NCS000558_Annual Report_20221107

Town of Benson
NPDES Phase 2 permit no. 558
Effective February 1, 2018
Expiring January 31, 2023
Permit Year 4: July 1, 2021 — June 30, 2022
Annual report
October 2022

Background
In 2019, the Town of Benson was audited by NCDEQ. The Town received the audit findings in 2020. In
2021, the Town completed a self audit and submitted a new application for coverage under the Phase 2
permit. The Town did not hear back from NCDEQ, so it is unclear if the revised SWMP was accepted and
approved. In 2022, the Town submitted a revised SWMP and renewal application to DEQ.
The following annual report describes activities that the Town has completed in Permit Year 4 of the
2018 issued permit. The sections referenced follow the 2018 permit, as do the BMPs and measurable
goals.
Section B: Public Education and Outreach
BMP A: Goals and Objectives
Measurable Goals: Defined goals and objectives of the Local Public Education and Outreach Program based on
community wide issues.
• The Town has continued to support CWEP education and outreach initiatives and believes that CWEP's
cohesive statewide stormwater education program has benefited the Town. The Town could not
complete the same tasks with Town staff for the same funding.
BMP B: Describe pollutants and/or stressors.
Measurable goals: The permittee will maintain a description of the target pollutants and/or stressors and likely
sources.
• The Town's list of potential pollutants and likely sources have been identified: sediment and nutrients.
BMP C: Describe target audiences
Measurable goal: The permittee shall maintain a description of the target audiences likely to have significant storm
water impacts and why they were selected.
• The Town continues to focus on general public education through CWEP and local public events. The
Town also focuses on the development community in coordination with Johnston County through the
plans review process.
BMP D: Describe residential and industrial/commercial issues
Measurable Goal: The permittee shall describe issues, such as pollutants, likely sources of those pollutants, impacts,
and the physical attributes of stormwater runoff, in their education/ outreach program.
• This goal is met through the Town's partnership with CWEP.
BMP E: Informational website
Measurable goal: The permittee shall promote and maintain, an internet web site designed to convey the
program's message.
• The Town's stormwater website can be found here: https://www.townofbenson.com/2282/Stormwater
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BMP F: Distribute public education materials to identified target audiences and user groups
Measurable Goal: The permittee shall distribute stormwater educational material to materials to identified target
appropriate target groups ( ex.: schools, homeowners, and/ or audiences and user groups. businesses). Instead of
developing its own materials, the permittee may rely on Public Education and Outreach materials supplied by the
state, and/ or other entities through a cooperative agreement, as available, when implementing its own program.
• The Town has relied upon CWEP to distribute public education materials.
BMP G: Maintain hotline/help line:
Measurable goal: The permittee shall promote and maintain a stormwater hotline/ helpline for the purpose of
public education and outreach.
• The Town maintains a general complaint line that goes to the Administration office and is then routed to
the appropriate department. The Town has also instituted the "GoGov" feedback system where the
public can submit complaints and concerns digitally. Where appropriate, these concerns generate Town
work orders. Work orders are tracked internally.
BMP H: Implement a Public Education and Outreach Program.
Measurable goal: The permittee' s outreach program, including those elements and Outreach Program.
implemented locally or through a cooperative agreement, shall include a combination of approaches designed to
reach the target audiences. For each media, event or activity, including those elements implemented locally or
through a cooperative agreement the permittee shall estimate and record the extent of exposure.
• During this permit year, the Town did not host the Big Sweep litter cleanup.
• In addition, the Town has found that distribution of printed education materials to be generally
ineffective. The Town has an active social media presence through Facebook and in future years will
utilize this medium for public education and awareness related to stormwater quality and quantity.
• The Town of Benson is a member of the Clean Water Education Partnership (CWEP). CWEP leverages
resources from multiple local governments to conduct educational and outreach programs geared
towards reducing stormwater runoff pollution. Programs include mass media campaigns such as
television, radio, internet, and printed materials.
• The Town of Benson provided support through financial contributions to CWEP in the amount of $2164.00
during the 4th permit year.
Section C. Pubic Involvement and Participation
BMP A. Volunteer community involvement program
Measurable goal: The permittee shall include and promote volunteer opportunities designed to promote ongoing
citizen participation.
During this permit year, the Town did not host the annual Big Sweep litter cleanup due to significant
staffing changes and departmental reorganization.
BMP B. Mechanism for Public Involvement
Measurable Goal: The permittee shall provide and promote a mechanism for public involvement that provides for
input on stormwater issues and the stormwater program.
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The Town maintains a phone number for citizens to call for any type of complaint. The Town also uses
"GoGov" to allow citizens to report problems. There was 1 stormwater complaint identified this permit
year through the GoGov reporting system. The complaint was related to flooding in the downtown
corridor, which is known to be problematic.
No public hearings were held regarding the Town's stormwater program in this permit year. The Town
also provides a public notice for all board of commissioners and planning board meetings, highlighting
topics to be heard. When the Town changes their Land Development Ordinance in the next permit year,
the public will be informed and allowed input on the revisions.
BMP C. Hotline/Help line
Measurable Goal: The permittee shall promote and maintain a hotline/ helpline for the purpose of public
involvement and participation.
The Town maintains a general complaint line that goes to the Administration office and is then routed to
the appropriate department.
The Town also collects complaints and concerns from citizens through the "GoGov" system here:
https://www.townofbenson.com/2298/Request-Form
Section D: IDDE
BMP A. Maintain adequate legal authorities.
Measurable goals: The permittee shall annually review the permittee' s IDDE ordinances or other regulatory
mechanisms, or adopt any new ordinances or other regulatory mechanisms that provide the permittee with
adequate legal authority to prohibit illicit connections and discharges and enforce the approved IDDE Program.
• As indicated in the 2020 audit report, the Town does not have a written IDDE program.
BMP B. Maintain a storm sewer system base map of major outfalls.
Measurable goal: The permittee shall maintain a current map showing major outfalls and receiving streams.
• The Town maintains a map of all known major outfalls and streams, as well as the majority of the Town's
stormwater system. There are very old sections of the Town where the stormwater system is unclear. As
the Town continues to maintain and upgrade system components through CIP projects or new
development projects, these system components will be better identified and upgraded/maintained if
needed. The map of the system will then be updated. It is the Town's intent to transfer this stormwater
system mapping to a GIS interface for easier viewing and management in the future.
BMP C. Detect dry weather flows.
Measurable goal: The permittee shall maintain a program for conducting dry weather flow field observations in
accordance with a written procedure for detecting and removing the sources of illicit discharges.
• The Town does not have a written SOP. However, Public Works field staff routinely visually screen
stormwater system components for obvious illicit discharges.
BMP D. Investigate sources of identified discharges.
Measurable goal: The permittee shall maintain a program for conducting dry weather flow field observations in
accordance with a written procedure for detecting and removing the sources of illicit discharges.
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• The Town does not have a written SOP. However, Public Works field staff routinely visually screen
stormwater system components for obvious illicit discharges and follow up on complaints. In permit year
4, no illicit discharges were identified.
BMP E. Track and document investigations illicit discharges.
Measurable goal: The permittee shall track all investigations and document the date(s) the illicit discharge was
observed; the results of the investigation; any follow-up of the investigation and the date the investigation was
closed.
• The Town does not have a written SOP. However, Public Works field staff routinely visually screen
stormwater system components for obvious illicit discharges and follow up on complaints. In permit year
4, no illicit discharges were identified.
BMP F. Employee training.
Measurable goal: The permittee shall implement and document a training program for appropriate municipal staff
who as part of their normal job responsibilities, may come into contact with or otherwise observe an illicit
discharge or illicit connection to the storm sewer system.
• No employee training was conducted in permit year 4 specific to IDDE.
BMP G. Provide public education.
Measurable goal: The permittee shall inform public employees, businesses, and the general public of hazards
associated with illegal discharges and improper disposal of waste.
• No public education on IDDE was conducted in permit year 4 specific to IDDE.
BMP H. Public reporting mechanism.
Measurable goal: The permittee shall promote, publicize, and facilitate a reporting mechanism for the public and
staff to report illicit discharges and establish and implement citizen request response procedures.
The Town publicizes the GoGov complaint system. Citizens can report concerns or problems — including
stormwater issues —through the Town's website here: https://www.townofbenson.com/2298/Reguest-
Form.
BMP I. Enforcement.
Measurable goal: The permittee shall implement a mechanism to track the issuance of notices of violation and
enforcement actions as administered by the permittee. This mechanism shall include the ability to identify chronic
violators for initiation of actions to reduce noncompliance.
• The Town did not have any NOVs issued within the Town's ETJ or Town limits in permit year 4.
Section E: Construction site runoff control
The Town of Benson has a new (2019) MOA with Johnston County to review plans, conduct inspections and
perform enforcement for the Town related to stormwater in new development and redevelopment. Coordination
policies were developed for the two organizations in 2020. The MOA and coordination policy address BMPs A — G.
The Town had 4 new development projects in permit year 4: 3 commercial/industrial and 1 single family
residential.
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The County provides annual reports to the Land Quality Section as a delegated program.
Section F: Post -construction stormwater management in new development and redevelopment
The Town of Benson has a new (2019) MOA with Johnston County to review plans, conduct inspections and
perform enforcement for the Town related to stormwater in new development and redevelopment. Coordination
policies were developed for the two organizations in 2020. The MOA and coordination policy address BMPs A — G.
The Town had 4 new development projects in permit year 4: 3 commercial/industrial and 1 single family
residential.
Section G. Pollution prevention/good housekeeping for municipal operations
BMP A. Inventory of all municipally owned or operated facilities.
Measurable goal: The permittee shall maintain, a current inventory of facilities operations owned and operated by
the permittee with the potential for generating polluted stormwater runoff. Also maintain a current inventory of
the MS4 system and municipally -owned structural SCMs.
• The Town has developed an inventory of all its owned or operated facilities.
• The Town has an incomplete inventory of structural SCMs. 3 ponds were added to the inventory in the 3ra
permit year. An additional 6 SCMs were designed and in construction in permit year 4.
BMP B. Inspect and maintenance for municipally owned or operated facilities.
Measurable goal: The permittee shall maintain and implement, evaluate annually and update as necessary an
Inspection and Maintenance (I&M) program for municipal owned and operated facilities with the potential for
generating polluted stormwater runoff. The I&M program shall specify the frequency of inspections and routine
maintenance requirements.
The Town has prioritized its facilities into high, medium and low priority facilities to prioritize inspections.
The only high priority facility owned/operated by the Town is the Public Works facility. This facility was
constructed over a stream many years back, with direct discharge of stormwater into the stream through
antiquated storm drain inlets. In 2022, the Town completed construction on the new $1.3M Public Works
facility with wash bay and an oil water separator. The old facility is no longer in use. It is the Town's
desire to daylight the stream under the old facility and implement a flood mitigation and stream
restoration project in that area. The Town is working with consultants on the design and permitting of
the stream project currently.
BMP C. Spill response procedures.
Measurable goal: The permittee shall have written spill response procedures for municipally owned or operated
facilities.
• The Town has spill response procedures for the WWTF and Public Works Facility.
BMP D. Streets, roads, and public parking lot maintenance.
Measurable goal: The permittee shall evaluate existing and new BMPs annually that reduce polluted stormwater
runoff from municipally -owned streets, roads, and public parking lots within their corporate limits. The permittee
must evaluate the effectiveness of these BMPs based on cost and the estimated quantity of pollutants removed.
• The Town has a vac truck and vacuums streets weekly.
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BMP E. Inspection and Maintenance for municipally -owned or maintained catch basins and
conveyance system.
Measurable goal: The permittee shall maintain and implement an I& M program for the stormwater sewer system
including catch basins conveyance systems that it owns and maintains.
Town field staff informally inspects the stormwater system on a daily basis. Storm drain system cleaning
with a vac truck occurs weekly. Stormwater catchbasins are cleaned out annually.
BMP F. Identify structural controls.
Measurable goal: The permittee shall maintain a current inventory of municipally - owned or operated structural
stormwater controls installed for compliance with the permittee's post- construction ordinance.
• The Town has an inventory of municipally -owned and operated SCMs.
• The Town has a listing of privately owned and operated SCMs located within the Town limits and the
Town's ETJ. Six new stormwater ponds were added to the inventory in the permit year.
BMP G. I&M for municipally -owned or maintained structural stormwater controls.
Measurable goals: The permittee shall maintain and implement an I&M program for municipally -owned or
maintained structural stormwater controls installed for compliance with the permittee's post -construction
ordinance. The I& M program shall specify the frequency of inspections and routine maintenance requirements.
The permittee shall inspect and maintain municipally -owned or maintained structural stormwater controls in
accordance with the schedule developed by permittee. The permittee shall document inspections and
maintenance of all municipally -owned or maintained structural stormwater controls.
• No new SCMs have been completely constructed in the last permit year. As noted above, 6 new SCMs
have been approved for construction.
BMP H. Pesticide, herbicide and fertilizer application management.
Measurable goals: The permittee shall require that contractors are properly trained and that all permits,
certifications, and other measures for applicators are followed. The permittee shall ensure municipal employees,
as appropriate based on job classification, are trained and that applicable permits and certifications are
maintained, and follow to the MEP measures for applicators.
• Parks and Recreation Department manages mowing, fertilizer and pesticide applications through
contracted services. The contracts require that applicators are properly licensed.
BMP I. Staff training.
Measurable goal: The permittee shall implement an employee training program for employees involved in
implementing pollution prevention and good housekeeping practices.
• Monthly safety meetings are held, headed by the town manager. Safety topics include materials
management and spill response.
BMP J. Prevent or minimize contamination of stormwater runoff from all areas used for vehicle and
equipment cleaning.
Measurable goal: The permittee shall describe and implement measures to prevent or minimize contamination of
the stormwater runoff from all areas used for vehicle and equipment cleaning.
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• All Town equipment is washed in the wash bay at the new Public Works Facility.
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