HomeMy WebLinkAboutNCS000518_Navassa Draft Final SWMP v3_20210305STORMWATER MANAGEMENT PLAN
TOWN OF NAVASSA
March 3, 2021 | NCS000518
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Table of Contents
PART 1: INTRODUCTION 1
PART 2: CERTIFICATION 2
PART 3: MS4 INFORMATION 3
3.1 Permitted MS4 Area 3
3.2 Existing MS4 Mapping 4
3.3 Receiving Waters 5
3.4 MS4 Interconnection 5
3.5 Total Maximum Daily Loads (TMDLs) 6
3.6 Endangered and Threatened Species and Critical Habitat 6
3.7 Industrial Facility Discharges 6
3.8 Non-Stormwater Discharges 7
3.9 Target Pollutants and Sources 8
PART 4: STORMWATER MANAGEMENT AMINISTRATION 9
4.1 Organizational Structure 9
4.2 Program Funding and Budget 11
4.3 Shared Responsibility 11
4.4 Co-Permittees 11
4.5 Measurable Goals for Program Administration 12
PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM 14
PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM 19
PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM 21
PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM 26
PART 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM 29
PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS 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
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 1
PART 1: INTRODUCTION
The purpose of this Stormwater Management Plan (SWMP) is to establish and define the means by which
the Town of Navassa will comply with 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 2
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.
☐ 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):
☐ 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____.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 3
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 4
3.2 Existing MS4 Mapping
The current MS4 mapping includes the location of the NC Department of Environment and Natural
Resources storm 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.
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 5
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 6
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
Waste Load
Allocation (Y/N)
Water Quality
Recovery
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 map 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 Species/Habitat Impacted by Surface Water Quality
Scientific Name Common name Species Group Federal Listing Status
Alligator mississippiensis American alligator T (S/A)
Acipenser 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 Map.
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 7
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-stormwater 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 crawl space 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 8
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
(leaves and grass
clippings)
Residents, businesses Public Education & Outreach, Pollution
Prevention & Good Housekeeping
Sediment Businesses, construction Public Education & Outreach,
Construction Site Runoff Control
Nutrients Sewer overflows, failing septic
systems, urbanization, schools
Public Education & Outreach, Illicit
Discharge Detection & Elimination,
Construction Site Runoff Control, Post
Construction Site Runoff Control,
Pollution Prevention & Good
Housekeeping
Fecal coliform Sewer overflows, failing septic
systems, wildlife, illicit discharges
Public Education & Outreach, Illicit
Discharge Detection & Elimination
Mercury/statewide Atmospheric deposition Public Education & Outreach (fish
consumption study)
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
of Waste
Residential, business, municipal staff Public Education & Outreach, Public
Involvement & Participation, Pollution
Prevention & Good Housekeeping
General non-point
source pollution
Residential, businesses, schools,
municipal staff
Public Education & Outreach
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 9
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.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 10
Table 8: Summary of Responsible Parties
SWMP Component Responsible Position Staff Name Department
Stormwater Program
Administration
Planning Director Barnes Sutton Planning and
Development
SWMP Management Planning Director Barnes Sutton Planning and
Development
Public Education &
Outreach
Planning Director Barnes Sutton Planning and
Development
Public Involvement &
Participation
Planning Director Barnes Sutton Planning and
Development
Illicit Discharge Detection &
Elimination
Stormwater Inspector Maurice Williams Public Works
Construction Site Runoff
Control
Stormwater Inspector Maurice Williams Public Works
Post-Construction
Stormwater Management
Stormwater Inspector Maurice Williams Public Works
Pollution Prevention/Good
Housekeeping for Municipal
Operations
Stormwater Inspector Maurice Williams Public Works
Municipal Facilities
Operation & Maintenance
Program
Stormwater Inspector Maurice Williams Public Works
Spill Response Program Stormwater Inspector Maurice Williams Public Works
MS4 Operation &
Maintenance Program
Stormwater Inspector Maurice Williams Public Works
Municipal SCM Operation &
Maintenance Program
Stormwater Inspector Maurice Williams Public Works
Pesticide, Herbicide &
Fertilizer Management
Program
Stormwater Inspector Maurice Williams Public Works
Vehicle & Equipment
Cleaning Program
Stormwater Inspector Maurice Williams Public Works
Pavement Management
Program
Stormwater Inspector Maurice Williams Public Works
Total Maximum Daily Load
(TMDL) Requirements
Planning Director Barnes Sutton Planning and
Development
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 11
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-permittee 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)
N/A
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 12
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 Stormwater Management Program.
Table 11: Program Administration BMPs
Permit
Ref.
2.1.2 and Part 4: Annual Self-Assessment
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 Stormwater Program. The self-assessment reporting period is the fiscal year (July 1 – June 30).
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
1. Annual Self-Assessment
Perform an annual evaluation of
SWMP implementation,
suitability of SWMP
commitments and any proposed
changes to the SWMP utilizing
the NCDEQ Annual Self-
Assessment Template.
1. Prepare, certify and
submit the Annual Self-
Assessment to NCDEQ
prior to August 31 each
year.
1. Annually for
Permit Years 1 –
4 (FY20/21 –
FY23/24)
1. Annual Self-Assessment
received by NCDEQ no later
than August 31 each year.
Permit
Ref.
1.6: Permit Renewal Application
Measures to submit a permit renewal application no later than 180 days prior to the expiration date of the
NPDES MS4 permit.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
2. Permit Renewal Application
Audit stormwater program
implementation for compliance
with the permit and approved
SWMP, and utilize the results
to prepare and submit a permit
renewal application package.
1. Participate in an
NPDES MS4 Permit
Compliance Audit, as
scheduled and performed
by EPA or NCDEQ.
1. Year 4 1. N/A
2. Self-audit and
document any
stormwater program
components not audited
by EPA or NCDEQ
utilizing the DEQ Audit
Template.
2. Year 5 2. Submit Self-Audit to
DEMLR (required
component of permit
renewal application
package).
3. Certify and submit the
stormwater permit
renewal application
(NOI, Self-Audit, and
Draft SWMP for the next
5-year permit cycle).
3. Year 5 3. Permit renewal
application package received
by DEQ at least 180 days
prior to permit expiration.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 13
Table 11: Program Administration BMPs
Permit
Ref.
2.1.1: Adequate Funding and Staffing
The permittee shall maintain adequate funding and staffing to implement and manage the provisions of the
SWMP and meet all requirements of this permit
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
3. Adequate funding
Perform a fiscal analysis
and explore options to
obtain adequate program
funding to fully fund the
stormwater program and
meet all requirements of
the permit. Select and
implement a funding
strategy for the Phase II
Stormwater Program.
1. Complete a fiscal gap
analysis
1. Year 1 1. Report monetary value of
gap
2. Determine available
funding mechanisms and
evaluate options
2. Year 1 2. Completed? –
yes/no/status
3. Select a funding
mechanism
3. Year 1-2 3. Report funding
mechanism selected
4.Implement funding
mechanism
4. Year 2 4. Implemented? –
yes/no/status
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 14
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 systems, urbanization, schools
Fecal coliform Sewer overflows, failing septic systems, wildlife, illicit discharges
Mercury/statewide Atmospheric deposition
Illicit discharges Residential, businesses, municipal staff
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 15
Table 13: Public Education and Outreach BMPs
Permit
Ref.
3.2.2 and 3.2.4: Outreach to Targeted Audiences
Measures to identify the specific elements and implementation of a Public Education and Outreach Program 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 locally or through a cooperative agreement.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
4. Partnership with CFCOG
The Town of Navassa will
partner with the Cape Fear
Council of Governments
(CFCOG) to more efficiently
implement education and
outreach activities.
1. Establish partnership
with CFCOG and/or
contract specific duties
1. Year 2 1. Report date established
and terms of legal agreement
2. Submit a partnership plan
detailing specific
commitments of the
CFCOG partnership to NC
DEQ for approval
2. Year 2 2. Report date plan is
approved and include as
enforceable amendment
to SWMP
3. Monitor CFCOG
activities to ensure
partnership commitments
are met
3. Annually,
following
establishment of
partnership
3. Yes/no/status
5.
Partner with Cape Fear River Watch
The Town will develop a
“Creek Week” program for
grade school youth lessons
during the summer related to
the local ecosystems in
which the SCMs discharge
into.
1. Open the dialogue with
Cape Fear River Watch.
1. Year 1 1. Is the partner willing to
participate? Yes/no/status
2. Develop a reoccurring
Creek Week program that
facilitates and encourages
the youth to learn about
local waterways and how
stormwater management
works.
2. Year 2 2. Is the program
developed? Yes/no/status
3. Document Creek Week
campaign event attendance
and report the number of
participants to the public
and elected officials at
Town Hall meetings and
other Town sponsored
events.
3. Years 3-5
3. Number of participants?
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 16
6. Social Media Campaign
The Town’s existing
Instagram account has been
used to reach the residential
target audience and share
information related to
stormwater issues, with a
minimum of one post per
year
1. Post about keeping
yard waste and litter out
of storm drains
1. Year 1 1. Report the date of the
post
2. Post about reducing
fertilizer runoff
2. Year 1 2. Report the date of the
post
3. Post about developing the
Stormwater Wetland and
Bioretention Master Plan
3. Year 2 3. Report the date of the
post
4. Post about greenway
projects that abut receiving
surface waters
4. Year 3 4. Report the date of the
post
5. Post about shared
experiences on the
greenways or surface waters
5. Year 4-5 5. Report the date of the
post
Permit
Ref.
2.1.7, 3.2.3 and 3.6.5(c): Establish Web Site
Measures to provide a web site designed to convey the program’s message(s) and provide online materials
including ordinances, or other regulatory mechanisms, or a list identifying the ordinances or other regulatory
mechanisms, 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
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
7. Develop a Stormwater Page on Town Website
Many excellent websites
have already been created by
other 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.
1. Promote and maintain an
internet web site. Examples
include, but are not limited
to: post newsletter articles
on stormwater, information
on water quality,
stormwater projects and
activities, and ways to
contact stormwater
management program staff.
1. Year 1 1. Is the website page
functional? Yes/no/status
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 17
Permit
Ref.
2.1.7, 3.2.3 and 3.6.5(c): Maintain Web Site
Measures to maintain a web site designed to convey the program’s message(s) and provide updated online
materials including ordinances, or other regulatory mechanisms, or a list identifying the ordinances or other
regulatory mechanisms, 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
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
8. Maintain a Stormwater Page on Town Website
Once the Town’s
Stormwater Management
page is active, Staff will
work to periodically update
the webpage to notify
citizens and business owners
of any changes to the
program or new ways in
which they will manage their
properties or further protect
the Town-wide system.
1. Maintain an internet web
site. Examples include, but
are not limited to: quarterly
newsletter articles on
stormwater, information on
water quality, stormwater
projects and activities, and
ways to contact stormwater
management program staff.
1. Year 2-5 1. Has the website page been
updated? Yes/no/status
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 18
Permit
Ref.
3.2.5: Stormwater Hotline
Measures for a stormwater hotline/helpline for the purpose of public education and outreach.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
9. Establish a stormwater hotline / helpline
This BMP requires that the
Town establish and publicize
a new hotline that will allow
residents to call Town Hall
to discuss stormwater
problems and issues.
1. Establish and maintain a
stormwater hotline /
helpline.
1. Year 1 1. Was the hotline
established? Yes/No/Patial
2. Establish and train a
responsible party to answer
stormwater reporting
mechanisms
2. Year 1 2. Report the date of
training, and the dates any
additional staff are trained
3. Train responsible parties
in general stormwater
knowledge, appropriate
contacts for stormwater
questions, and citizen
opportunities within the
stormwater program
3. Year 1 3. Report the date of training
and the dates any additional
staff are trained
4. Publicize hotline in
materials developed for
the stormwater program
and posting on
stormwater web page
4. Year 1 4. Yes/no/status
5. Establish a tracking
mechanism to document
the number and type of
calls received
5. Year 1 5. Was the tracking
mechanism established?
Yes/no/Partial
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 19
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
Ref.
3.3.1: Public Input
Mechanisms for public involvement that provide for input on stormwater issues and the stormwater program.
BMP
No.
A B C D
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
Town meeting to allow public
comment on the stormwater plan.
1. Conduct at least one
public meeting to
allow the public to
provide input and
comments on the
Town’s stormwater
plan.
1. Year 1
1. Yes/no/status
11. Stormwater Page on Town Website
Many excellent websites have
already been created by other
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)..
1. See BMP No. 7
1. See BMP No.
7
1. See BMP No. 7
12. Stormwater Hotline
A hotline will be maintained for
citizens to ask stormwater
questions and report stormwater
issues (See BMP No. 9).
1. See BMP No. 9
1. See BMP No.
9
1. See BMP No. 9
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 20
Permit
Ref.
3.3.2: Volunteer Opportunities
Measures to provide volunteer opportunities designed to promote ongoing citizen participation.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
13. Organize a volunteer community involvement program
Organize and implement a
volunteer stormwater related
program designed to promote
ongoing citizen participation.
1. Continue Adopt-A-
Street Program.
1. Annually Year
1-5
1. Was a volunteer event
held? Yes/No/Partial and
number of adoptions.
2. Litter sweeps in
conjunction with
NCDOT.
2. Biannually
Years 1-5
2. Yes/No/Partial and
number of participants or
bags collected.
14. Partner with Cape Fear Council of Governments
The Town of Navassa will partner
with the Cape Fear Council of
Governments (CFCOG) to more
efficiently implement education
and outreach activities.
1. See BMP No. 4
1. See BMP No.
4
1. See BMP No. 4
15. Partner with Cape Fear River Watch
The Town will develop a “Creek
Week” program for grade school
youth lessons during the summer
related to the local ecosystems in
which the SCMs discharge into.
1. See BMP No. 5
1. See BMP No.
5
1. See BMP No. 5
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 21
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
Ref.
3.4.1: MS4 Map
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
No.
A B C D
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
developing a system for
identifying and eliminating
illicit discharges into the
storm sewer system and local
streams. This base map will
serve as an important tool as
the Town begins its program
to detect and eliminate illicit
discharges in the third year of
the permit.
1. Map outfall locations
and stormwater drainage
system components. At a
minimum, components
include major outfalls,
receiving streams,
conveyances, and flow
direction.
1. Year 2
1. Yes/No/Partial
Permit
Ref.
3.4.1: MS4 Map
Maintain a municipal storm sewer system map including stormwater conveyances, flow direction, major
outfalls and waters of the United States receiving stormwater discharges.
BMP
No.
A B C D
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-
built information.
1. Continuasly 1. Year 3-5
1. Yes/No/Partial
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 22
18. Develop and implement an illicit discharge detection and elimination program.
This BMP will require that
the Town develop its own
program for detecting and
eliminating illicit discharges
into the MS4. Because of
limited staff availability for
this requirement it is
recommended that the Town
contract with an outside firm,
such as an environmental
engineering firm or perhaps
the City of Wilmington, to
conduct periodic inspections
and respond to complaints
forwarded to it by the Town
when an illicit discharge is
detected.
1. Develop and implement
an illicit discharge
detection and elimination
program including
provisions for program
assessment and evaluation.
1. Year 3 1. The Town will contract
with an outside firm to
provide this service and the
Town’s consulting engineer
will be able to assist with
finding a qualified
contractor. The Town’
attorney will research other
local ordinances to develop
an illicit discharge ordinance
for the Town.
2. Establish written
procedures for detecting
and tracing the sources of
illicit discharges and for
removing the sources.
Establish written
procedures for
identification of priority
areas likely to have illicit
discharges.
2. Year 3
2. This BMP will be tied in
with the requirement to
establish an illicit discharge
detection and elimination
program.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 23
Permit
Ref.
3.4.2: Regulatory Mechanism
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
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
19. Maintain Legal Authority
Review existing ordinance
(Phase II Stormwater
Ordinances, Article VII. Illicit
Discharges) in order to
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.
1. Review ordinance and
update if revision is
required to maintain
legal authority
1. Year 1
1. Report if a revision is
required and if a revision
is made
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
20. Establish and maintain appropriate legal authorities
This requirement ties in with
the previous BMP.
Essentially, the Town must
adopt ordinances to prohibit
the illicit discharge of
pollutants into the MS4.
1. Establish and maintain
adequate ordinances or
other legal authorities to
prohibit illicit discharges
and enforce the approved
illicit discharge detection
and elimination program.
1. Year 3 1. Many municipalities in
North Carolina have
ordinances like this in place
that will be modified for the
Town’s needs.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 24
Permit
Ref.
3.4.3: IDDE Plan
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
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
21. Outfall Inspections
Perform regular dry weather
(72 hours) outfall inspections
to proactively identify
illicit discharges and illicit
connections
1. Train inspections staff
to perform dry weather
outfall inspections and
illicit discharge
investigations
1. Year 1 1. Yes/No/Partial
2. Split major outfalls
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
2. Year 2
2. Yes/no/status
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 25
22. Illicit Discharge Identification Procedure
Revise and maintain a
standard operating procedure
(SOP) for investigation of
potential illicit discharges,
illicit connections, and illegal
dumping.
1. Develop a SOP for
investigating potential
illicit discharges and
connections
1. Year 1 1. Completed? -
yes/no/status
2. Implement IDDE SOP 2. Years 2-5
2. Yes/no/status
23. IDDE Program Evaluation
Yearly evaluation of IDDE
program to promote
continuance of effective
components and improvement
in areas that are lacking, as
well as, identification of
potential “hot-spot” areas.
1. Evaluation meeting with
IDDE program supervisor
and identify repeat
violations and/or areas of
concern
1. Annual
1. Yes/no/status
Permit
Ref.
3.4.4: IDDE Tracking
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
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
24. Tracking System
A tracking system for
observed IDDE violations and
follow-on actions will be
developed and implemented
in order to identify “hot-spot”
areas, chronic violators, and
recurring issues.
1. Develop a “Potential
Illicit Discharge Report”
form to include observed
illicit discharge indicators,
date, location, and contacts
made
1. Year 1 1. Yes/no/status
2. Develop a tracking
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
2. Year 1
2. Yes/no/status
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 26
Permit
Ref.
3.4.5: Staff IDDE Training
Measures to provide training for municipal staff and contractors who, 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
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
25. Staff training
This requires that Town
employees whose normal
duties place them in situations
where they will come across
illicit discharges of pollutants
into the MS4 be trained to
recognize and report them.
1. Conduct training for
appropriate municipal staff
on detecting and reporting
illicit discharges. Annual
onboarding training for any
relevant new staff and
annual refresher training.
1. Annual
2. Years 1-5
1. Yes/No/Partial
2. Number of staff trained
3. See BMP No. 8
Permit
Ref.
3.4.6: IDDE Reporting
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
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
26. Stormwater Page on City Website
Many excellent websites have
already been created by other
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).
1. See BMP No. 7
1. See BMP No.
7
1. See BMP No. 7
27.
Stormwater Hotline
A hotline will be maintained
for citizens to ask stormwater
questions and report
stormwater issues (See BMP
No. 8).
1. See BMP No. 8
1. See BMP No.
8
1. See BMP No. 8
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 27
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 NCG010000 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
Reference State or Local Program Name Legal
Authority Implementing Entity
Meets Whole
or Part of
Requirement
3.5.1 -
3.5.4
State Implemented SPCA Program 15A NCAC
Chapter 04
NCDEQ Whole
The Town of Navassa also implements the following BMPs to meet NPDES MS4 Permit requirements.
Table 17: Construction Site Runoff Control BMPs
Permit
Ref.
3.5.6: Public Input
Measures to provide and promote a means for the public to notify the appropriate authorities of observed
erosion and sedimentation problems.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
28. Municipal Staff Training
Train municipal staff who
receives calls from the public on
the protocols for referral and
tracking of construction site
runoff control complaints.
1. Train municipal
staff on proper
handling of
construction site runoff
control complaints.
1. Annually beginning
in Permit Year 1
1. Document and
report number of staff
trained, training
date(s) and topics
covered.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 28
Permit
Ref.
3.5.5: Waste Management
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
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
29. Maintain Legal Authority
Enforce construction site waste
management requirements via
Article V. – Enforcement and
Violations to control waste
1. Year 1
1. Annually Year 1-5 1. Yes/no/Partial
2. Provide construction
site operators with
educational
information on waste
management
requirements.
2. Year 2 2. Yes/No/Partial
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 29
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 30
Table 19: Summary of Existing Post-Construction Program Elements
Permit Requirements for
Plan Review and Approval
Municipal Ordinance/Code Reference(s)
and/or Document Title(s)
Date Adopted
3.6.2(a) Authority Town of Navassa Phase II Stormwater
Ordinance – Article 1-2
12-16-2010
3.6.3(a) & 15A NCAC 02H.0153(c)
Federal, State & Local Projects
Town of Navassa Phase II Stormwater
Ordinance – Article 1-5
12-16-2010
3.6.3(b) Plan Review Town of Navassa Phase II Stormwater
Ordinance – Article 1-22
12-16-2010
3.6.3(c) O&M Agreement Town of Navassa Phase II Stormwater
Ordinance – Article 1-55
12-16-2010
3.6.3(d) O&M Plan Town of Navassa Phase II Stormwater
Ordinance – Article 1-21(A)(2)(c), Sec. 1-55,
and 1-72
12-16-2010
3.6.3(e) Deed
Restrictions/Covenants
Town of Navassa Phase II Stormwater
Ordinance – Article 1-58
12-16-2010
3.6.3(f) Access Easements Town of Navassa Phase II Stormwater
Ordinance – Article 1-61
12-16-2010
Permit Requirements for
Inspections and Enforcement
Municipal Ordinance/Code Reference(s)
and/or Document Title(s)
Date Adopted
3.6.2(b) Documentation Town of Navassa Phase II Stormwater
Ordinance – Article 1-59
12-16-2010
3.6.2(c) Right of Entry Town of Navassa Phase II Stormwater
Ordinance – Article 1-55
12-16-2010
3.6.4(a) Pre-CO Inspections Town of Navassa Phase II Stormwater
Ordinance – Article 1-23 d
12-16-2010
3.6.4(b) Compliance with Plans Town of Navassa Phase II Stormwater
Ordinance – Article 1-23 c
12-16-2010
3.6.4(c) Annual SCM Inspections Town of Navassa Phase II Stormwater
Ordinance – Article 1-54 b
12-16-2010
3.6.4(d) Low Density Inspections Town of Navassa Phase II Stormwater
Ordinance – Article 1-37
12-16-2010
3.6.4(e) Qualified Professional Town of Navassa Phase II Stormwater
Ordinance – Article 1-54 b
12-16-2010
Permit Requirements for
Fecal Coliform Reduction
Municipal Ordinance/Code Reference(s)
and/or Document Title(s)
Date Adopted
3.6.6(a) Pet Waste Town of Navassa Phase II Stormwater
Ordinance – Article 1-43
12-16-2010
3.6.6(b) On-Site Domestic
Wastewater Treatment
Brunswick County Environmental Health
Application, Evaluation, and Permitting
Procedures For Septic Systems and Well
Construction – 5.3.8.10.ii
3-16-2015
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 31
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
Ref.
3.6.5(a), 3.6.5(b), and 4.1.3: Minimum Post-Construction Reporting Requirements
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
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
30. Standard Reporting
Implement standardized
tracking, documentation,
inspections and reporting
mechanisms to compile
appropriate data for the annual
self-assessment process. Data
shall be provided for each
Post-Construction/ Qualifying
Alternative Program being
implemented as listed in
Tables 18 and 19.
1. Track number of low
density and high density
plan reviews performed.
1. Continuously 1. Number of plan reviews
performed for low density
and high density.
2. Track number of low
density and high density
plans approved.
2. Continuously 2. Number of plan approvals
issued for low density and
high density.
3. Maintain a current
inventory of low density
projects and constructed
SCMs including SCM
type or low density
acreage, location and last
inspection date.
3. Continuously 3. Summary of number and
type of SCMs added to the
inventory; and number and
acreage of low density
projects constructed.
4. Track number of SCM
inspections performed.
4. Continuously 4. Number of SCM
inspections.
5. Track number of low
density inspections
performed.
5. Continuously 5. Number of low density
inspections.
6. Track number and type
of enforcement actions
taken.
6. Continuously 6. Number and type of
enforcement actions taken.
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 32
Permit
Ref.
3.6.2: Legal Authority
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
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
31. Impose or require deed restrictions and protective covenants for BMP maintenance
The ordinance will contain
language that requires the
property owners to comply
with the permit that is issued
by the Town at the time of
development and maintain the
structural and nonstructural
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.
1. Impose or require
recorded deed restrictions
and protective covenants
that ensure development
activities will maintain
the project consistent with
approved plans.
1. Year 2 1. Yes/No/Partial
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 33
Permit
Ref.
3.6.3: Plan Review and Approval
Measures to maintain plan review and approval authority, standards and procedures to: (a) Require Federal,
State, and local government projects 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
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
32. Revisions to Code of Ordinances
Revise existing ordinance to
specifically require compliance
by Federal, State, and Local
government projects and revise
reference to stormwater design
manual to specify NCDEQ
Stormwater Design manual.
1. Revise code to require
Federal, State, and local
government projects to
comply with post
construction requirements
unless subject to its own
NPDES MS4 permit or
qualifying alternative
program
1. Year 2 1. Report code reference and
date adopted
2. Revise code to specify
NCDEQ Stormwater
Design Manual as the
reference stormwater
design manual
2. Year 2 2. Report code reference and
date adopted
33. O&M Plan
Enforce Sec. 1-21(A)(c), Sec.
1-55, and 1-72 in the
Ordinance to the Town code
requiring each stormwater
control measure to have an
Operation and
Maintenance Plan that
complies with 15A NCAC
02H .1050(13)
1. Maintain legal
authority through code
enforcement
1. Year 1 1. Yes/No/Partial
2. Enforce code by
requiring approval of
O&M Plan by Stormwater
Administrator prior to
plan approval
2. Continuously 2. Number of O&M plans
approved
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 34
Permit
Ref.
3.6.4: Inspections and Enforcement
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 by a qualified professional.
BMP
No. A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
34. Conduct post-construction inspections and ensure compliance with routine inspections.
Maintain inspection and
enforcement authority by
conducting post-construction
inspections, hold projects to
construction standards in
accordance with the approved
plan, ensure annual
inspections, inspect low
density projects at least once
during the permit term, and
require that inspections be
conducted by a qualified
professional.
1. Conduct post-
construction inspections
prior to issuing a
Certificate of Occupancy
or a Temporary
Certificate of Occupancy
1. Continuously 1. Yes/No/Partial
2. Ensure that the project
has been constructed in
accordance with the
approved plan(s).
2. Continuously 2. Yes/No/Partial
3. Ensure annual
inspection of each
permitted SCM to ensure
compliance with the
approved Operation and
Maintenance Agreement,.
3. Continuously 3. Yes/No/Partial
4. Ensure inspection of
low density projects at
least once during the
permit term.
4. Continuously 4. Yes/No/Partial
5. Require that
inspections be conducted
by a qualified
professional.
5. Continuously 5. Yes/No/Partial
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 35
Permit
Ref.
3.6.6: Fecal Coliform Reduction
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
No.
A B C D
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
Town identify all existing on-
site wastewater treatment
systems (septic systems)
within its jurisdiction and
establish a program for
controlling discharges of fecal
coliform bacteria from them.
This will be carried out in
conjunction with the
requirement to eliminate
failing septic systems. (See
BMP No. 15)
1. Identify/Map septic
system locations within
the Navassa jurisdictional
area.
1. Year 2 1. The County Health
Department will assist
the Town with this
effort.
2. Collect inspection
reports from Brunswick
County.
2. Annually 2. Yes/No/Partial
3. Require pet waste
management.
3. Continuously 3. Yes/No/Partial
36 Establish procedures to identify and eliminate failing septic systems and report sanitary sewer overflows.
The Town will provide a
resource to let
homeowners report
failing septic systems to
the County, which will
then relay the location
and nature of the problem
to the Health Department.
The Town will also
explore establishing a
program with the County
to assist homeowners
with the cost of tying in
to the sewer system if
their septic system is
failing.
1. Establish procedures to
identify and report to the
County Health Department
failed septic systems located
within the permittee’s planning
jurisdiction.
1. Year 2
1. Yes/No/Partial
2. Establish procedures to
identify and report sanitary
sewer overflows and sewer
leaks to the system operator.
2. Year 2 2. Yes/No/Partial
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 36
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
Ref.
3.7.1: Municipal Facilities Operation and Maintenance Program
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 inspections and routine maintenance; establish specific frequencies, schedules, and standard
documentation; provide staff training on general stormwater awareness and implementing pollution prevention
and good housekeeping practices.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
37. Conduct staff training
Provide training to its staff on
pollution prevention
measures. All employees that
deal with hazardous materials
or who have duties that
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.
1. Conduct staff training
annually and as new staff
are onboarded for pollution
prevention and good
housekeeping procedures.
1. Annually 1. Yes/No/Partial
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 37
38. Prevent or minimize contamination of stormwater runoff from all areas used for facilities, vehicle or
equipment cleaning
Any washing or cleaning of
Town facilities, equipment, or
vehicles conducted on Town
property will be conducted in
a manner that does not impact
water quality. All Town
equipment and vehicles must
be washed or cleaned either
indoors, on grass or gravel
areas outdoors, or at a
washing facility that collects
wash water and discharges it
into a sanitary sewer system.
1. Identify/Inventory all
municipal facilities that
need a SPPP and/or
SPCC Plan.
1. Year 2 1. Yes/No/Partial
2. Map and record all
areas dedicated for
vehicle or equipment
cleaning.
2. Year 2 2. Yes/No/Partial
3. Develop a standard
inspection form and
tracking mechanism.
3. Year 2 3. Yes/No/Partial
Permit
Ref.
3.7.2: Spill Response Program
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 response procedures.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
39. Spill response procedures
This requires that the Town
inventory the type and
location of all potential
pollutants that will
accidentally enter the
stormwater system.
1. Establish spill
response procedures for
municipal operations
owned and operated by
the permittee with the
potential to generate
polluted stormwater
runoff.
1. Year 1 1. Yes/No/Partial
2. Develop a standard
inspection form and
tracking mechanism.
2. Year 2 2. Yes/No/Partial
3. Facilities that need a
SPPP and/or SPCC Plan
will be inspected
annually using a
standard form and
tracking mechanism.
3. Annually 3. Yes/No/Partial
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 38
Permit
Ref.
3.7.3: MS4 Operation and Maintenance Program
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 including catch basins and conveyances; and establish specific frequencies,
schedules, and standard documentation.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
40. Operations and Management Plan
A proactive plan for MS4
system maintenance,
requiring regular inspections
and maintenance.
1. Develop a written SOP
that includes proactive,
inspection schedules,
standard documentation,
staff responsibilities, and
proper maintenance
training.
1. Year 1 1. Yes/no/ Partial
2. Incorporate SOP into
SWMP as an enforceable
permit requirement.
2. Year 1 2. Yes/No/Partial
3. Implement the SOP 3. Years 2-5 3. Yes/No/Partial
Permit
Ref.
3.7.4: Municipal SCM Operation and Maintenance Program
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
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
41. Inventory of Municipal structural SCMs
Development and
maintenance of a current
inventory of municipally
owned structural SCMs.
1. Create an inventory of
existing Town-owned
SCMs with information
including type, year built,
date of last
inspection, and
maintenance actions
1. Year 2 1. Number of municipal
structural SCMs
2. Compile, and develop
as needed, Operation and
Maintenance Plans for all
Town-owned SCMs
2. Year 3 2. Yes/no/status
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 39
42. SCM Inspections and Maintenance
Performance and
documentation of regular
inspection and maintenance
of municipally owned
structural SCMs. Addition of
municipally owned SCMs to
MS4 map.
1. Locate Town-owned
SCMs and add them to
the MS4 Map with type
of SCM indicated
1. Year 2 1. Report the number and
type of SCMs added to
the map
2. Update the map when
new Town-owned SCMs
are constructed
2. Annually 2. Note annually whether
new Town-owned SCMs
were added.
3. Maintain NC SCM
Inspections and
Maintenance
Certification for
appropriate personnel
3. Continuously;
beginning Year 1
3. Number of staff
members with active
certification
4. Develop SCM
inspection form
4. Year 2 4. Yes/no/status
5. Inspect each device
using SCM inspection
form
5. Annually,
beginning Year 3
5. Number of SCMs
inspected, number
passing inspection,
number requiring
maintenance
Permit
Ref.
3.7.5: Pesticide, Herbicide and Fertilizer Management Program
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
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation Annual Reporting Metric
43. Pesticide, Herbicide, Fertilizer Applicator Training
Training of Town staff who
apply landscape chemicals in
order to minimize water
quality impacts from
pesticides, herbicides, and
fertilizers.
1. Obtain and maintain
Right-of Way Pest Control,
Public Health Control, and
Ornamental & Turf Pest
Control applicator
certifications for
appropriate personnel
1. Continuously 1. Yes/no/status
2. Number of certified staff
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 40
Permit
Ref.
3.7.6: Vehicle and Equipment Maintenance Program
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
No.
A B C D
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
general facility inspections to
ensure that vehicle and
equipment facilities are
following proper procedures
to minimize water quality
impacts from vehicle and
equipment cleaning and
maintenance.
1. Develop an inspections
checklist
1. Year 2 1. Yes/no/status
2. Perform inspections
using inspection checklist
and notify facility manager
of any corrective actions
required
2. Annually
beginning in
Year 3
2. Number of inspections
45. Staff Training
Provide general stormwater
awareness training and
pollution prevention training
to employees working in
vehicle maintenance and
cleaning areas (See BMP No.
37).
1. See BMP No. 37 1. See BMP No.
37
1. See BMP No. 37
DRAFT NCS000518 SWMP
Town of Navassa
March 3, 2021
Page 41
Permit
Ref.
3.7.7: Pavement Management Program
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.
BMP
No.
A B C D
Description of BMP Measurable Goal(s)
Schedule for
Implementatio
n
Annual Reporting Metric
46. Leaf Collection
Periodic collection of leaves
from residential and public
areas to reduce pollutants and
clogging of storm system
inlets.
1. Develop a written SOP
that includes proactive,
inspection schedules,
standard documentation,
staff responsibilities, and
proper maintenance
training.
1. Year 1 1. Yes/no/ Partial
2. Incorporate SOP into
SWMP as an enforceable
permit requirement.
2. Year 1 2. Yes/No/Partial
3. Implement the SOP 3. Years 2-5 3. Yes/No/Partial
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