NCS000518_Navassa Draft SWMP v3 DEQ Comment Letter_20210604

June 4, 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 v3 (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 and provided comments on November 5, 2020. DEQ received the revised Draft SWMP v2 on
November 6, 2020 and provided comments on February 23, 2021. The required third Draft SWMP was
submitted on March 5, 2021 and comments are provided below.

Staff have reviewed the submitted Draft SWMP v3 and are providing the following specific comments
and attached mark-up of the Draft SWMP v3 in MS Word track changes mode. Please address all
comments and submit a signed Draft Final SWMP and permit renewal application to DEQ within
thirty (30) calendar days of receipt of this letter. A permit renewal application was received on March
11, 2021. However, the required signatory authority for the Draft Final SWMP and permit renewal
application lies with the Mayor or Town Manager, per state statute. Therefore, the Mayor or Town
Manager are required as the signatory on both documents unless a Designation of Signature Authority is
submitted. Upon receipt, if the comments have been adequately addressed, the Draft Final SWMP will be
sent to notice for public comments and subsequent permit issuance.

Comments

1. General comment – The items below have been provided in the Word mark-up document in track
changes mode. Staff comments appear in blue. Accepting all comments in the provided
document will create an acceptable Draft Final SWMP. If any provided comments are not
accepted, please respond in writing as to why and provide equivalent or better alternative(s).
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2. Incorporate the standard 2021 SWMP template updates, available on the MS4 web page. These
updates have been cut/pasted into the provided comment mark-up version and are denoted by
green highlighting. Remove the green highlighting prior to submittal.
3. Part 2: Change the certification signature authority to the Mayor or Town Manager or submit a
designation of signature authority for the Planning Director to sign.
4. BMP 4: Update the partnership plan language to specifically include education on litter,
pollution prevention, and reporting water quality issues to the Town and implementation of
the plan. Update reporting metrics to Yes/No/Status and date submitted.
5. BMP 8: Include topics covered as an annual reporting metric.
6. BMP 9: Include number trained as as an annual reporting metric.
7. BMP 17: Add language to update the MS4 map as the collection system is surveyed and/or
expanded.
8. BMP 18: Modify reporting metrics to Yes/No/Status and move narrative to Description of BMP.
9. BMP 20: Modify reporting metric to Yes/No/Status and move narrative to Description of BMP.
10. BMP 21: Clarify inspection of 1/5 (language provided).
11. BMP 25: Update BMP reference from 8 to 9.
12. BMP 26: Include a link on the web page for citizen reporting.
13. BMP 27: Update BMP reference from 8 to 9.
14. BMP 28: Perform training annually in permit years 1 – 5 and report number of staff trained.
15. BMP 29: Provide contractors with educational material beginning in year 1 and enforce
construction waste management requirements beginning in year 2.
16. BMP 31: Move reporting metric narrative to BMP description and report Yes/No/Status.
17. BMP 33.B.2: Change plan to project.
18. BMP 34: report number of inspections and clarifying language is provided in mark-up.
19. BMP 35: Move reporting metric narrative to BMP description and report Yes/No/Status.
20. BMP 36: Move evaluation of homeowner assistance program here.
21. BMP 37: Remove DENR training, the Town cannot commit the state to perform training.
Include spill response in training. Report number trained.
22. BMP 38: Clarify municipal inventory tasks. Language provided in mark-up. Delete the three
duplicative BMP 38’s following the initial one. Formatting prevents staff from marking this
deletion in the provided mark-up.
23. BMP 39: Delete duplicative BMP 38 entries, keep spill response procedures measurable goals 1
and 2 in blue box (see mark-up).
24. BMP 40: Submit O&M SOP to DEQ for review and approval and report submittal date. Also
reference BMP 37.
25. BMP 41: Move two items from BMP 42 to here. Add SCMs to MS4 map, see measurable goals
3 and 4 in mark-up. Report Yes/No/Partial and number of SCMs added.
26. BMP 46: Submit SOP to DEQ for review and approval, report date submitted.
27. BMP 47: Add a BMP for street sweeping to address the permit requirements to reduce pollutants
from municipal streets, roads and parking lots.
28. BMP 48: Add litter management, see mark-up for recommended language.
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The required revised Draft Final SWMP submittal must include both a pdf electronic copy and a hard
copy. The Draft Final SWMP must include an original “wet” signature by the Town’s ranking elected
official or designated staff member in compliance with Part IV, Paragraph G of the current MS4 Permit.

Please submit the required signed Draft Final SWMP 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
[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