NC0025437_SPECIAL ORDER BY CONSENT 180 DAY EVALUATION_20251002

109 N Main Street Town of Rich Square Phone: [phone]
P.O Box 336 Fax: [phone]
Rich Square, NC 27869 Website: richsquarenc.org
September 30, 2025
Attn: Vanessa Manuel,
Assistant Regional Supervisor
Water Resources Water Quality Regional Operations Section
NPDES Program
1617 Mail Service Center
Raleigh, NC 27699-1617
Ms. Manuel,
NC Dept OfEnvironme'tal Quality
Raleigh Rcgional Oftic:e
Subject: SOC 180 Day Evaluation
EMC SOC WQ S24-002
NPDES NCO025437
Town of Rich Square
Northampton County
The Town of Rich Square holds permit NPDES NCO025437 for the operation and maintenance of
the town's wastewater treatment system. The town entered a Special Order by Consent (SOC)
with the Environmental Management Commission on March 26, 2025, to address issues associated
with the noncompliance with permitted limits.
As required by the conditions of the SOC, the Town is hereby submitting a required 180-day
treatment unit investigation to provide the Department of Environmental Quality and the
Environmental Management Commission of an evaluation of improvements made to the treatment
facility. This information was formulated by the Wastewater Training & Technical Assistance
division of the North Carolina Rural Water Association, with the assistance of representative
Richard Davis, and is based on his continued visits to the facility along with discussions with the
town staff.
Additionally, this 180-day treatment unit investigation utilized information obtained from
Engineering Services, PA of Garner, NC which serves as the town's consulting engineering
representative. A review of construction progress information and a recent review of laboratory
data for validation of permit compliance was also made.
• Solids Management Plan. Solids removal efforts have been completed and measurements
of sludge depths in the lagoon were made with a total of 148 dry tons of solids removed. It

is estimated that this effort resulted in the removal of more than 10-15% of the lagoon
solids. Measurements of the remaining lagoon depths have been made, and priority is
being determined for plans for future sludge removal. The town continues to review sources
and methods for future sludge removal and instituting a preliminary program to address
solids inventory and removal. There was no evidence of solids flowthrough when
inspection was made, and records indicate no overflow of solids have been present.
• Headworks Improvements: Equipment identified as part of the headworks has been
completed along with installation, start-up and testing and have resulted in acceptable
operational demonstrations. Staff training in equipment operations and maintenance
continues for the equipment currently installed and will follow-up with further
development of refined standard operating procedures and related equipment maintenance
service programs which is based on manufacturers manuals.
• Floating Aerators: All surface aerators are operational and have been installed along with
associated power cables and control equipment. Initial start-up testing and training has
been completed with completion of initial service maintenance. The staff have participated
in both operations strategies and maintenance procedures.
Information obtained from the equipment maintenance documents continues to be utilized
to develop a written planned program ensuring that maintenance and operations are
provided for each aerator to ensure longevity and service life. Presently, additional on -site
procedures specific to the controllers are in place for the removal of accumulation of fibers
from the aerators, which is a major factor in extending the service life of aerators.
Operational experience will be used to develop and improve reliability and operation of the
floating aerators.
• Chemical Feed Systems and Chemical Storage. Coverings to chemical storage tank site
location and protective coverings have been made to provide for and mitigate climate
effects. Strategies for chemical feed rates have been developed to provide for a more
adequate feed of chemicals which will enhance permit compliance. These efforts will assist
with purchase agreements that ensure continual chemical availability without degradation
to chemical quality.
Initial training and procedure development for the use of the chemical feed equipment
continues and operations staff are actively involved in adjusting chemical feed rates to meet
treatment goals of disinfection and pH control with flow changes. The town will continue
to partner with the NC Rural Water Association for training in development of procedures
to ensure a plan is created to address concerns related to safety, spill containment and
adequate chemical storage are attained on a continual basis.

Conclusion, this 180-day evaluation reflects the positive outcomes of construction planning and
construction efforts, along with operational activities, needed to abate previous deficiencies that
resulted in noncompliance with the NPDES permitted limited.
Completion of the current contract is expected soon and will provide an expected improvement to
treatment levels with a high level of confidence in meeting permitted performance.
The town of Rich Square and its staff are dedicated to making progress and improving the
performance of its wastewater treatment and protection of public health.
If you have any questions regarding this evaluation, please contact Victoria Newcombe at (252)
539-2315.
Sincerely,
V .
Victoria Newcombe, Mayor
Town of Rich Square
cc:
Raleigh Regional Supervisor
Water Quality Regional Operations Section
1628 Mail Service Center
Raleigh, NC 27699-1628
Compliance & Expedited Unit
NC DWR-NPDES Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617