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Chapter 1
Cape Fear River Subbasin 03-06-01
Including: Haw River, Troublesome Creek and Little Troublesome Creek
1.1 Subbasin Overview
Subbasin 03-06-01 at a Glance
Land and Water Area
Total area: 189 mil
Land area: 187 mil
Water area: 2 miz
Population
2000 Est. Pop.: 66,449 people
Pop. Density: 352 persons/mil
Land Cover (percent)
Forest/ Wetland: 58.6 %
Water: 2.0 %
,+ Urban: 1.7 %
Cultivated Crop: 7.1
Pasture/Managed
Herbaceous: 30.6
Counties
Alarnance, Caswell, Forsyth,
Guilford and Rockingham
Municipalities
Reidsville
Subbasin 03-06-01 is a piedmont watershed characterized
by highly erodible soils. Most of the watershed is
forested with extensive agriculture present. Development
is occurring north of Greensboro and around Reidsville.
Population is expected to grow by 140,000 people in
counties with portions or all of their areas in this subbasin
by 2020.
There are l I individual NPDES wastewater discharge
permits in this subbasin with a total permitted flow of 7.8
MGD (Figure 4). The largest is Reidsville W WTP (7.5
MGD). Refer to Appendix VI and Chapter 30 for more
information on NPDES permit holders. Issues related to
compliance with NPDES permit conditions are discussed
below in Section 1.3 for impaired waters.
There are no municipal areas in this subbasin required to
develop a stormwater program (Chapter 31).
There are two registered swine operations, one registered
cattle operation, one registered horse farm and four
registered dairy operations in this subbasin. Issues related
to animal operations are discussed below in Section 1.3
for Impaired waters.
There were l I benthic macroinvertebrate community
samples and two fish community samples (Figure 4 and Table 4) collected during this
assessment period. Some sites were not sampled because of high flows in 2003 and low flows in
2001 and 2002 may have had impacts on the biological communities as well. Data were also
collected from eight ambient monitoring stations including four DWQ stations, two UCFRBA
(Appendix V) stations and two shared station. Two reservoirs were also monitored. Refer to the
2003 Cape Fear River Basinwide Assessment Report at http://www.esb.enr.state.nc.tis/bar,htnil and
Appendix IV for more information on monitoring.
Waters in the following sections are identified by an assessment unit number (AU#). This
number is used to track defined segments in the water quality assessment database, 303(d)
Impaired waters list, and the various tables in this basin plan. The assessment unit number is a
subset of the DWQ index number (classification identification number). A letter attached to the
DRAFT Chapter 1— Cape Fear River Subbasin 03-06-01
end of the AU# indicates that the assessment unit is smaller than the DWQ index segment. No
letter indicates that the assessment unit and the DWQ index segment are the same.
Introduction 2
U.
Figure 4 Cape Fear River Subbasin 03-06-01
Division of Water Quality
inwide Planning Program
jary 27, 2005
c •4
Reidsville
B41
Lake
unt SS29
...... B j$.-.
ROCKINGHAM BB396 y
BBifi
BB21u n BB43 C3
BB395
BB392
GUILFORD
Lake
ReldsWfle
e>
BA14
HA
BA10
B�00 B fi3
'
I
BF61
r • BA3
BA15
LU
R
-
Q
a
a
5 a 5 10 Mlles
BA1fi ,
BA17
Legend
OSu6hasln
Boundary
®
Amhont Monitoring Stadon
Benedc Station
Fish Communhy Stallon
NPDES
Discharges
♦
uajar
Minor
Use Support Raling
n/
Supporting
NImpaired
NNot
Rated
No Data
A/
Primary Roads
C _J
County Boundary
CD
Munldpailty
Cape Fear Subbasin 03-06-01
Benthic
Fish
Rating
Rating
Community
Community
Ambient Data
AU Number Length Area
AL
REC
Station Year Bioclass
Station Year Bioclass
Station
Parameter
% Geomean
Applicability
HAW RIVER
16-(1)a 7.8 FWmiles
S
NR
BA2
dissolved oxygen <5mgll
17A
parameter elevated
BA2
fecal coliform bacteria
21.3
parameter elevated
BA2
no criteria exceeded
no criteria exceeded
16-(l)b 12.5 FWmiles
S
S
BF61 1998 G
BA3
dissolved oxygen <5mg/l
14
parameter elevated
16-(1)c 21.2 FWmiles
S
S
BB163 '2003 GF
BF61 '1998 G
BA16
no criteria exceeded
no criteriaexceedcd
BA l5
no criteria exceeded
no criteria exceeded
BA15
turbidity
7.3
parameter elevated
BA3
dissolved oxygen <5mg/l
14
parameter elevated
BA3
no criteria exceeded
no criteria exceeded
BA3
no criteria exceeded
no criteria exceeded
16-(1)dl 1.3 FWmiles
S
I
BA17
fecal coliform bacteria
29
standards violation
Little Troublesome Creek
16-7a 3.5 FWmiles NR BB415 '2001 NR
BB208 '2001 NR
BB86 '2000 NR
16-7b 5.1 FWmiles I S BB 161 '2000 F BF63 '2003 GF BA 14 no criteria exceeded no criteria exceeded
BB400 '2000 F BF63 '1998 P BA14 turbidity 9.3 parameter elevated
B8400 '2001 F
BB400 '2001 F
BB400 '2003 F
BB161 '2001 F
Draft Wednesday, February 16, 2005 03-06-01
Cape Fear Subbasin 03-06-01
Benthic Fish
Rating Rating Community Community Ambient Data
AU Number Length Area AL REC Station Year Bioclass Station Year Biorhms Station Parameter % Gcomean Applicability
Iq�l
Troublesome Creek
16-6-(0.3) 16.4 FWmiles S BB396 2002 GF
BB395 2002 GF
R8392 r2002 GF
BB212 '2002 GF
16-6-(3) 1.8 FWmiles I S BAID dissolved oxygen <4mgll 12.8 standards violation
BA l0 turbidity 7.3 parameter elevated
Troublesome Creek (Lake Reidsville)
16-6-(0.7) 667.5 Mures ISR Lake Mo chlorophyll a 66 parameter elevated
Unnamed Tributary to Troublesome Creek (Lake Hunt)
16-6-2-(1) 176.4 FWacres S Lake Mo no criteria exceeded no criteria exceeded
Draft Wednesday, February 16, 2005 03-06-01
Cape Fear Subbasin 03-06-01
Benthic Fish
Rating Rating Community Community Ambient Data
AU Number Length Area AL REC Station Year Bioclass Station Year Binclass Station Parameter % Geomean Applicability
Assessment Unit # -Portion of DWQ Classified Index where monitoring is app lied to assign a use support rating.
Use Categories:
Monitoring data type:
Bioclassifcations:
AL - Aquatic Life
BF - Fish Community Survey
E - Excellent
REC - Recreation
BB - Benthic Community Survey
G - Good
BA - Ambient Monitoring Site
GF - Good -Fair
Lake M o- Lake M onitoring
F - Fair
P - Poor
NI - Not Impaired
N- Natural
M- Moderate
S-Severe
Aquatic Life Ratings Summary
Recreation Ratings Summary
S m FWacres
176.4
S m FWmiles 40.5
S m FWmiles
59.2
I In FWmiles 1.3
1 in FWmiles
6.8
NR m FWmiles T8
NR m FWacres
667.5
No Data FWacres 868.7
NR m FWmiles
3.5
No Data FWmiles 54.8
No Data FWacres 24.8
No Data FWmiles 34.9
Total FWacres 868.7
Total FWmiles 104.5
Total FWacres 868.7
Total FWmiles 104.5
Use Support Ratings 2004:
S - Supporting, I - Impaired,
NR - Not Rated
Draft Wednesday, February 16, 2005
03-06-01
1.2 Use Support Assessment Summary
Use support ratings were assigned for waters in subbasin 03-06-01 in the aquatic life, recreation,
fish consumption and water supply categories. All waters are Impaired on an evaluated basis in
the fish consumption category because of fish consumption advice (Chapter 27) that applies to
the entire basin. in the water supply category, all WS classified waters (843.9 acres and 24.3
miles) are Supporting on an evaluated basis based on reports from DFH regional water treatment
plant consultants. Refer to Appendix III for a complete list of monitored waters and more
information on Supporting monitored waters.
There were 69.6 stream miles (66.6 percent) and 843.9 freshwater acres (97 percent) monitored
during this assessment period in the aquatic life category. There were 6.8 miles (6.5 percent) of
Impaired waters in this category. There were also 1.3 stream miles (1.2 percent) Impaired for
recreation in this subbasin.
1.3 Status and Recommendations of Previously and Newly Impaired
Waters
The following waters were either identified as Impaired in the previous basin plan (2000) or are
newly Impaired based on recent data. If previously identified as Impaired, the water will either
remain on the state's 303(d) list or will be delisted based on recent data showing water quality
improvements. If the water is newly Impaired, it will likely be placed on the 2006 303(d) list.
The current status and recommendations for addressing these waters are presented below, and
each is identified by an assessment unit number (AU#). Refer to the overview for more
information on Aus. Information regarding 303(d) listing and reporting methodology is
presented in Appendix VII.
1.3.1 Haw River [AU# 16-(1)a and b and d1j
2000 Recommendations
The 2000 basin plan recommended that no new discharges be permitted in these segments of the
Haw River and that further monitoring be done to determine the extent of agricultural impacts
and to identify stressors to the biological community.
Current Status
The Haw River [I6-(I)a) from the source to SR 2109 (7.8 miles) is Supporting aquatic life
because no criteria were exceeded at site BA2 although dissolved oxygen was below 5 mg/1 in 17
percent of samples collected during the assessment period. Previous benthic community ratings
were Fair at this site, although a benthic community sample was not collected during the most
recent assessment period due to high flows. This segment is Not Rated for recreation because
fecal coliform bacteria screening criteria were exceeded at site BA2. The Oak Ridge Military
Academy (NC0046043) had significant violations of the fecal coliform bacteria permit limits in
the last two years of the assessment period as well. The discharge is into an unnamed tributary
of the Haw River off NC 68. Oak Ridge Military Academy has had violations of other
parameters in 2004 that were handled with notice of violations (NOV) and enforcement actions
by DWQ.
DkAFT Chapter I — Cape Fear River Suhhasin 03-06-01
The Haw River [ 16-(1)b] from SR 2109 to SR 2426 (12.5 miles) is Supporting aquatic life
because of a Good fish community rating at site BF61. The site has regular high flows that have
made sampling difficult at site BF61. In 2003, flow was too high and the water was too turbid to
collect fish community samples. Dissolved oxygen was below 5 mg/l in 14 percent of samples at
site BA3 about six miles downstream of BF61.
No new dischargers have been permitted into these two segments. The western portion of the
watershed is currently experiencing rapid development from Greensboro and Kernersville. The
Ag Sediment Initiative (Chapter 28) identified runoff from impervious surfaces and streambank
erosion as stressors to the biological community in both segments.
The Haw River [16-(1)c] from SR 2426 to NC87 (21.2 miles) is Supporting aquatic life because
of a Good -Fair benthic community rating at site BB 163 and a Good fish community rating at site
BF61. Turbidity was above the standard in 7.3 percent of samples at site BA15.
The Haw River [I 6-(1)d I] from NC 87 to the subbasin boundary (1.3 miles) is Supporting
aquatic life because no criteria were exceeded at site BA 17. This segment is Impaired for
recreation because the fecal coliform bacteria standard was violated at site BA 17.
2005 Recommendations
DWQ will continue to monitor these segments of the Haw River and work with DSWC staff to
further implement BMPs to reduce the impacts of development and agriculture in this watershed,
Further recommendations to protect streams in urbanizing areas and to restore streams in existing
urban areas are discussed in Chapter 31. The NPDES compliance process will continue to be
used to address the significant permit violations noted above and any ongoing violations.
Segment 16-(1)a will remain on the 303(d) list due to an Impaired biological community from
1998 sampling, Segment 16-(1)b will be removed from the 303(d) list because of the improved
biological community rating. Segment 16-(1)dl will be added to the 303(d) list because it is
Impaired for recreation, TMDLs (Chapter 35) will be developed for identified stressors within
8-13 years of listing.
Water Quality Initiatives
The Ag Sediment Initiative (Chapter 28) estimates that over $1.2 million is needed in this
watershed to preserve 1,000 acres of farmland, repair 20,000 feet of streambank and install
BMPs on 525 acres of cropland. An urban conservationist is also recommended to help address
impacts in this watershed associated with conversion of cropland to development.
In 1998, the Haw River Assembly (Chapter 34) received a $24,500 CWMTF (Chapter 34) grant
to preserve four acres around the headwater springs of the Haw River. In 2002, the Piedmont
Land Conservancy (Chapter 34) received a mini -grant of $25,000 for pre -acquisition of 500
acres along the Haw River and Troublesome Creek. In 2001, the Haw River Assembly received
a mini -grant of $14,500 for pre -acquisition of six tracts in the headwaters of the Haw River.
DRAFT Chapter I — Cape Fear River Subbasin 03-06-01 8
1.3.2 Little Troublesome Creek ]AU# 16-7a and b]
2000 Recommendations
The 2000 basin plan recommended that DWQ work on a detailed study of Little Troublesome
Creek as part of the WARP project to assess the effects of nonpoint source runoff on the creek.
Current Status
Little Troublesome Creek [AU# 16-7a] from the source to the Reidsville WWTP (3.5 miles) is
Not Rated for aquatic life because benthic community ratings could not be assigned at sites
B13208, BB415 and BB86 because of the small size of the stream.
Little Troublesome Creek [AU# 16-7b] from Reidsville WWTP to the Haw River (5.1 miles) is
Impaired for aquatic life because of Fair benthic community ratings at sites BB 161 and BB400.
The fish community at site BF63 improved from Poor to Good -Fair after the Reidsville WWTP
discharge was moved to the Haw River in 1998. Turbidity also exceeded the water quality
standard in 9.3 percent of samples at site BA14.
A WARP study completed in November 2002 identified toxicity, organic enrichment and
widespread habitat degradation from storm sewers and runoff as being stressors to the biological
communities in both segments (DENR-DWQ 2002). An assessment made as part of the Little
Troublesome Creek Local Watershed Plan (Chapter 34) indicated that 43 to 59 percent of the
buffer had been disturbed in the upper watershed and greater than 10 percent was disturbed in the
lower watershed. The assessment also concluded that sediment from agricultural land was not a
problem in the watershed. The Ag Sediment Initiative (Chapter 28) identified runoff from
impervious surfaces, urban development, unpaved roads, road construction, cropland erosion and
streambank erosion as stressors to the biological community in both segments.
DWQ developed a fecal colifonn bacteria TMDL (Chapter 35) that was approved by EPA in
September 2002 that recommended a 40 percent reduction in fecal coliform bacteria loading to
Little Troublesome Creek.
2005 Recommendations
DWQ will continue to work with all agencies and local governments involved in the Local
Watershed Planning (Chapter 34) process to identify funding for and implementation of
restoration, BMPs and preservation projects in the watershed.
The City of Reidsville stormwater program should develop measures to help protect Little
Troublesome Creek from stormwater impacts and to reduce fecal coliform loading by the 40
percent targeted in the TMDL.
Both segments of Little Troublesome Creek will remain on the 303(d) list. TMDLs (Chapter 35)
will be developed for identified stressors within 8-13 years of listing.
Water Quality Initiatives
The Ag Sediment Initiative (Chapter 28) estimates that over $160,000 is needed in this
watershed to install field borders on 74 acres of cropland, 34 acres of cropland conversion and
other BMPs to help improve water quality from agriculture areas in the watershed.
DRAFT Chapter 1 — Cape Fear River Szthbasin 03-06-01 9
1.3.3 Troublesome Creek {AU# 16-6-(0.3) and 16-6-(3)]
2000 Recommendations
The 2000 basin plan recommended that no new discharges be permitted in these two segments of
Troublesome Creek and that further monitoring be done to determine the extent of agricultural
impacts and to identify stressors to the biological community.
Current Status
Troublesome Creek [16-6-(0.3)] from the source to SR 2423 (16.4 miles) is Supporting aquatic
life because of Good -Fair benthic community ratings at sites 1313212, BB392, BB395 and 1313396.
A special study conducted in April 2002 found that the benthic communities were slightly more
degraded than the reference stream and there were no indications of toxicity or nutrient impacts
to the community. There were indicators of low dissolved oxygen instream although no ambient
water quality data were collected in this segment. The sandy stream bottom is thought to be a
natural condition in upper piedmont streams (DENR-DWQ, 2002). Monroeton Elementary
School (NC0036994) had significant violations of the biological oxygen demand permit limit in
the last two years of the assessment period as well. The discharge was into an unnamed tributary
of Troublesome Creek off SR 2422 just upstream of site 1313396. This facility is no longer
discharging and the permit has been rescinded.
Lake Reidsville [16-6-(0.7)] a 667.5-acre impoundment of Troublesome Creek is Not Rated for
aquatic life. Although dissolved oxygen, chlorophyll a and turbidity exceeded water quality
standards during lakes monitoring, not enough samples were collected to assign a use support
rating. Dissolved oxygen saturation was elevated and nutrient levels were higher than in
previous years as well.
Reidsville uses the reservoir as a water supply and has implemented a 100-foot buffer on the
impoundment and 50-foot buffers on all tributaries. Reidsville should continue to protect the
water supply by implementing BMPs where possible to reduce nutrient loading and turbidity in
the watershed. DWQ will determine if increased monitoring efforts in this lake are warranted to
better assess water quality.
Troublesome Creek [16-6-(3)] from dam at Reidsville Lake to the Haw River (1.8 miles) is
Impaired for aquatic life because dissolved oxygen levels violated the standard in 12.8 percent of
samples at site BA 10 during the assessment period.
2005 Recommendations
DWQ will continue to monitor Troublesome Creek and work with DSWC staff to further
implement BMPs to reduce the impacts of agriculture in this watershed. DWQ will investigate
releases from the Reidsville Lake Dam to determine if the source of the low DO is from dam
releases.
Segment 16-6-(0.3) will be removed from the 303(d) list because of the improved biological
community rating. Segment 16-6-(3) will be added to the 303(d) list because of the dissolved
oxygen standard violation. TMDLs (Chapter 35) will be developed for identified stressors
within 8-13 years of listing.
DRAFT Chapter I — Cape Fear River Su66asin 03-06-01 10
Water uali Initiatives
In 2002, the Piedmont Land Conservancy (Chapter 34) received a mini -grant of $25,000 to pay
for pre -acquisition of 500 acres along the Haw River and Troublesome Creek.
1.4 Status and Recommendations for Waters with Noted Impacts
The surface waters discussed in this section are not Impaired. However, notable water quality
problems and concerns have been documented for these waters during this assessment. Attention
and resources should be focused on these waters to prevent additional degradation and facilitate
water quality improvements. DWQ will notify local agencies of these water quality concerns
and work with them to conduct further assessments and to locate sources of water quality
protection funding. Additionally, education on local water quality issues and voluntary actions
are useful tools to prevent water quality problems and to promote restoration efforts. Nonpoint
source program agency contacts are listed in Appendix X. Waters in the following section are
identified by assessment unit number (AU#). See overview for more information on AU#s.
1.4.1 Mears Fork [AU# 16-31
Current Status and 2005 Recommendations
Mears Fork, from source to Haw River was not assessed for use support determination. This
stream is near high growth areas north of Greensboro. This stream as well tributaries may be
adversely impacted by poor development practices. Further recommendations to protect streams
in urbanizing areas and to restore streams in existing urban areas are discussed in Chapter 31.
Water QualiU Initiatives
Mears Fork Conservation Plan. In 1999, the Haw River Assembly (Chapter 34) received a
$200,000 CWMTI~ (Chapter 34) grant to acquire 46 acres of land and for landowner permanent
conservation easements on another 60 acres in this watershed.
1.5 Additional Water Quality Issues within Subbasin 03-06-01
The following section discusses issues that may threaten water quality in the subbasin that are
not specific to particular streams, lakes or reservoirs. The issues discussed may be related to
waters near certain land use activities or within proximity to different pollution sources.
1.5.1 Jordan Haw River Watershed Nutrient Sensitive Waters Strategy
All land uses and discharges of wastewater and stormwater in subbasin 03-06-01 potentially
contribute nutrients to Jordan Reservoir in subbasins 03-06-04 and 03-06-05. The reservoir is
Impaired for aquatic life because chlorophyll a violated the standard in all segments of the
reservoir. Refer to Chapter 36 for more information on this strategy.
DRAFT Chapter 1— Cape Fear River Subbasin 03-06-01 11
Chapter 35
TMDLs in the Cape Fear River Basin
35.1 Introduction to TMDLs
A TMDL or Total Maximum Daily Load is a calculation of the maximum amount of a pollutant
that a waterbody can receive and still meet water quality standards, and an allocation of that
amount to the pollutant sources. A TMDL is the sum of the allowable loads of a single pollutant
from all contributing point and nonpoint sources. The calculation must include a margin of
safety to ensure that the waterbody can be used for the purposes the State had designated. The
calculation must also account for seasonal variation and critical conditions in water quality.
For each water quality limited segment Impaired by a pollutant and identified in the 303(d) list, a
TMDL must be developed. TMDLs are not required for waters Impaired by dam operations. A
TMDL includes a water quality assessment that provides the scientific foundation for an
implementation plan. An implementation plan outlines the steps necessary to reduce pollutant
loads in a certain body of water to restore and maintain human uses or aquatic life. For more
information on TMDLs and the 303(d) listing process, refer to Appendix VII or visit the TMDL
website at http:/ih2o.enr.state.nc.us/tmdl/
35.2 Approved TMDLs in the Cape Fear River Basin
The following TMDLs have been completed and approved by EPA (Table 38). Refer to the
subbasin chapters for specific reductions called for in the TMDLs and to determine what local
governments may be affected by TMDLs.
Table 38 EPA approved TMDLs in the Cape Fear River Basin
Waterbody
(Subbasin)
Pollutant
Approval
Date
Chapter
Little Troublesome Creek (03-06-01)
Fecal colifonn bacteria
May 17, 2002
l
North Buffalo Creek (03-06-02)
Fecal coliform bacteria
April 28, 2004
2
Town Branch (03-06-02)
Fecal coliform bacteria
September 16, 2002
2
Roberson (Robeson) Creek (03-06-04)
Chlorophyll a (Total phosphorus)
January 13, 2004
4
Northeast Creek (03-06-05)
Fecal colifonn bacteria
September 12, 2003
6
East Fork Deep River (03-06-08)
Turbidity, Fecal coliform bacteria
March 4, 2004
8
Richland and Muddy Creeks (03-06-08)
Fecal coliform bacteria
May 17, 2004
8
Several TMDLs are currently in progress at the DWQ. These include a fecal coliform bacteria
and turbidity TMDL for the Haw River (Chapter 1), a fecal coliform TMDL for the Deep River
(Chapter 8), a turbidity TMDL for Third Fork Creek (Chapter 5), a chlorophyll a TMDL for
DRAFT Chapter 35 — TMDLs in the Cape Fear River Basin 312
Jordan Reservoir (Chapter 36), and a dissolved oxygen TMDL for the Cape Fear Estuary
(Chapter 37).
Two large TMDL efforts underway in the Cape Fear River Basin include the Jordan Reservoir
Chlorophyll a TMDL and the Cape Fear Estuary Dissolved Oxygen TMDL. Information
regarding water quality data and assessment for Jordan Reservoir is discussed in Chapter 5,
while TMDL information in discussed in Chapter 36. Information regarding water quality data
and assessment for the Cape Fear Estuary is discussed in Chapter 17, while TMDL information
is discussed in Chapter 37.
35.3 Scheduled TMDLs in the Cape River Basin
EPA guidance provides a timeline for TMDL development of 8 to 13 years. Thus, the elapsed
time between 303(d) listing and TMDL development should not exceed 8 to 13 years. If the
pace of TMDL development does not comply with this schedule, EPA may elect to develop
TMDLs in order to meet this timeline. Waterbodies that were listed in 1998 should have
TMDLs developed by 2006 to 2011.
35.4 TMDL Implementation Efforts
Point source (i.e., wastewater) implementation plans are included in TMDLs per EPA guidance.
Thus, any point source discharging to an Impaired water will receive an explicit allocation within
the TMDL. In some cases, the allocation may be equal to existing permit limits, thus no action is
needed by the wastewater permittee. In other cases, the allocation may be associated with a
reduction in loading. Where applicable, the point source allocation may include provisions for
bubble permits and point-to-point trading.
Nonpoint source implementation plans are not included in TMDLs, nor are they required by
federal law. Nonpoint source implementation plans can be developed by DWQ, other agencies
within DENR, COGS, or local government offices. For example, the Piedmont Triad Council of
Governments (PTCOG) obtained Section 319 grants to develop implementation plans for Little
Troublesome Creek and Tow_ n Branch. Each of these TMDLs has only nonpoint source loadings
contributing to impairment.
EPA has provided guidance regarding TMDLs and NPDES stormwater permits. As a result,
selected NPDES stormwater permits may contain additional language when subject to a TMDL.
Per EPA, MS4s identified in TMDLs as contributors to impairment may be required to develop a
management plan that includes additional monitoring and BMP installation associated with
pollutants of concern.
35.5 Impaired Waters Update
Waters identified as Impaired during this assessment period will be updated in the 2006
Integrated Report. These waters will be considered Impaired upon EMC approval of this basin
plan. TMDLs will be scheduled as appropriate depending upon the classification of the
waterbody and the identified problem parameters.
DRAFT Chapter 35 — TMDLs in the Cape Fear River Basin
313
Chapter 36
Jordan Reservoir and Haw River Watershed NSW Strategy
36.1 - Introduction and Overview
In 1983, all waters in the Haw River watershed (subbasins 03-06-01 to 03-06-06) including
Jordan Reservoir received a supplemental classification of nutrient sensitive water (NSW) to
acknowledge that Jordan Reservoir could have water quality problems associated with excessive
nutrient inputs from both wastewater discharges and runoff from the various land uses in the
watershed. The supplemental classification required than an NSW strategy be put in place to
protect the reservoir from water quality problems associated with nutrient enrichment.
Total phosphorus (TP) limits of 2.0 mg/l were required for NPDES permitted facilities with now
greater than 0.005 MGD. In 2000, all subject dischargers were meeting this limit. In addition,
discharges located upstream of the Upper New Hope Arm of Jordan Reservoir received TP limits
of 0.5 mg/l during the months from April to October. However, nuisance algal blooms and
chlorophyll a levels exceeding water quality standards continue to be observed.
The Upper New Hope Arm of B. Everett Jordan Reservoir was placed on the 2002 303(d) list of
Impaired waters based on results of the nutrient response model developed as described in
Section 36.2 below. The listing of the Upper New Hope Arm is consistent with EPA rules that
require water quality models to be utilized as a basis for 303(d) listing. The 303(d) listing of the
Upper New Hope Arm of the reservoir results in the need for a TMDL for this portion of the
lake. Thus, the Jordan Reservoir nutrient management strategy was developed in order to meet
requirements of both the Clean Water Responsibility Act and the federal rules and guidance
regarding TMDLs. The Lower New Hope Arm and Haw River Arm are currently Impaired as
well (Chapter 5). Refer to Figure 34 for identification of the arms discussed here.
The following sections describe the Jordan stakeholder process, Clean Water Responsibility Act,
the modeling performed to support the nutrient management strategy, the development of
loading targets and the nutrient management strategy that have occurred throughout the
development of the models and the nutrient management strategy. For more information on use
support assessments used to identify impairment of the reservoir, refer to Chapter 5 and
Appendix X.
DRAFT Chapter 36 —Jordan Reservoir and Haw River Watershed NSW Strategy 314
Figure 34 Jordan Reservoir Segments
36.1 Jordan Reservoir Stakeholder Process
Two stakeholder processes occurred during the development of this strategy. The first process
was through the efforts of the Project Partners, During the initial development of the data review
technical memorandum and the nutrient response model, the Project Partners held regular
meetings with DWQ staff. At major completion steps, the Project Partners convened greater
stakeholder meetings to share and discuss results of the data review and the modeling.
DWQ staff, the Triangle J Council of Governments, and the Piedmont Triad Council of
Governments initialized a more formal stakeholder process to carry a greater group of
stakeholders forward through the development of management targets and the management
strategy. A USEPA grant, in the amount of $29,730, was used to support this stakeholder
process. A total of 21 stakeholder meetings were held between May 2003 and December 2004 to
discuss TMDL development, modeling issues, target setting, and management strategy
development. The councils of governments prepared a stakeholder report that includes
descriptions of the meetings, stakeholder comments and concerns, and recommendations. The
Triangle J Council of Governments also continues to maintain a project website, with links to
presentations and handouts posted regularly. Materials can be downloaded from this website at
httt):Hh2o.enr.state.ne.us/tmdl/SpecialStudies.htin#Jordan.
36.2 The Clean Water Responsibility Act of 1997 (House Bill 515, Senate
Bill 1366)
The Clean Water Responsibility Act of 1997 (often referred to as HB515) included legislation to
further address water quality problems in NSW waters. The act set total nitrogen (TN) and total
phosphorus (TP) NPDES permit limits for facilities discharging greater than 0.5 MGD into the
Jordan Reservoir/Haw River watershed. A 5-year compliance period for limits of 5.5 mg/l of TN
and 2 mg/l of TP was established for Qualifying facilities. Amendments to the act approved in
1998 (referred to as Senate Bill 1366) provided a compliance extension to the nutrient limits,
with conditions. Those wastewater facilities granted a compliance extension by the
Environmental Management Commission were required to develop a calibrated nutrient response
model, evaluate and optimize the operation of all facilities to reduce nutrient loading, and
evaluate methods to reduce nutrient mass loading to NSW waters. The municipalities of
Greensboro, Mebane, Reidsville, Graham, Pittsboro and Burlington; and the Orange Water and
Sewer Authority (OWASA) were granted the compliance extension by the Environmental
Management Commission in April 1999. This collective group of facilities will be referred to as
the Project Partners in subsequent sections of this chapter. Facilities that did not seek
compliance extensions are the City of Durham/Durham South WWTP and Durham
County/Triangle WWTP.
The CWRA provided a timeline for progress towards a site -specific nutrient management
strategy should facilities and/or municipalities choose to seek the compliance extension. This
established timeline is as follows:
Two years for the collection of data needed to prepare a calibrated nutrient response
model;
A maximum of one year to prepare the calibrated nutrient response model;
DRAFT Chapter 36 —Jordan Reservoir and Haw River Watershed NSW Strategy 316
■ The amount of time, if any, that is required for the Commission to develop a nutrient
management strategy and to adopt rules or to modify discharge permits to establish
maximum mass loads or concentration limits based on the calibrated nutrient
response model; and
■ A maximum of three years to plan, design, finance, and construct a facility that will
comply with those maximum mass loads and concentration limits.
If the Commission finds that additional time is needed to complete the construction of a facility,
the Commission may further extend the compliance date by a maximum of two additional years.
Each municipality developed optimization plans and submitted them to the Water Quality
Committee. Plans for nutrient response model development began in 1999 when the project
partners, through the local councils of governments, released a request for proposals for both a
data review document and nutrient response model development. Screening level and detailed
nutrient response models were developed by Tetra Tech, Inc., the consultant to the project
partners. The total cost to the project partners for the development of the data review document
and the models was $370,000. The combined hydrodynamic and water quality model was
approved by the Water Quality Committee in July 2002. DWQ began work to develop a nutrient
management strategy following this approval.
36.3 Nutrient Response and Watershed Loading Modeling
Both the Projects Partners, with the addition of the municipalities of Apex and Cary, and the
DWQ funded the development of numerous modeling tools to use for the development of the
nutrient management strategy. Four modeling tools were developed by the Project Partners to as
part of meeting the requirements of the Clean Water Responsibility Act. These tools included a
screening level nutrient response model using the BATHTUB modeling framework, a combined
hydrodynamic and water quality model, and a nutrient fate and transport model for all major
wastewater dischargers in the watershed. Hydrodynamic models simulate water circulation and
movement, and nutrient response models simulate the nitrogen and phosphorus cycles, and algal
response. The consultants, Tetra Tech, Inc., utilized the Environmental Fluid Dynamics Code
(EFDC) framework to construct the reservoir hydrodynamic model, and the Water Quality
Analysis Simulation Program (WASP) to link to the hydrodynamic model and simulate reservoir
nutrient response (i.e., the water quality model). The models were run for the time period from
1997 through 2001. The Jordan Reservoir Nutrient Response Model results were summarized to
provide information regarding the average chlorophyll a levels in the reservoir and the likelihood
of chlorophyll a standard violations in various portions of the reservoir. An example of model
output is provided below in Figure 35. Detailed model output is provided in the modeling
reports available on the Modeling and TMDL Unit website at h2o.enr.s1ate.nc.usltmdl.
The Project Partners also funded the development of a nutrient fate and transport model to
predict the fraction of wastewater that reaches Jordan Reservoir. The model demonstrates that a
smaller fraction of wastewater discharged from facilities located farther upstream in watershed
actually reaches Jordan Reservoir. This is contrary to facilities located nearer to the reservoir
that have substantially greater delivery to the reservoir. The fraction of nutrients delivered to the
lake from each of the major dischargers varies depending upon the location of the effluent
discharge. For example, 43% of the nitrogen load and 42% of the phosphorus load from the City
DRAFT Cahpter 36 — Jordan Reservoir and Haw River Watershed NSW Strategy 317
of Greensboro North Buffalo WWTP reaches Jordan Reservoir. In contrast, 96% of the nitrogen
load and 97% percent of the phosphorus load from the Durham County Triangle WWTP reaches
Jordan Reservoir. Specific delivery rates for each facility are provided in the nutrient
management strategy and TMDL document.
After approval from the Water Quality Committee, DWQ funded an update of the hydrodynamic
and nutrient response model developed by the Project Partners. An additional model year, 2001,
was added to the calibration and model summaries. This year had the largest amount of
measured data of the five years ultimately modeled. DWQ also funded the development of a
screening level watershed loading model in order to capture loading from nonpoint sources in the
watershed. The watershed loading model was constructed using the Generalized Watershed
Loading Function (GWLF) model. The watershed loading model was combined with the
previously developed fate and transport model to provide a better analysis of the point and
nonpoint source nutrient load contributions to Jordan Reservoir.
Sources of total nitrogen (TN)
Fbint(i.e.,
WWTP.)
36%
npoint
64%
Sources of total phosphorus (TP)
Fbint( i.e.,
WWTPs )
17%
Nonpoint
83%
Figure 35 Sources of nutrient loads to Jordan Reservoir, 1997-2000
Modeling reports are available electronically from the Triangle J Council of Governments
http://h2o.enr,state.nc.us/trndl/SliecialStudies.htni#Jordan and the DWQ Modeling and TMDL Unit
(http://h2o.enr.state.nc.us/tiiidl).
36.4 TMDL and Management Targets
Management targets are those nutrient load associated with chlorophyll a standard compliance.
The nutrient response model is used to determine nutrient loads likely to produce compliance in
all parts of the lake, For Jordan Reservoir, the loads would primarily derive from the Morgan,
New Hope and Northeast Creeks, and the Haw River. Nutrient loading targets were determined
for three different parts of the reservoir, the Upper New Hope Arm, the Lower New Hope Arm,
and the Haw River Arm. Together, these three parts of the reservoir include all of the main body
of Jordan Reservoir, with the exception of coves. These three parts were selected based on
hydrology, frequency of standard violations, and the locations of reservoir tributaries.
The federal rules for Impaired waters and TMDLs require targets to consider seasonal variation
and critical conditions. Thus, targets are based on the summer and early fall seasons to consider
those times when predicted algal growth is most likely to result in standard violations.
Consistent with use support methodology, the nutrient loading targets were then determined
based on a standard violation frequency of less than 10 percent during the summer and early fall.
DRAFT Cahpter 36 — Jordan Reservoir and Haw River Watershed NSW .Strategy 318
The federal rules for Impaired waters also require targets to have a margin of safety. Per EPA
guidance (1999), the margin of safety is a required component of a TMDL and accounts for the
uncertainty about the relationship between pollutant loads and the quality of the receiving
waterbody. For this TMDL the DWQ has elected to use an explicit margin of safety determined
by adjusting the TMDL target from a 10% standard violation frequency to an 8% standard
violation frequency.
Reduction targets were evaluated in terms of nitrogen and phoshorus loads. Multiple
combinations of nitrogen and phosphorus loading scenarios that resulted in an 8% standard
violation frequency were considered. Ultimately, three different targets were selected for Jordan
Reservoir, corresponding to three different hydrologic areas of the lake. These targets are
summarized in Table 39 by percentage reduction:
Table 39 Nutrient Load Reduction Targets from 1997-2001 Baseline
Area
Total Nitrogen (TN)
Percent Reduction
Total Phosphorus (TP)
Percent Reduction
Upper New Hope Arm (above SR 1008)
35%
5%
Middle and Lower New Hope Arm (ftom SR 1008 to the narrows)
0%(a)
0%(a)
Haw River Arm
8%
5%
(a) Provides a loading cap equal to 1997-2001 baseline nutrient loads.
36.5 Point Source Management Strategies
There are numerous factors considered in the point source allocation strategy. These include the
distance from the reservoir and the amount and type of waste discharged. Further weighting of
the amount of wasteload allocations for each facility was evaluated using the actual annual
average flow during the 1997-2001 period, the permitted flow during the 1997-2001 period, and
the permitted flow in 2004. The final allocations are based on the permitted flow in 2004. The
result of the allocation strategy is presented below for the Upper New Hope and Haw River arms
of the reservoir. Detailed discussions can be found in the TMDL document.
36.5.1 Upper New Hope Arm of Jordan Reservoir
Converting the wasteload allocation from the Iake to the load at the effluent pipe yields a total
allowable end of pipe nitrogen load of 444,088 lbs/year and phosphorus load of 34,270 Ibs/year
for all facilities. All of the available loading was allocated to the existing facilities. Therefore,
there will be no new nitrogen or phosphorus bearing loads permitted in this watershed. There are
five facilities discharging greater than 100,000 gallons per day in the ,Upper New Hope Arm, as
shown in Table 40. These facilities account for 99.8% of the total permitted flow from point
sources. The discharge allocations for these five facilities provide equivalent concentrations for
each facility. For nitrogen, this equivalent concentration is 3.05 mg/l, and for phosphorus this
equivalent is 0.23 mgll. Therefore, the five large facilities will receive annual mass load limits
as shown in Table 40.
DRAFT Cahpter 36 — Jordan Reservoir and Haw River Watershed NSW Strategy 319
Table 40 Wasteload Allocations for Facilities >100K GPD
Permittee
Facility
Permitted
Flow
(MGD)
Percent
of Total
Flow
Wasteload Allocation
lbs/vr
TN
TP
City of Durham
South Durham WRF
20.0
42.1
185,648
14,154
Orange Water & Sewer Authority
Mason Farm WWTP
14.5
30.5
134,595
10,262
Durham County
Triangle WWTP
12.0
25.3
111,389
8,492
Fearrington Utilities
Fearrington Utilities WWTP
0.5
1.1
4,461
354
Whippoorwill LLC
Carolina Meadows WWTP
0.35
0.7
3,249
248
Total for large facilities
47.4
99.8%
439.520
33,510
36.5.2 Haw River Arm of Jordan Reservoir
Converting the wasteload allocation from the lake to the load at the effluent pipe yields a total
allowable end of pipe nitrogen load of 1,570,890 lbs/year and phosphorus load of 195,510
lbs/year. All of the available loading was allocated to the existing facilities. Therefore, there
will be no new nitrogen or phosphorus bearing loads permitted in this watershed. There are ten
facilities discharging greater than 100,000 gallons per day in the Haw River Arm, as shown in
Table 41. These facilities account for 99.3% of the total permitted flow from point sources. The
discharge allocations for these ten facilities provide equivalent treatment levels for each facility.
For nitrogen, this equivalent treatment level is 5.3 mgll, and for phosphorus this equivalent is
0.67 mg/l. Therefore, the ten large facilities will receive annual mass load limits as shown in
Table 41.
Table 41 Wasteload Allocations for Facilities > I OOK GPD
Permittee
Facility
Permitted
Flow
(MGD)
Percent I
of Total
Flow
Wasteload allocation
Ibs/y r
TN
TP
City of Greensboro
T.Z. Osborne WWTP
40.0
41.5
645,834
81,222
City of Greensboro
North Buffalo Creek WWTP
16.0
16.6
258,333
32,489
City of Burlington
Eastside WWTP
12.0
12A
193,750
24,367
City of Burlington
Southside WWTP
12.0
12.4
193,750
24,367
City of Reidsville
Reidsville WWTP
7.5
7.8
121,094
15,229
City of Graham
Graham WWTP
3.5
3.6
56,510
7,107
City of Mebane
Mebane WWTP
2.5
2.6
40,365
5,076
Town of Pittsboro
Pittsboro WWTP
2.0
2.1
32,292
4,061
Quarterstone Farm
Homeowners Association
Quarterstone Farm WWTP
0.2
0.2
3,229
406
Gen Raven Inc.
Altamahaw Division plant
0,15
0.2
2,422
305
Total for large facilities
95.85
99.3%
1,547,580
194,630
DRAFT Cahpter 36 -- Jordan Reservoir and Haw River Watershed NSW Strategy 320
Special Permitting Options. There are two permitting options available to provide existing
facilities flexibility with target compliance. One option is a bubble permit, which allows
multiple facilities owned by the same permittee to pool the mass loading limits. This will only
be an option for the Cities of Greensboro and Burlington. Another option is a group compliance
option, which allows multiple facilities owned by various permittees to pool the mass loading
limits for compliance purposes. The group compliance option provides the interested permittees
the ability to meet to the total mass limit even if an individual facility does not meet the
individual mass limit. This option also provides the ability for a new discharge with nitrogen or
phosphorus bearing loads to purchase loading from the existing compliance group members, if
they choose to sell. Both options are provided in the TMDL document.
36.6 Nonpoint Source Management Strategies
36.6.1 Introduction and Overview
The comprehensive stakeholder process yielded five potential nonpoint source management
scenarios covering the spectrum of possibilities between completely voluntary and regulation of
all significant nutrient sources. Recognizing that point sources would be regulated, equity
concerns led the stakeholders to favor some form of mandatory measures for all significant
source types.
The NPS management strategy proposed by DWQ staff builds from concepts implemented in the
Neuse and Tar -Pamlico River Basins. All of the following elements would apply in the
subwatersheds of both the Upper New Hope and Haw River arms, while only the riparian buffer
protection and new development controls — would apply in the Lower New Hope subwatershed.
The proposed strategy would require that:
■ All agricultural operations would collectively meet N and P export performance goals as
implemented by local committees.
■ Stormwater:
o All local governments would meet NPDES Phase 11 stormwater requirements of S 1210.
o All local governments would achieve stormwater N and P export performance goals from
all new and existing development.
■ DWQ would protect existing riparian buffers.
■ Persons who apply fertilizers to lands in the subwatershed would complete nutrient
management training and a written plan for those lands. A tax on fertilizer would fund the
implementation of this rule.
■ DWQ would work with DEH to develop programs to reduce N and P loading from on -site
wastewater (the EMC has no control over this management area).
■ DWQ would refine existing wastewater land application permitting programs as needed.
■ DWQ would work with DFR to require forestry pre -harvest notification (EMC has no
control over this management area).
■ DWQ would establish a trading program among point sources, between point and nonpoint
sources, and among nonpoint sources.
DRAFT Cahpter 36 — Jordan Reservoir and Haw River Watershed NSW Strategy 321
■ Local governments and agricultural committees would provide annual reports to the EMC.
The EMC would reexamine the management strategy every five years.
Table 42 presents the loading goals that have been calculated based on the percentage reductions
established for each subwatershed. The following sections describe the agriculture, urban
stormwater, buffer protection, nutrient management, and land application proposals in more
detail. Proposed requirements in the agriculture and development sections refer back to these
numeric loading goals.
Table 42 Loading Goals by Subwatershed
Nitrogen Phosphorus
Subwatershed Reduction Goal / Load Goal Reduction Goal / Load Goal
Upper New Hope 35% 4.1 Ib/ac-yr 5% 1.1 lb/ac-yr
Haw 8% 5.6 Ib/ac-yr 5% 1.5 ib/ac-yr
Lower New Hope 0% 4.8 Ib/ac-yr 0% 0.8 Ib/ae-yr
36.6.2 Agriculture Strategy
Applicable Subwatersheds: Upper New Hope and Haw.
What: Achieve and maintain net annual N and P loads from agricultural lands, in lb/ac-yr, equal
to or less than the targets allocated to an Arm's Subwatershed.
Who Administers: Local committees and a watershed oversight committee.
Who is Affected: All agricultural operations lying wholly or partly within the subwatershed,
including animal operations, pasture and horticulture.
How: Local committees would be responsible for registering all producers, drafting strategies to
achieve load targets, and submitting annual progress reports. A watershed oversight committee
would develop a site evaluation tool to account for loading, review and approve local strategies,
and provide reports to the EMC. Individual producers could comply automatically by
implementing standard BMPs or they could contribute as needed to their collective local strategy
and rely on it to comply.
When: Relative to rule effective date, producers register within 1 year, accounting tool completed
in 2 years, strategies developed in 3 years, targets reached in 5 years. If a local committee did not
meet its goal in 5 years, then producers in that area would be subject to additional implementation
needs as determined by the EMC.
DRAFT Cahpter 36 — Jordan Reservoir and Haw River Watershed NSW Strategy 322
36.6.3 Urban Stormwater Strategy
Applicable Subwatersheds: Upper New Hope and Haw subject to all elements. Lower New
Hope - subject to new development and redevelopment elements; existing development element
would not apply, and NPDES Phase 11 would apply only to local governments dictated by
51210.
What: NPDES Phase II stormwater measures per Senate Bill S1210 and a stormwater rule. The
rule would require new development and redevelopment activities to achieve and maintain net
annual N and P loads, in Ib/ac-yr, equal to or less than the targets allocated to an Ann's
watershed. Redevelopment would have the option of meeting the subwatershed's percentage
reduction targets relative to the previous development. Offsite trading options would be
provided. The rule would also require retrofitting of existing development.
Who Administers: All local governments wholly or partly within an arm's subwatershed except
as stated above.
Who is Affected: All new development and redevelopment projects, and existing development.
How: Local governments would adopt ordinances. A watershed oversight committee would be
established, responsible for developing a site evaluation tool for load accounting by all local
governments and for presenting the tool to the EMC. For existing development, local
governments would analyze their jurisdictions within a subwatershed to determine stormwater
BMPs needed for existing development to meet the loading targets allocated to that
subwatershed. They would prioritize BMP installations, develop implementation schedules, then
implement retrofits.
When: New development and redevelopment permitting would begin upon adoption of local
ordinances within stormwater rule timeframes. Local governments would set retrofit
implementation schedules for existing development within 5 years, then provide annual
implementation reports to the EMC. The EMC would reexamine the retrofit approach every 5
years.
DRAFT Cahpter 36 — Jordan Reservoir and Haw River Watershed NSW Strategy 323
36.6.4 Buffer Protection Strategy
Applicable Subwatersheds: All.
What: Existing vegetated riparian buffers would be protected and maintained on both sides of
perennial and intermittent streams, lakes, and ponds.
Who Administers: DWQ. DWQ may delegate programs to interested, qualified local
governments.
Who is Affected: Potentially all owners of property with riparian buffers.
How: 50 feet of riparian area would be protected on each side of water bodies. The first 30 feet
adjacent to the water, or Zone 1, would remain undisturbed with the exception of certain
activities. The outer 20 feet, or Zone 2, would be revegetated, with certain additional uses
allowed. Specific activities would be identified in the rule as "exempt", "allowable", or
"allowable with mitigation". Examples of "exempt" activities would include driveway and
utility crossings of certain sizes through zone 1, and grading and revegetating in zone 2.
"Allowable" and "allowable with mitigation" activities would require review by DWQ staff and
would include activities such as new ponds in drainage ways and road crossings. Mitigation
options would be defined. Footprints of existing uses within the buffer such as cropland,
buildings, commercial facilities, lawns, utility lines, and onsite wastewater systems would be
exempt. A newly vegetated buffer would not be required unless the existing use of the riparian
area changes.
When: Upon rule effective date. DWQ may propose a temporary rule to expedite protection.
36.6.5 Nutrient Application Management Strategy
Applicable Subwatersheds: All.
What: Completion of training and continuing education in nutrient management, completion
and implementation of a written nutrient management plan addressing both N and P for all lands
where nutrients are applied.
Who Administers: Not yet determined.
Who is Affected: All persons who apply fertilizer or biosolids to, or manage, ten or more acres
of: cropland; golf courses; recreational lands; rights -of -way; residential, commercial, or
industrial lawns and gardens; and other turfgrass areas. Cropland with a certified animal waste
management plan would be exempt.
How: Revenue from a tax on fertilizer would fund implementation of the rule
When: Upon rule effective date, persons affected would be required to complete initial training
and plans within five years. Persons who become subject after the effective date would be given
a shorter time period to comply. Biosolids applicators would be given until 2010 to begin
implementation of plans addressing both N and P. All persons would be required to comply with
DRAFT Cahpter 36 — Jordan Reservoir and Han> River Watershed NSW Strategy 324
continuing education requirements on a periodic basis.
36.6.6 Wastewater Land Application Strategy
DWQ would refine its existing permitting program as needed for the entire Jordan Lake
watershed. Changes may include requiring all nondischarge systems within a certain distance of
the lake or mainstems of the Haw or New Hope tributaries to meet reclaimed water effluent
standards, with the exception of individual single family homes. New and existing industrial
non -discharge facilities may be required to establish vegetated buffers compliant with the
riparian buffer rule.
DRAFT Cahpter 36 — Jordan Reservoir and Haw River Watershed NSW Strategy 325