WQ0031030_Staff Report_20210519

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

To: NPDES Unit Non-Discharge Unit Application No.: WQ0031030
Attn: Poorva Mokashi Facility name: Shawboro Elementary School
From: Will Hart
Washington Regional Office
Note: This form has been adapted from the non-discharge facility staff report to document the review of both non-
discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? Yes or No
a. Date of site visit: !!!!!
b. Site visit conducted by:
c. Inspection report attached? Yes or No
d. Person contacted: !!!!! and their contact information: ( ) !!! - ext. !!!!
e. Driving directions:

II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A
ORC: Certificate #: Backup ORC: Certificate #:
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? Yes or No
If no, please explain:
Description of existing facilities:
Proposed flow:
Current permitted flow:
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership,
etc.)
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? Yes or No
If no, please explain:
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? Yes or No
If yes, please explain:
5. Is the residuals management plan adequate? Yes or No
If no, please explain:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? Yes or No
If no, please explain:
FORM: WQROSSR 04-14 Page 1 of 3

7. Is the existing groundwater monitoring program adequate? Yes No N/A
If no, explain and recommend any changes to the groundwater monitoring program:
8.Are there any setback conflictsfor existing treatment, storage and disposal sites? Yes or No
If yes, attach a map showing conflict areas.
9. Is the description of the facilities as written in the existing permit correct? Yes or No
If no, please explain:
10. Were monitoring wells properly constructed and located? Yes No N/A
If no, please explain:
11. Has a review of all self-monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? Yes or No
Please summarize any findings resulting from this review: Facility has history of NonCompliance - Late/Missing
Reports, Missing Parameters.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
12. Are there any permit changes needed in order to address ongoing BIMS violations? Yes or No
If yes, please explain: WaRO recommends monthly monitoring in the permit instead of 4 times per year.
The facility is a Grade II facility with mechanical treatment. The operators cannot run the system when
they do not have the monitoring to tweak the system in order to meet limits. The facility has had seven
NOVs over the past two years because the school will not pay for the additional sampling to insure
compliance.
13. Check all that apply:
No compliance issues Current enforcement action(s) Currently under JOC
Notice(s) of violation Currently under SOC Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place? NOV and NOV/NOI were issued for limit
violations in 2019; that issue appears to have been corrected. Compliance issues in 2020 consist mainly of late
and/or missing parameters/reports. The Regional Office is in the process of issuing Notices for outstanding
violations.
Have all compliance dates/conditions in the existing permit been satisfied? Yes No N/A
If no, please explain:
14. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
Yes No N/A
If yes, please explain:
15. Possible toxic impacts to surface waters:
16. Pretreatment Program (POTWs only):
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? Yes or No
If yes, please explain:
2. Recommendation: Hold, pending receipt and review of additional information by regional office
Hold, pending review of draft permit by regional office
Issue upon receipt of needed additional information
Issue
Deny (Please state reasons: )

FORM: WQROSSR 04-14 Page 2 of 3

3. Signature of report preparer:
Signature of regional supervisor:
Date:

COMMENTS: WaRO recommends monthly monitoring in the permit instead of 4 times per year. The facility is a
Grade II facility with mechanical treatment. The operators cannot run the system when they do not have the
monitoring to tweak the system in order to meet limits. The facility has had seven NOVs over the past two years
because the school will not pay for the additional sampling to insure compliance.

FORM: WQROSSR 04-14 Page 3 of 3