Little_Alamance_4b_Report_Final_Dec2014

CATEGORY 4B DEMONSTRATION PLAN TO ADDRESS BIOLOGICAL
IMPAIRMENT IN LITTLE ALAMANCE CREEK, NC

Prepared by:
NC Department of Transportation
Hydraulics Unit
1590 Mail Service Center
Raleigh, NC 27699-1590
919.707.6700

City of Burlington
Water Resources Department
1103 S. Mebane St.
Burlington, NC 27215
336.222.5145

City of Graham
201 South Main Street
PO Drawer 357
Graham, NC 27253
336.570.6700

In Partnership with the:
NC Division of Water Resources
1611 Mail Service Center
Raleigh, NC 27699-1611
919.707.9000

Final
December 2014

Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC

This page is intentionally blank

Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 ii December 2014
Table of Contents
Executive Summary ....................................................................................................................................... 1
1.0 Introduction ..................................................................................................................................... 3
1.1 Options for Addressing Biological Impairment ................................................................... 6
1.2 Description of the Category 4b Demonstration Approach ................................................. 7
1.3 Project Partners .................................................................................................................. 7
2.0 Historical Background ...................................................................................................................... 9
2.1 Eighteenth and Nineteenth Centuries ................................................................................ 9
2.2 Twentieth and Twenty-First Centuries ............................................................................. 12
3.0 Present Day Little Alamance Creek and its Watershed ................................................................. 17
3.1 General Watershed Conditions ......................................................................................... 17
3.2 Surface Waters and Wetlands .......................................................................................... 18
3.3 Riparian Condition ............................................................................................................ 19
3.4 Population and Land Use .................................................................................................. 19
4.0 Potential Stressors Causing Biological Impairment ....................................................................... 22
4.1 Existing Water Quality Data and Previously Identified Stressors ..................................... 26
4.2 Habitat, Riparian Condition, and Channel Geomorphology-Related Stressors ................ 30
4.3 Stream Geomorphology .................................................................................................... 31
4.4 Potential Point Source Stressors ....................................................................................... 32
4.5 Potential Nonpoint Source Stressors ................................................................................ 36
4.6 Potential Legacy Stressors ................................................................................................ 36
5.0 Pollution Controls .......................................................................................................................... 38
5.1 Public Education and Outreach and Public Involvement .................................................. 38
5.2 Illicit Discharge Detection and Elimination ....................................................................... 38
5.3 Erosion and Sediment Control .......................................................................................... 38
5.4 Post-Construction Runoff Control Program ...................................................................... 38
5.5 Pollution Prevention and Good Housekeeping ................................................................. 39
5.6 Collection System Improvements ..................................................................................... 39
5.7 Stream Buffers .................................................................................................................. 39
5.8 Stream Restoration and Enhancement ............................................................................. 40
5.9 Stormwater Retrofits ........................................................................................................ 40
5.10 Research ............................................................................................................................ 43
6.0 Implementation Plan ..................................................................................................................... 44
6.1 Public Education and Outreach and Public Involvement .................................................. 44
6.2 Illicit Discharge Detection and Elimination ....................................................................... 46
6.3 Erosion and Sediment Control .......................................................................................... 47
6.4 Post-Construction Runoff Control Program ...................................................................... 49
6.5 Pollution Prevention and Good Housekeeping ................................................................. 50
6.6 Collection System Improvements ..................................................................................... 52
6.7 Stream Buffers .................................................................................................................. 53
6.8 Stream Restoration and Enhancement ............................................................................. 54
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 iii December 2014
6.9 Stormwater Retrofits ........................................................................................................ 55
6.10 Research ............................................................................................................................ 56
7.0 Monitoring Plan to Track Effectiveness of Pollution Controls ....................................................... 58
7.1 Dashboard Approach ........................................................................................................ 58
8.0 Path Forward.................................................................................................................................. 61
8.1 Adaptive Management Process ........................................................................................ 61
8.2 Reporting Mechanisms ..................................................................................................... 62
9.0 Acknowledgements ........................................................................................................................ 63
References .................................................................................................................................................. 64
Appendix A Letters of Commitment to Category 4b Demonstration in Little Alamance Creek
Appendix B Historical Watershed Information
Appendix C Little Alamance Creek Existing Data Inventory

Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 iv December 2014
List of Tables
Table 1-1. Summary of streams within the Little Alamance watershed ...................................................... 5
Table 1-2. EPA/DWR-required elements for a Category 4b Demonstration ............................................... 7
Table 3-1. Hydrologic soil groups within the Little Alamance Creek watershed ....................................... 17
Table 3-2. Summary of Burlington, Graham, and NCDOT areas within the Little Alamance Creek
watershed ................................................................................................................................. 19
Table 4-1. Monitoring locations cross-referenced by reporting ID from select online databases and
reports ....................................................................................................................................... 24
Table 4-2. DWR biological sampling results in the Little Alamance Creek watershed .............................. 25
Table 4-3. Summary of reports or online databases describing water quality data in the Little
Alamance Creek watershed ...................................................................................................... 26
Table 4-4. Geomorphological values for select reaches ............................................................................ 31
Table 4-5. Permitted facilities in or near the Little Alamance Creek watershed ....................................... 34
Table 5-1. Select structural BMPs and their pollutant removal mechanism ............................................. 42
Table 6-1. External education BMPs to be implemented within the Little Alamance Creek
watershed ................................................................................................................................. 44
Table 6-2. IDDE BMPs to be implemented within the Little Alamance Creek watershed ......................... 47
Table 6-3. Erosion and sediment control BMPs to be implemented within the Little Alamance Creek
watershed ................................................................................................................................. 48
Table 6-4. Post-construction runoff BMPs to be implemented within the Little Alamance Creek
watershed ................................................................................................................................. 49
Table 6-5. PPGH BMPs to be implemented within the Little Alamance Creek watershed ........................ 51
Table 6-6. Collection system improvement BMPs to be implemented within the Little Alamance
Creek watershed ....................................................................................................................... 52
Table 6-7. Stream buffer BMPs to be implemented within the Little Alamance Creek watershed .......... 53
Table 6-8. Stream restoration and enhancement BMPs to be implemented within the Little
Alamance Creek watershed ...................................................................................................... 54
Table 6-9. Stormwater retrofit BMPs to be implemented within the Little Alamance Creek
watershed ................................................................................................................................. 55
Table 6-10. Research program BMPs to be implemented within the Little Alamance Creek
watershed ................................................................................................................................. 57
Table 7-1. Dashboard groups, toolbox items, and examples of associated tracking metrics ................... 59

Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 v December 2014
List of Figures
Figure 1-1. Little Alamance Creek watershed and surrounding region ........................................................ 3
Figure 1-2. Little Alamance Creek, tributaries, and neighboring cities ......................................................... 4
Figure 2-1. Historic map of Alamance County indicating six mills located along Little Alamance Creek
in 1893 ...................................................................................................................................... 11
Figure 2-2. Timeline of watershed events near Little Alamance Creek watershed, and state and
federal water quality regulations .............................................................................................. 13
Figure 3-1. Map of primary zoning categories in the Little Alamance Creek watershed ........................... 20
Figure 4-1. Biological, physicochemical, flow, and climate monitoring locations within the Little
Alamance Creek watershed. ..................................................................................................... 23
Figure 4-2. Weekly drought status history for the Haw subbasin (HUC 03030002) ................................... 25
Figure 4-3. Statewide drought status on August 21, 2007 ......................................................................... 27
Figure 4-4. Summary of recent (since 2002) monitoring data for Little Alamance Creek watershed. ....... 29
Figure 4-5. Active NPDES-permitted facilities within approximately 300 yards of Little Alamance
Creek watershed ....................................................................................................................... 33
Figure 5-1. Diagram of stream buffer zones ............................................................................................... 40
Figure 8-1. Adaptive management process to address biological integrity in Little Alamance Creek
watershed ................................................................................................................................. 61
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 vi December 2014
List of Acronyms
µg/L micrograms per Liter
BMP best management practice
CFR Code of Federal Regulations
cfs cubic feet per second
cfu colony-forming unit
COC certificate of coverage
DEMLR Division of Energy, Mineral and Land Resources
DWQ Division of Water Quality (name changed to DWR in 2013)
DWR Division of Water Resources
EMC Environmental Management Commission
EPA Environmental Protection Agency
FY fiscal year
GI green infrastructure
GIS geographic information systems
GREEN Guided Reduction of Excess Environmental Nutrients
HUC Hydrologic Unit Code
I&I infiltration and inflow
IDDE Illicit Discharge Detection and Elimination
LATT Little Alamance Creek, Travis Creek, and Tickle Creek
LID low impact development
mg/L milligrams per liter
MS4 municipal separate storm sewer systems
NC North Carolina
NCAC North Carolina Administrative Code
NCDENR North Carolina Department of Environment and Natural Resources
NCDMAC North Carolina Drought Management Advisory Council
NCDOT North Carolina Department of Transportation
NCEEP North Carolina Ecosystem Enhancement Program
NO3 nitrate
NPDES National Pollutant Discharge Elimination System
NRCS Natural Resources Conservation Service
NSW Nutrient Sensitive Waters
PCSP Post-Construction Stormwater Program
PTCOG Piedmont-Triad Council of Governments
PTRC Piedmont-Triad Regional Council
ROW right-of-way
SCMS Stormwater Control Management System
SMART Stormwater Management and Recovery of the Triad
SR State Route
SWPPP Stormwater Pollution Prevention Plan
TKN total Kjeldahl nitrogen
TMDL total maximum daily load
USFWS US Fish and Wildlife Service
USGS United States Geological Survey
WWTP wastewater treatment plant
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 1 December 2014
Executive Summary
The Little Alamance Creek watershed is located in Alamance County, North Carolina, within the upper
Cape Fear River Basin. The watershed is approximately 15.9 square miles in size and includes portions of
the cities of Burlington and Graham. Little Alamance Creek flows southeast into Big Alamance Creek,
approximately three miles upstream of its confluence with the Haw River.
In 2000, Little Alamance Creek was identified as impaired and included on the North Carolina 303(d) List
of Impaired Waters based on a “Poor” bioclassification rating due to the results of benthic
macroinvertebrate (benthos) sampling. Impairment for biological integrity is based on a narrative
standard that pertains to the aquatic life use designation. Biological integrity has been defined as "the
ability of an aquatic ecosystem to support and maintain a balanced and indigenous community of
organisms having species composition, diversity, population densities, and functional organization
similar to that of reference conditions” (15A NCAC 02B .0202). In streams and rivers, biological integrity
is often evaluated using quantitative and qualitative assessments of benthic macroinvertebrate and
other aquatic community assemblages. The health of these aquatic communities is determined by water
quality and habitat conditions as well as the interactions of complex physical, chemical, and biological
processes that shape these stream conditions.
Since 2000, water quality monitoring has confirmed the “Poor” benthos rating but has failed to identify
a specific pollutant(s) causing the impairment. A review of available water quality data concluded that
data on Little Alamance Creek are not sufficient to draw definitive conclusions on the source of
biological impairment or support the development of a total maximum daily load (TMDL) (URS, 2014).
The existing watershed reports attributed impairment to those factors that are typical of the complex
condition found in many urban watersheds, including hydro-modification, insufficient riparian buffer,
streambank erosion, pollutants in stormwater runoff, and degradation of instream habitat.

As described in section 2 of this report, most, if not all, of the stressors thought to be present in the
Little Alamance Creek watershed today may have been present long before its impaired status was
determined in 2000. Over the past three centuries, land and water resources in Alamance County have
been impacted by a multitude of wide-ranging human activities that have resulted in dramatic long-term
alterations to the natural hydrology and water quality of the streams in the watershed. Agricultural and
industrial activities, such as straightening and channelizing streams, and construction of dams for
gristmills, sawmills, cotton mills, and textile mills were common in the watershed and are well
documented. For many years the Little Alamance Creek was the receptor of industrial waste and raw
sewage. While the impacts of these pollutants cannot be quantified, it is likely that the effects of any
such legacy pollutants have had a lasting impact on the water quality in the watershed.

During the summer of 2012, representatives from the North Carolina Department of Transportation
(NCDOT) and the cities of Burlington and Graham (hereafter “project partners”) committed to
supporting a Category 4b Demonstration process in Little Alamance Creek watershed. As part of this
commitment, the project partners have prepared a Category 4b Demonstration Plan (this document)
describing management actions that, when implemented, will contribute to the overall goal of restoring
water quality and achieving a benthic macroinvertebrate community bioclassification of “Not Impaired”,
“Good-Fair”, or better.

Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 2 December 2014
Restoring biological integrity and aquatic life use in Little Alamance Creek will depend on the
implementation of pollution controls, management practices, and other strategies and activities
designed to mitigate known stressors. Collectively referred to as best management practices (BMPs),
these activities function to reduce or avoid pollutant inputs to receiving waters in order to achieve water
quality protection goals and restore and maintain the physical, chemical, and biological integrity of the
receiving waterbodies. BMPs provide this function through control of discharges that could alter natural
hydrology, reduction of pollutant loads that are delivered to a waterbody, and mitigation of other
stressors that might contribute to impairment. Section 6.0 of this document describes the specific BMPs
that the project partners will implement in Little Alamance Creek watershed and the schedule under
which those BMPs will be implemented. The project partners all share responsibility in implementing
their individual pollution controls for municipal operation and industrial activities being performed
within the boundaries of their municipal separate storm sewer system (MS4s) as well as at owned and
operated facilities. The proposed approach will enable each of the project partners to implement those
BMPs for which they are best suited.

BMPs and conditions in Little Alamance Creek will be reported through a dashboard approach described
in section 7. Four dashboard groups, “Streamside Enhancement”, “Public Involvement and Outreach”,
“Pollution Prevention and Reduction”, and “Stream Health” will be used to document implementation
activities designed to achieve water quality standards and track the effectiveness of those pollution
controls. Section 7 describes the dashboard groups along with the proposed BMPs and associated
reporting metrics.
It is anticipated that achieving the goal of “Not Impaired”, “Good-Fair”, or better benthos
bioclassification will require significant time and effort on the part of the project partners as well as
participation with other stakeholders within the watershed. As described in section 8, the toolbox items
will be implemented within an adaptive management framework. This framework for Little Alamance
Creek is built upon the overview of the historical and current state of the watershed (Sections 1–4) and
the assessment of appropriate pollution controls (Section 5–6). The adaptive management process
begins with the implementation of the toolbox items. Pollution controls and monitoring activities
performed by the project partners across the Little Alamance Creek watershed will then be tracked, and
efforts by the project partners will be assessed against available water quality data collected by North
Carolina Department of Environment and Natural Resources (NCDENR) and the project partners. Results
of this analysis will be used to adjust future actions performed by the project partners. A summary of
the information gathered during the adaptive management process will be distributed through a
proposed public website. In addition to reporting on watershed activities, the dashboard will serve the
project partners in communicating with and encouraging the general public to participate in
opportunities that help to restore biological health in Little Alamance Creek.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 3 December 2014
1.0 Introduction
The Little Alamance Creek watershed is located in Alamance County, North Carolina, within the upper
Cape Fear River Basin (Figure 1-1). The watershed is approximately 15.9 square miles in size and
corresponds with the United States Geological Survey (USGS) 12-digit hydrologic unit code (HUC-12)
030300020309 boundary. The watershed is located within the Southern Outer Piedmont ecoregion
(level IV), a subset of the larger Piedmont ecoregion (level III).

Figure 1-1. Little Alamance Creek watershed and surrounding region
The Little Alamance Creek watershed includes portions of the cities of Burlington and Graham, and is
drained by Little Alamance Creek and its tributaries: Coble Branch, Brown Branch (also referred to as
Willowbrook Creek), Dye Branch, and Bowden Branch (also known as Boyd Creek). The creek flows
southeast into Big Alamance Creek, approximately three miles upstream of its confluence with the Haw
River. Little Alamance Creek and four tributaries have been assigned an assessment unit ID by the North
Carolina Division of Water Resources (DWR) (Figure 1-2).
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 4 December 2014

Figure 1-2. Little Alamance Creek, tributaries, and neighboring cities
DWR (formerly Division of Water Quality, DWQ) regularly assesses waters throughout the state to
determine whether they are meeting the water quality criteria specified for their designated surface
water classification, as described in the North Carolina Administrative Code (NCAC) Title 15A NCAC 02B.
The results of these assessments are listed in the State’s biennial Integrated Report (DWQ, 2012a) to the
EPA, in fulfillment of the Clean Water Act (CWA). Each waterbody within the Integrated Report is
assigned a category based on its assessment results. Categories range from 1 to 5, with Categories 1 and
2 indicating no impairment, Category 3 indicating inconclusive data, and Categories 4 and 5 denoting
impairment from one or more parameters. Subcategories are denoted using letters.
Three named tributaries of Little Alamance Creek have not yet been assessed by DWR (Table 1-1). Coble
Branch was listed as a Category 3a due to inconclusive assessment results. In 2000, Little Alamance
Creek was listed as impaired (Category 5) by DWR due to a “Poor” bioclassification rating of the benthic
macroinvertebrate community (benthos). In 2013, Little Alamance Creek was assigned a “Good-Fair”
bioclassification for fish, but remained listed as Category 5 on the Impaired Waters List due to a benthos
bioclassification of “Poor”. Category 5 waterbodies not meeting defined water quality standards, i.e.,
waterbodies that are biologically or otherwise impaired and require a TMDL, are recorded in the State’s
303(d) list of impaired waters, which is incorporated into the North Carolina biennial Integrated Report.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 5 December 2014
Table 1-1. Summary of streams within the Little Alamance watershed (DWQ, 2012b)
Reach Name
Reach
Description
Assessment
Unit
Waterbody
Classifications*
2012
Integrated
Report
Category† Rating
Length
(miles)
Little
Alamance
Creek
From source to
Big Alamance
Creek
16-19-11 WS-V; NSW 5 Poor
bioclassification
(benthos, 2006)‡
12.6
1 Good-Fair
bioclassificiation
(fish, 2013)
Unnamed
Tributary (UT)
to Little
Alamance
Creek (Coble
Branch)
From source to
Little Alamance
Creek at Mays
Lake
16-19-11ut3 — 3a Not Rated 1.5
Brown Branch
(Willowbrook
Creek)
From source to
Little Alamance
Creek
16-19-11-1 WS-V; NSW — — 2.3
Dye Branch From source to
Brown Branch
16-19-11-1-1 WS-V; NSW — — 0.6
Bowden
Branch (Boyd
Creek)
From source to
Little Alamance
Creek
16-19-11-2 WS-V; NSW — — 3.8
Other UTs — — — — — >30.5
Notes:
* "WS-V" is Water Supply V. "NSW" is Nutrient Sensitive Waters.
† Categories range from 1 to 5, with letters used for subcategories. Categories 1 and 2 indicate no impairment; Category 3a
indicates inconclusive data; Category 3c indicates no data; Categories 4 and 5 denote impairment. The 2012 Integrated Report
lists overall ratings of “5” for assessment unit 16-19-11 and “3” for assessment unit 16-19-11ut3.
‡ Assessment unit 16-19-11 was first listed as impaired for poor bioclassification (benthos) on the 2000 303(d) List.

Impairment for biological integrity is based on a narrative standard that pertains to the aquatic life use
designation. Biological integrity has been defined as "the ability of an aquatic ecosystem to support and
maintain a balanced and indigenous community of organisms having species composition, diversity,
population densities and functional organization similar to that of reference conditions” (15A NCAC 02B
.0202). In streams and rivers, biological integrity is often evaluated using quantitative and qualitative
assessments of benthic macroinvertebrate and other aquatic community assemblages. The health of
these aquatic communities is determined by water quality and habitat conditions as well as the
interactions of complex physical, chemical, and biological processes that shape these stream conditions.
In contrast to some water quality impairment listings that indicate a specific pollutant of concern,
biological impairments simply indicate that an impaired condition exists. Biological assessments do not
provide a cause of impairment nor do they necessarily indicate what management approaches are best
suited to effectively address the impairment. Despite these limitations, the strength of biological
evaluations is that they provide the best indication of overall aquatic health because they reflect both
short and long-term stream conditions and reflect any impacts of stressors and pollutants that may not
be detected using episodic water quality chemistry measurements. In watersheds where no water
quality standard violations have been identified, biological impairments may indicate the presence of
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 6 December 2014
infrequent stresses, pollutants, or activities for which current water quality standards or criteria do not
exist or are inadequate in detecting.
1.1 Options for Addressing Biological Impairment
The goal of the CWA is “to restore and maintain the physical, chemical, and biological integrity of the
Nation’s waters” (33 U.S.C §1251(a)). Under Section 303(d) of the CWA, states are required to biennially
prepare and submit to the United States Environmental Protection Agency (EPA) a report that identifies
waters that do not meet or are not expected to meet surface water quality standards after
implementation of technology-based effluent limitations or other required controls. Impaired
waterbodies must be addressed through the preparation of total maximum daily loads (TMDLs), or other
appropriate management action, including technology-based effluent limitations, more stringent
effluent limitations, or other pollution control requirements (e.g., best management practices) that are
stringent enough to achieve water quality standards (see 40 CFR 130.7(b)(1)) within a reasonable period
of time. The list of impaired waters awaiting the development of a TMDL is referred to as the “303(d)
List”.
As its name implies, a TMDL is intended to improve water quality by defining the maximum loading
allowable for a given pollutant. When a waterbody is impaired for a known pollutant with identifiable
pollutant sources, TMDLs provide an effective tool for defining the existing and allowable pollutant load
and support activities that restore a waterbodies’ intended uses. However, in watersheds where the
pollutant or sources of impairment are unknown, existing and allowable loads cannot be calculated and
other management approaches are needed to assess existing conditions, stressors, or sources
contributing to impairment, and potential implementation activities or approaches. In densely
populated or urbanized watersheds, water quality and biological health may be compromised as a result
of multiple physical, chemical, and biological stressors rather than a single pollutant or source.
In 2001-2003, the North Carolina Department of Environment and Natural Resources (NCDENR)
Watershed Assessment and Restoration Program (WARP) performed intensive water quality and
watershed studies in eleven biologically-impaired streams to identify the most likely causes of
impairment, determine the major watershed activities and pollution sources contributing to those
causes, and define watershed strategies for restoration activities and best management practices
(BMPs) (NCDENR, 2014). In all eleven watersheds evaluated, the WARP reports concluded that biological
impairment was caused by multiple stressors and sources and that restoration activities should include a
wide range of management actions. Examples of management actions cited in the WARP studies include
restoring stream channels in conjunction with stormwater retrofit BMPs, restoring riparian vegetation
and aquatic habitat, implementing actions to reduce organic debris and nutrient loading, mitigating
hydrological effects from existing development, addressing toxicological sources, improving sediment
and erosion control practices, implementing BMPs to prevent the delivery of pesticides to the stream,
implementing education programs, and collecting additional data. These recommendations, along with
similar conclusions from other urban watershed studies, suggest that biological impairment is complex,
and that a broad range of management actions are generally needed to understand and address these
types of impairment.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 7 December 2014
1.2 Description of the Category 4b Demonstration Approach
The EPA encourages the use of alternative approaches, in addition to TMDLs, to achieve the water
quality goals of the State (EPA, 2013a). One listed alternative is known as the “Category 4b
Demonstration”. An impaired waterbody listed as Category 5 may be re-categorized as Category 4b
when the management strategy that is expected to address the identified impairment(s) is deemed
adequate by EPA. The process of approving a Category 4b Demonstration occurs through EPA’s formal
approval of the 303(d) List.
The objective of a Category 4b Demonstration is to “promote implementation activities designed to
achieve water quality standards in a reasonable period of time” (DWQ, 2011). To achieve this objective,
the EPA has identified six elements that should be addressed within a Category 4b Demonstration (Table
1-2). These six elements are also referenced within NCDENR’s Category 4b guidance (DWQ, 2011).
Specifically, a Category 4b Demonstration should clearly identify the Category 5 waterbody and its
impairment, describe the water quality standard and the pollution controls to be implemented in order
to reach said target, estimate the time upon which the specific water quality standard will be met,
provide a schedule for implementation of various pollution controls, specify a monitoring plan, and
provide a commitment to revising the Category 4b Demonstration, as necessary, toward meeting the
stated water quality target. As presented in Table 1-2, each EPA element has been included in this
Category 4b Demonstration for Little Alamance Creek.
Table 1-2. EPA/DWR-required elements for a Category 4b Demonstration (EPA, 2006a; DWQ, 2011)
Category 4b Demonstration Six Required Elements
Corresponding
Report Sections
1 Identification of waterbody assessment unit number(s) and
statement of the problem causing the impairment
Sections 1.0, 3.0, and 4.0
2 Description of pollution controls and how they will achieve water
quality standards (WQS)
Section 5.0
3 Estimation or projection of the time when WQS will be met Section 8.0
4 Schedule for implementing pollution controls Section 6.0
5 Monitoring plan to track effectiveness of pollution controls Section 7.0
6 Commitment to revise pollution controls, as necessary Section 7.1

1.3 Project Partners
In 2011 and 2012, representatives from NCDENR, NCDOT, the Cities of Burlington and Graham, and
other municipalities participated in meetings to discuss biologically-impaired waterbodies and strategies
for addressing impairment when the pollutant(s) causing impairment is unknown. During the course of
these meetings, the Category 4b Demonstration, along with other options, was discussed as an
alternative to a TMDL. After investigating these options, NCDOT, the Cities of Burlington and Graham
(hereafter referred to as the “project partners”) voluntarily committed to supporting a Category 4b
Demonstration process to address impairment in Little Alamance Creek. As part of this commitment, the
project partners have evaluated watershed data and information and jointly prepared a Category 4b
Demonstration report (this document) describing management actions that, when implemented, will
contribute to the overall goal of improving water quality and achieving a benthic macroinvertebrate
community bioclassification of “Not Impaired”, “Good-Fair”, or better. Formal letters of those
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 8 December 2014
commitments, along with DWR’s agreement to support a Category 4b Demonstration process in the
Little Alamance Creek watershed, are presented in appendix A.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 9 December 2014
2.0 Historical Background
Prior to European settlement of the area, the Little Alamance Creek watershed was likely a
predominately forested watershed interspersed with piedmont prairie maintained by fire and large
grazing animals such as bison and elk. Native American populations are known to have inhabited the
area and likely maintained or created open areas in the forest to raise crops and enhance hunting
opportunities of wild game. It is assumed that Native Americans did not have a major impact on water
quality and that Little Alamance Creek had abundant aquatic life and a stable hydrologic regime.
Beginning with the arrival of Europeans in the early 1700s, the land and water resources in Alamance
County have sustained the impacts of a multitude of wide-ranging human activities that have resulted in
dramatic long-term alterations to the natural hydrology and water quality of the streams in the
watershed.
Like many urban streams in the Piedmont of North Carolina, Little Alamance Creek has followed an
evolution from a pristine resource to an agrarian utility to an industrial engine to a waste conveyance to
the impaired urban drainages we see today. Likewise, the level of public concern and subsequent
governmental regulations regarding water resources have evolved over the years from non-existent to
driven by hygiene and sanitation, then water supply protection, and now reestablishing aquatic life and
biodiversity. The various industrial enterprises and lack of regulations likely resulted in the discharge of
pollutants to Little Alamance Creek and its tributaries. The effects of any such legacy pollutants may
have had a lasting impact on the water quality in the watershed.
The present-day condition of Little Alamance Creek is best understood in the context of these historical
activities as well as more recent efforts to restore and protect water resources. This section provides a
high-level overview of significant land use practices and activities affecting Little Alamance Creek since
the eighteenth century and also highlights key water quality protection measures. Major events that
affected water quality in and around the Little Alamance Creek watershed, as well as major state and
federal water quality regulations, are presented in Figure 2-2. As water quality regulations are typically
enacted to address existing concerns, there is often a temporal lag between watershed events and
water quality regulations. A more detailed historical commentary for the watershed is provided in
appendix B.
2.1 Eighteenth and Nineteenth Centuries
2.1.1 Land Use Changes
European settlement of the area began in the early eighteenth century. Quakers, Scots-Irish
Presbyterians, and German Lutherans from Pennsylvania were among early immigrants who established
numerous settlements in Alamance County (Vacca and Briggs, n.d.). Industrialization and urbanization
during this time influenced how water resources were altered and used during this and successive
periods.
2.1.1.1 Agricultural Impacts
Agriculture and silviculture were significant land uses in both the eighteenth and nineteenth centuries.
Timber was harvested and sawmills were constructed to supply lumber to build settlements and
eventually towns. The earliest farming was for subsistence and included growing fruits and vegetables
and raising cattle and hogs. Later in the eighteenth century, cotton, corn, wheat, oats and rye, flax, and
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 10 December 2014
tobacco were grown as commercial crops. Many streams were straightened and channelized to
maximize efficient use of arable land and enhance drainage. Dams were also constructed, as the streams
provided the channel slope and flow needed for mill races and water wheels. Numerous gristmills were
built along the Haw River and its tributaries to produce corn meal and flour. By 1890, there were also a
number of sawmills in Alamance County. Figure 2-1 indicates six hydro-powered mills located along
Little Alamance Creek in 1893.
2.1.1.2 Industrial Impacts
During the Industrial Revolution some early mill sites became the location for textile mills. Most textile
mills provided water power for spinning machines and looms; some mills were later converted to steam
power. By the late 1830s, there were 41 gristmills in Alamance County (Vacca and Briggs, n.d.). In 1879,
there were 40 gristmills and 24 sawmills. Over half of these mills were built during the previous 20 years
(Lounsbury, 1980). As late as 1928 there were still 30 mills, mill dams, or mill sites located in Alamance
County.
The first cotton mill in Alamance County was built on the Haw River in 1832, and by 1890, there were 17
cotton mills in the county. At least three late nineteenth century cotton mills were built near the
headwaters of several Little Alamance Creek tributaries.
Colorfast indigo dye was used to produce the first colored cotton goods in the South (Vincent, 2009).
The production and use of indigo dye was a potential source of water pollution. In addition to the
reactants normally used in the production of the dye, caustic lye (sodium hydroxide) and slaked lime
(calcium hydroxide) were sometimes added during the dyeing process. The process also used a mordant
agent to help set the dye on the fabric. Mordant agents were often metal oxides and included, at
various times, tannic acid, alum, urine, chrome alum (chromium potassium sulfate), sodium chloride,
and certain salts of aluminum, chromium, copper, iron, iodine, potassium, sodium, and tin . Chemical
byproducts from the dyeing process had the opportunity to enter the environment at three stages of
production: during the manufacturing of the dye, during the application of the dye to the yarn or cloth,
and during the disposal of industrial wastes.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 11 December 2014

Figure 2-1. Historic map of Alamance County indicating six mills located along Little Alamance Creek in 1893
(Spoon, 1893)
2.1.2 Water Quality Regulation and Legislation
In the 1700s, the primary interest in public water supply was focused on fire protection (Howells, 1989).
By the 1800s, there was a growing concern for hygiene and sanitation, and a greater awareness of the
connection between waste management and illness. The late 1800s saw a series of state legislative
Big Alamance Creek
Little Alamance Creek
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 12 December 2014
actions that constituted the first steps toward managing and protecting water resources. In 1877, the
North Carolina General Assembly created the North Carolina Board of Health, which was primarily
concerned with water quality in terms of sanitation. Before long, public concern grew to include aquatic
life and nuisance conditions, and the State passed an Act prohibiting the use of poisons to catch or kill
fish in waters of the state (Howells, 1990). In the 1890s, the North Carolina Board of Health was given
authority over all inland waters, including protection of watersheds for domestic water supplies. Before
the end of the century, all municipal water supplies in North Carolina were required to be inspected and
have chemical and bacteriological analyses. At the federal level, the first legislation to address water
pollution was the 1899 Refuse Act, which had the primary purpose of preventing discharge of refuse
into navigable waters.
2.2 Twentieth and Twenty-First Centuries
2.2.1 Land Use Changes
In the late nineteenth century, the first hosiery mills in Alamance County began operation. In the 1920s,
many cotton mills were converted to produce rayon and other fabrics. Byproducts of rayon production
included carbon disulfide, hydrogen sulfide, and zinc. By 1934, Burlington Mills was the largest producer
of rayon in the United States (Vacca and Briggs, n.d.).
2.2.2 Water Quality Regulation and Legislation
2.2.2.1 1900–1970
As the timeline in Figure 2-2 illustrates, the twentieth century saw a rapid expansion in efforts to control
degradation of water resources. In the early 1900s, water purification standards were adopted and
bacteriological analyses using coliform indicator bacteria came into practice. Soon after, legislation was
enacted to prevent stream pollution from the disposal of mining waste (Howells, 1990). A Fisheries
Commission Board was created to oversee commercial fishing and to enforce discharges of substances
harmful to fish.

Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 13 December 2014

Figure 2-2. Timeline of watershed events near Little Alamance Creek watershed, and state and federal water
quality regulations
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 14 December 2014

Figure 2-2. Timeline of watershed events near Little Alamance Creek watershed, and state and federal water
quality regulations (continued)
The most significant piece of legislation at the federal level was the Federal Water Pollution Control Act,
enacted by the United States Congress in 1948. It was the beginning of federal–state cooperative water
pollution control programs that continue today. In 1951, the North Carolina General Assembly enacted
the State Stream Sanitation Act which established the State Stream Sanitation Committee (Howells,
1989). The law authorized a comprehensive stream pollution control program determined by stream
classifications based upon best usage categories of the waterway. In 1955, acts were adopted to prohibit
discharges of raw sewage, industrial waste, and other substances into the Haw River and the Northeast
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 15 December 2014
Cape Fear River. Pollution of these waters was defined as conditions not meeting their best usage
classification or violation of applicable water quality standards (Howells, 1990). The Federal Water
Pollution Control Act was amended in 1956, 1961, and 1965, offering additional protections to streams
by enhancing wastewater treatment efforts and establishing water quality standards.
Municipal Sewage Discharge: Prior to the 1950s, there was no effective statewide law to control
discharges to waters of the state (DeVane, n.d.). Discharge of raw sewage directly to streams was
common. In the 1930s, the North Carolina Board of Health frequently cited stream pollution as one of
the State’s greatest problems. Like many communities at that time, the City of Burlington did not have a
wastewater treatment plant (WWTP), and sewage was discharged directly into Little Alamance Creek. In
1950, numerous complaints against the City of Burlington were filed with the North Carolina State Board
of Health by citizens living along Little Alamance Creek. In 1951, a claim in the amount of $20,000 was
filed against the City of Burlington by two residents of Graham for alleged damages arising from the
City’s discharge of sewage into Little Alamance Creek (The Burlington Daily Times-News, 1951).
In fact, more complaints had been filed against the City of Burlington than any other city in the state, so
the State Board of Health urged the City to construct a sewage disposal plant to avoid multiple law suits
(The Burlington Daily Times-News, 1950). In 1952, a WWTP located near what is now South Graham
Park began operations. Several years later, a major interceptor sewage line and a WWTP for the Little
Alamance Creek drainage area was built near the confluence of Big Alamance Creek and the Haw River
and the previous WWTP was closed. Currently, wastewater from within the watershed is treated by
either the South Burlington WWTP or the City of Graham WWTP. Both WWTPs discharge to surface
waters outside of the Little Alamance Creek watershed.
2.2.2.2 1970s–Early 2000s
Industrial Wastewater: By 1970, sewage management had improved substantially, but industrial
wastewater discharges were still a major source of degradation in receiving streams. In 1970,
regulations were adopted requiring cities receiving industrial wastes to adopt sewer use ordinances,
which were used to reimburse cities for the cost of treating industrial waste. The Federal Water
Pollution Control Act was again amended in 1972, requiring that all industrial discharges be permitted
under the National Pollution Discharge Elimination System (NPDES). Permitting was also required for
sanitary waste discharges. In 1975, the EPA delegated responsibility to North Carolina for the
administration of NPDES permits. With the 1972 amendments, the original focus on protection of public
water supplies was broadened to include protection of all water uses. Section 401 of the legislation
authorized states including North Carolina to require water quality certifications for federally permitted
or licensed activities that could result in a discharge of pollutants into waters of the United States.
Nonpoint Source Pollution: Throughout the 1970s, several other regulations were passed, including the
Sedimentation Pollution Control Act, which regulated construction sites and land-disturbing activities.
In 1989, the State reported that 30% of North Carolina’s streams were degraded, and nonpoint source
pollution was cited as the primary source of degradation (Howells, 1990). In order of importance,
agriculture, urban runoff, and construction with sediment were identified as the most widespread cause
of degradation. In response, the State created agriculture and forestry cost-share programs to match
funds for BMPs, and a water supply watershed protection program. State legislation and/or rules
followed for mandatory nonpoint source pollution control in water supply watersheds, undisturbed
buffer zones along trout waters, BMPs for silviculture, increased funding for agriculture, nonpoint
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 16 December 2014
source protection for High Quality Waters, expansion of nonpoint-related groundwater programs,
watershed management programs, waste reduction and recycling, and wetland protection.
In 1989, the State began planning for the development and adoption of a statewide stormwater
management plan, and also adopted legislation to enhance protection of water supply watersheds. In
the same year, NCDENR was created to consolidate all environmental, environmental health, and
natural resource programs into a single state agency (Howells, 1990).
Nutrient Management: In 1979, a supplemental usage classification was approved for Nutrient Sensitive
Waters for surface waters experiencing excessive algal or other aquatic plant growth. Following an
extensive fish kill in the Neuse River in 1995, NCDENR began focusing on reducing nitrogen in several of
the state’s rivers through the use of buffer rules. In 1997, buffer rules were adopted in the Neuse River
Basin. Subsequently, buffer rules were adopted in the Randleman Lake Water Supply Watershed in
1999, in the Tar-Pamlico River basin in 2000, in the Catawba River basin in 2004, in the Goose Creek
Water Supply Watershed in 2009, and in the Jordan Lake Water Supply Watershed in 2009.
In 2009, the Environmental Management Commission adopted the Jordan Lake Nutrient Management
Strategy rules. The Little Alamance Creek watershed, as well as the entirety of the cities of Burlington
and Graham, is within the Jordan Lake watershed and subject to the Jordan Lake Nutrient Strategy rules.
The strategy is intended to restore and maintain the lake’s classified uses. The rules require stormwater
management plans for new development, public education, inventory of municipal separate storm
sewer system systems (MS4s), removal of illicit discharges, retrofit opportunities for existing
development, and BMP maintenance for local communities within the Jordan Lake Watershed. The rules
also include options to offset nutrient loads by purchasing reduction credits from other sellers. Diffuse
flow into 50-foot wide riparian buffers is required for all intermittent and perennial streams, lakes,
ponds, and reservoirs. Nitrogen and phosphorus waste load allocations (WLA) are required for existing
wastewater treatment facilities. Nutrient reduction goals are required for agricultural operations as well
(NCDENR, n.d.-a).
NPDES Stormwater Program: In 1990, Phase I of the NPDES stormwater program was established and
required permit coverage for municipalities with populations of 100,000 people or more. Requirements
included public education, illicit discharge detection and elimination, construction and post-construction
programs, pollution prevention and good housekeeping, storm sewer system inventory and mapping,
and water quality monitoring (NCDENR, 2007). Phase II of the NPDES stormwater program began in
2003. The federal rules required certain smaller MS4 operators to meet similar Phase I requirements for
larger municipalities (EPA, 2005).
In 1997, the Environmental Management Commission adopted goals to improve nutrient-impaired
waters and developed management plans to reduce nutrient inputs from point sources and nonpoint
sources. In 2005, rules were established to implement nutrient management strategies to protect
drinking water supply reservoirs including TMDL limits when necessary (NCDENR, n.d.-b).
Additional content on the history of both the Little Alamance Creek watershed and North Carolina water
quality regulations are located in appendix B.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 17 December 2014
3.0 Present Day Little Alamance Creek and its Watershed
3.1 General Watershed Conditions
3.1.1 Topography
The Little Alamance Creek watershed is located in the Piedmont physiographic province of North
Carolina. The 15.9 square mile watershed ranges in elevation from approximately 450 feet at the
confluence with Big Alamance Creek to 700 feet in the headwaters. The Little Alamance Creek
watershed is located entirely within one the Southern Outer Piedmont (Level IV) Ecoregion. This
ecoregion has lower elevations, less relief, and less precipitation than its neighboring ecoregions. The
landform class is mostly dissected irregular with some rounded hills and ridges.
3.1.2 Geology and Soils
The Little Alamance Creek watershed lies in the Carolina Slate Belt. The watershed is composed mainly
of three geological types: metamorphosed granitic rock in the northern headwaters of the watershed,
and metamorphosed gabbro and diorite, and mafic metavolcanic rock in the middle and lower portions
of the watershed. Gneiss, schist, and granite are typical rock types, and the rocks are more intensely
deformed and metamorphosed than the geologic materials in neighboring ecoregions. The rocks are
covered with deep saprolite and mostly red, clayey subsoils.
An insignificant amount of soil in the watershed is classified as hydrologic soil group (HSG) A (sandy; low
runoff potential), with the remaining identified soil portion composed of types B, C, and D soils (Table
3-1). The predominant soil association in the Little Alamance Creek watershed is Mecklenburg-Enon-
Cecil, comprising almost the entire watershed south of US Highway 70 (US 70). The Vance-Appling-Enon-
Cecil association is found north of US 70 and encompasses the majority of the hydric soils found in the
watershed. Hydric soils can be found throughout the watershed within the floodplain, but most
predominantly along the Little Alamance Creek streambeds and surrounding area north of US 70.
Table 3-1. Hydrologic soil groups within the Little Alamance Creek watershed
Soil Group† Soil Texture Runoff Potential
Percentage of
Watershed Area
A Sandy Low 0.3
B Loamy Sand Moderately Low 25.0
C Sandy Clay Loam Moderately High 38.0
D Clayey High 12.0
N/A* — — 24.0
Open Water — — 0.6
† Soil data downloaded from http://datagateway.nrcs.usda.gov/GDGOrder.aspx
* Soil group data was not available for highly urban areas
3.1.3 Climate
Alamance County has a mild year-round climate with four seasonal changes. The annual normal mean
temperature is 59.2 °F, with the annual normal minimum and maximum temperatures of 47.1 °F and
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 18 December 2014
71.2 °F, respectively. The annual normal rainfall is approximately 45 inches, while the average annual
frozen precipitation is 4.0 inches (State Climate Office, 2013, weather station ID 311239).
The Little Alamance Creek watershed has experienced periods of moderate to exceptional drought in
recent years. The North Carolina Drought Management Advisory Council has recorded the weekly
drought status for each 8-digit HUC since January 2000. Additional precipitation and drought
information is presented in section 4.1.2.
3.2 Surface Waters and Wetlands
3.2.1 Little Alamance Creek and Its Tributaries
The Little Alamance Creek watershed is located in the Upper Cape Fear River Basin, within the Haw River
subbasin. Little Alamance Creek flows into Big Alamance Creek approximately three miles upstream of
its confluence with the Haw River. There are approximately 50 miles of perennial and intermittent
streams in the watershed as determined by the USGS Quadmap. The Little Alamance Creek assessment
unit is identified as 16-19-11. The assessment unit includes 12.6 freshwater miles from source to Big
Alamance Creek. Little Alamance Creek is designated a Class C water, indicating that it is protected for
secondary recreation, fish consumption, biological integrity, agriculture, and other uses suitable for
Class C. Little Alamance Creek is also classified as a Water Supply V (WS-V) and Nutrient Sensitive Waters
(NSW).
Key tributaries to the Little Alamance Creek include Bowden Branch, also known as Boyd Creek (3.8
miles); Brown Branch also known as Willowbrook Creek (2.3 miles); and Dye Creek (0.6 miles). Bowden
Branch originates at Snoffers Lake north of Providence Road and drains to the south to Little Alamance
Creek immediately north of Monroe Holt Road in the city of Graham. Bowden Branch divides the cities
of Burlington and Graham north of Interstate 85 (I-85). The contributing watershed north of I-85 is
primarily urban as evidenced by a lack of naturally-draining tributaries. In the southeast portion of the
watershed, south of I-85, the watershed is primarily undeveloped.
Brown Branch drains the older neighborhoods surrounding Burlington to the southwest of the
watershed. The headwaters originate near West Webb Avenue and converge with Little Alamance Creek
downstream of Pine Hill Cemetery. Much like Bowden Branch, there are very few naturally draining
tributaries.
Dye Creek is a tributary to Brown Branch. It originates near downtown Burlington and parallels Mebane
Street before it joins Brown Branch downstream of Pine Hill Cemetery. The contributing watershed
includes older neighborhoods southwest of downtown Burlington and sporadic industrial and
commercial developments.
3.2.2 Wetlands and Surface Waters
Wetland and surface waters can play an important role in balancing the hydrology of a watershed and
providing instream water quality treatment. Approximately 15.2 acres of freshwater wetlands
(emergent, shrub/scrub, and forested) and 66.4 acres of ponds and lakes are within the Little Alamance
Creek watershed (USFWS, 2013). Mays Lake is the only significant surface impoundment on Little
Alamance Creek. It is approximately eight acres in size and is located at the confluence of Coble Branch
and Little Alamance Creek, immediately upstream of US 70.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 19 December 2014
3.3 Riparian Condition
The absence of riparian buffers exacerbates other stream habitat problems including bank failure,
severe streambank erosion, embedded channel substrate, loss of riffle-pool sequences, and excessive
light penetration which leads to declines in the respective metrics used to assess these habitat features.
As part of the habitat assessments for the North Carolina Ecosystem Enhancement Program (NCEEP)
Local Watershed Plans, riparian vegetative width was recognized as the second best indicator of low
habitat scores. Both Brown Branch sites and the two most upstream Little Alamance Creek locations
(Little Alamance Creek at Mebane Street and NC 54) scored below 5 on the scale of 1 to 10 for Riparian
Vegetative Zone width. The three downstream sites had higher scores for this metric because they
passed through lesser developed areas with intact riparian buffers.
3.4 Population and Land Use
3.4.1 Land Use
The Little Alamance Creek watershed includes portions of the cities of Burlington and Graham, NCDOT
right-of-way (ROW), and non-incorporated area. The cities of Burlington and Graham, and NCDOT areas
cover approximately 87% of the Little Alamance Creek watershed (Table 3-2). Approximately two-thirds
and one-fifth of Burlington and Graham are located within the watershed, respectively, as are 63.4 miles
of NCDOT roads.
Table 3-2. Summary of Burlington, Graham, and NCDOT areas within the Little Alamance Creek watershed
Name
Total Area
(sq mi)*
Area within
Watershed (sq mi)
Percentage of
Watershed Area
Little Alamance Creek Watershed 15.9 15.9 100.0
Burlington 24.8 10.1 63.8
Graham 9.2 2.9 18.3
NCDOT ROW† — 0.8 4.8
Non-incorporated Areas — 2.1 13.1
* Total areas for the municipalities include the jurisdictional areas outside of Little Alamance Creek watershed. NCDOT area
outside of Little Alamance Creek watershed was not estimated for this table.
† Length of NCDOT roads within the watershed is 63.4 miles.
Land use and land cover in the watershed play a substantial role in stream water quality and aquatic
habitat. The Little Alamance Creek watershed is mostly urbanized with 89.4% of the area developed.
Single family residential housing is the most predominant land use (59.7%), followed by industrial
(12.4%) (Table 3-2). Both downtown Graham and Burlington are north of I-40/85 corridor and the
residential development radiates out from these urban cores. Industrial and commercial uses are
clustered mainly around the I-40/85 corridor and the major thoroughfares (US 70, NC 87, NC 54, NC 49,
and NC 100) between the urban cores and major thoroughfare intersections. NCDOT area is estimated
to be approximately 4.8% of the watershed. Undeveloped and agricultural land is mostly found south of
I-85. There are some areas south of the I-40/85 corridor that are within the watershed and are outside
of the corporate limits of Burlington and of Graham. These areas, 13.1% of the watershed, are
unincorporated areas within Alamance County.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 20 December 2014

Figure 3-1. Map of primary zoning categories in the Little Alamance Creek watershed (Trish Patterson, personal
communication, Geographic Information Systems [GIS] Specialist for the City of Burlington, July 15, 2014)
3.4.2 Future Development Trends
Future development within the watershed north of the I-40/85 corridor is limited by existing
development and topographical features. The primary areas of future development will likely be south
of the I-85/40 corridor and appear to be predominately residential development with some limited
industrial development potential to the south of Burlington and along the Burlington and Graham
boundary.
3.4.3 Current Population
An NCEEP (2007) report compiled by the Piedmont-Triad Regional Council (PTRC) (formerly Piedmont-
Triad Council of Governments [PTCOG]) listed the Little Alamance Creek watershed population at
27,581, based on 2000 US Census data. The same report also provided a 2005 population estimate of
29,512 based on data from the PTRC Regional Data Center. This equates to an annual population growth
rate of 1.3%.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 21 December 2014
3.4.4 Future Population and Trends
Population in Little Alamance Creek is thought to have leveled off since 2012 based on the impact of the
recent recession on housing development. While there are small amounts of undeveloped land in the
watershed, only a portion of these areas is likely to be developed as residential land use. Exact
development patterns in the area south of the I-40/85 corridor have not been identified. Regional
growth trends for the area indicate that multi-family development may be a major contributor to overall
residential development.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 22 December 2014
4.0 Potential Stressors Causing Biological Impairment
The biological impairment listing for Little Alamance Creek is based on the results of benthic
macroinvertebrate (benthos) sampling. Benthic macroinvertebrates have been surveyed 11 times by
DWR—five times at one site and one time at six additional sites. The USGS also conducted one benthic
survey at one site. Fish communities have been surveyed five times by DWR at one location. Locations of
these and other monitored locations within the watershed are shown in Figure 4-1. Since different
reports may refer to a single monitoring location using different names, Table 4-1 provides a cross-
reference of station IDs for major online databases and reports. Table 4-2 provides sampling dates as
well as bioclassifications for Little Alamance Creek watershed monitoring locations.

Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 23 December 2014

Figure 4-1. Biological, physicochemical, flow, and climate monitoring locations within the Little Alamance Creek watershed. Most recent DWR
bioclassification is noted at applicable sites. “LATT” refers to the NC Ecosystem Enhancement Program’s local watershed plan for Little Alamance Creek,
Travis Creek, and Tickle Creek.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 24 December 2014
Table 4-1. Monitoring locations cross-referenced by reporting ID from select online databases and reports
Monitoring Location
DWQ
Biological ID
USGS
Station ID
NCEEP
(2008) ID DWQ (2006) ID
Little Alamance Cr at Rogers
Rd (State Route [SR] 2309)
BB388,
B1920000,
BF60
209679804 19 Little Alamance Cr at
Rogers Rd
Coble Br at Engleman Ave BB42 — — Coble Br at Engleman Ave
Little Alamance Cr at
Edgewood St — — — Little Alamance Cr at
Edgewood St
Little Alamance Cr at
Woodland Ave — — — Little Alamance Cr at
Woodland Ave
Bowden Br at Hanford Rd (SR
2304) — — 20 —
Little Alamance Cr at NC 49 BB131 — — Little Alamance Cr at NC 49
Little Alamance Cr near I-85 BB46,
BB78 — 18
Little Alamance Cr at
Plantation Dr (I-85
Frontage)
Little Alamance Cr at NC 54 BB47 — 17 Little Alamance Cr at NC 54
(Tucker St)
Willowbrook Cr (Brown Br) at
Mebane St (SR 1363) — — 15 Meadowbrook Cr at
Mebane St
UT to Willowbrook (Brown Br)
Cr at Kime St — — 14 —
Little Alamance Cr at Mebane
St (SR 1363) — — 16 —
Little Alamance Cr at
Overbrook Rd BB193 — — —

The farthest downstream monitoring site in the watershed and the site with the most data, Little
Alamance Creek at Rogers Road (SR 2309), has samples dating to 1985. All benthos samples received a
bioclassification rating of “Fair” or “Poor” for each sampling event. This site received a “Not Rated”
score in 2008 due to low streamflow as a result of drought, but would have otherwise rated as “Fair”
score if adequate streamflow levels were present at the time of sampling (Figure 4-2). All DWR
bioclassifications for Little Alamance Creek watershed monitoring locations are listed in Table 4-2.

Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 25 December 2014
Table 4-2. DWR biological sampling results in the Little Alamance Creek watershed
Monitoring Location
STORET
ID
Sample
Date Type
DWR
Bioclassification
Little Alamance Cr at NC-49 BB131 6/23/2003 Benthos Poor
Little Alamance Cr at Overbrook Rd BB193 6/24/2003 Benthos Poor
Little Alamance Cr at Rogers Rd (SR 2309) BB388
7/14/2008 Benthos Not Rated1
9/12/2006 Benthos Poor
6/23/2003 Benthos Fair
7/10/1998 Benthos Poor
7/29/1985 Benthos Fair
Coble Br at Engleman Ave BB42 6/24/2003 Benthos Not Rated2
Little Alamance Cr near I-85 (Frontage Rd) BB46 9/12/2006 Benthos Poor
Little Alamance Cr at NC 54 BB47 9/12/2006 Benthos Poor
Little Alamance Cr near I-85 BB78 6/23/2003 Benthos Poor

Little Alamance Cr at Rogers Rd (SR 2309) BF60
4/24/2013 Fish Good-Fair
4/16/2009 Fish Good
4/23/2003 Fish Good
4/8/1998 Fish Fair
11/4/1993 Fish Good
1 “Not Rated” due to low flow conditions 2 “Not Rated” due to a small catchment area

Figure 4-2. Weekly drought status history for the Haw subbasin (HUC 03030002) which contains the Little
Alamance Creek watershed. DWR bioclassification ratings (right axis) for various monitoring sites within the
Little Alamance Creek watershed. Color of symbol denotes the drought status of the watershed at the time of
sampling. Upper-case letters denote sampled locations (EPA STORET ID): A = BF60; B=BB388; C=BB131, BB78,
BB193; D=BB46, BB47, BB388; E=BB42.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 26 December 2014
4.1 Existing Water Quality Data and Previously Identified Stressors
Prior to identifying potential stressors a literature review and inventory of existing sources of data for
the watershed was prepared. This task culminated in a document titled Little Alamance Creek 4b
Demonstration Project Existing Data Inventory (reprinted in appendix C). The data inventory included a
search of online databases, published documents, and personal communication with local officials. The
overall conclusion of the inventory was that extensive data on water quality is lacking, and the results
have been inconclusive in identifying specific stressors. The available water quality data was the product
of short-term targeted studies rather than long-term, continuous monitoring programs. Most of the
water quality data have been collected at one location (Little Alamance Creek at Rogers Road [SR 2309]).
Table 4-3 summarizes the sources containing water quality data, listed in chronological order by sample
date.
Table 4-3. Summary of reports or online databases describing water quality data in the Little Alamance Creek
watershed
Data Source
Date Range of
Data Collection
Number
of Sites
Sampled
EPA STORET data download (EPA, 2013b) 1968-1975 1
Selected Physical, Chemical, and Biological Data for 30 Urbanizing Streams
in the North Carolina Piedmont Ecoregion, 2002–2003. (Giddings et al.,
2007)
February 2003-
July 2003 1
TMDL stressor study of Little Alamance Creek, Alamance County, Cape Fear
(Memorandum) (DWQ, 2003) June 2003 5
Draft TMDL to Address Impaired Biological Integrity in the Little Alamance
Creek Watershed (DWQ, 2010) June 2003 5
Draft Summary of Existing Water Quality Data (DWQ, 2006) July 2006 8
Evaluation of Water Quality, Habitat and Stream Biology in the Little
Alamance, Travis, and Tickle Creek Watersheds (DWQ, 2008) December 2006-
August 2007 6
Biological Assessments – Cape Fear River Basin (DWQ, 2009) July 2008 1

4.1.1 Brief History of Water Quality Data Collection
The earliest known water quality sampling occurred from 1968 – 1975, at the SR 2309 location. During
this period, a wide variety of parameters were analyzed, but the total number of samples was small.
Water quality data for this period are available at the EPA STORET website.
In 2003, USGS conducted sampling on Little Alamance Creek at SR 2309 as part of a National Water
Quality Assessment study (Giddings et al., 2007). Continuous stream stage and stream temperature
measurements were collected for one year and water chemistry samples were collected twice.
Parameters analyzed included basic physiochemical parameters and nutrients as well as pesticides and
herbicides. Also in 2003, DWQ conducted a TMDL stressor study that included five sample locations
(DWQ, 2003). The study focused on benthic collections, and basic physiochemical data were collected
concurrently. In July of 2006, DWQ conducted a one-week study in an attempt to identify areas with
water quality problems and developed a plan for additional monitoring (DWQ, 2006). Single
measurements of specific conductance were taken at eight bridge crossings across the watershed.
Additionally, an automated sampling device was installed at the SR 2309 location for one week,
collecting hourly data on temperature, dissolved oxygen, pH, and specific conductance. The largest
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 27 December 2014
water quality sampling effort occurred from December 2006 to August 2007, in support of the NCEEP
Local Watershed Plans (DWQ, 2008). The results of this study are discussed in section 4.1.2. The dataset
available for the SR 2309 location includes one additional physicochemical measurement associated
with benthos sampling for the Cape Fear River Basin Biological Assessment in 2008.
4.1.2 DWQ Sampling Data (2006–2007)
The most extensive water quality dataset is reported in the Evaluation of Water Quality, Habitat, and
Stream Biology in the Little Alamance, Travis, and Tickle Creek Watersheds (DWQ, 2008). The data
included sites in two neighboring rural watersheds in addition to the Little Alamance Creek watershed.
Of the sources inventoried, this document contained the only dataset with multiple samples taken over
a broad spatial and temporal range. DWQ conducted sampling at seven sites in the watershed over a
period of nine months (December 2006 – August 2007). A portion of the sampling period coincided with
moderate to exceptional drought conditions across the state (Figure 4-3), which may have influenced
the results. The analysis included physicochemical parameters, nutrients, metals, and bacteria as well as
benthic community samples and habitat assessments. Samples were taken approximately monthly
during baseflow, and on three occasions during stormflow. Some key findings are summarized below.

Figure 4-3. Statewide drought status on August 21, 2007 (North Carolina Drought Management Advisory Council
[NCDMAC], http://www.ncdrought.org/archive/index.php)
Physicochemical Parameters. The highest specific conductance measurements occurred in the
headwater tributaries of Little Alamance Creek; values decreased at downstream monitoring locations.
DWQ concluded that dissolved substances were originating from the urban areas of downtown
Burlington and were being diluted further downstream. Brown Branch (referred to as Willowbrook
Creek in the DWQ report) samples showed several instances of supersaturated dissolved oxygen
concentrations, which were attributed to dense algal blooms noted during sampling. Lower portions of
the watershed were found to experience very low levels of dissolved oxygen, falling below the 4.0 mg/L
water quality threshold on several occasions. The DWQ report attributed these occurrences to seasonal
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 28 December 2014
patterns associated with high air temperatures that were exacerbated by extreme drought conditions
and very low flow. Water temperature and pH measurements were within normal ranges.
Nutrients. One site, Little Alamance Creek at Mebane Street, was found to have consistently high
ammonia concentrations; the site also had the highest Total Kjeldahl Nitrogen (TKN) observed during
the study. Willowbrook Creek and an unnamed tributary (UT) to Willowbrook Creek were found to have
the highest phosphorus concentrations. The 2008 DWQ report indicated that elevated nutrient
concentrations at Little Alamance Creek at Mebane Street and Willowbrook Creek and its UT could be
linked to the potential presence of malfunctioning septic or sewage sources. Elevated nutrient loading
within the Little Alamance watershed would also be consistent with the watershed’s location within the
larger, eutrophic Jordan Lake watershed.
Metals. Copper, zinc, and lead were found at measureable concentrations within the watershed,
predominantly in stormflow samples. Copper was detected in all but two stormflow samples, and most
stormflow samples exceeded the 7 µg/L action level. In addition, one baseflow sample taken at Little
Alamance Creek at SR 2309 was at the action level of 7 µg/L copper. Lead measurements exceeded the
reporting limit only once, in a stormflow sample at Willowbrook Creek. The report stated that this
pollutant may have originated from an old city vehicle maintenance facility or possibly from a landfill in
the Willowbrook Creek catchment. The Willowbrook Creek site also exceeded the action level for zinc
(50 µg/L) in the same stormflow sample, which may also have originated from the same source as the
lead. Zinc was measured in five out of seven stormflow samples, and detected in four baseflow samples.
Calcium and magnesium showed slightly elevated baseflow concentrations, possibly due to the
abundance of pavement in the urban areas. Both metal concentrations were lower during stormflow
samples, indicating dilution during rain events. Sodium concentrations were also elevated, particularly
at Willowbrook Creek and Little Alamance Creek at Mebane Street, which is directly downstream of
Willowbrook Creek. The report stated that the higher sodium could be an indicator of raw sewage
contamination, but could also have originated from other sources.
Fecal Coliform Bacteria. Measurements of fecal coliform are used as an indicator of fecal contamination
in water. Water contaminated with fecal material may carry Escherichia coli (E. coli) and other harmful
pathogens which can cause food poisoning. Several baseflow samples exceeded the 400 cfu/100 ml
reference level (cfu = colony-forming unit) for fecal coliform bacteria: Willowbrook Creek, UT to
Willowbrook Creek, and Little Alamance Creek at Mebane Street. One stormflow sample at SR 2309 also
exceeded the reference level. High fecal coliform values at these urban sites most likely indicate either
sewer line leakage and/or the presence of considerable numbers of domestic pets and/or wildlife.
A display of recent monitoring data events compiled from multiple resources (including the DWQ 2008
report), actual and normal monthly precipitation values, and weekly drought status for Little Alamance
Creek watershed is provided in Figure 4-4.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 29 December 2014

Figure 4-4. Summary of recent (since 2002) monitoring data for Little Alamance Creek watershed. Data compiled from multiple sources (URS, 2014). Top
portion indicates monthly precipitation and normal monthly precipitation from weather station ID 311239 (State Climate Office of North Carolina,
http://www.nc-climate.ncsu.edu). Color of square indicates the weekly drought status of Little Alamance Creek watershed at the time of sampling
(NCDMAC, http://www.ncdrought.org/archive/index.php).
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 30 December 2014
DWR Recommendations. Recommendations in the 2008 DWQ report included the following:
• Little Alamance Creek, particularly its tributary Willowbrook Creek, would likely benefit
from stormwater controls to help moderate the “flashy” hydrology and to reduce sediment
and chemical pollutant inputs.
• Restoration is recommended in the Willowbrook Creek subwatershed to improve
conditions and to reduce downstream impacts on Little Alamance Creek.
• Particular attention needs to be directed to detecting and correcting the sources of
elevated nutrients, heavy metals, and other pollutants in Willowbrook Creek and just
downstream of its confluence with Little Alamance Creek.
Summary. The available water quality data are not sufficient to draw definitive conclusions about the
source of the biological impairment in Little Alamance Creek watershed. The relatively intensive
sampling done by DWQ in 2006–2007 did not identify a specific pollutant causing the impairment.
Rather, it is likely that the impairment is due to a combination of many complex factors. The existing
reports have attributed the impairment to the general conditions typical of an urban watershed,
including the following sources:
• Hydro-modification
• Insufficient riparian buffer
• Streambank erosion
• Pollutants in stormwater runoff
• Degradation of instream habitat
4.2 Habitat, Riparian Condition, and Channel Geomorphology-Related
Stressors
Information on habitat, riparian condition, and channel geomorphology in the watershed is limited.
Habitat assessments have been conducted at seven locations throughout the watershed, often
concurrent with benthos sampling events. Five sites were evaluated by DWQ during the 2003 TMDL
stressor study, and seven sites were evaluated by DWQ in 2006–2007. The habitat assessment scores
throughout the watershed have ranged from 53 to 93, out of a maximum possible score of 100. The
Little Alamance Creek at SR 2309 site has been assessed three times, with progressively lower scores
each time; the scores were 73, 67, and 57 in 2003, 2006, and 2008 respectively. The lowest score was
found at Little Alamance Creek at Mebane Street and the highest score was at Bowden Branch at SR
2304. Willowbrook Creek at Mebane Street also had a poor habitat assessment score of 56. As
previously noted in section 4.1, this site had multiple water quality issues including elevated levels of
phosphorous, lead, zinc, sodium, fecal coliform, and super-saturated dissolved oxygen due to an algal
bloom. The reach had been channelized and had no woody riparian buffer. This site would have scored
substantially lower if the bank erosion had been active, rather than partially stabilized by herbaceous
vegetation and riprap along the bank slopes. Consequently, it is quite likely that bank erosion will
become active again and that the habitat total score at this location will decline.
Of the individual metrics that compose the total score, insufficient riffle habitat was the primary
contributing factor to low scores. Little Alamance Creek at four different locations (Mebane Street, NC
54, I-85 Frontage Road, and SR 2309) scored below 7 on a scale of 1 to 14 for this metric. The secondary
factor contributing to low scores was a lack of riparian buffer. The lack of good riparian buffer zones is a
major issue in urban areas where land is at a premium. The absence of riparian buffer exacerbates other
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 31 December 2014
stream habitat problems including streambank erosion and subsequent burial of channel substrates,
reduced shading, and reduced inputs of woody debris and leaf material.
Another potential stressor is the altered hydrology typical of an urban watershed. The 2008 DWQ study
stated that scouring at high flows is a major issue throughout Little Alamance Creek and its tributaries.
There are no long-term continuous data on flow, because there are no permanent gauge stations in the
watershed. However, stream flow data were collected as part of the USGS study on urbanizing Piedmont
streams in 2002 and 2003. Continuous stream stage data were collected hourly for one year, from
November 16, 2002 to November 15, 2003. The overall mean discharge for the year was 14.9 cfs.
4.3 Stream Geomorphology
There has been no comprehensive assessment of stream geomorphology performed in the Little
Alamance Creek watershed. However, three reaches were evaluated for stream restoration. As part of
the restoration projects, extensive geomorphological data were collected and documented in the
restoration plans for Little Alamance Creek and Brown Branch. Both projects were proposed to be
funded by NCEEP. Only one project consisting of the Little Alamance Creek and an unnamed tributary
was constructed. Section 5.1.3.1 includes additional information on this restoration project. Table 4-4
summarizes key findings from the pre-restoration geomorphological data.
Table 4-4. Geomorphological values for select reaches (ARCADIS, 2008)
Data Source
Little Alamance Creek
(City Park)
UT to Little Alamance
Creek (City Park)
Brown Branch
(Willowbrook Park)
Drainage Area (sq mi) 4.2 0.1 0.8
Gradient (ft/ft) 0.0024 0.0095 0.0069
Channel to Depth Ratio 14.0 9.3 13.9
Sinuosity 1.2 1.1 1.01
D50 (mm) 2.4 3.4 8.4
Rosgen Classification C5/1 and E5/1 E4/1 C4/1 and E4/1
NCDENR Stream
Classification Score 47.5 33.0 35.5
Little Alamance Creek at Burlington’s City Park in its pre-restoration condition was a pool-dominated
system with approximately 65% of the stream length comprised of pools. In the middle section of the
project reach, the pools are separated by fairly short and steep bed-rock steps. The C5 stream type is a
slightly entrenched, meandering, sand-dominated, riffle/pool channel with a well-developed floodplain
(Rosgen, 1997). The E5 stream type is characterized by low to moderate sinuosity, gentle to moderately
steep gradients with very low channel width to depth ratios (Rosgen, 1997). The substrate of an E5/1 or
C5/1 stream type is comprised mainly of sand with the occurrence of bedrock. The hybrid classification
given to Little Alamance Creek reflects the range of channel dimensions found throughout the site.
The upper reach of the UT immediately downstream of Overbrook Road is steeper than the lower reach
at the confluence with Little Alamance Creek. The lower reach is located in the relatively flat floodplain
of Little Alamance Creek. The E4/1 stream type has gentle to moderately steep gradients with very low
width to depth ratios. They are riffle/pool streams and exhibit gravel-size bed material with areas of
bedrock. Typically E4/1 channels are meandering streams.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 32 December 2014
Brown Branch exhibits the aforementioned characteristics of an E4/1 channel but a segment also
exhibits C4/1 characteristics. The C4/1 stream type is a slightly entrenched, riffle/pool channel with a
well-developed floodplain. The channel substrate is gravel-dominated with areas of bedrock. The C4/1
stream channels have gentle gradients of less than 2%, and display high width/depth ratios. Typically
C4/1 channels are meandering but this channel is confined by the limits of Willowbrook Park.
4.4 Potential Point Source Stressors
There are generally two types of stressors that impact waterways: nonpoint source pollution and point
source pollution. Nonpoint source pollution comes from diffuse sources and includes any source of
water pollution that does not meet the legal definition of a “point source” in section 502(14) of the
CWA. Point source stressors originate from a readily identifiable source, such as a wastewater discharge
pipe from an industrial process or a sewage treatment plant or other discrete conveyance such as a pipe
or constructed ditch. EPA also classifies urban stormwater running off of impervious surfaces as a point
source pollutant. The NPDES Program regulates point source stormwater discharges from MS4s,
construction activities, and industrial activities. There are three MS4 operators in the Little Alamance
Creek watershed: City of Burlington, City of Graham, and NCDOT.
4.4.1 Critical Areas
There are a number of locations and land uses within Little Alamance Creek that may exhibit the
potential to contribute to the degradation of water quality from contributing runoff, non-compliant
operations, or past practices. These areas may no longer be contributing pollutants via runoff, spills, or
groundwater to Little Alamance Creek or its tributaries but can be categorized as hot spots for future
evaluation and monitoring. Typical facilities and land uses that fall into this category include landfills,
NPDES discharges, dump sites, and industries no longer operating or now required to perform
pretreatment of the wastewater. The Cities of Burlington and Graham have compiled a spatial dataset of
these locations for reference in future planning efforts and plan implementation.
4.4.2 NPDES-Permitted Stormwater Dischargers
The Cities of Burlington and Graham are both regulated MS4 Phase II NPDES communities (NCS000428
and NCS000408, respectively). They received NPDES permits July 1, 2005, which were renewed in
November 2011. NCDOT has an active NPDES permit (NCS000250) originally issued in 1998 and most
recently renewed on September 10, 2010. A review of the NCDENR’s Stormwater Permitting Program
list (DEMLR, 2013) indicates that there are 14 active general NPDES stormwater permittees in or close to
the Little Alamance Creek watershed, three individual NPDES stormwater permittees, and two facilities
with No Exposure certifications within the watershed (Figure 4-5 and Table 4-5).
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 33 December 2014

Figure 4-5. Active NPDES-permitted facilities within approximately 300 yards of Little Alamance Creek watershed
(DEMLR, 2013; City of Burlington, personal communication, June 24, 2014)

Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 34 December 2014
Table 4-5. Permitted facilities in or near the Little Alamance Creek watershed (DEMLR, 2013)
Permit Class
Permit
Number Owner Name Facility Name Owner Type Permit Type
Effective
Date
Expiration
Date
Permit
Status
Within the Little Alamance Creek watershed:
MS4 NCS000428 City of Burlington City of Burlington Government
—Municipal Stormwater Discharge, Individual (MS4) 11/11/2011 11/10/2016 Active
MS4 NCS000408 City of Graham City of Graham Government
—Municipal Stormwater Discharge, Individual (MS4) 11/11/2011 11/10/2016 Active
MS4 NCS000250 NCDOT -
Hydraulics Unit
NCDOT Statewide
Stormwater MS4
Government
—State Stormwater Discharge, Individual (MS4) 9/10/2010 9/9/2015 Active
General NCG030188 Sapa Burlington
LLC SAPA Burlington, LLC Non-
Government Metal Fabrication Stormwater Discharge COC 12/4/2012 10/31/2017 Active
General NCG080315 Ernie Koury Jr The Place Non-
Government
Transportation w/Vehicle Maintenance/Petroleum
Bulk/Oil Water Separator Stormwater Discharge COC 11/1/2012 10/31/2017 Active
General NCG080431 Carolina Tank
Lines Inc
Carolina Tank Lines
Incorporated
Non-
Government
Transportation w/Vehicle Maintenance/Petroleum
Bulk/Oil Water Separator Stormwater Discharge COC 11/1/2012 10/31/2017 Active
General NCG080706 City of Burlington Burlington Equipment
Services
Government -
Municipal
Transportation w/Vehicle Maintenance/Petroleum
Bulk/Oil Water Separator Stormwater Discharge COC 11/1/2012 10/31/2017 Active
General NCG170202 Burlington
Industries LLC
Burlington Industries-
BHP Plant
Non-
Government Textile Mill Products Stormwater Discharge COC 8/1/2009 7/31/2014 Active
General NCG170228 Kayser-Roth
Corporation
Kayser Roth Corp-
Burlington Plant
Non-
Government Textile Mill Products Stormwater Discharge COC 8/1/2009 7/31/2014 Active
No Exposure NCGNE0091 Homac
Corporation
Lessona/Holt
Distribution
Non-
Government Stormwater Discharge, No Exposure Certificate 5/1/2005 — Active
No Exposure NCGNE0831 BD Diagnostics -
Women's Health
BD Diagnostics -
Women's Health
Non-
Government Stormwater Discharge, No Exposure Certificate 1/10/2012 — Active

Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 35 December 2014
Table 4-5. Permitted facilities in or near the Little Alamance Creek watershed (DEMLR, 2013) (continued)
Permit Class
Permit
Number Owner Name Facility Name Owner Type Permit Type
Effective
Date
Expiration
Date
Permit
Status
Within approximately 300 yards of Little Alamance Creek watershed:
General NCG080316 Lee Properties SC
LLC
Tucker Street Industrial
Park
Non-
Government
Transportation w/Vehicle Maintenance/Petroleum
Bulk/Oil Water Separator Stormwater Discharge COC 12/12/2012 10/31/2017 Active
General NCG140089 Chandler Concrete
Co., Inc.
Chandler Concrete Co -
Burlington Plt #601
Non-
Government
Ready Mix Concrete Stormwater/Wastewater
Discharge COC 7/1/2011 6/30/2016 Active
General NCG170213 Burlington
Technologies
Burlington
Manufacturing Services
Non-
Government Textile Mill Products Stormwater Discharge COC 8/1/2009 7/31/2014 Active
General NCG170241 Glen Raven Inc Glen Raven, Inc.
Custom Fabrics
Non-
Government Textile Mill Products Stormwater Discharge COC 8/1/2009 7/31/2014 Active
General NCG170242 Glen Raven Inc Glen Raven Inc Non-
Government Textile Mill Products Stormwater Discharge COC 8/1/2009 7/31/2014 Active
General NCG200346 Commercial
Metals Company
Commercial Metals
Company
Non-
Government
Wholesale Trade of Metal Waste and Scrap
Stormwater Discharge COC 1/1/2010 12/31/2014 Active
General NCG200483 — OK Recycling Individual Wholesale Trade of Metal Waste and Scrap
Stormwater Discharge COC 4/2/2012 12/31/2014 Active
General NCG170250 National Spinning
Company Inc
National Spinning
Company - Alamance
Dye
Non-
Government Textile Mill Products Stormwater Discharge COC 8/1/2009 7/31/2014 Active
Notes:
COC = certificate of coverage

Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 36 December 2014
Certain industrial facilities within Burlington and Graham may also have wastewater discharges that
would disproportionally impact the sanitary sewer lines or WWTP. For example, oil and grease can
obstruct sanitary sewer lines and therefore must be removed from the wastewater before it is
discharged into the sanitary sewer system. Industrial facilities that meet certain criteria must obtain a
discharge permit from their respective city and pretreat their wastewater to acceptable levels before
discharging to the sanitary sewer system.
4.4.3 NPDES-Permitted Wastewater Dischargers
There are no active NPDES wastewater discharge permits in the Little Alamance Creek watershed.
Previously, the City of Burlington WWTP was located at present-day South Graham City Park, but the
facility was closed in the early 1970’s.
4.4.4 Nonpermitted Point Sources
The sources reviewed for the data inventory did not identify any specific point sources of pollution,
though the area around Willowbrook Creek was recommended for further investigation due to several
samples with higher fecal coliform, nutrient, and heavy metal concentrations. Some potential point
sources to be investigated in this area include leaking sewer lines or septic systems, and a vehicle
maintenance facility. There is also an unlined abandoned landfill adjacent to Little Alamance Creek;
unlined landfills have the potential to convey contaminants into the stream via groundwater movement.
4.5 Potential Nonpoint Source Stressors
There are a multitude of potential nonpoint source stressors in the watershed. Stormwater runoff may
contain a complex mixture of contaminants that are accumulated as precipitation flows across surfaces.
Some pollutants commonly found in urban stormwater runoff include: pesticides and nutrients from
lawns, gardens, and golf courses; oil and other fluids from motor vehicles; heavy metals from roof
shingles, gutters, and motor vehicles; road salts; virus, bacteria, and nutrients from pet and wildlife
waste and failing septic systems or leaking sewer lines; and sediment from eroding streambanks and
construction sites. Thermal pollution can also be an issue, as water temperatures can increase as they
flow across dark impervious surfaces such as streets and rooftops or due to a lack of riparian buffer and
stream canopy. While these pollutants are common in most urban stormwater, none of these specific
stressors have been identified as the main source of impairment for the Little Alamance Creek
watershed.
Approximately 30% of the Little Alamance Creek watershed is comprised of impervious surfaces (Elon
University, 2010). Growth of impervious surface appears to have leveled off, as percentages for the
watershed were 26.0% and 26.2% based on 2001 and 2006 National Land Cover Database (NLCD) GIS
data, respectively. There are also private stormwater conveyance systems that are not part of the MS4s.
The areas outside of the MS4 stormwater conveyance systems primarily include the riparian areas
adjacent to streams and lakes, as well as a small unincorporated area between Burlington and Graham
in the central southern portion of the watershed.
4.6 Potential Legacy Stressors
In addition to the use of gristmills, cotton factories, and dyeing operations in the late nineteenth and
early twentieth centuries alongside Little Alamance Creek (see section 2.0), there are three identified
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 37 December 2014
historic wastewater discharge or landfill sites within Little Alamance Creek. There is a historic landfill site
located under the Pine Hill Cemetery and the Burlington Public Works facility on Mebane Street
between Little Alamance Creek and Brown Branch. The 95-acre landfill was closed and is likely unlined
per current standards. At the confluence of Brown Branch and Little Alamance Creek on the other side
of Mebane Street is a historic wastewater sludge application site. A second wastewater sludge
application site is located where the South Graham Municipal Park is located. These sites are no longer
active but could have lasting impacts to the water quality within the watershed.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 38 December 2014
5.0 Pollution Controls
Restoring biological integrity and aquatic life use in Little Alamance Creek will depend on the
implementation of pollution controls, management practices, and other strategies and activities
designed to mitigate the stressors discussed in section 4.0. Collectively referred to as BMPs, these
activities function to reduce or avoid pollutant inputs to receiving waters in order to achieve water
quality protection goals and restore and maintain the physical, chemical, and biological integrity of the
receiving waterbodies. BMPs provide this function through control of discharges that could alter natural
hydrology, reduction of pollutant loads that are delivered to a waterbody, and mitigation of other
stressors that might contribute to impairment.
5.1 Public Education and Outreach and Public Involvement
Educating and engaging the public on stormwater-related issues can help inform the public about the
importance of stormwater quality, reduce pollution at its source, and create a body of support for local
stormwater initiatives. Encouraging the proper application of lawn fertilizer and organizing volunteer
clean-up activities for roadsides or waterbodies are common examples of directly informing and
engaging the watershed’s community.
5.2 Illicit Discharge Detection and Elimination
An illicit discharge is a discharge that conveys unauthorized substances to the stormwater drainage
system. Entry of an illicit discharge into the stormwater system may be performed directly through the
spilling or dumping of substances or indirectly through the conveyance of substances overland to inlets
or direct connection to underground pipes. The illicit discharge may contain sediment, soap, pet waste,
litter, oil, fertilizer, pesticides, or raw sewage, and often times comes from “generating sites.”
Generating sites are points of pollution that continue over a period and are recurring at regular or
irregular intervals.
5.3 Erosion and Sediment Control
While erosion and sediment transport are natural processes, the acceleration and frequency of these
processes is problematic to receiving waters. Excessive sediment is a water quality pollutant that is
detrimental to benthic macroinvertebrates (EPA, 2006b). Land disturbance at construction sites is
characterized as a primary source of excessive sediment. Earth-stabilizing protocols, including temporary
ground cover, limit erosion processes. Sediment controls, such as silt fences and basins, help prevent
sediment from being transported offsite.
5.4 Post-Construction Runoff Control Program
The development of the natural landscape into impervious surfaces and managed land results in
increased runoff and pollutant loadings (both in amount and frequency of events). As a consequence,
qualifying development is required to implement post-construction stormwater controls. These controls
are designed to reduce potential pollutant and hydrological impacts to downstream waterbodies. Post-
construction stormwater may be addressed with BMPs to treat the runoff, or through site design that
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 39 December 2014
employs low impact development (LID) or green infrastructure (GI) principles in order to reduce the
volume of runoff.
5.5 Pollution Prevention and Good Housekeeping
Employees and contractors of governmental entities have the potential to impact stormwater quality
like the rest of the public, but as stewards of stormwater management they must demonstrate and lead
by example. Pollution Prevention and Good Housekeeping (PPGH) programs are a collection of internal
education initiatives that discuss the importance of stormwater quality, highlight specific ways their
work could impact stormwater quality, and review existing ordinances or protocols employees and
contractors are required to follow in order to improve stormwater quality. Fertilizer application
guidelines and facility-specific pollution prevention plans are two examples of PPGH initiatives.
5.6 Collection System Improvements
Older sanitary sewer lines may have significantly high rates of infiltration and inflow (I&I) (water
entering the sewer line) and exfiltration (untreated sewage leaching into the soil and groundwater).
Excessive I&I can cause the volume of the sewage transported to exceed the design capacity of the
system, producing sewer overflows. Untreated sewage may contain water quality pollutants including
pathogens, nutrients, oil and grease, metals, and pharmaceuticals. Dissolved oxygen levels in receiving
waterbodies may also be reduced due to the high biochemical oxygen demand (BOD) of untreated
sewage. Scheduled I&I inspections, sanitary sewer lining, and rehabilitation are some examples of
collection system improvements.
5.7 Stream Buffers
A stream buffer (riparian buffer) is the vegetated land adjacent to a streambank. Stream buffers stabilize
streambanks, provide shade, and supply detritus (e.g., leaves) to many aquatic organisms. These
ecological functions reduce streambank erosion, reduce thermal loadings, and support a more diverse
food web in the stream’s ecosystem. Stream buffers have also been shown to reduce nitrogen levels
(Messer et al., 2012). Many stream buffers are further defined into zones measured perpendicular from
the streambank. Zone 1 is adjacent to the streambank and consists of undisturbed woody vegetation.
Zone 2 is adjacent to Zone 1 and can include managed vegetation (Figure 5-1).
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 40 December 2014

Figure 5-1. Diagram of stream buffer zones (NCDENR, n.d.-c)
5.8 Stream Restoration and Enhancement
Degraded streams typically lack diversity in aquatic habitat and fauna, and may have increased levels of
streambank erosion. Stream degradation may be the product of past channelization, “flashy” hydrology
due to decreased levels of infiltration, lack of buffer, or upstream pollution.
Stream restoration is the re-establishment of the general structure, function, and self-sustaining
behavior of the stream. Many restoration projects feature aspects of the natural channel design method
such as modification of channel dimension, pattern, and profile (Rosgen, 1997). Stream enhancement
and stream stabilization are narrower in scope than stream restoration and focus on improving the
floodplain and streambank areas, respectively. “Daylighting” projects improve stream habitat by
converting a piped segment of the stream to a more natural state such as a vegetated channel.
5.9 Stormwater Retrofits
Structural BMPs are used to help control and treat stormwater runoff. A “retrofit” is a BMP that has
been installed within a previously developed area that does not have adequate runoff treatment in
place. BMPs often include stormwater retention, detention, and treatment devices that mitigate altered
hydrologic and pollutant loadings typically associated with land disturbance and development. BMPs can
provide hydrologic benefits by reducing runoff volume, increasing groundwater recharge, reducing the
peak flow and duration of high stream flows, and reducing stream velocities. While many of these
hydrologic benefits can directly enhance water quality, many BMPs provide additional water quality
benefits through additional treatment and pollutant removal mechanisms. For most BMPs, the removal
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 41 December 2014
mechanism involves sequestering the pollutant within the BMP (typically bound to the soil or within
vegetation) or completely removing it from the aquatic environment. For example, sediment-bound
phosphorus may be trapped within a forebay BMP and prevented from entering the receiving
waterbody, whereas water-soluble nitrate (NO3) may be transformed into nitrogen gas (N2) and enter
the atmosphere.
Certain pollutants are more efficiently removed using different mechanisms. Suspended solids can be
removed through sedimentation or filtration. Nitrogen loadings may be reduced through plant uptake or
be transformed into nitrogen gas (N2) via denitrification. Metals including copper, lead, and zinc are
efficiently removed through sorption onto organic matter such as mulch (Davis et al., 2001) or peat
(Chen et al., 1990). Hydrocarbons such as oil and grease are efficiently sorbed onto mulch and
subsequently biodegraded (i.e., removed from the environment) by microbes (Hong et al., 2006). A
reduction in thermal pollution has been documented in filtration BMPs (Jones and Hunt, 2009;
DiGennaro, 2008). Variable success has been shown in reducing pathogen loadings with structural BMPs
(Sullivan et al., 2007; Hathaway et al., 2009). Because of the variable removal rate, a combination of
treatment and source-reduction measures for pathogens is typically recommended. A list of structural
BMPs cross-referenced by their pollutant removal mechanisms is presented in Table 5-1.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 42 December 2014
Table 5-1. Select structural BMPs and their pollutant removal mechanism (adapted from NCDOT, 2008)
Structural
BMP Description In
f
i
l
t
r
a
t
i
o
n

Fi
l
t
r
a
t
i
o
n

De
t
e
n
t
i
o
n

Se
d
i
m
e
n
t
a
t
i
o
n

So
r
p
t
i
o
n

Mi
c
r
o
b
i
a
l
-me
d
i
a
t
e
d

tr
a
n
s
f
o
r
m
a
t
i
o
n
*
Bi
o
l
o
g
i
c
a
l

u
p
t
a
k
e

Po
l
l
u
t
i
o
n

P
r
e
v
e
n
t
i
o
n

En
e
r
g
y

d
i
s
s
i
p
a
t
i
o
n

Bioretention
Basin
A type of media filter with a shallow basin,
engineered media, an underdrain system, and
landscaped vegetation.
X X X X
Dry
Detention
Basin
A shallow, dry basin with an outlet pipe or orifice
near the invert of the basin. X X X
Filter Strip
A linear section of land, either grassed or
forested, that physically filters and infiltrates
stormwater.
X X X X
Filtration
Basin
A type of media filter with a shallow basin,
engineered media, and an underdrain system. X X X X
Forebay A small basin located upstream of another BMP. X X
Hazardous
Spill Basin
A shallow basin with an outlet control structure
that can trap all flow that enters the basin. X
Infiltration
Basin
A shallow basin in permeable soils that detains
and infiltrates stormwater runoff. X X
Level
Spreader
A trough and level lip used to redistribute
concentrated stormwater as diffuse flow.
Typically combined in a system with a filter strip.
X X
Riparian
Buffers
A defined width of protected or restored land—
wooded or not—adjacent to both sides of a
streambank.
X X X X
Preformed
Scour Hole
A riprap-lined basin formed at the outlet of a pipe
with a diameter less than or equal to 18 inches. X X
Stormwater
Wetland
An engineered marsh or swamp with dense
wetland vegetation. X X X X X
Stream
Restoration
The re-establishment of the self-sustaining
functions of a stream through channel
modification and re-alignment.
X X X
Swale A broad and shallow channel with dense
vegetation. X X X X
Wet
Detention
Basin
A shallow basin that maintains a permanent pool
of water by using an elevated outlet control
structure.
X X X X
* Certain microbes within the soil matrix are adept at transforming pollutants. For example, certain anaerobic
bacteria convert nitrate (NO3) into nitrogen gas (N2).
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 43 December 2014
Selecting the appropriate BMP depends largely on site-specific criteria such as drainage area,
topography, soil characteristics, water table elevation, and pollutant(s) of concern. Therefore,
identifying and prioritizing locations that are conducive to retrofits is an important part of a retrofit
program. After the type of BMP has been selected, the previously mentioned location-specific criteria
are used to customize the control measure for the given site. Often, a BMP is actually an assembly of
multiple BMPs working in sequence to maximize pollutant reduction. For example, a level spreader may
include a forebay, a vegetated buffer, a forested buffer, and a bypass swale, in addition to the actual
level spreader component.
5.10 Research
The science behind improving stormwater quality has advanced in recent decades. Today, a well-
developed stormwater management plan is not satisfied solely through the reduction of peak flow via a
large detention basin. New BMPs such as level spreaders and vegetated filter strips allow stormwater
agencies to choose from a larger selection of water quality improvement tools. Ongoing research
provides information on the pollutant removal effectiveness of various BMPs, as well as
recommendations for design, site selection and prioritization, installation techniques for contractors,
and frequency of maintenance activities. Research at the state or local level further engages the
community by creating partnerships between universities and stormwater agencies.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 44 December 2014
6.0 Implementation Plan
This section describes the various BMPs that the project partners will implement as part of this Category
4b Demonstration Plan. The project partners all share responsibility in implementing their individual
pollution controls within the boundaries of their MS4s as well as at owned and operated facilities. This
plan will include a wide range of pollution controls, management practices, and other strategies and
activities designed to mitigate identified stressors throughout the watershed. The schedule for
implementing BMPs will correspond with the North Carolina state fiscal year (FY) calendar (July 1
through June 30). The implementation of the following BMPs will contribute to the overall goal of
achieving a benthic macroinvertebrate community bioclassification of “Not Impaired”, “Good-Fair”, or
better.
6.1 Public Education and Outreach and Public Involvement
The goal of external education is to make the public aware of how their activities and choices can
contribute to potential stressors and to provide them the means to mitigate these actions. This goal is
achieved mainly by direct and indirect engagement of select audiences, provision of educational
materials, demonstration of best practices, and solicitation of feedback and involvement. Extended
education efforts in the watershed should not only foster stormwater pollution prevention but also
create a culture of environmental stewardship for stormwater mitigation and management. In order to
target the necessary audiences, a combination of broad and focused external education efforts will be
implemented as pollution controls.
The project partners have been implementing external education efforts over the duration of their
NPDES MS4 permits. These efforts, while diverse and numerous, have been focused at a broader level to
maximize the extent of awareness and provide straight-forward messaging. As a result, the project
partners are confident in asserting that awareness of stormwater pollution and environmental
stewardship is at an elevated level compared to a decade ago prior to the promulgation of NPDES MS4
permits. This is generally beneficial to restoration efforts for Little Alamance Creek but for the purposes
of this plan, these efforts will need to be tailored for the Little Alamance Creek watershed and its
stressors. The project partners will evaluate opportunities to implement specific external education
initiatives in the Little Alamance Creek watershed. As part of this Category 4b Demonstration Plan, a list
of external education BMPs proposed for implementation within the Little Alamance Creek watershed is
presented in Table 6-1.
Table 6-1. External education BMPs to be implemented
within the Little Alamance Creek watershed
Pollution Control Schedule
City of Burlington
Partner with the Stormwater Management and Recovery
of the Triad (SMART) program as a regional, broad-based
stormwater education provider
Currently implemented, continue as
programmed
Partner with Piedmont Triad Water Quality Partnership as
a regional, broad-based stormwater education provider
Currently implemented, continue as
programmed
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 45 December 2014
Pollution Control Schedule
Leverage the quarterly CityWorks newsletter distributed
with utility bills to inform the public of the Category 4b
Demonstration Plan and their potential involvement in
nonpoint source pollution reduction
Currently implemented, continue and
adapt as necessary
City of Burlington (continued)
Document Burlington customer response program,
stormwater, and stream-related solicitations in
watershed
Currently implemented, continue and
adapt as necessary
Conduct Annual Stormwater Meeting for public feedback
and solicitation
Currently implemented, continue and
adapt as necessary
Attend festivals/parades/events with stormwater-related
staff for public engagement
Currently implemented, continue and
adapt as necessary
Perform stormwater-related presentations for civic
groups
Currently implemented, continue and
adapt as necessary
Organize and publicize stream clean up in watershed Adapt current program in FY 2016
Promote proper disposal of E-Waste and collection events
in watershed Adapt current program in FY 2016
Promote water quality programs for Summer Camp
performed by the Recreation Department
Currently implemented, continue and
adapt as necessary
Develop Green Infrastructure Grant Program for targeted
areas in the watershed Implement new program in Year 3
Prioritize 50/50 Cost Share projects in the watershed Adapt current program in FY 2017
Develop specific watershed content for Stormwater
Division’s website Adapt current program in FY 2016
Partner with Alamance County Cooperative Extension on
rain garden education and construction in watershed Adapt current program in FY 2016
City of Graham
Partner with Stormwater SMART as a regional, broad-
based stormwater education provider
Currently implemented, continue as
programmed
Partner with Piedmont Triad Water Quality Partnership as
a regional, broad-based stormwater education provider Implement new relationship in FY 2017
Conduct Annual Stormwater Meeting for public feedback
and solicitation
Currently implemented, continue and
adapt as necessary
Attend festivals/parades/events with stormwater-related
staff for public engagement
Currently implemented, continue and
adapt as necessary
Perform stormwater-related presentations for civic
groups
Currently implemented, continue and
adapt as necessary
Prioritize projects identified through the 50/50 Cost Share
Program in the watershed Implement new program in FY 2017
Partner with Alamance County Cooperative Extension on
rain garden education and construction in watershed Implement new relationship in FY 2017
Continue relationship with Stormwater SMART as a
regional, broad-based stormwater education provider
Currently implemented, continue as
programmed
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 46 December 2014
Pollution Control Schedule
NCDOT
In cooperation with Burlington and Graham distribute
pollution prevention educational materials through
NCDOT’s Office of Beautification during local fairs/Earth
Day celebrations/and other appropriate community
events
Implement in FY 2016 and adapt as
necessary
Promote Category 4b Demonstration Plan and activities
through NCDOT social medias (Twitter/Facebook/RSS/
Flickr) and NCDOT Now (YouTube)
Implement in FY 2016 and adapt as
necessary
Adopt-A-Highway program for NCDOT roads in the
watershed
Currently implemented, continue and
adapt as necessary
Post this watershed plan and other appropriate content
on NCDOT’s Highway Stormwater Program website
Implement in FY 2016 and adapt as
necessary
Promote stakeholder group meetings for proposed
construction projects in watershed
Currently implemented, continue and
adapt as necessary

6.2 Illicit Discharge Detection and Elimination
The goal of illicit discharge detection and elimination pollution controls is to identify and mitigate non-
stormwater discharges to the MS4s and illegal dumping of materials indirectly or directly to the MS4.
This goal is achieved by routine inspections and monitoring as well as investigation following any
observation or complaint, reliance on regulatory measures for abatement and enforcement, and
remedial construction of illicit connections where necessary. The project partners all share responsibility
in implementing these pollution controls within the boundaries of their MS4s. Both the Cities of
Burlington and Graham have regulatory authority through local ordinances to prohibit and eliminate
illicit discharges and connections. NCDOT manages the potential for illicit discharges and connections
through their Illicit Discharge Detection and Elimination (IDDE) and Encroachment Programs.
The project partners have been implementing and reporting on illicit discharge detection and
elimination programs over the tenure of their NPDES MS4 permits. These programs will continue to be
used to reduce non-stormwater discharges of toxins, fats, oils, greases, and heavy metals, and to
prevent the cross-contamination of wastewater into the MS4 both during wet weather and dry weather
conditions. The pollution controls have been focused on the regulatory requirements of inspection,
investigation, and enforcement but will continue to be refined and adapted as the sources of
stormwater pollution stressors in Little Alamance Creek is understood better. As part of this Category 4b
Demonstration Plan, a list of IDDE-related BMPs proposed for implementation within the Little
Alamance Creek watershed is presented in Table 6-2.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 47 December 2014
Table 6-2. IDDE BMPs to be implemented
within the Little Alamance Creek watershed
Pollution Control Schedule
City of Burlington
Perform dry weather flow stream walks for the
intermittent and perennial streams in the watershed
within each permit cycle
Currently implemented, continue as
programmed
Perform annual representative outfall monitoring within
the watershed for designated outfalls Implement new program in FY 2016
Perform illicit discharge detection and elimination
program under authority of ordinance
Currently implemented, continue and
adapt as necessary
Utilize the Burlington customer response program for
fielding complaints about illegal dumping
Currently implemented, continue and
adapt as necessary
Perform annual inspections of 50% of the identified
dumpsters for proper function Implement new program in FY 2016
Perform analytical monitoring of 5 sites in the watershed Currently implemented, continue and
adapt as necessary
Perform inspections of locations in the watershed where
sanitary sewer cross-contamination may occur. Implement new program in FY 2016
City of Graham
Perform dry weather flow stream walks for the
intermittent and perennial streams in the watershed
within each permit cycle
Currently implemented, continue as
programmed
Perform annual representative outfall monitoring within
the watershed for outfalls Implement new program in FY 2020
Perform illicit discharge detection and elimination
program under authority of ordinance
Currently implemented, continue and
adapt as necessary
Illegal dumping hotline Continue to use the City’s primary number
and direct calls to appropriate contacts
Perform inspections of dumpsters in the watershed for
proper use and structural adequacy once per permit
cycle.
Implement new program in FY 2017
Perform inspections of sanitary sewer high priority lines
within the watershed Implement new program in FY 2016
NCDOT
Perform illicit discharge detection and elimination
program
Currently implemented, continue and
adapt as necessary
Perform illicit discharge detection training for NCDOT and
contractor staff in the watershed
Currently implemented, continue and
adapt as necessary

6.3 Erosion and Sediment Control
The goal of erosion and sediment pollution controls is to limit the generation and transport of sediments
associated with land disturbance for qualifying construction activities. This goal is achieved through the
administration of programs that include the dissemination of erosion and sediment control best
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 48 December 2014
practices, review of erosion and sediment control plans, implementation of routine inspections, reliance
on regulatory measures for abatement and enforcement, and implementation of self-monitoring. The
City of Burlington and NCDOT are directly responsible for implementing these pollution controls within
the boundaries of their program’s authority for qualifying construction activities. The City of Graham
relies on NCDENR to administer the program on their behalf. For the Cities of Graham and Burlington,
qualifying construction activities are limited to land disturbance of an acre or greater while NCDOT
administers NCDOT’s program for all land disturbances.
The project partners have been administering or delegating erosion and sediment control programs
within the boundaries of their authority since the 1970s. These programs, now in place for over 40
years, have established processes and practices that are well known throughout the development
community. Ongoing efforts within the programs include performing maintenance for the duration of
the project and evaluating and adapting controls to increase performance. Given the low remaining
development potential of the watershed, it is anticipated that these pollution controls will not play a
significant role in addressing existing stressors in Little Alamance Creek watershed but will help prevent
exacerbating the current level of impairment. With NCDOT’s significant involvement in linear
construction across the state, NCDOT’s ongoing research on the best technologies and methods for
controlling erosion and sediment will be deployed in Little Alamance Creek watershed for their
construction activities. As part of this Category 4b Demonstration Plan, a list of erosion and sediment
control BMPs proposed for implementation within the Little Alamance Creek watershed is presented in
Table 6-3.
Table 6-3. Erosion and sediment control BMPs to be implemented
within the Little Alamance Creek watershed
Pollution Control Schedule
City of Burlington
Implement approved, delegated erosion and sediment
control program administered by Engineering
Department
Currently implemented, continue and
adapt as necessary
Perform reviews of site plans and calculations by
Engineering Department for proposed erosion and
sediment controls
Currently implemented, continue and
adapt as necessary
Perform on-site inspections by Engineering Department
for plan and permit compliance
Currently implemented, continue and
adapt as necessary
Issue violations for noncompliance under authority of
delegated program
Currently implemented, continue and
adapt as necessary
City of Graham
Rely on State erosion and sediment control program
administered by NCDENR
Currently implemented, continue and
adapt as necessary
NCDOT
Implement approved, delegated erosion and sediment
control program administered by the Construction
Program
Currently implemented, continue and
adapt as necessary

Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 49 December 2014
6.4 Post-Construction Runoff Control Program
The goal of post-construction runoff pollution controls is to limit the generation and transport of
pollutants associated with built-upon areas and how they are used. This goal is achieved through the
administration of programs that include the regulatory requirement for post-construction runoff BMPs,
review of development and redevelopment plans, reliance on regulatory measures for abatement and
enforcement, and annual inspection and reporting. For the Cities of Burlington and Graham, qualifying
development is limited to land disturbance of an acre or greater. As part of their Post-Construction
Stormwater Program, NCDOT implements post-construction BMPs for discharges, controls runoff from
new development and redevelopment, and provides training on implementing the NCDOT Stormwater
Best Management Practices Toolbox.
The project partners have been managing post-construction runoff over the tenure of their NPDES MS4
permits. Given the remaining development potential of the watershed, it is anticipated that these
pollution controls will have minor positive impact going forward in addressing existing stressors in Little
Alamance Creek watershed but will help prevent exacerbating the current level of impairment. These
pollution controls could play a more significant role in pollutant reduction where redevelopment is
significant enough to trigger regulation. As part of this Category 4b Demonstration Plan, a list of post-
construction runoff BMPs proposed for implementation within the Little Alamance Creek watershed is
presented in Table 6-4.
Table 6-4. Post-construction runoff BMPs to be implemented
within the Little Alamance Creek watershed
Pollution Control Schedule
City of Burlington
Require conformance to stormwater standards for new
development and redevelopment projects by Stormwater
Division participation in Technical Review Committee
process
Currently implemented, continue and
adapt as necessary
Receive and evaluate annual inspection reports submitted
by owners for permitted structural BMPs in the
watershed
Currently implemented, continue and
adapt as necessary
Within each permit cycle perform inspections of
permitted structural BMPs in the watershed by
Stormwater Division
Currently implemented, continue and
adapt as necessary
Adopt by ordinance the standards for the control of
nutrients in accordance with the Jordan Lake Rules
Implement new program in accord with
legislative implementation schedule
Incorporate provisions for LID as part of Unified
Development Ordinance revision Implement new program in FY 2020
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 50 December 2014
Pollution Control Schedule
City of Graham
Perform reviews of site plans and calculations for
compliance with new development and redevelopment
standards
Currently implemented, continue and
adapt as necessary
Require developments that are greater than 10% of the
upstream drainage area to match predevelopment runoff
rates
Continued implementations of the City’s
Storm Drainage Design Manual and reduce
the upstream drainage limits within the
watershed to 10% from the current 25%.
Receive and evaluate annual inspection reports submitted
by owners for permitted structural BMPs in the
watershed
Currently implemented, continue and
adapt as necessary
Perform inspection of permitted structural BMPs in the
watershed once per NPDES Phase II Permit Cycle
Currently implemented, continue and
adapt as necessary
Adopt Jordan Lake Rules by ordinance for new and
development standards for the control of nutrients in
post-construction runoff
Implement new program in accord with
legislative implementation
NCDOT
Implement NCDOT’s Post-Construction Stormwater
Program (PCSP) controls for roadway and non-roadway
projects
Currently implemented, continue and
adapt as necessary
Perform inspection of BMPs in the watershed utilizing
NCDOT Stormwater Control Management System (SCMS)
database
Currently implemented, continue and
adapt as necessary
Maintain the use of the Best Management Practices
Toolbox for post-construction runoff control on NCDOT
projects
Currently implemented, continue and
adapt as necessary

6.5 Pollution Prevention and Good Housekeeping
The goal of this set of pollution controls is to prevent and reduce stormwater pollution from municipal
operations and industrial activities. This goal is achieved mainly by the development of directive plans
on the proper handling of potential pollutants and deployment of available controls, training and
education of staff, and implementation of identified operation and maintenance procedures. The
project partners are responsible for implementing their individual pollution controls for municipal
operation and industrial activities being performed within the boundaries of their MS4s as well as at
owned and operated facilities. NCDOT does not own or operate any permanent facilities within Little
Alamance Creek watershed so their responsibility is limited to industrial activities performed within the
NCDOT ROW within the watershed.
The project partners have been implementing and reporting on pollution prevention and good
housekeeping measures over the tenure of their NPDES MS4 permits. The pollution controls have been
focused on typical pollutants generated by project partner facilities and activities but will continue to be
refined and adapted, where applicable, as the understanding of the stormwater pollution stressors in
Little Alamance Creek increases. As part of this Category 4b Demonstration Plan, a list of PPGH BMPs
proposed for implementation within the Little Alamance Creek watershed is presented in Table 6-5.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 51 December 2014
Table 6-5. PPGH BMPs to be implemented
within the Little Alamance Creek watershed
Pollution Control Schedule
City of Burlington
Annual inspection of city owned facilities by Stormwater
Division for compliance with Stormwater Pollution
Prevention Plan (SWPPP)
Currently implemented, continue and
adapt as necessary
Development of SWPPP for remaining facility Develop SWPPP in FY 2016
Annual refresher training on good housekeeping and IDDE
for targeted City employees
Currently implemented, continue and
adapt as necessary
New employee training on good housekeeping and IDDE Currently implemented, continue and
adapt as necessary
Annual reviews of municipally-owned NPDES stormwater
permitted facilities by Stormwater Division
Currently implemented, continue and
adapt as necessary
Annual sweeping of curb and gutter streets in watershed Currently implemented, continue and
adapt as necessary
Provide seasonal leaf and weekly yard waste collection to
properties in the watershed
Currently implemented, continue and
adapt as necessary
Inspect and clean catch basins as necessary to insure
proper maintenance of the stormwater system
Currently implemented, continue and
adapt as necessary
City of Graham
Annual inspection of City-owned facilities by Stormwater
Consultant for compliance with SWPPP
Currently implemented, continue and
adapt as necessary
Annual refresher training on good housekeeping and IDDE
for targeted City divisions and departments
Currently implemented, continue and
adapt as necessary
New employee training on good housekeeping and IDDE Currently implemented, continue and
adapt as necessary
Annual reviews of City-owned NPDES stormwater
permitted facilities by Stormwater Consultant
Currently implemented, continue and
adapt as necessary
Annual sweeping curb and gutter streets in watershed Currently implemented, continue and
adapt as necessary
Inspect and clean catch basins as necessary to insure
proper maintenance of the stormwater system
Currently implemented, continue and
adapt as necessary
NCDOT
Provision and update of Industrial and Roadway
Maintenance Activities (IRMA) BMP Guidance Manual for
activities performed within the ROW
Currently implemented, continue and
adapt as necessary
Stormwater pollution prevention and spill prevention and
response training to NCDOT staff
Currently implemented, continue and
adapt as necessary
Train NCDOT staff and contractors on fertilizer
management and nutrient application decisions
Currently implemented, continue and
adapt as necessary

Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 52 December 2014
6.6 Collection System Improvements
The goal of collection system improvements as pollution controls is to prevent untreated sanitary sewer
discharges from entering the collection system. This goal is achieved primarily through regular
inspections, scheduled maintenance, targeted education about the operation of the collection system,
and capital construction projects and repairs. The Cities of Burlington and Graham are the primary
owners and operators of sanitary sewer collection systems where these pollution controls will be
implemented. NCDOT does not own or operate any wastewater collection systems within the
watershed.
The Cities of Burlington and Graham have been managing their wastewater collection systems to
permit-required conditions since 2002. The Cities are both audited by NCDENR staff approximately every
2 years for compliance and both programs are compliant with their permit conditions. These pollution
controls focus on the reduction of incidental discharges of untreated wastewater from the collection
system within the Little Alamance Creek watershed, thereby reducing the contribution of a wide range
of typical wastewater pollutants to the MS4 and waters of the state. As part of this Category 4b
Demonstration Plan, a list of collection system-related BMPs proposed for implementation within the
Little Alamance Creek watershed is presented in Table 6-6.
Table 6-6. Collection system improvement BMPs to be implemented
within the Little Alamance Creek watershed
Pollution Control Schedule
City of Burlington
Identify and prioritize I&I reduction projects for the
watershed
Currently implemented, continue and
adapt as necessary
Clean or asses 10% of non-unique sanitary sewer mains
annually
Currently implemented, continue and
adapt as necessary
Inspect high priority sanitary sewer lines in the watershed
semi-annually
Currently implemented, continue and
adapt as necessary
Perform fats, oils, and grease education distributions
annually for the watershed
Currently implemented, continue and
adapt as necessary
Assess the effectiveness of the pretreatment program
and provide recommended improvements to the Water
Resources Department
Currently implemented, continue and
adapt as necessary
City of Graham
Identify and prioritize I&I reduction projects for the
watershed
Currently implemented, continue and
adapt as necessary
Maintain sanitary sewer mains via high pressure jetting of
10% of the lines within the entire system on an annual
basis
Currently implemented, continue and
adapt as necessary
Inspect high priority sanitary sewer lines in the watershed
semi-annually
Currently implemented, continue and
adapt as necessary
Perform an annual fats, oils, and grease education
program element annually for watershed
Currently implemented, continue and
adapt as necessary
Inspect one pretreatment facility bi-annually in watershed
to ensure proper disposal procedures
Currently implemented, continue and
adapt as necessary
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 53 December 2014
6.7 Stream Buffers
The goal of stream buffers as a pollution control is to protect and maintain vegetative systems along
streams for the purposes of diffusing and treating stormwater runoff through biological and hydrologic
processes. This goal is achieved through the administration of programs that includes the review of
development and redevelopment plans for compliance stream buffer standards, routine inspections,
and reliance on regulatory measures for abatement and enforcement. For the Cities of Burlington and
Graham, language from the State’s model ordinance was incorporated into local stormwater
management and land use regulation ordinances granting the authority to require these pollution
controls along qualifying streams and waterbodies. NCDOT manages these pollution controls within its
ROW through its Stormwater Management Program under the overarching Guided Reduction of Excess
Environmental Nutrients (GREEN) program.
For the project partners, stream buffer protection and management is being driven recently by the
Jordan Lake Rules. For years prior to the adoption of the Jordan Lake Rules, stream buffers and built-
upon area setbacks existed through other regulations. Since 2009, NCDOT has been complying with
stream buffer standards for new development projects in the Little Alamance Creek watershed. The
Cities of Burlington and Graham implemented their stream buffer ordinances in 2011. Given the
available development potential of the watershed, it is anticipated that these pollution controls will be
limited for new development to those undeveloped portions and sparse redevelopment opportunities.
Efforts to publicize the new ordinance throughout the watershed have likely highlighted the role and
importance steam buffers provide to the community. The message being delivered through these efforts
can be parlayed into support for stream buffer restoration in developed areas of the watershed.
Ongoing stream buffer restoration efforts will be directed through education outreach and voluntary
adoption. As part of this Category 4b Demonstration Plan, a list of stream buffer BMPs proposed for
implementation within the Little Alamance Creek watershed is presented in Table 6-7.
Table 6-7. Stream buffer BMPs to be implemented
within the Little Alamance Creek watershed
Pollution Control Schedule
City of Burlington
Require conformance to stream buffer standards for new
existing developments by Stormwater Division
participation in Technical Review Committee process
Currently implemented, continue and
adapt as necessary
Enforce violations of stream buffer standards under
authority of ordinance
Currently implemented, continue and
adapt as necessary
City of Graham
Require conformance to stream buffer standards for new
and existing developments
Currently implemented, continue and
adapt as necessary
Enforce violations of stream buffer standards under
authority of ordinance
Currently implemented, continue and
adapt as necessary
NCDOT
Implement GREEN Program for New Development
projects in watershed
Currently implemented, continue and
adapt as necessary
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 54 December 2014
6.8 Stream Restoration and Enhancement
The goal of stream restoration and enhancement as a pollution control is to mitigate the nonpoint
source contribution of sediment and pollutants from streambanks and facilitate sediment transport in a
manner conducive to supporting biological habitat. This goal is achieved through planning efforts and
facilitating collaborative opportunities between local land owners and funding agencies. Mitigation
efforts may originate from the NCEEP; restoration opportunities may originate from the Clean Water
Management Trust Fund; and streambank stabilization opportunities may originate from citizen
concerns, sanitary sewer or GI in jeopardy, and local government cost-share funding. The Cities of
Burlington and Graham will implement this pollution control in their respective communities, where
feasible.
There are few completed stream restoration and streambank stabilization projects in Little Alamance
Creek. The Burlington City Park Stream Restoration was completed in 2012 and consisted of the
restoration and enhancement of 2,600 linear feet of stream. The project was successful in establishing a
stream buffer, reducing nonpoint source pollution from eroding banks, attenuating floodwaters,
stabilizing stream geomorphology, and enhancing aquatic habitat. The City Park Stream Restoration is a
model for future implementation in the watershed as other opportunities materialize. Stream
restoration and bank stabilization can provide a direct reduction in nonpoint source pollution while
improving aquatic habitat, but the impact can be limited by degraded upland watershed conditions. In
addition, willingness for implementation on private property and the cost of watershed-wide application
may limit the opportunities to implement this pollution control. As part of this Category 4b
Demonstration Plan, a list of stream restoration and enhancement BMPs proposed for implementation
within the Little Alamance Creek watershed is presented in Table 6-8.
Table 6-8. Stream restoration and enhancement BMPs to be implemented
within the Little Alamance Creek watershed
Pollution Control Schedule
City of Burlington
Compile and maintain active list of stream restoration and
streambank stabilization opportunities for possible
implementation.
Implement new program in FY 2017
Coordinate with funding agencies to identify and evaluate
potential projects from list Implement new program in FY 2018
Amend 50/50 Cost Share program to incorporate the
evaluation of streambank stabilization Implement new program in FY 2019
Identify additional stream restoration and streambank
stabilization opportunities through watershed planning
process
Implement new program in FY 2020
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 55 December 2014
Pollution Control Schedule
City of Graham
Compile and maintain active list of stream restoration and
streambank stabilization opportunities for possible
implementation.
Implement new program in FY 2016
Coordinate with funding agencies to identify and evaluate
potential projects from list Implement new program in FY 2017
Identify additional stream restoration and streambank
stabilization efforts as part of watershed study Implement new program in FY 2020

6.9 Stormwater Retrofits
The goal of stormwater retrofits as a pollution control is to reduce the contribution of pollutants from
stormwater and mitigate the hydraulic impacts of runoff from developed surfaces. This goal is achieved
through planning efforts and facilitating collaborative opportunities with local land owners. The project
partners all share responsibility in implementing these pollution controls within the boundaries of their
MS4.
There are few completed stormwater retrofit projects in Little Alamance Creek. A bioretention area that
treats 2.2 acres of runoff from a multi-recreational use facility was designed and constructed at the
Burlington Aquatic Center. The project was successful in leveraging stormwater utility fees to treat and
infiltrate stormwater from an eroding ditch and serves as a model and education outpost for future
implementation in the watershed as other opportunities materialize. Stormwater retrofits provide direct
mitigation of certain stormwater stressors, but willingness for implementation on private property and
cost of watershed-wide application may be limiting factors. Therefore retrofits can only be relied upon
as a part of the overall strategy. As part of this Category 4b Demonstration Plan, a list of retrofit BMPs
proposed for implementation within the Little Alamance Creek watershed is presented in Table 6-9.
Table 6-9. Stormwater retrofit BMPs to be implemented
within the Little Alamance Creek watershed
Pollution Control Schedule
City of Burlington
Compile and maintain active list of stormwater retrofit
opportunities for possible implementation Implement new program in FY 2016
Prioritize stormwater retrofits within the watershed Implement new program in FY 2018
Amend 50/50 Cost Share program to incorporate LID
projects Implement new program in FY 2017
Identify additional stormwater retrofits through
watershed planning process Implement new program in FY 2020
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 56 December 2014
Pollution Control Schedule
City of Graham
Compile and maintain active list of stormwater retrofit
opportunities for possible implementation Implement new program in FY 2016
Prioritize stormwater retrofit within the watershed Implement new program in FY 2018
Identify additional stormwater retrofits through
watershed planning process Implement new program in FY 2020
NCDOT
Compile and maintain active list of stormwater retrofit
opportunities for possible implementation Implement new program in FY 2016
Design and construct evaluated stormwater retrofits for
watershed Implement new program in FY 2018

6.10 Research
Stormwater research provides a mechanism to improve the understanding of the pollutants in
stormwater, their impacts on receiving streams, and the BMPs that can be used to mitigate or avoid
those impacts. This goal is achieved through leveraging research organizations for direct or relevant
research projects within the watershed. The City of Burlington will leverage its current membership on
North Carolina’s Water Resource Research Institute Stormwater Group in order to access opportunities
that align with needs of Little Alamance Creek watershed. The City of Burlington will also develop a new
research relationship with Elon University, a partner in the community. Under its NPDES stormwater
permit, NCDOT maintains a Research and Analysis Program which works closely with state and national
experts in the field of stormwater management.
Through the two current research programs, numerous stormwater or water quality-related studies and
projects have been conducted since 2001. Both research programs solicit new research ideas through a
competitive selection and funding process. Where opportunities materialize, pilot projects or case
studies can be directed to Little Alamance Creek watershed, potentially providing site-specific
monitoring and implementation of pollution controls. The addition of Elon University as a future
research partner enhances the project partner’s capability to identify more site-specific research
opportunities in the Little Alamance Creek watershed. As part of this Category 4b Demonstration Plan, a
list of BMP-related research programs proposed for implementation within the Little Alamance Creek
watershed is presented in Table 6-10.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 57 December 2014
Table 6-10. Research program BMPs to be implemented
within the Little Alamance Creek watershed
Pollution Control Schedule
City of Burlington
Continue participation in the Stormwater Group through
the North Carolina Water Resources Research Institute
Currently implemented, continue and
adapt as necessary
Develop partnership with Elon University for collaborative
research services in watershed Implement new program in FY 2017
NCDOT
Leverage findings from NCDOT’s Research and Analysis
Program for improvements to design or maintenance of
pollution controls in the watershed
Currently implemented, continue and
adapt as necessary
Evaluate new opportunities to initiate a stormwater
research project within watershed Evaluate in FY 2018

Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 58 December 2014
7.0 Monitoring Plan to Track Effectiveness of Pollution Controls
The overall goal of this Category 4b Demonstration Plan is to achieve a benthic macroinvertebrate
community bioclassification of “Not Impaired”, “Good-Fair”, or better for Little Alamance Creek.
Numeric values associated with a bioclassification of Good-Fair or better are determined by DWR, and
listed in the current benthic Standard Operating Procedures for Collection and Analysis of Benthic
Macroinvertebrates (DWR, 2013). For example, a bioclassification of Good-Fair is based on the average
of the biotic index and EPT scores = 3 (DWR, 2013). Actual numeric values depend upon stream size,
flow regime, season of collection, and collection method. Numeric target levels used to evaluate
attainment will be consistent with the SOP in effect at the time of evaluation. It is being presumed that
the benthos community will improve once the stressors are removed or mitigated. However, neither an
individual nor a group of specific stressors has been conclusively linked to the impairment of the
benthos community in Little Alamance Creek (see section 4.0). This is likely due to the cumulative effects
of environmental factors (e.g., sediment load, channel substrate condition, and upstream pollutant
discharges) that may affect the benthos community. Therefore, an approach that draws from the range
of pollution controls outlined in section 6.0 (hereafter “toolbox items”) seems prudent in progressing
towards the goal.
7.1 Dashboard Approach
A dashboard approach has been adopted for use in tracking execution of toolbox item implementation,
correlating progress with available data, and communicating efforts to the public. The toolbox items
comprise various potential activities as outlined in section 6.0. The dashboard approach allows the
project partners to maintain a long-term focus on addressing the various stressors, even as refined
effectiveness data on toolbox items becomes available and as project partner’s ability to implement or
organizational responsibilities evolve. Additionally, the dashboard approach facilitates the
communication of technical water quality information to a more public-friendly format in order to
communicate progress and encourage public participation in watershed restoration.
The dashboard for the Little Alamance Creek Category 4b Demonstration Plan is presented in Table 7-1.
The organization of the four dashboard groups not only provides the high-level framework for
addressing stressors but also provides direct linkages from dashboard group to the toolbox items to the
metrics. For example, implementation of the Streamside Enhancement dashboard group may include
the protection of stream buffers. Implementation of the stream buffer toolbox item could be tracked by
measuring the number of square feet of protected or restored stream buffers. Through these linkages
the public can more clearly understand why protecting stream buffers is important and that they can
contribute to the metrics of the plan. In addition, metric tracking provides common ground for the
project partners to work separately but collectively to a consistent goal. The cumulative tracking of
these metrics will be used to reinforce the implementation progress being made with respect to
analytical monitoring results.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 59 December 2014
Table 7-1. Dashboard groups, toolbox items, and examples of associated tracking metrics
Dashboard Groups Toolbox Items (see section 6) Example Metrics for Tracking Effectiveness
Streamside
Enhancement
Stream Buffers Linear feet/sq feet protected; # of potential sites
assessed/identified
Stream Restoration Linear feet of enhancement or restoration; # of
potential sites assessed/identified; instream habitat
index results; streambank stability index results
Public Involvement and
Outreach
Public Education and Outreach
and Public Involvement
Programs
# of stream clean-up events; # of volunteers; feet of
streams cleaned up; # of bags of trash collected; # of
events where information was distributed;
individual narratives highlighting specific public
initiatives
Research Individual narratives on current collaboration efforts
Illicit Discharge Detection and
Elimination
# of outfalls screened; # of illicit discharges
detected; # of internal training events/participants,
related to the IDDE program
Erosion and Sediment Control
Program
# of sites inspected; # of internal training
events/participants, related to the Erosion and
Sediment Control program
Pollution Prevention &
Reduction
Post-Construction Runoff
Program
# of sites inspected; # of training
events/participants, related to the Post-
Construction Runoff Program
Pollution Prevention and Good
Housekeeping
# of training events/participants, related to the
PPGH program; individual narratives illustrating an
improvement or concerted effort in water quality
protocols at a municipal maintenance facility
Collection System
Improvements
Feet of lines assessed; # of manholes assessed; feet
of lines slip-lined/replaced; # of manholes repaired
Retrofits # of potential sites assessed/identified; # of existing
sites; total drainage area of all completed BMPs;
nitrogen and phosphorus reduction estimates from
implemented BMPs; inspection & maintenance
results
Stream Health Ambient Water Chemistry* Narrative discussion of physicochemical water
quality results
Fish Community* North Carolina Index of Biotic Integrity (NCIBI) score
and rating results†
Benthos* Bioclassification results†
All monitoring* Summary of monitoring activities performed

Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 60 December 2014
Table 7-1. Dashboard groups, toolbox items, and examples of associated tracking metrics (continued)
* Items listed with the Stream Health dashboard group are not toolbox items, since they do not mitigate pollution.
† Data collected by NCDENR
Table 7-1 Photo Credits: “international tidyman” from public domain; toolbox by http://www.creattor.com/; water
drop by http://www.clipartbest.com/; fish by Kim Kraeer & Lucy van Essen-Fishman
(http://ian.umces.edu/imagelibrary/); and stream and stonefly by Tracey Saxby
(http://ian.umces.edu/imagelibrary/).

The fourth dashboard group, “Stream Health” contains all of the water quality monitoring efforts
performed by the project partners and NCDENR. While not explicitly an action to address a potential
stressor, the “Stream Health” dashboard group provides the basis for correlating progress towards the
goal with the overall efforts of the toolbox items being implemented. “Stream Health” will be compiled
from available water quality monitoring sources within and near the watershed where relevant. These
sources of water quality monitoring principally include NCDENR ambient monitoring programs,
municipal ambient monitoring programs for illicit discharge detection and elimination, and special
studies being performed by others in the watershed. NCDENR’s ambient monitoring program includes,
but is not limited to, temperature, specific conductance, turbidity, total suspended solids, dissolved
oxygen, pH, fecal coliform, nutrients, total hardness, chloride, fluoride, sulfate, oil and grease and
dissolved metals. Monitoring data will only be used where it has been collected in a manner consistent
with its prescribed quality control and assurance procedures. This is an appropriate approach given the
need to rely heavily on non-structural pollution controls and voluntary participation from the public in
order to progress towards the goal.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 61 December 2014
8.0 Path Forward
Achieving the goal of “Not Impaired”, “Good-Fair”, or better benthos bioclassification will require time
and effort on the part of the project partners as well as participation with other stakeholders within the
watershed. With this understanding, the toolbox items will be implemented within an adaptive
management framework, where they will be documented, assessed, and compared to water quality
data from Little Alamance Creek. Findings derived through the adaptive management process will be
used by the project partners to target future efforts in the watershed, in order to progress to the overall
goal. While there is no certain way of knowing when biological integrity will be restored, in consultation
with DWR, water quality standards are projected to be achieved by 2030.
8.1 Adaptive Management Process
As section 6.0 indicates, the list of BMPs performed by the project partners is extensive. In order to
make an informed decision on where to focus available resources, an adaptive management process will
be used to revise pollution controls within the watershed. The adaptive management process for this
Category 4b Demonstration Plan is built upon the overview of the historical and current state of the
watershed (Sections 1–4) and the assessment of appropriate pollution controls (section 5–6). The
adaptive management process begins with the implementation of the toolbox items (Figure 8-1, box 1).
Pollution controls and monitoring activities performed by the project partners across the Little
Alamance Creek watershed will be tracked (box 2). Efforts by the project partners will be assessed
against available water quality data collected by NCDENR and the project partners (box 3). Results of this
analysis will be used to adjust future actions performed by the project partners (box 4). A summary of
the information gathered during the adaptive management process will be presented in a website that
will be updated on a regular basis.
Figure 8-1. Adaptive management process to address biological integrity in Little Alamance Creek watershed
Review
historical and
current state
of the
watershed
(Sections 1-4)
List available
pollution
controls
(Sections 5-6)
Implement Pollution Controls (Section 6)
Track Pollution Control Effectiveness (Section 7)
Assess Progress
Toward Goal (Section 7)
Revise Pollution Controls, as needed (Section 8)
Website
1
2
3
4
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 62 December 2014
8.2 Reporting Mechanisms
A summary of the information gathered during the adaptive management process will be distributed
through a public website that will be updated on a continuous basis. The use of a website allows for
more timely and frequent updates on the efforts of the project partners throughout the watershed. The
organization of the website’s content into the four dashboard groups combined with an interactive user
experience will allow the Little Alamance Creek Category 4b Demonstration website to be accessible to
both the general public and water quality specialists. In addition to reporting on watershed activities,
the dashboard will serve the project partners in communicating with and encouraging the general public
to participate in opportunities that help to restore biological health in Little Alamance Creek.
Creation of the proposed Little Alamance Creek Category 4b Demonstration website would begin after
the approval of this Category 4b Demonstration Plan and will be hosted by the City of Burlington. While
updating the Little Alamance Creek Category 4b Demonstration website is the preferred reporting
mechanism, each project partner may elect to individually submit electronic reports to NCDENR.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 63 December 2014
9.0 Acknowledgements
This Category 4b Plan for Little Alamance Creek describes a partnership between NCDOT and the Cities
of Burlington and Graham that is designed to restore the biological integrity of Little Alamance Creek.
This Plan represents the combined efforts of staff from the North Carolina Department of
Transportation, the Cities of Burlington and Graham, URS Corporation, HDR, and Alley Williams, Carmen
and King, Inc. as listed below.
North Carolina Department of Transportation
Andrew McDaniel, P.E., North Carolina DOT
S. Craig Deal, P.E., North Carolina DOT
Brian Jacobson, P.H., CFM, URS Corporation*
Mark Fernandez, E.I., URS Corporation*
Melissa Bauguess, URS Corporation*
City of Burlington
Michael Layne, City of Burlington
Chester Patterson, City of Burlington
Patrick Blandford, P.E., HDR*
City of Graham
Josh Johnson, P.E., Alley, Williams, Carmen, and King, Inc.*

* Consultant for listed agency
In addition, valuable contributions were received from of the following: Patricia (Trish) Patterson at the
City of Burlington provided Burlington and Graham zoning GIS data. Mark H. Chilton, author of An
Historical Atlas of the Haw River, and Anne M. Cassebaum, author of Down Along the Haw: The History
of a North Carolina River, both provided insight to historical events.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 64 December 2014
References
ARCADIS G&M of North Carolina, Inc. 2008. Little Alamance Creek Stream Restoration, Alamance
County, State Construction Office Project Number: D07050S, Final Restoration Plan, for NCDENR,
Ecosystem Enhancement Program, January 2008.
Chen, X., T. Gosset, and D.R. Thevenot. 1990. Batch Copper Ion Binding and Exchange Properties of Peat.
Water Resources 24(12):1463-1471.
Davis, A.P., M. Shokouhian, H. Sharma, and C. Minami. 2001. Laboratory study of biological retention for
urban stormwater management. Water Environment Research 73(1).
DEMLR. 2013. Stormwater Permitting Program. http://portal.ncdenr.org/web/lr/stormwater (accessed
Mar 19, 2013).
DeVane, Boyd. n.d. History of Wastewater Permitting in North Carolina. PowerPoint presentation by
Boyd DeVane. Raleigh, NC: North Carolina Department of Environment and Natural Resources.
DiGennaro, N.P. 2008. Examination of Thermal Impacts from Storwater BMPs. Thesis. Rochester
Institute of Technology.
DWQ. 2003. TMDL stressor study of Little Alamance Creek, Alamance County, Cape Fear subbasin 03,
June 2003. Memo. November 3, 2003.
DWQ. 2006. Draft Summary of Existing Water Quality Data for Little Alamance, Travis, and Tickle Creek,
September 2006.
DWQ. 2008. Evaluation of Water Quality, Habitat, and Stream Biology in the Little Alamance, Tickle, and
Travis Creek Watersheds, Draft Final Report, February 2008.
DWQ. 2009. Cape Fear River Basin – 2009 Biological Assessments.
http://portal.ncdenr.org/web/wq/ess/reports
DWQ. 2010. Total Maximum Daily Load to Address Impaired Biological Integrity in the Little Alamance
Creek Watershed, Alamance County, Cape Fear River Basin, Draft, December 2010.
DWQ. 2011. North Carolina’s Division of Water Quality Category 4b Demonstration Guidance. Draft.
December 2011. http://portal.ncdenr.org/web/wq/ps/mtu/alternatives.
DWQ. 2012a. 2012 North Carolina Integrated Report. Approved by the United States Environmental
Protection Agency on August 10, 2012. http://portal.ncdenr.org/web/wq/ps/mtu/assessment.
DWQ. 2012b. Integrated Reporting Water Quality Ratings (2012 GIS layer).
http://portal.ncdenr.org/web/wq/ps/mtu/assessment.
DWR. 2013. Standard Operating Procedures for Collection and Analysis of Benthic Macroinvertebrates.
Version 4.0. December 2013. http://portal.ncdenr.org/web/wq/ess/bau.
Elon University. 2010. Little Alamance Restoration Alliance Meeting - Slide Presentation and Land Cover
Summary Statistics, Elon University Department of Environmental Studies, June 2010.
EPA. 2005. Stormwater Phase II Final Rule; An Overview. Washington, D.C.: United States Environmental
Protection Agency.
EPA. 2006a. Information Concerning 2008 Clean Water Act sections 303(d), 305(b), and 314 Integrated
Reporting and Listing Decisions, October 12, 2006.
http://water.epa.gov/lawsregs/lawsguidance/cwa/tmdl/2008_ir_memorandum.cfm.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 65 December 2014
EPA. 2006b. Wadeable Streams Assessment, A Collaborative Survey of the Nation’s Streams. Office of
Research and Development, Office of Water, Washington, ND 20460. EPA 841-B-06-002.
EPA. 2013a. A long-term vision for assessment, restoration, and protection under the Clean Water Act
Section 303(d) program.
http://water.epa.gov/lawsregs/lawsguidance/cwa/tmdl/upload/vision_303d_program_dec_2013.pd
f (accessed Jan 16, 2014).
EPA. 2013b. STORET Database. http://www.epa.gov/storet/ (accessed June 6, 2013).
Euliss, Elinor Samons, ed. 1984. Alamance County: The Legacy of Its People and Places. Greensboro,
N.C.: Legacy Publications.
Giddings, E.M., M.C. Moorman, T.F. Cuffney, G. McMahon, and D.A. Harned. 2007. Selected Physical,
Chemical, and Biological Data for 30 Urbanizing Streams in the North Carolina Piedmont Ecoregion,
2002–2003: U.S. Geological Survey Data Series 279, http://pubs.water.usgs.gov/ds279.
Hathaway, J.M., W.F. Hunt, and S. Jadlocki. 2009. Indicator Bacteria Removal in Storm-water Best
Management Practices in Charlotte, North Carolina. Journal of Environmental Engineering 135:1275-
1285.
Holm, Hannah. 2000. The Evolution of State Initiatives in North Carolina. Popular Government. Fall, 21.
Hong, E. E.A. Seagren, and A.P. Davis. 2006. Sustainable Oil and Grease Removal from Synthetic
Stormwater Runoff Using Bench-scale Bioretention Studies. Water Environmental Resources 78:141-
155
Howells, David H. 1989. Historical Account of Public Water Supplies in North Carolina. Raleigh: The
Water Resources Research Institute of the University of North Carolina.
Howells, David H. 1990. Quest for Clean Streams in North Carolina: An Historical Account of Stream
Pollution Control in in North Carolina. Raleigh: The Water Resources Research Institute of the
University of North Carolina.
Jones, M.P. and W.F. Hunt. 2009. Bioretention impact on runoff temperature in trout sensitive waters.
Journal of Hydrologic Engineering (ASCE) 135(8).
Lounsbury, Carl. 1980. Alamance County Architectural Heritage. Graham, N.C.: Alamance County
Historical Properties Commission.
Messer, T.L., M.R. Burchell II, G.L. Grabow, and D.L. Osmond. 2012. Groundwater nitrate reductions
within upstream and downstream sections of a riparian buffer. Ecological Engineering 47:297-307.
NCDENR. 2007. North Carolina Division of Water Quality Stormwater Best Management Practices
Manual.
NCDENR. 2010. Overview of Proposed Falls Lake Nutrient Strategy. Raleigh: North Carolina Department
of Environment and Natural Resources.
NCDENR. 2014. Watershed Assessment and Restoration Program (WARP) Project File Archive.
http://portal.ncdenr.org/web/wq/swp/ws/pdu/wat/warp (accessed Jan 16, 2014).
NCDENR. n.d.-a Development of the Jordan Lake Nutrient Strategy. Raleigh: North Carolina Department
of Environment and Natural Resources.
NCDENR. n.d.-b Jordan Lake Nutrient Management Strategy. Raleigh: North Carolina Department of
Environment and Natural Resources.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 66 December 2014
NCDENR. n.d.-c Riparian Buffer Rules, Jordan Lake Watershed, Neuse River Basin (including Falls Lake
Watershed). Slide deck.
NCDOT. 2008. Stormwater Best Management Practices Toolbox, Version 1, March 2008.
North Carolina Cooperative Extension Service. n.d. Economic Impacts of the Water Supply Watershed
Protection Act. Raleigh: North Carolina Cooperative Extension Service.
NCEEP. 2007. Little Alamance, Travis, and Tickle Creek Watershed Characterization Phase I, Final Report
for NCDENR NCEEP, March 2007.
NCEEP. 2008. Little Alamance, Travis, and Tickle Creek Watersheds Assessment: An Ecosystem
Enhancement Program Funded Local Watershed Plan Phase II, for NCDENR NCEEP June 2008.
Rosgen, D.L. 1997. A geomorphological approach to restoration of incised rivers. Proceedings of the
Conference on Management of Landscapes Disturbed by Channel Incision. ISBN 0-937099-05-8.
Spoon, William L. 1893. Map of Alamance County, North Carolina. Cleveland, Ohio: H.B. Stranahan &
Co., Engravers.
Stockard, Sallie Walker. 1900. The History of Alamance. Raleigh. N.C.: Capitol Printing Company.
Sullivan, T.J., J.A. Moore, D.R. Thomas, E. Mallery, K.U. Snyder, M. Wustenberg, J. Wustenberg, S.D.
Mackey, and D.L. Moore. 2007. Efficacy of Vegetated Buffers in Preventing Transport of Fecal
Coliform Bacteria from Pasturelands. Environmental Management 40:958-965.
Sweet, David G. n.d. Indigo in World History: Production, Distribution & Consumption: 1-16.
The Burlington Daily Times-News. 1950. 6 December.
The Burlington Daily Times-News. 1951. 27 April.
The Burlington Daily Times-News. 1962a. 11 January.
Troxler, Carole Watterson. 2000. East-west Pattern of the Trading Path Network in Alamance County.
Alamance County Historical Association. http://facstaff.elon.edu/troxlerc/alacotp.htm (accessed Dec
16, 2013).
Troxler, George W. 2006. Company Shops. NCPEDIA. http://ncpedia.org/company-shops (accessed Dec
20, 2013).
URS. 2014. Little Alamance Creek 4b Demonstration Project Existing Data Inventory.
http://portal.ncdenr.org/web/wq/ps/mtu/alternatives.
US Census. 2014. http://quickfacts.census.gov/qfd/states/37/37001.html (accessed May 19, 2014).
USFWS (US Fish and Wildlife Service). 2013 http://www.fws.gov/wetlands/Data/State-Downloads.html
(accessed July 9, 2013).
Vacca, Michele, and Benjamin Briggs. n.d. History of Alamance County 1670-1945. Alamance County
Architectural Survey Update.
http://www.hpo.ncdcr.gov/surveyreports/AlamanceCountySurveyUpdate(Historic%20Contexts)-
2002.pdf (accessed Dec 16, 2013).
Vincent, William Murray. 2009. Historic Alamance County: A Biographical History. San Antonio, Texas:
Historical Publishing Network.
Whitaker, Walter. 1949. Centennial History of Alamance County, 1849-1949. Durham: The Seeman
Printery, Inc.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC

This page intentionally left blank

Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC

Appendix A

Letters of Commitment to Category 4b Demonstration
in Little Alamance Creek

Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC

This page intentionally left blank
Mr. Chuck Wakild
Director
NC Division of Water Quality
1601 Mail Service Center
Raleigh, N.C. 27699-1601
.9l.ugust 8, 2012
Subject: Category 4b Demonstration as an altemative management approach to the
draft impervious cover limitation TMDL for Little Alamance Creek
Dear Mr. Wakild :
The City of Burlington has been investigating pursuing a Category 4b Demonstration for
Little Alamance Creek since our December 2, 2011 letter to former NC DWQ Director
Coleen Sullins. While the City still has reservations about the appropriateness about
TMDLs that use impervious cover as a sunogate for water quality, our investigation has
led us to committing to developing a Category 4b Program.
NC DWQ established a deadline for the stakeholders in Little Alamance Creek to commit
to the 4b demonstration was established in order to allow the municipalities to budget
effectively for program creation. As such the City of Burlington has funds in its cunent
budget to begin development of the Category 4b Program. In keeping with former NC
DWQ guidance, specifically the City's original draft NPDES Stormwater Permit about
impaired/TMDL waters, the City plans to develop its Category 4b program over the next
24 months from the acceptance of this letter by NC DWQ. Once the program is created
the City will submit it to NC DWQ for approval.
We look forward to working with DWQ staff on this important initiative to begin the
process of restoring the biological integrity of Little Alamance Creek. If you or your staff
have any questions or need any additional information please contact our Stormwater
Administrator, Michael Layne, P.E. at [phone] or via email at
[e-mail].
Connecting tlie Triatf ani tlie Triangfe
425 South LexjngtonJlvenue -PO 'Boi(1358-'Burfington, r;{C 27216
(336}222-5000 business
www. 'Burfingtonr;{C.gov
i.lDPZZ..J
Harold Owen, City Manager
Cc: Josh Jolmson, P.E. Alley, Williams, Carmen, and King
Michael Layne, P.E. City of Burlington
Andy McDaniel, P.E. NCDOT
Chris Rollins, City Manager City of Graham
Kathy Stecker, NC DWQ Planning Section
Mike Randall, NC DWQ Surface Water Protection Section
July 24, 2012
Mr. Chuck Wakild
Director
NC Division of Water Quality
1601 Mail Service Center
Raleigh, N.C. 27699-1601
Q!ity nf ~ra4am
P. 0. Drawer 357
201 South Main Street
Graham, North Carolina 27253
Tel: [phone] I Fax: [phone]
Subject: Category 4b Demonstration as an alternative management approach to the draft
impervious cover limitation TMDL for Little Alamance Creek
Dear Mr. Wakild:
The City of Graham has investigated pursuing a Category 4b Demonstration for Little Alamance Creek
since my November 30, 20111etter to former NC DWQ Director Coleen Sullins. While the City still has
reservations about the appropriateness of TMDls that use impervious cover as a surrogate for water
quality, our investigation has led us to commit to developing a Category 4b Program.
The July 2012 deadline in the original letter for the stakeholders in Little Alamance Creek to commit to
the 4b demonstration was established to allow the municipalities to budget effectively for program
creation. As such the City of Graham has funds in its current budget to begin development of the
Category 4b Program and plans to begin development this month. In keeping with former NC DWQ
guidance, specifically the City's original draft NPDES Stormwater Permit about impaired/TMDL waters,
the City plans to develop its Category 4b program over the next 24 months from the acceptance of this
letter by NC DWQ. Once the program is created the City will submit it to NC DWQ for approval.
We look forward to working with DWQ staff on this important initiative to begin the process of restoring
the biological integrity of Little Alamance Creek. If you or your staff have any questions or need any
additional information please contact our stormwater engineer, Josh Johnson, P .E. at [phone] or
through email at [e-mail].
Respectfully Submitted,
5~D ;
Chris Rollins, City Manager
Cc: Josh Johnson, P.E. Alley, Williams, Carmen, and King
Michael layne, P.E. City of Burlington
Andy McDaniel, P.E. NCDOT
Kathy Stecker, NC DWQ Planning Section
Mike Randall, NC DWQ Surface Water Protection Section
   Category 4b Demonstration Plan to Address 
   Biological Impairment in Little Alamance Creek, NC 

This page intentionally left blank 

STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
BEVERLY EAVES PERDUE
GOVERNOR
Mr. Chuck Waklid
Director
NC Division of Water Quality
160 1 Mail Service Center
Raleigh, N.C. 27699-1601
July 27, 2012
EUGENE A. CONTI, JR.
SECRETARY
Subject: Category 4b Demonstration as an alternative management approach to the
draft impervious cover limitation TMDL for Little Alamance Creek
Dear Mr. Waklid:
On October 21, 2011 the NCDOT participated in a meeting to discuss alternative
management approaches to restoring the biological integrity of Little Alamance Creek in
the Cape Fear River basin. The meeting was attended by representatives from DWQ's
Modeling & TMDL Unit, the Stormwater Permitting Unit, along with several local
government staff persons from across the state. As a follow-up to this meeting, on
November 22, 2011 I sent former Director Coleen Sullins a letter describing NCDOT's
commitment to further investigate the feasibility of preparing a Category 4b
Demonstration as an alternative to the draft impervious cover limitation TMDL, and as a
framework for achieving our common goal of restoring water quality standards in Little
Alamance Creek. In this letter NCDOT committed to work with its project partners at
DWQ and the cities of Burlington and Graham to reach a final decision on pursuing a
Category 4b Demonstration by July 2012.
Upon further investigation of the Category 4b process and in consultation with
representatives of Burlington and Graham, NCDOT believes a Category 4b
Demonstration is a viable alternative management approach to the draft impervious cover
limitation TMDL for Little Alamance Creek. As such, NCDOT commits to a cooperative
working partnership with Burlington and Graham to prepare a joint Category 4b Plan
designed to restore the biological integrity of Little Alamance Creek. NCDOT and its
municipal partners will submit the Plan to DWQ for your review and approval within a
time period no longer than twenty four (24) months after receiving written notice-to­
proceed from your office.
MAILING ADDRESS:
NC DEPARTMENT OF TRANSPORTATION
HYDRAULICS UNIT
1590 MAIL SERVICE CENTER
RALEIGH NC 27699-1590
TELEPHONE: [phone]
FAX: [phone]
WEBSITE: WWW.NCDOT. ORGIDOHI
LOCATION:
CENTURY CENTER COMPLEX
BUILDING B
1 020 BIRCH RIDGE DRIVE
RALEIGH NC
We look forward to working with DWQ staff and our municipal partners to begin the
process of restoring the aquatic life support uses of Little Alamance Creek. We hope you
concur with our findings that a Category 4b Demonstration is indeed a viable alternative
to an impervious cover limitation TMDL and we look forward to receiving your letter of
notice-to-proceed so we can begin this important project. If you or your staff have any
questions or need any additional information please contact Andy McDaniel, PE of my
staff at (919) 707-673 7 or through email at [e-mail].
Respectfully Submitted,
~~
David Chang, PhD, PE
State Hydraulics Engineer
Hydraulics Unit
NC Department of Transportation
cc: Kathy Stecker (DWQ)
Mike Randall (D WQ)
Mike Mills, PE (NCDOT)
Jerry Parker (NCDOT)
Don Lee, CPESC (NCDOT)
Ken Pace, PE (NCDOT)
Andy McDaniel, PE (NCDOT)
Harold Owen (City of Burlington)
Michael Layne, PE (City of Burlington)
Chris Rollins (City of Graham)
Josh Johnson, PE (Alley, Williams, Carmen, and King)
~ mJ ((; ~~ fl -r\t7 r!-::i @' ;;;:;:) .... ;;,;> :.::::.1 <1 0 r? ~) ._e.l ~
I
U AUG t 8 2012
~CDENR
North Carolina Department of Environment and Natural Resources DIVISIO~ OF HIGHWAYS
Division of Water Quality HYOAAUUCS~
Beverly Eaves Perdue
Governor
David Chang, PhD, PE
State Hydraulics Engineer
NC Department of Transportation
1590 MSC
Raleigh, NC 27699
Dear Dr. Chang:
Charles Wakild, P. E. Dee Freeman
Director Secretary
August 23, 2012
Our Director, Mr. Charles Wakild, asked me to respond to your July 27, 2012 letter regarding a Category
4b demonstration as an alternative management approach for Little Alamance Creek. According to EPA
guidance, Category 4b is appropriate for situations where a TMDL is not needed, because other
pollution control requirements are expected to result in the attainment of an applicable water quality
standard in a reasonable period of time. DWQ concurs that a Category 4b demonstration is a viable
alternative to the draft TMDL for Little Alamance Creek.
Please consider this letter to be your requested notice-to-proceed. We understand that within the next
24 months, NCDOT, Burlington, and Graham will submit documentation addressing each of the required
six elements of a 4b demonstration. We request that st~ff assigned to developing the 4b plan arrange
to meet with DWQ staff early in the process and then periodically as development proceeds. This will
help to ensure that the product is consistent with federal regulations and EPA's recommended
structure.
Thank you for your commitment to restoring Little Alamance Creek. Please contact me if you have any
questions. My phone number is 919-807-6331, and my email address is [e-mail].
Sincerely,
~ ~ pr ~ SJ.e_c_b_r
Kathy Stecker, Supervisor
Modeling and TMDL Unit
cc: Mike Randall
Andy McDaniel, DOT
Michael Layne, Burlington
JoshJohnson,AWCK
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] I FAX: [phone]
Internet www.ncwateroualitv.org
An Equal Opportunity\ Affirmative Action Employer N~rthCarolina
;!Vaturalllf
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC

This page intentionally left blank

Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC

Appendix B

Historical Watershed Information

Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC

This page intentionally left blank
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 B-1 December 2014
Historical Watershed Information
The original native inhabitants of present day Alamance County were referred to as the Shackory Indians
by the German explorer Dr. John Lederer in 1670 (Euliss 1984, 5). More commonly known as the
Sissipahaw Indians, they were Siouan and had settled between the Eno and Haw Rivers. Numerous
village sites have been located along the Haw River and Alamance Creek which indicate that the
Sissipahaw raised crops on fertile floodplains and hunted wild game.
Little else is known about the Sissipahaw. Native Americans left the area before the arrival of European
settlers perhaps merging with the Catawba Indians, the largest Siouan tribe in the Piedmont. European
settlement of the area began in the early 1700s; however, following the Tuscarora Indian Wars (1711–
1713) and the English Crown’s purchase of the Lords Proprietor’s Colony (1729) many more settlers
moved into the area (Vacca and Briggs, n.d, under “Colonial History: European Settlement”).
The Indian Trading Path linked Indians in east central Virginia with the Catawba Indians west of the
Yadkin River in North Carolina. A segment of the Trading Path passed through Alamance County from
northwest of Hillsborough toward Mebane crossing the Haw River at the Town of Haw River (Troxler
2000, under “East-west Pattern of the Trading Path Network in Alamance County”). Beyond the Haw
River the Path split into a “western Trading Path” and a “lower Trading Path”. The western Trading Path
continued to Graham and beyond where it crossed both Little Alamance Creek and Great Alamance
Creek.
The Trading Path became important for commerce between Virginia traders and the Catawba nation. In
1728 Colonel William Byrd of Virginia described the Trading Path as traversing “…the most fertile high
land in this part of the world…” (Euliss 1984, 5). This and other similar descriptions of the area attracted
settlers from the middle and northern colonies. Land in the Piedmont region of North Carolina was
relatively inexpensive when compared to land in Pennsylvania.
Quakers, Scots-Irish Presbyterians, and German Lutherans and Reformed from Pennsylvania were
among early immigrants who established numerous settlements in Alamance County (Vacca and Briggs,
n.d., under “Colonial History: Settlement Patterns”). German Lutheran and Reformed settlers located
along Alamance Creek and Stinking Quarters Creek. English, German, and Welsh Quakers settled near
Snow Camp along Cane Creek. Scots-Irish Presbyterians chose settlements in eastern Alamance County
near Hawfields.
Land Uses and Population
Agriculture and silviculture were significant land uses in both the eighteenth and nineteenth centuries.
Timber was harvested and sawmills were constructed to supply lumber to build settlements and later
towns. The earliest farming was for subsistence and included growing fruits and vegetables and raising
cattle and hogs. Corn, wheat, oats and rye, flax, and tobacco were grown later in the eighteenth century
as commercial crops. Numerous gristmills were built along the Haw River and its tributaries to produce
corn meal and flour.
Many of these streams were ideal locations to construct dams and provided the channel slope and
stream flow needed for mill races and water wheels. During the Industrial Revolution some early mill
sites became the location for textile mills. Most textile mills provided water power for spinning
machines and looms. Some mills were later converted to steam power. By the late 1830s there were 41
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 B-2 December 2014
gristmills in Alamance County (Vacca and Briggs, n.d, under “Textile Industry”). In 1879 there were 40
gristmills and 24 sawmills. Over one-half of these mills were built during the previous 20 years
(Lounsbury 1980, 68). As late as 1928 there were still 30 mills, mill dams, or mill sites located in the
county.
A number of mills were located along Little Alamance Creek. A map of Alamance County shows six
hydro-powered mills located along Little Alamance Creek between its confluence with Great (Big)
Alamance Creek and present-day Burlington (Figure B-1).
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 B-3 December 2014

Figure B-1. Historic map of Alamance County indicating six mills (the Rogers & Curtis Mill, the Harden Mill,
Whittsett’s Mill, W.F. Jones’s Mill, Sellar’s Old Saw Mill, and Coble’s Mill) located within the Little Alamance
Creek watershed (Spoon, 1893)
In 1832, John Trollinger built the first cotton mill in the county located on the Haw River north of Stony
Creek. In 1837, Edwin M. Holt and his brother-in-law William Carrigan founded the Alamance Cotton
Factory on Alamance Creek at Alamance.
Big Alamance Creek
Little Alamance Creek
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 B-4 December 2014
Carrigan later sold his interest to Holt who also acquired the Granite Cotton Factory at Haw River in
1845. In 1849, Edwin M. Holt built a yarn mill on the Haw River at Saxapahaw. He is considered the most
important of the early mill owners in Alamance County. It was largely his vision that led to the growth of
the textile industry in Alamance County and North Carolina.
Prior to that time most cotton grown in North Carolina was shipped to northern manufacturers to be
converted into yarn. North Carolina mills were in turn paying higher prices for the yarns produced by the
northern mills. Holt realized that building cotton mills in Alamance County would take advantage of
already having the raw materials nearby, benefit from low freight rates to the mill, utilize established
mill sites for water power and have abundant labor.
In 1879 there were six cotton mills in the county. By 1886 the number of mills had grown to 13, and by
1890 there were 17 mills. In 1890 there were also numerous grain and sawmills in the county.
It was also Edwin M. Holt who produced the first colored cotton goods in the South. In 1853, Holt’s son,
Thomas M. Holt, learned the art of dying cotton yarn. He and his father installed looms in the Alamance
Cotton Factory on Alamance Creek specifically for producing woven, dyed cotton cloth. This cloth
became known as Alamance Plaids (Stockard 1900, 92).
Holt’s mills produced hundreds of yards of cloth used to make Confederate uniforms during the Civil
War. In 1883, he built the E.M. Holt Plaid Mills in present-day Burlington. Alamance Plaids were also
manufactured at the Plaid Mills (Whitaker 1949, 103) and were very popular in both southern and
northern markets. In 1900, the E. M. Holt Plaid Mills converted from the plaid fabric to gingham which it
continued to produce until 1931 when it was converted again to manufacture yarn goods.
At least three late nineteenth century cotton mills were built near the headwaters of several Little
Alamance Creek tributaries. These were the Plaid Mills (1883) in present-day Burlington, the Oneida Mill
(1882), and the Sidney Mill (1885) both in present-day Graham (Dickenson 1987, various pages).
Color-fast indigo dye was used to produce the first Alamance Plaids (Vincent 2009, 76). Indican, a
natural blue colorant is found in many plants world-wide. Indigofera plant varieties are generally
considered to produce the largest amounts of Indican per plant and were highly desirable as sources for
Indigo dye in the nineteenth century.
The production of Indigo dye followed essentially the same process world-wide between the sixteenth
and the nineteenth centuries (Sweet, n.d, 1-16). Indican is a water-soluble glucoside which is easily
extracted by steeping the plant leaves and stems in water. In the nineteenth century the production of
Indigo dye required a series of large vats.
After steeping, the liquid created was allowed to ferment for 10 to 12 hours. During fermentation a
natural enzyme known as Indimulsin was added to hydrolyze the Indican and eliminate glucose. The
liquid would literally heave and swell and develop a foul odor.
The fermented liquid was then decanted into another vat exposing the Indican to air. The resultant
oxidation process transformed the Indican into an insoluble form. Once in the second vat the fermented
liquid was beaten or flailed with large paddles for several hours causing a precipitate called Indigotin to
form in the bottom of the vat. The precipitate was dried and cut into small blocks of Indigo dye.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 B-5 December 2014
To be used as dye these blocks were ground into a powder and mixed in an alkaline (mordant) bath.
Mordant agents were often metal oxides and included, at various times, tannic acid, alum, urine,
chrome alum, sodium chloride, and certain salts of aluminum, chromium, copper, iron, iodine,
potassium, sodium, and tin (Wikipedia 2014, under “Mordant”). They served to make the Indigo soluble
again and enhanced the saturation of the yarn or cloth with the dye during the dyeing process. Once
dyed the yarn or cloth was exposed to air to dry. The resultant oxidation process once again
transformed the Indican into an insoluble form making the dye color-fast.
The production and use of indigo dye resulted in potential sources of surface water pollution. In addition
to the reactants normally used in the production of the dye, caustic lye (sodium hydroxide) and slaked
lime (calcium hydroxide) were sometimes added during the dyeing process to aid fermentation and to
modify color intensity, respectively. Chemical by-products from the dyeing process had the opportunity
to enter the environment at three stages: during the manufacturing of the dye, during the application of
the dye to the yarn or cloth, and during disposal.
In the late nineteenth century the first hosiery mills in the county began operation. In the 1920s, many
cotton mills were converted to produce rayon and other fabrics. By 1934, Burlington Mills was the
largest producer of rayon in the United States (Vacca and Briggs, n.d, under “Textile Industry”).
Railroad
In 1849, the North Carolina General Assembly enacted legislation creating the North Carolina Railroad
Company. The action included a charter to construct a railroad to connect western North Carolina with
the Goldsboro terminus of the Wilmington and Weldon Railroad (Vincent 2009, 12). Various owners of
textile mills in Alamance County were among the chief proponents of the railroad (Euliss 1984, 13).
Construction began in 1851 with the route passing through central Alamance County. The first train
traveled the entire route from Goldsboro to Charlotte in January 1856. The advent of the railroad
significantly shaped the future of a number of towns and cities including Burlington and Graham.
The route of the railroad greatly influenced area demographics and ensured that late nineteenth
century mills and other manufacturing concerns would locate in towns near the railroad (Vincent 2009,
12). Indeed, seven late nineteenth century cotton mills were located adjacent to or in close proximity to
the railroad in the present-day cities of Burlington and Graham. The railroad alignment followed the
ridgeline that defines the upper watershed boundary of Little Alamance Creek.
A repair station was built midway along the route to service locomotive engines and rolling stock.
Construction began in 1855 and was largely complete by 1859. The station was known as Company
Shops and attracted engineers, mechanics, and other skilled workers from 10 states and several foreign
countries (Vincent 2009, 13).
The rapid population growth and diversity ultimately transformed the railroad town into a community of
varied cultural backgrounds. The original railroad directors envisioned a company town characteristic of
nineteenth century industrial development (Troxler 2006, under “Company Shops”). To control
development they acquired 632 acres, although the railroad shops occupied less than 30 acres.
By 1859, Company Shops included 57 buildings. Within the repair station seven shop structures were
built including two machine shops, a blacksmith shop, a foundry, a carpentry shop, an engine shed, and
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 B-6 December 2014
car shed. In addition, a passenger and freight station, a two-story hotel, houses for workers and railway
officials, and a company headquarters building were constructed.
Company Shops remained a village until 1863 when company stockholders approved the layout of
streets and the sale and lease of lots. The village was incorporated in 1866. In 1871, the railroad was
leased to the Richmond & Danville Railroad which was working in concert with the Pennsylvania
Railroad to link the Northeast with the South. By 1893 the North Carolina Railroad had become part of
the Southern Railway system.
Southern Railway built new shops in Spencer, North Carolina. The acquisition of the railroad and the
new shops in Spencer resulted in the transfer of many jobs. Resentment toward the railroad led citizens
to seek a change in the town name. In February 1887, the North Carolina General Assembly changed the
municipal charter and Company Shops formally became Burlington.
Sewage Discharge
In 1950, numerous complaints against the City of Burlington were filed with the North Carolina State
Board of Health by citizens living along Little Alamance Creek. At that time the City of Burlington was
discharging sewage into Little Alamance Creek. As more complaints had been filed against the City of
Burlington than any other city in the state, the State Board of Health urged the City to construct a
sewage disposal plant to avoid multiple law suits (The Burlington Daily Times-News, 6 December 1950).
On April 26, 1951, a claim in the amount of $20,000 was filed against the City of Burlington by two
residents of Graham for alleged damages arising from the City’s discharge of sewage into Little
Alamance Creek (The Burlington Daily Times-News, 27 April 1951). On January 10, 1962 the United
States Community Facilities Administration approved a $38,235 loan for the preliminary planning of a
major interceptor sewage line and waste treatment plant for the Little Alamance Creek drainage area
(The Burlington Daily Times-News, 1962a).
The Burlington city council voted unanimously on January 16, 1962 to purchase a 58-acre tract for the
construction of a waste treatment plant to be located near the confluence of Big Alamance Creek and
the Haw River (The Burlington Daily Times-News, 17 January 1962).
The proximity of various mills and other industrial enterprises to Little Alamance Creek and its
tributaries could have resulted in the discharge of potential pollutants dating to the Colonial period.
History of North Carolina’s Water Quality Permitting Programs
Eighteenth century interest in public water supply in antebellum North Carolina was mainly focused on
fire protection (Howells 1989, 1). Well into the nineteenth century unsafe water supplies were
frequently the cause of illness and death. Mortality figures from the Civil War reveal more deaths from
disease than from battle with water-borne illnesses often cited as the cause.
In response to growing concern for hygiene and sanitation, the North Carolina General Assembly
created the North Carolina Board of Health in 1877. Early water quality analyses were limited by the
incomplete understanding of the connection between water chemistry and disease and by the simplistic
analytic technology of the time (Howells 1989, 5). Still, these efforts successfully made the connection in
some instances between contaminated groundwater wells and illness.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 B-7 December 2014
Public concern for stream sanitation grew to include aquatic life and nuisance conditions. In 1883, the
North Carolina General Assembly enacted An Act to Prevent Poisoning Streams of Water in this State.
The Act made it illegal to use poisonous substances to catch, kill, or drive fish in waters, creeks, and
rivers of the state (Howells 1990, 4).
In 1886, both the City of Durham and the City of Raleigh acted to provide community water systems. By
1888, the North Carolina Board of Health reported 12 communities with public water supply systems
although the water quality for each varied. Turbidity was often reported. There was little to no use of
the water provided by poorer classes, presumably because of the cost.
These early public water supplies generally received no treatment other than some degree of
sedimentation. Whether deep wells or streams, the water sources themselves were not protected and
were vulnerable to pollution. For this reason the City of Raleigh sought legislation in 1887 to protect the
stream and watershed of Walnut Creek.
Thirty-five North Carolina counties reported cases of Typhoid fever in 1888. In 1889, the North Carolina
Board of Health issued several advisories that Cholera and Typhoid fever were commonly caused by
polluted drinking water and recommended that drinking water be boiled. This time period also saw the
general acceptance of the need to disinfect waste and treat sewage.
Beginning in 1889, the North Carolina General Assembly passed numerous legislative prohibitions
against pollution from lumber mill sawdust. Similar legislation was passed for various counties through
1921 (Howells 1990, 9).
In 1893, the North Carolina General Assembly authorized the North Carolina Board of Health to oversee
all inland waters and determine their potential as domestic water supplies. This authority extended to
the protection of watersheds. One early effect of this authorization was determining that the Little River
water supply for the City of Goldsboro was contaminated by streams draining unsanitary areas of the
City. The City was advised to abandon the river and obtain public water from deep wells.
In 1897, legislation was introduced in the North Carolina General Assembly that would have extended
the police powers of cities and towns to their water supply watersheds and would have required
periodic watershed inspections (Howells 1989, 22). Although the legislation was not enacted it
prompted the North Carolina Board of Health to order all municipal water supplies inspected and tested
chemically and bacteriologically. In 1899, the North Carolina General Assembly adopted legislation that
required public water companies to undertake quarterly biological and chemical analyses.
By 1902, the number of North Carolina towns having public water supplies had grown to 27; however,
the North Carolina Board of Health continued to express concern with the quality of the water furnished
by some of the systems. The quarterly watershed inspections and water quality analyses were generally
not being observed (Howells 1989, 35). Treatment was still commonly limited to mechanical filtration at
times augmented by coagulation prior to filtration. Water quality analyses had improved to some
degree but chemical analysis for chlorine, ammonia, nitrate and nitrite was limited.
Prior to the 1950s, there was no effective statewide law to control discharges to waters of the state
(DeVane, n.d.). In 1895, the North Carolina Board of Health reported that raw sewage was discharged to
Walnut Creek, the water source for the City of Raleigh. Discharge of raw sewage directly to streams or
their tributaries was common. In 1903, the North Carolina General Assembly adopted An Act to Protect
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 B-8 December 2014
Water Supplies. Under the law, pollution of water sources was considered a misdemeanor offense
subject to fines and imprisonment.
In 1905, the City of Durham sued Eno Cotton Mills under the Act alleging their wastewater discharge
resulted in pollution of the City’s Eno River water supply. The court ruled in favor of Durham, a decision
that was subsequently sustained on appeal to the State Supreme Court (Howell 1989, 38).
By 1907, the North Carolina Board of Health had published water purification standards and advocated
bacteriological analysis as the most appropriate test for acceptable drinking water. It was during this
period that analyses for coliform indicator bacteria were first recommended.
During this time, there were 48 communities with public water supplies but only 25 with sewer systems.
Efforts to treat drinking water and protect public water supply watersheds continued. The North
Carolina Board of Health first recommended disinfection with compounds of chlorine in 1911.
The same disinfection requirement was not applied to the discharge of sewage. While it was
acknowledged by this time that studies of sewage treatment and industrial wastes were needed to
determine the assimilative capacity of receiving streams, there appears to have been some debate
surrounding the legal rights of municipalities to discharge sewage. As late as 1926, a citizen petitioned
the North Carolina Board of Health with concerns about the Town of Warsaw’s raw sewage discharge.
The Board declined to make specific finding or recommendations citing differences of opinion about the
judicial right to discharge raw sewage to a stream.
Similarly the Town of Smithfield petitioned the North Carolina Board of Health over concerns about the
City of Raleigh discharge of sewage. The Town alleged health hazards arising from contamination of
their Neuse River water supply. Ultimately the Town of Smithfield sued the City of Raleigh in 1934
(DeVane, n.d.). The Superior Court ruled in favor of the Town as did the State Supreme Court on appeal.
The City of Raleigh was ordered to build a sewage disposal plant.
In 1911, the North Carolina General Assembly passed the first state legislation to prevent stream
pollution from the disposal of tailings waste from mining activities (Howells 1990, 11). In 1915, the
North Carolina General Assembly created a Fisheries Commission Board to oversee commercial fishing
and authorized it to enforce discharges to state waters of deleterious materials and substances
poisonous to fish life. Following this legislation the North Carolina General Assembly adopted An Act to
Prevent Pollution of Fishing Stream and Trespass on State Fish Hatchery Property in 1927.
In 1927, a Stream Sanitation and Conservation Committee was formed representing the North Carolina
Board of Health and the Conservation Commission. The committee was charged with investigation of
stream pollution on the Neuse, Haw, Tar, Catawba and Roanoke Rivers (Howells 1989, 59).
Increasing concern for interstate waters pollution resulted in the North Carolina General Assembly
enacting An Act Providing for Administration and Control of Interstate Waters in 1929.
In the 1930s, the North Carolina Board of Health frequently cited stream pollution as one of the State’s
greatest problems. In 1945, the North Carolina General Assembly established the State Stream
Sanitation and Conservation Committee.
At the federal level, the first legislation to address water pollution was the 1899 Refuse Act. While its
primary purpose was to prevent discharge of refuse into navigable waters, it was used successfully in
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 B-9 December 2014
the 1960s as an enforcement tool for the discharge of wastewater to navigable waters. The United
States Congress enacted Public Law 845, the Federal Water Pollution Control Act in 1948. It was the
beginning of the federal-state cooperative water pollution control programs that continue today.
In 1951, the North Carolina General Assembly enacted the State Stream Sanitation Act which
established the State Stream Sanitation Committee as an autonomous committee within the North
Carolina Board of Health (Howells 1989, 60). The law authorized a comprehensive stream pollution
control program determined by stream classification, which was based upon present or contemplated
best usage.
The State Stream Sanitation Committee adopted stream classifications and standards in 1953 (DeVane,
n.d.). The classifications were A-I: Protected Water Sources, A-II: Water Supply Sources Requiring Full
Treatment, B: Body Contact Recreation, C: Fish Life Propagation, D: Agriculture, Fish Survival, Industrial
Cooling and Processes, and E: Navigation, Sewage and Industrial Waste and Disposal Short of Nuisance
Conditions. For saline waters the classifications were SA: Shellfish Growing, SB: Body Contact Recreation,
SC: Fish Propagation, and SD: Navigation Short of Nuisance Conditions.
In 1955, the North Carolina General Assembly adopted acts to prohibit discharges of raw sewage,
industrial waste and other noxious and deleterious substances into the Haw River and the Northeast
Cape Fear River. Pollution of these waters was defined as conditions not meeting their best usage
classification or violation of applicable water quality standards (Howells 1990, 79).
During the 1950s, different committees within the North Carolina Board of Health administered the
stream sanitation law and health code. The Division of Water Pollution Control was responsible for
sources of pollution to classified waters. The Sanitary Engineering Division was responsible for sources
of pollution to unclassified waters. In 1959, the Stream Sanitation Committee along with its Division of
Water Pollution Control was transferred to a new Board of Water Resources.
The Federal Water Pollution Control Act was amended in 1956 by enactment of Public Law 660. The
amendments authorized federal grants for construction of publicly-owned wastewater treatment plants,
increased technical assistance, broadened research, and increased federal enforcement of wastewater
discharges to interstate waters. The Act was amended again in 1961 and 1965. The 1965 requirements
included standards for all streams in the United States, state-issued water quality standards for
interstate waters, and authorization for the Federal Water Pollution Control Administration to set
standards where states failed to do so.
The Water and Air Resources Act was enacted in 1967 by the North Carolina General Assembly. The
legislation called for pollution and water use surveys, preparation of comprehensive pollution
abatement plans and development of surface water classifications based upon best use and associated
water quality standards (Howells 1989, 61). The Board of Water Resources became the Board of Water
and Air Resources. In 1968, the state’s lowest stream classification (E) was abolished.
Federal Water Pollution Control Administration regulations adopted in 1970 required cities receiving
industrial wastes into their sewage systems to adopt sewer use ordinances. The ordinances provided for
the collection of user charges sufficient to reimburse the cities for the cost of treating industrial waste.
On July 9, 1970, the Federal Water Pollution Control Administration was transferred to the newly
created Environmental Protection Agency.
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 B-10 December 2014
The North Carolina Pesticide Act of 1971 was enacted to address the fate of pesticides and their
potential pollution of stream and lakes causing danger to aquatic life. The sale and use of pesticides
were regulated and licensure was required for dealers and applicators (Howells 1990, 120).
In 1971, the North Carolina General Assembly authorized the first appropriations to aid the construction
of local wastewater treatment plants. Also in that year the North Carolina General Assembly authorized
a bond referendum to aid public water supply, strengthened enforcement provisions and pollution
control monitoring requirements, and established minimum standards for public water supplies.
In 1971, the North Carolina General Assembly transferred the Department of Water and Air Resources
to a new Department of Natural and Economic Resources. The Board of Water and Air Resources
became the North Carolina Environmental Management Commission (EMC) along with its Division of
Environmental Management on July 1, 1974.
Also in 1971, the North Carolina General Assembly enacted the Mining Act. A major intent of the
legislation was to condition the issuance of mining permits on pollution control measures. Permits could
be denied if the mining operation would adversely affect freshwater, estuarine, or marine fisheries or
violate water quality standards.
The Federal Water Pollution Control Act was again amended in 1972. The amendments increased the
maximum federal contribution for matching grants to construct publicly-owned waste treatment plants.
The Act also required that all new and existing industrial discharges be permitted under the National
Pollutant Discharge Elimination System (NPDES). Permitting was also required for sanitary waste
discharges along with point source discharge technology-based standards. In 1975, the Environmental
Protection Agency delegated responsibility to North Carolina for the administration of NPDES permits.
With the 1972 amendments to the Federal Water Pollution Control Act the original focus on protection
of public water supplies was broadened to include protection of all water uses. Section 401 of the
legislation authorized states including North Carolina to require water quality certifications for federally-
permitted or licensed activities that could result in a discharge of pollutants into waters of the United
States. The certifications required that all state water quality standards, limitations, and restrictions be
met and were a condition for issuance of the federal permit or license. Section 401 was applicable to the
Clean Water Act Section 404 permits and authorizations, permits issued under Sections 9 and 10 of the
Rivers and Harbors Act, licenses for hydroelectric power plants issued under the Federal Power Act, and
licenses issued by the Nuclear Regulatory Commission.
In 1973, the North Carolina General Assembly enacted the Sedimentation Pollution Control Act to
regulate urban and highway construction land-disturbing activities. The Sedimentation Control
Commission and the Division of Land Resources were charged with policy enactment and enforcement.
Also in 1973, the North Carolina General Assembly adopted the Oil Pollution Control Act making it
unlawful to discharge oil into any waters, tidal flats, beaches, or lands or into any sewer or surface water
drain without a permit.
In 1972, Congress passed the Federal Coastal Zone Management Act. To protect estuaries, marine
ecosystems and other coastal resources the North Carolina General Assembly enacted the Coastal Area
Management Act in 1974. The Act restricted development in environmentally sensitive areas and
required local governments in coastal counties to adopt land-use plans that included policies and
standards for public and private land and water use (Holm 2000, 22).
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 B-11 December 2014
The Environmental Management Commission adopted federal effluent limitations in 1976. In 1977,
Congress again amended the Federal Water Pollution Control Act. Emphasis was placed upon toxic
pollutants and long-term funding for municipal sewage treatment construction grants. As a result, the
Environmental Protection Agency listed sixty-five toxic pollutants in 1978 that would serve as the basis
for developing effluent standards (Howells 1990, 135).
In 1978, the Division of Environmental Management proposed revisions to the State’s water quality
standards resulting from the triennial review required by Section 303 of the Federal Clean Water Act.
This was the second time the standards were reviewed in their entirety since 1953. Proposed changes
involved mixing zones, toxic chemicals, and nutrient standards.
In response to concerns about nitrogen and phosphorus the Environmental Management Commission
approved a supplemental Nutrient Sensitive Water Classification in 1979 for surface waters experiencing
excessive algal or other aquatic plant growth. Subsequent supplemental classifications were approved
for High Quality Waters (1989), Outstanding Resource Waters (1985), and Water Supply Waters (1985).
The North Carolina General Assembly enacted the North Carolina Safe Drinking Water Act in 1979
enabling the State to assume primary jurisdiction over drinking water standards authorized in the
Federal Safe Drinking Water Act (Howells 1989, 62).
A comprehensive set of new NPDES regulations was adopted by the Environmental Protection Agency in
1979 and translated to permit regulations in 1980. They reflected best available technology (BAT) and
best conventional technology (BCT) effluent limitations adopted by Congress in the 1977 Federal Clean
Water Act amendments.
The Environmental Management Commission approved new water supply (WS) classifications in 1985.
They were WS-I, WS-II, and WS-III, and were defined by the amount and types of point sources
regulated by the state and local government land use efforts to control nonpoint pollution sources.
In 1987, the North Carolina General Assembly authorized a Clean Water Revolving Loan and Grant Fund
in response to continued need for State aid for local government water and sewage facilities. Also in
1987, amendments to the Federal Water Pollution Control Act required states to designate at least 50%
of federal funds in fiscal year 1989-1990 for revolving loans. Following that period through fiscal year
1994 all federal funds were to be used for the revolving loan program (Howells 1990, 174).
The Division of Environmental Management proposed stormwater controls for development activities in
the 20 coastal counties in 1987. They were designed to protect shellfish waters and coastal water
quality. The Outstanding Resource Water classification, first adopted in 1985, played a significant role in
this approach.
An Act to Establish Penalties for Failure to remove Prohibited Discharges and An Act to Establish
Penalties for Prohibited Discharges were enacted in 1987. The former authorized civil penalties for the
willful or negligent discharge of hazardous substances, the failure to report an illegal discharge, or the
failure to comply with compliance orders. The latter authorized civil penalties for the willful or negligent
violation of classifications, standards, or limitations of prohibited discharges of radiological, chemical, or
biological warfare agents (Howells 1990, 216).
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 B-12 December 2014
The North Carolina General Assembly adopted An Act to Establish a Septage Management Program in
1988. Septage could be disposed of only at public or community sewage systems designed and
permitted to discharge effluent to surface waters.
In 1988, the Sedimentation Pollution Control Act was amended to strengthen compliance requirements
and enforcement provisions. In 1989, the Environmental Management Commission adopted a turbidity
standard to be imposed in cases of sedimentation violations.
The Division of Environmental Management reported on nonpoint source pollution assessment and
management in 1989 in conformance with the 1987 amendments to the Federal Water Pollution Control
Act. Thirty percent of the state’s streams were reported as degraded; nonpoint source pollution was
cited as the primary source of degradation of freshwater rivers and streams in the state. Pollution
sources, in order of importance, were agriculture, urban runoff, and construction with sediment
identified as the most widespread cause of degradation (Howells 1990, 181).
About five percent of estuarine waters were degraded with nonpoint sources accounting for 72% of the
degradation. Agriculture, septic tanks and urban runoff were the primary sources. Excess nutrients and
fecal coliform bacteria were cited as the principal causes of degradation.
In response to these findings, the Division of Environmental Management nonpoint source management
plan included agriculture and forestry cost-share programs to match funds for best management
practices (BMP), a water supply watershed protection program, regulation under the Sedimentation
Pollution Control Act and the Mining Act, and coastal stormwater regulations. The North Carolina
Nonpoint Program was approved by the Environmental Protection Agency in 1989.
State legislation and/or rules followed for mandatory nonpoint source pollution control in water supply
watersheds, undisturbed buffer zones along trout waters, BMPs for silviculture, increased funding for
agriculture, nonpoint source protection for High Quality Waters, expansion of nonpoint-related
groundwater programs, watershed management programs, waste reduction and recycling, and wetland
protection.
In 1989, the North Carolina General Assembly enacted An Act to Authorize and Direct the Environmental
Management Commission to Phase in Stormwater Runoff Rules and Programs. It required the
Environmental Management Commission to begin a continuous planning process for the development
and adoption of a statewide stormwater management plan including rules and enforcement.
The North Carolina General Assembly also acted in 1989 to ratify the Water Supply Watershed
Protection Act, requiring the Environmental Management Commission to adopt new water supply
watershed classification rules. Appropriate classifications were required for all water supply watersheds
in the state with associated minimum protective standards. Related legislation was passed to provide for
a state water supply plan and local water supply plans.
In 1989, the North Carolina General Assembly created the North Carolina Department of Environment,
Health, and Natural Resources to consolidate all environmental, environmental health, and natural
resource programs into a single state agency (Howells 1990, 224).
The Environmental Management Commission adopted a final set of Water Supply Watershed Protection
rules in 1992. The rules restricted development densities, limited land uses, and required stream buffers
to treat stormwater runoff and other nonpoint sources of pollution (North Carolina Cooperative
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 B-13 December 2014
Extension Service, n.d., 1). Point sources of pollution including domestic and industrial wastewater
discharges were also addressed. Local governments whose land-use jurisdictions included water supply
watersheds were required to implement watershed protection plans and adopt ordinances meeting or
exceeding state guidelines. WS-IV and WS-V waterbody classifications were also added.
Following an extensive fish kill in the Neuse River in 1995, the North Carolina General Assembly
established a goal of reducing nitrogen in the Neuse River by 30% by 2001. To achieve this goal the
Environmental Management Commission adopted the Neuse Buffer Rule in 1997 requiring a 50-foot
vegetated riparian buffer along streams and rivers in the Neuse River Basin. Buffer rules were
subsequently adopted in the Randleman Lake Water Supply Watershed in 1999, in the Tar-Pamlico River
Basin in 2000, in the Catawba River Basin in 2004, in the Goose Creek Water Supply Watershed in 2009,
and in the Jordan Lake Water Supply Watershed in 2009.
In 1990, Phase I of the NPDES stormwater program was established and required permit coverage for
municipalities with populations of 100,000 residents or more. Requirements included public education,
IDDE, construction and post-construction programs, PPGH, storm sewer system inventory and mapping,
and water quality monitoring (NCDENR, 2007, 2-2).
Phase II of the NPDES stormwater program began in 2003. The federal rules required certain smaller
MS4 operators to meet Phase I requirements for larger municipalities. Operators of construction sites
equal to or greater than one acre in area were required to file a Notice of Intent (NOI) prior to beginning
construction and develop and implement a SWPPP (EPA, 2005, 3).
In 1997, the North Carolina General Assembly enacted The Clean Water Responsibility Act. It required
the Environmental Management Commission to adopt goals to improve nutrient-impaired waters and to
develop and implement management plans to reduce nutrient inputs from point sources and nonpoint
sources. The North Carolina General Assembly subsequently enacted legislation in 2005 (S.L. 2005-190)
directing the Environmental Management Commission to adopt permanent rules to establish and
implement nutrient management strategies to protect drinking water supply reservoirs including total
maximum daily load (TMDL) load reduction limits when necessary (NCDENR, n.d., 1).
In 2009, the Environmental Management Commission adopted the Jordan Lake Nutrient Management
Strategy rules. The strategy is intended to restore and maintain the lake’s classified uses and enhance
protections currently implemented by local governments in existing water supply watersheds. The North
Carolina General Assembly subsequently modified the rules (S.L. 2009-216 and S.L. 2009-484).
The rules require stormwater management plans for new development, public education, inventory of
MS4 systems, removal of illicit discharges, retrofit opportunities for existing development, and
maintenance of BMPs. The rules also include options to offset nutrient loads by purchasing reduction
credit from other sellers. Diffuse flow into 50-foot wide riparian buffers is required for all intermittent
and perennial streams, lakes, ponds, and reservoirs. Nitrogen and phosphorus waste load allocations
(WLA) are required for existing wastewater treatment facilities. Nutrient reduction goals are required
for agricultural operations. Fertilizer application is also addressed (NCDENR, n.d., 1).
In 2011, the Environmental Management Commission adopted the Falls Reservoir Water Supply
Nutrient Strategy rules. The rules are similar to the Jordan Lake Nutrient Management Strategy rules
implemented in two stages. The first stage goal is to restore water quality in the lower portion of the
lake through requirements across the lake’s entire watershed. The second stage goal is to restore water
quality in the upper portion of the lake with additional requirements for regulated activities in the upper
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC
Version 1.0 B-14 December 2014
watershed. Stage I goals apply to the entire watershed to ensure that the chlorophyll-a standard is met
in the lower lake by 2021. Stage II requires additional reductions in the upper watershed to achieve the
chlorophyll-a standard throughout the lake by 2041 (NCDENR, 2010, 3).
Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC

Appendix C

Little Alamance Creek Existing Data Inventory

Category 4b Demonstration Plan to Address
Biological Impairment in Little Alamance Creek, NC

This page intentionally left blank
Little Alamance 4b Demonstration Existing Data Inventory

Little Alamance Creek 4b Demonstration Project
Existing Data Inventory

Prepared by:
URS Corporation – North Carolina
1600 Perimeter Park Drive
Suite 400
Morrisville, NC 27560

Prepared for:
NC Department of Transportation
Hydraulics Unit
1590 Mail Service Center
Raleigh, NC 27699-1590
919.250.4100

City of Burlington
Water Resources Department
1103 S. Mebane St.
Burlington, NC 27215
336.222.5145

City of Graham
Public Works Department
105 West Parker Street
PO Drawer 357
Graham, NC 27253
336.570.6709

Final
January 2014

Little Alamance 4b Demonstration Existing Data Inventory

This page is intentionally blank

Little Alamance 4b Demonstration Existing Data Inventory
C-3
Table of Contents
1.0 Introduction .................................................................................................................................... 6
1.1 Project Background .......................................................................................................... 6 1.2 Purpose of this Document ................................................................................................ 6 1.3 Activities to date ................................................................................................................ 6 1.4 Team Members, Roles, Responsibilities .......................................................................... 7
2.0 Existing Data Inventory ................................................................................................................ 7
2.1 Data Sources ...................................................................................................................... 7 2.2 Watershed Characteristics ............................................................................................... 9 2.2.1 Ecoregion ............................................................................................................... 9
2.2.2 Climate ................................................................................................................. 10 2.2.3 Land Use .............................................................................................................. 10
2.3 Water quality data .......................................................................................................... 12
2.3.1 Physicochemical parameters ................................................................................ 13 2.3.2 Nutrients .............................................................................................................. 14
2.3.3 Metals .................................................................................................................. 15
2.3.4 Other Water Quality Data .................................................................................... 16 2.4 Fecal Coliform Bacteria ................................................................................................. 16 2.5 Biological Data ................................................................................................................ 17
2.5.1 Benthic Macroinvertebrates ................................................................................. 17 2.5.2 Fish ...................................................................................................................... 18
2.5.3 Protected Species ................................................................................................. 18 2.6 Habitat assessment .......................................................................................................... 18 2.7 Channel Data ................................................................................................................... 19 2.7.1 Stream Morphology ............................................................................................. 19 2.7.2 Substrate Composition ......................................................................................... 20 2.7.3 Streambank Stability ............................................................................................ 20
2.7.4 Flow Data ............................................................................................................. 20 2.8 NPDES Wastewater Treatment Point Source Discharges .......................................... 21 2.9 Stormwater outfall inventory ............................................................................... 21
3.0 Summary of Existing Data .......................................................................................................... 22
3.1 Spatial Distribution ......................................................................................................... 22 3.2 Temporal Distribution .................................................................................................... 23
3.3 Extent of available data .................................................................................................. 24
4.0 Conclusions ................................................................................................................................... 25
5.0 References ..................................................................................................................................... 26

Little Alamance 4b Demonstration Existing Data Inventory
C-4
List of Tables
Table 1. Key project activities and milestones completed by the project team to date. ................................ 7 Table 2. Team members, roles, and responsibilities. .................................................................................... 7 Table 3. Existing documents reviewed for data on the Little Alamance Creek watershed, sorted by
document source and publication date. The three documents in bold type contain the majority of available data pertaining to water quality and stream biology. ..................................................................... 8 Table 4. General watershed characteristics. .................................................................................................. 9
Table 5. Change in land use over time. ....................................................................................................... 10 Table 6. Estimated percent impervious surface over time. ......................................................................... 11 Table 7. Little Alamance Creek watershed land use (Source: 2007 LATT Watershed
Characterization Phase I, Final Report; NCDOT area estimated to be approximately 4.8% of the watershed). .................................................................................................................................................. 11
Table 8. Percent land cover type for the drainage areas of selected monitoring sites across the Little
Alamance Creek watershed (National Land Cover Database 2001). .......................................................... 12 Table 9. Sources for water quality data in the Little Alamance Creek watershed. ..................................... 12
Table 10. Summary of available physicochemical data for the Little Alamance Creek watershed ............ 14
Table 11. Summary of available data on nutrients in water quality samples. ............................................. 15 Table 12. Summary of available data on metals in water quality samples. ................................................ 15
Table 13. Summary of other available water quality data. ......................................................................... 16 Table 14. Summary of available bacteria data for the Little Alamance Creek watershed. ......................... 17 Table 15. Biological data sources for the Little Alamance Creek watershed. ............................................ 17
Table 16. Benthic macroinvertebrate data summary. .................................................................................. 18 Table 17. Summary of fish sampling data. ................................................................................................. 18 Table 18. Habitat assessment data sources for the Little Alamance Creek watershed. .............................. 19
Table 18. Morphological data sources for the Little Alamance Creek watershed ...................................... 19 Table 19. Sources of flow data for Little Alamance Creek watershed ....................................................... 21 Table 20. Location and identity code information for all sample sites in the Little Alamance Creek
watershed .................................................................................................................................................... 22 Table 21. Availability of information on Little Alamance Creek watershed .............................................. 24

List of Figures
Figure 1. Little Alamance Creek watershed showing the spatial distribution of the 11 sites where
data have been collected ............................................................................................................................. 23

Little Alamance 4b Demonstration Existing Data Inventory
C-5
List of Acronyms and Abbreviations
µg/L Micrograms per Liter
BEHI Bank Erosion Hazard Index
BMP Best management practice
CFS Cubic feet per second
DWQ Division of Water Quality
DWR Division of Water Resources
LATT Little Alamance, Travis, and Tickle Creeks
mg/L Milligrams per Liter
NBS Near bank stress
NC North Carolina
NCDENR North Carolina Department of Environment and Natural Resources
NCDOT North Carolina Department of Transportation
NCEEP NC Ecosystem Enhancement Program
NSW Nutrient Sensitive Water
SPMD Semipermeable membrane device
SR State Route
TKN Total Kjeldahl Nitrogen
TMDL Total maximum daily load
UCFRBA Upper Cape Fear River Basin Association
USGS United States Geological Survey

Little Alamance 4b Demonstration Existing Data Inventory

C-6
1.0 Introduction
This document provides a summary of available watershed information and water quality data for the
Little Alamance Creek watershed. This document was prepared for the North Carolina Department of
Transportation (NCDOT), the City of Burlington, and the City of Graham under a collaborative project to
address impairment in the creek through a Category 4b demonstration. The assessment provided herein
will be used to identify data gaps, develop strategies for collecting additional data and implementing
stormwater controls, and to prepare the Category 4b demonstration report.
1.1 Project Background
Portions of Little Alamance Creek (Cape Fear River Basin) are impaired and included on the 2012 North
Carolina 303(d) List of Impaired Waters published by the North Carolina Department of Environment
and Natural Resources Division of Water Quality (DWQ) based on a “poor” bioclassification rating. In
October 2010, the DWQ prepared a draft total maximum daily load (TMDL) report to address the
impairment. The TMDL report identified stormwater runoff and hydromodification as potential
contributors to impairment and used impervious cover as a surrogate for biological impairment because
no specific pollutants were known or identified. Subsequent to the draft TMDL report, representatives
from NCDOT and the cities of Burlington and Graham (hereafter, “project team”) participated in
meetings with representatives from the North Carolina Division of Water Resources (DWR) Modeling
and TMDL Unit, Stormwater Permitting Unit, and local governments statewide to discuss alternatives to
traditional TMDL development in watersheds where the stream is listed as “Category 5” (not meeting
designated uses) but the pollutant causing impairment is unknown. During the course of these
discussions, the group took steps to investigate the feasibility of preparing a Category 4b demonstration
as an alternative to the draft impervious cover limitation TMDL. Category 4b demonstrations are used to
address impaired waters where a TMDL is not required because the waterbody is expected to meet
standards due to other pollution control requirements.
During the summer of 2012, the project team committed to supporting a Category 4b process in Little
Alamance. As part of this commitment, the project team will jointly prepare a Category 4b
demonstration describing management actions that, when implemented, will contribute to the overall
goal of restoring water quality and achieving a benthic macroinvertebrate community bioclassification
of “Not Impaired”, “Good-Fair”, or better. This plan will be submitted to DWR on or before August 23,
2014.
1.2 Purpose of this Document
The purpose of this document is to summarize existing water quality and watershed data and
information relevant to the impairment in Little Alamance Creek. This document also provides a
description of activities performed by the project team to date, a preliminary assessment of data gaps,
and recommendations on additional data collection or analysis.
1.3 Activities to date
Over the past year the project team has collaborated to develop and prioritize project goals and tasks,
participated in a watershed tour, and prepared a report outline. Key project activities and milestones
are shown in Table 1.
Little Alamance 4b Demonstration Existing Data Inventory

C-7
Table 1. Key project activities and milestones completed by the project team to date.
Date Project Activity or Milestone
September 7, 2012 Project team kick-off meeting.
October 10, 2012 Project kick-off meeting held with NCDWQ and project team. Project schedule,
deliverables, roles responsibilities, and points of contact defined.
January 28, 2013 Category 4b demonstration outline prepared.
February 28, 2013 Project team meeting and watershed tour. Project team member roles/responsibilities in
preparing the Category 4b demonstration, desired project outcomes, and opportunities for
implementing best management practices (BMP) discussed. The team meeting was
followed by a half-day watershed tour during which the project team drove throughout the
watershed, walked portions of the stream, discussed pending watershed improvement
projects and teaming opportunities, and identified areas that had the potential to support
BMP retrofits.
May 7, 2013 Project team coordination meeting with DWQ staff. Project progress, field visit, and report
outline discussed.
June 28, 2013 Full project schedule and roles prepared for project team comment.
September 3, 2013 Project progress and coordination meeting with DWR staff.
October 22, 2013 Coordination meeting with United States Environmental Protection Agency and DWR staff.
1.4 Team Members, Roles, Responsibilities
The project team includes NCDOT and representatives from the cities of Burlington and Graham. Team
members, along with their associated roles and responsibilities are shown below in Table 2.

Table 2. Team members, roles, and responsibilities.
Name Organization (Representing) Roles and Responsibilities
Josh Johnson Alley, Williams, Carmen & King, Inc.
(City of Graham)
Project management and report preparation
Michael Layne City of Burlington Project management
Patrick Blandford HDR, Inc. (City of Burlington) Task management and general support
Kenneth Trefzger HDR, Inc. (City of Burlington) Task management and general support
Andy McDaniel NCDOT Project management
Craig Deal NCDOT Report preparation
Brian Jacobson URS Corp. – North Carolina (NCDOT) Task management and report preparation
Melissa Bauguess URS Corp. – North Carolina (NCDOT) Data assessment and report preparation
2.0 Existing Data Inventory
2.1 Data Sources
A search for existing data on the Little Alamance Creek watershed consisted of internet research and
personal communication with the cities of Burlington and Graham, NC, and also Elon University. Table 3
Little Alamance 4b Demonstration Existing Data Inventory

C-8
lists the data sources that were reviewed for information pertaining to Little Alamance Creek. Not all
sources reviewed contained data specific to Little Alamance Creek.

Table 3. Existing documents reviewed for data on the Little Alamance Creek watershed, sorted by
document source and publication date. The three documents in bold type contain the majority of
available data pertaining to water quality and stream biology.
DWQ Documents - Cape Fear River Basin
1996 Cape Fear River Basinwide Water Quality Plan
2000 Cape Fear River Basinwide Water Quality Plan
2005 Cape Fear River Basinwide Water Quality Plan
2009 DWQ Biological Assessments - Cape Fear
2009 Cape Fear River Basin Basinwide Assessment Report Whole Effluent Toxicity Program, 2004 – 2008
2009 DWQ Lake and Reservoir Assessments – Cape Fear River Basin
2009 DWQ Cape Fear River Basin - Ambient Monitoring System Report
2009 Upper Cape Fear River Basin Association (UCFRBA) 2009 Annual Report
DWQ Documents – Little Alamance Watershed
2006 DWQ Draft Summary of Existing Water Quality Data for Little Alamance, Travis, and Tickle Creek (LATT)
2007 Evaluation of Water Quality, Habitat, and Stream Biology in the LATT Watersheds, Final Report
2008 Evaluation of Water Quality, Habitat, and Stream Biology in the LATT Watersheds, Draft Final Report
Undated. Prusha, DWQ LATT Benthic Study Review
2010 Total Maximum Daily Load to Address Impaired Biological Integrity in the Little Alamance Creek Watershed
NC Ecosystem Enhancement Program (NCEEP) Documents
2007 LATT Watershed Characterization Phase I, Final Report
2008 Little Alamance Creek Stream Restoration Plan (Arcadis)
2008 LATT Local Watershed Plan Phase II
2008 LATT Watersheds Report and Project Atlas, Phase III
2009 LATT Summary of Findings and Recommendations
Undated NCEEP LATT Local Watershed Plan Fact Sheet
Elon University Documents
2010 Elon University Little Alamance Restoration Alliance Meeting - Slide Presentation
Little Alamance Land Cover Summary Statistics
Haw River Watershed and Little Alamance Watershed Map
Little Alamance Watershed Map
Watershed Assessment and Restoration Program (WARP) Reports
2002 Biological Impairment in Little Troublesome Creek Watershed – Rockingham County
2003 Assessment Report- Biological Impairment in Horsepen Creek Watershed – Guilford County
Other
EPA STORET Database, http://www.epa.gov/storet/
2007 US Geological Survey (USGS) Data Series 279
State Climate Office of North Carolina, http://www.nc-climate.ncsu.edu/
NC Natural Heritage Program, http://www.ncnhp.org/
USFWS, http://www.fws.gov/
Little Alamance 4b Demonstration Existing Data Inventory

C-9
2.2 Watershed Characteristics
The Little Alamance Creek watershed is located in the upper Cape Fear River Basin, within the Haw River
subbasin. Little Alamance Creek flows into Big Alamance Creek approximately three miles upstream of
its confluence with the Haw River. This section presents an overview of watershed characteristics,
including drainage area, ecoregion, climate, and land use. The following table lists some general
identifying information about the Little Alamance Creek watershed.

Table 4. General watershed characteristics.
Characteristic Description
River Basin Cape Fear River Basin
Subbasin Haw River
USGS Hydrologic Unit Code 03030002040110
NCDWQ Subbasin 03-06-03
NC stream index number 16-19-11
NC stream classifications Class C: Protection of aquatic life and secondary recreation
Nutrient Sensitive Water (NSW): a supplemental classification, which carries
additional regulatory requirements for agricultural and stormwater management
practices.
Associated jurisdictions Alamance County, Burlington, Graham
Watershed Area 16 sq. mi. watershed
13 subwatersheds (as delineated for NCEEP Local Watershed Plan)
Named Tributaries and Lakes Boyd Creek (Bowden Branch on USGS topo map), Willowbrook Creek, Mays Lake,
May Brook, Walker Brook, Coble Brook, Powell Lake Branch, Gant Brook, Gant
Lake, Lamm Brook, Meadowbrook Branch
2.2.1 Ecoregion
The Little Alamance Creek watershed is located in the Piedmont physiographic province of North
Carolina. The elevation ranges from approximately 450 feet at the confluence with Big Alamance Creek
to 700 feet in the headwater regions. The Little Alamance Creek watershed is located entirely within one
Level IV Ecoregion – the Southern Outer Piedmont. This ecoregion has lower elevations, less relief, and
less precipitation than its neighboring ecoregions. Gneiss, schist, and granite are typical rock types, and
the rocks are more intensely deformed and metamorphosed than the geologic materials in neighboring
ecoregions. The rocks are covered with deep saprolite and mostly red, clayey subsoils.

The watershed is composed mainly of three geological types: quartzite in the northern headwaters of
the watershed, and metamorphosed gabbro and diorite, and mafic metavolcanic rock in the middle and
lower portions of the watershed.

The predominant soil association in the Little Alamance watershed is Mecklenburg-Elon–Cecil,
comprising almost the entire watershed south of Route 70. The Vance-Appling–Enon-Cecil association is
found north of Route 70 and encompasses the majority of the hydric soils found in the watershed.
Hydric soils can be found throughout the watershed within the floodplain, but most predominantly
along the Little Alamance Creek stream beds and surrounding area north of Route 70.
Little Alamance 4b Demonstration Existing Data Inventory

C-10
2.2.2 Climate
Extensive climatic data for the Little Alamance Creek watershed are available through the State Climate
Office of North Carolina. Temperature and precipitation records go back over one hundred years. There
are multiple weather stations in Alamance County, four of which are currently active. One of these,
located in Graham, has collected climatic data from 1902 to present.

Alamance County receives approximately 45 inches of rainfall per year, and another 4 inches per year of
frozen precipitation. The greatest one-day precipitation was 6.71 inches in 1954. Recent droughts have
impacted data collection efforts in the watershed. A significant drought was occurring in 2007 when
DWQ was performing an evaluation of water quality and stream biology. All North Carolina rivers and
streams commonly have a maximum flow in late spring, with low flow in fall.

The Normal Monthly Mean Temperature in Alamance County is 59.2 °F; the Normal Monthly Maximum
Temperature is 71.2 °F; and the Normal Monthly Minimum Temperature is 47.1 °F. The highest
temperature on record was 105°F and the lowest was -6 °F.
2.2.3 Land Use
Land use and land cover in the watershed play a substantial role in stream water quality and aquatic
habitat. There is relatively good information on these watershed features, as well as information on how
these features have changed over time. Elon University conducted an analysis of parcel and census data
to determine land use. Approximately 80% of the parcels are residential, and roughly 6.6% of the parcels
contain riparian areas; these numbers are based on the number of parcels and not on the total area of
land.

Elon University provided a land cover analysis based on aerial photographs from the years 1956, 1984,
and 2009. Table 5 shows how road length, forested area, and the number of buildings changed between
these years.

Table 5. Change in land use over time.
Year Total Road Length (miles)
Forested Area
(percent of watershed) Number of Buildings
1956 136 37.2 5,200
1984 174 33.3 8,204
2009 195 27.4 9,637

Elon University also estimated the percent of the watershed area that was covered in impervious
surfaces for various years. Between 1984 and 2010 the percentage of impervious surface was estimated
to increase from 24.6% to 30.0%. This translates to approximately 86 acres of additional impervious
surface.

Little Alamance 4b Demonstration Existing Data Inventory

C-11

Table 6. Estimated percent impervious surface over time.
Year Estimated Percent Impervious Surface
1984 24.6%
1993 27.0%
2001 28.6%
2005 29.6%
2010 30.0%

The first phase of NCEEP’s Local Watershed Plan for Little Alamance, Travis, and Tickle Creeks included
an analysis of land use. The results from the analysis are provided in Table 7.

Table 7. Little Alamance Creek watershed land use (Source: 2007 LATT Watershed Characterization
Phase I, Final Report; NCDOT area estimated to be approximately 4.8% of the watershed).
Type Acreage Percentage
Agriculture 318.0 3.6%
Commercial 565.5 6.6%
Industrial 1,082.1 12.4%
Institutional 171.1 1.9%
Mobile Homes 2.9 0.0%
Multifamily 545.3 6.2%
Office 226.6 2.6%
Open Space/Recreational 256.9 2.9%
Single Family 5,233.0 59.7%
Vacant 360.4 4.1%
Total Acreage in Parcels 8,761.8 100.0%

In addition to the work done by Elon University and NCEEP, land cover analysis was included in the DWQ
report Evaluation of Water Quality, Habitat, and Stream Biology in the Little Alamance, Tickle, and Travis
Creek Watersheds (2008). During 2006 and 2007, the DWQ conducted monitoring at seven sites in the
Little Alamance Creek watershed (Sites 14, 15, 16, 17, 18, 19, and 20). The land use data of the drainage
area for each sampling site were obtained from the National Land Cover Database 2001. Table 8 shows
the contribution of each category of land use within the drainages of each of the monitoring locations.
Most of the drainages are highly developed.

Little Alamance 4b Demonstration Existing Data Inventory

C-12
Table 8. Percent land cover type for the drainage areas of selected monitoring sites across the Little
Alamance Creek watershed (National Land Cover Database 2001).
Location
Drainage
Area
(sq. mi.)
High
Density
Developed
Low Density
Developed Forest Agriculture Herbaceous Water
UT to Willowbrook Cr at
Kime St.
0.4 61.6 38.5 0.0 0.0 0.0 0.0
Willowbrook Cr at
Mebane St (SR 1363)
1.3 21.3 78.7 0.0 0.0 0.0 0.0
Little Alamance Cr at
Mebane St (SR 1363)
4.4 12.7 85.8 1.3 0.1 0.1 0.1
Little Alamance Cr at NC
54 (Tucker St.)
6.4 37.1 53.1 8.4 1.0 0.5 0.0
Little Alamance Cr at I-
85 Frontage Rd (SR
1398)
7.7 29.6 61.6 8.4 0.2 0.1 0.0
Little Alamance Cr at
Rogers Rd. (SR 2309)
14.1 13.2 40.3 26.1 13.3 6.8 0.2
Bowden Br at Hanford
Rd (SR 2304)
2.5 19.3 65.2 11.2 2.1 2 0.0

2.3 Water quality data
Water quality sampling efforts have not been continuous or widespread throughout the watershed. The
majority of the water quality data exists for one location, Little Alamance Creek at SR 2309 (Rogers
Road). Additional locations throughout the watershed were sampled in support of DWQ’s TMDL study
and NCEEP’s Local Watershed Plan. The following sources for water quality data were identified.

Table 9. Sources for water quality data in the Little Alamance Creek watershed.
Data Source
Date Range of Data
Collection
Number of Sites
Sampled
EPA STORET data download 1968-1975 1
2007 Selected Physical, Chemical, and Biological Data for 30 Urbanizing
Streams in the North Carolina Piedmont Ecoregion, 2002–2003.
USGS Gage Station 0209679804
2/25/2003-
7/11/2003
1
2010-12 TMDL to Address Impaired Biological Integrity in the Little
Alamance Creek Watershed
June 2003 5
2006 DWQ Draft Summary of Existing Water Quality Data July 2006 8
2008 DWQ Evaluation of Water Quality, Habitat and Stream Biology in the
Little Alamance, Travis, and Tickle Creek Watersheds
December 2006-
August 2007
6
2009 DWQ Biological Assessments – Cape Fear July 2008 1

Little Alamance 4b Demonstration Existing Data Inventory

C-13
The various data sources collect and report data in different ways, and therefore combining or
summarizing the results would be inadvisable. This document focuses more on the extent or
completeness of data available, rather than reiterating the results of the various reports. The original
data sources (summarized below) contain more detailed information if desired.

The data downloaded from EPA STORET were collected from Little Alamance Creek at SR 2309 between
1968 and 1975. Analytical techniques and quality assurance procedures have improved since that time
period.

In 2002-2003 the US Geological Survey (USGS) conducted sampling on Little Alamance Creek at SR 2309
as part of a National Water Quality Assessment study. The purpose of the study was to examine the
effects of urbanization on stream ecosystems. Biological, chemical, and physical data were collected on
30 streams across the piedmont of North Carolina. The SR 2309 location is referred to as USGS Gage
Station 0209679804 for this USGS study. Continuous stream stage and stream temperature
measurements were collected hourly for one year, from November 16, 2002 to November 15, 2003.
Standard USGS streamgaging techniques for collection of streamflow data were not used because of the
short term of data collection at the sites and limited resources for the project. Instead, a submersible
pressure transducer with an internal data logger was used. Water chemistry samples were taken twice,
on February 25, 2003 and July 11, 2003. Parameters included basic physiochemical parameters and
nutrients as well as pesticides and herbicides.

The DWQ conducted a TMDL stressor study in June 2003 that included five sample locations. The study
focused on benthic collections but some physiochemical data were collected at the same time.

In July of 2006, DWQ personnel collected a limited amount of field data to ascertain if any water quality
problems could be readily identified, and to aid in the development of a plan for additional monitoring.

In support of the NCEEP Local Watershed Plan, DWQ conducted additional sampling at seven sites in the
watershed from December 2006 to August 2007. The sites are identified as 14, 15, 16, 17, 18, 19, and 20
in the Evaluation of Water Quality, Habitat, and Stream Biology in the Little Alamance, Travis and Tickle
Creek Watersheds (DWQ, 2008). The sampling included water quality data for physical parameters,
nutrients, metals, and bacteria. Samples were taken approximately monthly during baseflow, and on
three occasions during stormflow. The number of samples for each parameter and site varies.
2.3.1 Physicochemical parameters
Physicochemical parameters such as pH, specific conductance, dissolved oxygen, and temperature are
the most abundant type of water quality data available for Little Alamance Creek. The historical data
from 1968-1975 included these parameters (minus specific conductance) as well as alkalinity and
biochemical oxygen demand, two parameters that have not been analyzed since. These data included
approximately 18 samples at one location – Little Alamance Creek at SR 2309.

Physicochemical parameters were measured on a limited basis in 2003 by DWQ (one sample at each of
five locations) and USGS (two samples at one location). One additional measurement at SR 2309 was
taken by DWQ in 2008 with the biological assessment.

The majority of the physicochemical data were collected in 2006 and 2007 by DWQ. In July of 2006,
single measurements of specific conductance were measured at eight bridge crossings across the
Little Alamance 4b Demonstration Existing Data Inventory

C-14
watershed. In addition, duplicate data sondes were installed at Little Alamance Creek at SR 2309 that
recorded temperature, pH, specific conductance, dissolved oxygen and the percent saturation of
dissolved oxygen. Data were recorded at hourly intervals between July 25 and 31, 2005, for a total of
270 measurements for each parameter. The most widespread sampling effort was from December
2006-2007 when DWQ measured these same parameters at six sites across the watershed, collecting at
least 30 observations for each parameter.

Table 10. Summary of available physicochemical data for the Little Alamance Creek watershed
Data Source
Date range of Data
Collection
Number of
Sites Sampled
Approximate
Number of
Samples per Site
EPA STORET data download 1968-1975 1 18
2007 USGS Report
USGS Gage Station 0209679804
2/25/2003-
7/11/2003
1 2
2010-12 TMDL to Address Biological Integrity in the Little
Alamance Creek Watershed
June 2003 5 1
2006 DWQ Draft Summary of Existing Water Quality Data July 2006 8 270 at SR 2309
1 at others
2008 DWQ Evaluation of Water Quality, Habitat and
Stream Biology in Little Alamance, Travis, and Tickle
Creek
December 2006-
August 2007
6 30-34
2009 DWQ Biological Assessments – Cape Fear July 2008 1 1

The 2008 DWQ report identified that the highest specific conductance measurements occurred in the
headwater tributaries of Little Alamance Creek and that values decreased at downstream monitoring
locations. DWQ concluded that dissolved substances were originating from the urban area of downtown
Burlington and were being diluted further downstream. Willowbrook Creek samples showed several
instances of supersaturated dissolved oxygen concentrations, which were attributed to dense algal
blooms noted during sampling. Lower portions of the watershed were found to experience very low
levels of dissolved oxygen, falling below the 4.0 mg/L water quality threshold on several occasions. DWQ
attributed these occurrences to seasonal patterns associated with high air temperatures that were
exacerbated by extreme drought conditions and very low flow. Water temperature and pH
measurements were found to be within normal ranges.
2.3.2 Nutrients
Data for nutrients is somewhat more limited for the watershed. Three datasets were found containing
nutrient data. The historic data from SR 2309 included four nutrient samples in 1971 and 1972.
Ammonia, inorganic nitrogen, and Total Kjeldahl Nitrogen (TKN) were sampled once in 1971; in 1972,
ammonia, inorganic nitrogen, TKN, and phosphorus were sampled once.

In 2003, USGS measured nutrients in two samples at SR 2309 for the following parameters: TKN,
ammonia, nitrate plus nitrate, nitrite, particulate nitrogen, total nitrogen, orthophosphate, and
phosphorus.

Little Alamance 4b Demonstration Existing Data Inventory

C-15
The most widespread sampling effort was from December 2006-2007 when DWQ measured nutrients at
six sites across the watershed, collecting at least 30 samples for each of the following parameters:
ammonia, inorganic nitrogen, TKN, total nitrogen, and phosphorus. All parameters had 34 baseflow
samples and two stormflow samples.

Table 11. Summary of available data on nutrients in water quality samples.
Data Source
Date range of Data
Collection
Number of Sites
Sampled
Approximate
Number of
Samples
EPA STORET data download 1968-1975 1 2
2007 USGS Data Series 279
USGS Gage Station 0209679804
2/25/2003-
7/11/2003
1 2
2008 DWQ Evaluation of Water Quality, Habitat and
Stream Biology in LATT
December 2006-
August 2007
6 30-34

The 2008 DWQ report identified a few trends in the nutrient data. One site, Little Alamance Creek at
Mebane Street, was found to have consistently high ammonia nitrogen concentrations and the highest
TKN observed during the study. Willowbrook Creek and UT to Willowbrook Creek were found to have
the highest phosphorus concentrations. Willowbrook Creek and its UT were also high in ammonia and
sodium. The 2008 DWQ report indicated that elevated nutrient concentrations at Little Alamance Creek
at Mebane Street and Willowbrook Creek and its UT could be linked to the potential presence of
malfunctioning septic or sewage sources.
2.3.3 Metals
Only one dataset was found in which metal concentrations were reported. DWQ sampled six locations
for both toxic and non-toxic metals between December 2006 and August 2007, approximately monthly.
Results for several toxic metals (arsenic, cadmium, chromium, mercury, nickel, and silver) were below
the detection limit and were not reported. Three other toxic metals (copper, lead, and zinc) were found
and reported. Other metals analyzed included aluminum, iron, manganese, calcium, magnesium,
potassium, and sodium. Metals were sampled at six sites 10-15 times at low flow and two times during
high flow conditions. A summary of the available data on metals in the Little Alamance Creek watershed
is shown in Table 12.

Table 12. Summary of available data on metals in water quality samples.
Data Source
Date range of Data
Collection
Number of Sites
Sampled
Approximate
Number of
Samples
2008 DWQ Evaluation of Water Quality, Habitat and
Stream Biology in LATT
December 2006-
August 2007
6 10-15

Copper, zinc, and lead were found at measureable concentrations within the watershed, especially in
samples collected under high flow conditions. Copper was detected in all but two high flow samples, and
most high flow samples exceeded the 7 µg/L action level. In addition, one low flow sample taken at Little
Alamance Creek at SR 2309 was at the action level of 7 µg/L copper. Lead occurred above the reporting
limit only once, in a high flow sample at Willowbrook Creek. The report stated that this may have
Little Alamance 4b Demonstration Existing Data Inventory

C-16
originated from runoff from an old city vehicle maintenance facility or possibly from a landfill in the
subwatershed. The Willowbrook Creek Site also exceeded the action level for zinc (50 µg/L) in the same
high flow sample, which may also have originated from the same source as the lead. Zinc was measured
in all but two high flow samples, and detected in four low flow samples.

Among the other metals, calcium and magnesium were noted as having somewhat elevated low flow
concentrations, possibly due to the abundance of pavement in the urban areas. Both were lower during
high flow samples, indicating dilution during rain events. Sodium concentrations were also elevated,
particularly at Willowbrook Creek and Little Alamance Creek at Mebane Street, which is directly
downstream of Willowbrook Creek. The report stated that the higher sodium could be an indicator of
raw sewage contamination, but could also have originated from other sources. Because Willowbrook
Creek also had higher levels of ammonia, nitrogen, and phosphorous, lead, and zinc, further
investigation was recommended in this area.
2.3.4 Other Water Quality Data
The USGS study in 2003 included analysis of some additional parameters that have not been included in
the other datasets. The study included the total concentration and the quantity of pesticides, fungicides,
herbicides, insecticides, and nematicides. In addition, a Pesticide Toxicity Index was calculated for
cladocerans (water fleas), benthic macroinvertebrates, and fish.

The USGS study also included several organic constituents: total particulate carbon, particulate inorganic
carbon, particulate organic carbon and dissolved organic carbon were measured in the two samples.

USGS also collected data with semipermeable membrane devices (SPMDs) to examine concentrations of
hydrophobic organic compounds over time. The SPMDs were placed at each site for a period of
approximately 6 weeks during April and May 2003. SPMDs are passive samplers that concentrate trace
levels of hydrophobic organic compounds in the water column. They are designed to mimic the
bioaccumulation of organic compounds in the fatty tissues of aquatic organisms.

Table 13. Summary of other available water quality data.
Data Source
Date range of Data
Collection
Number of Sites
Sampled
Approximate
Number of
Samples
2007 USGS Data Series 279
USGS Gage Station 0209679804
2/25/2003-
7/11/2003
1 2
2.4 Fecal Coliform Bacteria
Two datasets were found containing data on fecal coliform bacteria. The historical data from SR 2309
contained 12 samples from July 1968 to February 1975.

DWQ also measured fecal coliform in water samples at six stations between December 2006 and August
2007. A total of 34 samples were analyzed, ranging from one to nine samples per site. The report
indicated that fecal coliform pollution is present at multiple sites. All available data on bacteria are
summarized in the table below.

Little Alamance 4b Demonstration Existing Data Inventory

C-17
Table 14. Summary of available bacteria data for the Little Alamance Creek watershed.
Data Source
Date range of Data
Collection
Number of Sites
Sampled
Approximate
Number of
Samples
EPA STORET data download 1968-1975 1 12
2008 DWQ Evaluation of Water Quality, Habitat and
Stream Biology in LATT
December 2006-
August 2007
6 34
2.5 Biological Data
Biological sampling in Little Alamance Creek has been documented since 1985. DWQ assigns each site a
“bioclassification” rating according to how many species are present at a sample site and the relative
abundances of the species. There are five bioclassifications ratings – Poor, Fair, Good-Fair, Good, and
Excellent – indicating how well aquatic life is being supported. Documents containing biological data are
shown in Table 15.

Table 15. Biological data sources for the Little Alamance Creek watershed.
Data Source Survey Date
Number of
Sites Surveyed
1996 Cape Fear River Basinwide Water Quality Plan July 1985 1
2000 Cape Fear River Basinwide Water Quality Plan July 1998 1
2007 Selected Physical, Chemical, and Biological Data for 30 Urbanizing
Streams in the North Carolina Piedmont Ecoregion, 2002–2003
May 2003 1
2005 Cape Fear River Basinwide Water Quality Plan June 2003 5
2010 TMDL to Address Biological Integrity in the Little Alamance Creek
Watershed
June 2003 5
2008 DWQ Evaluation of Water Quality, Habitat and Stream Biology in LATT September 2006 3
2009 DWQ Biological Assessments – Cape Fear July 2008 1
DWQ Little Alamance, Travis, and Tickle Creeks Benthic Study Review –
Prusha (undated)
Unknown 3
2.5.1 Benthic Macroinvertebrates
Benthic macroinvertebrates have been surveyed at seven locations throughout the Little Alamance
Creek watershed. Six of these locations have been surveyed once – five in 2003 and two in 2006.

Little Alamance Creek at SR 2309 has been sampled five times by DWQ between 1985 and 2008. The site
received a bioclassification rating of “Fair” or “Poor” each time. The site was Not Rated in 2008 due to
low streamflow as a result of drought, but would have otherwise rated as “Fair.” The USGS also
conducted macroinvertebrate sampling at SR 2309 in 2003. The data were collected for the National
Water Quality Assessment Program study, and included a variety of organisms including insects,
bivalves, gastropods, and annelids. The survey did not provide a bioclassification to compare with the
DWQ rating, but documented 47 species of macroinvertebrates at the site. Benthic macroinvertebrate
data are summarized in Table 16.
Little Alamance 4b Demonstration Existing Data Inventory

C-18
Table 16. Benthic macroinvertebrate data summary.
Sample Location Date DWQ Bioclassification
Coble Branch at Engleman Ave 6/24/2003 Not Rated
Little Alamance Cr at Overbrook Rd. 6/24/2003 Poor
Little Alamance Cr at NC 54 9/12/2006 Poor
Little Alamance Cr near I-85 6/23/2003 Poor
Little Alamance Cr I-85 Frontage Rd. 9/12/2006 Poor
Little Alamance Cr at NC 49 6/23/2003 Poor
Little Alamance Cr at Rogers Rd (SR 2309) 7/29/1985 Fair
7/10/1998 Poor
5/20/2003 N/A
6/23/2003 Fair
9/12/2006 Poor
7/14/2008 Not Rated
2.5.2 Fish
The fish community has been sampled four times at one site - Little Alamance Creek at SR 2309. Three of
the surveys were conducted by DWQ (1993, 1998, and 2003,) and one by USGS (2003). DWQ assigned
Bioclassification ratings of Good, Fair, and Good, respectively (see Table 17 below). The USGS does not
calculate the same bioclassification rating, but reported a total of 16 fish species. The most abundant
species were the bluehead chub (43), crescent shiner (35), and the tessellated darter (33).

Table 17. Summary of fish sampling data.
Sample Location Date Bioclassification
Little Alamance Cr at Rogers Rd (SR 2309) 1993 Good
Little Alamance Cr at Rogers Rd (SR 2309) 1998 Fair
Little Alamance Cr at Rogers Rd (SR 2309) 2003 Good
Little Alamance Cr at Rogers Rd (SR 2309) June 2003 N/A
2.5.3 Protected Species
There are no federally protected species in Alamance County. Four aquatic species are listed as Federal
Species of Concern. Two vertebrates, the American eel (Anguilla rostrata) and the Carolina darter
(Etheostoma collis lepidinion) have no state status. Two mussel species, the Carolina creekshell (Villosa
vaughaniana) and the Yellow lampmussel (Lampsilis cariosa) are listed as Federal Species of Concern
and North Carolina Endangered.
2.6 Habitat assessment
Data for habitat assessments were found in three documents, listed below in Table 18. The assessments
were generally conducted concurrently with benthic macroinvertebrate sampling.

Little Alamance 4b Demonstration Existing Data Inventory

C-19
Table 18. Habitat assessment data sources for the Little Alamance Creek watershed.
Data Source Survey Date
Number of Sites
Surveyed
2010-12 TMDL to Address Biological Integrity in the Little Alamance
Creek Watershed
June 2003 5
2008 DWQ Evaluation of Water Quality, Habitat and Stream Biology in
LATT
September 2006-
August 2007
7
2009 DWQ Biological Assessments – Cape Fear July 2008 1

Habitat assessment scores ranged from 53 to 93, out of a maximum possible score of 100. The Little
Alamance Creek at SR 2309 site has been assessed three times, with scores of 73, 67, and 57 in 2003,
2006, and 2008 respectively.
2.7 Channel Data
Morhpological data for the Little Alamance Creek watershed is very limited. The TMDL Stressor Study
performed by DWQ in 2003 included some basic channel characteristics at each of the five benthic
sampling sites. A stream restoration project conducted in Burlington’s City Park included more detailed
morphological data for the mainstem of Little Alamance Creek and one unnamed tributary.

Table 18. Morphological data sources for the Little Alamance Creek watershed
Data Source Survey Date
Number of Sites
Surveyed
2010 TMDL to Address Biological Integrity in the Little Alamance Creek
Watershed
June 2003 5
2007 USGS Data Series 279; USGS Gage Station 0209679804 2003 1
2008 Little Alamance Creek - Stream Restoration Plan - Arcadis Unknown 2
2.7.1 Stream Morphology
A stream restoration project was conducted by NCEEP on a 2,633-linear-foot section of Little Alamance
Creek in City Park in Burlington. The only available morphological data have been obtained from the
restoration plan for this project. Prior to restoration activities, this section of Little Alamance Creek was
approximately 30 to 60 feet wide at the top of the bank, with banks ranging between 4 and 8 feet high,
and bank height ratios between 1.0 and 1.4. An unnamed tributary included in the project was
approximately 5 to 10 feet wide at the top of bank, with bank heights of 2 to 4 feet and bank heights
ratios between 1.0 and 1.3.

Little Alamance Creek’s cross sectional area ranged between 79.3 ft2and 125.0 ft2 with an average of
95.0 ft2. Channel width ranged from 31.8 feet to 42.5 feet with an average of 36.2 feet, and mean depth
ranged between 2.2 feet and 2.9 feet, with an average of 2.6 feet. The width to depth ratio ranged
between 11.6 and 17.0 with an average of 14.0.

The pattern of the reach was slightly meandering, with a sinuosity of 1.2. The average water surface
slope of the section was 0.24 percent. Approximately 65 percent of the stream reach was comprised of
Little Alamance 4b Demonstration Existing Data Inventory

C-20
pools. In the middle section of the project reach, the existing pools were separated by fairly short and
steep bedrock steps.
2.7.2 Substrate Composition
The primary information on substrate composition comes from the NCEEP stream restoration plan for
the section of Little Alamance Creek in City Park. The streambed in that section was comprised mainly of
sand, though there is some occurrence of bedrock. The particle size distribution of Little Alamance
Creek’s substrate prior to restoration was: D16 = 0.2 mm, D35 = 0.7 mm, D50 = 2.4 mm, D84 = 138.0 mm,
and D95 = 216.0 mm.

Substrate composition was also estimated at the five benthic sampling sites in 2003.
2.7.3 Streambank Stability
Quantitative information on streambank stability is available for a portion of Little Alamance Creek in
Burlington’s City Park. This information was collected as part of a stream restoration project. Bank
erosion had caused the stream to become overly wide in some sections and mid-channel bars had
developed because the stream did not have the capacity to transport sediment through these reaches.

Prior to restoration, a Bank Erosion Hazard Index (BEHI) analysis was performed on Little Alamance
Creek and its unnamed tributary. The ratings ranged from low to extreme on Little Alamance Creek and
from low to very high on the unnamed tributary. Contributing to the high, very high, and extreme
ratings were high bank heights, shallow rooting depths, and low rooting densities (a function of the lack
of woody vegetation). Near bank stress (NBS) ranged from low to extreme on both Little Alamance
Creek and the unnamed tributary. Extreme NBS ratings were due to high banks, central bars, and tight
meander bends. Based on these ratings, an estimated 694 tons of sediment per year were being
contributed by this reach of Little Alamance Creek, and the unnamed tributary was contributing an
additional 55 tons of sediment per year.
2.7.4 Flow Data
There are no active USGS gages located in the Little Alamance Creek watershed. The nearest active gage
station, 02094500, is located on Reedy Fork west of Little Alamance near Gibsonville, NC. The station has
data for gage height and discharge for years 1928-present. Another long-term gage station is located to
the east of Little Alamance; Station 02096500 is located on the Haw River in the town of Haw River, NC.
The station has data for precipitation, gage height, and discharge for years 1928-present.

Three data sources were identified with flow data in the Little Alamance Creek watershed, shown in
Table 19.

Little Alamance 4b Demonstration Existing Data Inventory

C-21
Table 19. Sources of flow data for Little Alamance Creek watershed
Data Source
Date range of
Data Collection
Number of Sites
Sampled
Approximate
Number of
Samples
EPA STORET data download 1968-1975 1 8
2007 USGS Data Series 279
USGS Gage Station 0209679804
7/15/2002 -
7/14/2003
1 365 days of
hourly mean
2008 Little Alamance Creek - Stream Restoration Plan –
Arcadis
Unknown 1

The data downloaded from EPA’s STORET database indicated that stream gage height was measured on
Little Alamance Creek at SR 2309 from December 1970 to February 1975. A total of 8 stage heights were
reported, ranging from 11.75 feet to 17.8 feet. On four of these dates, a calculated mean flow was also
reported, ranging from two to nine cubic feet per second (cfs). However, the stage and discharge are not
correlated as expected – the highest stage measurement corresponds with the lowest discharge
calculation. The reliability of these historical data is not known.

Stream flow data were collected as part of the USGS study on urbanizing piedmont streams in 2002 and
2003. Continuous stream stage data were collected hourly for one year, from 11/16/2002 to
11/15/2003. Standard USGS stream gaging techniques for collection of streamflow data were not used
because of the short term of data collection at the sites and limited resources for the project. Instead, a
submersible pressure transducer with an internal data logger was used. Daily mean discharges were
computed for the period of record. The overall mean discharge for the year was 14.9 cfs. USGS
calculated numerous other statistics, including measures of flashiness and frequency of high and low
flow, and duration of high and low flow.

The bankfull discharge was also estimated for the stream restoration project in Burlington’s City Park.
Little Alamance Creek has a drainage area of 4.2 square miles at this location. The average velocity for
the channel was measured at 2.5 feet per second, which was multiplied by the average cross sectional
area of the channel, for a calculated discharge of 237.5 cfs at bankfull flow.
2.8 NPDES Wastewater Treatment Point Source Discharges
There are no known NPDES-permitted wastewater treatment facilities in the Little Alamance Creek
watershed.
2.9 Stormwater outfall inventory

The cities of Burlington and Graham have completed field inventories of stormwater infrastructure
within their respective municipal boundaries. An inventory of the stormwater infrastructure is currently
being conducted by NCDOT.
Little Alamance 4b Demonstration Existing Data Inventory

C-22
3.0 Summary of Existing Data
While some categories of data are more complete than others, the Little Alamance Creek watershed is
lacking comprehensive water quality data to explain the poor benthic community results.
3.1 Spatial Distribution
Data for the Little Alamance Creek watershed have been collected from a total of 11 different locations.
Various studies and reports sometimes refer to the same location by different identifying codes. Table
20 lists the location of each sampling site and a cross-referencing of the various codes that the location
has been sampled under. Figure 1 shows a map of the watershed with the location of each sampling
site.

Table 20. Location and identity code information for all sample sites in the Little Alamance Creek
watershed
Location Latitude Longitude
Watershed
Area (mi2) TMDL ID Benthic ID
2008
Eval ID
Coble Branch at Engleman Ave 36.086111 -79.469722 0.6 B1 BB42
Little Alamance Cr at
Overbrook Rd
36.083333 -79.452778 4.4 B2 BB193
Unnamed Tributary to
Willowbrook Cr at Kime St
36.0872 -79.4429 0.4 - 14
Willowbrook Cr at Mebane St
(SR 1363)
36.0839 -79.4433 1.3 - 15
Little Alamance Cr at Mebane
St (SR 1363)
36.0801 -79.4479 4.4 - 16
Little Alamance Cr at NC 54
(Tucker St)
36.074444 -79.443889 6.4 - BB47 17
Little Alamance Cr at I-85
Frontage Rd (SR 1398)
36.0650 -79.4376 7.7 B3 BB46 18
Little Alamance Cr near I-85 36.065 -79.437778 7.4 - BB78
Bowden Br at Hanford Rd (SR
2304)
36.0509 -79.4160 2.5 - 20
Little Alamance Cr at NC 49 36.052778 -79.435 9.0 B4 BB131
Little Alamance Cr at Rogers Rd
(SR 2309)*
36.0359 -79.4092 14.1 B5 BB388 19
* Little Alamance Creek at SR 2309 is also identified as Site B1920000 in the historical STORET data, and as USGS
Gage Station 0209679804.

Little Alamance 4b Demonstration Existing Data Inventory

C-23
Figure 1. Little Alamance Creek watershed showing the spatial distribution of the 11 sites where data
have been collected
3.2 Temporal Distribution
Water quality sampling efforts in the watershed span almost 40 years. The earliest known samples were
taken in July 1968. No data were collected between 1975 and 1985, when limited biological monitoring
resumed. More concentrated data collection efforts took place in 2003 and 2007.

Little Alamance 4b Demonstration Existing Data Inventory

C-24
3.3 Extent of available data
Table 21 presents a qualitative summary of the relative completeness of the various data categories. In
an effort to distill and summarize the findings of the data inventory into a single table, each data
category was given a qualitative rating of the relative completeness of the available data (Table 21). The
ratings are loosely defined as follows:

Inadquate: Very limited data relative to other parameters in the watershed. Data may be limited by total
samples or by spatial and temporal variability and additional data collection would be useful.

Moderate: Some data are available and have a greater number of data points or capture some degree of
spatial and temporal variability. However, data are not sufficient to draw conclusions or establish
baseline conditions.

Adequate: The existing dataset includes much or all available data and there is not a significant need for
additional data collection. (Note – this does not necessarily equate to a large quantity of data. For
example, NPDES-permitted wastewater discharges do not exist in the watershed, but since the
availability of these data are complete, the category was given a rating of Adequate).

Table 21. Availability of information on Little Alamance Creek watershed
Category Inadequate Moderate Adequate
Watershed Characteristics
General Information X
Ecoregion X
Climate X
Land Use X
Water Quality Data
Physicochemical parameters X
Nutrients X
Metals X
Bacteria X
Biological Data
Benthic macroinvertebrate sampling X
Fish sampling X
Habitat assessment X
Channel Data
Stream Morphology X
Substrate composition X
Streambank stability X
Flow Data X
NPDES WWTP Point Source Discharges X
Stormwater Outfall Inventory X

Little Alamance 4b Demonstration Existing Data Inventory

C-25
General information about the watershed is widely available and complete. Availability of water quality
data is sparse, with slightly more complete data for physicochemical parameters. Biological data are
generally sparse and are considered inadequate to support most planning and water quality and
watershed planning decisions or needs. Benthic macroinvertebrate data collections span over 20 years,
and therefore were given a rating of moderate. There is minimal information on channel characteristics
and stability. Flow data is somewhat more complete, as data were collected continuously for one year
near the bottom of the watershed.
4.0 Conclusions
Overall, the available data on Little Alamance Creek are not sufficient to draw definitive conclusions
about the source of the biological impairment or support development of a TMDL. The creek is impaired
for aquatic life only, and no specific pollutants were identified. The existing reports attributed the
impairment to the generally understood conditions of an urban watershed, including the following
sources:

• Hydromodification
• Insufficient riparian buffer
• Streambank erosion
• Pollutants in stormwater runoff
• Degradation of in-stream habitat

These conclusions were largely identified through field studies that occurred during a period of drought.
Regardless, no known water quality pollutants or pollutant sources have been identified to date.

Little Alamance 4b Demonstration Existing Data Inventory

C-26
5.0 References
Arcadis G&M of North Carolina, Inc., 2008. Little Alamance Creek Stream Restoration, Alamance County,
State Construction Office Project Number: D07050S, Final Restoration Plan, for NCDENR,
Ecosystem Enhancement Program, January 2008.

Elon University, 2010. Little Alamance Restoration Alliance Meeting - Slide Presentation and Land Cover
Summary Statistics, Elon University Department of Environmental Studies, June 2010.

EPA STORET Database, [Accessed June 6, 2013 online at: http://www.epa.gov/storet/].

Giddings, E.M., et al., 2007. Selected Physical, Chemical, and Biological Data for 30 Urbanizing Streams in
the North Carolina Piedmont Ecoregion, 2002–2003: U.S. Geological Survey Data Series 279,
[online at: http://pubs.water.usgs.gov/ds279]

NCDENR DWQ, 1996. Cape Fear River Basinwide Water Quality Plan, October 1996.

NCDENR DWQ, 2000. Cape Fear River Basinwide Water Quality Plan, July 2000.

NCDENR DWQ, 2005. Cape Fear River Basinwide Water Quality Plan, October 2005.

NCDENR DWQ, 2006. Draft Summary of Existing Water Quality Data for Little Alamance, Travis, and
Tickle Creek, September 2006.

NCDENR DWQ, 2007. Evaluation of Water Quality, Habitat, and Stream Biology in the Little Alamance,
Tickle, and Travis Creek Watersheds, Draft Final Report, February 2008.

NCDENR DWQ, 2009. Cape Fear River Basin – 2009 Biological Assessments [online at:
http://portal.ncdenr.org/web/wq/ess/reports]

NCDENR DWQ, 2010. Total Maximum Daily Load to Address Impaired Biological Integrity in the Little
Alamance Creek Watershed, Alamance County, Cape Fear River Basin, Draft, December 2010.

NCDENR DWQ, 2011. North Carolina’s Division of Water Quality Category 4b Demonstration Guidance.
Draft. December 2011. [online at: http://portal.ncdenr.org/web/wq/ps/mtu/alternatives]

NCDENR DWQ, 2012. 2012 North Carolina Integrated Report. Approved by the United States
Environmental Protection Agency on August 10, 2012. [online at :
http://portal.ncdenr.org/c/document_library/
get_file?uuid=9d45b3b4-d066-4619-82e6-ea8ea0e01930&groupId=38364,
http://portal.ncdenr.org/web/wq/ps/mtu/assessment ]

NC Natural Heritage Program, [Accessed July 9, 2013 online at: http://www.ncnhp.org/]

Piedmont Triad Council of Governments, 2007. Little Alamance, Travis, and Tickle Creek Watershed
Characterization Phase I, Final Report for NCDENR NCEEP, March 2007.
Little Alamance 4b Demonstration Existing Data Inventory

C-27
Piedmont Triad Council of Governments, 2008. Little Alamance, Travis, and Tickle Creek Watersheds
Assessment: An Ecosystem Enhancement Program Funded Local Watershed Plan Phase II, for
NCDENR NCEEP June 2008.

Piedmont Triad Council of Governments, 2008. Little Alamance, Travis, and Tickle Creek Watersheds
Report and Project Atlas: An Ecosystem Enhancement Program Funded Local Watershed Plan
Phase III, for NCDENR NCEEP, November2008.

State Climate Office of North Carolina, [Accessed June 8, 2013 online at: http://www.nc-
climate.ncsu.edu/]

US Fish and Wildlife Service, [Accessed July 9, 2013 online at: http://www.fws.gov/]