Loading...
HomeMy WebLinkAboutNCS000518_Navassa Draft SWMP v3 Comments_20210602 STORMWATER MANAGEMENT PLAN TOWN OF NAVASSA March 3, 2021 | NCS000518 This Page is Intentionally Left Blank 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 FINAL 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. Any major changes to the approved SWMP will require resubmittal, review and approval by NCDEQ, and may require a new public comment period depending on the nature of the changes. DRAFT FINAL 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 June 20____. DRAFT FINAL 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 FINAL 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 drainpipes, 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 Current 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 FINAL 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. The MS4 does/does not interconnect with the statewide NCDOT MS4 and includes: a. The interconnection is/is not receiving stormwater from the NCDOT MS4. The number of interconnections is known/estimated/unknown. Quantity: ## or N/A b. The interconnection is/is not discharging stormwater into the NCDOT MS4. The number of interconnections is known/estimated/unknown. Quantity: ## or N/A c. The MS4name MS4 mapping does/does not identify interconnections with the NCDOT MS4. d. The MS4name MS4 mapping does/does not include NCDOT MS4 outfalls. DRAFT FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 7 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. Based upon 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, the species listed in Table 4 have the potential to occur within the regulated MS4 urbanized area. 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: PotentialFederally 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 Maps & Permit Data web page. 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 FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 8 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 FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 9 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 FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 10 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 FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 11 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 FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 12 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 may 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 FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 13 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. Yes/No 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. Yes/No 2. Self-audit and document any stormwater program components not audited by EPA or NCDEQ utilizing the DEQ Audit Template. Submit Self- Audit to DEMLR (required component of permit renewal application package). 2. Year 5 2. Yes/No/Partial Table 11: Program Administration BMPs 3. Certify the stormwater permit renewal application (Permit renewal application form, Self-Audit, and Draft SWMP for the next 5-year permit cycle) and submit to NCDEQ at least 180 days prior to permit expiration. 3. Year 5 3. Date of permit renewal application submittal DRAFT FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 15 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 FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 16 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 can 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 Litter General Public 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 FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 17 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 can 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. Yes/No/Status 2. Submit a partnership plan detailing specific commitments of the CFCOG partnership to NC DEQ for review and approval. The plan will include education on litter, pollution prevention, and reporting water quality issues to the Town. 2. Year 2 2. Yes/No/Status Date submitted 3. Implement CFCOG partnership plan 3. Annually, following establishment of partnership plan 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 Table 13: Public Education and Outreach BMPs 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 FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 19 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 FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 20 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 web 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 Topics covered DRAFT FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 21 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/Partial 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 number 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 FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 22 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 FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 23 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 FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 24 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. Update MS4 Map Update MS4 map with as- built information as the collection system is surveyed and/or expands 1. Update MS4 map with as-built information. 1. Continuously Year 3-5 1. Yes/No/Partial DRAFT FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 25 18. Develop and implement an illicit discharge detection and elimination program. The Town will 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. The Town can contract with an outside firm to provide this service and the Town’s consulting engineer may be able to assist with finding a qualified contractor. The Town’ attorney can research other local ordinances to develop an illicit discharge ordinance for the Town.. 1. Develop and implement an illicit discharge detection and elimination program including provisions for program assessment and evaluation. 1. Year 3 1. Yes/No/Status 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. Yes/No/Status DRAFT FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 26 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 Yes/No/Status 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. Many municipalities in North Carolina have ordinances like this in place that will be modified for the Town’s needs. 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. Yes/No/Status DRAFT FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 27 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; Inspect one group per year, with all major outfalls inspected over a five-year period 2. Year 2 2. Yes/No/Status DRAFT FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 28 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 FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 29 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, may 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 may 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 Years 1-5 1. Yes/No/Partial Number of staff trained See BMP No. 9 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. IDDE Reporting Via Stormwater Page Establish a link on the Stormwater web page for citizens to report illicit discharges, illegal dumping and spills. 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. Establish a link on the Stormwater web page for citizens to report illicit discharges, illegal dumping and spills. 1. Year 1 1. Yes/No/Partial 27. 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 FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 31 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 as a qualifying alternative program to meet a portion of the NPDES MS4 Permit requirements for construction site runoff control measures. The SPCA requirements include reducing pollutants in stormwater runoff from construction activities that result in land disturbance of greater than or equal to one acre, and includes any construction activity that is part of a larger common plan of development that would disturb one acre or more. The state SPCA Program is either delegated to a city/town, delegated to a county, or implemented by NCDEQ in non- delegated areas. 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 Permit Years 1-5 1Yes/No/Status. Number of staff trained. DRAFT FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 32 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 may 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. Implement standard enforcement protocols for construction waste management violations. 1. Continuously Year 2-5 1. Yes/No/Status Number of violations 2. Provide construction site operators with educational information on waste management requirements. 2. Continuously Year 1-5 2. Yes/No/Partial DRAFT FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 33 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 FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 34 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 FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 35 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 Permit Years 1-5 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 Permit Years 1-5 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 Permit Years 1-5 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 Permit Years 1-5 4. Number of SCM inspections. 5. Track number of low density inspections performed. 5. Continuously Permit Years 1-5 5. Number of low density projects inspected. 6. Track number and type of enforcement actions taken. 6. Continuously Permit Years 1-5 6. Number of enforcement actions taken. DRAFT FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 36 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. 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/Status DRAFT FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 37 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 project approval 2. Continuously 2. Number of O&M plans approved DRAFT FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 38 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 Number of inspections 2. Ensure that the project has been constructed in accordance with the approved plan(s). 2. Continuously 2. Yes/No/Partial 3. Inspect each permitted SCM to ensure compliance with the approved Operation and Maintenance Agreement,. 3. Annually 3. Yes/No/Partial Number of inspections 4. Inspect each low density project at least once during the permit term. 4. Continuously 4. Yes/No/Partial Number of inspections DRAFT FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 39 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 may be achieved by revising an existing litter ordinance, and (b) An on-site domestic wastewater treatment system component, if applicable, which may 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. The Town will work with the County Health Department to complete this effort. 1. Identify and map septic system locations within the Navassa jurisdictional area. 1. Year 2 1. Yes/No/Status Number of mapped septic systems 2. Collect septic system inspection reports from Brunswick County. 2. Annually 2. Yes/No/Partial Number of County septic inspection reports received 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 3. Evaluate feasibility of 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. 3. Year 3 3. Yes/No/Status DRAFT FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 41 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 Town 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. 1. Conduct staff training annually and as new staff are onboarded for pollution prevention and good housekeeping procedures, including spill response procedures. 1. Annually Year 2-5 1. Yes/No/Partial Number trained DRAFT FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 42 38. Municipal Facility Inventory Any washing or cleaning of Town facilities, equipment, or vehicles conducted on Town property will be conducted in a manner that does not adversely 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, and evaluate whether theyhave significant stormwater pollution potential and need a SPPP and/or SPCC Plan. 1. Year 2 1. Yes/No/Partial Number of facilities inventoried 2. Map and record all areas dedicated for vehicle or equipment cleaning. 2. Year 2 2. Yes/No/Partial Number of vehicle cleaning facilities mapped 3. Develop a standard inspection form and tracking mechanism for inventoried Town facilities. . 3. Year 2 3. Yes/No/Partial 4. Inspect Town facilities that have been inventoried and determined to have significant stormwater pollution potential. 4. Annually Year 3 - 5 4. Yes/No/Partial Number of inspections 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 38. Municipal Facility Inventory Any washing or cleaning of Town facilities, equipment, or vehicles conducted on Town property will be conducted in a manner that does not adversely 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, and evaluate whether theyhave significant stormwater pollution potential and need a SPPP and/or SPCC Plan. 1. Year 2 1. Yes/No/Partial Number of facilities inventoried 2. Map and record all areas dedicated for vehicle or equipment cleaning. 2. Year 2 2. Yes/No/Partial Number of vehicle cleaning facilities mapped 3. Develop a standard inspection form and tracking mechanism for inventoried Town facilities. . 3. Year 2 3. Yes/No/Partial 4. Inspect Town facilities that have been inventoried and determined to have significant stormwater pollution potential. 4. Annually Year 3 - 5 4. Yes/No/Partial Number of inspections Provide appropriate spill response procedures and training for staff at Town facilities that have significant spill potential. 1. Establish spill response procedures for municipal operations owned and operated by the permittee that have significant spill potential. 2. See also BMP 37.B.1. 1. Year 2 1. Yes/No/Partial Number of facilities requiring spill procedures This requires that the Town inventory the type and location of all potential pollutants that may 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 38. Municipal Facility Inventory Any washing or cleaning of Town facilities, equipment, or vehicles conducted on Town property will be conducted in a manner that does not adversely 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, and evaluate whether theyhave significant stormwater pollution potential and need a SPPP and/or SPCC Plan. 1. Year 2 1. Yes/No/Partial Number of facilities inventoried 2. Map and record all areas dedicated for vehicle or equipment cleaning. 2. Year 2 2. Yes/No/Partial Number of vehicle cleaning facilities mapped 3. Develop a standard inspection form and tracking mechanism for inventoried Town facilities. . 3. Year 2 3. Yes/No/Partial 4. Inspect Town facilities that have been inventoried and determined to have significant stormwater pollution potential. 4. Annually Year 3 - 5 4. Yes/No/Partial Number of inspections 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 FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 45 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, maintenance requirements and proper maintenance training. 1. Year 1 1. Yes/No/ Partial 2. Submit O&M SOP to DEQ for review and approval. 2. Year 1 2. Yes/No/Status Date submitted I 3. Implement the SOP 3. Years 2-5 3. Yes/No/Partial 4. See BMP 37 3. See BMP 37 3. See BMP 37 Permit Ref. 3.7.4: Municipal SCM Operation and Maintenance Program Measures to manage municipally-owned, operated, and/or maintained structural stormwater control measures (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. Yes/No/Partial Number of municipal structural SCMs 2. Compile, and develop as needed, Operation and Maintenance Plans for each Town-owned SCM 2. Year 3 2. Yes/No/Status 3. Locate Town-owned SCMs and add them to the MS4 Map with type of SCM indicated 3. Year 2 3. Yes/No/Partial Number and type of SCMs added to the map 4. Update the map when new Town-owned SCMs are constructed 4. Continuously Year 2-5 4. Yes/No/Partial Number of Town-owned SCMs added DRAFT FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 47 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. Maintain NC SCM Inspections and Maintenance Certification for appropriate personnel 1. Continuously; beginning Year 1 1. Number of staff members with active certification 2. Develop SCM inspection form 2. Year 2 2. Yes/No/Status 3. Inspect each device using SCM inspection form 3. Annually, beginning Year 3 3. 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 Number of certified staff DRAFT FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 48 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 Perform 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 FINAL NCS000518 SWMP Town of Navassa March 3, 2021 Page 49 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. Submit SOP to DEQ for review and approval. 2. Year 1 2. Date submitted 3. Implement the SOP 3. Years 2-5 3. Yes/No/Partial 47. Street Sweeping Perform periodic street sweeping of Town- owned/operated streets and parking lots 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. Submit SOP to DEQ for review and approval. 2. Year 1 2. Date submitted 3. Implement the SOP 3. Years 2-5 3. Yes/No/Partial 48 Litter Management Educate the general public on littering and it’s impacts on 1. See BMP 4 1. See BMP 4 1. See BMP 4 water quality and remove litter from public parking areas, parks, etc. that are owned/operated by the Town. 2. Remove trash and litter from Town public spaces. 2. Monthly Year 1-5 2. Yes/No/Partial This Page is Intentionally Left Blank