December 10, 2001

Angie Pennock
Department of the Army
Wilmington District, Corps of Engineers
PO Box 1890
Wilmington, NC 28402-1890
Fax Number: (910) 251-4025

Re: Action ID No. 200100853, Riegel Ridge Landfill, Columbus County

Clean Water Act, Section 404

Dear Ms. Pennock:

On behalf of the Blue Ridge Environmental Defense League and our chapters in Brunswick and Columbus counties, Brunswick Environmental Defense League and Friends of Green Swamp, I write to comment on the proposal for municipal solid waste landfill by Riegel Ridge, LLC in Columbus County. In addition, we hereby request that a public hearing be held before action is taken and that the comment period be extended to provide the affected public with adequate time to submit information which would otherwise not be presented.

General Comments

The Army Corps of Engineers uses vegetation, soil, and hydrology to determine existence of wetlands. Typically all three indicators must be present during a part of the year; however, the land at Green Swamp has been altered, making the presence of a single characteristic sufficient to make the designation of the area as a wetland. The land has been altered by paper industry ditch and draining activities which have made the land suitable for tree plantation. Therefore, a single factor is sufficient to make the determination of wetlands in this case.

The US Army Corps of Engineers and the US Environmental Protection Agency define wetlands as follows:

Those areas that are inundated or saturated by surface or ground water at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, and similar areas.

The area under review for the Riegel Ridge solid waste landfill is known as the Green Swamp. This descriptive term and common definition applies to the area which has been known as a swamp for many years. For the reasons we have outlined in these comments, the site proposed for a landfill by Riegel Ridge is unsuitable for use as a landfill. A public hearing would allow for a full presentation of the facts material to proposed action No. 200100853.

Soil Types Indicate Wetlands

The Columbus County Soil Survey Map included in the November 9^th Action Notice shows the following soil types within the General Site Area: Grifton fine sandy loam (Gt), Goldsboro fine sandy loam (GoA), Lynchburg fine sandy loam (Ly), Butters loamy fine sand (BuB), Nakina fine sany loam (Nk), Norfolk loamy fine sand (NoA), Rains fine sandy loam (Ra), and Foreston loamy fine sand (Fo). Grifton fine sandy loam is listed as a hydric soil in “Hydric Soils of the United States.”

Another indicator of wetlands is the presence of soil which is sandy and has a layer of decomposing plant material at the soil surface or has dark stains or streaks of decomposed plant material just below the surface. Such characteristics are found throughout the area known as the Green Swamp and within the General Site Area.

Vegetation Types Indicate Wetlands

Certain types of vegetation, known as hydrophytic, are known to grow in wetland areas. The Green Swamp area and the General Site Area are widely vegetated with hydrophytic plants including cypress, cattails, bulrushes, cordgrass, sphagnum moss, willows, mangroves, sedges, rushes, arrowheads, and water plantains.

Environmental Impact Statement

Landfill leachate typically includes trichloroethylene, benzene, dichloromethane, ethylene chloride, dichloropropane, and many other toxic, carcinogenic compounds. All landfill leak. Subtitle D requirements under RCRA only retard the onset and extend the duration of the landfill leachate contamination of groundwater and surface waters.

Therefore, We ask that a full environmental impact statement for this action be prepared by the Corps and that the EIS fully consider all factors for the protection and use of important resources including water pollution, air pollution, and energy use. In addition to the general conservation and environmental those factors listed in the notice of November 9^th, we request that a full comparison of the alternatives to burial of solid waste in this landfill, i.e. recycling and composting, be included in the analysis. For example, the energy savings from recycling as compared to land filling would be 95% for aluminum, 60% for steel, 50% for paper, and 20% for glass. Air and water pollution and water use are reduced by similar percentages if these materials are recycled and not put into a landfill.

Respectfully submitted,

Louis Zeller