NCS000558_MS4 Annual Report (2023-24 FY)_20240916 (2)

Stormwater Management Program
Self-Assessment and
Annual Report
Town of Benson
NCS000558
Permit Year 1, Cycle 2
August 1, 2023 — June 30, 2024
August 30, 2024

This report constitutes the self assessment and annual report together.
Funding analysis.
The Town completed the funding analysis. The annual expenditure for the stormwater program is
approximately$154,000. This value assumes that approximately 25%of 10 Town staff dedicate time to
SWMP tasks.The Town continued providing CWEP $2164. In addition, the Town has a CIP plan with
stormwater system improvements identified,totaling$1.2M. The Town currently has a street sweeper,
vac truck and knuckle boom to maintenance its stormwater system. The Town's revenue from the
stormwater fee was$88,296 in FY24, meaning the general fund funded the remaining program.
Program challenges.
Staff turnover has been problematic. The Planning Director and Building Inspector left this permit year.
The position for the building inspector has been filled. However,the Planning Director's position has
not. Currently,the Town is using a part time contracted consultant to act as the Planning Director.
UDO delay. In late 2023, a consultant was hired to re-write the Unified Development Ordinance, which
was to house the stormwater and erosion control requirements for new development. The UDO
revision was not completed before the Planning Director left, so the UDO revision was slowed
considerably. To ensure compliance with the Phase 2 permit,the Town has developed an interim
stormwater ordinance that is going through the adoption process currently.
Erosion and sediment control program changes. In April,Johnston County rescinded the erosion and
sediment control program Memorandum of Agreement in all of the incorporated towns in the County.
The Town could either work towards becoming a delegated erosion control program or rely on NCDEQ
for compliance with this element of the Phase 2 permit. The Town elected to allow NCDEQ to review,
approve and enforce erosion control for the Town. This disconnection of erosion control and
stormwater has resulted in procedural changes within the Town to ensure that new development
receives erosion control plan approval.
SWMP Modifications
The Town requests a BMP Change- Reliance on other organizations: Up until April 1, 2024,the Town
relied upon Johnston County to implement the Construction Site Runoff Control Program within the
Town's limits. On April 1, 2024,the County gave the program implementation responsibility to the
Town, and the Town elected to have NCDEQ implement the Construction Site Runoff Control Program.
Based upon a discussion with Isaiah Reed via email,this constitutes a minor modification so no changes
to the SWMP were made.
The Town requests a BMP implementation adjustment—BMP32 Spill Response Plan. While the Public
Works facility has all the spill clean up materials and employees are knowledgeable in spill clean up, a
written spill clean up plan has not been written. This activity was supposed to be completed in this
permit year; however, it was simply missed in SWMP implementation this year. It is now a priority for
permit year 2.
Annual report
The remainder of this report details the activities completed in the first permit year of the 2nd MS4
permit cycle (August 1, 2023—June 30, 2024).
BMP Complete?
Administrative
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BMP1. Adequate funding/staffing: Program staffing is ever changing. The Town Y
Planning Director left in early 2024. Currently, the Town has a contracted part time
Planning Director while position is advertised. Adequate funding is available for
staffing and implementation.
BMP2. Written program:The Town has developed a written SWMP (managed by Ray Y
Adams, Water Systems Manager) , along with SOPs for the IDDE, construction site
runoff and post construction runoff programs. The SWMP committee meets as
needed to go through updates and program implementation.
BMP3. Annual self assessment. Town staff are implementing program elements per Y
the SWMP. Where gaps in program implementation have been identified, Town staff
are addressing the gaps. One example has been related to new development. Forms
have been updated to more effectively identify sites that need stormwater and
erosion control permits. In addition, since the revision of the UDO is taking longer
than expected, an interim stormwater ordinance has been developed.
BMP4. Not for this permit year. N/A
BMP5. Social media campaign. The PIO has reported more than 15 social media Y
posts related to water quality. Most of these posts came from the CWEP website.
BMP6. Continue supporting CWEP.The Town has continued their financial support of Y
CWEP.
BMP7. Maintain the Town's website.This effort is continuous. Information related Y
to new development and illicit discharges can be found on the Town's website.
BMP8. Maintain a phone number for the general public to call in complaints, and Y
develop a simple SOP for staff answering calls. While Town Hall staff know to route
complaints to Utilities and Planning, there is no written SOP in place yet. Town staff
have responded to at least 10 complaints in this permit year.
BMP9. GoGov complaint system. This system is still in place and is used by Town Y
citizens.The landing page for the Town's website has GoGov's link on it.
BMP9.1.Advertise GoGov on the website.See BMP9. Y
BMP10. Conduct a public hearing on ordinance changes. The hearing on the revisions Y
to the ordinance is scheduled for September 2024.
BMP11. Hold public meeting on annual report.This is the first annual report. The ' Y
meeting is scheduled for 9/10/24.
BMP 12. Post at least 1 opportunity annually for public involvement in stormwater Y
program.The Town had 1 opportunity for public input on the IDDE ordinance and will
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have 2 more opportunities in September for the stormwater ordinance and the
annual report.
BMP 13. Advertise input opportunities. These opportunities are advertised on the Y
website and in the newspaper as required.
BMP 14. Continue the annual Town spring cleanup.The annual spring cleanup was Y
held in March of this year.
BMP15. Revise outfall map as needed.The Town hasn't updated the outfall map, as Y
no new outfalls have been found.
BMP16. Develop illicit discharge ordinance. This ordinance has been developed and is Y
going through the Town's process for a public hearing and adoption.
BMP17. Develop IDDE SOP. The SOP has been developed. It is based upon the Center Y
for Watershed Protection/EPA's IDDE manual.
BMP18.A. Visually Screen all outfalls at least once per permit cycle. This is an ongoing N—by PY5
activity, with completion by 2028.
BMP18.B. Investigate illicit discharge complaints.The Town has received 2 ID Y
complaints, both related to commercial areas. Complaints were quickly resolved.
BMP18.C.Track illicit discharges to source. See BMP18.B. Y
BMP18.D.Take enforcement action to remove IDs. See BMP18.B. Y
BMP19. IDDE training. This BMP isn't required to be completed until PY2. N—PY2
BMP20.Train utility staff on IDs. This BMP isn't required to be completed until PY2. N- PY2
BMP 21. Social media posts about IDs. This BMP isn't required to be completed until N-PY2
PY2
BMP22. Departments providing spill response notify PW staff regarding spills. None Y
have been identified this permit year.
BMP23.Train staff receiving complaints about construction site runoff on referral and Y
tracking complaints. Administrative staff receiving complaints track the complaint
and resolution through the Town's work order system.
BMP24. Educate the public about construction site runoff via social media posts. This N-PY2
BMP isn't required to be completed until PY2
BMP25. Utilize the UDO to enforce construction site waste control. This is ongoing. Y
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BMP26. Implement tracking in Town limits. LD-0
Low density (LD) and high density(HD) development plans reviewed. HD-8
LD and HD plans approved HD-1
SCM inventory maintained.The Town has an inventory of 13 permanent SCMs Y
approved.
SCM inspections performed 1
LD inspections performed _ 0
No. and type of enforcement actions 1—NOV;
withheld
inspections
BMP27. Revise UDO to more clearly require stormwater permits. The UDO has been Y
under revision for about 10 months. When the Planning Director left,the UDO
revision slowed. However, an interim stormwater ordinance has been drafted and is
going to Public Hearing in September 2024.
BMP28. Maintain pet waste stations at dog park. Parks and Rec staff have continued Y
to maintain pet waste stations.
BMP29. Develop an inventory of all Town owned facilities. Public Utilities has Y
developed a list of all Town owned facilities.
BMP30. Inspect facilities identified in BMP29
Facilities that have no potential for generating polluted stormwater inspected once Y
per permit cycle.
Facilities that have the potential to generate polluted stormwater inspected annually. Y
The new Public Works facility was inspected in this permit year, with no issues noted.
BMP31. Provide spill kits for facilities that have the potential for spills. The Public Y
Works facility has a spill kit.
BMP32. Spill response plan. While the Public Works facility has all the spill clean up N
materials and employees are knowledgeable in spill clean up, a written spill clean up
plan has not been written. This activity was supposed to be completed in this permit
year;however, it was simply missed in SWMP implementation this year. It is now a
priority for permit year 2.
BMP33. Catch basin maintenance. The town has continued its catch basin cleaning Y
program.
BMP34. Inspect and perform maintenance on Town-owned SCMs. The Town does not Y
own or maintain any SCMs.
BMP35. Maintain an inventory of privately owned SCMs.See BMP26. Y
BMP36. Continue requiring licensed pesticide applicators to apply herbicides. Y
Ongoing
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BMP37. Wash bay and oil/water separator
Wash equipment in washbay. Ongoing. Y
Inspect oil/water separator. O/W separator inspected once this permit cycle. Y
Maintain oil/water separator. No maintenance needs were identified this permit cycle. Y
BMP38. Street Sweeper debris management. The Town continued storing debris from Y
street sweeper in dumpster.
BMP39. Street Sweeping. The Town continued sweeping streets routinely. Y
BMP40. Collect and properly handle yard waste. The Town continued collecting yard Y
waste at least monthly and processing it at the permitted yard waste facility.
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