map and Listed species believe to or known to occur in
North Carolina map as provided by the U.S. Fish and Wildlife Service. Of those species listed, Table 4
summarizes the species that may be significantly impacted by the quality of surface waters within their
habitat.
Table 4: Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality
Scientific Name
Common name
Species Group
Federal Listing
Status
Haliaeetus leucoce halus
Bald Eagle
Vertebrate
BGPA
Noturus furiosus
Carolina Madtom
Vertebrate
ARS
Necturus lewisi
Neuse River Waterdog
Vertebrate
ARS
Picoides borealis
Red -cockaded
Woodpecker
Vertebrate
E
Fusconaia masoni
Atlantic Pi toe
Invertebrate
ARS
Alasmidonta heterodon
Dwarf Wed emussel
Invertebrate
E
Lasmi ona subviridis
Green Floater
Invertebrate
ARS
Parvas ina steinstansana
Tar River S ine mussel
Invertebrate
E
Elliptio lanceolata
Yellow Lance
Invertebrate
T
Lindera subcoriacea
Bog s icebush
Vascular
ARS
Macbridea caroliniana
Carolina Bo mint
Vascular
ARS
Rhus michauxii
Michaux's Sumac
Vascular
E
3.7 Industrial Facility Discharges
The Town of Benson MS4 jurisdictional area includes the following industrial facilities which hold
NPDES Industrial Stormwater Permits, as determined from the NCDEQ Active NPDES Stormwater
Permit List and/or Active Stotmwater Permits Map.
Table 5: NPDES Stormwater Permitted Industrial Facilities
Permit Number
Facility Name
NCG210474
McIntosh Box and Pallet Co. -Benson
NCG170407
Chicopee, Inc.
NCG11062
Benson WWTP
3.8 Non-Stormwater Discharges
The water quality impacts of non-stormwater discharges have been evaluated by the Town of Benson as
summarized in Table 6 below. The unpermitted non-stormwater flows listed as incidental do not
significantly impact water quality.
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 9
Street washing discharges are addressed under the Pavement Management Program in Part 10 of this
SWMP. The Division has not required that other non-stormwater flows be specifically controlled by the
Town of Benson.
Wash water associated with car washing that does not contain detergents or does not discharge directly
into the MS4 is considered incidental. However, these types of non-stormwater discharges that do
contain detergents have not been evaluated by the Town of Benson to determine whether they may
significantly impact water quality.
If it is determined that car washing with detergents is not incidental, then the Town of Benson will
prohibit this activity if it results in washwater reaching a storm drain.
Table 6: Non-Stormwater Discharges
Non-Stormwater Discharge
Water Quality Impacts
Water line and fire hydrant flushing
Incidental
Landscape irrigation
Incidental
Diverted stream flows
Incidental
Rising groundwater
Incidental
Uncontaminated groundwater infiltration
Incidental
Uncontaminated pumped groundwater
Incidental
Uncontaminated potable water sources
Incidental
Foundation drains
Incidental
Air conditioning condensate
Incidental
Irrigation waters
Incidental
Springs
Incidental
Water from crawl space pumps
Incidental
Footing drains
Incidental
Lawn watering
Incidental
Residential and charity car washing
Incidental
Flows from riparian habitats and wetlands
Incidental
Dechlorinated swimming pool discharges
Incidental
Street wash water
Incidental
Flows from firefighting activities
Incidental
3.9 Target Pollutants and Sources
Based upon observations by Town staff and complaints from citizens, litter and yard waste has been
identified as a potential stormwater pollutant. Also, given that the Town limit is within the Neuse
Riverbasin, nitrogen is also a potential pollutant.
Table 7 below summarizes the water quality pollutants identified throughout Part 3 of this SWMP, the
likely activities/sources/targeted audiences attributed to each pollutant, and identifies the associated
SWMP program(s) that address each. In addition, the Town of Benson has evaluated schools,
homeowners and businesses as target audiences that are likely to have significant stormwater impacts.
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 10
The Town of Benson addresses litter and yard waste pollutants by reaching out to individual property
owners that are not in compliance with Town Ordinances. The Town conducts a community litter sweep
in April each year. Also, the Public Works Department operates a street sweeper and collects yard waste
weekly.
Table 7: Summary of Target Pollutants and Sources
Target Pollutant(s)
Likely Sources)/Target Audience(s)
SWMP Program Addressing
Target Pollutants)/Audience(s)
Litter
Residents
Public Education & Outreach
Yard Waste
Residents
Outreach
Nutrients
Development community
Post Construction Site Runoff Control
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 11
PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION
4.1 Organizational Structure
The Town of Benson's organizational structure does not currently staff personnel solely dedicated to
stormwater management. Under the oversite of the Director of Public Works and Utilities, staff members
from different departments participate in assigned roles to meet the goals of the program. The Town of
Benson also relies on Johnston County Public Utilities for some responsibilities associated with the
program.
Table 8: Summary of Responsible Parties
SWMP Component
Responsible Position
Staff Name
Department
Stormwater Program
Director of Public
Tim Robbins
TOB Public Works
Administration
Works and Utilities
Department
SWMP Management
Director of Public
Tim Robbins
TOB Public Works
Works and Utilities
Department
Public Education &
Public Information
Tyler Douglas
TOB Administration
Outreach
Officer
Public Involvement &
Public Information
Tyler Douglas
TOB Administration
Participation
Officer
Illicit Discharge
Utility Systems
Ray Adams
TOB Public Works
Detection &
Manager
Department
Elimination
Construction Site
Director of Planning
Erin Joseph
TOB Planning and
Runoff Control
and Inspections
Inspections Department
Johnston County
Jessica Batten
Johnston County
Stormwater Manager
Utilities De artment
Post -Construction
Director of Planning
Erin Joseph
TOB Planning and
Stormwater
and Inspections
Inspections Department
Management
Johnston County
Jessica Batten
Johnston County
Stormwater Manager
Utilities Department
Pollution
Public Works
Jeremy Bryant
TOB Public Works
Prevention/Good
Superintendent
Department
Housekeeping for
Parks Director
Matt Smith
TOB Parks and Rec
Municipal Operations
Municipal Facilities
Public Works
Jeremy Bryant
TOB Public Works
Operation &
Superintendent
Department
Maintenance Program
Parks Director
Matt Smith
TOB Parks and Rec
Spill Response Program
Fire Chief
Alan Johnson
TOB Fire Department
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 12
MS4 Operation &
Director of Public
Tim Robbins
TOB Public Works
Maintenance Program
Works and Utilities
Department
Municipal SCM
Utility Systems
Ray Adams
TOB Public Works
Operation &
Manager
Department
Maintenance Program
Pesticide, Herbicide &
Director of Public
Tim Robbins
TOB Public Works
Fertilizer Management
Works and Utilities
Department
Program
Vehicle & Equipment
Director of Public
Tim Robbins
TOB Public Works
Cleaning Program
Works and Utilities
Department
Pavement Management
Director of Public
Tim Robbins
TOB Public Works
Program
Works and Utilities
Department
Total Maximum Daily
Director of Public
Tim Robbins
TOB Public Works
Load (TMDL)
Works and Utilities
Department
Requirements
4.2 Program Funding and Budget
In accordance with the issued permit, the Town of Benson shall maintain adequate funding and staffing to
implement and manage the provisions of the SWMP and comply with the requirements of the NPDES
MS4 Permit. The budget includes the permit administering and compliance fee, which is billed by the
Division annually.
The Town of Benson implemented a Stormwater Fee in Fiscal Year 2020-2021. A charge of $2.50 per
month is assessed on each utility bill. This fee generates $52,050 per year.
4.3 Shared Responsibility
The Town of Benson will share the responsibility to implement the following minimum control measures,
which are at least as stringent as the corresponding NPDES MS4 Permit requirement. The Town of
Benson remains responsible for compliance if the other entity fails to perform the permit obligation, and
may be subject to enforcement action if neither the Town of Benson nor the other entity fully performs
the permit obligation. Table 9 below summarizes who will be implementing the component, what the
component program is called, the specific SWMP BMP or permit requirement that is being met by the
shared responsibility, and whether or not a legal agreement to share responsibility is in place.
Table 9: Shared Responsibilities
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 13
SWMP BMP or
Permit Requirement
Implementing Entity & Program Name
Legal
Agreement
(Y/N)
Construction site runoff
Johnston County Public Utilities
Y
control
Post construction site runoff
Johnston County Public Utilities
Y
control
4.4 Co-Permittees
There are no other entities applying for co-permittee status under the NPDES MS4 permit number
NCS000558 for the Town of Benson. Table 10 summarizes contact information for each co-permittee.
Table 10: Co-Permittee Contact Information
Co-Permittee MS4
Contact Person
Phone & E-Mail
Interlocal
Name
Agreement
(YN)
N/A
4.5 Measurable Goals for Program Administration
The Town of Benson will manage and report the following Best Management Practices (BMPs) for the
administration of the Stormwater Management Program.
Table 11: Program Administration BMPs
Permit
21.2 and Part 4: Annual Self -Assessment
Ref.
Measures to evaluate the performance and effectiveness of the SWMP program components at least annually.
Results shall be used by the permittee to modify the program components as necessary to accomplish the intent
of the Stormwater Program. The self -assessment reporting period is the fiscal ` year (Jul 1— June 30).
BMP'
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
#1
Annual Self -Assessment
Perform an annual evaluation of
1. Prepare, certify and
1. Annually for Permit
1. Annual Self-
SWMP implementation, suitability of
submit the Annual Self-
Years 1 — 4
Assessment received by
SWMP commitments and any
Assessment to NCDEQ
(FY21/22 — FY23/24)
NCDEQ no later than
proposed changes to the SWMP
prior to August 31 each
August 31 each year.
utilizing the NCDEQ Annual Self-
year.
Assessment Template. Note that the
Town was audited and completed a
self assessment in 2019 and 2021.
Therefore, therefor full self
assessments will begin in 2022 and
be submitted by August 31, 2022.
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 14
Table 11: Program Administration BMPs
Permit
1.6: Permit Renewal Application
Ref.
Measures to submit a permit renewal application no later than 180 days prior to the expiration date of the
NPDES MS4 permit.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
#1
Permit Renewal Application
Audit stormwater program
1. Participate in an
1.2019
1. N/A
implementation for compliance with
NPDES MS4 Permit
the permit and approved SWMP, and
Compliance Audit, as
utilize the results to prepare and
scheduled and performed
submit a permit renewal application
by EPA or NCDEQ.
package.
2. Self -audit of public
2.2021
2. Submit Self -Audit to
education and outreach,
DEMLR (required
Note: The Town assumes that
public involvement and
component of permit
DEMLR will renew the Town's MS4
construction site runoff
renewal application
permit in 2022.
control programs.
package).
3. Certify and submit the
3.2021
3. Permit application
stormwater permit
submitted to DEMLR
renewal application
(NOI, Self -Audit, and
Draft SWMP for the next
5-year permit cycle).
4. Participate in
4. TBD
4. N/A
EPA/NCDEQ MS4
permit compliance audits
under new permit.
5. Develop and submit a
5.2027
5. Permit application
permit renewal
submitted to DEMLR
application 180 days
prior to permit expiration
date.
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 15
PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM
The Town of Benson educates the public, business and development communities through the Town's
website, social media platforms, and Town events. The target audiences and identified pollutants listed
in Part 3.9 of this SWMP, which will be addressed by the Public Education and Outreach Program, are
summarized in Table 12 below. In addition, the Town of Benson is required to inform businesses and the
general public of the hazards associated with illicit discharges, illegal dumping and improper disposal of
waste.
Table 12: Summary of Target Pollutants & Audiences
Target Pollutants/Sources
Target Audience(s)
Litter
General Public
Yard waste
General Public
Nutrients
Development community
Illicit discharges
Business community
Table 13: Public Education and Outreach BMPs
Permit
3.2.2 and 3.2.4: Outreach to Targeted Audiences
Ref.
Measures to identify the specific elements and implementation ofa Public Education and Outreach Program to
share educational materials to the community or conduct equivalent outreach activities about the impacts of
stormwater discharges on water bodies and how the public can reduce pollutants in stormwater runoff. The
permittee shall provide educational information to identified target audiences on pollutants/sources identified in
table 12 above, and shall document the extent of exposure of each media, event or activity, including those'
elements implemented locally or through a cooperative agreement.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
#1
Social Media Campaign
The Town will utilize social media
1. Engage with the public
1. Annually
1. Number of social
platforms such as Facebook to
about water quality
media posts
distribute water quality information.
issues through Facebook
and other social media at
least once per year.
2.
2.
2.
3.
3.
3.
4.
4.
4.
5.
5.
5.
#2
Development Community and general public education
The Town will maintain a website
1. Website updated.
1.2022
1. Website maintained
proving information to the
development community and the
2.
2.
2.
general public. Items included:
3.
3.
3.
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 16
Table 13: Public Education and Outreach BMPs
personal pollution prevention,
4.
4.
4.
stormwater management related to
post construction, and SCM
5.
5.
5.
maintenance.
#3
Business community education
The Town's website will be updated
1. Website updated.
1.2022
1. Website updated and
to include information for businesses
maintained.
about illicit discharges.
2.
2.
2.
3.
3.
3.
4.
4.
4.
5.
5.
5.
Permit
2.1.7, 3.2.3 and 3.6.5(c): Web Site
Ref.
Measures to provide a web site designed to convey the program's message(s) and provide online materials
including 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
and SWMP. The web page shall also provide developers with all relevant post -construction requirements,
design standards, checklists and/or other materials.'
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
#2
Town of Benson Website: Stormwater Page
The Town's website will be updated
1. Revise website
1.2022
1. Website in place and
to inform developers/engineers about
kept current.
the requirements for erosion control
2.
2.
2.
and stormwater plans.
3.
3.
3.
4.
4.
4.
5.
5.
Permit
3.2.5: Stormwater Hotline
Ref.:
Measures for a stormwater hotline/helpline for the purpose of public education and outreach.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
#1
Town of Benson Utilities Department
The Town currently has a complaint
1. Revise customer
1.2022
1. manual revised
hotline listed on their website. The
service manual for
complaint line connects to Town
Utilities staff
Hall/Utilities. Town Hall/Utilities
2. Train staff on manual
2.2022
2. Number of staff
staff then direct the call to the correct
trained
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 17
Table 13: Public Education and Outreach BMPs
department. Town Hall/Utilities
3. Complaints received
3.2022 and ongoing
3. Complaints received
Staff have a customer service manual
and resolved
and resolution
that aids them in directing calls. This
4.
4.
4.
manual will be revised to include
5.
5.
5.
stormwater complaints, illicit
discharges, erosion control issues,
etc. information.
#2
Stormwater Hotline
The Town will maintain a complaint
1. Include on webpage
1.2022
1. Hotline advertised on
hotline for stormwater concerns
website.
2. Implementation
2.2022
2. Call count and
resolution
3.
3.
3.
4.
4.
4.
5.
5.
5.
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 18
PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM
This SWMP identifies the minimum elements and implementation of a Public Involvement and
Participation Program that complies with applicable State, Tribal and local public notice requirements.
The MS4name will manage, implement and report the following public involvement and participation
BMPs.
Table 14: Public Involvement and Participation BMPs
Permit
Ref.
3.3.1: Public Input
Mechanisms for public involvement that provide for input on stormwater issues and the stormwater program.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
#1
General Public
TOB will adhere to public notice
requirements for Unified
Development Ordinance changes.
1. UDO revisions placed
on public notice
1. Ongoing as needed
1. Public notice notices
2.
2.
2.
3.
3.
3.
4.
4.
4.
5.
5.
5.
#2
Town Council
TOB staff will educate the Council
on the SWMP.
1. Educational session to
council once SWMP has
been approved.
1.2022
1. Copy of Council
agenda
2. Update Council on
annual report findings
2. 2023 and annually
2. Copy of Council
agenda
3.
3.
3.
4.
4.
4.
5.
5.
5.
#3
2.
2.
2.
3.
3.
3.
4.
4.
4.
5.
5.
5.
Permit
Ref.
3.3.2: Volunteer Opportunities
Measures to provide volunteer opportunities designed to promote ongoing citizen participation.
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 19
Table 14: Public Involvement and Participation BMPs
BMP
A
B "
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
#1
TOB Spring Cleanup
The Town hosts an Annual Spring
1. Annual clean up with
1. Annually - April
1. number of participants
clean up event that focusses heavily
water quality information
on litter sweeps and Town
included.
beautification. The Town will also
2.
2.
2.
highlight personal pollution
prevention practices during clean ups
3.
3.
3.
to educate the public about water
quality protection.
4.
4.
4.
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 20
PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM
The Town of Benson will develop, manage, implement, document, report and enforce an Illicit Discharge
Detection and Elimination Program which shall, at a minimum, include the following illicit discharge
detection and elimination BMPs.
Table 15: Illicit Discharge Detection and Elimination BMPs
Permit
Ref.
3.4.1: MS4 Map
Measures to develop, update and maintain a>municipal storm sewer system map including stormwater
conveyances, flow direction, major outfalls and waters of the United States receiving stormwater discharges.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
#1
MS4 Map
The Town currently has outfalls
identified. This outfall map will be
kept current. In addition, the TOB
will develop a GIS layer of outfalls.
1. Revise and maintain
ma
1.2022
1. Map is current.
2. Develop and maintain
GIS layer
2.2024
2. GIS layer developed
3.
3.
3.
4.
4.
4.
5.
5.
5.
Permit
Ref.
3.4.2: Regulatory Mechanism
Measures to provide an IDDE' ordinance or other regulatory mechanism that provides legal authority to
prohibit, detect, and eliminate illicit connections and discharges, illegal dumping and spills into the MS4,
including enforcement procedures and actions.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
#1
Ordinance
Develop an Illicit Discharge
ordinance. Once developed, the
ordinance will be taken to Council for
approval and adoption.
1. Development of
Ordinance
1.2022
1. Ordinance developed.
2. Presented to Council
for adoption
2.2022
2. Council agenda
3.
3.
3.
4.
4.
4.
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 21
Table 15: Illicit Discharge Detection and Elimination BWs
Permit
3.4.3: IDDE Plan
Ref.
Measures to maintain and implement a written IDDE Plan to detect and address illicit discharges, illegal
dumping and any non-stormwater discharges identified as significant contributors of pollutants to the MS4.'
The plan shall provide standard procedures and documentation to:
a) Locate priority areas likely to have illicit discharges,
b) Conduct routine dry weather outfall inspections,
c) Identify illicit discharges and trace sources,
d) Eliminate the source(s) of an illicit discharge, and
e) Evaluate and assess the IDDE Program.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
#1
Develop a written IDDE Plan
TOB will develop written policies
1. IDDE written program
1.2022
1. Written policies and
and procedures related to the IDDE
developed
procedures in place
2.
program.
3.
3.
3.
4.
4.
4.
5.
5.
5.
Permit
3.4.4: IDDE Tracking
Ref.
Measures for tracking and documenting the date(s), an illicit discharge, illicit connection or illegal dumping was
observed, the results of the investigation, any follow-up of the investigation, the date the investigation was
closed, the issuance of enforcement actions, and the ability to identify chronic violators.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
#1
Screening for IDs
TOB will visually inspect all outfalls
1. 20% of outfalls
1.2022
1. Inspection
at least once per permit cycle.
visually screened.
documentation
2. 20% of outfalls
2.2023
2. Inspection
visually screened.
documentation
3. 20% of outfalls
3.2024
3. Inspection
visually screened.
documentation
4. 20% of outfalls
4.2025
4. Inspection
visually screened.
documentation
5. 20% of outfalls
5.2026
5. Inspection
visually screened.
documentation
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 22
Table 15: Illicit Discharge Detection and Elimination BMPs
Per
3.4.5: Staff IDDE Training
Ref.
Measures to provide training for municipal staff and contractors who, as part of their normal job
responsibilities, may observe an illicit discharge, illicit connection, illegal dumping or, spills. Training shall
include how to identify, and report illicit discharges, illicit connections, illegal dumping and spills. Each staff
training event shall be documented, including the a' enda/materials, date, and number of staff participating.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
#1
IDDE Training
The Town of Benson will use the
1. Training developed
1.2022
1. Training program
written IDDE plan to train field staff
developed/purchased
2. Training delivered
2.2022 and annually
2. Training roster
and inspections staff on identifying
illicit discharges and steps to take
when one is found.
3.
3.
3.
4.
4.
4.
5.
5.
5.
Permit
3.4.6: IDDE Reporting
Ref.
Measures for the public and staff to report illicit discharges, illegal dumping and spills. The mechanism shall be
publicized to facilitate reporting and shall be managed to provide rapid response by appropriately trained
personnel.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
#1
Train Utility Office Staff
The Town will establish written
1. Call count
1. 2022
1. Work orders
protocols for staff to take calls and
direct to the appropriate personnel.
2. Revise PU customer
service policy manual to
2.2022
2. Policy revision
address stormwater
complaints.
3.
3.
3.
4.
4.
4.
5.
5.
5.
#2
Tracking and responding to spills
Public Works staff will respond to
1. Continue tracking
1. ongoing
1. Number of spill
and track identified spills. Spill
spills through work
related work orders
response will include water quality
order system
2.
2.
2.
protection.
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 23
PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
In accordance with 15A NCAC 02H .0153, the Town of Benson relies upon the North Carolina
Sedimentation Pollution Control Act (SPCA) of 1973 and the NCGO 10000 permit for construction
activities as qualifying alternative programs to meet the NPDES MS4 Permit requirements for all
construction site runoff control measures to reduce pollutants in stormwater runoff from construction
activities that result in land disturbance of greater than or equal to one acre and any construction activity
that is part of a larger common plan of development that would disturb one acre or more.
Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program
Meets Whole
Permit
Reference
State or Local Program Name
Legal
Authority
Implementing Entity
or Part of
Requirement
3.5.1 -
Johnston County Stormwater
15A NCAC
Johnston County
Whole
3.5.4
Delegated SPCA Program*
Chapter 04
Stormwater
Program
* The local delegated SPCA Program ordinance(s)/regulatory mechanism(s) can be found at:
https://codelibrary. amlegal.com/codes/j ohnstoncounty/latest/j ohnstoncoun"c/0-0-0-3 759
The Town of Benson also implements the following BMPs to meet NPDES MS4 Permit requirements.
Table 17: Construction Site Runoff Control BMPs
Permit
3.5.6: Public Input
Ref.
Measures to provide and promote a means for the public to notify the appropriate authorities of observed
erosion and sedimentation problems.
BMP
A
B i
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
#1
Municipal Staff Training
Train municipal staff who receive
1. Train municipal staff
1. Annually beginning in
1. Document and report
calls from the public on the protocols
for referral and tracking of
on proper handling of
construction site runoff
Permit Year 1 (FY21/22)
number of staff trained,
training date(s) and
construction site runoff control
control complaints.
topics covered.
complaints. Revise the Utilities
2. Complaints received
2. Annually beginning in
2. Number of complaints
Customer Service Manual to address
and resolved through
Permit Year 1 (FY21/22)
received.
construction site runoff control
coordination with
complaints.
Johnston County.
3.
3.
3.
4.
4.
4.
5.
5.
5.
#2
Public Outreach
The Town has a strong presence on
1. Create at least 2 postT
2022
1. Number of posts
social media. This platform will be
per year
shared on social media
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 24
Table 17: Construction Site Runoff Control IBMPs'
used to educate the public about
construction site runoff.
3.
3.
3.
4.
4.
4.
5.
5.
5.
Permit
3.5.5: Waste Management
Ref.
Measures to require construction site operators to control waste such as discarded building materials, concrete
truck washout, chemicals, litter, and sanitary waste at the construction site that may cause adverse impact to
water quality.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
#.
E&SC plans required to include construction site waste and materials handling
The Town relies upon Johnston
1. Document
1. ongoing
1. Plan requirements
County for erosion and sediment
requirements
documented.
control plan review, inspections and
2.
2.
2.
enforcement. Johnston County
requires that 1 &SC plans contain
3.
3.
3.
plan sheets addressing construction
site wastes. The Town will document
4.
4.
4.
that the E&SC plan requirements of
Johnston County include construction
site waste management.
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 25
PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
This SWMP identifies the minimum elements to develop, implement and enforce a program to address
stormwater runoff from new development and redevelopment projects that disturb greater than or equal to
one acre, including projects less than one acre that are part of a larger common plan of development or
sale, that are located within the Town of Benson and discharge into the MS4. These elements are
designed to minimize water quality impacts utilizing a combination of structural Stormwater Control
Measures (SCMs) and/or non-structural BMPs appropriate for the community, and ensure adequate long-
term operation and maintenance of SCMs.
In accordance with 15A NCAC 02H .0153 and .1017, the Town of Benson implements the
following State post -construction program requirements, which satisfy the NPDES Phase II MS4
post -construction site runoff control requirements as Qualifying Alternative Programs (QAPs) in
the MS4 area(s) where they are implemented.
The Town has a MOU with Johnston County to implement the Neuse NSW rules as a QAP
Table 18: Qualifying Alternative Program(s) for Post -Construction Site Runoff Control Program
State QAP Name
State Requirements
Local Ordinance / Regulatory
Mechanism Reference
Neuse River Basin Nutrient Sensitive
15A NCAC 2B .0235
Johnston County Stormwater
(NSW) Management Strategy
Ordinance and BMP Manual
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 26
Neuse RB — Pink
Cape Fear RB - Yellow
PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS
This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the
Town of Benson municipal facilities and operations. Pollution prevention and good housekeeping is
accomplished through the implementation of seven required programs, which collectively address the
ultimate goal of preventing or reducing pollutant runoff from municipal operations such as parks and
open space maintenance, fleet and building maintenance, new construction and land disturbances, and
municipal storm sewer system maintenance.
Pollution prevention and good housekeeping for municipal operations includes the following programs:
1. Municipal Facilities Operation and Maintenance Program
2. Spill Response Program
3. MS4 Operation and Maintenance Program
4. Municipal SCM Operation and Maintenance Program
5. Pesticide, Herbicide and Fertilizer Management Program
6. Vehicle and Equipment Maintenance Program
7. Pavement Management Program
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 27
The Town of Benson will manage, implement and report the pollution prevention and good housekeeping
BMPs as specified in Table 21 below for each required program.
Table 21: Pollution Prevention and Good Housekeeping BMPs
Permit
3.7.1: MunicipalFacilities Operation and Maintenance Program
Ref.
Measures to manage facilities that are owned and operated by the permittee and have the potential for generating polluted
stormwater runoff. The permittee shall maintain` a current inventory of municipal facilities; perform facility inspections
and routine maintenance; establish specific frequencies, schedules, and standard documentation; provide staff training on
eneral stormwater awareness and implementin " pollution prevention and good' housekeeping ' ractices.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
#1
Facility Inventory
The Town has a listing of all facilities
1. List maintained
1. ongoing
1. Current list of Town
owned and operated by the Town.
owned facilities.
2. Determine which
2.2022
2. List of facilities likely
This list will be kept current. In
addition, the Town will identify the
facilities have the
to have pollutant
facilities that have a likelihood to
potential to discharge
discharges.
discharge pollutants.
pollutants.
3.
3.
3.
4.
4.
4.
5.
5.
5.
#2
Facility Inspections
The Town will develop inspection
1. Develop inspection
1.2022
1. Prioritization
priorities for facilities based upon the
prioritization.
completed.
facility's potential to discharge
2. High priority facilities
2.2022 and ongoing.
2. Inspections completed.
pollutants. High priority facilities will
inspected annually.
3.
3.
3.
be inspected annually.
4.
4.
4.
5.
5.
5.
#3
SOPs for facilities
Develop Standard Operating
1. Develop SOPS.
1.2022
1. SOPs developed
Procedures for materials handling and
storage at Town owned facilities.
Distribute the SOPs to facility
managers. Conduct employee
2. Train staff on SOPS
2. 2022 and annually
2. Sign in sheets for
training; training to ics
3.
3.
3.
training on SOPS.
4.
4.
4.
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 28
#4
Construct new Public Works
Facility.
1. Complete
1. 2022
1. Facility completed.
Currently, the Town's Public Works
construction of new
yard is constructed over an old,
public works yard.
poorly piped stream with open storm
2. Maintain oil water
2. As needed
2. Maintenance log
drain boxes that connect directly to
separator
the stream. During Hurricane
Matthew, the stream piping failed
and caused a significant amount of
flooding upgradient from the yard.
Managing stormwater around these
storm drain boxes has been difficult.
A new facility with an indoors wash
bay and oil/water separator is under
construction. The new facility will
have better pollution prevention
controls and materials management
built into the facility.
Permit
3.7.2: Spill Response Program
Ref.
Measures for facilities and operations that store and/or use materials that have the potential to contaminate stormwater
runoff if spilled. The permittee shall maintain written spill response procedures and train staff on spill response
rocedures.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
91
Spill Response Plan for Priority Facilities
The Town will develop SOPS for
1. SOP developed
1.2022
1. SOP developed
spill response for priority facilities.
92 Staff Training
Conduct spill response training for
each department, using the spill
response plan SOP.
3. 3. 3.
4. 4. 4.
5. 5. 5.
1. Provide Training 1.2022 and annually 1.Training Roster
2. 2. 2.
3. 3. 3.
4. 4. 4.
5. 5. 5.
ce Program
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 29
Table 21:
Pollution Prevention and Good Housekeeping BMPs
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
#1
Catch Basin Maintenance
Develop prioritization for
maintaining catch basins. Cleanout
priority catch basins as needed.
1. Prioritization matrix
developed.
1. 2022 and annually
reviewed for revisions
1. Prioritization
developed and reviewed
annually.
2. Priority catch basins
cleaned.
2. 2022 and as directed
by prioritization.
2. Records documenting
catch basins cleaned.
3.
3.
3.
4.
4.
4.
5.
5.
5.
#2
Street sweeping
The Town sweeps streets weekly to
remove sand, leaves and debris.
1. Streets swept weekly.
1. Weekly
1. Street sweeper
records; amount of
material removed per
year.
2.Clean up trash and
blockages
2. As needed
2.Record
3.
3.
3.
4.
4.
4.
5.
5.
5.
Permit
Ref.
3.7.4: Municipal SCM Operation and Maintenance Program
Measures to manage municipally -owned, operated, and/or maintained structural SCMs that are installed for compliance
with the permittee's post -construction program. The pennittee shall maintain a currentinventory of SCMs, perform SCM
inspection and maintenance, and shall establish 'ispecific frequencies, schedules, and documentation.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
#1
Post -Construction SCM Inspection and Maintenance
Currently, the Town does not own or
operate any SCMs.
1.
1.
1.
2.
2.
2.
3.
3.
3.
4.
4.
4.
5.
5.
5.
Permit
Ref.
3.7.5: Pesticide, Herbicide and Fertilizer Management Program
Measures to minimize water quality impacts from the use of landscape chemicals. The permittee shall provide routine
pollution prevention and chemical use, storage and handling training, and shall ensure compliance with permits and
applicator certifications.
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 30
Table 21: Pollution Prevention and Good Housekeeping BMPs '.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
#1
Licensed Pesticide Applicators
All Town staff pesticide applicators
1. Licensed Town staff
1. Annually
1. NCDA report
must be licensed pesticide
will maintain pesticide
applicators. Continuing education
license through
and training for licensed applicators
continuing education
supported by the Town.
2.
2.
2.
3.
3.
3.
4.
4.
4.
5.
5.
5.
Permit
3.7.6: Vehicle and Equipment Maintenance Program
Ref.
Measures to prevent and minimize contamination of stormwater runoff from areas used for municipal vehicle and
equipment maintenance and/or cleaning. The permittee shall ensure that municipal industrial facilities subject to NPDES
industrial permitting comply with those Permit requirements, provide routine pollution prevention training to staff,
perform routine inspections, and establish specific frequencies, schedules, and documentation.
BMP'
A
B
C
D
No.
Description of BMP
Measurable Goal(s) '
Schedule for
Implementation
Annual Reporting
Metric
#1
Washbay with Oil Separator
The new Public Works facility will
1. Construct washbay
1.2022
1. Complete construction
have a washbay for washing
of Public Works facility.
2. Wash all vehicles in
2. Ongoing
2. Inspection/Maint.
equipment.
the washbay.
Records for oil separator
3.
3.
3.
4.
4.
4.
5.
5.
5.
#2
WWTF
Evaluate the WWTF to determine if a
1. Evaluate WWTF for
1.2022
1. Evaluation
stormwater permit is required. If
no exposure or
documented.
required, obtain a permit.
stormwater permit.
2. If needed, submit a
2.2022
2. Permit application, if
stormwater permit for the
needed.
WWTF.
3.
3.
3.
4.
4.
4.
5.
5.
5.
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 31
Table 21:
Pollution Prevention and Good Housekeeping BMPs
Permit
Ref.
3.7.7: Pavement Management Program
Measures to reduce pollutants in stormwater runoff from municipally -owned streets, roads, and parking lots within the
permittee's corporate limits. The permittee shall implement measures to control litter, leaves, debris, particulate and fluid
ollutants associated with vehicles, and establish specific fre uencies, schedules, and documentation.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
#1
Street Sweeping
Sweep streets at least monthly.
1. All Town owned
streets swept at least
monthly.
1. Continuous
1. Sweeping record
2.
2.
2.
3.
3.
3.
4.
4.
4.
5.
5.
5.
NCS000558 SWMP
Town of Benson
July 1, 2021
Page 32