NCS000518_Navassa DEQ SWMP v1 Comment Letter_20201105

November 5, 2020

CERTIFIED MAIL 7019 1120 0000 5077 1773
RETURN RECEIPT REQUESTED

Town of Navassa
Attn: Barnes Sutton, Director of Planning and Development
334 Main Street
Navassa, NC 28451

Subject: COMMENTS ON DRAFT SWMP (NOV-2020-PC-0006)
Town of Navassa
NPDES MS4 Permit No. NCS000518
Brunswick County

Dear Mr. Sutton:

On December 9, 2019, the North Carolina Department of Environmental Quality (DEQ) audited the Town
of Navassa (Town) for compliance with the subject NPDES MS4 permit. As a result, a Notice of
Violation (NOV) was issued to the Town on January 6, 2020. The NOV defined specific document
submittals and deadlines, which have been provided in a timely manner.

DEQ received the required Draft Stormwater Management Plan (SWMP) submittal on December 20,
2019. Staff have reviewed the submitted Draft SWMP dated April 16, 2020 and request that the
following comments be addressed in a final Draft SWMP. The revised Draft SWMP is required to
be submitted to DEQ within thirty (30) calendar days of receipt of this letter.

Specific Comments

1. Once comments are addressed and the document is ready to be submitted as a final draft for
public notice, the SWMP will need to be signed by the permit owner (either the mayor or mayor
pro tem) unless signatory authority is designated by the owner to another person/position in
writing.
2. Permit Ref. 2.1.7, 3.2.3 and 3.6.5(c): Please break this into two separate BMPs – one to establish
the stormwater web page in year 1 and one to maintain/periodically update it in years 2-5.
3. BMP 8.D.1: The annual reporting metric should be “Was the hotline established? Y/N/Partial”.
4. BMP 8.D.5: The annual reporting metric should be “Was the tracking mechanism established?
Y/N/Partial”.
5. BMP 12.C.1 & D.1: The frequency should be annually Year 1-5, and the annual reporting metric
should be “Was a volunteer event held? Y/N/Partial”.
6. BMP 13.B.1: Please break into two separate BMPs – one to map and one to establish procedures.
The annual reporting metrics should be Y/N/Partial. It is recommended that Navassa consider
whether mapping can be fully completed in Year 2. There is no penalty for implementing this
over multiple years or completing the task early. However, not fulfilling the commitment in Year
2 could create a compliance issue.

7. BMP 14: There are two measurable goals lumped together. Please separate the into two
measurable goals.
8. BMP 17: Provide a schedule for implementation and annual reporting metric.
9. BMP 21: Onboarding training for any relevant new staff is required, and annual refresher
training is recommended.
10. BMP 25 should be listed under the Post-Construction section of the document.
11. BMP 26: The schedule for implementation should be annually for years 1-5. A measurable goal
to provide construction site operators with educational information on waste management
requirements should be added.
12. BMP 33: Cross reference to BMP 14. Include specific measurable goals for (1)
identifying/inventorying septic system locations within the Navassa jurisdictional area, (2)
coordinating with the county health department to identify/report failing septic systems, and (3)
requiring pet waste management.
13. BMP 34.B.1: Clarify that this will be a written plan.
14. BMP 35: Perform and document staff training annually, and as new staff are onboarded.
15. BMP 36.B: The two listed measurable goals are essentially the same – create a Stormwater
Pollution Prevention Plan (SPPP) for municipal facilities that have the potential to pollute
stormwater. Prior to developing a SPPP, there should be a measurable goal to identify/inventory
the facilities that need a SPPP and/or Spill Control & Countermeasure (SPCC) Plan. The Town
should also inspect all municipal facilities once per permit term to determine pollution potential,
and facilities that need a SPPP and/or SPCC Plan should be inspected annually using a standard
form and tracking mechanism.
16. BMP 37: See comment 15 above. NCDENR does not have a model spill response plan.
17. BMP 38: Clarify that this will be a written plan/SOP.
18. BMP 41.B.1: Change “obtain” to “obtain and maintain”. The NC Pesticide Applicator
Certification is required for anyone who applies restricted use pesticides.
19. BMP 42.C.2: Inspect these facilities for compliance with their SPPP annually beginning in year
3. See also comment number 15 above.
20. BMP 44.1.C: Clarify that this will be a written plan/SOP.
21. BMP 44.C.2: The schedule should be Annually beginning in Year 3.

General Comments
1. In general, the words “should”, “can” and “may” should all be “will” in order for the text to
present a clear and specific commitment.
2. In general, the explanatory text in the reporting metric columns is more relevant to the BMP and
measurable goal columns. The reporting metrics should be brief (see General SWMP Guidance
on the DEQ MS4 web page).
3. Just FYI, it is recommended that any standard inspection form include the inspector’s name,
signature and date of inspection.

The required revised Draft SWMP v2 submittal must include an electronic Word document in Track
Changes format, and a hard copy with a certifying statement and original “wet” signature by the Town’s
ranking elected official or designated staff member in compliance with Part IV, Paragraph G of the
current MS4 Permit. Please submit the required Draft SWMP v2 to:

DEQ-DEMLR Stormwater Program
Attn: Jeanette Powell
1612 Mail Service Center
Raleigh, NC 27699-1612
[e-mail]

Thank you for your prompt attention to this matter. Should you have any questions, please contact me at
[phone] or [e-mail].

Sincerely,

Jeanette Powell
MS4 Program Coordinator

Cc via email:
Annette Lucas, DEMLR Stormwater Program Supervisor
Dan Sams, Wilmington Regional Office
DEMLR NPDES MS4 Permit Laserfiche File