NCS000558_SWMP Approval_20230405

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GOY COOPER ,
Governor
ELIZABETH S.6ISER
Secretary
DOUGLAS R.ANSEL NORTH CAROLINA
Interim Director Environmental Quality
1
April 5,2023
CERTIFIED MAIL 7022 0410 0002 1249 7487
RETURN RECEIPT REQUESTED
Town of Benson
Attn: Kimberly Pickett, Town Manager
303 East Church Street
Benson,NC 27504
Subject: Letter of NCDEQ Concurrence
Town of Benson Draft SWMP
NPDES MS4 Permit No.NCS000558
Johnston County
Dear Ms. Pickett:
I
NCDEQ staff have reviewed the Draft SWMP submittal and concur with the outlined program
provided that the following comments be addressed in a final Draft SWMP submittal,to be j
provided to DEQ within thirty (30)calendar days of receipt of this letter to continue with the
renewal process.
Specific Comments
1. A BMP for permit requirement 2.1.1 is not present in the SWMP.
a. Consider a documented analysis to confirm that the program is adequately funded and
staffed to take place permit year 1. With an annual reporting metric of
adequate/inadequate.
2. A BMP for permit requirement 2.2.2 is not present in the SWMP.
a. Consider a measurable goal to create all required written procedures for permit year 1
with a reporting metric of yes/no.
b. Consider a measurable goal to review all written programs and update as need for permit
years 2-5 with an annual reporting metric of yes/no.
3. Consider modifying BMP 8 to include an opportunity(such as minutes in council meeting) in the
event that ordinance changes are not made. This provides the public which are not on social
media an opportunity to comment(consider annually).
4. BMP 11 reporting metric should include some method to estimate the total amount of litter
cleaned up, such as tonnage or bag totals.
5. BMP 16 should include a reporting metric which includes the total number of staff trained.
6. IDDE Program should include a BMP to track the issuance of NOVs(reporting the number of
NOVs issued. As well as a BMP to track complaints and investigations(reporting the number of
complaints received and number of investigations conducted).
7. BMP 27 should include a reporting metric which includes the number of inspections performed.
North Carolina Department of Environmental Quality I Division of Energy,Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center I Raleigh,North Carolina 2 76 9 9-1612
919.707.9200

Page 2 of 2
Letter of Concurrence
Town of Benson
April 5, 2023
I
8. BMP 31 should include a reporting metric which includes the number of inspections performed.
For final approval,the revised Draft SWMP submittal must include a scanned pdf sent to the below listed
email, and a hard copy with a certifying statement and original"wet"signature by the Town's ranking
elected official or designated Town staff member in compliance with Part IV, Paragraph G of the current
MS4 Permit. Please submit the revised SWMP to:
I
i
DEQ-DEMLR Stormwater Program
Attn: Isaiah Reed
1612 Mail Service Center
Raleigh,NC 27699-1612
And electronically to:
[e-mail]
Thank you for your prompt attention to this matter. Should you have any questions, please contact me at
[phone] or at Isaiah.reedgncdenr.gov.
Sincere 12
Is as Reed, PE, CPSWQ, MS4(ECI
MS4 Program Coordinator
North Carolina Department of Environmental Quality
ec: DEMLR NPDES MS4 Permit Laserfiche File
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