WQ0036210_Staff Report_20230214

;s State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit
Attn: Ehsan Bagheri
From: Tony W. Honeycutt
Fayetteville Regional Office
Application No.: WQ0036210
Facility name: Moore's Keep Christian Camp WWTF
Note: This form has been adapted from the non -discharge facilily 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 (Last site visit/Inspection was in August 2022)
a. Date of site visit: N/A
b. Site visit conducted by: N/A
c. Inspection report attached. ® Yes or ❑ No
d. Person contacted: Tom Lewis and their contact information: 919 815 - 7603 ext.
e. Driving directions: From Carthage take Hwy 24/27 west toward Biscoe to the intersection with Hwy 705.
Turn right and take Hwy 705 to Robbins. Go thru Robbins on Hwy 705 toward Seagrove and turn right onto
Leaman Rd. Drive approx. 4 miles. Leaman Rd becomes Reynolds Mill Rd and the intersection with Hussey
Rd. Take Hussey Road to the entrance of Moore's Keep Christian Camp.
2. Discharge Point(s): N/A
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: Bear Creek is the adjacent surface water to the spray irrigation fields
Classification: From Robbin's Water Supply intake to Deep River is Class "C" waters.
River Basin and Subbasin No. Cape Fear River Basin/CPF 10/17-26-6
Describe receiving stream features and pertinent downstream uses: Narrow Piedmont stream (approx.
60' across and approx. 5' deep) prior to discharging into the Deep River. The area surrounding the
Benchmark Ministries site is wooded timberland on both sides of Bear Creek and the Deep River.
IL PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
Proposed flow:
Current permitted flow:
2. Are the new treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No
If no, explain:
3. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? ❑ Yes ❑ No ❑ N/A
If no, please explain:
FORM: WQROSSR 04-14 Page 1 of 4

4. Do the plans and site map represent the actual site (property lines, wells, etc.)? ❑ Yes ❑ No ❑ N/A
If no, please explain:
5. Is the proposed residuals management plan adequate? ❑ Yes ❑ No ❑ N/A
If no, please explain:
6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? ❑ Yes ❑ No ❑ N/A
If no, please explain:
7. Are there any setback conflicts for proposed treatment, storage and disposal sites'? ❑ Yes or ❑ No
If yes, attach a map showing conflict areas.
8. Is the proposed or existing groundwater monitoring program adequate? ❑ Yes ❑ No ❑ N/A
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ❑ N/A
If yes, attach list of sites with restrictions (Certification B)
Describe the residuals handling and utilization scheme:
10. Possible toxic impacts to surface waters:
11. Pretreatment Program (POTWs only):
III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Thomas Lewis Certificate #: SI-1002746 Backup ORC: Not listed in application 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: Same as in original permit issued 27 February 2013.
Proposed flow: 12,000 gallons/day
Current permitted flow: 12,000 gallons/day
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: Benchmark has not started irrigation activities at the facility as of vet. Due to COVID
-19 restrickions and reduced number of camp sessions, evaporation has been able to maintain freeboard.
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 conflicts for 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:
FORM: WQROSSR 04-14 Page 2 of 4

10. Were monitoring wells properly constructed and located? ® Yes ❑ No ❑ N/A
If no, please explain:
11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ❑ N/A
If no, please complete the following (expand table if necessary):
Monitoring Well
Latitude
Longitude
MW-1
35.47632
-79.55597
MW-2
35.47749
-79.55526
C I II
C I II
C I II
C I II
C I II
C I II
12. 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: Irritation activities have not started at this time to
date.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
If yes, please explain:
14. 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. N/A Has the RO
been working with the Permittee? N/A Is a solution underway or in place? N/A
Have all compliance dates/conditions in the existing permit been satisfied? ❑ Yes ❑ No ® N/A
If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes® No ❑ N/A
If yes, please explain:
16. Possible toxic impacts to surface waters: N/A
17. Pretreatment Program (POTWs only): N/A
IV. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please explain:
2. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an
additional information request:
Item Reason
N/A
FORM: WQROSSR 04-14 Page 3 of 4

3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason
N/A
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
5.
6
Condition Reason
N/A
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
❑C4A
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/7/2023
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Date:
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V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
A back-up ORC was not listed on the renewal application.
To date Benchmark Ministries has not had a spray irrigation event.
FORM: WQROSSR 04-14 Page 4 of 4