BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE
www.BREDL.org
~ PO Box 88 Glendale Springs, North Carolina
28629 ~ Phone (336) 982-2691 ~ Fax (336) 982-2954
~ Email: BREDL@skybest.com
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. http://www.saw.usace.army.mil/wetlands/regtour.htm |
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 9th
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 9th, 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
|
