NCS000518_Navassa 2021 Renewal Application_20210311

NPDES MS4 Permit Renewal Application Form
National Pollutant Discharge Elimination System (NPDES)
Municipal Separate Storm Sewer System (MS4)
Please complete the information below and submit this form along with the required supplemental information
to the address indicated.
Part I: Permittee Information "
iDcnC:1\Mr1
Current Permit No.
NCS 000518
MS4 Name
Town of Navassa MAR 112021
Owner Name*
Barnes Sutton DENR-LAND QUALITY
Owner Title
Stormwater Administrator STORMWATE R PERMITTING
Street Address
334 Main Street
City, State, Zip
Navassa, NC 28451
Phone Number
910-371-2432
E-mail Address
[e-mail]
* The owner must be a principal executive officer or ranking elected official for the city/town/entity that
owns/operates the permitted MS4. Any permit enforcement actions will be sent to the owner on record.
Part II: Primary Contact**
Contact Name
Barnes Sutton
Contact Title
Stormwater Administrator
Employer
Town of Navassa
Street Address
334 Main Street
City,State Zip
Navassa NC 28451
Phone Number
910-371-2432
E-mail Address
[e-mail]
** The primary contact is the responsible party who will oversee the day-to-day permit compliance and
Stormwater Management Program implementation. With the exception of enforcement actions, permit
communications originating from NCDEQ will be sent to the primary contact and will be copied to the other
contacts listed below.
Part III: Other Contacts
Contact Name
Jerry Merrick
E-mail Address
[e-mail]
Contact Name
Claudia Bra
E-mail Address
[e-mail]
Part IV: Required Supplemental Information
Submit one (1) hard copy and one (1) electronic copy of a Draft Stormwater Management Plan (SWMP)
with this permit renewal application. The Draft SWMP must be in the current NCDEQ SWMP Template
format and shall include all required information in order for the permit renewal application to be
considered complete.
Page 1 of 2

Part V: 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 incomplete permit renewal
applications, inclusive of the required Draft SWMP, will not be processed and will be returned to the
permittee.
❑ I am a ranking elected official for the permitted MS4.
❑ 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 the permit owner listed in Part I of this application, which specifies me as (check
one):
® A specific individual having overall responsibility for the stormwater permit.
® A specific position having overall responsibility for the stormwater permit.
Signature:*
6,5e�,
Print Name:
Barnes Sutton
Title:
Storm water Administrator
Signed this 3 day of March 2021 .
* Please note that an original signature is required on this form, any required supplemental information, and any
representative authorization. Photocopies cannot be accepted.
Return this completed form along with the required supplemental information to:
DEQ-DEMLR Stormwater Program
Attn: MS4 Permitting
1612 Mail Service Center
Raleigh, NC 27699-1612
Page 2of2

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Table of Contents
PART 1: INTRODUCTION
PART 2: CERTIFICATION
PART 3: MS4 INFORMATION
3.1 Permitted MS4 Area
3.2 Existing MS4 Mapping
3.3 Receiving Waters
3.4 MS4 Interconnection
3.5 Total Maximum Daily Loads (TMDLs)
3.6 Endangered and Threatened Species and Critical Habitat
3.7 Industrial Facility Discharges
3.8 Non-Stormwater Discharges
3.9 Target Pollutants and Sources
PART 4: STORMWATER MANAGEMENT AMINISTRATION
4.1 Organizational Structure
4.2 Program Funding and Budget
4.3 Shared Responsibility
4.4 Co-Permittees
4.5 Measurable Goals for Program Administration
PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM
PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM
PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM
PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS
1
2
3
3
4
5
5
6
6
6
7
8
9
9
11
11
11
12
14
19
21
26
29
36

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 l: INTRODUCTION
The purpose of this Stormwater Management Plan (SWMP) is to establish and define the means by which
the Town of Navassa will comply wish 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 Navassa 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 NCS000518, 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 Navassa and located
within the corporate limits of the Town of Navassa.
In preparing this SWMP, the Town of Navassa 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.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 1

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.
X1 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):
N A specific individual having overall responsibility for stormwater matters.
® A specific position having overall responsibility for stormwater matters.
Signature:
Print
Name:
Barnes Sutton
Title:
Director of Planning and Development
Stormwater Administrator
Signed this day of March 20 'a R .
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 2

PART 3: MS4 INFORMATION
3.1 Permitted MS4 Area
This SWMP applies throughout the corporate limits of the Town of Navassa, including all regulated
activities associated with the discharge of stormwater from the MS4. The map below shows the corporate
limits of Town of Navassa (in pink) as of the date of this document.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 3

3.2 Existing MS4 Mapping
The current MS4 mapping includes the location of the NC Department of Environment and Natural
Resources stonn water permitted sites. The map also shows the water quality monitoring sites, drainage
ditch outfalls, and stormwater ponds. The natural features that are shown on this map include creeks and
the floodplains located within the Town boundary.
A part of an ongoing Stormwater Wetland and Bioretention Project, seeks to target initial stormwater
areas of concern identified by the Town of Navassa. The project sites are located in different catch -basins
of local watersheds susceptible to impairment via sediment and nutrient loading. This project includes a
mapping portion that looks to locate stormwater inflows, stormwater manholes, stormwater junction
boxes, culvert drain pipes, stormwater discharges, and settling basins. Additional details will include
information on material, diameter/box size, depth, and ground cover of stormwater inflows, culvert drain
pipes, and stormwater discharges.
Map 3.8
Sturm Water&
Water Quality Monlwr "g
O"W 1-lie"
)-It
Table 1: Summary of MS4 Mapping
Percent of MS4 Area Mapped
95
%
No. of Major Outfalls* Mapped
0
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.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 4

3.3 Receiving Waters
The Town of Navassa MS4 is located within the Cape Fear River Basin 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
Cape Fear River
18- 63
C;Sw
Sturgeon Creek
18-77-1
C;Sw
Indian Creek
18-70
C;Sw
Rowell Branch
18-77-1-1-1
C;Sw
Brunswick River
18-77
SC
Mill Creek
18-77-1-1
C;Sw
Mill Branch
18-70-4
C;Sw
Cherry Tree Prong
18-70-2
C;Sw
Cartwheel Branch
18-72
SC;Sw
C;Sw — Waters protected for uses such as secondary recreation, fishing, wildlife, fish consumption,
aquatic life including propagation, survival and maintenance of biological integrity, and agriculture.
Secondary recreation includes wading, boating, and other uses involving human body contact with water
where such activities take place in an infrequent, unorganized, or incidental manner. Supplemental
classification intended to recognize those waters which have low velocities and other natural
characteristics which are different from adjacent streams.
SC — All tidal salt waters protected for secondary recreation such as fishing, boating, and other activities
involving minimal skin contact; fish and noncommercial shellfish consumption; aquatic life propagation
and survival; and wildlife.
3.4 MS4 Interconnection
The Town of Navassa MS4 is not interconnected with another regulated MS4 and directly discharges to
the receiving waters as listed in Table 2 above.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 5

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 Quality
Waste Load
Recovery
Allocation Y/N
Program Y/N
N/A
N/A
N/A
N/A
The Town of Navassa has no water bodies with TMDLs.
3.6 Endangered and Threatened Species and Critical Habitat
Significant populations of threatened or endangered species and/or critical habitat are/are not 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 man 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 Snecies/Habitat Impacted by Surface Water Ouality
Scientific Name
Common name
Species Group
Federal Listing Status
Alligator mississippiensis
American alligator
T S/A
Aci enser oxyrinchus
Atlantic sturgeon
NT
T(S/A) = threatened due to similarity of appearance. A taxon that is threatened due to similarity of
appearance with another listed species and is listed for its protection. Taxa listed as T(S/A) are not
biologically endangered or threatened and are not subject to Section 7 consultation.
3.7 Industrial Facility Discharges
The Town of Navassa 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 Stormwater Permits Man.
Table 5: NPDES Stormwater Permitted Industrial Facilities
Permit Number
Facility Name
NCG130077
CSX - Davis Rail Yard
NCG080938
Davis Rail Yard
NCG080765
Florida Rock & Tank Lines - Navassa
SW8990810
Northeast Brunswick Regional WWTP
SW8930501
American Distillation - Navassa
NCG190085
Cape Fear Boat Works - Navassa
NCS000518
Navassa - Small MS4
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 6

3.8 Non-Stormwater Discharges
The water quality impacts of non-stormwater discharges have been evaluated by the Town of Navassa as
summarized in Table 6 below. The unpermitted non-stonnwater flows listed as incidental do not
significantly impact water quality. The Town of Navassa has evaluated residential and charity car
washing and street washing for possible significant water quality impacts.
The Division has not required that other non-stormwater flows be specifically controlled by the Town of
Navassa.
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 been evaluated by the Town of Navassa to determine whether they will
significantly impact water quality. They were determined to be a possible cause of water quality impacts
in more densely populated neighborhoods and will be addressed through public education efforts.
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 crawls ace pumps
Incidental
Footing drains
Incidental
Lawn watering
Incidental
Residential and charity car washing
Possible
Flows from riparian habitats and wetlands
Incidental
Dechlorinated swimming pool discharges
Incidental
Street wash water
Possible
Flows from firefighting activities
Incidental
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 7

3.9 Target Pollutants and Sources
In addition to those target pollutants identified above, the Town of Navassa is/is not aware of other
significant water quality issues within the permitted MS4 area.
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 programs that address each. In addition, the Town of Navassa has evaluated proposed schools,
homeowners and businesses as target audiences that are likely to have significant stormwater impacts.
The schools were selected as a target audience due to the opportunity to affect positive change through
education and involvement opportunities in a younger demographic. With the intent to start positive
habits that support sustainable behaviors such as anti -littering or interaction with local waterways.
Homeowners and businesses were identified as target audiences because they are likely sources of non -
point pollution through uninformed management practices.
Table 7: Summary of Target Pollutants and Sources
Target Pollutant(s)
Likely Source(s)/Target Audience(s)
SWMP Program Addressing Target
Pollutant(s)/Audience(s)
Litter
Residents, businesses, schools
Public Education & Outreach, Public
Involvement & Participation
Yard Waste
Residents, businesses
Public Education & Outreach, Pollution
(leaves and grass
Prevention & Good Housekeeping
clippings)
Sediment
Businesses, construction
Public Education & Outreach,
Construction Site Runoff Control
Nutrients
Sewer overflows, failing septic
Public Education & Outreach, Illicit
systems, urbanization, schools
Discharge Detection & Elimination,
Construction Site Runoff Control, Post
Construction Site Runoff Control,
Pollution Prevention & Good
Housekeeping
Fecal coliform
Sewer overflows, failing septic
Public Education & Outreach, Illicit
systems, wildlife, illicit discharges
Discharge Detection & Elimination
Mercury/statewide
Atmospheric deposition
Public Education & Outreach (fish
consumption stud
Illicit discharges
Residential, businesses, municipal staff
Public Education & Outreach, Illicit
Discharge Detection & Elimination
Illegal dumping
Residential, businesses, municipal staff
Public Education & Outreach, Pollution
Prevention & Good Housekeeping
Improper disposal
Residential, business, municipal staff
Public Education & Outreach, Public
of Waste
Involvement & Participation, Pollution
Prevention & Good Housekeeping
General non -point
Residential, businesses, schools,
Public Education & Outreach
source pollution
municipal staff
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 8

PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION
Organizational Structure
The Town of Navassa's Division of Stormwater Management is implemented in partnership by primarily
the Planning and Public Works departments. The Planning department is responsible for the public
outreach and involvement components, as well as plan reviews; while the Public Works department is
responsible for good housekeeping and municipal pollution prevention activities, storm sewer system
maintenance, and IDDE. The Planning Director is designated as the Stormwater Program Administrator.
The Planning Department manages the general administration of the program which includes MS4
Annual Report, the Stormwater Management Plan, the Phase II Stormwater Ordinance, Public Education
and Outreach, the Public Involvement and Participation, and the monitoring of the Total Maximum Daily
Load Requirements.
The Public Works Department manages the Illicit Discharge Detection and Elimination, Construction Site
Runoff Control, Post -Construction Stormwater Management, Pollution Prevention/Good Housekeeping
for Municipal Operations, Municipal Facilities Operation & Maintenance Program, Spill Response
Program, MS4 Operation and Maintenance Program, Municipal SCM Operation and Maintenance
Program, Chemical Management Program, Vehicle and Equipment Cleaning Program, and Pavement
Management Program.
go k NATIVE
Town Council
Town Administrator I I Town Clerk I I Town Attorney
Claudia Bray II Charlena Alston
Administr aLion
Deputy Clerk and F. Officer
Budget & Finance Michelyn Alston
Communication
Internal Audit
Legislative Affairs
Benefits and Compensation
Recruitment and Training
Risk Management and Safety
Municipal Buildings
Accounts Payable
Postal Services
Police Department
Field
Operationsl Office of
Support the Chief
Operations
Planning, Development, & Transit
Barnes Sutton
Planning & Zoning Public Services
Permitting &
Code Enforcement
Economic Development
Transportation & Streets
Floodplain Administration
Stormwater Management
Housing
Hazard Mitigation
Capital Improvement Plan
Community Services
Parks & Recreation
Community Development
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 9

Fable 8: Summary of Responsible Parties
SWMP Component
Responsible Position
Staff Name
Department'
Stormwater Program
Planning Director
Barnes Sutton
Planning and
Administration
Development
SWMP Management
Planning Director
Barnes Sutton
Planning and
Development
Public Education &
Planning Director
Barnes Sutton
Planning and
Outreach
Development
Public Involvement &
Planning Director
Barnes Sutton
Planning and
Participation
Development
Illicit Discharge Detection &
Stormwater Inspector
Maurice Williams
Public Works
Elimination
Construction Site Runoff
Stormwater Inspector
Maurice Williams
Public Works
Control
Post -Construction
Stormwater Inspector
Maurice Williams
Public Works
Stormwater Management
Pollution Prevention/Good
Stormwater Inspector
Maurice Williams
Public Works
Housekeeping for Municipal
Operations
Municipal Facilities
Stormwater Inspector
Maurice Williams
Public Works
Operation & Maintenance
Program
Spill Response Program
Stormwater Inspector
Maurice Williams
Public Works
MS4 Operation &
Stormwater Inspector
Maurice Williams
Public Works
Maintenance Program
Municipal SCM Operation &
Stormwater Inspector
Maurice Williams
Public Works
Maintenance Program
Pesticide, Herbicide &
Stormwater Inspector
Maurice Williams
Public Works
Fertilizer Management
Program
Vehicle & Equipment
Stormwater Inspector
Maurice Williams
Public Works
Cleaning Program
Pavement Management
Stormwater Inspector
Maurice Williams
Public Works
Program
Total Maximum Daily Load
Planning Director
Barnes Sutton
Planning and
(TMDL) Requirement,,
Develo ment
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 10

4.2 Program Funding and Budget
In accordance with the issued permit, the Town of Navassa 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 stormwater program currently receives funding of approximately $10,000 per year; this is funded
primarily through the General Fund. However, the Planning Director and Public Works employee
positions are funded through the General Fund and Powell Bill respectively. In total the program receives
2 full-time equivalent staff for pavement management (1 full time Stormwater Administrator and 1 full
time Stormwater Inspector).
The program is currently under -funded to conduct all the proactive elements of the permit. Further fiscal
analysis and investigation of funding options (such as additional general fund allocation or a stormwater
fee) will be conducted as indicated in BMP No. 3 in order to fully fund the program by Permit year two.
4.3 Shared Responsibility
The Town of Navassa 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 Navassa remains responsible for compliance if the other entity fails to perform the permit
obligation, and will be subject to enforcement action if neither the Town of Navassa 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
SWMP BMP or Permit Requirement
Implementing Entity & Program Name
Legal Agreement
Y/N
N/A
4.4 Co-Permittees
There are no other entities applying for co-pennittee status under the NPDES MS4 permit number
NCS000518 for the Town of Navassa. Table 10 summarizes contact information for each co-permittee.
Table 10: Co-Permittee Contact Information
Co-Permittee MS4 Name
Contact Person
Phone & E-Mail
Interlocal Agreement
Y
N/A
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 11

4.5 Measurable Goals for Program Administration
The Town of Navassa will manage and report the following Best Management Practices (BMPs) for the
administration of the Storinwater Management Program.
Table 11: Program Administration BMPs
Permit
' 2.1.2 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 iStormwater Program. ° The self -assessment reporting eriod is the fiscal Fear Jul 1—June 30 .
BMP
A
B
C
D
No.
Description of BMP
'Measurable Goal(s)
Schedule for
Implementation
Annual Reporting Metric
1•
Annual Self -Assessment
Perform an annual evaluation of
1. Prepare, certify and
1. Annually for
1. Annual Self -Assessment
SWMP implementation,
submit the Annual Self-
Permit Years 1 —
received by NCDEQ no later
suitability of SWMP
Assessment to NCDEQ
4 (FY20/21 —
than August 31 each year.
commitments and any proposed
prior to August 31 each
FY23/24)
changes to the SWMP utilizing
year.
the NCDEQ Annual Self -
Assessment Template.
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
2.
Permit Renewal Application
Audit stormwater program
1. Participate in an
1. Year 4
1. N/A
implementation for compliance
NPDES MS4 Permit
with the permit and approved
Compliance Audit, as
SWMP, and utilize the results
scheduled and performed
to prepare and submit a permit
by EPA or NCDEQ.
renewal application package.
2. Self -audit and
2. Year 5
2. Submit Self -Audit to
document any
DEMLR (required
stormwater program
component of permit
components not audited
renewal application
by EPA or NCDEQ
package).
utilizing the DEQ Audit
Template.
3. Certify and submit the
3. Year 5
3. Permit renewal
stormwater permit
application package received
renewal application
by DEQ at least 180 days
(NOI, Self -Audit, and
prior to permit expiration.
Draft SWMP for the next
5-year permit cycle).
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 12

Table 11: Program Administration BMPs
Permit
2.1.1: Adequate Funding and Staffing
Ref.
The permittee shall maintain adequate funding and staffing to implement and manage the provisions of the
SWMP and meet all re uirements of this permit
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting Metric
3.
Adequate funding
Perform a fiscal analysis
1. Complete a fiscal gap
1. Year 1
1. Report monetary value of
and explore options to
analysis
gap
obtain adequate program
2. Determine available
2. Year 1
2. Completed? —
funding to fully fund the
funding mechanisms and
yes/no/status
stormwater program and
evaluate options
meet all requirements of
3. Select a funding
3. Year 1-2
3. Report funding
the permit. Select and
mechanism
mechanism selected
implement a funding
4.I mplement funding
4. Year 2
4. Implemented? —
strategy for the Phase II
Stormwater Program.
mechanism
yes/no/status
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 13

PART 5: Public Education and Outreach Program
The Town of Navassa will implement a Public Education and Outreach Program to distribute educational
materials to the community or conduct equivalent outreach activities about the impacts of storm water
discharges on water bodies and steps the public will take to reduce pollutants in storm water runoff.
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
Navassa 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
Residents, businesses, schools
Yard Waste (leaves and grass
clippings)
Residents, businesses
Sediment
Businesses, construction
Nutrients
Sewer overflows, failing septic sstems, urbanization, schools
Fecal coliform
Sewer overflows, failing septic sstems, wildlife, illicit discharges
Mercury/statewide
Atmospheric deposition
Residential, businesses, municipal staff
Illicit discharges
Illegal dumping
Residential, businesses, municipal staff
Improper disposal of Waste
Residential, business, municipal staff
General non -point source pollution
Residential, businesses, schools, municipal staff
The Town of Navassa will partner with the Cape Fear Council of Governments (CFCOG) to more
efficiently implement education and outreach activities. A local resource called Cape Fear River Watch is
also a potential partner to have organized events related to Public Involvement and Engagement with
watersheds and water quality activities. Additionally, the Town will also develop a stormwater web page
and use social media to reach younger generations and signage on Town owned SCMs to reach
stakeholders at the site of stormwater management. The Town of Navassa will manage, implement and
report the following public education and outreach BMPs.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 14

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 of a Public Education and Outreach Progtam 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 will 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 locallyor through a cooperative agree °ment.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
-
Implementation
Annual Reporting Metric
4.
Partnership with CFCOG
The Town of Navassa will
1. Establish partnership
1. Year 2
1. Report date established
partner with the Cape Fear
with CFCOG and/or
and terms of legal agreement
Council of Governments
contract specific duties
(CFCOG) to more efficiently
2. Submit a partnership plan
2. Year 2
2. Report date plan is
implement education and
detailing specific
approved and include as
outreach activities.
commitments of the
enforceable amendment
CFCOG partnership to NC
to SWMP
DEQ for approval
3. Monitor CFCOG
3. Annually,
3. Yes/no/status
activities to ensure
following
partnership commitments
establishment of
are met
partnership
5.
Partner with Cape Fear River Watch
The Town will develop a
1. Open the dialogue with
1. Year 1
1. Is the partner willing to
"Creek Week" program for
Cape Fear River Watch.
participate? Yes/no/status
grade school youth lessons
during the summer related to
2. Develop a reoccurring
2. Year 2
2. Is the program
the local ecosystems in
Creek Week program that
developed? Yes/no/status
which the SCMs discharge
facilitates and encourages
into.
the youth to learn about
local waterways and how
stormwater management
works.
3. Document Creek Week
3. Years 3-5
3. Number of participants?
campaign event attendance
and report the number of
participants to the public
and elected officials at
Town Hall meetings and
other Town sponsored
events.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 15

6. Social Media Campaign
The Town's existing 1. Post about keeping 1. Year 1 1. Report the date of the
Instagram account has been yard waste and litter out post
used to reach the residential of storm drains
target audience and share
information related to 2. Post about reducing 2. Year 1 2. Report the date of the
stormwater issues, with a fertilizer runoff post
minimum of one post per 3. Post about developing the 3. Year 2 3. Report the date of the
year Stormwater Wetland and post
Bioretention Master Plan
4. Post about greenway 4. Year 3 4. Report the date of the
projects that abut receiving post
surface waters
5. Post about shared 5. Year 4-5 5. Report the date of the
experiences on the post
reenwa s or surface waters
Permit 2.1.7, 3.2.3 and 3.6.5(c): ' Establish Web Site
Ref. Measures to provide a web site designed to convey the program's message(s) and provide online material!
including ordinances, or other regulatory mechanisms, or a list identifying the ordinances or other regulator3
mechanisms, providing the legal authority necessary to implement and enforce the requirements of the permi
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. Schedule for
Description of BMP Measurable Goal(s) Annual Reporting Metric:
Implementation
7. Develop a Stormwater Page on Town Website
Many excellent websites
1. Promote and maintain an
1. Year 1
1. Is the website page
have already been created by
internet web site. Examples
functional? Yes/no/status
other towns that are in the
include, but are not limited
Phase II program, and so
to: post newsletter articles
there are numerous examples
on stormwater, information
easily available to guide the
on water quality,
Town as it begins
stormwater projects and
developing its web page.
activities, and ways to
Since the Town already
contact stormwater
maintains its own website it
management program staff.
will be able to achieve this
goal rather quickly.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 16

Permit
2.1.7, 3.2.3 and 3.6.5(c): Maintain Web Site
Ref.
Measures to maintain a web site designed to convey the program's message(s) and provide updated online i
materials including ordinances, or other regulatory mechanisms, or a list identifyingthe ordinances or other
regulatory inechanisins, 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
8.
Maintain a Stormwater Page on Town Website
Once the Town's
1. Maintain an internet web
1. Year 2-5
1. Has the website page been
Stormwater Management
site. Examples include, but
updated? Yes/no/status
page is active, Staff will
are not limited to: quarterly
work to periodically update
newsletter articles on
the webpage to notify
stormwater, information on
citizens and business owners
water quality, stormwater
of any changes to the
projects and activities, and
program or new ways in
ways to contact stormwater
which they will manage their
management program staff.
properties or further protect
the Town -wide system.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 17

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
9.
Establish a stormwater hotline / helpline
This BMP requires that the
1. Establish and maintain a
1. Year 1
1. Was the hotline
Town establish and publicize
stormwater hotline /
established? Yes NO/Patial
a new hotline that will allow
hel line.
residents to call Town Hall
2. Establish and train a
2. Year 1
2. Report the date of
to discuss stormwater
responsible party to answer
training, and the dates any
problems and issues.
stormwater reporting
additional staff are trained
mechanisms
3. Train responsible parties
3. Year 1
3. Report the date of training
in general stormwater
and the dates any additional
knowledge, appropriate
staff are trained
contacts for stormwater
questions, and citizen
opportunities within the
stormwater program
4. Publicize hotline in
4. Year 1
4. Yes/no/status
materials developed for
the stormwater program
and posting on
stormwater web page
5. Establish a tracking
5. Year 1
5. Was the tracking
mechanism to document
mechanism established?
the number and type of
Yes/no/Partial
calls received
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 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. A
stormwater hotline and a stormwater issue reporting mechanism on the webpage will be used to collect
public input. The Town of Navassa will manage, implement and report the following public involvement
and participation BMPs.
Table 14: Public Involvement and Participation BMPs
Permit
3.3.1: Public Input
Ref.
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
10.
Allow the public an opportunity to review and comment on the stormwater plan.
Time will be allotted at a future
1. Conduct at least one
1. Year 1
1. Yes/no/status
Town meeting to allow public
public meeting to
comment on the stormwater plan.
allow the public to
provide input and
comments on the
Town's stormwater
plan.
11.
Stormwater Page on Town Website
Many excellent websites have
1. See BMP No. 7
1. See BMP No.
1. See BMP No. 7
already been created by other
7
towns that are in the Phase II
program, and so there are
numerous examples easily
available to guide the Town as it
begins developing its web page.
Since the Town already maintains
its own website it will be able to
achieve this goal rather quickly
See BMP No. 7)..
12.
Stormwater Hotline
A hotline will be maintained for
1. See BMP No. 9
1. See BMP No.
1. See BMP No. 9
citizens to ask stormwater
9
questions and report stormwater
issues (See BMP No. 9).
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 19

Permit
3.3.2 Volunteer Opportunities
Ref.
Measures to provide volunteer opportunities designed to promote ongoing citizen participation.
BMP
A
B `
C
D
No.
Description of BMP
Measurable Goals)
Schedule for
Im lementation
AnnuaTReporting Metric
13.
Organize a volunteer community involvement program
Organize and implement a
1. Continue Adopt -A-
1. Annually Year
1. Was a volunteer event
volunteer stormwater related
Street Program.
1-5
held? Yes/No/Partial and
program designed to promote
number of adoptions.
ongoing citizen participation.
2. Litter sweeps in
2. Biannually
2. Yes/No/Partial and
conjunction with
Years 1-5
number of participants or
NCDOT.
bags collected.
14.
Partner with Cape Fear Council of Governments
The Town of Navassa will partner
1. See BMP No. 4
1. See BMP No.
1. See BMP No. 4
with the Cape Fear Council of
4
Governments (CFCOG) to more
efficiently implement education
and outreach activities.
15.
Partner with Cape Fear River Watch
The Town will develop a "Creek
1. See BMP No. 5
1. See BMP No.
1. See BMP No. 5
Week" program for grade school
5
youth lessons during the summer
related to the local ecosystems in
which the SCMs discharge into.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 20

Part 7: Illicit Discharge Detection and Elimination Program
The Town of Navassa 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. A new IDDE Program plan will be created in order to
implement a complete program by permit year 5. The existing MS4 map will be revised to illustrate all
known pipes and structures with additional GIS analysis to classify outfalls as major outfalls, add flow
directions, and receiving waters for a complete map.
Table 15: Illicit Discharge Detection and Elimination BMPs
Permit
:3.4.1: MS4 Map
Ref.
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
16.
Develop a storm sewer system base map and inventory of all major stormwater outfalls.
This is the first component of
1. Map outfall locations
1. Year 2
1. Yes/No/Partial
developing a system for
and stormwater drainage
identifying and eliminating
system components. At a
illicit discharges into the
minimum, components
storm sewer system and local
include major outfalls,
streams. This base map will
receiving streams,
serve as an important tool as
conveyances, and flow
the Town begins its program
direction.
to detect and eliminate illicit
discharges in the third year of
the permit.
Permit
'3.4.1: 'MS4 Map
Ref.
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
17•
Maintain a storm sewer system base map and inventory of all major stormwater outfalls.
1. Update MS4 map with as-
1. Continuasly
1. Year 3-5
1. Yes/No/Partial
built information.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 21

18.
Develop and implement an illicit discharge detection and elimination program.
This BMP will require that
1. Develop and implement
1. Year 3
1. The Town will contract
the Town develop its own
an illicit discharge
with an outside firm to
program for detecting and
detection and elimination
provide this service and the
eliminating illicit discharges
program including
Town's consulting engineer
into the MS4. Because of
provisions for program
will be able to assist with
limited staff availability for
assessment and evaluation.
finding a qualified
this requirement it is
contractor. The Town'
recommended that the Town
attorney will research other
contract with an outside firm,
local ordinances to develop
such as an environmental
an illicit discharge ordinance
engineering firm or perhaps
for the Town.
the City of Wilmington, to
2. Establish written
2. Year 3
2. This BMP will be tied in
conduct periodic inspections
procedures for detecting
with the requirement to
and respond to complaints
and tracing the sources of
establish an illicit discharge
forwarded to it by the Town
illicit discharges and for
detection and elimination
when an illicit discharge is
removing the sources.
program.
detected.
Establish written
procedures for
identification of priority
areas likely to have illicit
discharges.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 22

Permit
3.4.2: 'Regulatory Mechanism
Ref.
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
19.
Maintain Legal Authority
Review existing ordinance
1. Review ordinance and
1. Year 1
1. Report if a revision is
(Phase II Stormwater
update if revision is
required and if a revision
Ordinances, Article VII. Illicit
required to maintain
is made
Discharges) in order to
legal authority
maintain the legal authority to
prohibit, detect, and eliminate
illicit connections and
discharges, illegal dumping
and spills into the MS4,
including enforcement
procedures and actions.
Update ordinance if required.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting Metric
20.
Establish and maintain appropriate legal authorities
This requirement ties in with
1. Establish and maintain
1. Year 3
1. Many municipalities in
the previous BMP.
adequate ordinances or
North Carolina have
Essentially, the Town must
other legal authorities to
ordinances like this in place
adopt ordinances to prohibit
prohibit illicit discharges
that will be modified for the
the illicit discharge of
and enforce the approved
Town's needs.
pollutants into the MS4.
illicit discharge detection
and elimination program.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 23

Permit '
3.4.3: `I 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
21.
Outfall Inspections
Perform regular dry weather
1. Train inspections staff
1. Year 1
1. Yes/No/Partial
(72 hours) outfall inspections
to perform dry weather
to proactively identify
outfall inspections and
illicit discharges and illicit
illicit discharge
connections
investigations
2. Split major outfalls
2. Year 2
2. Yes/no/status
into five equal groups for
inspection; so that with
one group inspected per
year, all major outfalls
will be inspected over a
five-year period
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 24

22•
Illicit Discharge Identification Procedure
Revise and maintain a
1. Develop a SOP for
1. Year 1
1. Completed? -
standard operating procedure
investigating potential
,yes/no/status
(SOP) for investigation of
illicit discharges and
potential illicit discharges,
connections
illicit connections, and illegal
2. Implement IDDE SOP
2. Years 2-5
2. Yes/no/status
dumping.
23•
IDDE Program Evaluation
Yearly evaluation of IDDE
1. Evaluation meeting with
1. Annual
1. Yes/no/status
program to promote
IDDE program supervisor
continuance of effective
and identify repeat
components and improvement
violations and/or areas of
in areas that are lacking, as
concern
well as, identification of
potential "hot -spot" areas.
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
24•
Tracking System
A tracking system for
1. Develop a "Potential
1. Year 1
1. Yes/no/status
observed IDDE violations and
Illicit Discharge Report"
follow-on actions will be
form to include observed
developed and implemented
illicit discharge indicators,
in order to identify "hot -spot"
date, location, and contacts
areas, chronic violators, and
made
recurring issues.
2. Develop a tracking
2. Year 1
2. Yes/no/status
spreadsheet to collect data
from "Potential Illicit
Discharge Report" as well
as the results of the
investigation, any follow-
up, date of closure, and
enforcement actions taken
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 25

Permit
3.4.5:: Staff IDDE Training
Ref.
Measures to provide training for municipal staff and contractorswho, as part of their normal job'
responsibilities, will 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 agenda/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
25.
Staff training
This requires that Town
1. Conduct training for
1. Annual
1. Yes/No/Partial
employees whose normal
appropriate municipal staff
2. Years 1-5
2. Number of staff trained
duties place them in situations
on detecting and reporting
3. See BMP No. 8
where they will come across
illicit discharges. Annual
illicit discharges of pollutants
onboarding training for any
into the MS4 be trained to
relevant new staff and
recognize and report them.
annual refresher training.
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
26•
Stormwater Page on City Website
Many excellent websites have
1. See BMP No. 7
1. See BMP No.
1. See BMP No. 7
already been created by other
7
towns that are in the Phase 11
program, and so there are
numerous examples easily
available to guide the Town
as it begins developing its
web page. Since the Town
already maintains its own
website it will be able to
achieve this goal rather
quickly (See BMP No. 7).
27•
Stormwater Hotline
A hotline will be maintained
1. See BMP No. 8
1. See BMP No.
1. See BMP No. 8
for citizens to ask stormwater
8
questions and report
stormwater issues (See BMP
No. 8).
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 26

Part 8: Construction Site Runoff Control Program
In accordance with 15A NCAC 02H .0153, the Town of Navassa relies upon the North Carolina
Sedimentation Pollution Control Act (SPCA) of 1973 and the NCGO10000 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
Permit
Legal
Meets Whole
Reference
State or Local Program Name
Authority
Implementing Entity
or Part of
Requirement
3.5.1 -
State Implemented SPCA Program
15A NCAC
NCDEQ
Whole
3.5.4
1 Chapter 04
The Town of Navassa 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
C
D
No.
Description of BMP °
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
28.
Municipal Staff Training
Train municipal staff who
1. Train municipal
1. Annually beginning
1. Document and
receives calls from the public on
staff on proper
in Permit Year 1
report number of staff
the protocols for referral and
handling of
trained, training
tracking of construction site
construction site runoff
date(s) and topics
runoff control complaints.
control complaints.
covered.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 27

Permit
3.5.5Waste 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 will cause adverse impact to
water'quality.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
29.
Maintain Legal Authority
Enforce construction site waste
1. Year 1
1. Annually Year 1-5
1. Yes/no/Partial
management requirements via
Article V. — Enforcement and
Violations to control waste
2. Provide construction
2. Year 2
2. Yes NO/Partial
site operators with
educational
information on waste
management
requirements.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 28

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 Navassa 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 Navassa 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.
Table 18: Qualifying Alternative Program(s) for Post -Construction Site Runoff Control Program
State QAP Name
State Requirements
Local Ordinance / Regulatory
Mechanism Reference
None
N/A
N/A
The Town of Navassa has existing requirements other than Qualifying Alternative Program(s) for
implementation of the NPDES Phase II MS4 post -construction program requirements. These existing
requirements are codified in local ordinance(s), and implementation is further defined in guidance,
manuals and/or standard operating procedure(s) as summarized in Table 19 below.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 29

Table 19: Summary of Existing Post -Construction Program Elements
Permit Requirements for
Municipal Ordinance/Code Reference(s)
Date Adopted
Plan Review and Approval
and/or Document Title(s)
3.6.2(a) Authority
Town of Navassa Phase II Stormwater
12-16-2010
Ordinance — Article 1-2
3.6.3(a) & 15A NCAC 02H.0153(c)
Town of Navassa Phase II Stormwater
12-16-2010
Federal, State & Local Projects
Ordinance — Article 1-5
3.6.3(b) Plan Review
Town of Navassa Phase II Stormwater
12-16-2010
Ordinance — Article 1-22
3.6.3(c) O&M Agreement
Town of Navassa Phase II Stormwater
12-16-2010
Ordinance —Article 1-55
3.6.3(d) O&M Plan
Town of Navassa Phase II Stormwater
12-16-2010
Ordinance —Article 1-2 1 (A)(2)(c), Sec. 1-55,
and 1-72
3.6.3(e) Deed
Town of Navassa Phase II Stormwater
12-16-2010
Restrictions/Covenants
Ordinance —Article 1-58
3.6.3(f) Access Easements
Town of Navassa Phase II Stormwater
12-16-2010
Ordinance — Article 1-61
Permit Requirements for
Municipal Ordinance/Code Reference(s)
bate Adopted
Inspections and Enforcement
and/or Document Title(s)
3.6.2(b) Documentation
Town of Navassa Phase II Stormwater
12-16-2010
Ordinance —Article 1-59
3.6.2(c) Right of Entry
Town of Navassa Phase II Stormwater
12-16-2010
Ordinance —Article 1-55
3.6.4(a) Pre -CO Inspections
Town of Navassa Phase II Stormwater
12-16-2010
Ordinance — Article 1-23 d
3.6.4(b) Compliance with Plans
Town of Navassa Phase II Stormwater
12-16-2010
Ordinance — Article 1-23 c
3.6.4(c) Annual SCM Inspections
Town of Navassa Phase II Stormwater
12-16-2010
Ordinance — Article 1-54 b
3.6.4(d) Low Density Inspections
Town of Navassa Phase II Stormwater
12-16-2010
Ordinance —Article 1-37
3.6.4(e) Qualified Professional
Town of Navassa Phase II Stormwater
12-16-2010
Ordinance — Article 1-54 b
Permit Requirements for
Municipal Ordinance/Code Reference(s)
Date Adopted
Fecal Coliform'Reduction
and/or Document Title(s)
3.6.6(a) Pet Waste
Town of Navassa Phase II Stormwater
12-16-2010
Ordinance — Article 1-43
3.6.6(b) On -Site Domestic
Brunswick County Environmental Health
3-16-2015
Wastewater Treatment
Application, Evaluation, and Permitting
Procedures For Septic Systems and Well
Construction — 5.3.8. 10.ii
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 30

The annual reporting metrics for the post construction program are provided in Table 20: Post
Construction Site Runoff Control BMPs below.
Table 20: Post Construction Site Runoff Control BMPs
Permit
3.6.5(a), 3.6.5(b), and 4.1.3:Minimum Post -Construction Reporting Requirements
Ref.
Measures to document activities over the 'course of the fiscal year (July 1 — June 30) including appropriate
information to accurately describe progress, status, and results.
BMP
A
B
C
D
Na
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting Metric
30.
Standard Reporting
Implement standardized
1. Track number of low
1. Continuously
1. Number of plan reviews
tracking, documentation,
density and high density
performed for low density
inspections and reporting
plan reviews performed.
and hi h density.
mechanisms to compile
2. Track number of low
2. Continuously
2. Number of plan approvals
appropriate data for the annual
density and high density
issued for low density and
self -assessment process. Data
plans approved.
high density.
shall be provided for each
3. Maintain a current
3. Continuously
3. Summary of number and
Post -Construction/ Qualifying
inventory of low density
type of SCMs added to the
Alternative Program being
projects and constructed
inventory; and number and
implemented as listed in
SCMs including SCM
acreage of low density
Tables 18 and 19.
type or low density
projects constructed.
acreage, location and last
inspection date.
4. Track number of SCM
4. Continuously
4. Number of SCM
inspections performed.
inspections.
5. Track number of low
5. Continuously
5. Number of low density
density inspections
inspections.
performed.
6. Track number and type
6. Continuously
6. Number and type of
of enforcement actions
enforcement actions taken.
taken.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 31

Permit
3.6.2: Legal Authority
Ref.
Measures to maintain adequate legal authorities through ordinance or other regulatory mechanism to: (a)
review designs and proposals for new development and redevelopment to determine whether adequate
stormwater control measures will be installed, implemented, and maintained,; (b) request information such as
stormwater plans, inspection reports, monitoring ;results, and other information deemed necessary to evaluate
compliance with the Post -Construction Stormwater Management Program, and (c) enter private property for the
purpose of inspecting at reasonable times any facilities, equipment, practices, or operations 'related to
stormwater discharges to determine whether there is compliance with the Post -Construction Stormwater
Management Program.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting Metric
31.
.Implementation
Impose or require deed restrictions and protective covenants for BMP maintenance
The ordinance will contain
1. Impose or require
1. Year 2
1. Yes/No/Partial
language that requires the
recorded deed restrictions
property owners to comply
and protective covenants
with the permit that is issued
that ensure development
by the Town at the time of
activities will maintain
development and maintain the
the project consistent with
structural and nonstructural
approved plans.
BMPs in accordance with their
approved management plans,
including long term financial
funding of maintenance
activities.
The Town's attorney will
assist with this requirement
while modifying the model
stormwater ordinance.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 32

Permit
3.6.3: Plan Review and Approval
Ref.
Measures to maintain plan review and approval authority, standards and procedures to: (a) Require Federal,
State, and local government iprojects to comply with Post -Construction Program requirements throughout the
entire MS4 permitted area, unless the entity is subject to its own NPDES'MS4 permit or a qualifying alternative
program, (b) Conduct site plan reviews of all new development and redeveloped sites that disturb greater than°
or equal to one acre, and sites that disturb less' than one acre that are part of a larger common plan of
development or sale for compliance with 15A NCAC 02H .1017 and the qualifying alternative programs that
apply within your jurisdiction, (c) Ensure that each project has an Operation and Maintenance Agreement that
complies with 15A NCAC 02H .1050(12), (d) Ensure that each project has an Operation and Maintenance Plan
that complies with 15A NCAC 02H' .1050(13), (e) Ensure that each project has recorded deed restrictions and
protective covenants, that require the project to be maintained consistent with approved plans, and (f) Ensure'
that each SCM and associated maintenance accesses be protected in a permanent recorded easement per 15A
NCAC'02H 1050 9 and (10).
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting Metric
32•
Revisions to Code of Ordinances
Revise existing ordinance to
1. Revise code to require
1. Year 2
1. Report code reference and
specifically require compliance
Federal, State, and local
date adopted
by Federal, State, and Local
government projects to
government projects and revise
comply with post
reference to stormwater design
construction requirements
manual to specify NCDEQ
unless subject to its own
Stormwater Design manual.
NPDES MS4 permit or
qualifying alternative
program
2. Revise code to specify
2. Year 2
2. Report code reference and
NCDEQ Stormwater
date adopted
Design Manual as the
reference stormwater
design manual
33.
O&M Plan
Enforce Sec. 1-21(A)(c), Sec.
1. Maintain legal
1. Year 1
1. Yes/No/Partial
1-55, and 1-72 in the
authority through code
Ordinance to the Town code
enforcement
requiring each stormwater
2. Enforce code by
2. Continuously
2. Number of O&M plans
control measure to have an
requiring approval of
approved
Operation and
O&M Plan by Stormwater
Maintenance Plan that
Administrator prior to
complies with 15A NCAC
plan approval
02H .1050(13)
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 33

Permit
3.6.4:'Inspections and Enforcement
Ref.
Measures to maintain inspection and enforcement authority, standards and procedures to: (a) Conduct post -
construction inspections prior to issuing a Certificate of Occupancy or a Temporary Certificate of Occupancy.
Alternatively, the project owner may provide a surety bond to guarantee compliance with the approved plan(s),
(b) Ensure that the project has been constructed in accordance with the approved plan(s), (c) Ensure annual
inspection of each permitted SCM to ensure compliance with the 'approved Operation and Maintenance
Agreement, (d) Ensure inspection of low density projects at least once during the permit term, and (e) Require
that inspections be conducted b a qualified professional.
BMP
No.
A
B
C
D
Description of BMP
Measurable Goal(s)
Schedule forAnnual
Implementation
Reporting Metric
34.
Conduct post -construction inspections and ensure compliance with routine inspections.
Maintain inspection and
1. Conduct post-
1. Continuously
1. Yes/No/Partial
enforcement authority by
construction inspections
conducting post -construction
prior to issuing a
inspections, hold projects to
Certificate of Occupancy
construction standards in
or a Temporary
accordance with the approved
Certificate of Occupancy
plan, ensure annual
inspections, inspect low
2. Ensure that the project
2. Continuously
2. Yes%NO/Partial
density projects at least once
has been constructed in
during the permit term, and
accordance with the
require that inspections be
approved plan(s).
conducted by a qualified
professional.
3. Ensure annual
3. Continuously
3. Yes/No/Partial
inspection of each
permitted SCM to ensure
compliance with the
approved Operation and
Maintenance Agreement,.
4. Ensure inspection of
4. Continuously
4. Yes/No/Partial
low density projects at
least once during the
permit term.
5. Require that
5. Continuously
5. Yes/No/Partial
inspections be conducted
by a qualified
professional.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 34

Permit
3.6.6: `Fecal Coliform Reduction
Ref.
Measures to control,to the maximum extent practicable, sources of fecal coliform per 15A NCAC 02H
.1017(7). At a minimum, the program shall include: (a) A pet waste management component, which will be
achieved by revising an existing litter ordinance,` and (b) An on -site domestic wastewater treatment system `
component, if applicable, which will be coordinated with local county health department, to ensure proper
operation and maintenance of such systems.
BMP
A
B
C <
D
No.
Description of BMP
Measurable Goal(s)
Schedule for `
Implementation
Annual Reporting Metric
35.
Establish a program to control the sources of fecal coliform to the maximum extent practicable.
This BMP requires that the
1. Identify/Map septic
1. Year 2
1. The County Health
Town identify all existing on-
system locations within
Department will assist
site wastewater treatment
the Navassa jurisdictional
the Town with this
systems (septic systems)
area.
effort.
within its jurisdiction and
2. Collect inspection
2. Annually
2. Yes/No/Partial
establish a program for
controlling discharges of fecal
reports from Brunswick
coliform bacteria from them.
County.
This will be carried out in
conjunction with the
3. Require pet waste
3. Continuously
3. Yes/No/Partial
requirement to eliminate
management.
failing septic systems. (See
BMP No. 15)
36
Establish procedures to identify and eliminate failing septic systems and report sanitary sewer overflows.
The Town will provide a
1. Establish procedures to
1. Year 2
1. Yes/No/Partial
resource to let
identify and report to the
homeowners report
County Health Department
failing septic systems to
failed septic systems located
the County, which will
within the permittee's planning
then relay the location
jurisdiction.
and nature of the problem
to the Health Department.
The Town will also
2. Establish procedures to
2. Year 2
2. Yes/No/Partial
explore establishing a
program with the County
identify and report sanitary
to assist homeowners
sewer overflows and sewer
with the cost of tying in
leaks to the system operator.
to the sewer system if
their septic system is
failing.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 35

Part 10: Pollution Prevention and Good Housekeeping Programs
This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the
Town of Navassa 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
The Town of Navassa 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: Municipal Facilities 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 inspectionsand routine maintenance; establish; specific frequencies, ; schedules, and standard
documentation; provide staff training on general stormwater awareness and implementing pollution prevention
and good housekeeping ractices.
BMP
A
B
C
D
No.
Description of BMP
`Measurable Goal(s)
Schedule for
Implementation
Annual Reporting Metric
37•
Conduct staff training
Provide training to its staff on
1. Conduct staff training
1. Annually
1. Yes/No/Partial
pollution prevention
annually and as new staff
measures. All employees that
are onboarded for pollution
deal with hazardous materials
prevention and good
or who have duties that
housekeeping procedures.
include activities that could
contribute to water pollution
will be required to attend
training. NC DENR and
County agencies that deal
with hazardous waste will be
able to provide training to
Town staff.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 36

38.
Prevent or minimize contamination of stormwater runoff from all areas used for facilities, vehicle or
equipment cleaning
Any washing or cleaning of
1. Identify/Inventory all
1. Year 2
1. Yes/No/Partial
Town facilities, equipment, or
municipal facilities that
vehicles conducted on Town
need a SPPP and/or
property will be conducted in
SPCC Plan.
a manner that does not impact
water quality. All Town
2. Map and record all
2. Year 2
2. Yes/No/Partial
equipment and vehicles must
be washed or cleaned either
areas dedicated for
indoors, on grass or gravel
vehicle or equipment
areas outdoors, or at a
cleaning.
washing facility that collects
wash water and discharges it
3. Develop a standard
3. Year 2
3. Yes/No/Partial
into a sanitary sewer system.
inspection form and
tracking mechanism.
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 responseprocedures.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting Metric
39.
Spill response procedures
This requires that the Town
1. Establish spill
1. Year 1
1. Yes/No/Partial
inventory the type and
response procedures for
location of all potential
municipal operations
pollutants that will
owned and operated by
accidentally enter the
the permittee with the
stormwater system.
potential to generate
polluted stormwater
runoff.
2. Develop a standard
2. Year 2
2. Yes/No/Partial
inspection form and
tracking mechanism.
3. Facilities that need a
3. Annually
3. Yes NO/Partial
SPPP and/or SPCC Plan
will be inspected
annually using a
standard form and
tracking mechanism.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 37

Permit
3.7.3: MS4 Operation and Maintenance Program
Ref.
Measures to minimize pollutants in the stormwater collection system. The permittee shall provide operation'
and maintenance staff training on stormwater awareness and pollution prevention, perform MS4 inspections,
maintain the collection system includingcatch basins and conveyances; and establish specific frequencies,
schedules, and standard documentation.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s) ;
Schedule for
Implementation
Annual Reporting Metric
40.
Operations and Management Plan
A proactive plan for MS4
1. Develop a written SOP
1. Year 1
1. Yes/no/ Partial
system maintenance,
that includes proactive,
requiring regular inspections
inspection schedules,
and maintenance.
standard documentation,
staff responsibilities, and
proper maintenance
training.
2. Incorporate SOP into
2. Year 1
2. Yes/No/Partial
SWMP as an enforceable
permit requirement.
3. Implement the SOP
3. Years 2-5
3. Yes/No/Partial
Permit
3.7.4: Municipal SCM Operation and Maintenance Program
Ref.
Measures to manage municipally -owned, :operated, and/or maintained' structural SCMs that are installed for
compliance with the permittee's post -construction program. The permittee shall maintain a current inventory
of SCMs, perform SCM inspections and maintenance, and shall establish specific frequencies, schedules, and
documentation.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting Metric
41.
Inventory of Municipal structural SCMs
Development and
1. Create an inventory of
1. Year 2
1. Number of municipal
maintenance of a current
existing Town -owned
structural SCMs
inventory of municipally
SCMs with information
owned structural SCMs.
including type, year built,
date of last
inspection, and
maintenance actions
2. Compile, and develop
2. Year 3
2. Yes/no/status
as needed, Operation and
Maintenance Plans for all
Town -owned SCMs
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 3 8

42•
SCM Inspections and Maintenance
Performance and
1. Locate Town -owned
1. Year 2
1. Report the number and
documentation of regular
SCMs and add them to
type of SCMs added to
inspection and maintenance
the MS4 Map with type
the map
of municipally owned
of SCM indicated
structural SCMs. Addition of
2. Update the map when
2. Annually
2. Note annually whether
municipally owned SCMs to
new Town -owned SCMs
new Town -owned SCMs
MS4 map.
are constructed
were added.
3. Maintain NC SCM
3. Continuously;
3. Number of staff
Inspections and
beginning Year 1
members with active
Maintenance
certification
Certification for
appropriate ersonnel
4. Develop SCM
4. Year 2
4. Yes/no/status
inspection form
5. Inspect each device
5. Annually,
5. Number of SCMs
using SCM inspection
beginning Year 3
inspected, number
form
passing inspection,
number requiring
maintenance
Permit
3.7.5: Pesticide, Herbicide and Fertilizer Management Program
Ref.
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.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting Metric
43.
Pesticide, Herbicide, Fertilizer Applicator Training
Training of Town staff who
1. Obtain and maintain
1. Continuously
1. Yes/no/status
apply landscape chemicals in
Right -of Way Pest Control,
2. Number of certified staff
order to minimize water
Public Health Control, and
quality impacts from
Ornamental & Turf Pest
pesticides, herbicides, and
Control applicator
fertilizers.
certifications for
appropriate personnel
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 39

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
44.
Vehicle and Equipment Cleaning and Maintenance Facility Inspection
Routine inspections as part of
1. Develop an inspections
1. Year 2
1. Yes/no/status
general facility inspections to
checklist
ensure that vehicle and
2. Perform inspections
2. Annually
2. Number of inspections
equipment facilities are
following proper procedures
using inspection checklist
beginning in
to minimize water quality
and notify facility manager
Year 3
impacts from vehicle and
of any corrective actions
equipment cleaning and
required
maintenance.
45.
Staff Training
Provide general stormwater
1. See BMP No. 37
1. See BMP No.
1. See BMP No. 37
awareness training and
37
pollution prevention training
to employees working in
vehicle maintenance and
cleaning areas (See BMP No.
37).
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 40

Permit
3.7.7: 'Pavement Management Program
Ref.
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 pollutants associated with vehicles, and establish specific frequencies, schedules, and
documentation.
A
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for "
Implementatio
Annual Reporting Metric
n'
46.
Leaf Collection
Periodic collection of leaves
1. Develop a written SOP
1. Year 1
1. Yes/no/ Partial
from residential and public
that includes proactive,
areas to reduce pollutants and
inspection schedules,
clogging of storm system
standard documentation,
inlets.
staff responsibilities, and
proper maintenance
training.
2. Incorporate SOP into
2. Year 1
2. Yes/No/Partial
SWMP as an enforceable
permit requirement.
3. Implement the SOP
3. Years 2-5
3. Yes/No/Partial
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 41

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