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I can't seem to track down a normative requirement that the nav document be a conforming xhtml content document.
The closest we come is this statement near the end of the restrictions section:
As a conforming XHTML content document, EPUB creators MAY include the EPUB navigation document in the spine.
As that isn't a normative requirement, you could conceivably embed nav elements in an svg and call it a navigation document, since all we have are nav restrictions.
In Packages 3.2, we used to have this requirement:
Activity