NCG551257_Notice of Violation_20240924

September 24, 2024
CERTIFIED MAIL: 7017 0190 2486 0018
RETURN RECEIPT REQUESTED

Robert Mann
2715 Brown Road
Hurdle Mills, NC 27541
Subject: NOTICE OF VIOLATION
NOV-2024-PC-0549
Single Family Wastewater Treatment System
General NPDES Permit NCG550000
Certificate of Coverage NCG551257
Facility: 2715 Brown Road
Orange County
Dear Mr. Mann:

On August 28, 2024, Tyler Clark and Kurtis Waibel from the Raleigh Regional Office of the Division of
Water Resources (DWR) visited your single-family residence (SFR) wastewater treatment system to evaluate
compliance with the subject General NPDES Permit.

This wastewater treatment system is located at 2715 Brown Road in Orange County and is currently
permitted to Robert Mann. Our records indicate the wastewater treatment system consists of a septic tank,
pump tank, above ground recirculating sand filter, tablet chlorinator, and effluent discharge pipe and a rip-
rap apron for post aeration.

General NPDES Permit NCG550000 and Certificate of Coverage (COC) NCG551257 authorize this
discharge of domestic wastewater from your treatment system to receiving waters designated as unnamed
tributary to the North Fork Little River in the Neuse River Basin. This authorized discharge is in accordance
with the effluent limits and monitoring requirements established within the General Permit.

The subject site visit and file review revealed the following:

Treatment system component failure. The site visit revealed what appeared to be a failed pump or flow
blockage that has resulted in untreated domestic wastewater to surface, such that it has short-circuited
treatment from the sub-surface sand filter and from disinfection and is ponding.

Docusign Envelope ID: 6882007E-AA0F-4AF8-A041-546719CC5769
Robert Mann, NCG551257
September 24, 2024 Page 2 of 5

This system failure has been ongoing long enough that the wastewater is ponded, the ground is soft/ saturated and lawnmower traffic is evident through untreated waste. Additionally, there were obviously significant amounts of nutrients and solids (human waste) as fly larvae were plentiful, active and feeding off untreated organic matter. This is a significant vector and pathogen concern.
Docusign Envelope ID: 6882007E-AA0F-4AF8-A041-546719CC5769
Robert Mann, NCG551257
September 24, 2024 Page 3 of 5

Accordingly, these observations constitute violations of the following conditions of your General NPDES
Permit (COC) NCG551257:

Part 1, D. Operations & Maintenance & Records

(2.) Bypassing of Treatment Facilities: Treatment systems shall be maintained at all times to prevent
seepage of sewage.
(4.) System Components: All system components, including but not necessarily limited to, septic tanks,
surface sand filters, other filter components, pump/recirculation tanks, controls and alarms, disinfection
units, dechlorination apparatus, and the outfalls shall be maintained at all times and in good operating
order. The Permittee is responsible for the operation and maintenance of the entire wastewater treatment
system including, but not limited to the following items:
a. Accessible sand filter surfaces shall be raked and leveled every six months and any vegetative growth
shall be removed manually.
b. All pump and alarm systems shall be inspected and tested monthly.

(6.) Outfall Location: A visual review of the outfall location shall be executed twice each year (one at the
time of sampling) to ensure that no visible solids or other obvious evidence of system malfunctioning is
observed. Any visible signs of a malfunctioning system shall be documented, and steps taken to correct
the problem.

Part II. Section B. General Conditions

2. Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharges of sludge use or
disposal in violation of this permit with a reasonable likelihood of adversely affecting human health or
the environment [40 CFR 122.41 (d)].

Part II, Section C. Operation and Maintenance of Pollution Controls

2. Proper Operations and Maintenance. The Permittee shall at all times properly operate and maintain
all facilities and systems of treatment and control (and related appurtenances) which are installed or
used by the Permittee to achieve compliance with the conditions of this permit. Proper operation and
maintenance also includes adequate laboratory controls and appropriate quality assurance procedures.
This provision requires the Permittee to install and operated backup or auxiliary facility only when
necessary to achieve compliance with the conditions of the permit [40 CFR 122.41(e)].

These violations and any future violations are subject to civil penalty assessment of up to $25,000 per day
per violation. Please respond to this letter in writing within 30 days of receipt of this letter. Your response
should minimally address the following items:
1) Please explain and detail in your written response what steps you have taken to correct your
malfunctioning system. (e.g. pumping septic tank, replacement of pump, panel repair,
findings/observations and repairs efforts of plumber, receipts etc.)
Docusign Envelope ID: 6882007E-AA0F-4AF8-A041-546719CC5769
Robert Mann, NCG551257
September 24, 2024 Page 4 of 5

2) Discuss in your response how the system has been repaired, such that wastewater is being treated and
disinfected, as appropriate.

Your wastewater system is failing or is not operating properly. The Raleigh Regional Office requests that
you (Permittee) secure a plumber or a NC certified engineer to inspect your existing system and determine
what repairs are needed and/or what components need replacing. This is necessary to ensure that the system
functions as intended and meets the conditions of your permit, including meeting the effluent monitoring
limits.

Finally, Attachment A includes additional findings of the compliance evaluation inspection and
highlights select system operational and maintenance requirements for your reference and future use.

Thank you for your attention to this matter. This office requires that the violations, as detailed above, be
abated immediately and properly resolved. Environmental damage and/or failures to properly comply
with permit conditions and to properly operate and maintain the waste treatment system, as stated above, has
occurred. Please understand, periodic or routine occurrence of waste discharges in violation of permit
conditions (sewage) must be eliminated. This cannot continue to occur.

If you have questions or comments about the inspection, this report or the requirements to take corrective
action, please contact Tyler Clark at [phone] (Timothy.clark @deq.nc.gov) or me at 919-791-4232 or
via email at [e-mail].

Sincerely,

Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

Attachment(s): EPA Water Compliance Inspection Report
Attachment A
Annual Permit Fee Invoice – Due 7/6/2024

Cc: Laserfiche

Docusign Envelope ID: 6882007E-AA0F-4AF8-A041-546719CC5769
Robert Mann, NCG551257
September 24, 2024 Page 5 of 5

Attachment A
1. Pumping the septic tank: Septic tanks should be pumped out approximately every five years or when the
solids level is found to be more than 1/3 of the liquid depth in the septic tank compartment, whichever is
greater. A pumping company can check the status periodically and determine when pumping is required.

For your reference, the General NPDES Permit requires the permittee to retain records associated with
sewage disposal activities for a period of at least 5 years.

2. Chlorine tablets in the chlorinator: You are reminded that it is required that chlorine tablets be maintained
in the chlorinator to ensure proper disinfection of the discharged wastewater. Chlorine tablets are intended to
provide effective disinfection and prevent/limit harmful bacteria from discharging to the environment. The
product label for these tablets must indicate the tablets are approved for wastewater use and not for
swimming pools. Part 1, Section D (1) of General NPDES Permit NCG550000 requires the permittee to
inspect the tablet chlorinator weekly to ensure there is an adequate supply of tablets for continuous and proper
operation. Section D (4) requires the permittee to maintain all system components, including...disinfection
units...at all times and in good operating order.
Please ensure the correct type of tablets are used and maintained in the chlorinator and de-chlorination
contact tubes as required by the General NPDES Permit. Please be sure to keep records of this nature
available for your reference and used during future inspections. (Note: Examples of these products
(disinfection and the disinfection neutralizer) can be readily observed online. You may wish to conduct an
online search by using google for “chlorine tablets for wastewater” and “dechlorination tablets for
wastewater”).

3. Discharge outlet location. The permittee is required to conduct a visual review of the outfall location at least
twice each year (once at the time of sampling) to ensure that no visible solids or other obvious evidence of
system malfunctioning is observed. Any visible signs of a malfunctioning system shall be documented, and
steps taken to correct the problem.

4. Analyzing the effluent: Part 1. C., Effluent Limitations and Monitoring Requirements, within General Permit
NCG550000 requires a permittee to sample and analyze the effluent (wastewater discharge) leaving the
treatment system. This sampling effort is required to be conducted annually.

If you have not already collected the effluent for this year, please collect a representative sample of the
effluent and have it analyzed by a certified commercial laboratory. If no wastewater flow is observed from
your system, please document that information for your records and use during the next system inspection.
Note: Certified Laboratory listings (see “Commercial In-state listing”) can be found at this email address:
https://www.deq.nc.gov/about/divisions/water-resources/water-sciences/chemistry-laboratory/laboratory-
certification-branch/certified-laboratory-listings

5. Part II Section B.14 of General Permit NCG550000 requires the permittee to “pay the annual administering
and compliance monitoring fee within thirty days after being billed by the Division.”

A review of the billing records for this facility indicates that the permit annual fee for 2024 is overdue. This
billing period begins on 07/01/2024 and ends 06/30/2025. The billing due date is 7/6/2024 for this billing
period. A copy of the invoice is attached.

6. You are also reminded to maintain all monitoring data and associated maintenance records. These materials
should be maintained for a minimum of five years and be available for review.
Docusign Envelope ID: 6882007E-AA0F-4AF8-A041-546719CC5769
EPA
United States Environmental Protection Agency
Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 N 52 NCG551257 24/08/28 C S31112171819 20
21 66
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved-------------------
N67707172 73 74 75 80
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
2715 Brown Road
2715 Brown Rd
Hurdle Mills NC 27541
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
02:00PM 24/08/28 13/08/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Other Facility Data
02:45PM 24/08/28 18/07/31
Name, Address of Responsible Official/Title/Phone and Fax Number
Robert Mann,2715 Brown Rd Hurdle Mills NC 27541///Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Operations & Maintenance Records/Reports Facility Site Review
Effluent/Receiving Waters
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s)Agency/Office/Phone and Fax Numbers Date
Timothy Clark DWR/RRO WQ/919-791-4234/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#1
9/24/2024
Docusign Envelope ID: 6882007E-AA0F-4AF8-A041-546719CC5769
9/24/2024
NPDES yr/mo/day
24/08/28
Inspection Type
C3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
The subject site visit and file review revealed the following:
Treatment system component failure. The site visit revealed what appeared to be a failed pump or
flow blockage that has resulted in untreated domestic wastewater to surface, such that it has
short-circuited treatment from the sub-surface sand filter and from disinfection and is ponding.

This system failure has been ongoing long enough that the wastewater is ponded, the ground is soft/
saturated and lawnmower traffic is evident through untreated waste. Additionally, there were
obviously significant amounts of nutrients and solids (human waste) as fly larvae were plentiful, active
and feeding off untreated organic matter. This is a significant vector and pathogen concern.
Accordingly, these observations constitute violations of the following conditions of your General
NPDES Permit (COC) NCG551257:
Part 1, D. Operations & Maintenance & Records
(2.) Bypassing of Treatment Facilities: Treatment systems shall be maintained at all times to prevent
seepage of sewage.
(4.) System Components: All system components, including but not necessarily limited to, septic
tanks, surface sand filters, other filter components, pump/recirculation tanks, controls and alarms,
disinfection units, dechlorination apparatus, and the outfalls shall be maintained at all times and in
good operating order. The Permittee is responsible for the operation and maintenance of the entire
wastewater treatment system including, but not limited to the following items:
a. Accessible sand filter surfaces shall be raked and leveled every six months and any vegetative
growth shall be removed manually.
b. All pump and alarm systems shall be inspected and tested monthly.
(6.) Outfall Location: A visual review of the outfall location shall be executed twice each year (one at
the time of sampling) to ensure that no visible solids or other obvious evidence of system
malfunctioning is observed. Any visible signs of a malfunctioning system shall be documented, and
steps taken to correct the problem.
Part II. Section B. General Conditions
2. Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharges of sludge use or
disposal in violation of this permit with a reasonable likelihood of adversely affecting human health or
the environment {40 CFR 122.41 (d)].
Part II, Section C. Operation and Maintenance of Pollution Controls
2. Proper Operations and Maintenance. The Permittee shall at all times properly operate and
maintain all facilities and systems of treatment and control (and related appurtenances) which are
installed or used by the Permittee to achieve compliance with these conditions of this permit. Proper
operation and maintenance also includes adequate laboratory controls and appropriated quality
assurance procedures. This provision requires the Permittee to install and operated backup or
auxiliary facility only when necessary to achieve compliance with the conditions of the permit [40 CFR
122.41(e)].
These violations and any future violations are subject to civil penalty assessment of up to $25,000
NCG551257 17 (Cont.)
Page#2
Docusign Envelope ID: 6882007E-AA0F-4AF8-A041-546719CC5769
Permit:NCG551257
Inspection Date:08/28/2024
Owner - Facility:
Inspection Type:
2715 Brown Road
Compliance Evaluation
per day per violation. Please respond to this letter in writing within 30 days of receipt this letter. Your
response should minimally address the following items:
1)Please explain detail in your written response what steps you have taken to correct your
malfunctioning system. (e.g. pumping septic tank, replacement of pump, panel repair,
findings/observations and repairs efforts of plumber, receipts etc.)
2)Discuss in your response how the system has been repaired, such that wastewater is being
treated and disinfected, as appropriate.
Your wastewater system is failing or is not operating properly. The Raleigh Regional Office requests
that you (Permittee) secure a plumber or a NC certified engineer to inspect your existing system and
determine what repairs are needed and / or what components need replacing. This is necessary to
ensure that the system functions as intended and meets the conditions of your permit, including
meeting the effluent monitoring limits.
Finally, Attachment A includes additional findings of the compliance evaluation inspection and
highlights select system operational and maintenance requirements for your reference and future
use.
Thank you for your attention to this matter. This office requires that the violations, as detailed above,
be abated immediately and properly resolved. Environmental damage and/or failures to properly
comply with permit conditions and to properly operate and maintain the waste treatment system, as
stated above, has occurred. Please understand, periodic or routine occurrence of waste discharges
in violation of permit conditions (sewage) must be eliminated. This cannot continue to occur.
These violations and any future violations are subject to a civil penalty assessment of up to a
maximum of $25,000.00 per day for each violation. Your above-mentioned response to this
correspondence will be considered in any civil penalty assessment process that may occur.
Page#3
Docusign Envelope ID: 6882007E-AA0F-4AF8-A041-546719CC5769
Permit:NCG551257
Inspection Date:08/28/2024
Owner - Facility:
Inspection Type:
2715 Brown Road
Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping?
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
Failure to properly operate and maintain treatment system such that untreated/partially
treated wastewater is ponding on the ground surface.
Comment:
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
application?
Is the facility as described in the permit?
# Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
Comment:
Page#4
Docusign Envelope ID: 6882007E-AA0F-4AF8-A041-546719CC5769
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENTAL QUALITY
This annual fee is required by the North Carolina Administrative Code. It covers the administrative costs associated
with your permit. It is required of any person holding a permit for any time during the annual fee period, regardless
of the facility’s operating status. Failure to pay the fee by the due date will subject the permit to revocation.
Operating without a valid permit is a violation and is subject to a $10,000 per day fine. If the permit is revoked and
you later decide a permit is needed, you must reapply, with the understanding the permit request may be denied
due to changes in environmental, regulatory, or modeling conditions.
INVOICE
Annual Permit Fee Overdue
*2024PR005695*
Permit Number:NCG551257
Annual Fee Period:
Orange County
Invoice Date:06/06/2024
2715 Brown Road Due Date:07/06/2024
Annual Fee:$60.00
07/01/2024 to 06/30/2025
Robert Mann
2715 Brown Rd
Hurdle Mills, NC 27541
2024PR005695Invoice Number:
Notes:
1.You may pay either by mail with check/money order OR by electronic payment (eCheck or Credit Card).
2.If payment is by check/money order, please remit payment to:
NCDEQ - Division of Water Resources
Attn: Animal/Discharge/Non-Discharge Billing
1617 Mail Service Center
Raleigh, NC 27699-1617
3.If payment is electronic, please see https://epay.deq.nc.gov/wq-epayments.html to pay electronically. Payments by eCheck will
debit your checking account. Credit card transactions will incur a convenience fee.
4.Please include your Permit Number and Invoice Number on all correspondence.
5.A $35.00 processing fee will be charged for returned checks in accordance with North Carolina General Statute 25-3-506.
6.The Department cannot accept checks older than 6 months under Uniform Commercial Code 4-404.
7.Non-Payment of this fee by the payment due date will initiate the permit revocation process.
8.Should you need to update any Owner/Permit/Contact information or have any questions regarding this invoice, please send
email to [e-mail] or you may also contact the following:
- NPDES WW Program Administrative Contact at 919-707-3601 or
- Annual Administering and Compliance Fee Coordinator at 919-707-3698
Robert Mann
2715 Brown Rd
Hurdle Mills, NC 27541
Invoice Number:
(Return This Portion With Check)
ANNUAL PERMIT INVOICE
Permit Number:NCG551257
Annual Fee Period:
Orange County Invoice Date:6/6/2024
2715 Brown Road Due Date:7/6/2024
Annual Fee:$60.00
Check Number:
07/01/2024 to 06/30/2025
Overdue
*2024PR005695*
2024PR005695
Docusign Envelope ID: 6882007E-AA0F-4AF8-A041-546719CC5769