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Chapter 1 – Chowan River Subbasin 03-01-01 19
Chapter 1
Chowan River Subbasin 03-01-01
Including: Chowan River (Upper), Wiccacon River, Ahoskie Creek and Bennetts Creek
(Merchants Millpond)
1.1 Subbasin Overview
The upper Chowan River subbasin is located in the Middle
Atlantic Coastal Plains ecoregion of North Carolina. The
Chowan River is formed at the border of Virginia and North
Carolina by the confluence of the Nottoway and Blackwater
Rivers. It then flows southeastward toward Albemarle
Sound. The Chowan River basin includes 1,315 square miles
in North Carolina, but the largest part of the drainage basin
(3,575 mi²) drains from Virginia. Major tributaries to the
Chowan River in this subbasin include the Wiccacon River
and Ahoskie Creek. A map of this subbasin including water
quality sampling locations is presented as Figure 3.
Portions of Merchants Millpond State Park and Chowan
Swamp State Natural Area are also located in this subbasin.
The Chowan Swamp State Natural Area, administered by the
Division of Parks and Recreation, protects more than 6,000
acres. Merchants Millpond supports a diverse assemblage of
aquatic plants including several rare species.
The largest municipalities in this subbasin include Ahoskie,
Aulander, and Winton. Based on 2000 census data, Winton’s
population grew 20 percent since 1990, but the other
municipalities’ populations declined. Refer to Chapter 8 for
more information about population growth and trends.
There are five minor National Pollutant Discharge
Elimination System (NPDES) wastewater discharge permits
in this subbasin with a total permitted flow of 0.04 MGD.
The largest facility is Aluminum Casting Technology in
Hertford County. Aluminum Casting Technology, permitted
to discharge 0.024 MGD of industrial process and
commercial waste into Ahoskie Creek (Section 1.4.3), has
discontinued its operation and will likely apply to rescind its
NPDES permit. There are ten non-discharge permits and nine stormwater permits in this
subbasin. Refer to Appendix III for the listing of NPDES permit holders.
A map including the locations of the NPDES facilities and water quality monitoring stations is
presented in Figure 3. Table 3 contains a summary of monitored waterbodies with their
associated assessment unit numbers (AU#) and lengths, monitoring data types, locations and
results, along with use support ratings.
Subbasin 03-01-01 at a
Glance
Land and Water Area
Total area: 579 mi2
Land area: 569 mi2
Water area: 10 mi2
Land Cover (percent)
Forest/Wetland: 73%
Cultivated Crop: 24%
Surface Water: 2%
Urban: <1%
Pasture/
Managed Herbaceous: 1%
Counties
Bertie, Gates and Hertford
Municipalities
Ahoskie, Aulander, Cofield,
Como, Gatesville and Winton
Monitored Waterbody Statistics
Aquatic Life:
Total: 137.7 mi
Total Supporting: 70.6 mi
Total Not Rated: 44.6 mi
Total Impaired: 22.5 mi
Recreation:
Total: 39.8 mi
Total Supporting: 39.8 mi
Planning Section
Basinwide Planning Section
February 21, 2007
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Figure 3 Chowan River Subbasin 03-01-01
04812162
Miles
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AU Number
Description
Length/AreaClassification
AL Rating REC RatingStation
Year/
ParameterResult % Exc
Aquatic Life Assessment
ResultStation
Recreation Assessment
Stressors Sources
CHO 03-01-01SubbasinTable 3
Ahoskie Creek (Ahoskie Swamp, Bear Swamp)
25-14-1
From source to Wiccacon River
33.3 FW MilesC;NSW NR
DB1 NR 2005
DB1 NR 2005
Nutrient Impacts WWTP NPDES
Habitat Degradation Agriculture
Bennetts Creek (Merchants Millpond)
25-17
From source to Chowan River
23.3 FW MilesC;NSW S
DB2 M 2005
Chinkapin Creek (Cessons Millpond)
25-14-3
From source to Wiccacon River
7.1 FW MilesC;NSW S
DB3 N 2005
CHOWAN RIVER
25a1
From North Carolina-Virginia State Line to near
Riddicksville
1.8 FW MilesB;NSW NR+SDA1 NCE
DA2 NCE
DA3 CE Low DO 15.1
DA4 NCE Low DO 9.3
DB5 G 2005
DA1 NCE
DA2 NCE
DA3 NCE
DA4 NCE
Low Dissolved Oxygen Unknown
25a2a
From near Riddicksville to Deep Creek
24.4 FW MilesB;NSW S SDA7 NCE DA7 NCE
25a2b
From Deep Creek to Wiccacon River
9.5 FW MilesB;NSW NR+S
DB4 F 2005
25a2c
From Wiccacon River to the subbasin 03-01-01/03-01-03
boundary
4.1 FW MilesB;NSW S SDA8 NCE DA8 NCE
CHO Subbasin 03-01-01
AU Number
Description
Length/AreaClassification
AL Rating REC RatingStation
Year/
ParameterResult % Exc
Aquatic Life Assessment
ResultStation
Recreation Assessment
Stressors Sources
CHO 03-01-01SubbasinTable 3
Cole Creek (Lilleys Millpond)
25-12-7
From source to Sarem Creek
9.5 FW MilesC;NSW S NR
DB6 M 2005
Nutrient Impacts Agriculture
Low Dissolved Oxygen Agriculture
Total Suspended Solids WWTP NPDES
Fecal Coliform Bacteria WWTP NPDES
Stony Creek
25-14-1-6
From source to Ahoskie Creek
2.2 FW MilesC;NSW S
DB7 M 2005
Wiccacon River (Hoggard Swamp)
25-14
From source to Chowan River
22.5 FW MilesC;NSW I
DB8 F 2005
Habitat Degradation Unknown
Nutrient Impacts Agriculture
Low Dissolved Oxygen Unknown
CHO Subbasin 03-01-01
AU Number
Description
Length/AreaClassification
AL Rating REC RatingStation
Year/
ParameterResult % Exc
Aquatic Life Assessment
ResultStation
Recreation Assessment
Stressors Sources
CHO 03-01-01SubbasinTable 3
Use Categories:Monitoring data type: Use Support Ratings 2005:
AL - Aquatic Life DF - Fish Community Survey E - Excellent S - Supporting, I - Impaired
REC - Recreation DB - Benthic Community Survey G - Good NR - Not Rated
DA - Ambient Monitoring Site GF - Good-Fair NR*- Not Rated for Recreation (screening criteria exceeded)
DL- Lake Monitoring F - Fair ND-No Data Collected to make assessment
P - Poor NR+-Not Rated because draft criteria used for rating
NI - Not Impaired
Miles/Acres m- Monitored N- Natural
FW- Fresh Water e- Evaluated M- Moderate CE-Criteria Exceeded > 10% and more than 10 samples
S- Severe NCE-No Criteria Exceeded
ID- Insufficeint Data Available
Results:
Results
Aquatic Life Rating Summary
S 70.6 FW Milesm
NR 11.3 FW Milesm
NR 33.3 FW Milesm
I 22.5 FW Milesm
278.5 FW Miles
Recreation Rating Summary
39.8 FW MilesSm
9.5 FW MilesNR e
367.0 FW Miles
Fish Consumption Rating Summary
416.3 FW MilesIe
CHO Subbasin 03-01-01
24 Chapter 1 – Chowan River Subbasin 03-01-01
There were eight benthic macroinvertebrate samples collected during this assessment period. Six
of the sites sampled in 2005 were also sampled in 2000. Overall, conditions in the subbasin
appear similar to the samples collected in 2000; however, four sites showed a decrease in biotic
index. Sites sampled indicated better water quality in the upper Chowan River than in the
Wiccacon River or the middle reaches of the Chowan River near Gatesville. The benthic sample
collected in the Wiccacon River indicated problems associated with nutrient enrichment and low
dissolved oxygen.
All of the basinwide swamp streams in this subbasin were sampled at least twice. Three of the
four streams sampled during the winter period rated Moderate in 2005. No swamp water quality
trends were identified. Data were also collected from four ambient monitoring stations. Refer to
the 2006 Chowan River Basinwide Assessment Report
(http://www.ncwaterquality.org/esb/Basinwide/ChowanBASINWIDEFinal.pdf) and Appendix I
for more information on monitoring.
All waters in this subbasin receive the supplemental classification of Nutrient Sensitive Waters
(NSW) in addition to the primary classification of Class C or Class B. See Chapter 5 for more
information on water classifications.
Waters in the following sections and in Table 3 are identified by an assessment unit number
(AU#). This number is used to track defined segments in the water quality assessment database,
list 303(d) Impaired waters, and to identify waters throughout the basin plan. The AU# is a
subset of the DWQ index number (classification identification number). A letter attached to the
end of the AU# indicates that the assessment is smaller than the DWQ index segment. No letter
indicates that the AU# and the DWQ index segment are the same.
1.2 Use Support Assessment Summary
All surface waters in the state are assigned a
classification appropriate to the best-intended use of
that water. Waters are regularly assessed by DWQ
to determine how well they are meeting their best-
intended use. Refer to Table 4 for a summary of use
support for waters in subbasin 03-01-01.
In this subbasin, use support was assigned for
aquatic life, recreation, and fish consumption
categories. Waters are Supporting, Impaired, Not
Rated, and No Data in the aquatic life and recreation
categories on a monitored or evaluated basis.
Waters are Impaired in the fish consumption
category on an evaluated basis based on fish
consumption advice issued by the Department of
Health and Human Services (DHHS).
For more information about use support
determinations, refer to Appendix II or the
Supplemental Guide to North Carolina’s Basinwide Planning: Support Document for Basinwide
Water Quality Plans found at DWQ’s website:
Table 4 Summary of Use Support
Ratings by Category in Subbasin 03-01-01
Use Support
Rating Aquatic Life Recreation
Monitored Waters
Supporting 70.6 mi 39.8 mi
Impaired*
22.5 mi
(16.3%) 0
Not Rated 44.6 mi 0
Total 137.7 mi 39.8 mi
Unmonitored Waters
Not Rated 0 9.5 mi
No Data 278.5 mi 376.0 mi
Total 278.5 mi 376.5 mi
All Waters 416.2 mi 416.3 mi
* The noted percent Impaired is the percent of monitored
mile/acres only.
** Total Monitored + Total Unmonitored = Total All
Waters.
Chapter 1 – Chowan River Subbasin 03-01-01 25
http://www.ncwaterquality.org/basinwide/SupplementalGuide.htm. Appendix V provides
definitions of the terms used throughout this basin plan.
1.3 Status and Recommendations of Previously and Newly Impaired
Waters
The following waters were either identified as Impaired in the previous basin plan (2002) 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 2008 303(d) list.
The current status and recommendations for addressing these waters are presented below, and
each is identified by an AU#. Information regarding 303(d) listing and reporting methodology is
presented in Chapter 11.
1.3.1 Chowan River [AU# 25a1, a2a, a2b, a2c]
2002 Status
The Chowan River was listed on the 2002 and 2004 303(d) list of impaired waters for low
dissolved oxygen (DO). Potential sources included agriculture and intensive animal feeding
operations. Through the Albemarle-Pamlico National Estuary Program, North Carolina signed a
Memorandum of Agreement (MOA) with the Virginia Department of Conservation and
Recreation to reduce nutrient levels crossing the state line and facilitate discussions to protect
and restore water quality along the coastal rivers and sounds. It was recommended that DWQ
continue to participate in the MOA and include the upper Chowan River in a swamp water study
plan to determine natural DO and pH levels in the river.
Current Status
The upper Chowan River [AU# 25a1], from the Virginia-North Carolina state line to near
Riddicksville (1.8 miles), is Not Rated+ in the aquatic life category. Site DB5 was sampled using
draft criteria for Coastal B Rivers. Coastal B rivers are defined as waters in the coastal plain that
are deep (nonwadeable), freshwater systems with little or no visible current under normal or low
flow conditions. Other characteristics may include an open canopy, low pH and low DO. Boat
sampling is required for these waters. Site DB5 received a Good benthic bioclassification based
on draft criteria for Coastal B rivers. Any bioclassification derived from sampling data should be
considered draft and not used for use support decisions; therefore the upper Chowan River is Not
Rated (BAU, July 2006).
The four ambient monitoring stations in this subbasin are located in the upper Chowan
watershed. Three of these ambient stations are located in Virginia. The fourth is located near
Riddicksville, near the benthic sampling site. The sampling locations are approximately one
mile downstream of the confluence of the Blackwater and Nottoway Rivers. The drainage area
above the sampling point is over 2,400 square miles. The substrate of this large, slow-moving
coastal river is mostly sand with some silt. Riparian vegetation appeared natural and undisturbed
and the stream banks were stable. No water quality standards were exceeded at the ambient
station near Riddicksville (DA4); however, the water quality standard for dissolved oxygen was
exceeded near the confluence of the Nottaway and Blackwater Rivers (DA3). This exceedence is
likely associated with swamp water drainage and is considered a natural condition. No water
quality standards were exceeded further upstream on the Nottaway (DA1) or Blackwater (DA2)
Rivers in Virginia. Heavy flooding events have been noted as a reoccurring problem on the
26 Chapter 1 – Chowan River Subbasin 03-01-01
Virginia side of the Chowan River basin. This may be associated with the development and the
loss of permeable surface.
The Chowan River [AU# 25a2b], from Deep Creek to the Wiccacon River (9.5 miles), is Not
Rated+ in the aquatic life category. A Fair benthic bioclassification at site DB4 was given based
on draft criteria for Coastal B rivers. This is a decrease of two bioclassifications from the Good
rating it received in 2000. In 2000 and 2005, the benthic site was rated on draft criteria for
Coastal B rivers. The Gatesville site is located approximately 15 miles downstream of the
Riddicksville site, and approximately three miles upstream of where the Wiccacon River joins
the Chowan. The drainage area is over 2,500 square miles. This sampling area is within one
mile downstream of CF Industries and Nucor Corporation. Currently, CF Industries, a closed
fertilizer plant superfund site, is being monitored and considered stable. This section of the river
is very different from the Riddicksville site mostly because of the slower velocities and a notably
greater depth in the channel. Benthic substrate consisted of mostly sand with some silt, and both
banks were dominated by forested wetlands.
Two other segments (AU#s 25a2a and 25a2c) are Supporting due to no criteria exceeded at
ambient stations DA7 and DA8.
2007 Recommendations
DWQ recommends that the upper Chowan River [AU# 25a1] be removed from the 2008 303(d)
list of impaired waters for water quality standards. Ambient monitoring indicates that no criteria
were exceeded beyond natural conditions. Benthic sampling also shows that the biological
community has improved since the previous assessment period. Increased interaction and
cooperation with Virginia Department of Conservation and Recreation is necessary to develop
appropriate strategies to manage potential pollutant runoff associated with increased flooding
events in the upper watershed.
1.3.2 Wiccacon River (Hoggard Swamp) [AU# 25-14]
2002 Status
The Wiccacon River was listed on the 2002 and 2004 303(d) list of impaired waters for aquatic
life. Potential sources were not identified; however, the watershed consists primarily of
agricultural land and many of the tributaries have been channelized throughout the years. DWQ
recommended the implementation of nonpoint source best management practices (BMPs) to
reduce nutrient and sediment loads.
Current Status
The Wiccacon River (Hoggard Swamp), from source to the Chowan River (22.5 miles), is
Impaired in the aquatic life category due to a Fair bioclassification at site DB8. A total of eight
benthic samples have been collected from the Wiccacon River since 1983, with all eight samples
remaining Fair and/or Poor. Benthic species collected in 2005 suggested nutrient enrichment,
degraded water quality and low dissolved oxygen. Further evidence of low dissolved oxygen in
the river was the abundance of freshwater sponges growing on snags in both 2000 and 2005.
The sample site for the Wiccacon River is located near a NC Wildlife Resources Commission
boat ramp off SR 1433. The drainage area (253 sq mi.) is partially channelized and ditched. The
water is cloudy and has a tannic color and conditions reflect an ongoing algal bloom. Benthic
substrate is dominated by silt and clay with a small amount of gravel present.
Chapter 1 – Chowan River Subbasin 03-01-01 27
Farming activities are considered more intense here than in other areas of the basin, with
predominantly poultry and hog operations. Within in the Wiccacon River watershed, there are
13 poultry operations, with eight of them having poultry litter drystacks, five without drystacks
and one is planned for installation in 2007. There are five operating swine facilities and one
facility is in the process of closure. Conservation Reserve Enhancement Program (CREP) has
contracted to maintain over 851 acres in trees for at least five years within this watershed.
2007 Recommendations
This segment of the Wiccacon River will remain on the draft 2008 303(d) list of impaired waters
and will be placed on a schedule for TMDL development. DWQ continues to recommend the use
of nonpoint source BMPs to reduce nutrient and sediment loads. Funds should be appropriated
to encourage more traditional BMPs (strip planting, no-till, cover crops) and new technologies.
DWQ will work closely with other resource agencies to prioritize implementation of efforts to
address agriculture impacts within this watershed.
1.4 Status and Recommendations for Waters with Noted Impacts
Based on DWQ’s most recent use support methodologies, the surface waters discussed in this
section are not Impaired. However, notable water quality problems and concerns were
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. The current status and recommendations for
addressing these waters are presented below, and each is identified by an AU#. Refer to Section
1.1 for more information about AU#. Nonpoint source program agency contacts are listed in
Appendix IV.
1.4.1 Cole Creek (Lilley’s Millpond) [AU# 25-12-7]
Cole Creek, from source to Sarem Creek (9.5 miles), is Supporting in the aquatic life category
due to a Moderate swamp benthic bioclassification at site DB6. This is the same rating it
received in 2000; however, benthic species collected during the 2005 biological sampling
indicated nutrient enrichment and lower dissolved oxygen levels. Significant noncompliance
issues were also identified at the permitted wastewater treatment facility for Buckland
Elementary School (Gates County Schools Permit NC0043974). Levels for total suspended
solids (TSS) and fecal coliform bacteria exceeded permit limits during the last two years of the
assessment period.
The sampling location of Cole Creek at US 158 in 2000 was erroneously labeled as NC 58 in the
prior basinwide report. This swamp stream was sampled at the same location in 2005. It is an
eastern tributary of Sarem Creek, and has a braided channel that flows into a single cut
(approximately five to seven meters wide) before flowing under US 158. In the past, the creek
has been straightened and channelized (>2 meters deep) from this channel cut downstream. The
swamp above this point appears to be in a more natural condition, averaging 0.5 to 1 meter in
depth. The drainage area here is 32 square miles. The landscape and lack of flow causes this
creek to appear lake-like (>20 meters wide) before exiting through an artificial cut. Thick
28 Chapter 1 – Chowan River Subbasin 03-01-01
filamentous algae had formed on woody surfaces such as logs and tree trunks. The benthic
surface was a muck of silt and clay.
2007 Recommendations
DWQ will continue to work with the County School System to improve the function and
compliance of the permitted WWTP. Agriculture and forestry BMPs are encouraged to limit
nutrient and sediment runoff from these predominant land use activities in Cole Creek’s
watershed. Residential development has increased in this watershed, creating the potential to
increase water quality degradation associated with residential areas (e.g., impervious surface
runoff, ineffective sewage treatment, lawn runoff). Local governments and agencies are
encouraged to proactively plan and implement conservation strategies to prevent water quality
degradation.
1.4.2 Ahoskie Creek [AU# 25-14-1]
Ahoskie Creek (Bear Swamp), from source to the Wiccacon River (33.3 miles), is Not Rated in
the aquatic life category due to Not Rated benthic bioclassifications at site DB1. Ahoskie Creek
was sampled twice in 2005 – once in February during the swamp sampling period and once in
August during the summer basinwide sampling period. The stream was rated based on swamp
criteria in the past (1995), but due to its transitional nature (from Coastal A to Swamp), a Not
Rated bioclassification was assigned until additional data can be collected from this site.
This section of Ahoskie Creek is located at NC 42 and has a drainage area of 125 square feet.
The stream has deep carvings and lacks in-stream habitat such as logs, snags and leaf packs.
Along one side of the channelized stream, the riparian zone showed little to no native woody
vegetation. The benthic substrate was made up of sand.
2007 Recommendations
The Town of Ahoskie holds Permit No. WQ0003855 for the continued operation of a 901,000
GPD wastewater treatment and disposal system that utilizes spray irrigation for disposal
purposes. The spray irrigation fields are incapable of handling the amount of wastewater that is
land applied. Because the hydraulic loading rates are higher than what the fields can accept,
significant runoff occurs. Recent investigations report average daily runoff to be approximately
200,000 to 300,000 GPD. Ahoskie Creek is the receiving waterbody for the runoff. Ahoskie
currently operates the facility under a Special Order by Consent due to the inability to maintain
permit compliance. Ahoskie has evaluated multiple alternatives or potential modifications to
bring the facility into compliance. However, no simple solution has been identified. Improving
inflow and infiltration will aid in eliminating non-wastewater from being processed by the
WWTP. DWQ will continue to work with the town to develop appropriate long-term wastewater
treatment facilities. As of July 2007, a draft permit for the Town of Ahoskie has been issued for
discharge into Ahoskie Creek.
The Town of Powellsville received a Clean Water Management Trust Fund grant to construct a
wastewater treatment facility that will help reduce pollutant delivery to Ahoskie Creek. The
project is to eliminate 168 failing septic tanks in the town by constructing a collection system
and land application waste treatment facility.
Chapter 1 – Chowan River Subbasin 03-01-01 29
1.4.3 Stony Creek [AU# 25-14-1-6]
Stony Creek, from source to Ahoskie Creek (2.2 miles), is Supporting in the aquatic life category
due to a Moderate swamp benthic bioclassification at site DB7. This is the same
bioclassification it received in 2000 where no serious water quality problems were identified. As
in 2000, no serious water quality problems were identified in 2005 and the biological community
did not indicate nutrient enrichment or low dissolved oxygen problems. There were even a few
aquatic species that are unique to the Chowan River basin.
Stony Creek is a southern tributary of Ahoskie Creek and drains an area of 39 square miles. The
habitat in this stream includes extensive cypress wetlands adjacent to the stream on both banks.
This watershed has active forestry operations and clear-cutting can be seen on the eastern
riparian zone of this site. The benthic surface consists of about 95 percent silt and fine particles
and five percent sand particles.
1.4.4 Bennetts Creek (Merchants Millpond) [AU# 25-17]
Bennetts Creek (Merchants Millpond) was not sampled during the last assessment period;
however, aquatic weeds were a noted impact in the 1997 basinwide water quality plan. Bennetts
Creek was sampled as part of a special study requested by the DWQ Washington Regional
Office (WaRO) during this assessment period to assess biological water quality conditions.
Bennetts Creek (Merchants Millpond), from source to the Chowan River (23.3 miles) is
Supporting in the aquatic life category due to a Moderate swamp benthic bioclassification at site
DB2, with the lowest total taxa of any stream or river in the Chowan River basin. The benthic
community represented a highly pollution tolerant community. Three permitted dischargers
(Gatesville and T.S. Cooper Elementary and Sunbury Primary Schools) are located in this
watershed and all have a history of noncompliance.
The sampling location of Bennett’s Creek is just below the outfall of the millpond, downstream
of SR 1400, and drains an area of 74 square miles. The sampling of this site was done in
February 2005 (during the swamp sampling period) upstream of one discharger (Gatesville
Elementary School WWTP), but downstream of the other two.
The biological community in Bennetts Creek did not contain pollution intolerant species as were
found in similar streams nearby. DWQ was unable to determine to what extent the millpond
itself was affecting the biological community. Impoundments such as a millpond can result in
downstream reaches having lowered dissolved oxygen levels and flows, as well as increased
temperatures. In winter, those affects are minimized and this sampling effort would likely not
have recorded these effects. Also, the large size of the millpond relative to Bennetts Creek could
act as a sink for upstream pollutants and mask the effects from the two dischargers noted above.
2007 Recommendations
Infrastructure and flow problems have been resolved with the Gatesville schools. Gates County
middle and high schools have tied into the Department of Correction Prison non-discharge
system (WQ0000267). Gully formation outside the facility shows signs of effluent leaking
(runoff) to surface waters. Better management of sprayfield operations is needed to help meet
compliance standards. DWQ recommends the facility seek additional land to expand sprayfield
application and to assess and manage for the amount of flows received from the schools.
30 Chapter 1 – Chowan River Subbasin 03-01-01
Agriculture and forestry are the predominant land use activities in this watershed and the SWCD
has identified this drainage as an area of concern. Implementation of agricultural BMPs are
needed to continue to protect the waters of Bennett Creek, a popular recreational area.