NCS000518_Navassa Draft SWMP v2 DEQ Comment Letter_20210223

February 23, 2021

VIA EMAIL ONLY
RETURN RECEIPT REQUESTED

Town of Navassa
Attn: Eulis A. Willis, Mayor
[e-mail]
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 Mayor Willis:

On December 9, 2019, the 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), version 1, submittal on May 4,
2020, provided comments on November 5, 2020 and received the revised Draft SWMP v2 on Nove,ber 6,
2020. Staff have reviewed the submitted Draft SWMP v2 and request that the following comments
be addressed in a Final Draft SWMP. The Final Draft SWMP is required to be signed and
submitted to DEQ within thirty (30) calendar days of receipt of this letter, along with a signed
permit renewal application.

Comments

1. General comment: Annual Reporting Metrics in Column D should be brief - a quantity, number
trained, Y/N/Status, date completed, etc. See SWMP Template Instructions and the new General
SWMP Guidance on the DEQ MS4 Forms & Resources web page for additional information. In
general, the descriptive verbiage in Column D should be located in the BMP description in
Column A.
Please note that the new permit will be issued with an annual reporting template that is specific to
the approved SWMP, and this information will be utilized to ensure that the MS4 is on track to
maintain compliance. The provided template will be an Excel spreadsheet, which will facilitate
future electronic reporting requirements, but will not support the submittal of additional
documentation such as agendas, documents, etc.

2. Table 3: Enter N/A in the table.
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3. Table 7 & 12: Since Mercury is a statewide air quality TMDL, the town can elect to address it as
a stormwater pollutant of concern, but is not required to.
4. General Comment, Description of BMP, Column A: Change “plans to” to “will” throughout in
order to make the BMPs less vague and a specific commitment.
5. BMP 5.C.2: Add an additional BMP for the recurring implementation of the Creek Week youth
program annually in Permit Years 3-5, report number of participants.
6. BMP 5.B.3: It is unclear what this Measurable Goal is/accomplishes. A Measurable Goal to
implement the program in Permit Years 3-5 is required.
7. BMP 13: Text in Column B.1 should be moved to Column A to describe the BMP. The
Measurable Goals should be:
1. Continue Adopt-A-Street Program, Annually Years 1-5, Yes/No/Partial and number
of adoptions.
2. Litter sweeps in conjunction with NCDOT, Bi-Annually Years 1-5, Yes/No/Partial
and number of participants or bags collected.
8. BMP 16.B.1: Include conveyances and flow direction.
9. BMP 17: It appears that the Stormwater Ordinance Sec. 1-23(C) provides the authority to require
infrastructure as-builts, so this BMP may be revised to:
1. Update the MS4 map with as-built information, Continuously, Permit Years 3-5,
Yes/No/Partial.
10. BMP 18.D.1: The current language should be included in Column A if needed to describe the
BMP. Please report Yes/No/Partial for both Measurable Goals 1 and 2.
11. BMP 18: This BMP is incorrectly placed, move to Permit Ref. 3.6.6 Fecal Coliform Reduction.
12. BMP 19 conflicts with the BMPs listed under Permit Ref. 3.4.3. Please resolve.
13. BMP 22.B.2: Change “Keep a written IDDE program” to “Implement IDDE SOP” and include
applicable permit Years in Column C.
14. BMP 25.C & D: Move text to column B and list the Schedule for Implementation as Annual and
provide the applicable permit years. Also provide Yes/No/Partial and number of staff trained in
Column D. Also cross reference BMP No. 8 for reporting purposes.
15. Table 16: The town of Navassa does not have a state-delegated Sediment Pollution Control Act
program, nor does Brunswick County. Therefore, the correct table entry should be: 3.5.1 - 3.5.4 State Implemented SPCA Program 15A NCAC Chapter 04 NCDEQ Whole

16. BMP 29: The BMP is confusing, please clarify.
17. Delete Permit Ref. 2.3 and 3.6: Qualifying Alternative Program(s) as the Town does not
implement any.
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18. BMP 31.D.1: Move text to column A and provide a reporting metric of Yes/No/Partial.
19. BMP 32: This is not the correct location for this BMP. Please move it under Permit Ref. 3.4.2 in
Table 15.
20. Reinsert Permit Ref. 3.6.4 Inspections and Enforcement from the SWMP Template into the table
at the appropriate location.
21. Table 19 3.6.3(d), BMP 32 & 34: It appears that a BMP may be needed to provide legal authority
to require an O&M Plan. However, the existing ordinance does provide the authority for the
Stormwater Administrator to establish permit application requirements [Ref. Sec. 1-21(A)(2)(c)
and Sec. 1-55 and 1-72 establish O&M Plan enforcement authority. Please resolve/clarify.
22. BMP 35: Move D.1 text to Column A and provide Yes/No/Partial reporting metrics. It is
recommended that identified septic systems be included as a layer in the GIS MS4 map to
facilitate illicit discharge detection and elimination.
23. BMP 35.B.2: This is not a clear and specific measurable goal. Clarify whether inspections will
be performed and documented. An alternative could be to provide informational septic O&M
brochures to each residence with a permitted septic system.
24. BMP 36: Delete Permit Ref. 3.5.6 Public Input in this location and BMP 36. This Permit Ref.
belongs in Table 17 for Construction Site Runoff Controls and is already listed there.
25. BMP 37: This BMP is not relevant to Permit Ref. 3.7.1 Municipal Facilities O&M Program.
SCM O&M is listed under Permit Ref. 3.7.4 further down in the table.
26. BMP 39: Please clarify the BMP to meet the requirement to inventory all municipal facilities
(not just vehicle or equipment cleaning), inspect to identify pollution potential, and inspect those
with potential at least once annually. A standard inspection form and tracking mechanism must
also be developed.
27. BMP 40: Does the town already have a standard form and tracking mechanism? If not,
developing those should be specific measurable goals. D.1 is a measurable goal.
28. BMP 41: The proposed BMP is insufficient to address the permit requirements in 3.7.3 MS4
Operation and Maintenance Program. If the proposal is to develop a compliant plan, then the
SOP must be reviewed and approved by DEQ, incorporated into the SWMP as an enforceable
permit requirement, and must be completed in Permit Year 1 and implemented in Permit Years 2-
5.
29. BMP 44.D: Also include number of certified staff.
30. BMP 46: Correct the listed cross reference to BMP No. 24, which is not applicable here.
31. BMP 47: The proposed BMP is insufficient to address the permit requirements in 3.7.7 Pavement
Management Program. If the proposal is to develop a compliant plan, then the SOP must be
reviewed and approved by DEQ, incorporated into the SWMP as an enforceable permit
requirement, and must be completed in Permit Year 1 and implemented in Permit Years 2-5.
The required revised Final Draft SWMP v3 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.
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Please submit the required signed Draft SWMP v3 and permit renewal application 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:
Barnes Sutton, [e-mail]
Annette Lucas, Stormwater Program Supervisor
Dan Sams, Wilmington Regional Office
DEMLR NPDES MS4 Permit Laserfiche File