20011680 Ver 1_COMPLETE FILE_20011113 (2)

. MARLOWE, DREITZLER & ASSOCIATES
Consulting Engineers
219 North Boylan Avenue 919-834-1113
Raleigh, N.C. 27603 919-834-6060 (Fax)
June 4, 2001
1 21
Mr. John Dorney
n
lip
NC Division of Water Quality, Wetlands Section
1621 Mail Service Center
Raleigh, North Carolina 27626-0621
Reference: Wetland Impacts Corps of Engineers Permit Application
Riegel Ridge Municipal Solid Waste Landfill
Columbus County, North Carolina
Dear Mr. Sechler:
The Corps of Engineers has requested that I contact your Agency to inform you of a site
meeting to be held at 10:00 AM on July 11, 2001. The meeting will constitute an inter-
agency meeting prior to submittal of a permit application for the proposed impacts of
just less than I/2 acre of wetlands identified on the Riegel Ridge Landfill site. The
initial Public Meeting for this project was held in Columbus County on February 21,
2000, with a March 3, 2000 submittal of the Site Study documents required under the
North Carolina Solid Waste Management Rules. The Corps of Engineers signed off the
wetland location map on October 2, 2000. The Archaeological Study was completed on
June 20, 2000 while the initial Rare and Endangered Species Study was completed on
June 29, 2000. A follow-up Rare and Endangered Species Study, as requested by the
Natural Heritage Program, was completed on October 6, 2000.
In addition to the environmental studies mentioned, significant geological and
hydrological investigations have been made on the proposed site, including nearly 200
soil borings across the 760-acre site. The hydrogeologic studies have been presented to
the Division of Solid Waste Management for review. The initial Hydrogeologic Report
was submitted on March 3, 2000, with addendum No. 1 completed on April 6, 2000 and
addendum No. 2 completed on May 9, 2001. The addenda were prepared in response to
questions and further evaluations requested by the Division of Solid Waste
Management.
At the direction of the Wilmington Field Office of theU.S. Army Corps of Engineers, I
am respectfully requesting your attendance at the Riegel Ridge Municipal Solid Waste
Landfill site to participate in an inter-agency meeting prior to a wetlands impact permit
application. I have enclosed a copy of the Regional Characterization Study Map for
your reference as to the Site's general location. In addition, I will follow up with

detailed directions and a specific on site meeting location prior to July 11, 2001. In the
meantime, if you have any questions, please call me at your convenience.
Sincerely,
MARLOWE, DREITZLER & ASSOCIATES
0I
William W. Dreitzler, P.E.
Partner
Director of Engineering Services
Cc: John Whitehurst, Columbus County Administrator
Angie Pennock, Biologist, Wilmington Corps of Engineers
Jeffrey H. Richter, Biologist, Project Manager, Wilmigton Corps of Engineers
O?O? W AT 4?,4QG
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Mr. Kevin Martin
Sand EC
11010 Raven Ridge Road
Raleigh, North Carolina 27614
Dear Mr. Martin:
' Michael F. Easley, Governor
William G. Ross Jr., Secretary
2 ?O rth Carolina Department of Environment and Natural Resources
„fie( Gregory J. Thorpe, Ph.D.
Acting Director
CjDivision of Water Quality
Subject: Project: Riegel Ridge Landfill
County: Columbus
18, 2001
f L
COE: 200100853
The purpose of this letter is to notify you that the North Carolina Wetlands Restoration
Program (NCWRP) will accept payment for non-riparian wetland impacts associated with the
subject project.
Based on the information supplied by you in a letter dated October 1, 2001, the
non-riparian wetland restoration that is necessary to satisfy the compensatory mitigation
requirements for this project is summarized in the following table. The maximum amount of
mitigation that the NCWRP will accept for this project is also indicated in this table.
Stream
(linear feet) Non-Riparian Wetlands
(acres) Riparian Buffer
(ft2)
Impact 0.69
Mitigation Max. 1.38
As requested, the NCWRP will provide non-riparian wetland mitigation as specified in
the 401 Water Quality Certification and/or Section 404 Permit for impacts associated with the
subject project. Although the impacts are in Cataloging Unit 03040206 in the Lumber River
basin, NCWRP proposes to mitigate within the same physiographic region in the Lumber
River basin.
If you have any questions or need additional information, please contact Crystal
Braswell at [phone].
&cere
Ronald E. Fe ell,
Program Manager.
cc: Rob Ridings, Wetlands/401 Unit
Angie Pennock, USACOE
Joanne Steenhuis, WiRO
file
r
NCDEhR
Wetlands Restoration Program 1619 Mail Service Center Raleigh, NC 27699-1619 [phone] Customer Service
320 West Jones Street Raleigh, NC 27603 Fax: [phone] 623-7748

JOHN D. RUNKLE
ATTORNEY AT LAW
POST OFFICE BOX 3793
CHAPEL HILL, NORTH CAROLINA 27515
TELEPHONE: [phone]
March 12, 2002
Sherri Coghill
Solid 'Haste Section
Division of Waste Management
Mail Service Center 1646
Raleigh, NC 27699-1646
RE: Proposed Riegel Ridge Landfill, Columbus County
Dear Sherri:
,s
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tit 1 5 ?
WE"NNS GROUP
?_ " TEa R QUALITY SECT IQ.K!
Has there been any additional filings on the Riegel Ridge Landfill since the first of the year?
The only new piece of information I have received is the attached letter from William R.
Straw of the Federal Emergency Management Agency that was filed as a comment on the
404 permit from the Army Corps of Engineers regarding the floodplain on the site.
Sincerely,

John D. Runkle
Enc.
CC. Cyndi Karoly, Wetlands Unit, Division of Water Quality
Jeff Lane, Friends of the Green Swamp
Todd Miller, NC Coastal Federation
Derb Carter, Southern Environmental Law Center
RECYCLED PAPER

Y M.I.1 fn
Federal Emergency Management Agency
?n,, Region IV
%I..
VIA
x? A 3003 Chamblee-Tucker Road 0 A Zs?r31
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°?? *•^ ' ?, Atlanta, Georgia 3034 1-4 130
January 29, 2002
Ms. Angie Pennock
Wilmington District, Corps of Engineers
Department of the Army
Post Office Box 1890
Wilmington, North Carolina 28402-1890
Reference: Action ID No. 200100853; Proposed Riegel Ridge Landfill
Dear Ms. Pennock:
This letter comments on the proposed location and boundaries of the Riegel Ridge landfill and
their relationship to the 100-year floodplain. We realize that the comment period for action
200100853 has expired, regret that we could not respond sooner, and hope the issues we raise
may still be considered.
We have two concerns. One involves what may have been undue weight placed on the
floodplain boundary as depicted on the current Flood Insurance Rate Map (FIRM) of the area.
The other involves likely changes in those boundaries, currently in preparation and anticipated to
go into effect officially later this year.
The current FIRM is based on very limited data from a flood study conducted in the mid-1970s.
The flood boundaries depicted are only approximate and are thought to involve uncertainties on
the order of several feet. Giver, the subtle topographic relief that characterizes this part of
Columbus County, the actual 100-year floodplain boundaries could be displaced laterally some
distance from depicted locations. Certain proposed operational boundaries follow the published
floodplain boundaries with a fidelity that far exceeds the quality of data on which those
boundaries were based. Use of the FIRM in this way appears to have given it undue weight.
We note that a detailed study of floodplain boundaries in Columbus County is currently
under=gay and is being managed by the ivo?:,h Carolina Moo dplain .lapping Program (Mr. Abdul
Rahmani, Project Manager, 919-715-8000, ext. 266). A revised FIRMM is expected to be issued
later this year and will include more accurate floodplain elevations and boundaries for the project
area.
Given the above, it may be prudent to delay determining the precise location of operation
boundaries until accurate data becomes available. Also, it may be appropriate to coordinate with
Mr. Rahmani's office as useful data may be available in advance of o(&Jal publication dates.
Finally, we note that section 2(a)(1) of Presidential Executive Order (EO) 11988 requires that
floodplain boundaries be determined from FIRMs unless more detailed map-s-of an area are
available. An argument can be made that better maps are.,Nlailable. Immediately across the
county line to the east of the project site, where more ac.Cturate flood studies have been done, the
mapped 100-year floodplain boundary approximately f lows the sixty foot contou` line. Since
f/
A• 2
the applicant has prepared topographic maps of the proposed site at one foot contour intervals,
these could be used to estimate floodplain boundaries. The boundary estimated in this fashion is
substantially different from the one shown on the official FIR-Nit and extends across portions of
the proposed landfill.
It is worth noting that, where flood elevations have not yet been established, the Columbus
County floodplain ordinance, in compliance with kEMA regulations at 44 CFR 60.3(b)(3),
requires an applicant proposing to disturb five or more acres of floodplain (with, say, borrow
pits) to determine the elevation of the 100-year flood. Hence, better maps are available, or will
be available before this project can proceed, more accurately depicting floodplain boundaries.
If more accurate maps are available and show the project located, in part, within the floodplain,
EO 11988 issues need to be addressed in a public forum prior to issuance of any 404 permit for
the project. If EO 11988 applies, the applicant must provide "an explanation of why the action is
proposed to be located in the floodplain." Also, thhere must be a discussion of alternative places
where the landfill might be located, or a discussion of why citing in a floodplain is "the only
practicable alternative consistent with the law and the policy set forth in this order [EO 11988]."
And lastly, there must be an explanation of how the proposed landfill is an activity "which in the
public interest must occur in or impact upon floodplains."
Before closing, we should note that EO 11988 and Anny regulations at 33 CFR 320.4(1) also
require mitigation (for increased risks due to loss of floodplain storage and conveyance
capacities) when a facility must'oe located in a floodplain. However, if the facility will be in the
floodplain, North Carolina regulations at 15A NCAC Subchapter 13B Section. 1 622(2) require
more stringent precautions. Hence, there is no need to consider floodplain mitigation at the
federal level.
In summary, the location of floodplain boundaries in eastern Columbus County cannot be
accurately determined from FIRM is and this may complicate decision-making on the Riegel
Ridge Landfill project. Once again, we regret that we could not respond to your notice sooner
and hope that data and lack of data on flood risks will be properly evaluated in connection with
the Corps' pennitting decision. If you have any questions or comments on this matter, please
contact Mr. Charles Beck of this office at 770-220-5334.
Sincerely, •??
fWilliam R. Straw, Ph,D.
Regional Envirolvnental Officer
cc; Abdul Rahmani, NC Floodplain Mapping Program
Jim Coffey, NC DENR DWM Solid Waste Section
Philip S. Letsinger, NC Emergency Management
Walter Batten. Columbus County
Marty L awing, Brunswick County
Alton Boozer, SC DHEC, Bureau of 'eater
Efitity Names
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DEPARTMENT OF THE SECRETAR"Y" OF STATE
OrPorallons
Date: 5/5/2002
Document Filings
Corporation Names
Name Name Type
RIEGEL RIDGE, LLC Legal
Riegal Ridge Landfill Consortium, LLC Prev Legal
Limited Liability Company Information
SOSID: 0479552
Status: Current-Active
Date Formed: 12/23/1998
Citizenship: Domestic
State of Inc.: NC
Duration: DEC 2098
Registered Agent Principal Office No Address Listed
Agent Name: Peverall, Gregory aa. Address:
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Address: Raleigh NC 27603 Address: Raleigh NC 27603
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Limited Liability Company Information
SOSI D: 0479552
Status: Current-Active
Date Formed: 12/23/1998
Citizenship: Domestic
State of Inc.: NC
Duration: DEC 2098
Registered Agent
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Registered Office 219 N Boylan Ave
Address: Raleigh NC 27603
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Hickmans Branch LBR57 15-23-3 L24NE4 C SW
Hillburn Branch LBR53 14-2.2-13-1 I23SW3 C SW
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Hog Branch LBR58 15-4-8-4-1-2 J23SE9 C Sw
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Holy Swamp (Holly Swamp) LBR52 14-10-10 I22NW6 WS-IV SW
Honey Island Swamp LBR57 15-7-5 K25NE4 C SW
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Horns Millrace (Horns old Millpond) LBR54 14-30-4 J22NW5 C SW
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Horse Creek LBR56 15-2-6-4-5-1 J25SW1 C Sw +
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Horse Swamp LBR54 14-30-3 I22SW8 C Sw
Horsepen Branch LBR53 14-22-1-1-1 H23NW4 C SW
Horsepen Branch LBR53 14-22-16-2 J23NE1 C SW
Horsepen Branch LBR54 14-30-7-2 I22SE6 C SW
Horsepen Branch LBR58 15-4-1-1-1-2-2 I24SW6 C Sw
Horsepen Branch LBR51 15-4-8-1 J23SE5 C SW
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Horseshoe Swamp LBR58 15-4-1-1-2-2 I24SE9 C SW
Huckleberry Swamp LBR53 14-22-6-2 123NE3 C SW
Huggins Creek LBR57 14-36 K23NW5 B SW
Humphrey Branch LBR52 14-10-6-(1) H22SE7 C SW
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Copyright (C) 1997, Maptech, Inc.
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
Division of Water Quality
Department of Environmental and Natural Resources
Wetlands/401 Unit
Street Address: 2321 Crabtree Boulevard, Suite 250
Raleigh, NC 27604-2260
Mailing Address: 1650 Mail Service Center
Raleigh, NC 27699-1650
Contact Information: Phone #: [phone]
. Fax #: [phone]
Fax To.
Company:
Vumber of pages including cover sheet:
Fax #: U `1 ?QC?U CJ
Date: VW162-
'*Totes or special instructions:
S
0 l>-/f
C. Division of Water Quality, 401 Wetlands Certification Unit,
-50 Mail Service Center, Raleigh, NC 27699-1650 (Mailing Address)
21 Crabtree Blvd., Raleigh, NC 27604-2260 (Location)
19) 733-1786 (phone), 919-733-6893 (fax), (http://h2o.enr.state.ne.us/newedands
O1 P -?A Il
Michael F. Easley, Governor
?O'F \NAT?,9 William G. Ross Jr., Secretary
QG North Carolina Department of Environment and Natural Resources
?O y Alan W. Klimek, P.E., Director
t- Division of Water Quality
>_ -f
October 7, 2002
Angie Pennock
Department of the Army
Wilmington District, Corps of Engineers
P.O. Box 1890
Wilmington, North Carolina 28402-1890
Subject: Riegel Ridge Landfill
Practical Alternatives Determination
DWQ Project No. 01-1680
Columbus County
Dear Ms. Pennock:
The Division of Water Quality (DWQ) received Riegel Ridge, LLC's request for a 401 Water Quality
Certification on December 17, 2001. On April 18, 2002, DWQ held a public hearing on the application. By
letter dated June 10, 2002 and September 20, 2002, DWQ requested additional information for the review of the
401 Certification application.
As a part of DWQ's review, a practical alternative review is required pursuant to North Carolina
Administrative Code .0506(b)(1). However, if the Corps of Engineers conducts this review, our rules state that
we shall not duplicate that review. As such, please provide this office with a statement as to whether: 1) the
USACOE has conducted a practical alternative determination, 2) if conducted, the results of the practical
alternatives determination, 3) the materials considered in order to conduct this analysis and 4) any additional
information that you feel may be beneficial to DWQ with respect to this issue.
Thank you for your attention to this matter
Danny Smith at [phone].
If you have any questions please do not hesitate to call

cc: Wetlands/ 401 Unit -file copy
Wetlands/401 Unit- Danny Smith
Fayetteville Regional Office - Paul Rawls
File Copy
Central Files
Supervisor
l
N. C. Division of Water Quality, 401 Wetlands Certification Unit,
1650 Mail Service Center, Raleigh, NC 27699-1650 (Mailing Address)
2321 Crabtree Blvd., Raleigh, NC 27604-2260 (Location)
[phone] (phone), 919-733-6893 (fax), (http://h2o.enr.state.nc.us/ncwetlands
REPLY TO
ATTENTION OF:
Regulatory Division
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
P.O. BOX 1890
WILMINGTON. NORTH CAROLINA 28402-1890
Action ID No. 200100853
Mr. Danny Smith
Division of Water Quality
North Carolina Department of
Environment and Natural Resources
1650 Mail Service Center
Raleigh, North Carolina 27699-1650
Dear Mr. Smith:
October 17, 2002
ocr ?
tv?.H'?TLa.,,._
. Thank you for your October 7, 2002, letter requesting information on the alternatives
analysis process utilized in the DA permitting process. This information was requested in
relation to the proposed discharge of approximately 540 cubic yards of fill material into 0.69 acre
of jurisdictional waters of the United States adjacent to Honey Island Swamp to facilitate the
construction of a municipal solid waste landfill, located southwest of North Carolina Route 211
at Roberts Road, approximately 7 miles southeast of Lake Waccamaw, Columbus County, North
Carolina.
The United States Army Corps of Engineers completes an alternatives analysis for each
permit application received. The basis for this analysis can be found in the Code of Federal
Regulations at 40 CFR 230 and 33 CFR 325 Appendix B, paragraphs 7 and 9(b)(5) for the
implementation of the 404(b)(1) guidelines and National Environmental Policy Act (NEPA),
respectively. The 404(b)(1) guidelines dictate that no discharge will be permitted if there is a
less environmentally damaging, practicable alternative. Reasonable alternatives are evaluated in
accordance with NEPA.
We will complete an alternatives analysis for the Riegle Ridge project. It will be an
integral part of our Environmental Assessment (EA) and any subsequent environmental
documentation prepared as part of our decision making process. Currently, we are awaiting
additional information from the applicant and have not completed our analysis. A critical
element of our documentation will be your input regarding water quality impacts and the
proposed project's compliance with Section 401 certification criteria.

Questions or comments may be addressed to me at the Wilmington Field Office,
Regulatory Division, telephone [phone].
Sincerely,
Angie Pennock, Regulatory Specialist
Wilmington Regulatory Field Office
Copies Furnished:
Mr. Paul Rawls
Division of Water Quality
North Carolina Department of
F,nvironment and Natural Resources
225 Green Street, Suite 714
Fayetteville, North Carolina 28301-5043
Mr. John Dorney
Division of Water Quality
North Carolina Department of
Environment and Natural Resources
1650 Mail Service Center
Raleigh, North Carolina 27699-1650
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
P.O. BOX 1890
WILMINGTON. NORTH CAROLINA 28402-1890
REPLY TO
ATTENTION OF:
October 17, 2002
Regulatory Division
Action ID No. 200100853
Mr. Danny Smith
Division of Water (,duality
North Carolina Department of
Environment and Natural Resources
1650 Mail Service Center
Raleigh, North Carolina 27699-1650
Dear Mr. Smith:
b
T 20,f
C?T2
Thank you for your October 7, 2002, letter requesting information on the alternatives
analysis process utilized in the DA permitting process. This information was requested in
relation to the proposed discharge of approximately 540 cubic yards of fill material into 0.69 acre
of jurisdictional waters of the United States adjacent to Honey Island Swamp to facilitate the
construction of a municipal solid waste landfill, located southwest of North Carolina Route 211
at Roberts Road, approximately 7 miles southeast of Lake Waccamaw, Columbus County, North
Carolina.
The United States Army Corps of Engineers completes an alternatives analysis for each
permit application received. The basis for this analysis can be found in the Code of Federal
Regulations at 40 CFR 230 and 33 CFR 325 Appendix B, paragraphs 7 and 9(b)(5) for the
implementation of the 404(b)(l) guidelines and National Environmental Policy Act (NEPA),
respectively. The 404(b)(1) guidelines dictate that no discharge will be permitted if there is a
less environmentally damaging, practicable alternative. Reasonable alternatives are evaluated in
accordance with NEPA.
We will complete an alternatives analysis for the Riegle Ridge project. It will be an
integral part of our Environmental Assessment (EA) and any subsequent environmental
documentation prepared as part of our decision making process. Currently, we are awaiting
additional information from the applicant and have not completed our analysis. A critical
element of our documentation will be your input regarding water quality impacts and the
proposed project's compliance with Section 401 certification criteria.
Questions or comments may be addressed to me at the Wilmington Field Office,
Regulatory Division, telephone [phone].
Sincerely,
WV- z?? d----
Angie Pennock, Regulatory Specialist
Wilmington Regulatory Field Office
Copies Furnished:
Mr. Paul Rawls
Division of Water Quality
North Carolina Department of
Environment and Natural Resources
225 Green Street, Suite 714
Fayetteville, North Carolina 28301-5043
Mr. John Dorney
Division of Water Quality
North Carolina Department of
Environment and Natural Resources
1650 Mail Service Center
Raleigh, North Carolina 27699-1650

JOHN D. RUNKLE
ATTORNEY AT LAW
POST OFFICE BOX 3793
CHAPEL HILL, NORTH CAROLINA 27515
TELEPHONE: [phone]
Danny Smith
Division of Water Quality
401 Wetlands Unit
1650 Mail Service Center
Raleigh, NC 27699-1650
Sherri Coghill
Solid Waste Section
Division of Waste Management
1646 Mail Service Center
Raleigh, NC 27699-1646
October 24,
Angie Pennock
Department of the Army
Wilmington District, Corps of Engineers
Post Office Box 1890
Wilmington, N.C. 28402-18990
IV j
OCT 2 9 20002 ' r

Re: Riegel Ridge MSW Landfill, Columbus County, North Carolina
Dear Reviewers:
At its October 21, 2002, meeting, the Columbus County Board of County Commissioners
postponed for the third time a decision on whether to amend its Flood Damage Prevention
Ordinance to comply with the N.C. Floodway Regulation Act, G.S. 143-215.51 ff. It was
announced at the meeting that this postponement was done at the behest of Riegel Ridge
LLC.
New landfills are banned from the 100-year floodplain unless the County passes an
ordinance that complies with Act and the requirements of the National Flood Insurance
Program, and allows variances for those uses. Even if the County ordinance is amended,
the proposed landfill cannot meet the requirements of G.S. 143-215.54A(b), i.e. in order to
grant a variance allowing a landfill within the floodplain, the local government has to make
four findings. The most important of these is (b)(4), which requires that "NO FEASIBLE
LOCATION EXISTS FOR THE LOCATION OF THE USE OUTSIDE THE 100-YEAR
FLOODPLAIN." A similar kind of showing of "no practicai alternative" is also a requirement
for projects that impact wetlands and water quality.
RECYCLED PAPER
Page 2, Riegel Ridge Landfill
There is no question that the Riegel Ridge landfill is in the floodplain. The Company's own
floodplain calculations found that a significant portion of the site is within the floodplain.
("Flood Study to Determine 100-year Floodplain Limits," December 20, 2001 by
Alpha & Omega Group, Engineers).
Based on my recent talks with staff at the N.C. Floodplain Planning office, there is a strong
probability that the entire site is in the floodplain. Based on the agency's detailed mapping
of Brunswick County, the entire Riegel Ridge site may be under as much as seven feet of
water during floods. (Note that the preliminary floodplain maps for the Lumber Basin
portion of Columbus County are not completed but should be out for public comment in
November. However the basic elevation maps for the Lumber Basin and Cape Fear Basin
should be posted soon on the FEMA website: www.ncfloodmaps.com).
The project is not going forward at this point, and in all likelihood, will be unable to proceed
at all.
Sincerely,
?P&- V"Pzj4-
John D. Runkle
for the Friends of Green Swamp
CC. Jeff Lane, Friends of the Green Swamp
Todd Miller, NC Coastal Federation
Derb Carter, Southern Environmental Law Center
200 Benson Road NE
• Leland, N.C. 28451
• [e-mail]
Swamp Watch Acfion Team
January 7, 2003
Danny Smith r.
NC DENR Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1718 Wq?
??SFCTbN
Danny,
Enclosed you will find the three maps we were entrusted to copy and return. We very much
appreciate your allowing us to review the files of DWQ on the Riegel Ridge Landfill last Thursday. I
know it must have been an inconvenience to be in the midst of such cramped working space.
I'm truly saddened by the lack of funding given to a department as important as Water Quality. I just
finished listening to an online lecture to physicians given by Marion Moses, President of the Pesticide
Education Center. The lecture was on Women and Health (at www.researchchannel.org); she stated
that the most prevalent contaminant in groundwater is pesticides (insecticides, fungicides, and
herbicides), none of which are removed by water treatment facilities. Water quality is crucial to life on
earth. You have a great copier but I think DWQ should have one of the fine new university buildings
we see going up everywhere, more funding, more manpower, and more credit.
In a brief scan of the material we copied from the files, we have found inconsistencies in some of the
responses to DWQ's requests, such as groundwater levels in a monitoring well 30 some miles to the
east when there is a well documented 5 miles from the site. Another example is describing the
ditching as varying from 6 inches to 3 feet. There's no such thing as a 6- inch ditch in the Green
Swamp; the ruts in the road are deeper than that, and a ditch no deeper than 3 feet would be an
exception rather than the rule.
We will be going over these responses in greater detail and expect to find more areas of concern. To
whom should we direct these issues - Water Quality or Waste Management? I know you're busy.
You can respond by e-mail if you like (seayland a-aol.com).
cer ly,
C ounder
closures
Kill the Environment & Our Children W111 Die With It. • • • • • • • • • • • • • • • • • •
HEN
WHIIAMS
May 2, 2003
By Hand
WETLANDS/ 401 GROUP
MAY V,
WATER QUALITY SECTION
DWQ - 401 Wetlands Group
c/o Michael Horan
2321 Crabtree Boulevard
Raleigh, NC
Dear Mr. Horan:
POST OFFICE BOX 109
RALEIGH, NORTH CAROLINA 27602
TEL [phone]
FAX 919.833 •6352
919.899.3096
TALICIA C. NEAL
DIRECT DIAL: 919.899.3054
EMAIL: [e-mail]
FILE NO: 48431.29
Per our agreement, attached please find check # 4040645 in the amount of $25.30 to cover
costs associated with my duplication of the Riegel Ridge/Columbus County file.
If you have any questions, please contact me directly at 919.899.3054.
Respectfully submitted,
k.-Ja b .0 -a e. /-/j 0j
Talicia C. Neal,
Legal Assistant
Attachments
ATLANTA AUSTIN BANGKOK BRUSSELS CHARLOTTE DALLAS HONG KONG KNOXVILLE LONDON
MCLEAN MIAMI NEW'YORK NORFOLK RALEIGH RICHMOND WARSAW WASHINGTON
TA,
NCDENR
North Carolina Department of Environment and Natural Resources
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan Klimek, P.E., Director
Division of Water Quality
June 10, 2002
Certified Mail
Return Receipt Requested
Mr. William W. Dreitzler
Riegle Ridge, LLC
211 East Six Forks Road, Suite 203
Raleigh, NC 27609
Subject: Additional Information Request
Riegle Ridge Landfill
DWQ 011680
Columbus County
Dear Mr. Dreitzler:
6 ?1
JIM
Subsequent to the review of the 401 Water Quality Certification Request for Rie
Landfill developed by Soil and Environmental Consultants, Inc., the site Hydrogeological Report
developed by Titan Atlantic Group, the April 18, 2002, Public Hearing comments, and the respective
written comments received by the Division of Water Quality the following additional information is
requested. Specifically the below-mentioned items are requested pursuant to 15A NCAC 2H .0506 (b) (1
-6).
As such, insufficient evidence is present in our files to conclude that your project must be built as
planned in waters and/or wetlands in accordance with 15A NCAC 211.0506. Therefore, this project will
remain on hold as incomplete until we receive this additional information. Also, we are requesting (by
copy of this letter) that the U. S. Army Corps of Engineers place your project on administrative hold.
• 15A NCAC 2H.0506 (b) (1) has no practical alternative under the criteria outlined in
Paragraph (f) of this Rule.
- Although this issue was briefly addressed in application prepared by Soil and Environmental
Consultants, please provide copies of any additional accounts/information provided to the Corps of
Engineers with respect to the alternatives to the proposed Riegel Ridge site.
-On May 22, 2002, the Wetlands/ 401 Unit of DWQ received information that included the 1994
Columbus County report that cites different possible landfill locations within Columbus County.
Thank you for providing this information. This is an item that was to be requested
in this correspondence and is'as such in process of being reviewed. Although the review of this
document is incomplete, please additionally provide at minimally the site selection process and what
factors were used to select the proposed site.
Fayetteville Regional Office
225 Green Street - Suite 714, Fayetteville, North Carolina 28301-5043
Phone: [phone]/FAX: [phone] \ Internet: www.enr.state.nc.us/ENR
An Equal Opportunity \ Affirmative Action Employer - 50% Recycled 110% Post Consumer Paper
Mr. William W. Dreitzler
Page 2
June 10, 2002
• 15A NCAC 211.0506 (b) (2) will minimize adverse impacts to the surface waters based on
consideration on existing topography, vegetation, fish and wildlife resources, and hydrological
conditions under the criteria outlined in Paragraph (g) of this Rule;
-Please indicate whether the excavation of these borrow pits may affect adjacent wetlands. This
discussion should clearly explain whether such excavations may result in hydraulic gradient
alteration, thereby draining/reducing adjacent wetland jurisdictional areas. This concern/confusion
stems from the Titan Atlantic Group, Site Hydrogeologic Report that indicated the "final surface
water elevations in the borrow areas are anticipated to be slightly lower (ranging from 1- 2 feet) than
the groundwater levels in the surrounding undisturbed areas". Conversely, Soil and Environmental
Consultants accounts indicated after the review of soil permeability (undisturbed areas), borrow area
volume, and rainfall/evaporation assessment that groundwater from non-wetland areas will augment
rainfall as the borrow excavations are filled to normal groundwater depths in short periods of time.
A fifty ???bt buffer from the edge of the borrow pit excavation and the respective wetland
jurisdictional edge is proposed. Please provide a rational as to why this is a sufficient distance
subsequent'to consideration of the above-mentioned question?
-The application prepared by S &EC indicates a proposed wetland monitoring plan would be
developed in coordination with the USACE. It was also noted in the application that Borrow Area A
activities are of sufficient distance from wetlands and do not merit wetland monitoring. However, for
Borrow Area B, the landfill Operations Plan will include provisions such that these wetlands areas
must be flagged by wetland professionals, and then the flagged lines field assessed and accepted by
the Wilmington USACE and surveyed prior to use of the borrow area (note: a similar
determination/proposal was asserted for each borrow area).
After reviewing the application and the respective wetland monitoring proposal, it is requested that
Reigle Ridge, LLC provide DWQ a wetland monitoring plan detailing how data may be collected to
insure that the 118 acres of wetlands proposed to be avoided are adequately monitored. This plan
should include a map indicating the landscape position of all wetlands, locations of ditches, proposed
wetland monitoring well placement, borrow areas, stormwater controls, the landfill footprint and
frequency of wetland physical monitoring (efforts to periodically reaffirm the presence of the
jurisdictional wetlands and soils), well data collection, well inspections and maintenance, data
analysis, and reporting. Also, this monitoring plan should include a monitoring plan schedule.
-Please provide a contingency plan that details how the wetland polygons that may be determined to
be impacted from the on-site activities would be determined from the above-mentioned monitoring
plan and how these impacts would be abated.
• 15A NCAC 2H.0506 (b) (3) does not result in the degradation of ground waters or surface
waters
-During pit excavation, it is proposed that materials will be excavated and that the pits will not outlet,
thereby no discharge will result from this borrow activities. Please consider how you propose to
dewater this material, have necessary work space for machinery and not increase the impervious area
such that increase stormwater runoff would result.

Mr. William W. Dreitzler
Page 3
June 10, 2002
-Please explain whether the proposed landfill liner will. leak and if the landfill will allow Groundwater
contamination to occur (this includes but not limited to surficial groundwater and the discussion
should include three time lines; 1) during the life of the landfill 2) a timeline beyond the active life of
the landfill receiving waste, and 3) beyond the 30-year post closure.)
-The application prepared by S&EC briefly address the success of Title D landfills. As such, please
provide accounts of liners like that proposed for use at Riegle Ridge site. These accounts should
focus on liners that have successfully prevented groundwater contamination from occurring (the
landfill age, location, and frequency of the monitoring should be include in these accounts).
Specifically detail the success of both the liners and the landfills like that proposed at Riegle Ridge,
include the data, and a timeline for the data that supports these results.
-Conversely, please identify and provided accounts of liners and landfills, like that proposed for
Riegle Ridge, that have failed to protect groundwater. Please explain the failures, landfill retrofit
efforts, and the respective groundwater clean up that has occurred. 'Specifically detail the lack of
success of the liners and landfills like that proposed at Riegle Ridge, include the data, and a timeline
for the data that supports these results.
-It is our understanding that wells are to be installed around the proposed landfill for the purpose of
monitoring. It is also our understanding that this monitoring schedule will be of a long duration.
Please explain frequency of monitoring, how long the monitoring wells are to be monitored beyond
the life of the landfill, who will be responsible for the monitoring, and what kind of monitoring well
maintenance plan you propose to use to ensure that the wells are maintained and are functioning
properly. Also, will monitoring occur beyond the 30-year post landfill closure time window? If so, by
who?
-What is the likelihood of the liner failing and groundwater standard violations occurring within the
active life of the landfill. What is the likelihood of the liner failing and groundwater standard
violations occurring within 30-years subsequent to the landfill closure? What is the likelihood of the
liner failing and groundwater standard violations occurring after 30-years, post landfill closure?
-What maintenance and monitoring is associated with leachate storage/containment? What is the
elevation of the leachate storage structure.
- A letter from FEMA, dated January 29, 2002, indicated that immediately across the county line to
the east of the project site, where more accurate flood studies have been done, the mapped 100-year
floodplain boundary approximately follows the sixty foot contour line. Please clearly state which
floodplain elevation are to be use for site design and how/why this figure was determined/chosen.
-Address tropical storm events where stormwater and respective flooding events may be well beyond
the 100 year levels. Also, please discuss whether the saturated landscape adjacent to the landfill and
the respective changes in head between a landfill cell could result in a structural compromise of the
floor/footprint of the landfill. Is this a reasonable concern, as sometimes encountered/noted in other
flood caused land uses impacts? How can this concern be addressed?
Mr. William W. Dreitzler
Page 4
June 10, 2002
• 15A NCAC 2H.0506 (b) (4) does not result in cumulative impacts based upon pastor
reasonably anticipated future impacts, that cause or will cause a violations of downstream
water quality standards;
You should include any additional items you feel are merited in the following cumulative impact
discussion; however, your response should minimally include the following items:
- Please indicate the anticipated volumes and deposition of leachate.
- As note above indicate whether the borrow pits will impact adjacent wetlands.
In the application prepared by S&EC, a perimeter ditch is proposed to be located around the
footprint of the landfill. A review of the landfill footprint and jurisdictional wetlands indicate
that a wetland polygon is located near the western corner of the landfill. This wetland is
adjacent to the confluence of the proposed perimeter ditch (located at the western edge of the
landfill) and the proposed outlet of the perimeter ditch. Accordingly, will the presence of
this ditch and the respective change in, hydraulic gradient or the interception of adjacent
hydrology impact the wetland?
- Please discuss whether public road improvements/upgrades will be coincident to the
construction and/or the respective use of the proposed landfill. Specifically, please address.
whether road improvements (e.g. widening or installation of turn lanes etc.) will be required
and result in impacts to waters or wetlands.
- Please provide a "Sea Gull" investigation/management plan necessary to document the flight
pathways and to assess the suitability of the proposed management plan. Further, this plan
should include a reporting proposal and mechanisms to revisit this issue if monitoring data
indicates a significant population increase of the presence avian species that frequent both
Lake Waccamaw and the proposed landfill
• 15A NCAC 2H.0506 (b) (5) provide for protection of downstream water quality standards
through the use of on-site stormwater controls measures;
-Please provide a stormwater management plan for the proposed site. The above-mentioned concern
with respect to pit excavation and borrow dewatering should be included in this account.
-This plan must account for Total Suspended Solids removal necessary to protect state waters
(typically, 85% TSS reduction).
-This plan must result in peak flow rates being the same after post construction as they are for pre-
construction.
Mr. William W. Dreitzler
Page 5
June 10, 2002
-Stormwater control structure maintenance must also be addressed. Provide a monitoring plan and
detail who is to be responsible for the necessary maintenance of the stormwater control structures
during the period of time the landfill is active, during the 30-years period of time post landfill closure,
and subsequent to 30-years post landfill closure.
-Please address what prevision are to be provided to protect the facility, including stormwater controls
during tropical storms events.
- In addition, who will be responsible for maintaining the landfill cap during the 30-years period of
time post landfill closure and subsequent to 30-years post landfill closure. (A necessary concern to
ensure sloughing and erosion issues that may arise post landfill closeout are addressed and do not
compromise stormwater controls.)
-Please clearly indicate in your stormwater plan the flow pathway(s) and respective outlet locations of
the stormwater, locations of all control structures, and detail the respective location of the
jurisdictional wetlands and waters located on-site. The information you provide should also indicate
the location of all outfalls and specifically address whether the receiving feature is a forestry ditch or
wetlands etc.)
-Please provide a simple vicinity map, indicating the surface water pathway from the proposed site to
the confluence with ocean.
Thank you for your attention to these matters. Please mail your response to both the letterhead address
and to the attention of Danny Smith at Wetland/401 Unit 2321 Crabtree Blvd., Raleigh NC 27604 -2260.
A response to each of the above mentioned items, in writing is necessary in order for completion of the
review of this project and the subsequent decision by the Director with respect to the 401 Water Quality
Certification request.
Sincerely,
Vaui Raw s
Water Quality Regional Supervisor
cc: Wetlands/ 401 Unit - Danny Smith
Wetlands/401 Unit - File Copy
Division of Solid Waste - Sherri Coghill
Wilmington Regional Office, DWQ - Rick Shiver
Fayetteville Regional Office - Paul Rawls
USACE - Wilmington Regional Office: Attention Angie Pennock

December 16, 2002
HEARING OFFICER REPORT
RIEGEL RIDGE LANDFILL
Columbus County, NC
Request for 401 Water Certification
DWQ Project Number 01-1680
Hearing Officer: Paul Rawls, Fayetteville Regional Supervisor
SUAEWARY:
Riegel Ridge Landfill, LLC (in c/o William W. Dreitzler), submitted an individual
permit application to the US Army Corps of Engineers (USACOE) to impact 0.69 acres
of jurisdictional waters. The Division of Water Quality (DWQ) received a new
application in the form of a Corps of Engineers Public Notice on December 17, 2001.
The subject Riegel Ridge tract occupies 760 acres and is located along Highway 211 in
Columbus County, North Carolina. The proposed landfill footprint, located within this
tract, is 107 acres.
It was determined by the Director of the Division of Water Quality that it was in the
public interest to conduct a public hearing for the proposed project. Accordingly, the
information provided by Riegel Ridge, LLC prior to the closing date of the written
comment period and post comment period were reviewed. In addition, the DWQ
reviewed a Division of Waste Management (DWM) letter, dated July 24, 2001. This
letter addresses the North Carolina General Statute 143-215.54 prohibiting the siting of
new solid waste landfills in 100-year floodplains. Further, the oral and written comments
as a result of the public hearing process were also reviewed.
A review of public comments and information provided by Riegel Ridge, LLC
(which includes the application, supporting documentation, subsequent
amendments/additional information request responses) has been completed. Based on that
review it is the recommendation of the hearing officer that a 401 Water Quality
Certification be conditionally issued. This recommendation is based on the incorporation
of the suggested special conditions noted in the addendum to this report.
NARRATIVE / GENERAL OVERVIEW
Riegel Ridge Landfill, LLC has submitted an individual permit application to the
US Army Corps of Engineers (USACOE) to impact 0.69 acres of jurisdictional waters.
On December 17, 2001 the 401/Wetlands Unit received an application for the Riegel
Ridge Landfill in the form of an amended Corps of Engineers Public Notice.
The subject Riegel Ridge tract occupies 760 acres and is located along Highway
211 in Columbus County, North Carolina. The proposed landfill footprint, located
within this tract, is 107 acres. The waters to be impacted by the landfill are old forestry
ditches that predate the Clean Water Act, as determined by the USACOE. The proposed
landfill is located approximately 6.1 air miles from the southeastern edge of Lake
Waccamaw State Park, approximately 20 miles from the coastal edge of Ocean Isle
Beach and is immediately adjacent to the open water systems within Honey Island
Swamp. The siting location of the proposed landfill is within the area known as the
Green Swamp as indicated in the "Flood Study to Determine 100-year Flood Plain Limits
for Riegel Ridge MSW Landfill" dated December 20, 2001. The active life of this
landfill is proposed to be 25 to 30 years.
The subject tract consists of a mosaic of upland soils and forestry ditches. As a
part of this project, the land beyond the 107-acre landfill footprint is proposed to include
seven (7) borrow pit areas. These borrow pits will approximately total 216-acres by the
end of the active life of the landfill. The borrow pits will provide the necessary material
(soil) to separate the base waste elevation of the landfill by a minimum of 4-feet from
groundwater and supply other materials (soil) necessary for landfill operation.
It is understood that the Division of Waste Management (DWM) Rules will
require the geomembrane portion of the landfill liner system to be located a minimum of
4-feet above seasonal high groundwater elevations. It should be noted that groundwater
issues were a major concern of the public and DWQ staff. Based on comments from the
DWM indicating that protection of the groundwater will be provided for in the design and
permitting of the landfill, it is the opinion of the writer that DWM should ensure that
appropriate safeguards are installed to ensure protection of groundwater. Groundwater
monitoring is typically required during both the active portion and 30 years post landfill
closure by the DWM's permit.
The waste base elevation of the proposed landfill is approximately 55 feet above
sea level. The built-out top elevation of the completed landfill is approximately 305 feet
above mean sea level. Accordingly, the landfill height will be approximately 250 feet.
PROJECT REVIEW:
On December 17, 2001 the NC Division of Water Quality (DWQ) received an
application, in the form of a US Army Corps of Engineers Public Notice for a 401 Water
Quality Certification Request for the proposed Riegel Ridge Landfill in Columbus
County. On January 9, 2002 this project was placed on hold and additional information
was requested.
On February 11, 2002, the DWQ notified Riegel Ridge, LLC of the determination
that it was in the public interest to conduct a public hearing. This hearing allowed DWQ
to review public comment and to consider additional information provided as a result of
the hearing process. A notice of the public hearing was published once in each the
Fayetteville Observer (Fayetteville), Wilmington Star News (Wilmington), and the News
Reporter (Whiteville). The hearing was held on April 18, 2002, at 7:00 p.m. in the
Whiteville High School Auditorium. The hearing lasted approximately 3.5 hours and
was well attended. Approximately 225 people attended the.hearing; approximately 60
spoke during the hearing and 97 requested a copy of the decision. The public comment
period, continued for 30 days after the hearing date. Prior to and during the comment
period DWQ received approximately 540 written correspondences. The hearing was well
attended and many thoughtful written comments regarding subject project were received.
Subsequent to the hearing closing date, Riegel Ridge, LLC provided DWQ
information beyond that included in the initial application (received on May 20, 2002).
On June 10, 2002, DWQ provided a formal additional information request to Riegel
Ridge, LLC. This letter was based on the review of the application, comments from the
public hearing, and the information received by DWQ as of the close of the public
comment period. On July 22, 2002 DWQ received a response to the June 10, 2002
information request. On July 24, 2002, the DWQ received a letter from the Division of
Waste Management explaining how the siting of landfills within 100-year floodplains
was prohibited pursuant to NCGS 143-215.54. The respective continued review of the
above-mentioned information provided to DWQ resulted in a second additional
information request letter dated September 20, 2002, and a response was received by
DWQ on November 1, 2002.
RECOMMENDATION:
The information provided for this project allowed, a review as required in 15A NCAC
2H.0500. Specifically, six (6) items were considered: practical alternative, minimization
of adverse impacts, no degradation to surface waters and groundwaters, no cumulative
impacts, protect downstream water quality, and mitigation.
Accordingly, DWQ determined that the US Army Corps of Engineers will complete
an alternatives analysis for Riegel Ridge project (as explained to DWQ in an October 17,
2002 letter from US Army Corps Engineers). Since the DWQ can not duplicate this
review, as per 15A NCAC 2H.506(i), no alternatives review has been conducted by
DWQ for this project. With respect to the minimization of adverse impacts to surface
waters, no degradation of groundwaters or surface waters, no cumulative impacts, and the
protection of downstream water quality standards (pursuant to 15A NCAC 2H.0506), it
will be necessary to address these issues through certification conditions. Finally,
because impacts are less than one (1) acre no mitigation will be required for the impacts.
However, the US Army Corps of Engineers may require mitigation as 'a part of their
review.
The information provided by Riegel Ridge, LLC has been reviewed. In addition, the
Division of Water Quality (DWQ) reviewed a letter from the Division of. Waste
Management (DWM), dated July 24, 2002. This letter addresses the North Carolina
General Statute 143-215.54 prohibiting the siting of new solid waste landfills in 100-year
floodplains. Further, the oral and written comments as a result of the public hearing
process were also reviewed, as well as the information provided within the response from
Riegel Ridge, LLC to the additional information requests.

Considering oral and written comments received as part of the public hearing and
after reviewing information provided by the applicant, it is recommend that the DWQ
proceed with issuance of the 401 Water Quality Certification incorporating the special
conditions contained in the addendum to this report.
HEARING OFFICER'S REPORT ADDENDUM
RECOMMENDED SPECIAL CONDITONS
Riegel Ridge, LLC
Columbus County, NC
Considering oral and written comments received as part of the public hearing and.
after reviewing information provided by the applicant, it is recommend that the DWQ
proceed with issuance of the 401 Water Quality Certification incorporating the special
conditions contained in this addendum to the Hearing Officer's Report.
1) Turbidity
• At no time shall the discharge(s) from this site cause violations of stream standards.
• Construction must be conducted in phases according to the erosion and sediment
control plans approved by the Division of Land resources and/or the Division of
Waste Management. Sedimentation and Erosion Control measures for each phase
shall be in place before construction can begin in the next phase (including the
perimeter berm).
• Sufficient materials required for stabilization and/or repair of erosion control
measures and stormwater routing and treatment shall be on site at all times.
• Access will be granted to DENR staff for sampling, inspection or other purposes as
deemed necessary by DENR upon request.
• Beyond what is specifically authorized as a part of the 0.69 acres of impact
authorized in this Certification, fill may not be located in wetlands or waters;
2) Surface Water Monitoring
• Monitoring of surface water parameters of the receiving waters is required as a
condition of this Certification. If surface water monitoring reveals indications of
degradation or reveals that there has been loss of intended usage as determined by
either Riegel Ridge, LLC or the Division of Water Quality a Corrective Action Plan
(CAP) must be developed and submitted to DWQ within 60 days of the
determination. Upon first discovering that waters and/or wetlands have indications of
degradation or loss of intended use Riegel Ridge, LLC shall notify the DWQ
Wilmington Regional Office. This notification shall be within 24hrs of first
knowledge or the first business day thereafter and shall include a detailed explanation
of the nature of the problem. Also, Riegel Ridge, LLC shall provide follow-up
notification, in writing, within 5 business days of first knowledge of the problem. It
should be noted that notification of the conditions noted above is not considered the
submission of the CAP. Should Riegel Ridge, LLC, fail to provide a CAP within 60
days or fail to initiate corrective actions in a timely manner acceptance of waste by
this facility will be suspended. Suspension of the landfill receiving waste will be
effective upon receipt of notification by DWQ. Suspension of the landfill receiving
waste shall last until such time as a CAP has been provided to and approved by
DWQ.
-Prior to start of construction, a "surface water monitoring plan" must be provided to
the Division of Water Quality and Riegel Ridge, LLC must receive written approval
for the plan by DWQ.
-It will be required that monitoring station locations be developed for every discharge
outfall located on the site.
-Two additional sample/monitoring station locations must be developed as well
(upstream and downstream from the confluence of all of the surface waters on site).
Sampling from each of the stations must at a minimum include the following:
-COD (frequency monthly)
-Fecal Coliform (frequency monthly)
-Grease and Oil (frequency monthly)
-Turbidity (frequency monthly)
-Dissolved Oxygen (frequency monthly)
-Annual Pollutant Analysis Monitoring -APAM (frequency annual)
(attached)
Sampling from receiving waters up slope from Tram Road must at a minimum
include the following:
-width and depth ratio accounts (sampling frequency - annual);
-depth of natural sediment/organic matter accumulation(sampling frequency -
quarterly);
-depth of aggraded sediment from construction activities, and presence of
debris/trash within and adjacent to the receiving feature (sampling frequency -
quarterly);
concurrent digital photograph, taken during the monitoring effort, must
accompany monitoring data collection and be submitted with the respective
monitoring results.
All tests (where applicable) must be performed by DENR certified laboratory.
It a requirement of this Certification that this facility apply for and secure an NPDES
Permit to Discharge Stormwater as required for Landfills that are permitted by the
North Carolina Division of Solid Waste Management prior to initiation of
construction.
• It is a requirement of this Certification that in addition to the above-mentioned
sampling, this facility maintain full compliance with all of the NPDES Permits
condition required for this facility.
• All samples collected from monitoring required above must be reported as a part of
this Certification and included in any NPDES monitoring reports.
3) Wetland Monitoring
•
Monitoring of wetlands is required as a condition of this Certification. If wetlands
impacts are determined to have occurred, if the wetlands develop indications of
instability which include eroding, sloughing, or the removal of the hydrology, as
determined by Riegel Ridge, LLC or the Division of Water Quality then a Corrective
Action Plan must be developed within 60 days of the determination. If wetlands have
been impacted Riegel Ridge, LLC shall notify the DWQ Wilmington Regional Office
in writing. This notification shall be within 24 hrs of first knowledge or the first
business day thereafter and shall include a detailed explanation of the nature of the
problem.
• If wetlands are determined to be impacted, beyond impacts that are authorized by this
Certification, restoration or mitigation as. described in 15A NCAC 2H .0506 is
required and the continued excavation/mining of on site borrow materials will be
suspended until DWQ approves an onsite restoration or mitigation plan.
• Prior to start of construction, a "wetland monitoring plan" must be provided to the
Division of Water Quality and Riegel Ridge, LLC must receive written approval for
the plan by DWQ. The monitoring plan must satisfactorily address how it will be
determined whether wetlands draining will occur.
The wetland monitoring plan submitted on November 1, 2002, must be revised to
additionally include the following:
-Physical Monitoring for eroding or sloughing of the wetland (monitoring frequency-
annual)
-A schedule and account of when the ditches that currently bisect proposed borrow
sites will be plugged (e.g. within 90 days).
-Within the monitoring plan, the above-mentioned plugs must also be inspected to
insure they are stable and not failing. This review must be included within the annual
wetland monitoring report.
-Wells as depicted in the November 1, 2002 monitoring plan proposal must be
installed and properly maintained throughout the active life of the landfill.
-A requirement of the monitoring plan includes that annually, well data (collected
daily) must be provided annually to DWQ along with a written account of the
hydrological status of the wetlands on the tract. This includes each wetland polygons
(and all wells) as indicated on the November 1, 2002 monitoring plan.
4) Avian Monitoring
• Avian monitoring is required as a condition of this Certification and must be
approved by DWQ prior to impacts to any wetlands or waters.
-The plan must describe the monitoring station locations.
As a part of the plan, if the "avian" monitoring indicates water quality standard
violations with respect to vector/avian species problems additional monitoring or
action plans, with an implementation schedule, may be required by the DWQ.
• An annual report must be submitted to the DWQ, Wilmington Regional Office of the
results of the monitoring efforts for each year by June 1. This report should include,
the past years monitoring efforts and a list of all complaints received by the Riegel
Ridge, LLC regarding avian or other vector concerns by the public.
5) Groundwater Monitoring
It is understood that the DWM will require groundwater monitoring at the
proposed facility if permitted. It is recommended that DWQ work with DWM to
ensure that the following. conditions are either contained in the DWQ Water Quality
Certification or the DWM permit for this site.
Monitoring of groundwater is required as a condition of this Certification.
Groundwater monitoring results that indicate a statistically significant increase to
background conditions or a 15A NCAC 2L groundwater standard violation, will
require a remedial action plan development within 60 days of the determination and
this plan must be submitted to the Wilmington Regional Office of the DWQ.
• If a statistically significant increase over background has been detected for one or
more of the constituents listed in Appendix I of 40 CFR Part258 or if a 15A NCAC
2L groundwater standard violation is determined, the continued acceptance of waste
by this facility may be suspended and all landfill cells required to be capped if Riegel
Ridge, LLC fails to address the issues as required by the Division of Waste
Management. The suspension of waste acceptance will continue at this facility until
such time as the completion of Assessment Monitoring (which requires monitoring
and testing for all constituents identified in Appendix II of 40 CFR Part 258), a
respective satisfactory restoration plan is provided and approved by the Division of
Waste Management, and a satisfactory restoration plan is implemented or as required
by the Division of Waste Management.
All sample data collected from groundwater from any onsite monitoring wells are
required to be reported to the Division of Water Quality Wilmington Regional Office
within 30 days of receipt. If a statistically significant increase over background is
detected for one or more of the constituents listed in Appendix I of 40 CFR Part 258
or if a 15A NCAC 2L groundwater standard violation is determined written
notification to DWQ of must be reported in writing to DWQ.
• The ground water monitoring will continue in perpetuity at this facility unless Riegel
Ridge, LLC requests in writing and secures written authorization from NCDENR for
a reduction in monitoring as required within this Certification. However, a reduction
in monitoring request may only occur after a minimum 30-years post closure of the
landfill (30 years beyond last date"that waste is received at the landfill).
• If these conditions are included or are more stringent in the DWM landfill permit, the
reporting-to DWM shall be sufficient for the reporting requirements of this
Certification.
6) Stormwater
• An approved stormwater plan and Operation and Maintenance agreement for the
stormwater controls is required as a condition of this Certification. This plan and
respective agreement must be returned to the DWQ Central Office prior to initiation
of construction. No impacts to wetlands or waters may occur until that plan receives
written approval from DWQ.
• Subsequent to the review of the Riegel Ridge Stormwater Management Plans
submitted on November 1, 2002, it is required that Riegel Ridge, LLC resubmit plans
that address the following items:
- The plans must clearly depict how stormwater will be routed and treated from all
areas of the project to include but not necessarily limited to the entrance roads,
scale house and office areas, maintenance area, and the perimeter ditch.
Stormwater from these areas is required to, at a minimum, be treated to an 85%
TSS reduction. If onsite stormwater treatment and control measures do not protect
water quality standards Riegel Ridge, LLC shall submit within 60 days of first
knowledge of impacts to surface waters a CAP to address this issue. The plan and
associated control measures must be implement within 30 days of approval by
DWQ.
- Recycle areas or staging areas for public or single family household use is not
indicated in the plans. If in future these facilities are determined to be necessary
by Riegel Ridge, LLC written notification to. the DWQ, along with stormwater
management proposal must be submitted to the DWQ for review and written
approval prior to construction of these facilities.
- It is required that the plans be modified such that minimally, all side slopes of
stormwater control structures, ditches, or road shoulders are minimally 3:1.
From initiation of construction and through a minimum period of 30 years, post
landfill closure, monitoring of the stability and maintenance of control structures will
be required at a monthly frequency and after every 10-year or greater precipitation
event. The monitoring information must be described in a monthly report and this
information. must be mailed to DWQ annually, by June 1 of each year and made
available upon DENR staff request at anytime throughout the year.
• Any monitoring results that indicate failures of or need for maintenance or prepares
stormwater structures must receive repairs immediately. An account of problems,
maintenance, and of the repairs must be completed and submitted to the Wilmington
Regional Office of the DWQ within 30 days of the determination.
• The stormwater monitoring will continue in perpetuity at this facility unless Riegel
Ridge, LLC requests in writing and secures written authorization from NCDENR for
a reduction in monitoring as required within this Certification.
7) Access, Notification and impact constraints.
• Access to DENR staff for inspections and sampling must be provided upon request;
• Beyond what is specifically authorized as a part of the 0.69 acres of impact
authorized in this Certification waste, fill, or sediment may not be located in wetlands
or waters;
• Borrow/mining sites shall not be located in streams or wetlands.
• Borrow/mining sites shall not cause impacts to surface waters or wetlands.
• The Wilmington Regional Office of DWQ must be notified by telephone within 24
hours and in writing (within 5 days) of a Riegel Ride, LLC determination that
monitoring results indicate a significant increase over background conditions or a
15A NCAC 2L groundwater standard violation.
• The Wilmington Regional Office of DWQ must be notified by telephone within 24
hours and in writing of a Riegel Ridge, LLC determination of a structure failure
which includes berms, cap, liner, stormwater control structures, leachate storage
facilities and sedimentation and erosion control devices.
• Violations of any conditions herein set forth may result in the revocation of this
Certification and if appropriate result in criminal and/or civil penalties.
8) Floodplain
• Prior to initiation of construction of the Landfill facilities, Riegel Ridge; LLC
must be in full compliance with North Carolina Genera Statute 143-215.54.
Specifically, until such time as Riegel Ridge, LLC has secured the respective
variance, meeting the North Carolina General Statute prohibition of siting a
landfill within the 100-year floodplain (pursuant to 143-215.54) activities
associated with this Certification may not proceed.
F W A T?
?O G
r
o ?
NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
1617 Mail Service Center
Raleigh, NC 27699-1617
Fax: 919-733-; 496- °I to i
Phone: [phone]
TELECOPY TO:
FAX NUMBER:
FROM:
PHONE: # OF ;AGES INCLUDING THIS SHEET: COMMENTS:

FEB.13.2003
-i
J?U
4
9:51AM , NCDENR WIRO
Certified Mail
Return Receipt Requested
NO. 626 P.2
Michael R Easley, Uovetnor
William G. Ross Jr., Secretary
North Carolipa Depar;rncnt of Environmept and Naioral Resources
Alan W. Klimek, P.E., Director
Division of Water Quality

Riegel Ridge, LLC
C/o William W. Dreitzler
211 East Six Forks Road, Sui ?e 203
Raleigh, NC 27609 - ."
Re: Riegel Ridge Landfill, C lumbus County, North Carolina
DWQ Project No, 01168 ; US Army Corps of Engineers ID No. 200100853
Dear Mr. Dreitzler. s
Attached hereto is a copy of Irtification No. 3406 issued to Riegel Ridge, LLC in c/o William W. Dreitzler
dated December 16, 2002. If we can be of further assistance, do not hesitate_to contact us.
. t
i Sincerely,
Alan W. Klimek, RE., Director
Division of Water Quality
Attachments
D WQ 01 1680
cc: -U.S. Army Corps of Erigi jeers, Wilmington Regulatory Field Office
DWQ, Fayetteville Region il Office - Paul Rawls
DWQ, Wilmington Regional Office - Noelle Lutheran
DWQ, Wetlands/401 Lint i Danny Smith .
MR, Wilmington Region Office - Dau. Sams
File Copy
Central files
Division of Solid Waste- S erri Coghyll
Crime Control and Public! 1 afety
Interested Citizens from lic Dearing
.- Wit.
V. c, Division of Water Qoalily, 401 Wetlands C fcadou Unit,
1650 Mail Service Center, Raleigh, NC 27599-1550' (Mailing Address)
?321 Crmbtrea Blvd., Rmleigh, NC 27604-2760 film)
419) 733.1786 (phone), 919-733-6893 (U), (bttp:IhZo,enr,omtc.no.uslncwedands
FEB.13.2003 9:52AM NCDENR WIRO N0.626 P.3
.
This Certification is issued in conformity with the requirements of Section 491 Public
Laws 92-500 and 95-21V of the United States and subject to the North Carolina Division
of Water Quality (DWQ Regulations in 15A NCAC 2H, Section .0500 to Riegel Ridge,
LLC (in c/o Willi= W. Dreitzler), resulting in the discharge of fill into 0,69 acres of
jurisdictional wetlands d waters associated with the construction of a 107 acre
municipal solid waste la dfill in Columbus County, North Carolina, pursuant to an
amended applicatiov in he form of the Corps Public Notice received on the 17th day of
December, 2001. The a placation and subsequent amendments to the application on May
23, 2002, July 22, 2002, October 22, 2002 and November 1, 2002 which include
stonnwater management, avian management, wetland monitoring and groundwater
monitoring plan propos ls.
The application proldes adequate assurance that the proposed work will not result in
a violation of applicable Water Quality Standards and discharge guidelines. Therefore
the State of North Carolina certifies that this activity will not violate the applicable
portions of Section 301, 302, 303, 306, 307 of PL 92-500 and PL 95-217 if conducted in
accordance with the application and conditions hereinafter set forth.
This approval is onl valid for the purposes and design that you submitted (and
modified) in your amen ed application in the form of the Corps of Engineer's Public
Notice received on the 17th day of December, 2001 and amended on May 23, 2002, July
22, 2002, October 22, 2002, November 1, 2002 and as conditioned below. If you change
your project, you must notify the Central Office of Division of Water Quality in writing
and may be required send the Central Office of the Division of Water Quality an
application for a new c 'fication. If Riegel Ridge, LLC is sold or if the name of the
LLC is changed, or the rgperty is sold, you must notify the Central Office and the
Wilmington Regional eld Office of the Division of Water Quality in writing, and the
new owner of the LLC dl or property must be given a copy of the Certification,
approval letter, all necessary supplementary information detailed in the application and
subsequent amendmentp, and is thereby responsible for complying with all conditions of
this Certificatimmitigatiq? Sh d wetlands fill be requested in the future, additional ?? --=- --
compensatory may be required as described in 15A NCAC 2H.0506 (h)(6)
and (7). For this appro? al to be valid, you trust follow the conditions listed below. In
addition, you should get any other federal, state or local permits before you go ahead with
your project including ut not limited to) Solid Waste, Erosion and Sediment Control
Permit, Floodplain Lan I11 Siting Variance (pursuant to NCGS 143-215,54) Coastal
Stormwater Permit, an Non-discharge Permit.
Conditions of Cerd ication:
1. During the ' of construction and duration of the time the facflrty receives
waste, approp mate sediment and erosion control practices is order to assure
compliance with the appropriate ureter quality standards must: be
implemented:
FEB.13.2003 9:52AM y NCDENR WIRO NO.626 F.4
3
A) At no time shall ?the discharge(s) from this site cause violations of surface water
standards.
B) Appropriate se Iment and erosion control practices which equal or exceed
those outlined iq the most recent version of two mapuals, either the "North
Carolina Sedim " nt and Erosion Control Planning and Design Manual" or the
forth CarolinarSurface Mining Manual" (available from the Division of
Land resources in the DRHNR regional or Central Offices). The control
practices shall b? utilized to prevent exceedances of the appropriate turbidity
water quality stodard (50 N''!'Crs in all fresh water streams and rivers not
designated as trdut waters; 25 NTUs in all lakes and reservoirs, and all
saltwater classed; and 10 NTUs in trout waters);
C) Sufficient materials required for stabilization and/or repair of erosion control
measures and str rmWater routing and treatment shall be on site at all times.
TT. Monitoring of s ace water parameters of the receiving waters is required as a
condition of this Certification. If surface water monitoring reveals water duality of
degradation or reveals that there has been loss of intended usage as determined by
either Riegel Ridge, LLC or the Division of Water Quality, then a Corrective
Action Plan (CAS'} must be developed and submitted to DWQ within 60 days of
the deterninatio . Upon first discovering that waters and/or wetlands have water
quality degrade on or loss of intended uses, Riegel Ridge, 1-LC shall notify the
DWQ Wilmingt n Regional Office. This notification shall be within 24 hrs of
first knowledge fir the first business day thereafter and shaA include a detailed
explanation of the nature of the problem, Also, Riegel Ridge, I.I.C shall provide
follow-up notif 'ation, in writing, within 5 business days of the first knowledge of
the problem.
A. Prior to start of construction, a "surface water monitoring plan' must be
provided to a Division of Water Quality. Riegel Ridge, LLC must receive ;
written apprgval for the plan by DWQ before any wetlands or waters are
impacted i
a) Sample/ monitoring station locations must be developed for every
discharg outfall located on the site, The first station must be down slope
from the?WWI. The second station must be approximately halfway
between the outfall. and its confluence with Honey Island Swamp. These
sample locations must be depicted within the final monitoring plan.
b) SannplQ from each of station must minimally include pre-construction
data collel'cted for a minimum period of six months prior to the begin of
construction.
c) SamplinJ from each monitoring station must at a minimum include the
following:
FEB.13.2003 9:52AM ` NCDENR WIRO N0.6?6
-COD (fr¢quenGy monthly)
-Fecal C ? iform (frequency monthl y)
Grease and Oil (frequency month] y)
-Turbiditj (frequency monthly)
-Dissolved Oxygen (frequency monthly)
-Conductivity (frequency monthly)
-Annual Pollutant Analysis Monitoring APAM (frequency annual-
outfall to ations only see attached)
d) Samplinjfrom receiving 'Waters up slope from Tram Road, must at a
minimu ' include the following:
-width an depth ratio (sampling: frequency ^ annual);
-depth of stural sedimentlorganic matter accumulation(sampling
frequenc ^ quarterly);
-depth ofia.ggraded sediment from construction activities, and presence of
debris/ h within and adjacent to the receiving feature (sampling
frequenc -quarterly);
conc nt digital photographs must accompany monitoring data
collecto and be submitted with the respective monitoring results.
-All testsl(where applicable) must be performed by DENR certified
laboratories,
e. It is a re ' 'rement of this Certification that this facility apply for and
secure NPDES Permit to Discharge Stormwater as required for
Imdfllls that are permitted by the North Carolina Division of Solid Waste
Management prior to initiation of construction.
r.5
f. It is a requirement of this Certification that in addition to the above-
mentionO sampling, this facility must maintain full compliance with all of
the NPDPS Permit conditions required for this facility.
g, All samples collected from the monitoring required above, must be
reported 0 a part of this Certification and included in any NPDES
monitoring reports. -.:
h. A condiP on of this Certification is that leachate must be properly
coIleeW and contained. Also, all of the proper permits must be secured
and compliance with all permits must be maintained with respect to the
disposalI and transport of leachate.
r
III) Monitoring of wetlands is required as a. condition of this Certification, If wetland
impacts are determined to have occurred, which can include indications of
instability, erodi g, sloughing, or removal of the hydrology, as determined by
Riegel Ridge, L C or the Division of Water Quality, then a Corrective Action
Plan must be de eloped within Gb days of the determination, If wetlands have
been impacted, Riegel Ridge, LLC shall notify the DWQ Wilmington Regional
4
FEB.13.2003 9:52AM NCDENR WIRO N0.626 P.6
5
Office. This no fication shall be within 24 hrs of first lmowledge or the first
business day thereafter and shall include a detailed explanation of the nature of
ae, problem.
A. If wetlands ate determined to be impacted (beyond impacts that are authorized
by this Certilf caOon) mitigation as described in 15A NCAC 2I-1.0506 is
required and the continued excavatiquhnining of on site borrow materials will
be suspended until DWQ approves an on-site restoration or mitigation plan.
$. Prior to start of construction, a "wetland monitoring plan" must be provided to
the Division f Water Quality and Riegel Ridge, LLC must receive written
approval for he plan by DWQ. The monitoring plan must satisfactorily
address how It will be determined whether wetlands draining will occur.
Wetland or Water impact may not occur until Riegel Ridge, LLC receives
written approval- from DWQ for this plan.
a. The wetland monitoring plan submitted on November 1, 2002, mast be
revised t4 additionally include the following:
PhysicallMonitoring for eroding or sloughing of the wetland (monitoring
frequency- annual)
-A. schedule and account of when the ditches that currently bisect
proposed borrow sites will be plugged (e.g. within 90 days).
-Within a monitoring plan, the above-mentioned plugs must also be
inspec to ensure they are stable and not failing. This review must be
included within the annual wetland monitoring report,
-Wells a depicted in the November 1, 2002 monitoring plan proposal
must be i stalled and properly maintained throughout the active life of the
landfill.
-A requi ment of the monitoring plan includes that well data. must be
provided r wally to DWI along with a written account of the
hydrological status of the wetlands on the tract. This includes each
wetland polygops (and all wells) as indicated on the November 1, 2002-
monitoring plan. --
b. The initi0ion of data collection (including rainfall data) must begin within
90 days c? issuance of this Certification or the issuance of the 404 PenTAt,
which is )later.
c. Rain gags and data collection from rain gages trust be properly
maintained and monitoring/data recording must occur at the frequency
required n the approved plan,
d. Wetland 1Vlonitoring reports must be submitted annually to both the
Central C"iffice of the Division of Water Quality and the Wilmington
Regional Office of DWQ, by June 1 of each year.
FEB.13.2003 9:53AM NCDENR WIRD N0.626
I
IV. Avian Monitoring
A) Avian moni ring is required as a condition of this Certification and must be
approved b DWQ prior to impacts to any wetlands or waters.
a. The plan' must describe the monitoring station locations.
b. As a p of the plan, if the "avian" monitoring indicates water quality
standard violations with respect to vectortavian species problems then
addition monitoring or action plans with an implementation schedule,
may be uired by the 17WQ,
c. An annu report must be submitted to the DWQ, Wilmington Regional
Office o the results of the monitoring efforts for each year by tune 1.
This rep rt should include, the past years monitoring efforts and a list of
all corn amts received by the Riegel Ridge, L LC regarding avian or other
vector c ncerns by the public.
V) Groundwater Motoring
A) During the tinie of construction and duration of the time the facility receives
waste plus at least, thirty (30) years beyond closure, the following
groundwater monitoring its required to assure compliance with the
appropriate wRier quality standards.
a) Monitoring f groundwater is required as a condition of this Certification.
Crroundwa monitoring results that indicate a statistically significant increase
from back and conditions or a 15A NCAC 2L groundwater standard
violation, wi 1 require a remedial action plan development within 60 days of
the determin lion and this plan must be submitted to the "Wilmington Regional
Office of the DWQ.
b) If a statistic ly significant increase over background has been detected for
one or more f the constituents listed in Appendix I of 40 CFR Part 258 or if a
15A NCAC gmundwatpr standard violation is determined, then the ...,.. . .
Continued ac-eptance of waste by this facility shall be suspended and all
landfill cells must be capped if Riegel Midge, LLC fails to address the issue as
required by tie Division of Waste Management. The suspension of the
acceptance waste will continue at this facility until such time as the
completion f Assessment Monitoring (which requires monitoring and testing
for all constituents identified in. Appendix II of 40 CFR. Part 258), a respective
satisfactory storation plan is provided and approved by DWM, ands.
satisfactory restoration plan is implemented or as required for by the Division
of Waste M Tagement.
c) All sample dAta collected from groundwater from any onstte monitoring wells
are required o be reported to the Division of Water Quality Wilmington
N
P.7
FF-B.13.2003 9:53AM NCDENR WIRO N0.626
7
Regional Of 'ce within 30 days of receipt. If a statistically significant
increase ovebackground is detected for one or more of the constituents listed
in Appendix j of 40 CFR Part 258 or if a 15A NCAC 2L groundwater
standard violation is determined, then written notification to DWQ must be
reported in nting to DWQ.
d) The ground , Ater monitoring will continue in perpetuity at this facility unless
Riegel Ridg LLC requests in writing and secures written authorization from
NCDENR fo a reduction in monitoring as required within this Certification.
e) If these ab4 conditions are included or are more stringent in the DyVM
landfill pernvt, the reporting to DWM shall be sufficient for the reporting
requirement, of this Certification.
f) Minimum m d itoring frequency for all monitoring wells installed on site is
once per yea As a condition of this Certification, R,iegol Ridge, LLC must
submit to th6 Wilmington Regional Office of the DWQ a written account of
the results and analysis, These monitoring results must be submitted to DWQ
and must include background data and analysis of compliance with the
conditions s t forth in this Certification by June I of each calendar year,
1) Mo ? oring requirements include all wells approved for monitoring by
the Division of Solid waste,
2) All s pies and sample results collected from groundwater monitoring
wellare required to be reported (regardless of the frequency of
sampAes) as a part of this Certification and included in any monitoring
reports. _
VD The following monitoring and respective action plans are required to assure
compliance with the appropriate water quality standards: -- -
A.) An approved stoPwater plan and Operation and Maintenance agreement for the
stormwater man4gement controls is required as a condition of this Certification.
This plan and pectiye agreement must be returned to the DWQ Central Office
prior to initiatio of construction. No impacts to wetlands or waters may occur
until that plan Ives written approval from D'WQ.
S) Subsequent to a review of the Riegel Ridge Stormwater Management flans
submitted on N vember 1, 2002, Riegel Ridge, LLC must resubmit plans that
address the following items:
a) The plats must clearly depict how stormwater will be treated from the
entrance p? roads, scale house and office areas, maintenance area, and the
P.8
FEB.13.2003 9:53AM f NCDENR WIRO
NO. 626 P.9
perimet ditch associated with the respective Construction and
Demoliton facility. These areas are required to be designed to achieve an
85% TS reduction.
b) Recycle eas or staging areas for public or single family household use is
not indicated in the plans. If in future these facilities are determined to be
necessary by Riegel Ridge, LLC, then written notification to the DWQ,
along With a stormwamr management proposal must be submitted to the
DWQ fo review and written approval prior to cons=tion of these
facilities
c) Plans m %t be modified such that minimally, all side slopes to control
stormw' structures, ditches, or road shoulders are minimally 3;1.
d) If onsite stormwater treatment and control measures do not protect water
quality s andards Riegel Ridge, LLC shall submit within 60 days of first
knowledge of impacts to surface waters a CAP to address lids issue. The
plan and associated control measures must be implemented within 30 days
of -writte approval for DWQ,
e) From in' "ation of construction and through ainimum period of 30 years,
post lan fill cell closure, monitoring of the stability and maintenance of
control structures will be required at a monthly frequency and after every
10-year Or greater precipitation event. The monitoring information must
be desc bed in a monthly report and this information must be mailed to
DWQ riually, by June 1 of each year and made available upon DENR
staff req est at anytime throughout the year.
f) A rain g ge station must be maintained, daily information recorded, and
the resp dive results provided along with the monitoring results.
Post clo pure monitoring reports must include a monthly determination that
all cone ntated runoff is treated to meet the specifications listed in
NWCorlditi .?? number I of this Certification.,
?Monitorin of stormwater and respective site maintenance will continue in
perpetuity at this facility unless Riegel Ridge, LLiC requests in writing and
secures written authorization from NCDENR for a reduction in monitoring
as required within this Certification.
VII) The following conditions are required to assure compliance with the
appropriate w Ater quality standards:
A) Access to D Q staff for inspections and sampling must be provided to upon
DWQ requ t.
FEB.13.2003 9:53AM ? NCDENR WIRO
N0.626 P.10
9
B) Beyond wham is specifically authorized as a part of the 0,69 acres of impact
authorized in this Certification, waste, fill, or sediment may not be located in
wetlands or v aters.
C) All sediment and erosion control measures placed in wetlands and waters shall
be removed 4nd the original grade restored within twenty-one days after the
Division of Land Resources releases the project.
D) Live or fresh concrete may not come in contact with waters of the state until
the concrete as hardened.
E) The Wilming on Regional Office of DWQ must be notified by telephone
within 24 hours and in writing (within 5 days) of a Riegel Ridge, LLC
determinatiot that monitoring results indicate a significant increase over
background onditions or a 15A NCAC 2L groundwater standard violation.
F) ')('he Wilmin?ton Regional Office of DWQ must be notified by telephone
within 24 ho s and in writing of a Riegel Ridge, LLC determination of a
structural fai ure which includes berms, cap, liner, stormwater control
structures, le hate storage facilities and sedimentation and erosion control
devices. Th Wilmington Regional Office of DO Q must be notified in
writing with two weeks prior to initiation of construction.
G) The enclose t? "Certification of CoMpletYOn Form" is to be used to notify DWQ
when all w included in the 401 Certification has been completed.
VM Prior to initiati?n of Constmetion of the Landfill facilities, Riegel Ridge, LLC
must: be in fall compliance with North Carolina Genera Statute 143-215.54.
Specifically, until such time as Riegel Ridge, LLC has secured the respective
variance, meetf ttg the North Carolina ? to 143 215.54) impacts siting a
landfill within ?he 100-year floodplai (pursuant
associated with this Certification may not proceed.
The conditions of this Certification notwithstanding, Riegel Midge, LLC or its
successor is required to ponduct its activities in a manner consistent with water quality
standards and classifications as well as all applicable state and federal laws. If water
quality standards and cl ssifications are not met or if state and/or federal laws are
violated, the Division y reevaluate this Certification. This reevaluation may result in
modifications to the Cetti,fication to include conditions appropriate to ensure compliance
with-water quality stan ds and classifications as well as state and federal law in
accordance with 15A N .AC 2H.0507 (d). Before modifying this Certification, the
Division shall notify Ri gel Ridge, LLC or its successor and the US Army Corps of
Engineers, provide noti in accordance with 15A NCAC 2K ,0503, and provide
opportunity for a public' hearing in accordance with 15A NCAC 21;1.0504. Any new or
revised conditions shall be provided to Riegel Midge, LLC or its successor in writing.
FEB.13.2003 9:53AM j NCDENR WIRO
NO. 626 P.11
10
Violations of any conditions herein set forth may result in revocation of this
Certification and may result in criminal and/or civil penalties. This Certification shall
expire on expiration of t e 404 Permit,
If this Certification ip unacceptable to you, you have the right to an adjudicatory
hearing upon written re uest within the sixty (60) days following the receipt of this
Certification. This requost must be in the form of a written petition conforming to
Chapter I50H of the Noj-th Caroling General Statures a-nd filed with the Office of
Administrative Hearing , 6714 Mail Service Center, Raleigh, N.C. 27699-6714. If
modifications upon are ade to an original Certification, you have right to a.djudicatory
on the modifications up n written request within sixty days following receipt of the
Certification. Unless su h demands axe made, this Certification shall be final and
binding.
This the 16th day of December 2002
DIVISION OF WAT13R QUALITY
Alan W. Klimek, RE.
WQC 0 3406
FEB.13.2003 9:53AM NCDENR WIRO
NO. 626 P.12
11
All information reported m t be based on data collected ghrough analyses conducted 4sing 40 CFR Part
136 methods. In addition, th a data must comply with QAJQC requirements of 40 C.p'RPart 136 and other
appropriate QA/QC requir eats for standard methods. for analyses not addressed by 40 CPR Part 136,
Indicate in the biank rows pr vided below any data you may have on pollutants not specifically listed in
this form. At a mininam a neat testing data must be based on at least three pollutant scans and must be
no more than four and oa- f years old.

p+aeiliLy Name ORC
Date of sampling Phone
Analytical Laboratory
i

a (as 1
Composite i
Dissolved ouygen Composite
Nitrate/Nitrite Composite
Total Yjeldahl nitrogen Composite
Total Phoaphorus I Composite
Total dissolved solids Composite
1jardness Composite
Chlorine (total residual, TRCJ Grab
Oil and grease
Antimony drab
Composite
Arsenic Composite
Beryllium composite
Cadmium Composite
Chromium + Composite
Copper Cornpoaite
Lead Composite
McrGury QQmpoai? _.. - • ---
Nickel Composite
Selenium Comfit
Silver Composite
Thallium Composite
Mae Composite
Cyanide i Grab
Total phenolio c*rapounds

Acrolein. Grab

Graf?

7

7
I1
Acrylonitrile drab 7 7
Benzene errs 1
N0.626 P.13
FEB.13.E003 9:54AM NCDENR WIRO
12
gramofonn Grab

tetrachloride
Carbon Grab
,
ChlarQcne Grab

Chlorodibromornethane + Grab

Chloroethane Grab

2-chlor3ethylvtnyl ether Grab
Chloroform Grata

Dichlorobromomethane Grab

1, ,1-dichloroethan.e Grab
1,2-dichloraethane . Grab
Trans-l,2-dichloroethylene
1-dlchloraethylenc Grab
Grab
1,2-dicYYloroprop=e Grab
1,3-dichloropropylene Grab
lbenzeme
Fth Grab
y
Y
Methyl bromide Grab
Methyl chloride Grab
Idlethylene chlorlde Cxrab
1,1,2,2-tetrachloroethane Grab
Tetra,chloruethylcn.e Grab

Toluene Grab

1,1,1-triehloroethane drab
1,1,2-trichlomethane Graf}
Trichlaroethylene Grab

Vinyl chloride
F-chlora-m-creso Grab
Grab
2-chloraphenal Grab

2,4-dichlorophenol Grab
2,4-dimethylphenol Grab
6-41nitro,o-cresol
4 Grab
,
2,4-dinitrophenol Grab
2-nitrophenol Grab
4-nitrophenol Grab
Pentachiorophernol Grab
Phenol Grab
2,4,6-ir- hlorophenol
FAenaphthene Grab
Grate
3 ? -03.13.2003 9: 54AH "
i -V?HrO
iE C;?2prOjeCt No.: -
Jr--=,z=Ct-xsm0: _
of Issuance 0f40x Way
completian 'of An w0i,,
--:- + ?t mpditcatiOUX, tbr-
tiality, 16
of Water' Q'
ira?iau
-.? applicant, the applicant
-51!:f these.
r r_r used is the observation d
M7 jig= and, latent of the 4
zr+==m, oth" supporting mateaals
k'??8#?t1LC: ?
iS'i?7{f'S (,:eltL?fLC? ,
rr a usod is the obsesvatida d
:'wimm ptjence and iutemt of the 4
R bther suppwftg materials
c?-r?aCUro'
cam' a--m project was designed bi
L=kjr3Mdecap0 Architect, $W6Y6
- Y' fun ) the eonstnti
and diligence was used .4
8diuinaal COmp ca
a Xzzd spec ficaiioiis, m»d otl" 81
iZ?nAf17Te;
. c, Dlv?elon oFlfVster GlUellty, 401 W
• V- 1 Crebtte'e ?MW. AslelDh. NIC 27q
.C#3r NM 9) 733.1788 (phape), 918-735-0
FEB. 13.2003 9:54AM NCDENR WIRO
Acenaphthylene Grab --
Anthracene Grab
Benzidine Grab
Benao(Oanthracene Grab
Benzo(a)pyrene Grab
3,4 benzofluorarsthene Grab
Benzo(ghi)perylene Grab
SenzoGofluoranthene Grab .
Bia (2-chloroethmy) meth Grab
Big (2_chlorcethyl) ether Grab
Bis (2-chloroisopropyl) ethe Grab
Bis (2-e-thylhexyl) phthalate Grab
4-bromopher?yl phenyl eth,e Grab
Butyl benzyl phthalate Grab
2-chloronaphthalene Grab
4-chloropheayl phenyl ether
Chrysene Grab
Grab
151-n-butyl phthalate Grab
Di-n-octyl phthalate
n Grab
Dlbenza(a,h)anthracene Grab
1.27dichlorabenzene C,rabb
0-dichloroberama Grail
1,4-dichlorabomene Grab
3,3-dichlorobenzichne Grab
DiedMI phthalate Grab
Dftnethyl phthalate Grab
2,4-dinitrotoluene Gmb
2,6-dinitrotoluene Grab
1,2-diphenylhydlrazWe Grab
Muoranthene Grab
Fluorene Grab
J- Iexaehlorobenzene Grab
blexachlorobutadiene Grab
Hmmehlorocyclo-pentadiene Grab
I- exubioroethane Grab
Iudenc(I,2,3-ed)pyrene Grab
IsoplYOronp Grab
Naphthalene Grab
Nitrobenzene Grab
APR-13-2006 10:44 JOYCE ENGINEERING, INC.
FAX
ENGINEERING, INC.
Henderson Building
2301 W. Meadowview Road, Ste. 203
Greensboro, North Carolina 27407
Phone - 336.323.0092
Fax - 336.323.0093
[e-mail]
Tne nannv Smith From: Van Burbach
Fax: [phone] Pages: 8 (including cover)
Phenia! [phone] Date: 04/13/06
Re: (919) 733-503, ext. 353 Email: [e-mail]
® Urgent []For Your Use I] Please Comment R Please Reply 0 Please Recycle
e Comments:
Danny-
Here are the pertinent pages from the 404 permit for the Riegel Ridge Landfill project.
Actually, our client said this was from the 404 permit, it may be from the 401 permit. To
reiterate our phone conversation, we have been asked to do the pre-construction surface water
sampling required in Section II, and we have the following questions:
1) What is the DWQ looldag for in the Surface Water Monitoring Plan? Is this a plan to do the
six months of pre-construction sampling (in which case, I assume it needs to be submitted to and
approved by the DWQ prior to doing the sampling), or is it a plan to be completed after the pre-
construction sampling to describe the plans for continuing surface water monitoring during and
after the construction phase (in which case, how does it relate to the Stormwater Management
Plan)?
2) As we understand the sampling requirements, only one sample per year will require the
APAM parameters, the other five months of pre-construction sampling need only be the water
quality parameters listed in jQ.A..c. For the APAM list, the inorganic parameters are listed as
composite samples. You said that likely meant a composite of samples over a 24-hour period.
What sampling frequency is required for the composite samples, and can you give us any
additional guidance on the sampling protocol for these samples?
Any help you can give us with this will be greatly appreciated.
Van urbach
P. 01
p:Viegel ridge, I1c\1 jei fax memo.doc
APR-13-2006 10:45 JOYCE ENGINEERING, INC. P.02
M(chad R Eiky. Governor
William G. Ross Jr., Secretary
A r. Carolina Department of l nvimu%ent and Natural Resources
r Alan W. Klimek P.E. Director
Division of Water Quality
0 ? A T T A ?--77'3 2&,& loo .8 5-3
Certified Mail
Return Receipt Requested
Riegel Ridge, LLC
C/o William W. Dreitzler
211 East Six Forks Road, Suite 203
Raleigh, NC 27609
RE?T?
Dhc04M17
K"AnAl.
WaNcimm-, 1)M V
Re: Riegel Ridge Landfill, Columbus Count), North Carolina
DWQ Project No. 011680; US Army Corps of Engineers ID N (.20(')10085)
Dear Mr. Dreitzler:
Attached hereto is a copy of Certification No. 3406 issued to Riegel Ridge, LLC in C/o William W. Dreitzler
dated December 16, 2002. If we can be of ftwher assistance, do not hesitate to contact us.
Sincerely,
Alan W. Klimek, P.E., Director
Division of 'Vier Quahty
Attachments
DWQ 01 1680
cc: U.S. Arnay Corps of Engineefs, Wilmington Regulatory Field Office
DWQ, Fayetteville Regional Office --- Paul pawls
DWQ, Wilmington Regional Office -- Noe-.le Lutheran
DWQ, Wetlands/401 Unit-Danny Smith
MR, Wilmington Regional Office - Darn ales
File Copy
Central files
Division, of Solid Waste- Sherri, Coghill
Crime Control and Public Safety
Interested Citizens from Public Hearing
N. C. Divisiou of WatwQuaHty, 401 Wedaods Cerdreatlon Unit,
2621 Mail Service Center, Raleigh, NC 27699.1650 (Mailing Address)
2321 Crabtree Blvd., Itateigh, NC z760a226p p.,oeation)
[phone] (phone), 919-733.6893 (fu), Chupy/62o.enr,stam.ae.ugaII wet Ends
rin„Trar.ravrt•v„ af,7eRa f Yvd Tf1 : M) 4111117; CIl: [ (1
APR-13-2006 10:46 JOYCE ENGINEERING, INC. P.03
. V, ,
A) At no time shall the discharg (,•) from this site cause violations of surface water
standards.
13) Appropriate sediment and erosion control practices which equal or exceed
those outlined in the most recent version of two manuals, either the "North
Carolina Sediment and Erosion Control Planning and Design Manual" or the
"North Carolina Surface Mining Manual" (available from the Division of
Land Resources in the DEMM-Regional or Central Offices). The control
practices shall be utilized to prevent exceedances of the appropriate turbidity
water quality standard (54 NT M in all fresh water streams and rivers not
designated as trout waters; 25 NI'Us in all. lakes and reservoirs, and all
saltwater classes; and 10 NTU is trout waters);
C) Sufficient materials required for stabilization and/or repair of erosion control
measures and stormwater routirW and treatment shall be on site at all times.
II. Monitoring of surface water parameters of the receiving waters is required as a
condition of this Certification. V f surface water'monitoring reveals water quality of
degradation or reveals that there has been loss of intended usage as determined by
either Riegel Ridge,.LLC or tht Division of Water Quality, then a Corrective
Action Plan (CAP) must,be developed and submitted to, DWQ within 50 days of
the determination. Upon first ^iscovering that waters and/or wetlands have water
quality degradation or loss of intended uses, Riegel Ridge, LLC shall notify the
DWQ Wilmington Regional Office. This notification shall be within 24 hrs of
first knowledge or the first business day thereafter and shall include a detailed
explanation of the nature of the problem. Also, Riegel Ridge, LLC shall provide
follow-up notification, in writing, within S business days of the first knowledge of
the problem.
A. Prior to start of consti uctiou, a "surface water monitoring plan" must be
provided to the Division of Water Quality. Riegel Ridge, LLC must receive
written approval for the plan by DWQ before any wetlands or waters are
impacted
a) Sample/ monitoring sta;Jim locations must be developed for every
discharge outfalI located on the site. The first station must be down slope
from the outfall. The &-cond station must be approximately halfway
between the outfaal and its confluence with Honey Island Swamp. These
sample locations must be depicted within the final moritoring plan.
b) Sampling from each o nation must minimally include pre-construction
data collected for a minimwn period of six months prior to the begin of
construction.
C) Sampling from each rte `;tlitoring station must at a minizuum include the
following:
MS66L XV3 TO:VO 90QZ%£Q%1'0
APR-13-2006 10:47 JOYCE ENGINEERING, INC. P.04

{ft')
-00
do M-# ? y)
r; .e ,PAM
attic
-: hed).
d) Sampling fx'om receivin ;.Waters up slope from Tram Road, must at a
minimum include the -following:
idi
-
AdT*aft*mWvWdipt
acaat??;k?S+eH:EE ;0
-c'bor?
169-
cs?llea?an?d- ?br?aii?:=?'?'?+t'o].??sulte?.
-All tests (where applicable) must be performed by DENR certified
laboratories.
e. It is a requirement of ti.is Certification that this facility apply for and
secure an NPDES Per.; i.: to Discharge Stormwater as required for
Landfills that are perm. tied by the North Carolina Division of Solid Waste
Management prior to iritiation of construction.
f. It is a requirement of this Certification that in addition to the above-
mentioned sampling, this facility must maintain full compliance with all of
the NPDES Permit coqji ions required for this facility.
g. All samples collected from. the monitoring required above, must be
reported as a part of this Certification and included in any Nl?DES
monitoring reports.
h. A condition of this Ce -tif cation is that leachate must be properly
collected and containe 1. Also, all of the proper permits must be secured
and compliance with a(.'. permits must be maintained with respect to the
disposal and transport A leachate.
III) Monitoring of wetlands is required as a condition of this Certification. If wetland
impacts are determined to havE occurred, which can include indications of
instability, eroding, sloughing, or removal of the hydrology, as determined by
Riegel Ridge, LLC or the Division of Water Quality, then a Corrective Action
Plan must be developed within 60 days of the determination. If wetlands have
been impacted, Riegel Ridge, I LC shall notify the DWQ Wilmington Regional
4
rnnG3i Iii'I45L9t?JY3LSYM M966L xVd Zo:to 9000 CO/1")
APR-13-2006 10:47
. 1
JOYCE ENGINEERING, INC.
11
P.05
AD information reported must be based on data collected through analyses conducted using 40 CFR part
136 methods. In addition, these data must coraf.)y with QA/QC requirements of 40 CFR Part 136 and other
appropriate QA/QC requirements for standard rrq.hods for analyzes not addressed by 40 CPR Part 136.
Indicate in the blank rows provided below any .i ::a you may have on pollutants not specifically listed in
this form. At a minimum, effluent testing data-pustbe based on at least three pollutant scans and must be
no more than four and one-half years old.
A•
. ? - M
t
?`'F CmI:NIr:'.
10rf it T VC%WS7 T C V It
av.7enai Yvi Pn:t,n ann7ien/t,n
APR-13-2006
-M
10:4e JOYCE ENGINEERING, INC.
1;.
12
P.06
W S66L TVd M tO 90OZ%CO/VO
APR-13-2006 10:48
JOYCE ENGINEERING, INC.
1; .

P.06
12
M ML YVd WtO 90OZ/COi1'0
APR-13-2006 10:48
JOYCE ENGINEERING, INC.
13
P.07
,s LinMTT6XNW7TCVA! Rt7gARL Y8d WfO 9009/C01tO
APR-13-2006 10:49 JOYCE ENGINEERING. INC. P.08
14
N-YUSaaocu-xa-prolryiaunin?e Grab
N-nltrosodimethylarnine oral}
N nitrosodiphenylaxr we CGrab
i?henand=e Giab
Pyreue Gral)
1.2,4: trichlorobenzene Grab
I certify under penalty of law that this document and all attachments were prepared under may direction
and supervlsi.om in accordance with a system to design to assure that qualified perdonnel properly
gather and, evaluat the information submitted. Based on may inquiry of the person or persons that
manage the system, or thbre persons directly responslbel for gathering the information, the ?
information submitted is , to the best of my knowledge and belief. true accurate and complete. I am
aware that there are sigxxiiacant penalties, for submitting false information: including the
possibility of fines and imprisonment for lm6wing violations.
Authorl2ed Representative name
' .t
i.rn r, i?'T.11ZWhW3.TS?M 6VZS66L Yv3 ro:to goo Z!Eo/to
S
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
Division of Water Quality
Department of Environmental and Natural Resources
Wetlands/401 Unit
Street Address: 2321 Crabtree Boulevard, Suite 250
Raleigh, NC 27604-2260
Mailing Address: 1650 Mail Service Center
Raleigh, NC 27699-1650
Contact Information: Phone #: [phone]
Fax #: [phone]
Fax To: pall att'x Fax #:
Company: Date:
Number of pages including cover sheet:
Notes or special instructions:

QS
7

Gam- ?G??G ? / ?i^?
J f ?1 l

N. C. Division of Water Quality, 401 Wetlands Certification Unit,
1650 Mail Service Center, Raleigh, NC 27699-1650 (Mailing Address)
2321 Crabtree Blvd., Raleigh, NC 276042260 (Location)
[phone] (phone), 919-733-6893 (fax),.(http://h2o.enr.state.nc.us/ncwetlands
wwrit.
WASTE MANAGEMENT
April 27, 2004
Re: Riegel Ridge, LLC
401 Water Quality Certification
Notice of change in ownership

WETLANDS/ 401 GROUP
MAY 0 5 2004
ATI P
QUALITY SECTION
. Alan W. Klimak, P.E., Director
ivision of Water Quality
North Carolina Department of Environment and Natural
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Mr. Klimack:
WASTE MANAGEMENT
2859 Paces Ferry Road
Suite 1600
Atlanta, GA 30339
[phone]
Resources
1, +P P'? 9 7 2004
DIV. OF MATER QUALITY
DIRECTOR'S OFFICE
On December 16, 2002, your agency issued Certification No. 3406 to Riegel
Ridge, L.L.C. Among the requirements of that certification is that notice must be
provided to the Division if there is any change in ownership.
On October 8, 2003, Waste Management of Carolinas, Inc., ("Waste
Management") acquired all of the membership interests in Riegel Ridge, L.L.C.
As a wholly-owned subsidiary of Waste Management, Riegel Ridge will continue
to comply with the 401 Certification and all other State and Federal requirements
that are necessary to permit the proposed landfill in Columbus County.
If you have any questions, please contact Steve Anderson, Project Manager, at
770-805-3352.
ZVerytr our s,
h
Vice President
Waste Management of Carolinas, Inc.
Cc: Mr. Rick Shiver, DWQ Regional Field Office, Wilmington
Ms. Angie Pennock, Corps of Engineers, Wilmington
Mr. Billy Joe Farmer, Columbus County
Mr. William W. Dreitzler, P.E.
Mr. James C. Coffey, Waste Management Division, Raleigh
Mr. Steve Parascandola, Esq.
&\\\9
g
Q4,4A?R?North'
Carolina Floodplain Mapping Program
.??.
NO Cooperating Technical State
MAR 2 5 2004 WETLA l0,',
Mr. John D. Runkle MAR 2 9 2004
Attorney at Law
P.O. Box 3793°wt'p
Chapel Hill, North Carolina 27515
RE: Preliminary Flood Insurance Rate Map for Columbus County and Incorporated Areas,
North Carolina
Dear Mr. Runkle:
This is in response to your letter, dated November 17, 2003, to the Department of Homeland
Security's Federal Emergency Management Agency (FEMA) and the State of North Carolina,
regarding your protest of the referenced preliminary Flood Insurance Study (FIS) Report and
Flood Insurance Rate Map (FIRM) submitted on behalf of the Friends of the Green Swamp and
the North Carolina Chapter of the Nature Conservancy. The information contained in your fetter
was forwarded to FEMA's Map Coordination Contractor and the State's engineering contractor
for evaluation.
In addition, FEMA and the North Carolina Floodplain Mapping Program (NCFMP) received a
letter from Mr. Jeff Lane, Chairman of the Friends of the Green Swamp, in December 2003,
supporting the protest of the floodplain delineation in this area as outlined in your
November 17, 2003 letter. Mr. Lane also submitted topographic data to support the protest.
As defined in Paragraph 67.6(a) of the National Flood Insurance Program (NFIP) regulations,
"the sole basis of appeal under this part shall be the possession of knowledge or information
indicating that the elevations proposed by FEMA are scientifically or technically incorrect...
appellants are required to demonstrate that alternative methods or applications result in more
correct estimates of base flood elevations, thus demonstrating that FEMA's estimates are
incorrect." The basis of your concern appears to consist of more accurate topographic
information to revise the delineation of the 1% annual chance (100-year) floodplain and,
therefore, is considered a protest.
FEMA and the NCFMP have complete confidence in the methods use to obtain elevation data
and the engineering models developed during the map production process. The new topographic
data were developed through Light Detection and Ranging (LIDAR) technology, and the data
were collected in the winter of 2000. Airborne LIDAR sensors emit between 5,000 and 50,000
laser pulses per second. Factoring in the scan angle, height, speed, pitch and role of the aircraft,
one can determine the bare earth elevation. Once a scrubbing process has taken place to
eliminate the vegetation, the topographic data have an improved accuracy standard of 20-cm
(1.3 feet accuracy at the 95% confidence limit).

Although the appeal period for Columbus County ended on December 24, 2003, we would like
to ensure that all parties are satisfied with the FIS Report and FIRM panels before finalization.
Therefore, the NCFMP's engineering contractor has been tasked to survey and evaluate the
topographic data used to prepare the FIS Report and FIRM in the vicinity of the proposed Riegel
Ridge Landfill. Once the evaluation has been completed, a summary of findings can be issued to
you for your review and comment.
We appreciate your concern that the new FIRM for the communities within Columbus County
reflects the most accurate information available. If representatives of the Friends of the Green
Swamp or the Nature Conservancy have any further questions or concerns, please have them
contact John Dorman, NCFMP Director, via email at [e-mail] or by telephone
at [phone], ext. 261.
Sincerely,
Doug Bellomo, P.E., Acting Branch Chief _ John K. Dorman, Director - -=-=-.
Hazards Study Branch North Carolina Floodplain _
Mitigation Division Mapping Program
Emergency Preparedness
and Response Directorate
cc: Mr. Billy Joe Farmer, County Administrator
Mr. Darren Currie, Assistant County Administrator
Ms. Sherri Coghill, N.C. Division of Waste Management
Mr. John Dorney, N.C. Wetland Unit
Ms. Angie Pennock, U.S. Army Corps of Engineers
Mr. Jeff Lane, Chairman, Friends of the Green Swamp
Mr. Abdul Rahmani, NCFMP
Mr. Philip Letsinger, State NFIP Coordinator
Mr. Ed Curtis, NCFMP Scoping and Outreach Coordinator
FEMA Region IV
. . r M1 A* *
' • I??
NCDENR
North Carolina Department of Environment and Natural Resources
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan Klimek, P.E., Director
Division of Water Quality
June 10, 2002
Certified Mai
Return Receipt Requested
Mr. William W. Dreitzler
Riegle Ridge, LLC
211 East Six Forks Road, Suite 203
Raleigh, 14C 27609
l
410
WA Tr 3?:?,5 Qllro
Subject: Additional Information Request
Riegle Ridge Landfill
DWQ 011680
Columbus County
Dear Mr. Dreitzler:
Subsequent to the review of the 401 Water Quality Certification Request for Riegel Ridge MSW
Landfill developed by Soil and Environmental Consultants, Inc., the site Hydrogeological Report
developed by Titan Atlantic Group, the April 18, 2002, Public Hearing comments, and the respective
written comments received by the Division of Water Quality the following additional information is
requested. Specifically the below-mentioned items are requested pursuant to 15A NCAC 2H .0506 (b) (1
-6).
As such, insufficient evidence is present in our files to conclude that your project must be built as
planned in waters and/or wetlands in accordance with 15A NCAC 2H .0506. Therefore, this project will
remain on hold as incomplete until we receive this additional information. Also, we are requesting (by
copy of this letter) that the U. S. Army Corps of Engineers place your project on administrative hold.
• 15A NCAC 2H.0506 (b) (1) has no practical alternative under the criteria outlined in
Paragraph (f) of this Rule.
- Although this issue was briefly addressed in application prepared by Soil and Environmental
Consultants, please provide copies of any additional accounts/information provided to the Corps of
Engineers with respect to the alternatives to the proposed Riegel Ridge site.
-On May 22, 2002, the Wetlands/ 401 Unit of DWQ received information that included the 1994
Columbus County report that cites different possible landfill locations within Columbus County.
Thank you for providing this information. This is an item that was to be requested
in this correspondence and is as such in process of being reviewed. Although the review of this
document is incomplete, please additionally provide at minimally the site selection process and what
factors were used to select the proposed site.
Fayetteville Regional Office
225 Green Street- Suite 714, Fayetteville, North Carolina 28301-5043
Phone: [phone]/FAX: [phone]Internet: www.enr.state.nc.us/ENR
An Fnnai nnnnrtnnity 1 Affirmative Artinn Fmnlover - 50% Recvcled 110% Post Consumer Paper
Mr. William W. Dreitzler
Page 3
June 10, 2002
-Please explain whether the proposed landfill liner will leak and if the landfill will allow Groundwater
contamination to occur (this includes but not limited to surficial groundwater and the discussion
should include three time lines; 1) during the life of the landfill 2) a timeline beyond the active life of
the landfill receiving waste, and 3) beyond the 30-year post closure.)
-The application prepared by S&EC briefly address the success of Title D landfills. As such, please
provide accounts of liners like that proposed for use at Riegle Ridge site. These accounts should
focus on liners that have successfully prevented groundwater contamination from occurring (the
landfill age, location, and frequency of the monitoring should be include in these accounts).
Specifically detail the success of both the liners and the landfills like that proposed at Riegle Ridge,
include the data, and a timeline for the data that supports these results.
-Conversely, please identify and provided accounts of liners and landfills, like that proposed for
Riegle Ridge, that have failed to protect groundwater. Please explain the failures, landfill retrofit
efforts, and the respective groundwater clean up that has occurred. Specifically detail the lack of
success of the liners and landfills like that proposed at Riegle Ridge, include the data, and a timeline
for the data that supports thesexesults.
-It is our understanding that wells are to be installed around the proposed landfill for the purpose of
monitoring. It is also our understanding that this monitoring schedule will be of a long duration.
Please explain frequency of monitoring, how long the monitoring wells are to be monitored beyond
the life of the landfill, who will be responsible for the monitoring, and what kind of monitoring well
maintenance plan you propose to use to ensure that the wells are maintained and are functioning
properly. Also, will monitoring occur beyond the 30-year post landfill closure time window? If so, by
who?
-What is the likelihood of the liner failing and groundwater standard violations occurring within the
active life of the landfill. What is the likelihood of the liner failing and groundwater standard
violations occurring within 30-years subsequent to the landfill closure? What is the likelihood of the
liner failing and groundwater standard violations occurring after 30-years, post landfill closure?
-What maintenance and monitoring is associated with leachate storage/containment? What is the
elevation of the leachate storage structure.
- A letter from FEMA, dated January 29, 2002, indicated that immediately across the county line to
the east of the project site, where more accurate flood studies have been done, the mapped 100-year
floodplain boundary approximately follows the sixty foot contour line. Please clearly state which
floodplain elevation are to be use for site design and how/why this figure was determined/chosen.
-Address tropical storm events where stormwater and respective flooding events may be well beyond
the 100 year levels. Also, please discuss whether the saturated landscape adjacent to the landfill and
the respective changes in head between a landfill cell could result in a structural compromise of the
floor/footprint of the landfill. Is this a reasonable concern, as sometimes encountered/noted in other
flood caused land uses impacts? How can this concern be addressed?
Mr. William W. Dreitzler
Page 5
June 10, 2002
-Stormwater control structure maintenance must also be addressed. Provide a monitoring plan and
detail who is to be responsible for the necessary maintenance of the stormwater control structures
during the period of time the landfill is active, during the 30-years period of time post landfill closure,
and subsequent to 30-years post landfill closure.
-Please address what prevision are to be provided to protect the facility, including stormwater controls
during tropical storms events.
- In addition, who will be responsible for maintaining the landfill cap during the 30-years period of
time post landfill closure and subsequent to 30-years post landfill closure. (A necessary concern to
ensure sloughing and erosion issues that may arise post landfill closeout are addressed and do not
compromise stormwater controls.)
-Please clearly indicate in your stormwater plan the flow pathway(s) and respective outlet locations of
the stormwater, locations of all control structures, and detail the respective location of the
jurisdictional wetlands and waters located on-site. The information you provide should also indicate
the location of all outfalls and specifically address whether the receiving feature is a forestry ditch or
wetlands etc.)
-Please provide a simple vicinity map, indicating the surface water pathway from the proposed site to
the confluence with ocean.
Thank you for your attention to these matters. Please mail your response to both the letterhead address
and to the attention of Danny Smith at Wetland/401 Unit 2321 Crabtree Blvd., Raleigh NC 27604 -2260.
A response to each of the above mentioned items, in writing is necessary in order for completion of the
review of this project and the subsequent decision by the Director with respect to the 401 Water Quality
Certification request.
Sincerely,
aul Rawls
Water Quality Regional Supervisor
cc: Wetlands/ 401 Unit -Danny Smith
Wetlands/401 Unit - File Copy
Division of Solid Waste - Sherri Coghill
Wilmington Regional Office, DWQ - Rick Shiver
Fayetteville Regional Office - Paul Rawls
USACE - Wilmington Regional Office: Attention Angie Pennock
?O? WA
OT ?9QG
c
o -c
January 9, 2002
Columbus County
DWQ Project No. 01-1680
CERTIFIED MAIL: RETURN RECEIPT REQUESTED
William W. Dreitzler
Riegel Ridge, LLC
211 East Six Forks Road, Suite 203
Raleigh, NC, 27609
Dear Mr. Dreitzler:
On December 17, 2001, the NC Dt&ion of Water Quality (DWQ) received your application (in the form of the amended
Corps' Public Notice) for a 401 Water Quality C?--r fication for the proposed Riegel Ridge Landfill in Columbus County.
Insufficient information has been provided in order for us to complete our review. Specifically, please provide the following
materials so that we can complete our review of your application:
• Please discuss how secondary and curr?ulative impacts will be avoided. Specifically, please address how you will
dredge the sand cover in the vim., with no pumping or mining involved. Please also discuss how draining of
wetlands on the property will be avo'?ds--d, riven the excavation required to construct the landfill;
• Attached is a copy of a commierA fetterv%;e received from the Wildlife Resources Commission (WRC), in which they
list numerous concerns with respect to t-is project. Please note that these issues must be addressed as part of
the 401 Certification review. We stror4i?y suggest that you provide an itemized response to the WRC letter.
Until the information requested in lh-s letter is provided, l will request (by copy of this letter) that the Corps of Engineers
place this project on hold. Also, this prim will ba ptaaed on hold for our processing due to incomplete information (15A
NCAC 2H .0507(h)).
You should also note that DWQ has received rAxnerous form letters and individual letters requesting a public hearing
for this project. The Director of the Division of War QLm2 ty is reviewing your application, along with the comment letters,
to decide whether a public hearing o,-'] :r_ `e ti... inform you whether or not he recommends a public hearing, and if
so, will discuss the schedule with you_
Thank you for your attention. tf ycu eve any gt*sbons, please Cyndi Karoly in our Central Office in Raleigh at (919)
733-9721.
Sincerely,
cc: Corps of Engineers Witmfngton R atoiy l=ld Office
Wilmington DWQ Regional Office
Greg Thorpe
Coleen Sullins -
Dennis Ramsey
File Copy
Central Files
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
/111 John Dorney
011680
North Carolina Division cfV1aWrOrmftf,AM Wetlands Certification Unit,
1650 Mail Service Center, R- , lC v5. -1650 (Mairng Address)
2321 Crabtree Blvd., Raleig %PIC 27F1.c lW )
n+n ??n ? roc i..i.,.....t run 7is oof? ;z...... ?.,...-ea.i+-.....? .. ........ i........,?i.....,.. r
O?O? W AT FRQG Michael F.. Easley
Governor
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
January 9, 2002
Columbus County
DWQ Project No. 01-1680
CERTIFIED MAIL: RETURN RECEIPT REQUESTED
William W. Dreitzler
Riegel Ridge, LLC
211 East Six Forks Road, Suite 203
Raleigh, NC, 27609
Dear Mr. Dreitzler:
On December 17, 2001, the NC Division of Water Quality (DWQ) received your application (in the form of the amended
Corps' Public Notice) for a 401 Water Quality Certification for the proposed Riegel Ridge Landfill in Columbus County.
Insufficient information has been provided in order for us to complete our review. Specifically, please provide the following
materials so that we can complete our review of your application:
• Please discuss how secondary and cumulative impacts will be avoided. Specifically, please address how you will
dredge the sand cover in the wet, with no pumping or mining involved. Please also discuss how draining of
wetlands on the property will be avoided, given the excavation required to construct the landfill;
• Attached is a copy of a comment letter we received from the Wildlife Resources Commission (WRC), in which they
list numerous concerns with respect to this project. Please note that these issues must be addressed as part of
the 401 Certification review. We strongly suggest that you provide an itemized response to the WRC letter.
Until the information requested in this letter is provided, I will request (by copy of this letter) that the Corps of Engineers
place this project on hold. Also, this project will be placed on hold for our processing due to incomplete information (15A
NCAC 2H .0507(h)).
You should also note that DWQ has received numerous form letters and individual letters requesting a public hearing
for this project. The Director of the Division of Water Quality is reviewing your application, along with the comment letters,
to decide whether a public hearing will be held. We will inform you whether or not he recommends a public hearing, and if
so, will discuss the schedule with you.
Thank you for your attention. If you have any questions, please Cyndi Karoly in our Central Office in Raleigh at (919)
733-9721.
Sincerely,
John Dorney
cc: Corps of Engineers Wilmington Regulatory Field Office
Wilmington DWQ Regional Office
Greg Thorpe
Coleen Sullins
Dennis Ramsey
File Copy
Central Files
011680
North Carolina Division of Water Quality, 401 Wetlands Certification Unit,
1650 Mail Service Center, Raleigh, NC 27699-1650 (Mailing Address)
2321 Crabtree Blvd., Raleigh, NC 27604-2260 (Location)
nIn'177 I10a /..1 ---I nIn 17' con? fg--\ L.M-..//L.n., r...-..•..s.. .... .... /....,.,?H.....1,./
MARLOWE, DREITZLER & ASSOCIATES
Consulting Engineers
211 East Six Forks Road, Suite 203
Raleigh, N.C. 27609
May 23, 2002
Paul Rawls
C/O Daiuiy Smith
NC Division of Water Quality
2321 Crabtree Blvd.
Raleigh, North Carolina
Reference: Riegel Ridge MSW Landfill - Columbus County, North Carolina
Additional Information -- Site Study
Dear Mr. Rawls:

919-834-1113
919-834-6060(Fax)
In addition to the information provided under cover dated May 20, 2002, please find attached a
set of Volume I and Volume II of the Site Study, which has been on file with the Division of
Waste Management since March 3, 2000. The "Site Study" is often referenced in
correspondence related to this project so I am providing you with a copy for your benefit.
Volume I and Volume II of the Site Study can be combined with the complete Hydrogeologic
Report provided to the Division of Water Quality back on November 13, 2001 to mirror the
application on file with the Division of Waste Management. If I can be of further assistance,
please contact me at your convenience.
Sincerely,
7OWE, DREITZLER & ASSOCIATES
William W. Dreitzler, P.E.
Partner
Director of Engineering Services
Cc: Greg Thorpe, Division of Water Quality (no attachments)
John Dorney, Division of Water Quality (no attachments)
Coleen Sullins, Divsion of Water Quality (no attachments)
Sherri Coghill, Division of Waste Management (not attachments)
Angie Pennock, Wilmington Regulatory Field Office, USACE (no attachments)
Billy Farmer, Columbus County Administrator (no attachments)
Amon McKenzie, Chairman, Columbus County Board of Commissioners
(no attachments)
Jcnnifcr Burdette, S&.EC (no attachments)
Riegel Ridge, L.L.C. File Copy

'*I MARLOWE, DREITZLER & ASSOCIATES
Consulting Engineers
211 East Six Forks Road, Suite 203
Raleigh, N.C. 27609
May 20, 2002
Paul Rawls
C/O Danny Smith
NC Division of Water Quality
2321 Crabtree Blvd.
Raleigh, North Carolina

DIV. OF WATER QUALITY
DIRECTOR'S OFFICE
r`
0901-"41
919-834-1113
919-834-6060(Fax)
y
.;,.?. 4
n r?0?
?r?oti 1Reference: Riegel Ridge MSW Landfill - Columbus County, North Carolina
Additional Information
Dear Mr. Rawls:
As you are aware, additional technical information regarding the Riegel Ridge application
was provided at the request of the Division of Water Quality (DWQ) under cover dated
November 13, 2001. The following information was submitted:
• 7 copies of the complete USACE Application
• 1 complete copy of the project hydrogeologic report
• 1 copy of transcripts from previous public hearings
• Application fee of $475.00 (check)
In a DWQ letter dated January 9, 2002, it was requested that Riegel Ridge provide "the
following materials so that we can complete our review of your application". The DWQ
letter contained comments on only two issues. First, a discussion regarding the proposed
borrow sites for the landfill and how the borrow will take place without impacting adjacent
wetlands. This information is contained within the original USACE Application provided
to the DWQ on November 13, 2001. In conversations with Jennifer Burdette of S&EC,
Joanne Steenhuis acknowledged that the comments were hers' and that she had made those
comments without thoroughly reviewing the USACE Application because it was her
understanding the a public hearing would be forthcoming. Therefore, DWQ has
acknowledged that the information requested regarding a discussion of the borrow
operations is in fact contained within the original USACE Application and has been
available to DWQ since November 13, 2001. The second issue contained within the
January 9th letter was a request that an itemized response be provided to a comment letter
received from the Wildlife Resources Commission (WRC). On January 31, 2002 two
separate letters were provided to Mr. Frank McBride, Supervisor, Habitat Conservation
Program, North Carolina Wildlife Resources Commission. One letter dealt specifically
with the issue of Environmental Assessments and Environmental Impact Statements. The
.11
second letter addressed each of eight (8) specific issues raised by the WRC and included
support data, were applicable. The DWQ was copied the response provided to the WRC.
Therefore, as of January 31, 2002, Riegel Ridge was in complete compliance with all
requests made of the applicant by the DWQ.
On February 11, 2002, I received a letter from John Dorney informing me that the project
would again be put on hold. Mr. Dorney stated "The Division has decided that it is in the
public interest that a public hearing for the purpose of reviewing public comment and
additional information be held prior to granting or denying the 401 Water Quality
Certification. Therefore the project will be placed on hold since the final decision on the
401 Certification will be made pursuant to the public hearing." The DWQ files document
the decision making process and indicate a hearing was called generally because of the
public interest in the project. The public hearing was held on April 18, 2002 and based on
the language in Mr. Dorney's February 11, 2002 letter, the project was no longer
considered "on hold" after that date.
Based on my attendance of the public hearing and my subsequent review of data submitted
to the DWQ through the public input process, I believe four key issues were discussed
which relate specifically to Water Quality and the issues of the landfill permit process
which could warrant evaluation by the DWQ. These issues are:
1. Potential Water Quality Impacts to Lake Waccamaw - Gulls:
Riegel Ridge and the North Carolina Division of Parks and Recreation have been
discussing this issue for months. Working closely with Mr. Brian Strong, Biologist
and Resource Management Specialist with the Division of Parks and Recreation, as
well as with Carol A. Tingley, Chief, Planning and Natural Resources, Division of
Parks and Recreation we developed a Gull Management Plan designed to mitigate the
number of gulls attracted to the landfill, and to provide habitat such that those gulls
attracted to the landfill during the 2 or 3 month winter migration period for which the
Division anticipated the potential risk to Lake Waccamaw. The final Report was
provided to Dr. McKnelly, Division Director, Division of Parks and Recreation on
April 1, 2002. A copy of the Report is attached for DWQ review. In a letter dated
May 2, 2002 Dr. McKnelly states that "These concerns have been presented to the
consulting engineer and they have developed a proposed landfill design to encourage
the gulls to stay on-site and not roost off the landfill site. In addition, the designers
have demonstrated, to the satisfaction of the Division, that the landfill will not degrade
the viewshed or diminish the recreational experience of lake users." In addition, the
Gull Report provides that the landfill is likely to draw existing gulls from Lake
Waccamaw, thereby reducing the number of gulls that occupy the Lake. A copy of Dr.
McKnelly's letter is provided for DWQ review. This data clearly demonstrates that the
Riegel Ridge Landfill does not pose any potential impact to the water quality of Lake
Waccamaw due to the migration of seagulls.

2. Landfill Location and Protection of Aquifer Water Quality:
It was suggested in the public hearing that the DWQ should listen more closely to an
expert recommended by opposition groups to the project as opposed to the licensed
professionals who have provided detailed hydrogeological evaluations under contract
with Riegel Ridge. Given those suggestions, Riegel Ridge contacted Ralph C. Heath,
Consulting Hydrogeologist, and author of the centerpiece of the claims that the
Brunswick County water supply source would be at risk if the landfill were
constructed. We asked Mr. Heath to review the project location and comment on the
references made to his report at the public hearing. After review of the landfill location
and associated site data, Mr. Heath came to the conclusion that the Riegel Ridge
Landfill site is placed at a good location with respect to water quality concerns. In a
letter provided by Mr. Heath to Kevin Martin, S&EC, he states that "The Riegel Ridge
landfill site is clearly located in an area that I would have classified in the Brunswick
County report as a dry flat and sloping upland. As I noted in the Brunswick report, dry
flat and sloping uplands, especially where they are located adjacent to perennial
streams, should receive primary consideration for waste sites (p. 13, last para.). The
Riegel Ridge site meets this criterion because it is adjacent to Honey Island Swamp
(creek)." Figure 3 of the Brunswick County Report demonstrates the impact of a
perennial stream as a discharge feature. In a meeting with myself and representatives
from S&EC, Mr. Heath stated that in his opinion, any contamination that escaped the
safety features of the landfill design would migrate no further than the surficial aquifer
and quickly discharge into the Honey Island Swamp creek feature were the
contaminates would dissipate. He further stated that the Peedee and Castle Hayne
aquifers had virtually no potential for contamination from the landfill site and that
water supply sources in Brunswick County had virtually no potential for contamination
from the landfill site. Based on the evaluation of the oppositions recommended
Hydrogeologist, it is clear that the Peedee and Castle Hayne aquifers, and therefore
Brunswick County, have no risk of water quality contamination related to the Riegel
Ridge Landfill. A copy of the Aquifer-Sensitivity Map of Brunswick County, North
Carolina (report), and the subsequent letter authored by Mr. Heath on May 13, 2002 are
provided for DWQ review.
3. Green Swamp Restoration and the Impact on Groundwater Elevations:
The position of Riegel Ridge on this issue is that the concern simply has no basis. The
only aspect of this concern related to water quality would be that the landfill design
comply with the EPA mandated 4-foot separation between seasonal high groundwater
and the HDPE geomembrane layer of the liner system (post-settlement). A
potentiometric map was prepared under the guidelines of Section .1623 - Geologic and
Hydrogeologic Investigations For MSWLF Facilities, of the North Carolina Solid
Waste Management Rules. The potentiometric map (groundwater contour map) was
provided to the Division of Waste Management on March 3, 2000 for review. The
final determination of the elevations for seasonal high groundwater rest with the
approval of the Site Study by the Division of Waste Management, and the Division has

indicated the 404 permit, and thus the 401 Water Quality Certification must be
obtained prior to the Division of Waste Management issuing Site Suitability, or
approval of the Site Study. However, relative impact should be the primary criteria
evaluated. In a conversation with Mr. Ralph Heath, I posed the question, should major
Green Swamp restoration take place in the manner suggested by Dr. Riggs (Mr. Heath
reviewed the Dr. Riggs comments letter) what would be the potential impacts with
regards to groundwater on the proposed Riegel Ridge site, and what would be the
magnitude of those impacts? Mr. Heath commented that it was possible for
groundwater elevations to be impacted should a major Green Swamp restoration
project take place over the next 50 years. However, the magnitude of the impact would
be marginal at best. In other words, we are talking about groundwater elevation
impacts due to the unlikely restoration of privately held lands within the Green Swamp
of a few inches, and the likelihood of this impact very slim. The landfill design does
not provide for an HDPE geomembrane to seasonal high groundwater separation of
exactly 4 feet, but rather a separation in excess of 4 feet. Therefore, this issue, with
respect to water quality can be summarized by a risk comparison. The EPA requires a
4-foot separation, and therefore this separation design is considered acceptable with
regards to water quality protection. Should the separation of Riegel Ridge meet the
EPA requirement without margin, and over the next 50 years the Green Swamp is
restored to wetter conditions present some 100 years ago, the net impact on the landfill
would be that the separation from seasonal high groundwater to the HDPE
geomembrane would shrink from 4 feet to something on the order of 3'-10".
Therefore, a modified seasonal high groundwater to HDPE geomembrane layer
separation of 4'-2" or other reasonable amount would eliminate the perceived risk. A
copy of the Dr. Stan Riggs comment letter submitted to the Corps of Engineers is
provided for DWQ review.
4. Historical Ditching and the Application of the Clean Water Act:
Angie Pennock, USACOE, Wilmington Field Office, has done extensive review
including map research and on-site evaluations to determine the history and legality of
the ditching performed on the Riegel Ridge Site by International Paper. She has
concluded that the ditch for which this permit application proposes impact (the 0.69
acres of wetland impact) was constructed prior to the 1972 Clean Water Act. In
addition, she has concluded that the balance of the ditching installed after 1972 was
done in a legal manner. Her evaluations, research and conclusions were reviewed not
only by her Supervisor, but have also been reviewed by USACOE legal counsel.
Given the relationship between the USACOE and the DWQ on a 404 permit
application and associated 401 certification, the DWQ should accept the extensive
review already provided by the USACOE.
In addition to the information provided to the DWQ upon request on November 13, 2001,
and the information provided via response to the Wildlife Resources Commission on
January 31, 2002, the DWQ met with Riegel Ridge on the landfill site on March 22, 2002.
The site meeting was a coordinated visit with the Corps of Engineers, Division of Parks
and Recreation and the Division of Waste Management. Since the March 22, 2002

meeting, Riegel Ridge has made repeated requests both to meet with the DWQ to discuss
any DWQ concerns and to discuss any information that Riegel Ridge might provide to
further aide the DWQ 401 Certification review. To date DWQ has repeatedly denied our
request for a meeting to discuss the merits of the application. In addition, while continuing
to suggest that DWQ will request additional information to aid the review process, DWQ
has not provided any such request. Therefore, in an effort to assist DWQ with expediting
the review process, I am hereby providing the following additional information in support
of our application (please note that some of the data listed below is also referenced in the
above discussion):
• Report - Site Use by Gulls (March 20, 2002)
• Division of Parks and Recreation response to Gull Report (May 2, 2002)
• Ralph C. Heath, Consulting Hydrogeologist, Aquifer-Sensitivity Map of
Brunswick County, North Carolina (September, 1997, revised October 1997)
• Ralph C. Heath letter regarding the Riegel Ridge site location (May 13, 2002)
• Dr. Stan Riggs comments letter as provided to the Corps of Engineers
(December 7, 2001)
• Flood Study to Determine 100-Year Floodplain Limits, Riegel Ridge MS W
Landfill, Columbus County, North Carolina, by Alpha & Omega Group
(December 20, 2001)
• Titan Atlantic Memorandum - Help Model Results, preliminary leachate
collection analysis for Riegel Ridge (December 7, 2001)
• Riegel Ridge Landfill Contaminant Transport Model Report, Titan Atlantic
(February 5, 2002)
• Wetland and 100-Year Floodplain Location Plan (24" x 36" drawing)
• Green Swamp Location Plan and Green Swamp National Natural Landmark
Boundary (24" x 36" drawing)
• Columbus County, North Carolina Regional Lined Landfill Site Selection
Study (March 1994)
• Archaeological Survey
• Rare and Endangered Species Survey
Based on our diligent effort to provide the DWQ with any and all information required to
make a favorable decision regarding the Riegel Ridge 401 Water Quality Certification it is
our request that the DWQ adhere to the time limits imposed by Section .0507(b) of the
North Carolina Administrative Code. Section .0507 states that "All applications for
certification shall be granted or denied within 60 days after a public hearing. Failure to
take final action within 60 days shall result in a waiver of the certification requirement by
the Director unless the applicant otherwise agrees in writing, on unless Subparagraph
(a)(3), (4), or (5) of the Rule apply."
The three exceptions referenced should not apply when evaluated based on this
application. Subparagraph (a)(3) states that the applicant has failed to furnish information
necessary to the Director's decision. Clearly Riegel Ridge, as evidence by this letter, has
gone above and beyond statutory requirements in an effort to provide the DWQ any and all
information needed. Subparagraph (a)(4) states that the applicant has refused the staff
access to its records or premises. Clearly that has not been the case with this project, and
Riegel Ridge further confirms that DWQ is granted all access required to appropriate
records, documents as well as the site. Subparagraph (a)(5) states that information
necessary to the Director's decision is unavailable. This project has been under regulatory
review since March 3, 2000, while the initial site evaluations began back in the Fall of
1998. As is evidenced by the voluminous amounts of technical data already provided to
the DWQ since the initial 404 public notice on November 9, 2001 it would be very
difficult to legally defend a position that necessary information is unavailable.
Given the above, we respectfully await the decision of the DWQ regarding the Riegel
Ridge 401 dater Quality Certification on or before the June 18, 2002 date mandated by
the ;North Carolina Administrative Code. We continue to offer our immediate availability
to the DWQ to assist with the review process.
Sincerely,
>vi RLOWE, DREITZLER & ASSOCIATES
William Dreitzler, P.E.
Partner
Director of Engineering Services
Cc: Greg Thorpe, Division of Water Quality (no attachments)
John Donxey, Division of Water Quality (no attachments)
Coleen Sullins, Divsion of Water Quality (no attachments)
Sherri Coghill, Division of Waste Management (not attachments)
Angie Pennock, Wilmington Regulatory Field Office, USACH (no attachments)
Billy Farmer, Columbus County Administrator (no attachments)
Amon McKenzie, Chairman, Columbus County Board of Commissioners
(no attachments)
Jennifer Burdette, S&EC (no attachments)
Riegel Ridge, L.L.C. File Copy
MARLOW7E., D]REITZLEJR & ASSOCIATES
Consulting Engineers
211 East Six Forks Road, Suite 203
Raleigh, N.C. 27609
May 23, 2002
Paul Rawls
C/O Danny Smith
NC Division of Water Quality
2321 Crabtree Blvd.
Raleigh, North Carolina
Reference: Riegel Ridge MSW Landfill - Columbus County, North Carolina
Additional Information -- Site Study
Dear Mr. Rawls:
,-0?
919-834-1113
919-834-6060(Fax)
In addition to the information provided under cover dated May 20, 2002, please find attached a
set of Volume I and Volume II of the Site Study, which has been on file with the Division of
Waste Management since March 3, 2000. The "Site Study" is often referenced in
correspondence related to this project so I am providing you with a copy for your benefit.
Volume I and Volume II of the Site Study can be combined with the complete Hydrogeologic
Report provided to the Division of Water Quality back on November 13, 2001 to mirror the
application on file with the Division of Waste Management. If I can be of further assistance,
please contact me at your convenience.
Sincerely,
A OWE, 7ITZLER & ASSOCIATES
William W. Dreitzler, P.E.
Partner
Director of Engineering Services
Cc: Greg Thorpe, Division of Water Quality (no attachments)
John Dorney, Division of Water Quality (no attachments)
Coleen Sullins, Divsion of Water Quality (no attachments)
Sherri Coghill, Division of Waste Management (not attachments)
Angie Pennock, Wilmington Regulatory Field Office, USAGE (no attachments)
Billy Farmer, Columbus County Administrator (no attachments)
Amon Mckenzie, Chairman, Columbus County Board of Commissioners
(no attachments)
Jennifer Burdette, S&EC (no attachments)
Riegel Ridge, L.L.C. File Copy
OW A r?9QG
6 r
Certified Mail
Return Receipt Requested
Riegel Ridge, LLC
C/o William W. Dreitzler
211 East Six Forks Road, Suite 203
Raleigh, NC 27609
Dear Mr. Dreitzler:
September 20, 2002
Subject: Request for additional information
Riegel Ridge Landfill
DWQ 011680
Columbus County
The Division of Water Quality (DWQ) received Riegel Ridge, LLC's request for a 401 Water Quality
Certification on December 17, 2001. On April 18, 2002, DWQ held a public hearing on the application. By letter
dated June 10, 2002 DWQ requested additional information for review of the 401 Certification application.
Riegel Ridge, LLC responded to DWQ's additional information request by letter dated July 22, 2002.
We have reviewed the July 22, 2002 response and determined that Riegel Ridge, LLC has not yet provided
sufficient information to enable the Division to issue a 401 Water Quality Certification which states that the
project will comply with State water quality standards and 15A NCAC 2H.0506. Therefore this application will
remain on hold pending the receipt of the additional information outlined below.
This information must be received by DWQ for review by November 1, 2002. The one-year period for state
action provided in the Clean Water Act expires as of December 17, 2001. If DWQ does not receive the additional
information outlined below by November 1, 2002, then DWQ will be prepared to deny the 401 Water Quality
Certification for this project in order not to waive its right to issue a 401 Certification for this project.
The Riegel Ridge, LLC 401 application is still deficient in the following respects:
1. Compliance with State water quality standards for wetlands, surface waters, and groundwater.
In your response to DWQ's June 10, 2002 letter, your explained that the design of the final landfill liner
system, leachate collection and storage system, leachate disposal alternatives, landfill cap system and cap
maintenance, and the groundwater and surface - water monitoring plans was not available. This
information is related to the protection of water quality standards as outlined in the 401 Certification
rules. The location of the leachate collection system as well as other items outlined above have potential
to impact additional waters. Additionally, the management of the leachate and stormwater must be
performed in a manner to assure the protection of water quality. Further information is required regarding
the location and design of these measures in order for the Division to be able to determine that water
quality will be protected.
r
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
N. C. Division of Water Quality, 401 Wetlands Certification Unit,
1650 Mail Service Center, Raleigh, NC 27699-1650 (Mailing Address)
2321 Crabtree Blvd., Raleigh, NC 27604-2260 (Location)
[phone] (phone), 919-733-6893 (fax), (http://h2o.enr.state.nc.us/ncwetlands

2. Protection of downstream water quality standards through the use of on-site stormwater control
measures.
The information submitted by Riegel Ridge, LLC is insufficient to enable the Division to determine that
"downstream water quality standards will be protected through the use of on-site stormwater control
measures" pursuant to 15A NCAC 211.0506(b)(5) and (c)(5). In your July 22, 2002 letter, Riegel Ridge,
LLC did not account for the landfill cap as an impervious surface. Since the whole purpose of the cap is
to prevent (or severely restrict) infiltration, the landfill is thereby impervious. When the landfill is
included in the impervious surface area, there will be a significant amount of stormwater runoff that must
be managed to assure water quality standards are not violated.
Riegel Ridge must provide a site plan in sufficient detail to assure DWQ that storm water can be
adequately managed on-site to protect downstream water quality. Please address this underlying issue as
well as the broader design and engineering issues outlined below:
• The location and approximate size of on-site stormwater measures of sufficient size to provide
removal of total suspended solids and other associated pollutants in order to protect water quality
standards. These facilities must be designed to meet the criteria outlined in the most recent version of
DWQ's Stormwater Design Manual.
• These facilities must be designed to provide stoftnwater discharge rates for the 2, 5, and 10-year
discharges equal to or less than the pre-developed 2, 5, and 10-year discharge rates respectively in
order to protect downstream bank stability.
• Stormwater control structure operation and maintenance. The plan must.identify the entity/individual
responsible for maintenance of the stormwater control structures during the 30-years active life of the
landfill, as well as the 30-years period post- landfill closure.
• The plan must identify the location of all control structures, as well as all jurisdictional wetlands and
waters. The plan must also indicate the location of all outfalls and specifically identify the type of
receiving feature, i.e. ditches, wetlands, streams, etc. In this regard, it may be possible to rehydrate
locations on-site, which are not jurisdictional wetlands today due to past silvicultural practices. DWQ
would encourage this practice on this site where feasible.
• Please be aware that a condition of any possible 401 Certification for this project will be that a final
stormwater plan must be approved by DWQ before any impact to waters occurs on this site.
3. Assurance that the project will minimize adverse impacts to wetlands and surface waters.
DWQ is concerned that the activities at the landfill, particularly the excavation of borrow pits, will
adversely affect the wetland hydrology. To alleviate that concern,.DWQ requested a Wetland Monitoring
Plan for the Landfill. The Wetland Monitoring Plan submitted on July 19, 2002 while an improvement
over previous submittals is still deficient in several aspects. The items that were found to be deficient are:
a) The monitoring plan did not include sufficient wells to document whether the proposed activities
would result in the wetland hydrology being concentrically diminished. Additional wells are
necessary.
b) Riegel Ridge, LLC proposed to discontinue monitoring of the wetlands located adjacent to borrow
pits that remained jurisdictional five years after borrow activity ceased. This is unacceptable to DWQ
unless Riegel Ridge, LLC can propose an acceptable alternative methodology for assuring DWQ that
2
the wetlands are not being drained by other adjacent activities (notably construction of additional
borrow areas as well as stormwater management facilities).
c) The proposed locations of the automatic recording rain gauges must be indicated in the report.
d) The plan must include and indicate a location for a control wetland for use when affirming
DRAINMOD calibrations.
e) The current plan shows that ditches bisect some of the borrow pits. The plan must clearly state how
these ditch inlets and outlets will be plugged in order prevent the borrow pits from discharging and
thereby potentially draining adjacent wetlands.
For future reference, please note that the Division will require compliance with N.C. Gen. Statute § 143-
215.51 et seq (the Floodway Regulation) prior to construction of the landfill as a condition of any 401 Water
Quality Certification that may be issued for this project. The Floodway Regulation prohibits landfills in 100-year
floodplains unless a variance is obtained pursuant to N.C. Gen. Statute § 143-215.54A. Please be aware that any
401 Certification will be conditioned to require compliance with this state law.
By copy of this letter, we are requesting that the U. S. Army Corps of Engineers continue to place this project
on hold and not issue an Individual Permit for the subject project. If you would like to discuss any of these
matters, please call Danny Smith at [phone].
Sincerely,
cc:
File Copy
Division of Solid Waste - Sherri Coghill
Crime Control. and Public Safety
Wilmington Regional Office, DWQ - Rick Shiver
Fayetteville Regional Office - Paul Rawls
Wetlands/ 401 Unit - Danny Smith
Kevin Martin, Soil and Environmental Consultants
Central Files
3
G
rp..
y
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
September 20, 2002
Certified Mail
Return Receipt Requested
Riegel Ridge, LLC
C/o William W. Dreitzler
211 East Six Forks Road, Suite 203
Raleigh, NC 27609
Dear Mr. Dreitzler:
Subject: Request for additional information
Riegel Ridge Landfill
DWQ 011680
Columbus County
The Division of Water Quality (DWQ) received Riegel Ridge, LLC's request for a 401 Water Quality
Certification on December 17, 2001. On April 18, 2002, DWQ held a public hearing on the application. By letter
dated June 10, 2002 DWQ requested additional information for review of the 401 Certification application.
Riegel Ridge, LLC responded to DWQ's additional information request by letter dated July 22, 2002.
We have reviewed the July 22, 2002 response and determined that Riegel Ridge, LLC has not yet provided
sufficient information to enable the Division to issue a 401 Water Quality Certification which states that the
project will comply with State water quality standards and 15A NCAC 2H .0506. 't'herefore this application will
remain on hold pending the receipt of the additional information outlined below.
This information must be received by DWQ for review by November 1, 2002. The one-year period for state
action provided in the Clean Water Act expires as of December 17, 2001. If DWQ does not receive the additional
information outlined below by November 1, 2002, then DWQ will be prepared to deny the 401 Water Quality
Certification for this project in order not to waive its right to issue a 401 Certification for this project.
The Riegel Ridge, LLC 401 application is still deficient in the following respects:
1. Compliance with State water quality standards for wetlands, surface waters, and groundwater.
In your response to DWQ's June 10, 2002 letter, your explained that the design of the final landfill liner
system, leachate collection and storage system, leachate disposal alternatives, landfill cap system and cap
maintenance, and the groundwater and surface - water monitoring plans was not available. This
information is related to the protection of water quality standards as outlined in the. 401 Certification
rules. The location of the leachate collection system as well as other items outlined above have potential
to impact additional. waters. Additionally, the management of the leachate and.-:stormwater must be
performed in a manner to assure the protection of water quality. Further information is required regarding
the location and design of these measures in order for the Division to be able to determine that water-
quality will be protected.

Division of Water. Quality, 401 Wetlands Certification Unit,
Mail Service Center, Raleigh NC 27699-1650 (Mailing Address)
Crabtree Blvd., Raleigh, NC 27604-2260 (Location)
733-1786 (phone), 919733-6893 (fax), (http://h2o.enr.state.nc.us/ncwetlands r 5

2. Protection of downstream water quality standards through the use of on-site stormwater control
measures.
The information submitted by Riegel Ridge, LLC is insufficient to enable the Division to determine that
"downstream water quality standards will be protected through the use of on-site stormwater control
measures" pursuant to 15A NCAC 2H .0506(b)(5) and (c)(5). In your July 22, 2002 letter, Riegel Ridge,
LLC did not account for the landfill cap as. an impervious surface. Since the whole purpose of the cap is
to prevent (or severely restrict) infiltration, the landfill is thereby impervious. When the landfill is
included in the impervious surface area, there will be a significant amount of stormwater runoff that must
be managed to assure water quality standards are not violated.
Riegel Ridge must provide a site plan in sufficient detail to assure DWQ that stormwater can be
adequately managed on-site to. protect downstream water quality. Please address this underlying issue as
well as the broader design and engineering issues outlined below:
• The location and approximate size of on-site stormwater measures of sufficient size to provide
removal of total suspended solids and other associated pollutants in order to protect water quality
standards. These facilities must be designed to meet the criteria outlined in the most recent version of
DWQ's Stormwater Design Manual.
• These facilities must be designed to provide stormwater discharge rates for the 2, 5, and 10-year
discharges equal to or less than the pre-developed 2, 5, and 10-year discharge rates respectively in
order to protect downstream bank stability.
• Stormwater control structure operation and maintenance. The plan must identify the entity/individual
responsible for maintenance of the stormwater control structures during the 30-years active life of the
landfill, as well as the 30-years period post- landfill closure:
• The plan must identify the location of all control. structures, as well as all jurisdictional wetlands and
waters. The plan must also indicate the location.of all outfalls and specifically identify the type of
receiving feature, i.e. ditches, wetlands, streams, etc. In this regard, it may be possible to rehydrate
locations on-site, which are not jurisdictional wetlands. today due to past silvicultural practices. DWQ
would encourage this practice on this site where feasible.
• Please be aware that a condition of any pos
stormwater plan must be approved by DWQ
3. Assurance that the project will minimize
DWQ is concerned that the activities at the
adversely affect the wetland hydrology. To al:
Plan for the Landfill. The Wetland Monitoril
over previous submittals is still deficient in sei
a) The monitoring plan did not include sufi
would result in the wetland hydrology
:ertification for this project will be that a final
r impact to waters occurs on this site.
kto wetlands and surface waters.
irly the excavation of borrow pits, will
i, DWQ requested a Wetland Monitoring
on July 19, 2002 while an improvement
items that were found to be deficient are:
ent whether the proposed activities
diminished. Additional wells are
necessary.
b) Riegel Ridge, LLC proposed to disco
pits that remained jurisdictional five ye
unless Riegel Ridge, LLC can propose
the wetlands located adjacent to borrow
ity ceased. This is unacceptable to DWQ
tive methodology for assuring DWQ that
2
A
Jy/M
,I
J
the wetlands are not being drained by other adjacent activities (notably construction of additional
borrow areas as well as stormwater management facilities).
c) The proposed locations of the automatic recording rain gauges must be indicated in the report.
d) The plan must include and indicate a location for a control wetland for use when affirming
DRAINMOD calibrations.
e) The current plan shows that ditches bisect some of the borrow pits. The plan must clearly state how
these ditch inlets and outlets will be plugged in order prevent the borrow pits from discharging and
thereby potentially draining adjacent wetlands.
For future reference, please note that the Division will require compliance with N.C. Gen. Statute § 143-
215.51 et seq (the.Floodway Regulation) prior toyconstruction of the landfill as a condition of any 401 Water
Quality Certification that may be issued for this project. The Floodway Regulation prohibits landfills in 100-year
floodplains unless a variance is obtained pursuant to N.C. Gen, Statute § 143-215.54A. Please be aware that any
401 Certification will. be conditioned to require compliance with this state law.
By copy of this letter, we are requesting that the U. S..Army Corps of Engineers continue to place this project
on hold and not issue an Individual Permit for the subject project. If you would like to discuss any of these
matters, please call Danny Smith at [phone].
Sincerely,
cc:
File Copy
Division of Solid Waste - Sherri Coghill
Crime Control and Public Safety
Wilmington Regional Office, DWQ - Rick Shiver
Fayetteville Regional Office - Paul Rawls
Wetlands/ 401 Unit - Danny Smith
Kevin Martin, Soil and Environmental Consultants
Central Files
MARLOWE, DREITZLER & ASSOCIATES
Consulting Engineers

`. - 211 East Six Forks Road, Suite 203
Raleigh, N.C. 27609
October 31, 2002
Mr. Paul Rawls
Water Quality Regional Supervisor
Fayetteville Regional Office
NC Division of Water Quality
225 Green Street
Suite 714
Fayetteville, N.C. 28301-5043
919-834-1113
919-834-6060(Fax)
5 55'
VIE;LikNDS GROUP
WAI ER UALITY SECTION
Reference: Riegel Ridge MSW Landfill - Columbus County, North Carolina
September 20, 2002 Additional Information Request
Dear Mr. Rawls:
The following is a response to your specific request for Additional Information regarding the
Riegel Ridge Landfill 404 Permit Application to fill 0.69-acres of wetlands. Your request
letter was received via fax on September 20, 2002 and each of the issues detailed in your
letter is addressed below. Marlowe, Dreitzler and Associates has provided additional
information to aid the Division of Water Quality (DWQ) review, and in an effort to fully
address all DWQ concerns and questions on the following dates:
November 13, 2001
January 31, 2001
May 20, 2002
May 23, 2002
July 22, 2002
October 22, 2002
September 20, 2002 Request for Additional Information:
Compliance with State water quality standards for wetlands, surface waters, and
groundwater.
`In your response to DWQ's June 10, 2002 letter, you explained that the design of the final landfill liner
system, leachate collection and storage system, leachate disposal alternatives, landfill cap system and cap
maintenance, and the groundwater and surface water monitoring plans was not available. This information
is related to the protection of water quality standards as outlined in the 401 Certification rules. The
location of the leachate collection system as well as other items outlined above have potential to impact
additional waters. Additionally, the management of the leachate and stormwater must be performed in a
October 2002 1 Riegel Ridge Landfill
401 Certification
manner to assure the protection of water quality. Further information is required regarding the location
and design of these measures in order for the Division to be able to determine that water quality will be
protected. "
We met at the DWQ offices on Crabtree Boulevard in Raleigh, N.C. on September 24,
2002 for the purposes of reviewing the September 20, 2002 request for additional
information letter and to assure that an adequate and proper response would be made to
the Division's request. We discussed that detailed design information is available for the
landfill liner system, leachate collection and storage system, leachate disposal alternatives;
landfill cap system and cap maintenance, and the groundwater and surface water
monitoring plans. The intent of the June 10, 2002 letter was to clarify that these areas of
concern can not be permitted by the Division of Waste Management until after a 401/404
Permit is issued for the project.
Landfill Liner System: Sheet 15 of 22 from the 404 Application submitted to the Corps
of Engineers on October 15, 2001 and provided to the Division of Water Quality on
November 13, 2001 is a detail of the proposed landfill liner system. A copy of the detail
is included as Appendix A of this submittal. The liner system detailed is the standard
EPA Subtitle D minimum design including 2-feet of compacted clay with a permeability
of less than or equal to 1 X 10 (-7) cm/sec. On top of the clay liner is a 60-mil HDPE
geomembrane, then a geocomposite drainage layer and a protective soils layer. Solid
Watste Management rules require that the 60-mil HDPE geomembrane maintain a
minimum 4-foot separation from seasonal high groundwater elevations. To achieve this
separation, the Riegel Ridge Landfill will be what is referred to as an "above ground
landfill". Subgrade fill will be placed in the landfill footprint area to depths estimated at 3
to 6 feet prior to placement of the 2-feet of clay described above. Based on our meeting,
no additional information is required regarding the landfill liner system.
Leachate Collection and Storage System: Copies of Sheet 7 of 22 from the 404
Application were distributed to those attending the September 24, 2002 meeting. A copy
is included as Appendix B of this submittal. This sheet includes a landfill footprint plan
that shows the 5 proposed 5-year landfill cells with the leachate collection piping within
each 5-year cell. The size of the piping and the grades are indicated. In addition, the
sheet includes a typical section through the completed leachate collection pipe trench, a
plan view detail of the leachate collection sump area and a cross-section detail of the
leachate collection sump area indicating the sideslope riser pipe and the location of the
leachate submersible pumps. The plan view also indicates a perimeter leachate force
main which distributes the leachate pumped from the landfill cell areas to an above
ground storage tank. The location of the storage tanks has been moved since the October
15, 2001 submittal of this detail. During the meeting, the new location was pointed out on
the Stormwater Management Plan that was included with the July 22, 2002 submittal to
DWQ. The location of the above ground leachate storage tanks is completely outside the
100-year floodplain for the site and this is evident through review of the Stormwater
Management Plan. In addition, photographs of a "typical" leachate above ground storage
tank system were provided with the July 22, 2002 submittal and the photograph was
reviewed during our meeting. A copy of the photograph is included under Appendix B.
Additional leachate system design information was provided to the DWQ under the May
October 2002 2 Riegel Ridge Landfill
401 Certification
20, 2002 submittal and discussed at our meeting. Titan Atlantic prepared a Memorandum
indicating Help Model Results for the proposed landfill. These results can be used to
estimate leakage rates and collection rates for the leachate collection system. In addition,
the DWQ was provided under the May 20, 2002 submittal a copy of the Titan Atlantic
Riegel Ridge Landfill Contaminant Transport Model Report. This model is provided to
demonstrate the significant travel time associated with any contaminant that would bypass
the landfill liner and leachate collection system and to demonstrate the effectiveness that
would be afforded groundwater protection when coupled with the groundwater and
surface water monitoring system included with the Riegel Ridge design. Copies of the
Help Model Memorandum and the Contaminant Transport Model Report are also
included under Appendix B. Based on our meeting, no additional information regarding
the on-site leachate collection and storage system is required for this submittal.
Leachate Disposal Alternatives: The only outstanding issue after our meeting regarding
the leachate collection and storage design was the ultimate destination of the leachate for
disposal. The DWQ agreed that a final determination could not be made at this time and
further agreed that we would provide a few potential locations. These potential leachate
disposal locations include:
• Noble Oil
• Whiteville, NC Wastewater Treatment Facility
• Wilmington, NC Wastewater Treatment Facility
Use of any of these locations will include compliance with any pre-treatment
requirements established by the respective facility. These locations are provided as
examples only and no agreements are in place to deliver leachate from the Riegel Ridge
Landfill to any of the aforementioned locations.
Landfill Cap System and Cap Maintenance: Included in Appendix C of this submittal
is a detail of the proposed Landfill Cap System. The Cap System is required under the
Solid Waste Management Rules to be at a minimum equal to the Landfill Liner System.
The detail of the proposed Riegel Ridge Landfill Cap System shows a cross-section
indicating the liner system, waste placement area, cap system, outside slope benching,
slope drains, and the perimeter ditching.
As described on page 16 of the July 22, 2002 submittal to DWQ:
"Riegel Ridge, L.L.C. as the permitee with the Division of Waste Management, and holding the Permit to
Operate the landfill, will be the responsible party for all aspects of the landfill operations, closure and post-
closure activities. Section .1627 - Closure and Post-Closure Requirements for MSWLF Facilities, Section
.1628 - Financial Assurance Rule and .1629 - Closure and Post-Closure Plan, from the North Carolina
Solid Waste Management Rules must be complied with as part of the Permit to Operate the facility. These
Rules detail the closure and post-closure requirements mandated by the State, including maintenance
requirements."
As further clarification, as the permitee, Riegel Ridge, L.L.C. will be held responsible for
the Construction, Operation, Closure and the 30-year Post-Closure period of the landfill in
October 2002 3 Riegel Ridge Landfill
401 Certification
compliance with the .1627, .1628 and .1629 Rules. A copy of these Rules is included in
Appendix C of this submittal. The Division of Waste Management has the authority to
extend the 30-year post closure period if deemed appropriate based on the monitoring that
will have taken place during the post-closure time frame.
Groundwater and Surface Water Monitoring Plan: The complete Groundwater and
Surface Water Monitoring Plan is included within the Site Hydrogeological Report as was
submitted to the DWQ on November 13, 2001. A copy of the Groundwater and Surface
Water Monitoring Plan from the Site Hydrogeological Report is included as Appendix D
of this submittal.
At our September 24, 2002 meeting, the DWQ requested that I provide a summary of the
Groundwater Monitoring Rules as required by the North Carolina General Statutes for
Landfills. The details can be found under the .1600 Section of the North Carolina Solid
Waste Management Rules (15A NCAC 13B). The following apply:
.1630 Applicability of Groundwater Monitoring Requirements
.1631 Groundwater Monitoring Systems
.1632 Groundwater Sampling and Analysis Requirements
.1633 Detection Monitoring Program
.1634 Assessment Monitoring Program
.1635 Assessment of Corrective Measures
.1636 Selection of Remedy
.1637 Implementation of the Corrective Action Program
Each of the above Rules is included under Appendix D of this submittal. The first step for
a landfill applicant with regards to groundwater and surface water monitoring is to design
a monitoring plan meeting the minimum requirements of .1631 of the Solid Waste
Management Rules. This was completed for the Riegel Ridge Landfill and submitted to
the Division of Waste Management under Addendum No. 2 of the Site Hydrogeological
Report on May 9, 2001. The plan shows the proposed locations of upgradient monitoring
well locations for both the Construction and Demolition Debris disposal area and the
Municipal Solid Waste disposal area. In addition the plan indicates proposed
downgradient monitoring well locations and the proposed upgradient and downgradient
surface water sampling locations. Approval of the plan by the Division of Waste
Management will be a part of the "Permit to Construct". Prior to any placement of waste
within the facility, the Operator must establish a -background groundwater quality in
hydraulically upgradient or background wells for each of the monitoring constituents
required. The Rules offer five (5) statistical analysis methods. Once a "background" has
been established and is acceptable to the Division of Waste Management the landfill may
begin receiving waste and the Detection Monitoring Program goes into effect. Section
.1633(a) of the Solid Waste Management Rules establishes Appendix 1 of 40 CFR Part
258 as the basis for Detection Monitoring. Section .1633(b) of the Solid Waste
Management Rules establishes the sampling frequency as semi-annual during the life of
the landfill including the closure and post-closure periods. Appendix 1 of 40 CFR Part
258 of the Federal Register is included in Appendix D of this submittal.
October 2002 4 Riegel Ridge Landfill
401 Certification
If during the semi-annual sampling during landfill operations the Operator determines that
there is a statistically significant increase over background for one or more of the
Appendix 1 constituents, Assessment Monitoring shall be implemented. Assessment
Monitoring can also be triggered for any violation detected of the 15A NCAC 2L
standards. Section .1634(b) of the Solid Waste Management rules establishes Appendix II
of 40 CFR Part 258 of the Federal Register as the sampling constituents list for the.
Assessment Monitoring program. Appendix II of 40 CFR Part 258 is included in Apendix
D of this submittal. The Rule also sets forth procedures for establishing background for
the Appendix II constituents not included in Appendix I. If two consecutive sampling
periods show Appendix II constituents at or below background values then the Division
may allow the operator to return to Detection Monitoring. If the concentrations of any
Appendix II constituents are above background, but below the 2L standards, Assessment
Monitoring shall be required to continue. If during Assessment Monitoring one or more
of the constituents is found to be at statistically significant levels above groundwater
protection standards, procedures are established for the Assessment of Corrective
Measures. These procedures include a public hearing to discuss the proposed corrective
measures in a public forum. Once a public meeting has been held, the operator will
submit the selected corrective measure remedy to the Division of Waste Management for
review and approval. Section .1637 of the Solid Waste Management Rules sets forth the
procedures for implementing the Corrective Action Program.
The Groundwater and Surface Water Monitoring Plan proposed for the Riegel Ridge
Landfill includes a total of ten (10) shallow groundwater monitoring wells, seven (7) deep
groundwater monitoring wells and three (3) surface water sampling locations. A map
indicating the location of each of the wells is included with the Groundwater Monitoring
Plan (reference Appendix D).
Based on my understanding of our discussions during our September 24, 2002 meeting,
submittal of this information represents the additional information requested in Item 1 of
the September 20, 2002 letter from DWQ.
2. Protection of downstream water quality standards through the use of on-site
stormwater control measures.
"The information submitted by Riegel Ridge, L.L. C. is insufficient to enable the Division to determine that
"downstream water quality standards will be protected through the use of on-site stormwater control
measures" pursuant to 15A NCAC 2H.0506(b)(5) and (c)(5). In your July 22, 2002 letter, Riegel Ridge,
L.L. C. did not account for the landfill cap as an impervious surface. Since the whole purpose of the cap is
to prevent (or severely restrict) infiltration, the landfill is thereby impervious. When the landfill is included
in the impervious surface area, there will be a significant amount of stormwater runoff that must be
managed to assure water quality standards are not violated.
Riegel Ridge must provide a site plan in sufficient detail to assure DWQ that stormwater can be adequately
managed on-site to protect downstream water quality. Please address this underlying issue as well as the
broader design and engineering issues outlined below:
October 2002 5 Riegel Ridge Landfill
401 Certification
During our September 24, 2002 meeting we reviewed in detail the Stormwater
Management Plan that was included under Attachment H of the July 22, 2002 submittal of
additional information to the DWQ. It was determined during our review that while the
Plan included many of the stormwater management structures referenced by DWQ; the
Plan needed to be taken to a "final" design level for eventual approval by DWQ. The
DWQ noted that approval of the Stormwater Management Plan would be a condition of
any 401 Certification issued for the project. In addition, the DWQ stated that final
approval of the Plan was not required by the December 17, 2002 deadline, as it would be
a conditional item. Refer to Appendix F of this submittal package for the complete
Stormwater Management Plan ,for the Riegel Ridge Landfill. The submittal includes a
Site Plan, Ditch Profile Sheet and Construction Details. In addition, find included a
complete copy of the engineering computations including a summary sheet of design
results.
* The location of and approximate size of on-site stormwater measures of sufficient size to provide removal
of total suspended solids and other associated pollutants in order to protect water quality standards. These
facilities must be designed to meet the criteria outlined in the most recent version of D WQ s Stormwater
Deign Manual.
The proposed Stormwater Management Plan as detailed in Appendix F of this submittal
package has been designed within the guidelines of the DWQ's Stormwater Design
Manual. The Riegel Ridge Landfill Stormwater ..Management Plan is specifically
designed to maximize the protection of the waters, of the United States. The Plan
combines the features of Stormwater Management and Erosion/Sedimentation Control
and the use of level spreaders to direct clean surface waters into on-site wetland areas. In
summary, the key element of the Plan is a perimeter trapezoidal ditch around the 107-acre
landfill footprint. The ditch width varies, but can be generally described as 60-65 feet
across the bottom with 2:1 side slopes. The design includes a West Ditch, East Ditch and
South Ditch. The western ditch collects the most runoff and discharges into a man-made
ditch, which leaves the site under. Tram Road. The western ditch is comprised of a series
of 7 retention basins, each of which discharges into the other in series. To maximize
retention time and thus solids settlement, guidelines suggest a 2:1 basin length to with
ratio. This design offers a length to width ratio from a low of 3:1 to a high of nearly 24:1
allowing for maximum efficiency in terms of TSS removal. The discharge from Basin 7
flows to a level spreader, which disperses the flow across an approximately 350-foot long
level spreader that discharges into an on-site ditch. Flow is then directed under Tram
Road and along an off-site ditch until the ultimate discharge into the Honey Island
Swamp. The series of 7 retention basins and then the level spreader design will provide
significant protection of downstream waters.
The eastern ditch includes a series of 3 retention basins, each of which discharges into the
other in series. Similar to the western ditch, these basins offer length to width ratios in
excess of the 2:1 minimum recommended for efficient solids settlement. In addition, the
discharge from the 3rd retention basin flows to a level spreader that disperses the runoff
into on-site wetlands. Again, the use of 3 retention basins in series with length to width
ratios allowing for the maximization of TSS removal, then the use of a level spreader
October 2002 6 Riegel Ridge Landfill
401 Certification
design to disperse the runoff into existing on-site wetlands offers a design which protects
downstream waters.
The southern ditch collects the smallest area of runoff and is designed as a single retention
structure. This retention basin also discharges to a level spreader, which disperses flows
and discharges into an existing on-site wetland. Exhibit F of this submittal package
includes the Design Drawings and Computations for the proposed Stormwater
Management Plan. With the utilization of 11 separate retention basins and 3 separate
level spreaders, the Plan not only provides for post-development discharges below pre-
development rates, the Plan also provides for protection of the waters of the United States
in excess of the minimum requirements of the Division of Water Quality Stormw?ter
Design Manual and the minimum requirements of the Land Quality Section of the
Department of Environment and Natural Resources.
* These facilities must be designed to provide stormwater discharge rates for the 2, S and 10 year
discharges equal to or less than the pre-developed 2, S and 10 year discharge rates respectively in order to
protect downstream bank stability.
Refer to the engineering computations under Appendix F of this submittal package. Each
of the stormwater retention basins was routed for the 2, 5 and 10-year storm events. The
stormwater plan includes discharges over level spreaders at three separate locations. Two
of the locations discharge into existing on-site wetland areas meeting the
recommendations of the - DWQ. The third location discharges into the existing
jurisdictional ditch at the southern end of the site. Since the ditch bottom is jurisdictional,
we have included a level spreader design at this location to prevent the possibility of
- future erosion in the existing ditch. In addition, the post-development discharge into the
storm pipe under Tram Road has been kept to below pre-development discharge rates. It
should be noted that the travel path for the discharge point under Tram road includes
approximately 2,500 linear feet of man-made ditch installed by International Paper during
a time frame that is estimated to be in the late 1960's. The ditch extends through
International Paper lands and discharges into the expansive Honey Island Swamp were
flow rates far exceed that provided by the discharges from the Riegel Ridge site.
* Stormwater control structure operation and maintenance. The plan must identify the entity/individual
responsible for maintenance of the stormwater control structures during the 30 years active life of the
landfill, as well as the 30 years period post landfall closure.
A note has been added to Sheet 1 of the Stormwater Management Plan to specify Riegel
Ridge, LLC as the entity that will be responsible for maintenance of the stormwater
control structures during the 30-year active life of the landfill, as well as the 30-year post
closure period.
* The plan must identify the location of all control structures, as well as all jurisdictional wetlands and
waters. The plan must also indicate the location of all ou falls and specifically identify the type of receiving
feature, ie ditches, wetlands, streams, etc. In this regard, it may be possible to rehydrate locations on-site,
which are not jurisdictional wetlands today due to past silvicultural practices. DWQ would encourage this
practice on this site where feasible.
October 2002 7 Riegel Ridge Landfill
401 Certification
Refer to Sheet 1 of the Stormwater Management plan included under Appendix F of this
submittal package. The key control structures for the landfill are a series of stormwater
retention ponds, which discharge at three separate locations. Two of the discharge points
are into on-site wetland areas and the third location discharges into a jurisdictional
wetland ditch that does leave the site. All three discharge points include level spreader
designs. The settlement that will be achieved by the series of retention structures prior to
the level spreaders will yield TSS removals in excess of DWQ minimum standards. The
recommended minimum length to width ration for achieving adequate settlement is 2:1.
The Riegel Ridge design will employ ratios ranging from low of 3:1 to as much as 24:1.
* Please be aware that a condition of any possible 401 Certification for this project will be that a final
stormwater plan must be approved by DWQ before any impact to waters occurs on this site.
This condition has been duly noted.
3. Assurance that the project will minimize adverse impacts to wetlands and surface
waters.
DWQ is concerned that the activities at the landfill, particularly the excavation of borrow pits, will
adversely affect the wetland hydrology. To alleviate that concern, DWQ requested a Wetland Monitoring
Plan for the Landfill. The Wetland Monitoring Plan submitted on July 19, 2002 while an improvement over
previous submittals is still deficient in several aspects. The items. that were found to be deficient are:
a) The monitoring plan did not include sufficient wells to document whether the proposed activities would
result in the wetland hydrology being concentrically diminished. Additional wells are necessary.
During our meeting with the DWQ on September 24, 2002 we reviewed the Wetlands
Monitoring Plan. The DWQ staff provided nine (9) additional monitoring well
locations to be added to the proposed plan. Refer to Appendix E for a copy of the
revised Wetlands Monitoring Plan with the additional well locations as requested by
the DWQ.
b) Riegel Ridge, L.L.C. proposed to discontinue monitoring of the wetlands located adjacent to borrow
pits that remained jurisdictional five years after borrow activity ceased. This is unacceptable to DWQ
unless Riegel Ridge, L.L.C. can propose an acceptable alternative methodology for assuring DWQ that
the wetlands are not being drained by other adjacent activities (notably construction of additional
borrow areas as well as stormwater management facilities).
The intent of the language was to allow a mechanism for the elimination of the
monitoring activities if warranted. As per the request of the DWQ the language in the
last paragraph of page 4 of the Wetlands Monitoring Plan has been revised to
eliminate the five year window. Refer to Appendix E for a copy of the revised
Wetlands Monitoring Plan.
c) The proposed locations of the automatic recording rain gauges must be indicated in the report.
Refer to Appendix E for a copy of the revised Wetlands Monitoring Plan. The rain
gauge locations have been added to the Site Plan.
October 2002 8 Riegel Ridge Landfill
401 Certification
d) The plan must include and indicate a location for a control wetland for use when affirming
DRAINMOD calibrations.
Refer to Appendix E for a copy of the revised Wetlands Monitoring Plan. The revised
Site Plan includes the location of 11 separate Control Wells. In addition, the Plan calls
for these 11 Control Wells to be installed at the time of receipt of a 404 Permit
allowing for significant background data to be accumulated prior to any borrow
activities taking place. The issue of control wells was discussed in length at our
September 24, 2002 meeting with the DWQ. At the meeting, all parties concurred that
the most accurate way to monitor on-site wetlands adjacent to borrow activities was to
model each wetland area independently. While this adds considerable expense and
requires 11 control wells to be installed in advance of permitting by the Division of
Waste Management, this approach will offer the most accurate monitoring.
In addition, a lengthy discussion was held at our September 24, 2002 meeting
regarding the use of DRAINMOD. The DWQ was not prepared at the time of the
meeting to accept the use of DRAINMOD as the preferred method for determining if
wetland impacts have taken place and/or what caused the wetland impacts.
e) The current plan shows that ditches bisect some of the borrow pits. The plan must clearly state how
these ditch inlets and outlets will be plugged in order to prevent the borrow pits from discharging and
thereby potentially draining adjacent wetlands.
Refer to the drawing included as Appendix G of this submittal package. A
comprehensive field evaluation of the topographic anomalies was completed on
October 28, 2002. The Appendix G drawing is highlighted to indicate four basic
features which exist on site:
A. Logging Access Roads (yellow)
B. Secondary Site Access Paths (green)
C. Logging Industry Fire Lines (red)
D. Drainage Ditches (blue)
The Logging Access Roads include excavated roadway side ditches, which vary in
depths from 6-inches to an estimated 3-feet depending on the specific location. While
it appears that in all instances these roadway side ditches are above seasonal high
groundwater elevations, the Wetlands Monitoring Plan has been revised to include a
note specifying that ALL ditches bisecting the downstream side of a borrow activity
will be filled for a minimum of 25-feet beyond the borrow site border to assure that
the drainage feature does not allow for any discharge from the borrow site. The
secondary site access paths are simply grass paths used to access property. They are
suitable for off-road or 4-wheel drive vehicles only and do not include any side
ditches. The fire lines indicated are old features and no ditching was observed related
to these lines. The main drainage ditches for the site are incorporated within the
Stormwater Management Plan as is evidenced in Appendix F of this submittal
package.
October 2002 9 Riegel Ridge Landfill
7 401 Certification
APPENDIX A
October 2002 10 Riegel Ridge Landfill
401 Certification
LANDFILL LINER DETAIL

October 2002 11 Riegel Ridge Landfill
401 Certification
? r
>_ y
Certified Mail
Return Receipt Requested
Riegel Ridge, LLC
C/o William W. Dreitzler
211 East Six Forks Road, Suite 203
Raleigh, NC 27609
Dear Mr. Dreitzler:
September 20, 2002
Subject: Request for additional information
Riegel Ridge Landfill
DWQ 011680
Columbus County
The Division of Water Quality (DWQ) received Riegel Ridge, LLC's request for a 401 Water Quality
Certification on December 17, 2001. On April 18, 2002, DWQ held a public hearing on the application. By letter
dated June 10, 2002 DWQ requested additional information for review of the 401 Certification application.
Riegel Ridge, LLC responded to DWQ's additional information request by letter dated July 22, 2002.
We have reviewed the July 22, 2002 response and determined that Riegel Ridge, LLC has not yet provided
sufficient information to enable the Division to issue a 401 Water Quality Certification which states that the
project will comply with State water quality standards and 15A NCAC 2H .0506. Therefore this application will
remain on hold pending the receipt of the additional information outlined below.
This information must be received by DWQ for review by November 1, 2002. The one-year period for state
action provided in the Clean Water Act expires as of December 17, 2001. If DWQ does not receive the additional
information outlined below by November 1, 2002, then DWQ will be prepared to deny the 401 Water Quality
Certification for this project in order not to waive its right to issue a 401 Certification for this project.
The Riegel Ridge, LLC 401 application is still deficient in the following respects:
1. Compliance with State water quality standards for wetlands, surface waters, and groundwater.
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
In your response to DWQ's June 10, 2002 letter, your explained that the design of the final landfill liner
system, leachate collection and storage system, leachate disposal alternatives, landfill cap system and cap
maintenance, and the groundwater and surface - water monitoring plans was not available. This
information is related to the protection of water quality standards as outlined in the 401 Certification
rules. The location of the leachate collection system as well as other items outlined above have potential
to impact additional waters. Additionally, the management of the leachate and stormwater must be
performed in a manner to assure the protection of water quality. Further information is required regarding
the location and design of these measures in order for the Division to be able to determine that water
quality will be protected.
I. C. Division of Water Quality, 401 Wetlands Certification Unit,
X50 Mail Service Center, Raleigh, NC 27699-1650 (Mailing Address)
`I Crabtree Blvd., Raleigh, NC 27604-2260 (Location)
`) 733-1786 (phone), 919-733-6893 (fax), (http://h2o.enr.state.nc.us/ncwetlands

2. Protection of downstream water quality standards through the use of on-site stormwater control
measures.
The information submitted by Riegel Ridge, LLC is insufficient to enable the Division to determine that
"downstream water quality standards will be protected through the use of on-site stormwater control
measures" pursuant to 15A NCAC 2H.0506(b)(5) and (c)(5). In your July 22, 2002 letter, Riegel Ridge,
LLC did not account for the landfill cap as an impervious surface. Since the whole purpose of the cap is
to prevent (or severely restrict) infiltration, the landfill is thereby impervious. When the landfill is
included in the impervious surface area, there will be a significant amount of stormwater runoff that must
be managed to assure water quality standards are not violated.
Riegel Ridge must provide a site plan in sufficient detail to assure DWQ that stormwater can be
adequately managed on-site to protect downstream water quality. Please address this underlying issue as
well as the broader design and engineering issues outlined below:
• The location and approximate size of on-site stormwater measures of sufficient size to provide
removal of total suspended solids and other associated pollutants in order to protect water quality
standards. These facilities must be designed to meet the criteria outlined in the most recent version of
DWQ's Stormwater Design Manual.
• These facilities must be designed to provide stormwater discharge rates for the 2, 5, and 10-year
discharges equal to or less than the pre-developed 2, 5, and 10-year discharge rates respectively in
order to protect downstream bank stability.
• Stormwater control structure operation and maintenance. The plan must identify the entity/individual
responsible for maintenance of the stormwater control structures during the 30-years active life of the
landfill, as well as the 30-years period post- landfill closure.
• The plan must identify the location of all control structures, as well as all jurisdictional wetlands and
waters. The plan must also indicate the location of all outfalls and specifically identify the type of
receiving feature, i.e. ditches, wetlands, streams, etc. In this regard, it may be possible to rehydrate
locations on-site, which are not jurisdictional wetlands today due to past silvicultural practices. DWQ
would encourage this practice on this site where feasible.
• Please be aware that a condition of any possible 401 Certification for this project will be that a final
stormwater plan must be approved by DWQ before any impact to waters occurs on this site.
3. Assurance that the project will minimize adverse impacts to wetlands and surface waters.
DWQ is concerned that the activities at the landfill, particularly the excavation of borrow pits, will
adversely affect the wetland hydrology. To alleviate that concern, DWQ requested a Wetland Monitoring
Plan for the Landfill. The Wetland Monitoring Plan submitted on July 19, 2002 while an improvement
over previous submittals is still deficient in several aspects. The items that were found to be deficient are:
a) The monitoring plan did not include sufficient wells to document whether the proposed activities
would result in the wetland hydrology being concentrically diminished. Additional wells are
necessary.
b) Riegel Ridge, LLC proposed to discontinue monitoring of the wetlands located adjacent to borrow
pits that remained jurisdictional five years after borrow activity ceased. This is unacceptable to DWQ
unless Riegel Ridge, LLC can propose an acceptable alternative methodology for assuring DWQ that

2 '?

the wetlands are not being drained by other adjacent activities (notably construction of additional
borrow areas as well as stormwater management facilities).
c) The proposed locations of the automatic recording rain gauges must be indicated in the report.
d) The plan must include and indicate a location for a control wetland for use when affirming
DRAINMOD calibrations.
e) The current plan shows that ditches bisect some of the borrow pits. The plan must clearly state how
these ditch inlets and outlets will be plugged in order prevent the borrow pits from discharging and
thereby potentially draining adjacent wetlands.
For future reference, please note that the Division will require compliance with N.C. Gen. Statute § 143-
215.51 et seq (the Floodway Regulation) prior to construction of the landfill as a condition of any 401 Water
Quality Certification that may be issued for this project. The Floodway Regulation prohibits landfills in 100-year
floodplains unless a variance is obtained pursuant to N.C. Gen. Statute § 143-215.54A. Please be aware that any
401 Certification will be conditioned to require compliance with this state law.
By copy of this letter, we are requesting that the U. S.. Army Corps of Engineers continue to place this project
on hold and not issue an Individual Permit for the subject project. If you would like to discuss any of these
matters, please call Danny Smith at [phone].
Sincerely,

cc
File Copy
Division of Solid Waste - Sherri Coghill
Crime Control and Public Safety
Wilmington Regional Office, DWQ - Rick Shiver
Fayetteville Regional Office - Paul Rawls
Wetlands/ 401 Unit - Danny Smith
Kevin Martin, Soil and Environmental Consultants
Central Files
3
W A TF Michael F. Easley, Governor
O 9QG William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Cn Alan W. Klimek, P.E., Director
> L) --i Division of Water Quality
September 20, 2002 fns (?s 4
i
Certified Mail
Return Receipt Requested
Riegel Ridge LLC `
Yo'E sU"t^, 9 5 G2G?J?
C/o William W. Dreitzler WATU", ?ilry+'_ITY Sr+ ^h?
211 East Six Forks Road, Suite 203
Raleigh, NC 27609
Subject: Request for additional information
Riegel Ridge Landfill
DWQ 011680
Columbus County
Dear Mr. Dreitzler:
The Division of Water Quality (DWQ) received Riegel Ridge, LLC's request for a 401 Water Quality
Certification on December 17, 2001. On April 18, 2002, DWQ held a public hearing on the application. By letter
dated June 10, 2002 DWQ requested additional information for review of the 401 Certification application.
Riegel Ridge, LLC responded to DWQ's additional information request by letter dated July 22, 2002.
We have reviewed the July 22, 2002 response and determined that Riegel Ridge, LLC has not yet provided
sufficient information to enable the Division to issue a 401 Water Quality Certification which states that the
project will comply with State water quality standards and 15A NCAC 2H .0506. 'therefore this application will
remain on hold pending the receipt of the additional information outlined below.
This information must be received by DWQ for review by November 1, 2002. The one-year period for state
action provided in the Clean Water Act expires as of December 17, 2001. If DWQ does not receive the additional
information outlined below by November 1, 2002, then DWQ will be prepared to deny the 401 Water Quality
Certification for this project in order not to waive its right to issue a 401 Certification for this project.
The Riegel Ridge, LLC 401 application is still deficient in the following respects:
1. Compliance with State water quality standards for wetlands; surface waters, and groundwater.
In your response to DWQ's June 10, 2002 letter, your explained that the design of the final landfill liner
system, leachate collection and storage system, leachate disposal alternatives, landfill cap system and cap
maintenance, and the groundwater and surface water monitoring plans was not available. This
information is related to the protection of water quality standards as outlined in the 401 Certification
rules. The location of the leachate collection system as well as other items outlined above have potential
to impact additional waters. Additionally, the management of the leachate and stormwater must be
performed in a manner to assure the protection of water quality. Further information is required regarding
the location and design of these measures in order for the Division to be able to determine that water
quality will be protected.
NODE rN>
N. C. Division of Water Quality, 401 Wetlands Certification Unit,
1650 Mail Service Center, Raleigh, NC 27699-1650 (Mailing Address)
2321 Crabtree Blvd., Raleigh, NC 27604-2260 (Location)
(919) 7334786 (phone), 919-733-6893 (fax), (http://h2o.enr.state.nc.us/ncwetlands
2. Protection of downstream water quality standards through the use of on-site stormwater control
measures.
The information submitted by Riegel Ridge, LLC is insufficient to enable the Division to determine that
"downstream water quality standards will be protected through the use of on-site stormwater control
measures" pursuant to 15A NCAC 2H .0506(b)(5) and (c)(5). In your July 22, 2002 letter, Riegel Ridge,
LLC did not account for the landfill cap as an impervious surface. Since the whole purpose of the cap is
to prevent (or severely restrict) infiltration, the landfill is thereby impervious. When the landfill is
included in the impervious surface area, there will be a significant amount of stormwater runoff that must
be managed to assure water quality standards are not violated.
Riegel Ridge must provide a site plan in sufficient detail to assure DWQ that stormwater can be
adequately managed on-site to protect downstream water quality. Please address this underlying issue as
well as the broader design and engineering issues outlined below:
• The location and approximate size of on-site stormwater measures of sufficient size to provide
removal of total suspended solids and other associated pollutants in order to protect water quality
standards. These facilities must be designed to meet the criteria outlined in the most recent version of
DWQ's Stormwater Design Manual.
• These facilities must be designed to provide stormwater discharge rates for the 2, 5, and 10-year
discharges equal to or less than the pre-developed 2, 5, and 10-year discharge rates respectively in
order to protect downstream bank stability.
• Stormwater control structure operation and maintenance. The plan must identify the entity/individual
responsible for maintenance of the stormwater control structures during the 30-years active life of the
landfill, as well as the 30-years period post- landfill closure.
• The plan must identify the location of all control structures, as well as all jurisdictional wetlands and
waters. The plan must also indicate the location of all outfalls and specifically identify the type of
receiving feature, i.e. ditches, wetlands, streams, etc. In this regard, it may be possible to rehydrate
locations on-site, which are not jurisdictional wetlands today due to past silvicultural practices. DWQ
would encourage this practice on this site where feasible.
• Please be aware that a condition of any possible 401 Certification for this project will be that a final
stormwater plan must be approved by DWQ before any impact to waters occurs on this site.
3. Assurance that the project will minimize adverse impacts to wetlands and surface waters.
DWQ is concerned that the activities at the landfill, particularly the excavation of borrow pits, will
adversely affect the wetland hydrology. To alleviate that concern, DWQ requested a Wetland Monitoring
Plan for the Landfill. The Wetland Monitoring Plan submitted on July 19, 2002 while an improvement
over previous submittals is still deficient in several aspects. The items that were found to be deficient are:
a) The monitoring plan did not include sufficient wells to document whether the proposed activities
would result in the wetland hydrology being concentrically diminished. Additional wells are
necessary.
b) Riegel Ridge, LLC proposed to discontinue monitoring of the wetlands located adjacent to borrow
pits that remained jurisdictional five years after borrow activity ceased. This is unacceptable to DWQ
unless Riegel Ridge, LLC can propose an acceptable alternative methodology for assuring DWQ that
2
the wetlands are not being drained by other adjacent activities (notably construction of additional
borrow areas as well as stormwater management facilities).
c) The proposed locations of the automatic recording rain gauges must be indicated in the report.
d) The plan must include and indicate a location for a control wetland for use when affirming
DRAINMOD calibrations.
e) The current plan shows that ditches bisect some of the borrow pits. The plan must clearly state how
these ditch inlets and outlets will be plugged in order prevent the borrow pits from discharging and
thereby potentially draining adjacent wetlands.
For future reference, please note that the Division will require compliance with N.C. Gen. Statute § 143-
215.51 et seq (the Floodway Regulation) prior to construction of the landfill as a condition of any 401 Water
Quality Certification that may be issued for this project. The Floodway Regulation prohibits landfills in 100-year
floodplains unless a variance is obtained pursuant to N.C. Gen. Statute § 143-215.54A. Please be aware that any
401 Certification will be conditioned to require compliance with this state law.
By copy of this letter, we are requesting that the U. S. Army Corps of Engineers continue to place this project
on hold and not issue an Individual Permit for the subject project. If you would like to discuss any of these
matters, please call Danny Smith at [phone].
Sincerely,
cc: File Copy
Division of Solid Waste - Sherri Coghill
Crime Control and Public Safety
Wilmington Regional Office, DWQ - Rick Shiver
Fayetteville Regional Office - Paul Rawls
Wetlands/ 401 Unit - Danny Smith
Kevin Martin, Soil and Environmental Consultants
Central Files
3
A
FEB.13.2003
-i
W-3)
9:51AM u NCDENR WIRD
Certified Mail
Return Receipt Requested

Riegel Ridge, LLC
C/o William W. Dreitzler ~' f 1
211 East Six Forks Road, Sui ?e 203 '`-
Raleigh, NC 27609
Re: Riogei Ridge Landfill, C lumlibus County, North Carolina
DWQ Project No. 01168 ; US Army Corps of Engineers ID No. 200100853
Dear NU. Dreitzler. 11
d hereto is a copy of Iraication No. 3406 issued to Riegel Ridge, LLC in c/o William W. Dreitzler
Attache
dated December 16, 2002. If we can be of further assistance, do not hesitate-to contact us.
i
i Sincerely,
4
{ Alan W. Klimek, P.E., Director
Division of Water Quality
Attachments
DWQ 01 1680 ,
cc; U.S. Array Corps of Eriglpeers, Wilmington Regulatory Field Office
DWQ, Fayetteville Regional Office - Paul Rawls
DWQ, Wilmington Regional Office - Noelle Lutheran
DWQ, Wetlands/401 Unit i Danny Spaith .
MR, Wilmington Region Office -- Dan Sams
File Copy
Central files
Division of Solid Waste- S erri Coghill
Crime Control and Public afety
Interested Citizens from lic Dearing
.1. C, Division of Water Qpahty, 401 Wetlands
1650 Mail Service Center, Raleigh, NC 27699-
?321 Cmbtrca Blvd., ltaleiglt, NC 27604-22611
919) 733-1786 (phone). 919.733-6893 00x), Q
@cadon l;ln %
(Mailing Address)
us/nmedands
N0.626 P.2
Michael R Dsley, Governor
William G. Ross Jr., Secretary
Nonh Carolilaa Departmcnt of Environment and NatuN Resources
Alan W. Klimek, P.E., Director
DivisicM Of Water Quality

FEB.13.2003 9:52AM NGDENR WIRO
NO. 626 P.3
This certification is issued in conformity, with the requirements of Section 401 Public
Laws 92-500 and 95-211 of the United States and subject to the North Carolina Division
of Water Quality (DWQ Regulations in 15A NCAC 21-L Section .0500 to Riegel Ridge,
LLC (in c/o William W. Dreitzler), resulting in the discharge of fill into 0,69 acres of
jurisdictional wetlands and waters associated with the construction of a 107 acre
municipal solid waste la dfill in Columbus County, North Carolina, pursuant to an
amended application in he form of the Corps Public Notice received on the 17th day of
December, 2001. The a placation and subsequent amendments to the application on May
23, 2002, July 22, 2002, October 22, 2002 and November 1, 2002 which include
stormwater managemen, avian management, wetland monitoring and groundwater
monitoring plan proposals.
The application proldes adequate assurance that the proposed work will not result in
a violation of applicable Water Quality Standards and discharge guidelines. Therefore
the State of North Carolina certifies that this activity yvill not violate the applicable
portions of Section 301, 342, 303, 306, 307 of PL 92-500 and PL 95-217 if conducted in
accordance with the apOication and conditions hereinafter set forth.
This approval is onl valid for the purposes and design that you submitted (and
modified) in your amen ed application in the form of the Corps of Engineer's Public
Notice received on the 17th day of December, 2001 and amended on May 23, 2002, July
22, 2002, October 22, 2002, November 1, 2002 and as conditioned below. If you change
your project, you must notify the Central Office of Division of Water Quality in writing
and may be required s d the Central Office of the Division of Water Quality an
application for a new c 'fication. If Riegel Ridge, LLC is sold or if the name of the
LLC is changed, or the rgperty is sold, you must notify the Central Office and the
Wilmington Regional eld Office of the Division of Water Quality in writing, and the
new owner of the LLC d/or property must be given a copy of the Certification,
approval letter, all necessary supplementary information detailed in the application and
subsequent amendmentp, and is thereby responsible for complying with all conditions of
this Certification. Shoqld wetlands fill be. requested in the future, additional
compensatory mitigation may be required as described in 15A NGAC 2H.0506 (h)(6)
and (7). For this approval to be valid, you must follow the conditions listed below. In
addition, you should get any other federal, state or local permits before you go ahead with
your project including ut not limited to) Solid Waste, Erosion and Sediment Control
Permit, Floodplain Lan ill Siting Variance (pursuant to NCGS 143-215.54) Coastal
Stormwater Permit, an Non- scharge Permit.
Conditions of Certi ication:
1. During the fl of construction and duration of the time the facility receives
waste, approp iatte sediment and erosion control practices in order to assure
compliance wi- h the appropriate water quality standards must be
implemented:
FEB.13.2003 9:52AM w NCDENR WIRO NO.626
3
A) At no time shall ?the discharge(s) from this site cause violations of surface water
standards.
B)
C)
11.
Appropriate se 'meet and erosion control practices which equal or exceed
those outlined the most recent version of two mapuals, either the "North
Carolina Sedim `nt and Erosion Control Planning and Design Manual" or the
"forth CarolinalSurface Mining Manual" (available from the Division of
Land resources in the DEHNR Regional or Central Offices). The control
practices shall be utilized to prevent exceedances of the appropriate turbidity
water quality st*tdard (50 K Ws in all fresh water streams and rivers not
designated as trout waters; 25 NTUs in all lakes and reservoirs, and all
saltwater classes and 10 NTUs in trout waters);
Sufficient materials required for stabilization and/or repair of erosion control
measures and stgrmwawr routing and treatment shall be on site at all times.
Monitoring of s ace water parameters of the receiving waters is required as a
condition of this Certification. If surface water monitoring reveals water duality of
degradation or r veals that there has been loss of intended usage as determined by
either Riegel Ri ge, LLC or the Division of Water Quality, then a Corrective
Action Plan (CAMP) must be developed and submitted to DWQ within 60 days of
the determinatio . Upon first discovering that waters and/or wetlands have water
quality degrade on or loss of intended uses, Riegel Ridge, LLC shall notify the
DWQ Wilmingt n Regional Office, This notification shall be within 24 hrs of
first knowledge sir the first business day thereafter and shall include a detailed
explanation of the nature of the problem., Also, Riegel Ridge, LLC shall provide
ation, in writing, within 5 business days of the first knowledge of
follow-up notifii
the problem. A. Prior to start f construction, a "surface water monitoring plan" must be
provided to the Division of Water Quality. Riegel Ridge, LLC must receive
written approval for the plan by DWQ before any wetlands or waters are
impacted
a) Sample/ monitoring station locations must be developed for every
discharg outfall located on the site. The first station must be down slope
from the utfall. The second station must be approximately halfway
between the outfall and its confluence with ]`Toney Island Swamp. These
sample locations must be depicted within the final monitoring plan.
b) Samplin? from each of station must minimally include pre-construction
data eollTted for a minimum period of six months prior to the begin of
constructjon.
c) Sampling from each monitoring station must at a minimum include the
following:
P.4
FEB.13.2003 9:52AM u NCDENR WIRO N0.626 P.5
4
-COD (fr quency monthly)
-Fecal CTform (frequency monthly)
rGrease alid Oil (frequency monthly)
-Turbidity (frequency monthly)
-Dissolved Oxygen (frequency monthly)
-Conductivity (frequency monthly)
-Annual Pollutant Analysis Monitoring -ADAM (frequency annual-
outfall 10 ations only - see attached)
d) Samplin from receiving Waters up slope from Tram Road, must at a
rninimu ' include the following:
-width an depth ratio (sampling frequency - annual);
-depth of atural sediment/organic matter accumulation(sampling
frequenc quarterly);
-depth oflaggraded sediment from construction activities, and presence of
debris/ h within and adjacent to the receiving feature (sampling
frequenc -quarterly); data
concurrent digital photographs must accompany monitoring
collection and be submitted with the respective monitoring results.
-All testJ(where applicable) must be performed by DENR certified
laboratories,
e, It is a r irement of this Certification that this facility apply for and
secure NFDES Permit to Discharge Stormwater as required for
Landfills that are permitted by the North Carolina Division of Solid Waste
Management prior to initiation of construction.
f. It is a requirement of this Certification that in addition to the above-
menti*d sampling, this facility trust maintain full compliance with all of
the NPDPS Permit conditions required for this facility.
S, All samples collected from, the monitoring required above, must be
reported 4s a part of this Certification and included in any NPDES
monitoring reports...: ......
h. A condition of this Certification is that leachate must be properly
collected and contained. Also, all of the proper permits must be secured
and compliance with all permits must be maintained with respect to the
disposal and transport of leachate.
M) Monitoring of wetlands is required as a. condition of this Certification. If wetland
impacts are determined to have occurred, which can include indications of
instability, erodi g, sloughing, or removal of the hydrology, as determined by
Riegel Ridge, L C or the Division of Water Quality, then a Corrective Action
Plan must be de eloped within 60 days of the determination. If wetlands have
been impacted, Riegel Ridge, LX.C shall notify the DWQ Wilmington Regional
h
FEB.13.2003 9:52AM I NCDENR WIRD N0.626 P.6
i
5
Office. This notification shall be within 24 hrs of first knowledge or the first
business day theieafter and shall include a detailed explanation of the nature of
the problem.
determined to be impacted (beyond impacts that are authorized
A. Tf wetlands a£e
by this Certification) mitigation as described in 15A NCAC 2H.0506 is
required and the continued excavatiQn/minirig of on site borrow materials will
be suspended until DWQ approves an on-site restoration or mitigation plan.
B. Prior to start f construction, a "wetland monitoring plan" must be provided to
the Division f Water Quality and Riegel Bridge, LLC must receive written
approval for he plan by DWQ. The monitoring plan must satisfactorily
address how ?t will be determined whether wetlands draining will occur,
Wetland or Water impact may not occur until Riegel Midge, LLC receives
written approval from DWQ for this plan.
a. The wetland monitoring plan submitted on November 1, 2002, must be
revised t4 additionally include the following:
PhysicallMonitoring for eroding or sloughing of the wetland (monitoring
frequenct- annual)
,A schedule and account of when the ditches that currently bisect
proposed borrow sites will be plugged (e.g. within 90 days).
-Within flie monitoring plan, the above-mentioned plugs must also be
inspect to ensure they are stable and not failing. This review must be
included ithin the annual wetland monitoring report.
-Wells a depicted irk the November 1, 2002 monitoring plan proposal
must be i stalled and properly maintained throughout the active life of the
landfill.
-A requirfinent of the monitoring plan includes that well data must be
provided lannually to DWQ along with a written account of the
hydrological status of the wetlands on the tract. This includes each
wetland polygom (and a U wells) as indicated on the November _1, 2002-
-monitoring plan. _^=-------
b. The initiation of data collection (including rainfall data) must begin within
90 days c? issuance of this Certification or the issuance of the 404 Permit,
which is later.
i
c, Rain gags and data collection from rain gages must be properly
maintain d and monitoring/data recording most occur at the frequency
required n the approved plan.
d, Wetland Monitoring reports must be submitted annually to both the
Central {ffice of the Division of Water Quality and the Wilmington
RegionallOffice of DWQ, by June 1 of each year.
FEB.13.2003 9:53AM NCDENR WIRO NO.626
6
IV. Avian Monitor ng
A) Avian moni ring is required as a condition of this Certification and must be
approved b DWQ prior to impacts to any wetlands or waters.
7
a. The plan must describe the monitoring station locations.
b. As a par. of the plan, if the "avian" monitoring indicates water quality
standard violations with respect to vectortavian species problems then
addition monitoring or action plans with an implementation schedule,
may be uired by the DWQ.
C. An annu report must be submitted to the DWQ, Wilmington Regional
Office of the results of the monitoring efforts for each year by June 1.
should include, the past years monitoring efforts and a list of
This rep rt
all com airts received by the Riegel Ridge, LLC regarding avian or other
vector cgncerns by the public.
V) Groundwater
A) During the time of construction and duration of the time the facility receives
waste plus at le? st, thirty (30) years beyond closure, the following
groundwater mlonitoring is required to assure compliance with the
appropriate woer quality standards.
a) Monitoring f groundwater is required as a condition of this Certification.
Groundwa monitoring results that indicate a statistically significant increase
from back and conditions or a 15A NCAC 2L groundwater standard
violation, wi 1 require a remedial action plan development within 60 days of
the determin tion and this plan must be submitted to the 'W'ilmington Regional
Office of th DWQ,
b) If a statistic ly significant increase over background has been detected for
one or more f the constituents listed in Appendix X of 40 CFR Part 258 or if a
15A NCAC groundwater standard violation is determined, then the...,. .
continued acceptance of waste by this facility shall be suspended and all
landfill cells must be capped if Riegel Ridge, LLC fails to address the issue as
required by tie Division of Waste Management. The suspension of the
acceptance of waste will continue at this facility until such time as the
completion cf Assessment Monitoring (which requires monitoring and testing
for all consti ueuts identified in Appendix U of 40 CPR Part 258), a respective
satisfactory storation plan is provided and approved by D"O K and a
satisfactory restoration plan is implemented or as required for by the Division
of Waste Management,
c) AfI sample d4ta collected from groundwater from any onsite monitoring wells
are required 110 be reported to the Division of Water Quality Wilmington
1
I
P.7
FI?B.13.2003 9:53AM NCDENR WIRO
NO. 626 P.8
7
I
Regional Ofi'ce within 30 days of receipt. If a statistically significant
increase ove background is detected for one or more of the constituents listed
in Appendix of 40 CFR Part 258 or if a 15A NCAC 2L groundwater
standard vi -on is determined, then written notification to DWQ must be
reported in ntmg to DWQ.
d) The groundwater monitoring will continue in perpetuity at this facility unless
Riegel Ridg LL C requests in writing and secures written authorization from
NCDENR fo a reduction in monitoring as required within this Certification.
e) If these above conditions are included or are more stringent in the DWM
landfill perm?Iit, the reporting to DWM shall be sufficient for the reporting
requiremend of this Certification.
f) Minimum m itoring frequency for all monitoring wells installed on site is
once per yea . As a condition of this Certification, R*01 Ridge, LLC must
submit to th4 Wilmington Regional Office of the D"Gii'Q a written account of
the results d analysis. These monitoring results must be submitted to DWQ*
and must in ude background data and analysis of compliance with the
conditions s t forth in this Certification by June i of each calendar year,
1) Mo oring requirements include all wells approved for monitoring by
the Division of Solid waste,
2) Zs?mples and sample results collected from groundwater monitoring
are required to be reported (regardless of the frequency of
sainAe,s) as a part of this Certification and included in any monitoring
reports.
VI) The following monitoring and respective action plans are required to assure
compliance with the appropriate water quality standards:
A.) An approved stl?mwater plan and Operation and Maintenance agreement for the
stormwater man4gement controls is required as a condition of this Certification.
This plan and respectiye agreement must be returned to the DWQ Central Office
prior to initiation of construction. No impacts to wetlands or waters may occur
until that plan receives written approval from, DWQ.
B) Subsequent to a review of the Riegel Ridge Stormwater Management Plans
submitted on November 1, 2002, Riegel Ridge, LLC must resubmit plans that
address the folly wing items:
a) The plan must clearly depict how stormwater will be treated from the
entrance roads, scale house and office areas, maintenance area, and the
FEB.13.2003 9:53AM I NCDENR WIRO NO.626
perimeter ditch associated with the respective Construction and
Demolit on facility. These areas are required to be designed to achieve an
$5%a TS reduction.
b) Recycle eas or staging areas for public or single family household use is
not indicated in the plans. If in future these facilities are determined to be
necessary by Riegel Ridge, LLC, then written notification to the DWQ,
along with a stormwamr management proposal must be submitted to the
DWQ for review and written approval prior to construction of these
facilities
C) Plans mILst be modified such that minimally, all side slopes to control
stormwiter structures, ditches, or toad shoulders are minimally 3;1.
P.9
d) If onsite stormwater treatment and control measures do not protect water
quality s andards Riegel Ridge, LLC shall submit within 60 days of first
knowledge of impacts to surface waters a CAP to address this issue. The
plan and associated control measures must be implemented within 30 days
of writte approval for DWQ.
e) From in' ' ation of construction and through a minimum period of 30 years,
post landfill cell closure, monitoring of the stability and maintenance of
control structures will be required at a monthly frequency and after every
I0-year Or greater precipitation event. The monitoring information must
be des 'bed in a monthly report and this information must be mailed to
DWQ aually, by June 1 of each year and made available upon DENR
staff req est at anytime throughout the year.
f) A rain g ge station must be irWntained, daily information recorded, and
the resp ctive results provided along with the monitoring results.
g) Post clo ure monitoring reports must include a monthly determination that
all cone ntated runoff is treated to meet the specifications listed in
Cnrtditi . ,..numbed of this Certification,
f) Monitormt of stormwater and respective site maintenance will continue in
perpetuijy at this facility unless Riegel Ridge, LT_.C requests in writing and
secures written authorization from NCDENR for a reduction in monitoring
as required within this Certification.
VW The following londitions are required to assure compliance with the
appropriate w Ater quality standards:
A) Access to D Q staff for inspections and sampling must be provided to upon
DWQ requ t.
F-B.13.2003 9:53AM i NCDENR WIRO
N0.626 H. 1W
B) Beyond wham is specifically authorized as a part of the 0,69 acres of impact
authorized in this Certification, waste, fill, or sediment may not be located in
wetlands or caters.
Q All sediment and erosion control measures placed in wetlands and waters shall
be removed 4nd the original grade restored within twenty-one days after the
Division of Land Resources releases the project.
D) hive or fresh concrete may not come in contact with waters of the state until
the concrete hardened.
e
B) The Wilmin on Regional Office of DWQ must be notified by telephone
within 24 hours and in writing (within 5 days) of a Riegel Ridge, LLC
determin4tio that monitoring results indicate a significant increase over
background onditions or a 15A NCAC 2L groundwater standard violation.
F) The Wilminoon Regional Office of DWQ must be notified by telephone
within 24 ho sand in Writing of a Riegel Ridge, LLC determination of a
structural fai ure which includes berms, cap, liner, stormwater control
structures, le' hate storage facilities and sedimentation and erosion control
devices. Th Wilmington Regional Office of DWI must be notified in
writing with two weeks prior to initiation of construction.
G) The enclose "Certification of Completion Form" is to be used to notify DWQ
when all wo$ included in the 401 Certification has been completed.
Vii) Prior to initiation of constmetion of the Landfill facilities, Riegel Ridge, LLC
must be in full compliance with North Carolina Genera Statute 143-215.54.
Specifically, un:01 such time as Riegel Ridge, LLC has secured the respective
variance, meeting the North Carolina General Statute prohi0ittion of siting a
landfill within the 100-year floodplain (pursuant to 143.215.54) impacts
associated with this Certification may not proceed.
The conditions of this Certification notwithstanding, Riegel Ridge, LLC or its
successor is required to conduct its activities in a manner consistent with water quality
standards and classifica ions, as well as all applicable state and federal laws. If water
quality standards and cl ssifications are not met or if state and/or federal laws are
violated, the Division y reevaluate this Certification. This reevaluation may result in
modifications to the Certification to include conditions appropriate to ensure compliance
with-water quality standards and classifications as well as state and federal law in
accordance with 15A N AC 2H.0507 (d). Before modifying this Certification, the
Division shall notify Ri gel Ridge, LLC or its successor and the US Anny Corps of
Engineers, provide noti in accordance with 15A NCAC 2f1,0503, and provide
opportunity for a public' hearing in accordance with I SA NCAC 214.0504. Any new or
revised conditions shall be provided to Riegel Ridge, LLC or its successor in writing,
FEB.13.2003 9:53AM j NCDENR WIRO
NO. 626 P.11
10
Violations of any conditions herein set forth may result in revocation of this
Certification and may result in criminal and/or civil penalties. This Certification shall
expire on expiration of T e 404 Permit.
if this Certification iS unacceptable to you, you have the right to an 4udicatory
hearing upon written re uest within the sixty (60) days following the receipt of this
Certification. This request must be in the form of a written petition conforming to
Chapter 150E of the Noah Carolina General Statures and filed with the Office of
Administrative Hearing, 6714 Mail Service Center, Raleigh, N.C. 27699-6714. If
modifications upon are made to an original Certification, you have right to adjudicatory
on the modifications up n written request within sixty days following receipt of the
Certification. Unless su h demands axe made, this Certification shall be final and
binding.
This the 16th day of December 2002
DMSION OF WATFR QUALITY
. t
46LVI
Alan W. Klimek, P.E.
WQC # 3406
FEB.13.2003 9:53AM NCDENR WIRO
NO. 626 P.12
11 ?
All information reported m t be based on data collected Through analyses conducted i1sing 40 CPR Part
1,36 methods. In addition, th a data mint comply with QA/QC requirements of 40 CPR Part 136 and other
appropriate QA/QC requir ents for standard methods for analytes not addressed by 40 CPR Part 136.
Indicate in the blank roWs prpvided below any data you may hate on pollutants not specifically listed in
this form. At a minimum, a went testing data must be based on at least three pollutant scans and must be
no more than four and one- f years old.
I

F W ility Name on ?
Date of sampling Phone
Analytical Laboratory
i

Aumumminnia (as N)
Composite i
Dissolved oxygen composite
Nitrate/Nitrite composite
Total Kjeldahl nitrogen Composite
Total Phosphorus Composite
Total dissolved solids Composite
Hardness C*ompooite
Chlorine (total residual, TIZC? Grab
oil and grease
Ant!mony Grab
Composite
Arsenic Composite
Beryllium Composite
Cadmium Composite
Chromium Composite
Copper Composite
Lead Composite
Mercury Cozposite
Nickel Composite
Selenium composite
silver Composite
Thallium Composite
Blue Composite
Cyanide Grab
Total phenolic compounds
Acrolein Grab
Grab
Acrylonitrile Grab
Benzene Grab
FEB.13.2003 9:54AM NCDENR WIRO
N0.626 P.13
12
Bremoform Grab
Carbon, tetrachloride Grab
Chlarobenzene Grab
Chlorodibromorncthane + Grab
ZlW- roethane Grab
2-chloroethylvinyl ether Grab
Chloroform Grab
Dichlorobromomethanc Grab
1,1-dichI`oroethane Grab
1,2-dichloroethane . Grab
Trans-l,2-dichloroethylene
1,1-dichloroethylene Grab
Grab
1,2-dichloropropane Grab
1,3-dichloropropylene Grab
F,thylbe e-ne Grab
methyl bromide Grab
Methyl chloride Grab
Methylene ehloride Crrab
1, 1,2,2-tetrachloroethane Grab
Tetrachloroethylene Grab
Toluene Grab
1, 1, 1 -trichloroethane Grab
1,1,2-trichloroethane Grab
Trichloroethylene Gmp
Vinyl chloride

P-61ora-m-creso Grab

Grab
I
2-chlorcphenol Grab
2,4-dichlorophenol Grab
2,4-dimethy1phcn0l Grab '
4,6-4initro-o-cresol Grab
2,44initrophenol Grab
2-nitrophpnol Grab
4-nitrophen0l Grab
Pentachiorophenol Grab
Phenol Grab
2,4,6-trichlorophenol
Aaenaphthene Grab
Grab
FEB.13.2003 9:54AM 6 NCDENR WIRD
NO. 626 P.14
13
Aeenaphthylene Grab
Anthracene Grab
Benzidine Grab
Bemo(a)anthracene Grab
Benzo(a)pyrene Grab
3,4 benzofluoranthene Grab
Benzo(ghi)perylene Grab
BenzoDotluoranthene Grab ,
Bi,q (2-chloroethoxsy) meth Grab
Bie (2-chloroathyl) ether Grab
Bis (2-chloroisopropyl) ethe Grab
Bis (2-ethylhexyi) phthalate Grab
4-bromophenyl phenyl ethe Grab
Butyl benzyI phthalate Grab
2-chloronaphthalene Grab
4 ehlorophenyl phenyl ether
Chrysene Grab
Grab
Din-butyl phthalate Grab
Di-n-octyl phthalate a Grab
l)ibenza(a,lh)anthracene Grab
1,2-dichlorobenzene Grab
1,3-dichlorobenzene Grab
1,4-dichlorobemene Grab
3,3-dichlorobenzidine Grab
Diethyl phthalate Grab
Dimethyl phthalate Grab
2,4-dinitrotoluene Grab
2,6-dinitrotoluene Grab
1,2-diphenylhydrazine Grab
Muoranthene Grab
Fluorene Grab
l- Iexachlorobenzane Grab
Iiexaehlorobutadiene Grab
Hexachlorocyclo-pentadione Grab
I-Imobloroethane Grab
Iudeno(1,2,3-cd)pyrene Grab
Isophorvn0 Grab
Naphthalana Grab
Nitrobenzene Grab
FEB.13.2003 9:54AM NCDENR WIRO NO.626 P.15
14 ?
Grab
Grab
Grab
Grab
Pyrene "'--
,2,4,-trichlorobem enc Grab
I certify under penalty of w that this document and all attachm
and supervision in acco ce with a system to design to assure
gather and evaluat the rmation submitted. Based on my Inq,
manage the system, or tl se persons directly responsibel for gat
information submitted is j to the best of my knowledge and belies
aware that there are %gnjpcant penalties for submitting false inf
nts were prepared under my mrecu
hat qualified perdonnel properly
ry of the person or persons that
gyring the information, the
true, accurate and complete. I am
Representative x1ame

I
.QF yB~ 13.2a03
QG
DWQ Pr*r-t PTO.: C014ntY:
Applicant:
' d
project-Name: "
Date of Issuance of4QX Water"ty Certification;
Cerdftcate of C„ ornpledon
Upon completion 'of all Work approved wid t the 401 Water Quality Certification- and Buffer Rulos, and any,
snbsequeut modificafions, the applicant is reguire4 to return this certificate to the 401:/'4Stetiamds Unit, Forth Carolina-
DivisionA of Water Qiiality, 1621 Service Center, Raleigh, NC, 27649,1621. This form tvay be renumtid to DWQ
by' ft applicant, 'the applicant's agent, or the project engineer. It is not necessary to eend ceriif sates from
all of these.
Appicant's tr'ert?'calidn ,- •
hereby state iitat,• to the best of my abilities, due-am and dMgmce
was used is the abservation of th4 eongruoiicm such that the comUnatice'was observed. to be built Wid9n substantial
compliance and, intent of the 401 ator Quality C.e dmoadon and Bunter Rules, the approved plans and Vmfficmtiona,
and other supporting mate"s,
Signature: Date:
Agent's Cey6f iccaadaa
hereby state that. to the best, of my abilities, due care and dligence
was used in the observation of , coustruction, such that the emstruction. was, observed to be bolt witbiu substantial
compliance and intent of the 401 ??ater Quality Cxttification and Bufer Rules, the approved plate sued spocifm4ons,
&Ad 6dw supporting materials.
sip &=: ?. Date:
if this project was de 4Mid by a t ed Fi jirssiond
T, as a duly roistered Professional tri.a., Engineer.
Landscapo Architect, Survmr, eta,) in the State of North C,aroliaa, having been authoemed to observe (periodically,
weWdy, full time) the consauction of the project, for the Pemtittee hereby eta that, to the err of my abilities; due
cam and diligence was used in the pbserva ion Qf the constructtnn such tluit'the eonstcuctioa was olasesved to be bunt,
within substantial c_ onpIimce and hitent of the 401 Water Quality Certification and Buffer Rules, the approved Pik' s
and specifications, and others materials.
S cone: Registraxian No. Date
N. C. Dlvolon of Water QUAINY, 441 wmaro. l Certiflambn Unk ,
1850 Man servIce center, Raleigh, NC Z7f?sf?IM (MaIW*,Addfs)
( ) 79?.M-i B (Bhd. phone), 9191-73333-as27804-2280 (00811m),
e3 ((ax), (trttp:/MW enr atate.m.aa/ncwadands
9:54AM NCDENR WIRO N0.626 N. 's,16owr+7or
WiNlim Q fids9 Jr., 9eepatary
p I Onh oaronds Department of EnvywMent and Natursl I'Wo m
Alan W. *19knsk, P.E„ Director
Divielon of Water Quality
1.?

December 16, 2002
HEARING OFFICER REPORT
RIEGEL RIDGE LANDFILL
Columbus County, NC
Request for 401 Water Certification
DWQ Project Number 01-1680
Hearing Officer: Paul Rawls, Fayetteville Regional Supervisor
SUIVEVIARY:
Riegel Ridge Landfill, LLC (in c/o William W. Dreitzler), submitted an individual
permit application to the US Army Corps of Engineers (USACOE) to impact 0.69 acres
of jurisdictional waters. The Division of Water Quality (DWQ) received a new
application in the form of a Corps of Engineers Public Notice on December 17, 2001.
The subject Riegel Ridge tract occupies 760 acres and is located along Highway 211 in
Columbus County, North Carolina. The proposed landfill footprint, located within this
tract, is 107 acres.
It was determined by the Director of the Division of Water Quality that it was in the
public interest to conduct a public hearing for the proposed project. Accordingly, the
information provided by Riegel Ridge, LLC prior to the closing date of the written
comment period and post comment period were reviewed. In addition, the DWQ
reviewed a Division of Waste Management (DWM) letter, dated July 24, 2001. This
letter addresses the North Carolina General Statute 143-215.54 prohibiting the siting of
new solid waste landfills in 100-year floodplains. Further, the oral and written comments
as a result of the public hearing process were also reviewed.
A review of public comments and information provided by Riegel Ridge, LLC
(which includes the application, supporting documentation, subsequent
amendments/additional information request responses) has been completed. Based on that
review it is the recommendation of the hearing officer that a 401 Water Quality
Certification be conditionally issued. This recommendation is based on the incorporation
of the suggested special conditions noted in the addendum to this report.
NARRATIVE / GENERAL OVERVIEW
Riegel Ridge Landfill, LLC has submitted an individual permit application to the
US Army Corps of Engineers (USACOE) to impact 0.69 acres of jurisdictional waters.
On December 17, 2001 the 401/Wetlands Unit received an application for the Riegel
Ridge Landfill in the form of an amended Corps of Engineers Public Notice.
The subject Riegel Ridge tract occupies 760 acres and is located along Highway
211 in Columbus County, North Carolina. The proposed landfill footprint, located
v
within this tract, is 107 acres. The waters to be impacted by the landfill are old forestry
ditches that predate the Clean Water Act, as determined by the USACOE. The proposed
landfill is located approximately 6.1 air miles from the southeastern edge of Lake
Waccamaw State Park, approximately 20 miles from the coastal edge of Ocean Isle
Beach and is immediately adjacent to the open water systems within Honey Island
Swamp. The siting location of the proposed landfill is within the area known as the
Green Swamp as indicated in the "Flood Study to Determine 100-year Flood Plain Limits
for Riegel Ridge MSW Landfill" dated December 20, 2001. The active life of this
landfill is proposed to be 25 to 30 years.
The subject tract consists of a mosaic of upland soils and forestry ditches. As a
part of this project, the land beyond the 107-acre landfill footprint is proposed to include
seven (7) borrow pit areas. These borrow pits will approximately total 216-acres by the
end of the active life of the landfill. The borrow pits will provide the necessary material
(soil) to separate the base waste elevation of the landfill by a minimum of 4-feet from
groundwater and supply other materials (soil) necessary for landfill operation.
It is understood that the Division of Waste Management (DWM) Rules will
require the geomembrane portion of the landfill liner system to be located a minimum of
4-feet above seasonal high groundwater elevations. It should be noted that groundwater
issues were a major concern of the public and DWQ staff. Based on comments from the
DWM indicating that protection of the groundwater will be provided for in the design and
permitting of the landfill, it is the opinion of the writer that DWM should ensure that
appropriate safeguards are installed to ensure protection of groundwater. Groundwater
monitoring is typically required during both the active portion and 30 years post landfill
closure by the DWM's permit.
The waste base elevation of the proposed landfill is approximately 55 feet above
sea level. The built-out top elevation of the completed landfill is approximately 305 feet
above mean sea level. Accordingly, the landfill height will be approximately 250 feet.
PROJECT REVIEW:
On December 17, 2001 the NC Division of Water Quality (DWQ) received an
application, in the form of a US Army Corps of Engineers Public Notice for a 401 Water
Quality Certification Request for the proposed Riegel Ridge Landfill in Columbus
County. On January 9, 2002 this project was placed on hold and additional information
was requested.
On February 11, 2002, the DWQ notified Riegel Ridge, LLC of the determination
that it was in the public interest to conduct a public hearing. This hearing allowed DWQ
to review public comment and to consider additional information provided as a result of
the hearing process. A notice of the public hearing was published once in each the
Fayetteville Observer (Fayetteville), Wilmington Star News (Wilmington), and the News
Reporter (Whiteville). The hearing was held on April 18, 2002, at 7:00 p.m. in the
Whiteville High School Auditorium. The hearing lasted approximately 3.5 hours and
was well attended. Approximately 225 people attended the. hearing; approximately 60
spoke during the hearing and 97 requested a copy of the decision. The public comment
period, continued for 30 days after the hearing date. Prior to and during the comment
period DWQ received approximately 540 written correspondences. The hearing was well
attended and many thoughtful written comments regarding subject project were received.
Subsequent to the hearing closing date, Riegel Ridge, LLC provided DWQ
information beyond that included in the initial application (received on May 20, 2002).
On June 10, 2002, DWQ provided a formal additional information request to Riegel
Ridge, LLC. This letter was based on the review of the application, comments from the
public hearing, and the information received by DWQ as of the close of the public
comment period. On July 22, 2002 DWQ received a response to the June 10, 2002
information request. On July 24, 2002, the DWQ received a letter from the Division of
Waste Management explaining how the siting of landfills within 100-year floodplains
was prohibited pursuant to NCGS 143-215.54. The respective continued review of the
above-mentioned information provided to DWQ resulted in a second additional
information request letter dated September 20, 2002, and a response was received by
DWQ on November 1, 2002.
RECONBIENDATION:
The information provided for this project allowed a review as required in 15A NCAC
2H.0500. Specifically, six (6) items were considered: practical alternative, minimization
of adverse impacts, no degradation to surface waters and groundwaters, no cumulative
impacts, protect downstream water quality, and mitigation.
Accordingly, DWQ determined that the US Army Corps of Engineers will complete
an alternatives analysis for Riegel Ridge project (as explained to DWQ in an October 17,
2002 letter from US Army Corps Engineers). Since the DWQ can not duplicate this
review, as per 15A NCAC 2H .506(i), no alternatives review has been conducted by
DWQ for this project. With respect to the minimization of adverse impacts to surface
waters, no degradation of groundwaters or surface waters, no cumulative impacts, and the
protection of downstream water quality standards (pursuant to 15A NCAC 2H .0506), it
will be necessary to address these issues through certification conditions. Finally,
because impacts are less than one (1) acre no mitigation will be required for the impacts.
However, the US Army Corps of Engineers may require mitigation as a part of their
review.
The information provided by Riegel Ridge, LLC has been reviewed. In addition, the
Division of Water Quality (DWQ) reviewed a letter from the Division of Waste
Management (DWM), dated July 24, 2002. This letter addresses the North Carolina
General Statute 143-215.54 prohibiting the siting of new solid waste landfills in 100-year
floodplains. Further, the oral and written comments as a result of the public hearing
process were also reviewed, as well as the information provided within the response from
Riegel Ridge, LLC to the additional information requests.
Considering oral and written comments received as part of the public hearing and
after reviewing information provided by the applicant, it is recommend that the DWQ
proceed with issuance of the 401 Water Quality Certification incorporating the special
conditions contained in the addendum to this report.
HEARING OFFICER'S REPORT ADDENDUM
RECOMMENDED SPECIAL CONDITONS
Riegel Ridge, LLC
Columbus County, NC
Considering oral and written comments received as part of the public hearing and.
after reviewing information provided by the applicant, it is recommend that the DWQ
proceed with issuance of the 401 Water Quality Certification incorporating the special
conditions contained in this addendum to the Hearing Officer's Report.
1) Turbidity
• At no time shall the discharge(s) from this site cause violations of stream standards.
Construction must be conducted in phases according to the erosion and sediment
control plans approved by the Division of Land resources and/or the Division of
Waste Management. Sedimentation and Erosion Control measures for each phase
shall be in place before construction can begin in the next phase (including the
perimeter berm).
• Sufficient materials required for stabilization and/or repair of erosion control
measures and stormwater routing and treatment shall be on site at all times.
• Access will be granted to DENR staff for sampling, inspection or other purposes as
deemed necessary by DENR upon request.
• Beyond what is specifically authorized as a part of the 0.69 acres of impact
authorized in this Certification, fill may not be located in wetlands or waters;
2) Surface Water Monitoring
• Monitoring of surface water parameters of the receiving waters is required as a
condition of this Certification. If surface water monitoring reveals indications of
degradation or reveals that there has been loss of intended usage as determined by
either Riegel Ridge, LLC or the Division of Water Quality a Corrective Action Plan
(CAP) must be developed and submitted to DWQ within 60 days of the
determination. Upon first discovering that waters and/or wetlands have indications of
degradation or loss of intended use Riegel Ridge, LLC shall notify the DWQ
Wilmington Regional Office. This notification shall be within 24hrs of first
knowledge or the first business day thereafter and shall include a detailed explanation
of the nature of the problem. Also, Riegel Ridge, LLC shall provide follow-up
notification, in writing, within 5 business days of first knowledge of the problem. It
should be noted that notification of the conditions noted above is not considered the
submission of the CAP. Should Riegel Ridge, LLC, fail to provide a CAP within 60
days or fail to initiate corrective actions in a timely manner acceptance of waste by
this facility will be suspended. Suspension of the landfill receiving waste will be
effective upon receipt of notification by DWQ. Suspension of the landfill receiving
waste shall last until such time as a CAP has been provided to and approved by
DWQ.
-Prior to start of construction, a "surface water monitoring plan" must be provided to
the Division of Water Quality and Riegel Ridge, LLC must receive written approval
for the plan by DWQ.
-It will be required that monitoring station locations be developed for every discharge
outfall located on the site.
-Two additional sample/monitoring station locations must be developed as well
(upstream and downstream from the confluence of all of the surface waters on site).
Sampling from each of the stations must at a minimum include the following:
-COD (frequency monthly)
-Fecal Coliform (frequency monthly)
-Grease and Oil (frequency monthly)
-Turbidity (frequency monthly)
-Dissolved Oxygen (frequency monthly)
-Annual Pollutant Analysis Monitoring -APAM (frequency annual)
(attached)
Sampling from receiving waters up slope from Tram Road must at a minimum
include the following:
-width and depth ratio accounts (sampling frequency - annual);
-depth of natural sediment/organic matter accumulation(sampling frequency -
quarterly);
-depth of aggraded sediment from construction activities, and presence of
debris/trash within and adjacent to the receiving feature (sampling frequency -
quarterly);
- concurrent digital photograph, taken during the monitoring effort, must
accompany monitoring data collection and be submitted with the respective
monitoring results.
All tests (where applicable) must be performed by DENR certified laboratory.
• It a requirement of this Certification that this facility apply for and secure an NPDES
Permit to Discharge Stormwater as required for Landfills that are permitted by the
North Carolina Division of Solid Waste Management prior to initiation of
construction.
• It is a requirement of this Certification that in addition to the above-mentioned
sampling, this facility maintain full compliance with all of the NPDES Permits
condition required for this facility.
• All samples collected from monitoring required above must be reported as a part of
this Certification and included in any NPDES monitoring reports.
3) Wetland Monitoring
• Monitoring of wetlands is required as a condition of this Certification. If wetlands
impacts are determined to have occurred, if the wetlands develop indications of
instability which include eroding, sloughing, or the removal of the hydrology, as
determined by Riegel Ridge, LLC or the Division of Water Quality then a Corrective
Action Plan must be developed within 60 days of the determination. If wetlands have
been impacted Riegel Ridge, LLC shall notify the DWQ Wilmington Regional Office
in writing. This notification shall be within 24 hrs of first knowledge or the first
business day thereafter and shall include a detailed explanation of the nature of the
problem.
• If wetlands are determined to be impacted, beyond impacts that are authorized by this
Certification, restoration or mitigation as described in 15A NCAC 2H.0506 is
required and the continued excavation/mining of on site borrow materials will be
suspended until DWQ approves an onsite restoration or mitigation plan.
• Prior to start of construction, a "wetland monitoring plan" must be provided to the
Division of Water Quality and Riegel Ridge, LLC must receive written approval for
the plan by DWQ. The monitoring plan must satisfactorily address how it will be
determined whether wetlands draining will occur.
The wetland monitoring plan submitted on November 1, 2002, must be revised to
additionally include the following:
-Physical Monitoring for eroding or sloughing of the wetland (monitoring frequency-
annual)
-A schedule and account of when the ditches that currently bisect proposed borrow
sites will be plugged (e.g. within 90 days).
-Within the monitoring plan, the above-mentioned plugs must also be inspected to
insure they are stable and not failing. This review must be included within the annual
wetland monitoring report.
-Wells as depicted in the November 1, 2002 monitoring plan proposal must be
installed and properly maintained throughout the active life of the landfill.
-A requirement of the monitoring plan includes that annually, well data (collected
daily) must be provided annually to DWQ along with a written account of the
hydrological status of the wetlands on the tract. This includes each wetland polygons
(and all wells) as indicated on the November 1, 2002 monitoring plan.
4) Avian Monitoring
• Avian monitoring is required as a condition of this Certification and must be
approved by DWQ prior to impacts to any wetlands or waters.
-The plan must describe the monitoring station locations.
• As a part of the plan, if the "avian" monitoring indicates water quality standard
violations with respect to vector/avian species problems additional monitoring or
action plans, with an implementation schedule, may be required by the DWQ.
• An annual report must be submitted to the DWQ, Wilmington Regional Office of the
results of the monitoring efforts for each year by June 1. This report should include,
the past years monitoring efforts and a list of all complaints received by the Riegel
Ridge, LLC regarding avian or other vector concerns by the public.
5) Groundwater Monitoring
It is understood that the DWM will require groundwater monitoring at the
proposed facility if permitted. It is recommended that DWQ work with DWM to
ensure that the following conditions are either contained in the DWQ Water Quality
Certification or the DWM permit for this site.
Monitoring of groundwater is required as a condition of this Certification.
Groundwater monitoring results that indicate a statistically significant increase to
background conditions or a 15A NCAC 2L groundwater standard violation, will
require a remedial action plan development within 60 days of the determination and
this plan must be submitted to the Wilmington Regional Office of the DWQ.
• If a statistically significant increase over background has been detected for one or
more of the constituents listed in Appendix I of 40 CFR Part 258 or if a 15A NCAC
2L groundwater standard violation is determined, the continued acceptance of waste
by this facility may be suspended and all landfill cells required to be capped if Riegel
Ridge, LLC fails to address the issues as required by the Division of Waste
Management. The suspension of waste acceptance will continue at this facility until
such time as the completion of Assessment Monitoring (which requires monitoring
and testing for all constituents identified in Appendix II of 40 CFR Part 258), a
respective satisfactory restoration plan is provided and approved by the Division of
Waste Management, and a satisfactory restoration plan is implemented or as required
by the Division of Waste Management.
All sample data collected from groundwater from any onsite monitoring wells are
required to be reported to the Division of Water Quality Wilmington Regional Office
within 30 days of receipt. If a statistically significant increase over background is
detected for one or more of the constituents listed in Appendix I of 40 CFR Part 258
or if a 15A NCAC 2L groundwater standard violation is determined written
notification to DWQ of must be reported in writing to DWQ.
• The ground water monitoring will continue in perpetuity at this facility unless Riegel
Ridge, LLC requests in writing and secures written authorization from NCDENR for
a reduction in monitoring as required within this Certification. However, a reduction
in monitoring request may only occur after a minimum 30-years post closure of the
landfill (30 years beyond last date that waste is received at the landfill).
• If these conditions are included or are more stringent in the DWM landfill permit, the
reporting-to DWM shall be sufficient for the reporting requirements of this
Certification.
6) Stormwater
• An approved stormwater plan and Operation and Maintenance agreement for the
stormwater controls is required as a condition of this Certification. This plan and
respective agreement must be returned to the DWQ Central Office prior to initiation
of construction. No impacts to wetlands or waters may occur until that plan receives
written approval from DWQ.
• Subsequent to the review of the Riegel Ridge Stormwater Management Plans
submitted on November 1, 2002, it is required that Riegel Ridge, LLC resubmit plans
that address the following items:
The plans must clearly depict how stormwater will be routed and treated from all
areas of the project to include but not necessarily limited to the entrance roads,
scale house and office areas, maintenance area, and the perimeter ditch.
Stormwater from these areas is required to, at a minimum, be treated to an 85%
TSS reduction. If onsite stormwater treatment and control measures do not protect
water quality standards Riegel Ridge, LLC shall submit within 60 days of first
knowledge of impacts to surface waters a CAP to address this issue. The plan and
associated control measures must be implement within 30 days of approval by
DWQ.
Recycle areas or staging areas for public or single family household use is not
indicated in the plans. If in future these facilities are determined to be necessary
by Riegel Ridge, LLC written notification to the DWQ, along with Stormwater
management proposal must be submitted to the DWQ for review and written
approval prior to construction of these facilities.
It is required that the plans be modified such that minimally, all side slopes of
stormwater control structures, ditches, or road shoulders are minimally 3:1.
From initiation of construction and through a minimum period of 30 years, post
landfill closure, monitoring of the stability and maintenance of control structures will
be required at a monthly frequency and after every 10-year or greater precipitation
event. The monitoring information must be described in a monthly report and this
information must be mailed to DWQ annually, by June 1 of each year and made
available upon DENR staff request at anytime throughout the year.
• Any monitoring results that indicate failures of or need for maintenance or prepares
stormwater structures must receive repairs immediately. An account of problems,

maintenance, and of the repairs must be completed and submitted to the Wilmington
Regional Office of the DWQ within 30 days of the determination.
• The stormwater monitoring will continue in perpetuity at this facility unless Riegel
Ridge, LLC requests in writing and secures written authorization from NCDENR for
a reduction in monitoring as required within this Certification.
7) Access, Notification and impact constraints
• Access to DENR staff for inspections and sampling must be provided upon request;
• Beyond what is specifically authorized as a part of the 0.69 acres of impact
authorized in this Certification waste, fill, or sediment may not be located in wetlands
or waters;
• Borrow/mining sites shall not be located in streams or wetlands.
• Borrow/mining sites shall not cause impacts to surface waters or wetlands.
• The Wilmington Regional Office of DWQ must be notified by telephone within 24
hours and in writing (within 5 days) of a Riegel Ride, LLC determination that
monitoring results indicate a significant increase over background conditions or a
15A NCAC 2L groundwater standard violation.
• The Wilmington Regional Office of DWQ must be notified by telephone within 24
hours and in writing of a Riegel Ridge, LLC determination of a structure failure
which includes berms, cap, liner, stormwater control structures, leachate storage
facilities and sedimentation and erosion control devices.
• Violations of any conditions herein set forth may result in the revocation of this
Certification and if appropriate result in criminal and/or civil penalties.
8) Floodplain
• Prior to initiation of construction of the Landfill facilities, Riegel Ridge, LLC
must be in full compliance with North Carolina Genera Statute 143-215.54.
Specifically, until such time as Riegel Ridge, LLC has secured the respective
variance, meeting the North Carolina General Statute prohibition of siting a
landfill within the 100-year floodplain (pursuant to 143-215.54) activities
associated with this Certification may not proceed.
r-fir,
1Lto
b? 'G
June 11, 2001
Dear Mr. John Dorney, " G
We citizens here in the eastern part of Columbus County, N.C. feel that we
have been placed between a..rock and an extreme hard place.
-our county commissioners, except for one(Comm. Bill Memory) have voted for and
are working with a landfill contractor (Riegel Ridge Limited Liability Corp.)
to prepare a site for a very large regional landfill (approximately 760 acres
and potentially 190+ feet tall, accepting garbage from a 100 mile radius) On a
very delicate site.
The site chosen is in a 330,000 acre swamp (called the Green Swamp), which serves
as a water reservoir for part of Columbus and Brunswick Counties with drainage
into Waccamaw River, and is near (6 miles as the crow flies) to Lake Waccamaw.
Many citizens here in Columbus county ( and probably all of Brunswick county)
feel this is a very bad location choice and seek your help in discouraging the
construction of such a pontential environmental disaster to be located as proposed.
Would you please give this land fill location proposal your most careful scrutiny
and oppose if you so agree.
F,
Thanks very much, / rVVZL&
Wm. Ed Morris
2201 Creek Ridge Road
Lake Waccamaw, N.C. 28450
[Fwd: Proposed Riegel Ridge Regional Landfill in Columbus Co.]
Subject: [Fwd: Proposed Riegel Ridge Regional Landfill in Columbus Co.]
Date: Wed, 11 Jul 200107:30:03 -0400
From: John Dorney <[e-mail]>
To: Danny Smith <[e-mail]>
fyi. please print out and start file.
- - -- - - - - ---- -
F - -7 -7 -7
Subject: Re: Proposed Riegel Ridge Regional Landfill in Columbus Co.
Date: Tue, 10 Jul 2001 14:20:21 -0400
From: "Jeff lane" <[e-mail]>
To: "John Dorney" <[e-mail]>, "Legrand, Harry" <[e-mail]>,
"Sherri Coghill" <[e-mail]>, "Eric Imhof" <[e-mail]>,
"Melba McGee" <[e-mail]>, "Paul Clark" <[e-mail]>,
"James.C.Coffey" <[e-mail]>,
"Angie Pennock" <[e-mail]>
CC: "Runkle, John" <[e-mail]>, "Rick Dove" <[e-mail]>
To: Riegel Ridge landfill reviewers,
For the record, I do not agree that the project is exempt from EA or EIS
requirements on the basis of public monies considerations. The Riegel Ridge
Project is the culmination of an effort by Columbus County, funded by public
monies, over much of the last decade to site a landfill in the county.
Indeed, during this time the county paid Marlowe, Drietzler and Associates
to conduct a feasibility study specifically directed at identifying and
assessing potential landfill sites in Columbus County. Even though no
public money has been spent on the "Riegel Ridge site suitability study" per
se (ie., the document as it appears in the application), there is no doubt
that considerable public funds have been spent in the site selection process
which has culminated in the Riegel Ridge application. Indeed, in a recent
newspaper advertisement promoting the proposed landfill, Riegel Ridge, LLC
acknowledged that the site was one of approximately a dozen which had been
evaluated, referring to the feasibility study paid for by the county. Even
more importantly, two of the three principles in Riegel Ridge, LLC are Dan
Marlowe and Bill Drietzler, of Marlowe, Drietzler and Associates. The
notion that no public monies have been involved in the proposed Riegel Ridge
Landfill flies in the face of the facts, considering that Marlowe and
Drietzler were paid by the county specifically to assess potential landfill
sites in the county, and have now simply put on another hat for the Riegel
Ridge landfill development project.
I would also like to take this opportunity to point out that the proposed
landfill has drawn widespread public opposition. Even in sparsely populated
Columbus County, nearly 500 people attended a recent public hearing to voice
their opposition. Siting a landfill in the Green Swamp, near Lake Waccamaw
and in and around other ecological significant areas has raised many issues
on which the public has viable concerns, and which need to be fully assessed
and resolved. I encourage you, as reviewers, to give the Riegel Ridge
application the level of scrutiny it deserves, to maintain a open and public
process, and to remember that there are times when it is fully appropriate
to simply say "No". I would also like to take this opportunity to thank
Sherri Coghill for the effort she has put into listening to the public to
this point. I look forward to developing a similar working relationship
with other reviewers as this process goes forward.
Jeff Lane,
Chairman, Friends of the Green Swamp
1 of 3 7/11/01 5:53 PM
[Fwd: Proposed Riegel Ridge Regional Landfill in Columbus Co.]

----- Original Message
From: "Sherri Coghill" <Sherri. Coghill@ncmail. net>
To: "Eric Imhof" <[e-mail]>; "Melba McGee"
<[e-mail]>; "Paul Clark" <[e-mail]>;
"James.C.Coffey" <[e-mail]>; <[e-mail]>
Sent: Tuesday, July 10, 2001 10:05 AM
Subject: Re: Proposed Riegel Ridge Regional Landfill in Columbus Co.
> Eric,
> I am currently reviewing the site study application for this facililty.
The
> site study is the first part of the solid waste permitting process. If
DWM
> determines that the site is acceptable for landfilling, then the applicant
will
> be asked to submit a construction plan application for review. If this
meets
> all regulatory requirements, then a Solid Waste Permit, Part 1: Permit to
> Construct is issued. Following construction and DWM approval of CQA
> documentation, Part 2 of the solid waste permit, the Permit to Operate, is
> issued.
> There are wetlands on the site that will be directly impacted and some
that may
> be indirectly impacted. The Corps of Engineers and Water Quality-Wetlands
Unit
> are involved in the wetlands permitting. DCM is requiring a CAMA
'consistency
> determination. Cultural Resources, Parks and Rec, and Natural Heritage
Program
> have provided comments on the archaeological survey, the endangered and
> threatened species survey and impacts to lands included in the State
Nature
> Preserve.
> Riegel Ridge LLC is the landfill applicant and will be owner and operator
of the
> landfill. Columbus County has been involved in issuing a solid waste
franchise
> and will be using the facililty, if permitted, but the county will not
develop,
> own or operate the landfill themselves. It is my opinion that SEPA
requirements
> do not apply.
> I speak with Jeff Lane quite frequently and have provided him with this
> information.
> The consultant for the landfill is Bill Dreitzler of Marlowe, Dreitzler
and
> Assoc. The phone number is [phone]
> Let me know if you need further information.
> Sherri Coghill
> Eric Imhof wrote:
> > Do you know anything about this proposed landfill? if yes, do you know
what
> > stage the review process is in? Who is the consultant and would it be OK
2 of 3 7/11/01 5:53 PM
[Fwd: Proposed Riegel Ridge Regional Landfill in Columbus Co.]
if
> > I contact them? Mr. Jeff Lane of "Friends of the Green Swamp" contacted
me
> > for information. I am trying to determine what permits might be required
and
> > if an EA or EIS will be required. It sounds like a,private project and
that
> > no public monies will be involved. I have more questions, but I will
wait
> > untill I hear back from you. Thanks.
> > Eric Imhof- One-Stop Permit Assistance Coordinator 910-395-3900
3 of 3 7/11/01 5:53 PM
ON THE SHORES OF NORTH CAROLINA'S LARGEST NATURAL LAKE
P. 0. Box 145
Lake Waccamaw, North Carolina 28450
1970) 646-3700
9 i 0) 646.3860 Fax
email lake waccamawl @webink.net
September 19, 2001
John Dorney, NC Division of Water Quality
2321 Crabtree Blvd., Suite 250
Raleigh, NC 27604-2260
Dear Mr. Dorney:
Member N.C. League of Municlpalilles

The Town of Lake Waccamaw wishes to express our utmost concern regarding the
placement of a landfill in the Green Swamp in Columbus County for the following
reasons:
? The wetland function of the Green Swamp, supplying water to residents of North
and South Carolina, would be exposed to leachate, estimated by the EPA at 1200
gallons per day for a site this size.
? Methane gas would migrate into the soil and cracks in the rocks, contaminating
the water as well as leachate.
? Methane gas, even when monitored, can exceed state regulations (ex: Hanes Mill
Landfill), setting the stage for a major explosion and possible repeat of the great
forest fire that swept the entire Green Swamp in the 1950s.
? As the Green Swamp ranks 2nd to the Everglades as the greatest source of fresh
water in the North American continent, it is essential that this treasure be restored
and protected, neither of which could happen with a regional landfill present.
? Landfills of this size (260-280 feet in height with a 100-acre footprint) produce an
odor that has been described as being two to three times greater than that of a hog
cesspool combined with the rotting carcasses of cows, hogs, and subsequent road
kill such as deer, fox, squirrel, and possum. Odors from landfills this size are
know to spread 30 to 50 miles from the site, which would impact the citizens of
Lake Waccamaw.
? The Green Swamp and is home to more than 30 rare species that are found
nowhere else in the world. Its Long Leaf Pine savannahs are 2nd in biodiversity
only to the Rainforests or Central America. The Nature Conservancy, located
approximately 10 miles from the proposed site, is the home of Red Cockaded
Woodpeckers. It is unlikely that these federally endangered birds will remain
with the increased traffic, stench, and thousands of scavenger birds that
n
_?c1f
net,\
accompany mountains of garbage.
Therefore, we, the Town of Lake Waccamaw, would like to voice op si d to
ask that we be kept informed. We would also like to request that ublic hearin a held
prior to the granting of this permit. Thank you for your specific atte i s matter.
Jewel Burkette Alexander

Gw-om &/ie 9'a-xm
December 3, 2001
John Dorney
North Carolina Division
1650 Mail Service Center
Raleigh, NC 27699-1650
Dear Mr, Dorney:
of Water Quality

As the files of the North Carolina Division of Water Quality will
show, for the past two years I have written, not only to the
Division, but the Environmental Protection Agency, all our
representatives and the press. With those letters I have included
a COPY of an astounding map, done by Regal Ridge itself, but
never displayed for the public to see, That map shows the great
number of creeks, lakes, rivers and streams surrounding and going
through the area of the proposed landfill site, proving beyond
any reasonable doubt, such a landfill, in that area guarantees
The map, with my letters, raised the concerns of a number of
representatives, In their replies, it was Senator John Edwards'
statement, with this warning, that critically covered and summed
up their ma or concern. He said, "After the devastation left by
hurricane Floyd, local, state and federal officials should use
extra caution when considering projects that could have a potentially
devastating environmental impact in the even of another hurricane,"
We are told the proposed "trash mound" will be 700 feet tall,
Long before it reaches that height,. Just one of our strong winds
or a hurricane which we always have, will spread the material,
diseased or otherwise, from that landfill into those creeks rivers,
lakes and streams which connect with places like White MarsA. Soules
Swamp and those two all important Waccamaw River and Cape Fear Rivers
from whence comes much of our drinking water, -- I haven't mentioned
whether we could eat fish that come from water so contaminated by such
debris,
2
T am enclosing a cop of that scale map of the proposed landfill
site, done by Regal Ridge, but not displayed for the public to
see, as I saido As you also will see, Just how dangerous a
landfill in the Green Swamp will be to the health,and well being,
of us all.
No permit should ever be granted to put a landfill in the
Grp -Swamp.
Very truly yours,
ke to l ex
952 Rough-N-Ready R
whiteville, NC 284
encl.

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Scale 1:250,000 (at center) D US Highway - - State Boundary TITAN ?/luat?lc (?,?u f?
5 Miles O Interstate/Limited Access Land E"°"°°" 9• °° "° ?^ `^? ?°^'? ?9
SITE LOCATION PLAN
'--?' Major Connector
511 vm Water
RIEGEL RIDGE LANDFILL
State Route
• River/Canal
COLUMBUS COUNTY, NC
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Exit Zipcode Boundary 20-8382-01
County Seat DRAWING NO. 1
Small Town

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December 6th, 2001
Mr. John Dorney
North Carolina Division of Water Quality
1650 Mail Service Center,
Raleigh, NC 27699--1650
Q ?S
(R?
We appreciate this opportunity to express our concerns with the proposed
placement of a landfill in Columbus County by Riegel Ridge, LLC and offer the
following comments.
The more presence of a landfill would be aesthetically unappealing and
would definitely be a deterrent to continuing and further developing
recreational facilities in the area, such as those at nearby Lake Waccamaw and
the Lake Waccamaw State Park. Inherent road debris from garbage trucks and odors
from the facility itself would be constant reminders of the presence of a
"garbage dump".
The increase in highway traffic the proposed landfill would entail would
have an adverse impact on local residents as well as on vacationers and tourists
who use Highway 211, a two-lane road, while traveling to and from local beaches
and tourist attractions. Columbus County already ranks among the worst in the
State in terms of traffic accidents. Increasing the traffic on the narrow local
roads would only exacerbate the current undesirable trend.
Runoff from roadways, both paved and not, and dust from the passing of heavy
trucks on unpaved roadways would certainly have adverse effects on the wildlife
in adjacent areas. Consideration must be given to those areas that have not been
surveyed and, very probably, provide habitat for rare, threatened, or endangered
species of wildlife, or species that are of special concern, on both state and
national levels.
Converting what was previously managed forests that evolved over many
years from clear cuts to mature trees, thereby providing habitat for a wide
variety of wildlife would have a substantially adverse effect on local wildlife.
And the activities involved with operating a landfill would disturb wildlife in
adjacent areas as well as create more runoff from associated paved areas and
from roads.
Although the location of the proposed landfill is currently considered
mostly upland, it must be remembered that it was wetlands not too long ago.
Efforts to drain the area have been extensive and have required the creation of
a vast network of ditches and canals, some of which are over fifty feet wide and
more than tan feet deep. Without a doubt, this massive movement of surface and
ground water from the area has caused subsidence of the water table and if it
continues unabated will probably affect drinking water wells in the local area.
All the more reason to believe those current drainage practices of local timber
operations will necessarily be modified in the future. And that future will
include the entire time that the proposed landfill will exist, not just the time
that it will be in operation.
Flooding, like that which took place after Hurricane Floyd, is a constant
threat to the entire area. And even though there is a massive drainage system in
place, which would tend to move water off of the area, the tremendous increase
in sheet flow during heavy rains would overload this system. The rapid transport
of surface water off of the area tends to increase the amount of water that
downstream areas must carry. Thereby increasing flood conditions downstream.
There are no requirements for adjacent property owners to maintain or even
continue the existing drainage system. If drainage ditches on adjacent
properties are closed or substantially altered the proposed landfill site
operators would be unable to prevent flooding during seasonal rainfall events.
Also should be considered is the possibility that adjacent properties could be
converted for uses other than those currently in effect; ones that would not
entail extensive drainage. The landfill operators would have no influence over
such decisions made by adjacent property owners.
Although it is planned to be in operation for only 25-30 years, the
facility would be a permanent fixture, and since it would rise almost three
hundred feet into the air it would be a prominent feature in the area, visible
for many miles, in perpetuity. Long after the current decision-makers have gone
to their reward, the landfill would remain a monument to their vision, or lack
thereof, should it in fact be approved.
We do not believe that concerted efforts were made to find, much less
consider an alternative site for the proposed landfill. A diligent search should
be made and this proposal should not be considered until, and if, such a search
proves fruitless.
There has not been established a need for a regional landfill in Columbus
County. Adjacent counties have landfills and do accept waste from Columbus
County at present. A landfill that would accept waste from within a 100-mile
radius would place an unnecessary burden on Columbus County residents and
certainly be extremely to the fragile ecology in the area of the proposed
landfill.
For the above stated reasons, we believe that the proposal to place a
landfill in the area designated would be ill advised. As provided by the Clean
Water Act, we request that an Environmental Impact Statement be conducted and a
public hearing be held to allow comments from concerned citizens and other
interested parties.
Respectfully,
alp(r-jl?
Bob Slaughter
Cape Fear Group, Sierra Club
PO Box 91
Winnabow, NC 28479
JAN 1 1 2002
1929 Civietown Rd SW
Supply, NC 28462
December 20, 2001
Angie Pennock
Department of the Army
Wilmington District Corps of Engineers
PO Box 1890
Wilmington, NC 28402-1890
Re: Proposed Riegel Ridge MSW landfill in Columbus County
ACOE Action ID No. 200100853
Dear Ms. Pennock:
As a concerned citizen, I would like to comment on the above referenced permit
application. This comment is submitted in recognition that the permit application is
deficient and incomplete. It fails to provide sufficient information for adequate comment.
Gross deficiencies in the public notice and amended public notice are thus noted, and it is
expected that further comment will be allowed once sufficient information is provided.
1. Addressing first the Amended Public Notice of Dec. 11, 2001, the second paragraph
begins "...The Corps of Engineers will consider alternatives in accordance with applicable
law." According to the permit application submitted to the Corps October 15, 2001, the
third paragraph states ".....the applicant has not provided detailed information regarding
off-site alternatives with this application. It is our understanding that site suitability issues
are under the jurisdiction of the NC DENR Division of Solid Waste Management and that
these issues will not be re-evaluated by the USACE as part of this application. An
extensive off-site alternatives analysis was required by the state prior to this site being
selected as the best alternative." If the Corps is now going to consider alternatives, it
must have the `detailed information regarding off-site alternatives' as a part of the permit
application on which to base their considerations. Without this information, the permit
application is incomplete. If the Corps has the `extensive off-site alternatives
analysis... required by the state..', I formally request a copy under the Freedom of
Information Act. If they do not have it, the application is incomplete and should be
denied.
2. A landfill is not a "water-dependent" activity. The Corps' rules (40 CFR 230.10(3))
specify that the discharge of dredge and fill material is not permitted for activities that are
not water dependent. They further provide that "(p)racticable alternatives that do not
involve special aquatic sites are presumed to be available, unless clearly demonstrated
otherwise." The public notice provides no alternatives analysis; therefore the permit
application should be denied.
Pagel of 4
3. Given the size of the proposed project and the large impact to wetlands, a detailed
analysis of practicable alternatives must be provided, in accordance with Regulatory
Guidance Letter, No. 93-2, "Guidance on Flexibility of the 404(b)(1) Guidelines and
Mitigation Banking" 11 (August 23, 1993), which provides in relevant part that "The
amount of information needed to make such a determination and the level of scrutiny
required by the [Section 404(b)(1) Guidelines] is commensurate with the severity of the
environmental impact and the scope/cost of the project." The guidance establishes less
stringent alternatives review for projects that would have only minor impacts. It also
provides that "[g]enerally, as the scope/cost of the project increases, the level of analysis
should also increase." The rules require detailed analysis of alternatives for this proposed
project.
4. Has a comprehensive Environmental Impact Study (EIS) been prepared for the
proposed activity? Given the large scale of the proposed activity, and the large area of a
wetlands ecosystem involved, it would appear that the proposed activity can not go
forward prior to completion of a comprehensive EIS. If such a study has been prepared,
this letter constitutes a formal request pursuant to the Freedom of Information Act for a
copy. If such a study has not been prepared, please explain why. This letter also
constitutes a formal request for such a study, if it has not been prepared.
5. Has the Corps complied with its obligations under the Endangered Species Act to
prepare a biological assessment and complete a thorough section 7 consultation with the
US Fish and Wildlife Service on this proposed activity? Please provide documentation of
such compliance.
6. Please provide analysis for why the Corps stated that the District Engineer "is not
aware that the proposed activity will affect species, or their critical habitat, designated as
endangered or threatened pursuant to the Endangered Species Act of 1973." This
determination was made in error. The Corps must first make a "no effect" or a "may
affect" determination, based on adequate information and documentation, none of which is
available in the public notice. The Surveys for endangered and threatened species
mentioned in the original public notice were conducted by an engineering firm paid by the
applicants, and no mention is made that any government agency has confirmed or denied
their conclusions.
7. Regulations promulgated under the National Environmental Policy Act provide that all
effects, both direct and indirect, shall be considered by the Corps (40 CFR 1508.8). All
cumulative impacts shall also be considered (40 CFR 1508.7). Please provide analysis of
all direct effects, indirect effects, and cumulative impacts of this project. These include,
but are not limited to:
Fragmentation of the landscape
Impacts to floodplain, water quality and aquifer reFlwge
Impacts to wildlife, including federally listed species
Loss of biodiversity
Page 2 of 4
8. No discussion of whether and to what extent this proposed project will "cause or
contribute to significant degradation of the waters of the United States" is provided, as
required by 40 CFR 230.10(c). What impact will this enormous landfill have upon the
integrity of the region's water supply? What impact will this landfill have upon the
surficial aquifer? Has the integrity of the Green Swamp as a watershed been considered in
the course of the permit review process? Have the direct, secondary and cumulative
impacts upon the watershed been reviewed?
9. Has FEMA been consulted on this proposed activity? The 1991 100-year floodplain
maps used in the site proposal plans pre-date the massive flooding evidenced from
Hurricane Floyd, and many of those maps are in process of being updated as a
consequence. This is a very low-lying area of which a portion of the site, and much of the
surrounding land, are jurisdictional wetlands. The possibility of flooding on nearby and
contiguous properties that may result from this proposed activity must be completely
evaluated and analyzed.
10. Regarding the Public Interest Review required by 33 CFR 320.4, no information is
provided with respect to the following elements of the review. Please provide adequate
information to allow proper comment on the following:
a. In what way does this project serve the public interest to locate it in a
hydrologically- and environmentally-sensitive area instead of finding another site away
from adjacent wetlands?
b. How does the transfonnation of the Green Swamp (designated a National
Natural Landmark by the US Park Service) into a garbage dump serve the public interest?
c. The value of conserving these wetlands must be evaluated.
d. The economics of this project must be evaluated, including the cost to the
community of all the services to be provided.
e. The floodplain values of this land must be evaluated, not just based on old maps
that have proven (by Hurricane Floyd) to be unreliable. Will this project be subject to
flooding? Will it affect adjacent wetlands? Has FEMA been consulted?
f. This project will most probably degrade water quality in the area. Please
evaluate.
g. What is the public need for this project? We are already running out of clean,
potable water and wetlands. This project makes yet one more demand on that water and
serves to degrade the region's water supply.
h. Does the environment receive any benefit from this project?
i. What is the long-term affect on wetlands in the area?
j. What is the potential for flooding and other negative impacts to adjacent lands?
k. Will this project destroy all wildlife habitat value of this land?
1. Is conservation of wetlands important to the public interest?
m. What will this proposed activity do to water quality in the area?
Page 3 of 4
Through this letter I formally request, pursuant to the Freedom of Information Act, a copy
of any EIS, Environmental Assessment, Biological Assessment and Off-Site Alternatives
Analysis.
Thank you for your consideration of these coimnents and my public records request. I
would also like to request extensive public hearings on this permit application to address
the multitude of community and scientific concerns associated with this project, many of
which are referenced in this letter. In the event a permit is issued, I respectfully request a
copy of any EA/FONSI, alternatives analysis and the permit itself. I look forward to
hearing from you soon.
Sincerely,
n l?i • G?ic.?
Cindy H. Evans
cc:
William L. Cox, EPA
US Fish and Wildlife Service
Jim Coffey, DENR Div. of Waste Mgt.
FEMA
V1 John Dorney, NCDWQ
Page 4 of 4
I -w
JAN 2002
1929 Civietown Rd SW
Supply, NC 28462
December 20, 2001
Angie Pennock
Department of the Army
Wilmington District Corps of Engineers
PO Box 1890
Wilmington, NC 28402-1890
Re: Proposed Riegel-Ridge MSW_landfll in Columbus County
ACOE Action ID No. 200100853
Dear Ms. Pennock:
As a concerned citizen, I would like to comment on the above referenced permit
application. This comment is submitted in recognition that the permit application is
deficient and incomplete. It fails to provide sufficient information for adequate comment.
Gross deficiencies in the public notice and amended public notice are thus noted, and it is
expected that further comment will be allowed once sufficient information is provided.
1. Addressing first the Amended Public Notice of Dec. 11, 2001, the second paragraph
begins "...The Corps of Engineers will consider alternatives in accordance with applicable
law." According to the permit application submitted to the Corps October 15, 2001, the
third paragraph states ".....the applicant has not provided detailed information regarding
off-site alternatives with this application. It is our understanding that site suitability issues
are under the jurisdiction of the NC DENR Division of Solid Waste Management and that
these issues will not be re-evaluated by the USACE as part of this application. An
extensive off-site alternatives analysis was required by the state prior to this site being
selected as the best alternative." If the Corps is now going to consider alternatives, it
must have the `detailed information regarding off-site alternatives' as a part of the permit
application on which to base their considerations. Without this information, the permit
application is incomplete. If the Corps has the `extensive off-site alternatives
analysis... required by the state..', I formally request a copy under the Freedom of
Information Act. If they do not have it, the application is incomplete and should be
denied.
2. A landfill is not a "water-dependent" activity. The Corps' rules (40 CFR 230.10(3))
specify that the discharge of dredge and fill material is not permitted for activities that are
not water dependent. They further provide that "(p)racticable alternatives that do not
involve special aquatic sites are presumed to be available, unless clearly demonstrated
otherwise." The public notice provides no alternatives analysis; therefore the permit
application should be denied.
Page 1 of 4
w.
3. Given the size of the proposed project and the large impact to wetlands, a detailed
analysis of practicable alternatives must be provided, in accordance with Regulatory
Guidance Letter, No. 93-2, "Guidance on Flexibility of the 404(b)(1) Guidelines and
Mitigation Banking" 11 (August 23, 1993), which provides in relevant part that "The
amount of information needed to make such a determination and the level of scrutiny
required by the [Section 404(b)(1) Guidelines] is commensurate with the severity of the
environmental impact and the scope/cost of the,project." The guidance establishes less
stringent alternatives review for projects that would have only minor impacts. It also
provides that "[g]enerally, as the scope/cost of the project increases, the level of analysis
should also increase." The rules require detailed analysis of alternatives for this proposed
project.
4. Has a comprehensive Environmental Impact Study (EIS) been prepared for the
proposed activity? Given the large scale of the proposed activity, and the large area of a
wetlands ecosystem involved, it would appear that the proposed activity can not go
forward prior to completion of a comprehensive EIS. If such a study has been prepared,
this letter constitutes a formal request pursuant to the Freedom of Information Act for a
copy. If such a study has not been prepared, please explain why. This letter also
constitutes a formal request for such a study, if it has not been prepared.
5. Has the Corps complied with its obligations under the Endangered Species Act to
prepare a biological assessment and complete a thorough section 7 consultation with the
US Fish and Wildlife Service on this proposed activity? Please provide documentation of
such compliance.
6. Please provide analysis for why the Corps stated that the District Engineer "is not
aware that the proposed activity will affect species, or their critical habitat, designated as
endangered or threatened pursuant to the Endangered Species Act of 1973." This
determination was made in error. The Corps must first make a "no effect" or a "may
affect" determination, based on adequate information and documentation, none of which is
available in the public notice. The Surveys for endangered and threatened species
mentioned in the original public notice were conducted by an engineering firm paid by the
applicants, and no mention is made that any government agency has confirmed or denied
their conclusions.
7. Regulations promulgated under the National Environmental Policy Act provide that all
effects, both direct and indirect, shall be considered by the Corps (40 CFR 1508.8). All
cumulative impacts shall also be considered (40 CFR 1508.7). Please provide analysis of
all direct effects, indirect effects, and cumulative impacts of this project. These include,
but are not limited to:
Fragmentation of the landscape
Impacts to floodplain, water quality and aquifer reclwge
Impacts to wildlife, including federally listed species''
Loss of biodiversity
Page 2 of 4
8. No discussion of whether and to what extent this proposed project will "cause or
e United contribute to significant degradation of the watersaf tenormous landfill have upon the
required by 40 CFR 230.10(c). What impact will t
integrity of the region's water supply? What impact will this landfill have upon the
surficial aquifer? Has the integrity of the Green Swamp as a watershed been considered in
and cumulative
the course of the permit review process? Have the direct, secondary impacts upon the watershed been reviewed?
9. Has FEMA been consulted on this proposed activity? The 19911 00-year floodplain
--naps evidenced from
used in the site proposal plans pre-date the massive flooding
in process r,fbeing updated as a
Hurricane Floydu? ??manY oft
consequence. This is a very low-lying area of which a portion of the site, and much of the
surrounding land, are jurisdictional wetlands. The possibility of flooding on nearby and
contiguous properties that may result from this proposed activity must be completely
evaluated and analyzed.
10. Regarding the Public Interest Review required by 33 CFR 320.4, no information is
provided with respect to the following elements of the review. Please provide information to allow proper comment on the following:
a. In what way does this project serve the public interest to locate it in a
hydrologically- and environmentally-sensitive area instead of finding another site away
from adjacent wetlands?
b. How does the transformation of the Green Swamp (designated n Public in Brest?
Natural Landmark by the US Park Service) into a garbage dump serve the P
c. The value of conserving these wetlands must be evaluated. cost to the
d. The economics of this project must be evaluated, including the
community of all the services to be provided.
e. The floodplain values of this land must be evaluated, u t be based
tops
that have proven (by Hurricane Floyd) to be unreliable. Will this p J
flooding? Will it affect adjacent wetlands? Has FFMA been consulted?
ea. Please
f. This project will most probably degrade water quality
evaluate.
g. What is the public need for this project? We are already running out of clean,
table water and wetlands. This project makes yet one more demand on that water and
serves to degrade the region's water supply.
benefit from this project?
IL Does the environment receive any
i. What is the long-term affect on wetlands in the area? to adjacent lands?
j What is the potential for flooding and other negative impacts J
k. Will this project destroy all wildlife habitat value of this land?
rtant to the public interest?
1. Is conservation of wetlands imPo water quality in the area?
m. What will this proposed activity do to
Page 3 of 4
Through this letter I formally request, pursuant to the Freedom of Information Act, a copy
of any EIS, Environmental Assessment, Biological Assessment and Off-Site Alternatives
Analysis.
Thank you for your consideration of these comments and my public records request. I
would also like to request extensive public hearings on this permit application to address
the multitude of community and scientific concerns associated with this project, many of
which are referenced in this letter. In the event a permit is issued, I respectfully request a
copy of any EA/FONSI, alternatives analysis and the permit itself. I look forward to
hcarinm-you soon._._-.-._.. _
Sincerely,
, N.
Cindy R Evans
cc:
William L. Cox, EPA
US Fish and Wildlife Service
Jim Coffey, DENR Div. of Waste Mgt.
FEMA
V1 John Dorney, NCDWQ
Page 4 of 4
r- ,
SOUTHERN ENVIRONMENTAL LAW CENTE
MIA
200 WEST FRANKLIN STREET. S
JIM
CHAPEL HILL, NC 2752o- fAA1 ?00,9
Telephone [phone]
Facsimile 919-929-9421
[e-mail]
Angie Pennock
Department of the Army
Wilmington District, Corps of Engineers
Post Office Box 1890
, ,,' Wilmington, NC 28402-1890
RjG^O?i
Chario-...? . VA
char. '.W- NC
DIV Atarta., GA
WA 7
-?,
DDIREC
December 21, 20051

=s; f
Re: Action ID No. 200100853, Application or i tsel Ridge, LLC for permit to
construct municipal solid waste landfill in the C S
Dear Ms. Pennock:
These comments are submitted on behalf of FLL-ads of Jae- Green Swamp and the
North Carolina Coastal Federation on the above referenced permit application. Riegel
Ridge, LLC proposes to construct a regional municipalslid waste landfill (landfill) in a
portion of the Green Swamp approximately seven miles southeast of Lake Waccamaw,
Columbus County, North Carolina. This 760.6 acre si-z consiss of a mix of abandoned
agricultural fields, pine plantations and areas dominated by poco~sm. vegetation. The
public notice states that approximately 540 cubic yards oi•fill material would be placed in
0.69 acres of waters of the United States to construct the 107 acre footprint of the landfill.
In addition, approximately 203 acres of borrow areas ill be constructed to provide
material for the construction and operation of the landfflL Much of the land within the
project site is ditched for silvicultural production. For the reasons discussed in detail
below, the Corps must deny the application for a section 404 permit. If the Corps fails to
deny the application for a permit, it must provide a revised and accurate delineation of
wetlands on the site, prepare an environmental impact statement, and conduct a public
hearing on the application.
Riegel Ridge, LLC also has submitted a site study application for the proposed
landfill to the Solid Waste Section within the North Carolina Division of Waste
Management. On December 7, 2001 the Solid Waste Section informed Riegel Ridge that
it would not continue review of the application. The Section identified several concerns
that relate to potential impacts to wetlands on the site:
The Section has determined, after an extensive review of the information
submitted in the site study and in cooperation -with other pertinent state and
federal agencies, that several major issues remain inadequately addressed.
However, it is clear that if the site is ever determined to be suitable for a MSWLF,
100% recycled paper

2
it would be a marginally suitable site at be:5_? Siz cons which raise
questions concerning the suitability of the sinL- i fs hiAh ground-water table,
compression and consolidation of sow ce2dz?,,r%hty and settlement "issues,
questionable on-site soil resources, and opermional impacts on adjacent
and nearby environmentally-sensithr-c ?m swfi as wetlands, floodplains, and
state nature and historic preserves. Tae siLz_ yr extensive engineering
design to resolve serious construction are- Cgeraffewl cant-erns.
See letter of December 7, 2001 from James C_ Cam,
Aztfng Chief, Solid Waste Section
to Mr. William W. Dreitzler, P.E. (attache4
Hydrology data suggest erroneous wetland iuHs5ricna[ won
Construction of the proposed landfill z ? to resuk is the filling or mechanical
excavation of a far greater area of wetlands f=, d= i c5cated in the permit application
and public notice. The application and purist mac thar: approximately 0.69 acres
of waters of the United States would be fiIlt-,d to duct the footprint of the landfill.
This area of waters of the United States corsigs of the bottom of ditches-crossing the
landfill site. While much of the area has be:= d ?H-_xif, Lydioto?dc data provided by the
applicant indicate that significant areas retain weE=- d hydrology As partof a state
application for a permit, Riegel Ridge subn ~n--d d,=caLed graundwazer data for the
landfill site. Depth of-groundwater from the was -_--abH_4aed on March 18-19,
1999. As indicated on the attached plats, p----3,- ` by the applicam and previously
provided to you by Jeff Lane, Chair, Friends Cr--_Cn SW-=, tnis survey reveals that
two substantial areas within the landnll foo-_-j_-:=. and a&acenr bo=w site retain wetland
hydrology on these dates. Rainfall during Fz==e and 41r--ch 1999 was substantially
below average. (See attached rainfall data).
The 1987 Corps of Engineer Wetlands De eatiaa Manual requires the presence
of hydrophytic vegetation, hydric soils, and defined "-edand hydrology" for an area to
be determined to be a wetland. Most of the &rea Ridlin the footurint of the landfill and
the adjacent borrow area consists of hydric soils (Cdftoa) and is dominated by
hydrophytic vegetation. Numerous drained ditches were consnucted throughout the site
over the past 30 years. (See attached aerial photographs illmstrating the site's ditching
history.) Apparently, the applicant concluded that the wetlands on the site were
effectively drained by the silvicultural ditching acti`ities. he Corps must first determine
whether the silvicultural drainage activities are law'fuL Sihzcultural drainage that
converts a wetland to an upland is prohibited by section 410411f(2). If the drainage ditches
were not lawfully constructed, the Corps must evaluate the erwem of wetlands on the site
under the manual provisions for atypical situations and consider appropriate enforcement.
If the Corps determines that the ditches were law-filly constructed, the Corps
cannot ignore the specific hydrologic indicator of wetland hydrology submitted by the
applicant to the state in seeking the state permit. Wetland hydrology is established by
visual observation of soil saturation within a major portion of the root zone, usually
within 12 inches of the surface. (1987 Manual at 3 8.) Corps guidance states that areas

r
L
3
which are seasonally inundated and/or saturated to the surface for a consecutive number
of days for more than 12.5% of the growing season are wetlands, and areas that are
saturated to the surface for more than 5% of the growing season may be wetlands. See
Department of Army Memorandum regarding Classification and Interpretation of the
1987 Manual (March 8, 1992). The detailed hydrology analysis provided by the
applicant to the state indicates that wetland hydrology was present on substantial portions
of the landfill and adjacent borrow area site at the beginning of the growing season in
1999. This positive indicator of wetland hydrology creates a presumption that these
portions of the site constitute wetlands unless refuted by other competent hydrologic
information.
The applicant has failed to demonstrate avoidance of special aquatic sites
The applicant has failed to demonstrate that alternative sites for the landfill that
avoid filling waters of the United States do not exist. Under the 404b(1) guidelines, the
applicant for a section 404 permit for non-water-dependent activities has the burden of
demonstrating that alternative sites that avoid filling of wetlands or other waters of the
United States do not exist. 40 CFR § 230.10(a). A municipal solid waste landfill is not a
water-dependent activity. In the application for a permit, the applicant states that thirteen
potential landfill sites within Columbus County were evaluated in 1994. According to
the applicant, none of these sites were selected primarily because of "the proximity of the
sites to residential areas." After rejecting these sites, the County directed a search to find
a suitable site within the wetland rich Green Swamp. The applicant has failed to provide
information adequate to meet its burden of demonstrating that alternative sites exist that
would not impact wetlands or waters of the United States. The thirteen alternative sites,
and possible additional sites, that would avoid wetlands must be analyzed by the Corps
prior to issuance of the requested permit.
In addition, the applicant has not demonstrated the need for a large regional
landfill that would take solid waste from some twenty-five counties in two states. A
smaller landfill to address Columbus County's immediate needs would almost certainly
have less environmental impacts and must be evaluated. We understand that a private
landfill in Sampson County is willing to take wastes from Columbus County. Because of
the failure of the applicant to meet its burden of demonstrating that wetlands and waters
of the United States have been avoided to the maximum extent practicable, the permit
must be denied.
Issuance of the permit is contrary to the public interest
The Corps must thoroughly evaluate the public interest factors in Corps
regulations prior to issuance of section 404 permits. 33 CFR § 320.4. Dr. Stanley R.
Riggs, Distinguished Research Professor, Department of Geology, East Carolina
University, has conducted extensive research on the Green Swamp. On December 7,
2001, Dr. Riggs submitted comments to the Corps regarding anticipated impacts of the
proposed landfill. The following summary of public interest factors establishes that the
4
proposed landfill is contrary to the public interest and the permit application must be
denied.
The proposed landfill will harm conservation of rare species. The application
indicates that several colonies of the rare and declining venus flytrap will be adversely
affected by the construction of the landfill. Venus flytrap is listed as a federal species of
concern and is a state candidate/special concern species. The applicant proposes to
relocate five of the seven colonies of versus flytrap that have been located on the site.
Relocation poses a significant risk of mortality, and reducing the number of colonies
increases the susceptibility of the remaining plants to extirpation. It should be noted that
consultants for the applicant initially identified only one colony of versus flytrap on the
landfill site. Remaining sites were identified by members of Friends of the Green
Swamp. It is thus possible, if not likely, that other rare and imperiled species may be
present on the site and not identified by the applicant in their incomplete and inadequate
surveys. The proposed landfill is contrary to the public interest because it will impair
conservation and recovery of rare species.
The proposed landfill poses the potential for severe adverse impacts on water
quality. The attached letter from Dr. Riggs summarizes many of the concerns related to
water quality. In addition, as noted above, the North Carolina Division of Waste
Management recently informed the applicant that the proposed site is "marginally
suitable at best" and will require "extensive engineering design to resolve serious
construction and operational concerns." The site poses an unacceptable risk of severe
impact to water quality from landfill runoff, landfill leachate, and ground-water
contamination. The high potential for severe adverse water quality impact is contrary to
the public interest, and the permit should be denied.
The study by Dr. Riggs and his colleagues addresses the cumulative water quality
impacts of the proposed landfill activity. Of special concern are the waters flowing from
the landfill to Lake Waccamaw, classified as outstanding resource waters (ORW). The
North Carolina rules at 15A NCAC 2B.0225(e)(10) further define the Lake Waccamaw
ORW as including "all undesignated waterbodies that are tributary.to Lake Waccamaw."
This includes the landfill site and its drainage area. Rule .0225(c) states that "at a
minimum, no new discharges or expansions of existing discharges shall be permitted"
into this waterbody. Allowing an additional discharge in the Lake Waccamaw area is
contrary to the public interest, and the permit should be denied.
As discussed above, the landfill footprint will likely result in the filling of
substantial wetland areas. In addition, borrow areas have the potential to alter the
hydrology of adjacent wetlands interspersed throughout the site. The adverse impacts to
wetlands are contrary to the public interest, and the permit should be denied.
The landfill site is located in a remote and fairly undeveloped portion of the
historic Green Swamp. The construction and operation of the landfill and the increased
truck traffic hauling material to the landfill will adversely affect the aesthetics of this
5
relatively undeveloped area. These adverse impact via are chary to the ( .
public interest, and the permit should be denied.
As discussed above, the proposed landfill will harm effim w comarve rare and
imperiled species. In addition, conversion of the exisCmg sit: ic a tandfiIl will harm other
fish and wildlife values by eliminating existing habitat_ These its are contrary to the
public interest, and the permit should be denied.
,
The attached letter from Dr. Riggs summarized food ids cried by the
proposed landfill. These hazards include both the pawl for i mxeased flooding off site
as a result of the facility and the direct risk of flood to thee.icE y itsel° .Increased
flood hazards are contrary to the public interest, and tlx permit sold be denied.
The proposed landfill is located in an altered pardon of the Green Swamp.
Existing land use in the area is abandoned agricultural and sUv5caftaral w-hh some
relatively undisturbed sites. The landfill will dramadcaRy chmsa these existing land
uses and is incompatible with surrounding land use. Ongoing
gal eLorts to restore
wetlands and endangered natural communities such as longieai pine savmnas, which
historically dominated this site would be compromise:, by cxsnseon of pis site to a
landfill. The proposed landfill is incompatible with existing land uses and contrary to the
public interest, and the permit should be denied
The proposed landfill will eliminate any existirQ use of the proposed
site and importantly, preclude future recreational use_ i acre ar-- easier needs for
recreational opportunities and lands in southeastern tiaith Carolina and these needs are
important to the welfare of the people. The landfill wf snbst=,- y reduce existing and
future opportunities for recreation and is contrary to the public iffiest.
The proposed landfill presents a range of envronmental concerns azat are
summarized above and in the attached letter from Dr. RiQ?. ine '_`orth Carolina
Division of Waste Management has determined that errvzronmenml concern related to
the proposed site are substantial if not overwhelming Authorizing the proposed landfill
in the face of these environmental concerns is contrary to the public interest, and the
permit must be denied.
Environmental Impact Statement
The decision to issue the requested permit constitutes a major federal action
significantly affecting the quality of the environment But for the landfill footprint and R
borrow area excavation, none of the 760 acre site would be developed as a regional
municipal solid waste landfill. The broad range of adverse envirommental effects that
would result from construction of the landfill on the Green Swamp environs and the high
degree of public controversy related to the project require the preparation of an
environmental impact statement prior to issuance of the permit
.i r
6
A 24,800 acre portion of the Green Swamp is a designated Nationai Natural
Landmark. This area was designated in May 1974. A National'Natm-al. Landmark is an
area designated by the Secretary of the Interior as being of national sirgnificance to the
United States because it is an outstanding example of major biological and geological
features found within the boundaries of the United States. In making this designation, the
U.S. Department of the Interior concluded:
The Green Swamp is the largest and most unique mosaic of wetland communities
in the Carolinas. Other large swamp areas exist in the coastal plain of North and
South Carolina, but none contain a similar assemblage of unusual ;ommuniry
types and the great abundance of rare and endemic plant species. _Tne site is also
a refuge for rare animal species such as the puma, black bear and alligator.
See attached designation documents, U.S. Department of the Interior.
The landfill area is approximately five miles from the northern boundary of the National
Natural Landmark. It will certainly be at least indirectly affected by increased track
traffic to the landfill should it be authorized. Department of the Interior regulations
require that federal agencies consider the existence and location ofdesi National
Natural Landmarks in assessing the effects of their activities on the environment under
section 102(2)c of the National Environmental Policy Act. 36 CFR § 62.6(f). The
proximity, impacts, and significance of the Green Swamp as a \afional Natural
Landmark further require preparation of an environmental impact statement prior to
issuance of the requested permit.
Public Hearin
The significant public interest in this permit application requires that the Corps
hold a public hearing prior to issuance of the permit. The Friends of the Gre?een Swamp
and the North Carolina Coastal Federation request that a public hearing be held prior to
the issuance of any permit.
The applicant is not financially responsible
In its recent response to Riegel Ridge's state permit application, the Solid Waste
Section concluded that the applicant failed to submit adequate financial information
required by state law to establish that the applicant is financially qualified to carry out the
activity for which the permit is required. See attached letter. This determination bears
directly on the ability of the applicant for the section 404 permit to comply with
conditions in the permit including any mitigation requirements. For these reasons, the
permit application should be denied.
1 a?
7
We appreciate the opportunity to submit these eoinments.. If you have any
questions, please feel free to inquire. - - - -
Sirac.¢reh,
Derb S. Cam, Jr.
Senior ;=y
Attachments
DSC/all
cc: Jeff Lane, Friends of the Green Swamp
John Runkle, Conservation Council or`-\C
Todd Miller, North Carolina Coastal Federation
John Dorney, Division of Water Quality
James Coffey, Solid Waste Section
/ Swamp Watch
December 26, 2001
Angie Pennock
Department of the Army
Wilmington District, Corps of Engineers
P. 0. Box 1890
Wilmington, North Carolina 28402-1890
RE: Proposed Riegel Ridge MSW Landfill in Columbus County
Action ID No. 200100853
Dear Ms. Pennock: /I-
200 Benson Road NE
Leland, N.C. 28451
[e-mail]
10 - 2 2002
og'
The attached petitions contain the signatures of 1,353 c?fizens opposed to locating a
regional landfill in the Green Swamp. These signatures were gathered in a 5-day period of
time; any lengthy effort would certainly yield thousands more. You are being furnished with
copies; the originals will be on file with Swamp Watch.
1
We are concerned that at the very least, an Environmental Impact Statement should be
prepared and public hearings should be held for a proposed project of this magnitude.
We respectfully request that the permit application review be halted by all agencies while
this is done.
Sincerely,
Gean M. Seay, Co-Founder
cc: Governor Mike Easley
William L. Cox, EPA, Region 4, Wetlands Section
Garland Pardue, U.S. Fish & Wildlife Service
Jim Coffey, DENR, Division of Waste Management
in Dorney, NC DENR, Division of Water Quality
William Straw, FEMA, Region 4
John Sutherland, NC DENR, Division of Water Resources
101 the Environment & Our Children Will Die With It. • • • • • • • • • • • • • • • • • •
To Whom ft Maycona :
As c3wa ned cithmm ofBmaswick County, NC, we would S w to go on wwrd as
ohm *WS the pwposW YteW Ridgy bbmi*d I.aonM in the On= Swamp: Evan
though located in Cow Couxmy, our camay would be bpacted by probability of
vote r poDat ion, increased pnab ty ofd, threat to ssalmkive caviromane?st ah=dy
ww * con promiod, and many odor bx*b of degradation of the enWmm wd and
qual ty offfe in our area. We ask that you deny peasmb for thm landfill, or at heast hold \
exlciswe public h=W before a ffinal oon*knf n.
Name Address: (Street, city, sta low zip)
AIM
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To Whom It May-Concern:
As concerned citizens of Brunswick County, NC, we would like to go on record as
opposing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of
water pollution, increased probability of flooding, threat to sensitive environment already
severely compromised, and many other facets of degradation of the environment and
quality of life in our area. We ask that you deny permits for this landfill, or at least hold
extensive public hearings before a final consideration.
Name Address: (Street, city, state, z1p)
1023
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To Whom It May-Concern:
As concerned citizens of Brunswick County, NC, we would like to go on record as
opposing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of
water pollution, increased probability of flooding, threat to sensitive environment already
severely compromised, and many other facets of degradation of the environment and
quality of He in our area. We ask that you deny permits for this landfill, or at least hold
extoisive public hearings before a final consideration.
in Address: (Street. city, state, ZIP)

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To Whom It May-Concern:
As concerned citizens of Brunswick County, NC, we would like to go on record as
oppt)sing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Cohunbus County, our county would be impacted by probability of
water pollution, increased probability of flooding, threat to sensitive environment already
severely compromised, and many other'facets of degradation of the environment and _
quality of life in our area. We ask that you deny permits for this landfill, or at least hold j
exta live public hearings before a final consideration.
Name Add ss: (Street, city, state zip)
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To Whom It May-Concern:
As concerned citizens of Brunswick County, NC, we would like to go on record as
oppc'sing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of
water po'Hution, increased probability of flooding, threat to sensitive environment already
severely compromised, and many other facets of degradation of the environment and
quality of life in our area. We ask that you deny permits for this landfill, or at least hold
extensive public hearings before a final consideration.
s /,?aroee• /Qirn..M ..iii ..i..i.._ .•i..l
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To Whom It May -Concern:
As concerned citizens of Brunswick County, NC, we would like to go on record as
opposing the proposed R.eigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of
water pollution, increased probability of flooding, threat to sensitive environment already
severely compromised, and many other facets of degradation of the environment and
quality of life in our area. We ask that you deny permits for this Iandfill, or at least hold
exto live public hearings before a final consideration.
p
r
1-v? ?ak r
,
Add
fv-*,\
ess: (Street, city, state zIp
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To Whom It May Concern:
There is no justifiation for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
North Americas 2nd greatest source of fresh water. There is no sane reason for placing millions of tons of toxin-laden
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in an
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
Swamp over a 24-hour period in the mid `80s and caused no significant flooding. Only 20" of rain fell over 48 hours
during Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and enhanced
industrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
capable of sending Its swirling destruction in any direction depending on wind and sheet flow - certainly not a suitable
site.for a hundred-acre mountain of garbage almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp be
restored and protected, not made the home of a regional dump.
C

\I_?__
(S--,)
name
c Address: (Street, city, state, zip)
?1U Gc?c°S? &)v ?- ? 'Z/6 i
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To Whom It May -Concerw
As concerned citizens of Brunswick County, NC, we would like to go on record as
opposing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of
water pollution, increased probability of flooding, threat to sensitive environment already
severely compromised, and many other facets of degradation of the environment and
quality of life in our area. We ask that you deny permits for this landfill, or at least hold
extensive public hearings before a final consideration
1e Address: (Street, city, state, zip)

"-ril Od. .tea I1Itth , h ,C -

i
To Whom It May-Concern:
As concerned citizens of Brunswick County, NC, we would like to go on record as
oppc?sing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of
water pollution, increased probability of flooding, threat to sensitive environment already
severely compromised, and many other facets of degradation of the environment and
quality of life in our area. We ask that you deny permits for this landfill, or at least hold
extensive public hearings before a final consideration.
?e ( Address: (Street, city, state, zip)
7
.5 ?S /

To Whom It May Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
North America's 2"d greatest source of fresh water. There is no sane reason for placing millions of tons of toxin-laden
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in an
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
Swamp over a 24-hour period in the mid '80s and caused no significant flooding. Only 20" of rain fell over 48 hours
during Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and enhanced
industrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
capable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a suitable
site for a hundred-acre mountain of garbage almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green 5Wamp be
restored and protected, not made the home of a regional dump. 7, l/
Name Address: OStreet, city, state, zip)

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To Whom It May Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
North America's 2"d greatest source of fresh water. There is no sane reason for placing millions of tons of toxin-laden
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in an
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
Swamp over a 24-hour period in the mid `80s and caused no significant flooding. Only 20" of rain fell over 48 hours
during Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and enhanced
industrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
capable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a suitable
site for a hundred-acre mountain of garbage almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp be
restored and protected, not made the home of a regional dump. 2
Name Address: (Street, city, state, zip)
Cfh Al*;72fCT

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To Whom It May Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
North Americas 2 greatest source of fresh water. There is no sane reason for placing millions of tons of toxin-laden
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in an
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
Swamp over a 24-hour period in the mid `80s and caused no significant flooding. Only 20" of rain fell over 48 hours
during Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and enhanced
industrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
capable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a suitable
site for a hundred-acre mountain of garbage almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp be
restored and protected, not made the home of a regional dump.
ame Address: (Street, city, state, zip)

2 YO LaiLdik-
A
-

'1/1(.1 ??ki t_??,t .t 1 L?, ? C) l Ij ? C' ? C? SL ?'--

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Fo Whom It May Concern:
there is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
4orth Americas 2 greatest source of fresh water. There is no sane reason for placing millions of tons of toxin-laden
tarbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in an
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
Swamp over a 24-hour period in the mid '80s and caused no significant flooding. Only 20" of rain fell over 48 hours
luring Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and enhanced
ndustrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
:apable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a suitable
;ite for a hundred-acre mountain of garbage almost 300 feet tall.
-HEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp be
estored and protected, not made the home of a regional dump.
2
Name v Address: (Street, city, state, z?)

1"0. 1 GCS 3 ?7L

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ro Whom It May Concern:
(here is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
9oith America's 2"d greatest source of fresh water. There is no sane reason for placing millions of tons of toxin-laden
tarbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in an
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
Swamp over a 24-hour period in the mid '80s and caused no significant flooding. Only 20' of rain fell over 48 hours
luring Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and enhanced
ndustrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
Apable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a suitable
aite for a hundred-acre mountain of garbage almost 300 feet tall.
Name

THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp be
estored and protected, not made the home of a regional dump. `j
To Whom It May Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the.Green Swamp, the
site of North America's 2nd greatest source of fresh water. There is no sane reason for placing, millions of tons
of toxin-laden garbage in an area subject to contaminate two aquifers supplying most of the water to eastern
North Carolina or in an area equaled in biodiversity only by the Great Tropical Rain F!)rest of Central America.
22" of rain fell in the Green Swamp over a 24-hour period in the mid '80s and caused no Ripnificant flooding.
Only 20" of rain fell over 48 hours during Hurricane Floyd and created flash floods cresti C!ver 23 feet. With
the presence of increased and enhanced industrial draining, the Green Swamp is destine t§-once again be
the source of colossal flooding in the near future, capable of sending its swirling destruction 1kc1ny direction
depending on wind and sheet flow - certainly not a suitable site for a hundred-acre mountain c`.: arbage
almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Orten Swamp
be restored and protected, not made the home of a regional dump.
Name Address: (Street, city, state, zip)
O lt
tgc
V c'3

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?% ' 6',5
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-47
-7 -2 0

To Whom It May-Concern:
As concerned citizens of Brunswick County, NC, we would.like to go on record as
opposing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of
water pollution, increased probability of flooding, threat to sensitive environment already
severely compromised, and many other facets of degradation of the environment and
quality of life in our area. We ask that you deny permits for this landfill, or at least hold
extensive public hearings before a final consideration.
Name Address: (Street, city, state, zip)

Adams S??'?h ?C?1? a?c?P/s ?arr?S? c??' ??/ sl-??lla??e
gy, "f / ` i P C?e

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To Whom It May Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the
site of North America's 2nd greatest. source of fresh water. There is no sane reason for placing millions of tons
of toxin-laden garbage in an area subject to contaminate two aquifers supplying most of the water to eastern
North Carolina or in an area equaled in biodiversity only by the Great Tropical Rain Forest of Central America.
22" of rain fell in the Green Swamp over a 24-hour period in the mid '80s and caused no significant flooding.
Only 20" of rain fell over 48 hours during Hurricane Floyd and created flash floods cresting over 23 feet. With
the presence of increased and enhanced industrial draining, the Green Swamp is destined to once again be
the source of colossal flooding in the near future, capable of sending its swirling destruction in any direction
depending on wind and sheet flow - certainly not a suitable site for a hundred-acre mountain of garbage
almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp
be restored and protected, not made the home of a regional dump.
Name Address: (Street, city, state, zip)
le-am 7111,am,
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-
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0
To Whom It May Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the
site of North America's 2nd greatest source of fresh water. There is no sane reason for placing millions of tons
of toxin-laden garbage in an area subject to contaminate two aquifers supplying most of the water to eastern
North Carolina or in an area equaled in biodiversity only by the Great Tropical Rain Forest of Central America.
22" of rain fell in the Green Swamp over a 24-hour period in the mid '80s and caused no significant flooding.
Only 20" of rain fell over 48 hours during Hurricane Floyd and created flash floods cresting over 23 feet. With
the presence of increased and enhanced industrial draining, the Green Swamp is destined to once again be
the source of colossal flooding in the near future, capable of sending its swirling destruction in any direction
depending on wind and sheet flow - certainly not a suitable site for a hundred-acre mountain of garbage
almost 300 feet tail.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp
be restored and protected, not made the home of a regional dump.
Name Address: (Street, city, state, zip)
(?/?/IG6Gc

v?O on O ? n >zl Eli ? , ? ? L ?? Pi c-

?? eL Lid Al?
S
_

To Whom It May-Concern:
As concerned citizens of Brunswick County, NC, we would lice to go on record as
opposing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of C_
water poWon, increased probability of flooding, threat to sensitive environment already
severely compromised, and many other facets of degradation of the environment and
quality of life in our area. We ask that you deny permits for this landfill, or at least hold
extensive public bearings before a final consideration.
Name Address: (Street, city, state, zip)
c 0C c >
A?Z? 4ZI '?'RtAJJAV S71, ?4,4k#C- 9 VC -_-,9V7(D
_
1 l
S lJ` 1 L I

V L/t "'i 7
1V V(0
Of 1 ra 2c ?r. S?se/? ?? ?/L

JO
WC?
To Whom It May-Concern:
As concerned citizens of Brunswick County, NC, we would lice to go on record as
opposing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of
water pollution, increased probability of flooding, threat to sensitive environment already
severely compromised, and many other facets of degradation of the environment and
quality of life in our area. We ask that you deny permits for this landfill, or at least hold
extensive public bearings before a final consideration.
Name Address: (Street, city, state, zip)
QC ZE?Q
-q M11 4LALVT - t
I i S c
r
A01 to L
0 r
-kc
i k
JrG. S SS?et Ta ?- C? d l', .t /L C 2'P% 2 Z
akA?_k LO-LA (4A-
-0)4AkQ,,W- IW? '1 --
0?,,IL <- 8
T
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/VC
t4K ?-/" 0- ?R- 'vc '2-RVI"O
iv:N 19-,
1

To Whom It May Concern:
As concerned citizens of Brunswick County, NC, we would like to go on record as
opposing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of
water pollution, increased probability of flooding, threat to sensitive environment already
severely compromised, and many other facets of degradation of the environment and
quality of life in our area. We ask that you deny permits for this landfill, or at least hold
extensive public hearings before a final consideration. _-
a

k
.-7 Name Address: (Street, ity, state, zip)
?d. 7 5d ?v,?rsCUrc {2
?.
&?4 71

ZuU. ? c? 6639 4u? rj /V Inc
`t

i j a ?G,

To Whom It May Concern:
I
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
North America's 2`d greatest source of fresh water. There is no sane reason for placing millions of tons of toxin-laden
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in an
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22° of rain fell in the Green
Swamp over a 24-hour period in the mid '80s and caused no significant flooding. Only 20" of rain fell over 48 hours
during Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and enhanced
industrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
capable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a suitable
site for a hundred-acre mountain of garbage almost 300 feet tall.
THEREFORE, we the undersigneO, believe it is in the best interest of the general public that the Green Swamp be
restored and protected, not made the home of a regional dump.
Name Address: (Street, city, state, zip)
;? j '? L
T614 ?J /'
261 u; S K S?L? 4
L? ! Z ?
.Lr G /
'oe
2 2-
25.7 4=. C6'?? 2--Z--
' 1174

To Whom It May Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
North America's 2"° greatest source of fresh water. There is no sane reason for placing millions of tons of toxin-laden
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in an
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
Swamp over a 24-hour period in the mid '80s and caused no significant flooding. Only 20" of rain fell over 48 hours
during Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and enhanced
industrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
capable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a suitable
site for a hundred-acre mountain of garbage almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp be
restored and protected, not made the home of a regional dump. (f ?(7 ,
Name Address: (Street, city, state, zip)

y .;'Yv. ?.?1?L•???•;.1"!t? -? i. 'fttS I -,??-5 1-,`?'?.' !7 ?'ir`?Q /? . V
a??? ? y? ?, ?1y G>l - 2
122

To Wh )m It May Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp,
North America's 2nd greatest source of fresh water. There is no sane reason for placing millions of tons o
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carol
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in th
Swamp over a 24-hour period in the mid '80s and caused no significant flooding. Only 20" of rain fell over 4
during Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and e
industrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near
.capable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a
site for a hundred-acre mountain of garbage almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp, q
restored and protected, not made the home of a regional dump. 7)
l
Name Address: (Street, city, state, zip)

j

VIYL VC
x Le, a 61 5 N) 161-1

"el
To Whom It May Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp,
North America's 2"d greatest source of fresh water. There is no sane reason for placing millions of tons of
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carol
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in th
Swamp over a 24-hour period in the mid '80s and caused no significant flooding. Only 20" of rain fell over
during Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and
industrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the nea
capable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a
site for a hundred-acre mountain of garbage almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swar
restored and protected, not made the home of a regional dump.
Name Address: (Street, city, state, zip)
f .,
1:0 11;?
r/l ? l
J L
/.
De 1_V_
-,I. e-1 e A A en
.-
C&,?b L 14 10 UAL,, ke AFV6 Z_

l
,

r
,L5

x W4 S "I
'z f114 r,,
tic
710"X,
To Whom It May Concern:
JAN ` 2 2002
There is no juGi if e non for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
North Americas 2nd greatest source of fresh water. There is no sane reason for placing millions of tons of toxin-laden
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in ar
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
Swamp over a 24-hour period in the mid `80s and caused no significant flooding. Only 20" of rain fell over 48 hours
during Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and enhance:
industrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
capable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a suitablE
site for a hundred-acre mountain of garbage almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swam; be
restored and protected, not made the home of a regional dump.
A1601110 Aaaress: (Street, city, state, zip)

I
-r?? i
(3
?.,
.y.z-,r ?'lJ 1 r/ !` ?- .) L`&C-L oIr ;.
4 lore-
i

C1. ?/
LIZ
3 ' `yvl C sS ?- --?
61

C?At??1? ; S?ryv4ct- w ` (o_.3 I Ck0,4) Acukk c?

-ram-' N???' 1???/ (y ?Y.' ?!/? ??L%??-?.?/ ??1 ???J-' • VV / ??1? ??i`?!?/) ?v j' /?L„ L?:J? / ?`?

xxc .
l
To tAwn It May Corn:
As c mcawd tens ofBnmswick County, NC, we would bike to go on record as
opPx -gig the proposed le e Mm alt al LwO ld in the Green Swam. Even
thougb loafed in Cohobus'County, our county would be impeected by probebOity of
wrote c poMon inizeased prdbabflhy of flooding, threat to s We envirotnew akeedy
seve vly cominom*d, d many other faints of degradation of the environment and
qual ty of life M. our area. We ask that you denypem*s for this brill, or at least hold
exte;isive public &vings before a final consideration
Name Address: (Street, city, state, zip)

r?t
6?r ?„ r,,
i?
??-

? s-

IXALA/

n ` r
ZLIJ

IL6

IM Q

T-
To Whom It May Concern:
As concerned citizens of Brunswick County, NC, we would like to go on record as
opposing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of
water pollution, increased probability of flooding, threat to sensitive environment already
severely compromised, and many other facets of degradation of the environment and
quality of life in our area. We ask that you deny permits for this landfill, or at least hold
exte>>sive public hearings before a final consideration.
name Address: (Street, city, state, zip)
3U q 70

A t
Oe6h y "N Wc-
JG

6

Pli-, /Uv-dw q 3 1

r
To Whom It May Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
North America's 2n4 greatest source of fresh water. There is no sane reason for placing millions of tons of toxin-laden,
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in an
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
Swamp over a 24-hour period in the mid '80s and caused no significant flooding. Only 20° of rain fell over 48 hours
during Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and enhanced
industrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
capable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a suitable
site for a hundred-acre mountain of garbage almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp be
restored and protected, ,rot made the home of a regional dump.
name Address: (Street, city, state, zip)

?O r3?, Cr kJ

z J</
0 C,

i

J
ql? Cd _4'r,
?- C

:`"`,?C? -
5kJ "--. Z 5 E,.4,5 ''c), i,./l?.t? 1I? yv,C. 7o?ti?
C& e- 4, 5

de; 3 Z) ?Z t? k Z_ Z 4sx? X-,e- ,?_ks4;L6
?Vpv

Ci ?C C C `C
n "'

J

C- . V 1_ , u Ut
r?S A-tk ?,,z
S-
XY? I LP C,?wlovLll-? /Jc,

?;
v

To Whom It May Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
North Americas 2 greatest source of fresh water. There is no sane reason for placing millions of tons of toxin-laden
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolinas or in are
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
Swamp over a 24-hour period in the mid `80s and caused no significant flooding. Only 20" of rain fell over 48 hours
during Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and enhances:
industrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
capable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a suitable
site for a hundred-acre mountain of garbage almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swainp be
restored and protected, not made the home of a regional dump.
.1
r?arn8 Address: (Street, city, state, zip)

t r L/E Y ?? " /?r?V ?? pct ) r )?( rli

r
> c

S S ? 4

112 t-

?15 'ITS
_YL
f

17 ?7,
-?
•' r

kl)

10
To Where It May Concem
As cancemed ckizens ofBrunswick County, NC, we would like to go on record as
opIx sing the proposed lteigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of
watt r pollution, increased probability of flooding, threat to sensitive environment already
seve -ely compromised, and many other facets of degradation of the environment and
qual ty of He in our area. We ask that you deny permits for this landfill, or at least (Hold
exte; isive public hearings before a final consideration.
Name - Address: (Street, city, state, zip) -- 1
1

1

U ? L-r t ? cir bc, S>< S 11 1 ? / f ? /? L' r,/ s 01

j

i

9 LA Ott-I OZ)
-

di V -Z
1-3
nx c 4 0
-
L-1 ZI_ ?Ie
7 "/e/ 6Z

1)

To Whom It May Concern:
As concerned citizens of Brunswick County, NC, we would like to go on record as
opposing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of
water pollution, increased probability of flooding, threat to sensitive environment already
severely compromised, and many other facets of degradation of the environment and
quabty of life in our area. We ask that you deny permits for this landfill, or at least hold
extensive public hearings before a final consideration.
z
C
G

Nam kd ress: (Street, city, state, zip)

V, Z-6 Cf
UKA6-n%?
a4a
D c-, 1Cocit- VI.
.
--

O'er (? ' • / V G ? ? ..
P, 14
?s c

'13 n?n?
LAJ
q5 is h-?? t? ?ci Ai?, N

.I- LAL:?4, JlaY-c?? 0

.
&-?;A
r C,

5. /

52 CC ?? Al f 1v
016x
/,>-7
ll ?o 6s4,4OJ M, Sri ,vi-ti

fiamoma- i
k

0

To Whom It May Concern:
There is no justification for burying garbage on a thin street of plastic in the middle of the Green Swamp, the site of
North America's 2' greatest source. of fresh water. There is no sane reason for placing millions of tons of toxin-lade
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in a;
area equated in bio Diversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
Swamp over a 24-hour period in the mid 'bps and caused no significant flooding. Only 20' of rain fell over R hours
during Hunicane Fl,)yd and created flash floods cresting over 23 feet With the presence of increased and enhances
industrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
capable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a subbb
site for a hundred-acre mountain of garbage almost 300 feet tell.
THEREFORE, we tie undersigned, believe it is In the best interest of the general public that the Green Swamp be
restored and protected, IIgi made the home of a regional dump.
Nampe + Address: (Stroet, chy, state, zip)
77 7
t (1
N?
Ald nn
j /
y t` aC 2. Ici'2J
n ` ? l
4,(- 0 f 1, t_-, ?,1 cl G?? ,t:? g- 4,1' C z
I 1/jv ?)" t t
J
4
PCI ):U)
:3 o.
1)6fN C-1
Lt A
C \ ?f`q
;V
X11 x 1C ,V\ C;
-.k Lk
41
.1, J 1
?rvtq? rats

J

To Whom It May Concern:
As concerned citizens of Brunswick County, NC, we would like to go on record as
opposing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of
water pollution, increased probability of flooding, threat to sensitive environment already
severely compromised, and many other facets of degradation of the environment and
quality of life in our area. We ask that you deny permits for this landfill, or at least hold
extensive public hearings before a final consideration.

C
C
C
r
t
Address: (stre t, city,-Mate, zi

p
f-?>. r Dc)fzSb

J
? 71,
f
?- /
1 l J

C

f C1
C.

?? ?'E?:?;?/"'?.?:•? c??':t?? ??????%_?. r?.%y? /?? tau ? !?,?//o/; ?.

-Sao-' e

i. s vim' -.•' E F' i f l : c c L j? It 2

u
r,` f? G, r...?•
kill

c-

To Whom It May Concern:

There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the
site of North America's 2 d greatest source of fresh water. There is no sane reason for placing millions of tons
of toxin-laden garbage in an area subject to contaminate two aquifers supplying most of the water to eastern
North Carolina or in an area equaled in biodiversity only by the Great Tropical Rain Forest of Central America.
22" of rain fell in the Green Swamp over a 24-hour period in the mid `80s and caused no significant flooding.
Only 20" of rain fell over 48 hours during Hurricane Floyd and created flash floods cresting over 23 feet. With
the presence of increased and enhanced industrial draining, the Green Swamp is destined to once again be
the source of colossal flooding in the near future, capable of sending its swirling destruction in any direction
depending on wind and sheet flow - certainly not a suitable site for a hundred-acre mountain of garbage
almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swarnp
be restored and protected, not made the home of a regional dump.
Name Address: (Street, city, state, zip)
tj L

mil! 6o =16,t,
J ?-
?LTr
A c) CU (v e ,, 0y`jC/

"r) Uc
_

c
4) A,
lo??? l I? VL ?
? ?I (r?

7?J? 7

r ,
?L?l?LG l ?/? c cC I /
?Z? < ti ( 0 ,14 ?.
u? I ; 9
k; C 94 -2-

100 L'A 0 G
,
r
Rua ?_, ?Gl ? Ql:_?

) `l

To Whom It May Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the
site of North Americas 2nd greatest source of fresh water. There is no sane reason for placing millions of tons
of toxin-laden garbage in an area subject to contaminate two aquifers supplying most of the water to eastern
North Carolina or in an area equaled in biodiversity only by the Great Tropical Rain Forest of Central America.
22" of rain fell in the Green Swamp over a 24-hour period in the mid '80s and caused no significant flooding.
Only 20" of rain fell over 48 hours during Hurricane Floyd and created flash floods cresting over 23 feet. With
the presence of increased and enhanced industrial draining, the Green Swamp is destined to once again be
the source of colossal flooding in the near future, capable of sending its swirling destruction in any direction
depending on wind and sheet flow - certainly not a suitable site for a hundred-acre mountain of garbage
almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp
be /restored anyroe
tted
, not made the home of a regional dump.
??a? /7--11 _.: (,-

Name
C - - ?? •f /JG i Y r C 0< 0 - ? •'?
Address: (Street, city, state, zip)
C
,
an,
LO
- v N C c 7`? S
C
L x 100 4-h -

2G4 ;
nee,( Focl_ C:^ Ed,
?
n ?~

ell,
s ?5 `?,z? e ass %

`A C?
U-z ? 11X7 ega-cl ,yam. Clio
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114,h uda LaLff a
f
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L' L AI, S, E
SE. Ze A,) 0
_ / r?Y /A- )/)/9 L?L 0:? ZJ; V
o C,? /l A'. SJ c) (,L)

Z- bi-xp_ UJW\)\, f) SaLk tl t

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14 17
NC

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r A-WO X/
L
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n
Q/U1 C1L)nl ??
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To IVhom It May Concern:
As c 3neern d citizens of Brunswick County, NC, we would hike to go on record as
opIx sing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
thou 0 located in Columbus County, our county would be impacted by probability of
watt r pollution, increased probability of flooding, threat to sensitive environment already
seve rely compromised, and many other facets of degradation of the environment and
qual ty of life in our area. We ask that you deny permits for this landfill, or at least hold
exte; isive public hearings before a final consideration.
Name - Address: (Street, city, state, zip)

AA

6-5 G J
Z?5 z--
/ C
C

/''

v\
S

.'l ??L'L '?.C/? /.r?(.-? {/ ? ? ,/ ?r7.q. ?? ?_J ?Z???rL?L'?? I L'-?-L ?'C ``"i ' ?.'// ?^ -

To Whom It May Concern:
As concerned citizens of Brunswick County, NC, we would like to go on record as
opposing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of
water pollution, increased probability of flooding, threat to sensitive environment already
severely compromised, and many other facets of degradation of the environment and
quality of life in our area. We ask that you deny permits for this landfill, or at least hold
extensive public hearings before a final consideration.
N
Aaaress: (Street, city, state, zip)

.

2 0 ev
Z) -5 57 Y-? '/

f
.
X
s' Cl
-

?u rl ?l G?
; 6' ell (Z .2-

C ?`c
3> ?/ U j?? J f- 5? ll? ?If frv c c?
S
? C / ??L /Yr? /(/?/ r? _?

57

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,

C
To Whom It May Concern:
As concerned citizens of Brunswick County, NC, we would like to go on record as
opposing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of
water pollution, increased probability of flooding, threat to sensitive environment already
severely compromised, and many other facets of degradation of the environment and
quality of life in our area. We ask that you deny permits for this landfill, or at least hold
extensive public hearings before a final consideration.

i?-
r?"-/

Ct,
-r
I

name Address: (Street, city, state, zip)

L

/C y

?' ;?cr fll1'C ?r
_ t
o 'r

,
/ G

Dc. SW
ro)W

n ' F

d? cr z ?? r 1-xl c

tobik')j ) Y&
??' 6,u
Z?c
?[ >?? 3 Z, ?? (? . ? ??- .r.? •? i ,mod ? ?i?C

?i

-L i
To Whom It May Concern:
As concerned citizens of Brunswick County, NC, we would like to go on record as
opposing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of
Neater pollution, increased probability of flooding, threat to sensitive environment already
severely compromised, and many other facets of degradation of the environment and
quality of life in our area. We ask that you deny permits for this landfill, or at least hold
extensive public hearings before a final consideration.

rya Address: (Street, city, state, zip)
V s ('j (-C 0 77-C I\1L Z eY7 0

?n?Z'k batv- <? 7Sh 0, 1/0
ZZ
Q / -1

.plc'
C
C-. 1 ?G ?= JLI C. ay 7 0
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A A) J'L ,l,j J - L ?r. w
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CDr C1 0 Po fix 13 5ha?1? -+e n?. ?q?S Ch?"? } :5?.?
.

?`?Vj.-1('Yl U, /"% ?` `(r r r:J'"l \i?(''?-? ftir ?ws
r.

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To `Vhom It May•Concem
As c )ncerned citizens of Brunswick County, NC, we would like to go on record as
opposing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of
watt r pollution, increased probability of flooding, threat to sensitive environment ak=dy
seve -ely compromised, and many other facets of degradation of the environment and
qual ty of life in our area. We ask that you deny permits for this landfill, or at least hold
exit, nsive public hearings before a final consideration.
Name Address: (Street, city, state, zip)

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To Whom It May Concern:
:SAN - 2 2002
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
North Americas 2 greatest source of fresh water. There is no sane reason for placing millions of tons of toxin-laden
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in an
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
Swamp over a 24-hour period in the mid `80s and caused no significant flooding. Only 20" of rain fell over 48 hours
during Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and enhanced
industrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
capable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a suitable
site for a hundred-acre mountain of garbage almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp be
restored and protected, not made the home of a regional dump.
.l..
?•a???a Aaaress: (Street, city, state, zip)
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To Whom It May Concern:
As c:)ncerned citizens of Brunswick County, NC, we would like to go on record as
oplx sing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of
watt r pollution, increased probability of flooding, threat to sensitive environment a}ready
seve my compromised, and many other fitcets of degradation of the environment and
qual ty of life in our area. We ask that you decry permits for this landfill, or at least hold
exte; isive public hearings before a final consideration.
Name Address: (Street, city, state, zip)

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To Whom It May Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
North Americas 2 greatest source of fresh water. There is no sane reason for placing millions of tons of toxin-laden
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in an
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
Swamp over a 24-hour period in the mid `80s and caused no significant flooding. Only 20" of rain fell over 48 hours
during Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and enhanced
industrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
capable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a suitable
site for a hundred-acre mountain of garbage almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp be
restored and protected, not made the home of a regional dump.

L
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I ame Aaaress: (street, city, state, zip)

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To Whom It May Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
North America's 2"a greatest source of fresh water. There is no sane reason for placing millions of tons of toxin laden
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in an
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
Swamp over a 24-hour period in the mid `80s ,-nd caused no significant flooding. Only 20" of rain fell over 48 hours
during Hurricane Floyd and created flash flood:- cresting over 23 feet. With the presence of increased and enhanced
industrial draining, the Green Swamp Is destined to once again be the source of colossal flooding in the near future,
capable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a suitable
site for a hundred-acre mountain of garbage almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp be
restored and protected, not made the home of a regional dump.
name Address: (Street, city, state, zip)
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To Whom It May Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
North Americas 2 greatest source of fresh water. There is no sane reason for placing millions of tons of toxin-laden
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in an
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
Swamp over a 24-hour period in the mid `80s and caused no significant flooding. Only 20" of rain fell over 48 hours
during Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and enhanced
industrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
capable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a suitable
site for a hundred-acre mountain of garbage almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamis be
restored and protected, not made the home of a regional dump.
.l.
Aaaress: (street, city, state, zip)

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Tc Who -m It May-Concern:
As concerned citizens of Brunswick County, NC, we would like to go on record as
opposing the proposed Reigle Ridge 1bnicipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probab ity of
water pollution, increased probability of flooding, threat to semi6w environment already
severely compromised, and many other facets of degradation of the enviroinnlent and
quality of life in our area. We ask that you deny permits for this landfill, or at leas*_ hold
ext.e;:sive public hearings before a final consideration.
mama -

- -•••- Address: (street, cip , state, zip) ?
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To Whom It May Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
North America's 2"d greatest source of fresh water. There is no sane reason for placing millions of tons of toxin-laden
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina orfnAn
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
Swamp over a 24-hour period in the mid'80s and caused no significant flooding. Only 20" of rain fell over48*hou^s
during Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of Increased and enhanced
industrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
capable of sending its swirling destruction in any direction depending on wind and sheet flout - certainly not a suitable
site for a hundred-acre mountain of garbage almost 340 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp be
restored and protected, not made the home of a regional dump.
Name Address: (Street, city, state, zip)
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To Whom It May-Concern:
As concerned citizens of Brunswick County, NC, we would like to go on record as
opposing the proposed Reigle Ridge Municipal Landfill in the Green Swamp, Even
though Io"cated in Columbus County, our county would be impacted by probability of
water pollution, increased probability of flooding, threat to sensitive environment already
severely compromised, and many other facets of degradation of the environment and
quabty of life in our area. We ask that you deny permits for this landfill, or at least hold
extensive public hearings before a final consideration.
Address: (Street, city, state, zip) _---
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To Who: it may Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
North Americas 2" greatest source of fresh water. There is no sane reason for placing millions of tons of toxin-laden
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in an
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
Swamp over a 24-hour period in the mid `80s and caused no significant flooding. Only 20" of rain fell over 48 hours
during Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and enha nceu
industrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near f,.sture,
capable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a Suitable
site for a hundred-acre mountain of garbage almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp be
restored and protected, not made the home of a regional dump.
Aaaress: (street, city, state, zip)
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To Whom It May Concern:
As concerned citizens of Brunswick County, NC, we would like to go on record as
opposing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of
water pollution, increased probability of flooding, threat to sensitive environment already
severely compromised, and many other facets of degradation of the environment and
quality of life in our area. We ask that you deny permits for this landfill, or at least hold
extensive public hearings before a final consideration.

Name /Address: (Street, city, state, zip)
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To Whom It May Concern:
As c incerned citizens of Brunswick County, NC, we would lice to go on record as
opIx sing the proposed Reigle Ridge Municipal ImWfill in the Green Swamp. Even
thou gh located in Columbus County, our county would be impacted by probability of
Ovate r pollution, increased probability of flooding, threat to sensitive environment already
seve -ely compromised, and many other facets of degradation of the environment and
quat ty of fife in our area. We ask that you deny permits for this landfill, or at least hold
exte; nsive public hearings before a final consideration.
Name Address: (Street, city, state, zip)
C. N, ' 7 f ~ Z?, c' ; 7?E t

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To Whom It May Concern:
As concerned citizens of Brunswick County, NC, we would like to go on record as
opposing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of
water pollution, increased probability of flooding, threat to sensitive environment already
severely compromised, and many other facets of degradation of the environment and
quality of life in our area. We ask that you deny permits for this landfill, or at least hold
extensive public hearings before a final consideration.
Name Address: (Street, city, state, zip)
1cu 10?C' CS n'
y
a 1? t w? O Q R
r

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To Whom It May Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
North Americas 2 greatest source of fresh water. There is no sane reason for placing millions of tons of toxin-lader
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in ar
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
Swamp over a 24-hour period in the mid '80s and caused no significant flooding. Only 20" of rain fell over 48 hours
during Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and enhanced
industrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
capable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a suitable
site for a hundred-acre mountain of garbage almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp be
restored and protected, not made the home of a regional dump.
r; . _
-Q" Aaaress: (street, city, state, zip)

.5?Z
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To Whom It May Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
North America's 2"d greatest source of fresh water. There is no sane reason for placing millions of tons of toxin-laden
3arbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in an
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
Swamp over a 24-hour period in the mid '80s and caused no significant flooding. Only 20" of rain fell over 48 hours
Suring Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and enhanced
ndustrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
;apable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a suitable
;ite for a hundred-acre mountain of garbage almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp be
-estored and protected, not made the home of a regional dump.
Nn MA

i3 ?,,? e
+?I (o mutiress: (street, city, state, zip)

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To Whom It May Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
North Americas 2 greatest source of fresh water. There is no sane reason for placing millions of tons of toxin-laden
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in an
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
Swamp over a 24-hour period in the mid `80s and caused no significant flooding. Only 20" of rain fell over 48 hours
during Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and enhanced
industrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
capable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a suitable
site for a hundred-acre mountain of garbage almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp be
restored and protected, not made the home of a regional dump.

Nam Address: (Street, city, state, zip)
J,13 fls?
Vc)x
?umm

r1
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To Whom It May -Concern:
As c 3ncerned citizens of Brunswick County, NC, we would like to go on record as
opposing the proposed Reigle Ridge Municipal Landfill in the Green Swamp, Even
thou gh located in Columbus County, our county would be unpacked by probability of
water pollution, increased probability of flooding, threat to sensitive environment ah=.dy
save -eiy compromised, and many other facets of degradation of the environment and
qual ty of life in our area. We ask that you deny permits for this landfill, or at least hold
exte, Wve public hemings before a f W consideration.
Name Address: (Street, city, state, zip) -
/jC

0 Y /r? ?2 h(-O'ln ''61 r
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To Whom It May Concern:
As concerned citizens of Brunswick County, NC, we would like to go on record as
opposing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of
water pollution, increased probability of flooding, threat to sensitive environment already
severely compromised, and many other facets of degradation of the environment and
quality of life in our area. We ask that you deny permits for this landfill, or at least hold
extensive public hearings before a final consideration.
To Whom It May Concern:
As c ancerned citizens of Brunswick County, NC, we would lace to go on record as
opix sing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though located in Columbus County, our county would be impacted by probability of
water pollution, increased probability of flooding, threat to sensitive environment already
seve -ely compromised, and many other facets of degradation of the environment and
qual ty of life in our area. We ask that you deny permits for this landfill, or at least hold
extensive public hearings before a final consideration.
Name - Address: (Street, city, state, zip)
> J

0lVI Ctait?? ? C - 2??C?° ?

n
`/6 t

Whom It May Concern:
here is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
forth America's 2"d greatest source of fresh water. There is no sane reason for placing millions of tons of toxin-laden
arbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in an
rea equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
,wamp over a 24-hour period in the mid r80s and caused no significant flooding. Only 20" of rain fell over 48 hours
uring Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and enhanced
idustriai draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
apable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a suitable
ite for a hundred-acre mountain of garbage almost 300 feet tall.
'HEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp be
estored and protected, not made the home of a regional dump.
Name Address: (Street, city, state, zip)

,?e U Ce L?-' Z YZZ
Yv?

1 1I1 A ?ii
?q- ?/`

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r
To AVhom It AUy Concern:
As concerned cozens of Brunswick County, NC, we would like to go on record as
oppc -sing the proposed Reigle Ridge Municipal Landfill in the Green Swamp. Even
though looted in Columbus County, our county would be impacted by probability of
iwate r pollution, increased probability of Hooding, threat to sensitive environment already
seve -ely compromised, and many other facets of degradation of the environment and
quay ty of life in our area. We ask that you deny permits for this lancft or at least hold
exte;isive public brings before a final consideration.
Name - Address: (Street, city, state, zip)
;2Z

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To Whom It May Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
North America's 2' greatest source of fresh water. There is no sane reason for placing millions of tons of toxin-laden
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in an
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
Swamp over a 24-hour period in the mid '80s and caused no significant flooding. Only 20" of rain fell over 48 hours
during Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and enhanced
industrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
capable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a suitable
site for a hundred-acre mountain of garbage almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp be
restored and protected, not made the home of a regional dump.
Name Address: (Street, city, state, zip)
If

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To Whom It May Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
North Americas 2 greatest source of fresh water. There is no sane reason for placing millions of tons of toxin-laden
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in an
area equaled in biodiversity only by the Great Tropical Rain Forest of Central America. 22" of rain fell in the Green
Swamp over a 24-hour period in the mid '80s and caused no significant flooding. Only 20" of rain fell over 48 hours
during Hurricane Floyd and created flash floods cresting over 23 feet. With the presence of increased and enhanced
industrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
capable of sending its swirling destruction in any direction depending on wind and sheet flow - certainly not a suitable
site for a hundred-acre mountain of garbage almost 300 feet tall.
C
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp be
restored and protected, trot made the home of a regional dump.
To Whom It May Concern:
There is no justification for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the
site of North Americas 2 u greatest source of fresh water. There is no sane reason for placing millions of tons
of toxin-laden garbage in an area subject to contaminate two aquifers supplying most of the water to eastern
North Carolina or in an area equaled in biodiversity only by the Great Tropical Rain Forest of Central America.
22" of rain fell in the Green Swamp over a 24-hour period in the mid `80s and caused no significant flooding.
Only 20" of rain fell over 48 hours during Hurricane Floyd and created flash floods cresting over 23 feet. With
the presence of increased and enhanced industrial draining, the Green Swamp is destined to once again be
the source of colossal flooding in the near future, capable of sending its swirling destruction in any direction
depending on wind and sheet flow - certainly not a suitable site for a hundred-acre mountain of garbage
almost 300 feet tall.
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp
be restored and protected, not made the home of a regional dump.
Name

so" ..
,„• Address: (S,trept, city,tstate, zip
tom' t'• " I ?1?/ ??? 11_ri ?V?.
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To Whom It May Concern:

There is no justification fr burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the
site of North Americas 2n, greatest source of fresh water. There is no sane reason for placing millions of tons
of toxin-laden garbage in an area subject to contaminate two aquifers supplying most of the water to eastern
North Carolina or in an area equaled in biodiversity only by the Great Tropical Rain Forest of Central America.
22" of rain fell in the Green Swamp over a 24-hour period in the mid '80s and caused no significant flooding.
Only 20" of rain fell over 48 hours during Hurricane Floyd and created flash floods cresting over 23 feet. With
the presence of increased and enhanced industrial draining, the Green Swamp is destined to once again be
the source of colossal flooding in the near future, capable of sending its swirling destruction in any direction
depending on wind and sheet flow - certainly not a suitable site for a hundred-acre mountain of garbage
almost 300 feet tall.

n
THEREFORE, we the undersigned, believe it is in the best interest of the general public that the Green Swamp
be restored and protected, not made the home of a regional dump.
Name Address: (Street, city, state, zip)

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To Whom It M ??'? ~ ; 'Pl(1f
sy Concern:
There is no justitjcation for burying garbage on a thin sheet of plastic in the middle of the Green Swamp, the site of
North America's 2` greatest source. of fresh water. There is no sane reason for placing millions of tons of toxin-lade+
garbage in an area subject to contaminate two aquifers supplying most of the water to eastern North Carolina or in ai
area equaled in NO Diversity only by the Great Tropical Rain Forest of Central America. 22° of rain fell In the Green
Swamp over a 24-hour period in the mid `80s and caused no significant flooding. Only 20" of rain fell over M hours
during Hurricane Floyd and Meted flash floods cresflng over 23 feet. With the presence of increased and enhanret
industrial draining, the Green Swamp is destined to once again be the source of colossal flooding in the near future,
capable of sending its swlriing destruction in any dkecdon depending on wind and sheet flow -- certainly not a suitabh
site for a hundred-ace mountain of garbage asst 300 feet to#.
THEREFORE, we tote undersigned, believe it is in the best Interest of the general public that the Green Swamp be
and protected, tg made the home of a regional dump.
13 5 7

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*Ms. Kit Adcock, President
Morrisville, NC
*Dr. Gene Douglas, Vice President
Bald Head Island, NC
*Mr. Vivian Hollinshed, Secretary
Fayetteville, NC
*Mr. Larry Lammert, Treasurer
Bald Head Island, NC
Directors at Large:
Mr. Harry Baxley
Bald Head Island, NC
Dr. Bill Berne
Bald Head Island, NC
Dr. Eric Bolen
Wilmington, NC
Mr. William J. Cathcart
Raleigh, NC
Ms. Karen Christian
Laurinberg, NC
Ms. Mary Conklin
Bald Head Island, NC
*Dr. John Dees
Cary, NC
Mr. George Enochs
Bald Head Island, NC
*Dr. William Farabow
High Point, NC
*Mr. David Hasson
Bald Head Island, NC
Dr. Alexander Hattaway
Raleigh, NC
Ms. Gianca Helgesen
Bald Head Island, NC
Mr. Charlie Himes
Bald Head Island, NC
Dr. Paul Hosier
Wilmington, NC
Ms. Cheryl Lingenfelter
Charlotte, NC
Ms. Sarah Neuwirth
Wilmington, NC
Ms. Mary Peyton
Bald Head Island, NC
Dr. Kenneth Reckhow
Durham, NC
Ms. Helen Rozar
Bald Head Island, NC
Ms. Maureen Syring
Bald Head Island, NC
Mr. Bill Taft
Bald Head Island, NC
Dr. Bob Timmons
Bald Head Island, NC
*Dr. Thad Wester
Bald Head Island, NC
*Executive Committee
BALD HEAD ISLAND CONSERVANCY, INC.
Post Office Box 3109 • 7000 Federal Road • Bald Head Island, Noith Carolina • 28461
Tel. [phone] • FAX [phone] . Web Site: www.bhic.org • E-Mail: [e-mail]
December 28, 2001
-Mr. John-Dorney
Division of Water Resources
Archdale Building
1611 Mall Service Center
Raleigh, NC 27699-1611
Dear Mr. Dorney:
Alen
I am writing to you on behalf of the Bald Head Island Conservancy, a non-profit
organization of 750-plus members who support our efforts to protect, preserve,
and promote the environmental resources of Bald Head Island and of the
surrounding area. We strongly oppose proceeding any further with the proposed
regional. landfill. in.theGreen Swamp _in.Columbus.County.until.a.full
environmental impact study can be complete .
The Green Swamp is simply too unique, sensitive, and valuable a resource to
jeopardize without first studying all possible effects that such a project may
have on this ecosystem. There are currently too many unanswered questions
concerning possible degradation of water quality, loss of unique habitat, impact
of commercial traffic, etc. to proceed without utilizing absolute due diligence.
This seems to be exactly the type of proposed project that must be considered in
light of a complete environmental impact study, and anything less should not be
allowed. I hope you will be able to push for this as this project proceeds.
Thank you for your efforts to protect this extremely valuable resource!
Sincerely,
H. Gilbert Powell, III
Executive Director
BRUNSWICK COUNTY ADMINISTRATION
BRUNSWICK COUNTY GOVERNMENT CENTER
45 COURTHOUSE DRIVE N.E.
BOLIVIA, NORTH CAROLINA 28422 TELEPHONE
MAILING ADDRESS: [phone]
POST OFFICE Box 249 [phone] (NC)
BOLIVIA, NORTH CAROLINA 28422 FACSIMILE
[phone]
January 10, 2002
Mr. John Dorney
NC DENR, Division of Water Quality
1650 Mail Service Center
Raleigh, North Carolina 27699-1650
Dear Mr. Dorney:
Enclosed please find a copy of a letter from Mr. Marty K. Lawing, Brunswick County
Manager to Mr. James C. Coffey, Acting Chief, DENR, reference the proposed Reigel Ridge MSW
Landfill in Columbus County. I have also included a copy of the Resolution passed by the Brunswick
County Board of Commissioners requesting that the Columbus County Board of Commissioners
conduct a Public Hearing concerning the same.
If you have any questions, please do not hesitate to contact our office.
Sincerely,
avA?W)kk* e
Andrea Merklinger
Administrative Assistant
/am
Enclosure (2)
O?J?SWICK CMG f?
CA
i
r• ?

BRUNSWICK COUNTY ADMINISTRATION
BRUNSWICK COUNTY GOVERNMENT CENTER
45 COURTHOUSE DRIVE N.E.
BOLIVIA, NORTH CAROLINA 25422 TELEPHONE
MAILING ADDREss: [phone]
POST OFFICE Box 249 [phone] (NC)
BOLIVIA, NORTH CAROLINA 28422 FACSIMILE
(910) 5 2
dN , ^r0L
January 10, 2002
NC DENR Wetlands Division
2321 Crabtree Blvd., Suite 250
Raleigh, North Carolina 27604
Dear Sir or Madam:
Enclosed please find a copy of a letter from Mr. Marty K. Lawing, Brunswick County
Manager to Mr. James C. Coffey, Acting Chief, DENR, reference the proposed Reigel Ridge MSW
Landfill in Columbus County. I have also included a copy of the Resolution passed by the Brunswick
County Board of Commissioners requesting that the Columbus County Board of Commissioners
conduct a Public Hearing concerning the same.
If you have any questions, please do not hesitate to contact our office.
Sincerely,
\?L • - 1
Andrea Merklinger d
Administrative Assistant
/am
Enclosure (2)
?eJ?SM?ICK c?G?s
4 yp APO???p
i-
BRUNSWICK COUNTY ADMINISTRATION
MAILING ADDRESS:
POST OFFmcE Box 249
BOLIVIA, NORTH CAROLINA 28422
BRUNSWICK COUNTY GOVERNMENT CENTER
45 COURTHOUSE DRIVE N.E.
BOLIVIA, NORTH CAROLINA 28422
December 20, 2001
Mr. James C. Coffey, Acting Chief
Solid Waste Section
Department of Environment and Natural Resources
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
RE: Proposed Reigel Ridge MSW Landfill, Columbus County
Dear Mr. Coffey:
TELEPHONE
[phone]
[phone] (NC)
FACSIMILE
[phone]

Many people in Brunswick County are very concerned about the potential environmental impacts
which may result from the construction of the proposed MSW landfill site in Columbus County. The
Brunswick County Commissioners have received hundreds of letters from residents of southeastern North
Carolina and northeastern South Carolina asking for assistance in preventing the construction of the landfill.
Multiple public presentations and requests have been made to the Commissioners by such organizations as the
Friends of the Green Swamp and the Brunswick Environmental Defense League. Although Brunswick County
has no direct jurisdiction over the project, we are very concerned about the impact such a facility could have on
surface and groundwater in our county.
The proximity of the proposed site to the Green Swamp and the high water table in the area of the
proposed site make us question the suitability of the site for an MSW landfill. I know that the landfill is
projected to have a favorable financial impact on Columbus County. We support economic opportunity for
our neighboring county but not at the expense of the environment and natural resources of Brunswick County.
Columbus County is large in land area and sparsely developed. It seems that the landfill developer could
identify a more suitable site with fewer obvious environmental liabilities.
Thank you for your thorough evaluation and scrutiny of the permit application for the proposed
landfill site.
Sincerely,
Marty K. Lawing
County Manager
CC: Board of Commissioners
?SwWX co
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WMnTj 0/ 1- T-W""d-
S?S.ty1CK Cp14?
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RESOLUTION REQUESTING COLUMBUS COUNTY BOARD OF COMMISSIONERS TO
CONDUCT PUBLIC HEARING CONCERNING REIGEL RIDGE LANDFILL
WHEREAS, the Brunswick County Board of Commissioners have kept a long tradition of care
and concern for the natural order of things and the promotion of environmental protection and preservation,
and
WHEREAS, the Brunswick County Board of Commissioners have recently been appraised of the
concerns of citizens that live in Brunswick County near the Columbus County line, and
i
A WHEREAS, those persons' concerns over the possible location of a lined landfill in an area of the
Green Swamp were couched in terms that, if true, would be rational ideas that might be appropriate for
redress or alteration, and
WHEREAS, that information was received in a public meeting of the Brunswick County
Commissioners, and related that the business that is the primary proponent and developer of the landfill
might be a cause for concern that is worthy of investigation, and
WHEREAS, Brunswick County will be impacted by the location of the landfill due to the
geography of the site, and the Waccamaw River would also be affected due to its proximity to the proposed
site, and
WHEREAS, some of these concerns, taken alone, might not be of alarming interest, but the
composite affect of all of these facets, taken in unison, would be a matter that would deserve being
investigated in an open forum.
NOW THERFORE, THE BRUNSWICK COUNTY BOARD OF COMMISSIONERS ARE
RESOLVED, to humbly and respectfully request that the Columbus County Board of Commissioners, a
body of equal status and tradition, publish notice and conduct a public hearing in and for Columbus
County, so that the citizens of Columbus County might hear the address of their concerns in a logical and
orderly fashion, as our system of government does provide.
This the 5th day of March, 2001.
Chair
Attest:
?j as
s
Deborah S. Deb Gore, Jerk tot a Board 1 `'?f
JOHN D. RUNKLE
ATTORNEY AT LAW
POST OFFICE BOX 3793
CHAPEL HILL, NORTH CAROLINA 27515
TELEPHONE: [phone]
January 11, 2002
Cyndi Karoly
Wetlands Unit
NC Division of Water Quality
1650 Mail Service Center
Raleigh, NC 27699-1650
Re: Riegel Ridge Landfill, 401 Certification, ID No. 011680
Dear Ms. Karoly:
,MM t 5 XO2
I reviewed the files for the Riegel Ridge Landfill's 401 certification yesterday. I noticed
that you did not have the December 7, 2001, letter from Jim Coffey of the Solid Waste
Section to Bill Dreitzler of Riegel Ridge after the Section's review of the landfill's site study
application. As you can see, there are several significant areas in which this site is not
suitable for a landfill and for which there are not engineering solutions. There are serious
questions about the applicant's financial qualifications.
Please give these concerns your serious attention as you review the application for the 401
certification.
Sincerely,
John D. Runkle
for Friends of the Green Swamp
Enc.
CC. Jeff Lane, FOGS
Derb Carter, Southern Environmental Law Center
Todd Miller, NC Coastal Federation
RECYCLED PAPER
s
4,
Swamp Watch Act-ion Team
200 Benson Road NE
Leland, N.C. 28451 n
swampwatchteam@ao11 oMV;ii_,
?C
J o, D
CERTIFIED MAIL
March 8, 2002
US Army Corps of Engineers
Wilmington District
Angie Pennock
P. O. Box 1890
Wilmington, North Carolina 28402
RE: Action ID No. 200100853, Application of Riegel Ridge, LLC for permit to construct municipal solid waste
landfill in the Green Swamp
Dear Ms. Pennock:
A landfill is not a "water-dependent" activity. The Corps' rules (40 CFR § 230.10(3)) specify that the discharge of
dredge and fill material is not permitted for activities that are not water dependent. They further provide that
"[p]racticable alternatives that do not involve special aquatic sites are presumed to be available, unless clearly
demonstrated otherwise." Given the size of the proposed project and the large impact to wetlands (Honey Island
Swamp, South Brunswick Estuaries, the Peedee Aquifer outcropping, the Surficial Aquifer, and the Waccamaw River), a
detailed analysis of practicable alternatives must be provided, in accordance with Regulatory Guidance Letter, No. 93-2,
"Guidance on Flexibility of the 404(b)(1) Guidelines and Mitigation Banking" 11 (August 23, 1993), which provide in
relevant part that "The amount of information needed to make such a determination and the level of scrutiny required by
the [Section 404(b)(1) Guidelines] is commensurate with the severity of the environmental impact and the scope/cost of
the project." The guidance establishes less stringent alternatives review for projects that would have only minor impacts.
It also provides that "[g]enerally, as the scope/cost of the project increases, the level of analysis should also increase."
Corps' rules require detailed analysis of alternatives for this proposed project.
The applicant's Application, dated October 15, 2001, stated that a detailed alternative sites analysis was not included as
it was their understanding the site suitability issues were under the jurisdiction of the NC DENR Division of Solid
Waste Management and that these issues would not be re-evaluated by the USACE as part of the application. The Public
Notice issued by the Corps, therefore, did not contain the alternative sites analysis, presumably because it was thought to
be in the possession of NC DENR Division of Solid Waste. When questioned about the analysis, however, NC DSW
had not seen anything purporting to be an alternative sites analysis. A Public Notice Amendment was subsequently
issued by the Corps, addressing only the subject of the analysis but with no information. When we subsequently
requested a copy of the study through the Freedom of Information Act, we learned that the analysis had not been
received by the Corps until December 181h. Upon receiving the analysis (a study dated 1994), we find that the applicant
neglected to identify one of the formerly rejected 13 sites as being in the Green Swamp and that their own research stated
it would be likely to find that 92.5% of the Green Swamp was composed of hydric soils, making it unsuitable for a
landfill. The site they rejected in 1994 was near Livingston Creek and thought at that time to be too much of an impact
on groundwater. Given that the Livingston Creek site was not directly connected to the Honey Island Swamp,
Brunswick Estuaries, or the Waccamaw River, we are puzzled that only six years later, an area sited on the very edge of
Honey Island Swamp and draining into Brunswick Estuaries and the Waccamaw River seems to be their ideal spot to
pile a 107-acre, 280-foot mountain of solid waste and toxic leachate.
101 the Environment &'Our Children Will Die With It
. . . . . . . . . . . . . .
1%
..
ipR 4 h0
VVH i ER QUALITY
SECTION
March 8, 2002
Page 2
a
M
Had this detailed alternative sites analysis been favorable to siting a landfill in the Green Swamp, it would be a mute
point. However, the Applicant's own study rejected the Green Swamp site and clearly deemed the swamp as an
unfavorable place for a solid waste landfill, much less a regional landfill. Given that we, the public, were unable to
comment on this study because it was not given to us and, in fact, was not even in the possession of the State or the
Corps at the time of the issuance of either the Notice or Amended Notice, we find the Public Notice and the Public
Notice Amendment incomplete and hereby request that an additional comment period be opened for the public to give an
informed comment on this new information.
Sincerely,
Gean M. Seay, Co-Founder
Swamp Watch Action Team
cc: John Hankinson, EPA
William L. Cox, Wetlands Section Chief, USEPA
Kathy Matthews, USEPA/EAB
Garland Pardue, US Fish & Wildlife
William Straw, FEMA
Dept of Interior, US Fish & Wildlife Service
Senator John Edwards
Mike McIntyre, US House of Representatives
Mi ael Easley, Governor, NC
Environmental Management Commission
Ryan D. Turner, NC Environmental Management Commission
Charles H. Peterson, NC Environmental Management Commission
John Sutherland, NC Division of Water Resources
Frank McBride, Wildlife Resources Commission
Carolinas Commercial Fishermen's Association
NC Division of Coastal Management
Bill Holman, CWMTF
William Ross, Secretary, NC DENR
Wetlands Division, NC DENR
Senator Marc Basnight
Senator Luther Jordan
Senator R. C. Soles
Representative Dewey Hill
Representative Thomas Wright
Representative David Redwine
James Coffey, NC DENR, DSW
John Dorney, NC DENR, DWQ
Gregory T. Thorpe, PhD, NC DENR, DWQ
Danny Smith, NC DENR, DWQ
Brunswick County Commissioners
200 Benson Road NE
Leland, N.C. 28451
[e-mail]
Swamp Watch Acfi*on Team
CERTIFIED MAIL
March 8, 2002 i
Mkt 13 W
US Army Corps of Engineers F;,ETLANDS GPOUP "?
Wilmington District ,TF'ikl ALITY SEGTIV;!%`
Angie Pennock
P. O. Box 1890
Wilmington, North Carolina 28402
RE: Action ID No. 200100853, Application of Riegel Ridge, LLC for permit to construct municipal solid waste
landfill in the Green Swamp
Dear Ms. Pennock:
A landfill is not a "water-dependent" activity. The Corps' rules (40 CFR § 230.10(3)) specify that the discharge of
dredge and fill material is not permitted for activities that are not water dependent. They further provide that
"[p]racticable alternatives that do not involve special aquatic sites are presumed to be available, unless clearly
demonstrated otherwise." Given the size of the proposed project and the large impact to wetlands (Honey Island
Swamp, South Brunswick Estuaries, the Peedee Aquifer outcropping, the Surficial Aquifer, and the Waccamaw River), a
detailed analysis of practicable alternatives must be provided, in accordance with Regulatory Guidance Letter, No. 93-2,
"Guidance on Flexibility of the 404(b)(1) Guidelines and Mitigation Banking" 11 (August 23, 1993), which provide in
relevant part that "The amount of information needed to make such a determination and the level of scrutiny required by
the [Section 404(b)(1) Guidelines] is commensurate with the severity of the environmental impact and the scope/cost of
the project." The guidance establishes less stringent alternatives review for projects that would have only minor impacts.
It also provides that "[g]enerally, as the scope/cost of the project increases, the level of analysis should also increase."
Corps' rules require detailed analysis of alternatives for this proposed project.
The applicant's Application, dated October 15, 2001, stated that a detailed alternative sites analysis was not included as
it was their understanding the site suitability issues were under the jurisdiction of the NC DENR Division of Solid
Waste Management and that these issues would not be re-evaluated by the USACE as part of the application. The Public
Notice issued by the Corps, therefore, did not contain the alternative sites analysis, presumably because it was thought to
be in the possession of NC DENR Division of Solid Waste. When questioned about the analysis, however, NC DSW
had not seen anything purporting to be an alternative sites analysis. A Public Notice Amendment was subsequently
issued by the Corps, addressing only the subject of the analysis but with no information. When we subsequently
requested a copy of the study through the Freedom of Information Act, we learned that the analysis had not been
received by the Corps until December 18`x`. Upon receiving the analysis (a study dated 1994), we find that the applicant
neglected to identify one of the formerly rejected 13 sites as being in the Green Swamp and that their own research stated
it would be likely to find that 92.5% of the Green Swamp was composed of hydric soils, making it unsuitable for a
landfill. The site they rejected in 1994 was near Livingston Creek and thought at that time to be too much of an impact
on groundwater. Given that the Livingston Creek site was not directly connected to the Honey Island Swamp,
Brunswick Estuaries, or the Waccamaw River, we are puzzled that only six years later, an area sited on the very edge of
Honey Island Swamp and draining into Brunswick Estuaries and the Waccamaw River seems to be their ideal spot to
pile a 107-acre, 280-foot mountain of solid waste and toxic leachate.
Kill the Environment & Our Children Will Die With It. • • • • • • • • • • • • • • • • •
March 8, 2002
Page 2
Had this detailed alternative sites analysis been favorable to siting a landfill in the Green Swamp, it would be a mute
point. However, the Applicant's own study rejected the Green Swamp site and clearly deemed the swamp as an
unfavorable place for a solid waste landfill, much less a regional landfill. Given that we, the public, were unable to
comment on this study because it was not given to us and, in fact, was not even in the possession of the State or the
Corps at the time of the issuance of either the Notice or Amended Notice, we find the Public Notice and the Public
1`Iutice -.Amendment incomplete and hereby request that an additional comment period be opened for the public to give an
informed comment on this new information.
Sincerely,
Gean M. Seay, Co-Founder
Swamp Watch Action Team
cc: John Hankinson, EPA
William L. Cox, Wetlands Section Chief, USEPA
Kathy Matthews, USEPA/EAB
Garland Pardue, US Fish & Wildlife
William Straw, FEMA
Dept of Interior, US Fish & Wildlife Service
Senator John Edwards
Mike McIntyre, US House of Representatives
Michael Easley, Governor, NC
NC Environmental Management Commission
Ryan D. Turner, NC Environmental Management Commission
Charles H. Peterson, NC Environmental Management Commission
John Sutherland, NC Division of Water Resources
Frank McBride, Wildlife Resources Commission
Carolinas Commercial Fishermen's Association
NC Division of Coastal Management
Bill Holman, CWMTF
William Ross, Secretary, NC DENR.
Wetlands Division, NC DENR
Senator Marc Basnight
Senator Luther Jordan
Senator R. C. Soles
Representative Dewey Hill
Representative Thomas Wright
Representative David Redwine
James Coffey, NC DENR, DSW
Jo orney, NC DENR, DWQ
regory T. Thorpe, PhD, NC DENR, DWQ
Danny Smith, NC DENR, DWQ
Brunswick County Commissioners
200 Benson Road NE
Leland, N.C. 28451
[e-mail]
Swamp Watch Action Team
CERTIFIED MAIL
March 8, 2002
US Army Corps of Engineers
Wilmington District
Angie Pennock
P. O. Box 1890
Wilmington, North Carolina 28402
RE: Action ID No. 200100853, Application of Riegel Ridge, LLC for permit to construct municipal solid waste
landfill in the Green Swamp
Dear Ms. Pennock:
A landfill is not a "water-dependent" activity. The Corps' rules (40 CFR § 230.10(3)) specify that the discharge of
dredge and fill material is not permitted for activities that are not water dependent. They further provide that
"[p]racticable alternatives that do not involve special aquatic sites are presumed to be available, unless clearly
demonstrated otherwise." Given the size of the proposed project and the large impact to wetlands (Honey Island
Swamp, South Brunswick Estuaries, the Peedee Aquifer outcropping, the Surficial Aquifer, and the Waccamaw River), a
detailed analysis of practicable alternatives must be provided, in accordance with Regulatory Guidance Letter, No. 93-2,
"`Guidance on Flexibility of the 404(b)(1) Guidelines and Mitigation Banking" 11 (August 23, 1993), which provide in
relevant part that "The amount of information needed to make such a determination and the level of scrutiny required by
the [Section 404(b)(1) Guidelines] is commensurate with the severity of the environmental impact and the scope/cost of
the project." The guidance establishes less stringent alternatives review for projects that would have only minor impacts.
It also provides that "[g]enerally, as the scope/cost of the project increases, the level of analysis should also increase."
Corps' rules require detailed analysis of alternatives for this proposed project.
The applicant's Application, dated October 15, 2001, stated that a detailed alternative sites analysis was not included as
it was their understanding the site suitability issues were under the jurisdiction of the NC DENR Division of Solid
Waste Management and that these issues would not be re-evaluated by the USACE as part of the application. The Public
Notice issued by the Corps, therefore, did not contain the alternative sites analysis, presumably because it was thought to
be in the possession of NC DENR Division of Solid Waste. When questioned about the analysis, however, NC DSW
had not seen anything purporting to be an alternative sites analysis. A Public Notice Amendment was subsequently
issued by the Corps, addressing only the subject of the analysis but with no information. When we subsequently
requested a copy of the study through the Freedom of Information Act, we learned that the analysis had not been
received by the Corps until December 18`h. Upon receiving the analysis (a study dated 1994), we find that the applicant
neglected to identify one of the formerly rejected 13 sites as being in the Green Swamp and that their own research stated
it would be likely to find that 92.5% of the Green Swamp was composed of hydric soils, making it unsuitable for a
landfill. The site they rejected in 1994 was near Livingston Creek and thought at that time to be too much of an impact
on groundwater. Given that the Livingston Creek site was not directly connected to the Honey Island Swamp,
Brunswick Estuaries, or the Waccamaw River, we are puzzled that only six years later, an area sited on the very edge of
Honey Island Swamp and draining into Brunswick Estuaries and the Waccamaw River seems to be their ideal spot to
pile a 107-acre, 280-foot mountain of solid waste and toxic leachate.
K11theEnvironment &OurChildren Will DieWithIt. • •••••••••••••••••••••••••
March 8, 2002
Page 2
Had this detailed alternative sites analysis been favorable to siting a landfill in the Green Swamp, it would be a mute
point. However, the Applicant's own study rejected the Green Swamp site and clearly deemed the swamp as an
unfavorable place for a solid waste landfill, much less a regional landfill. Given that we, the public, were unable to
comment on this study because it was not given to us and, in fact, was not even in the possession of the State or the
Corps at the time of the issuance of either the Notice or Amended Notice, we find the Public Notice and the Public
Notice Amendment incomplete and hereby request that an additional comment period be opened for the public to give an
informed comment on this new information.
Sincerely,
Gean M. Seay, Co-Founder
Swamp Watch Action Team
cc: John Hankinson, EPA
William L. Cox, Wetlands Section Chief, USEPA
Kathy Matthews, USEPA/EAB
Garland Pardue, US Fish & Wildlife
William Straw, FEMA
Dept of Interior, US Fish & Wildlife Service
Senator John Edwards
Mike McIntyre, US House of Representatives
Michael Easley, Governor, NC
NC Environmental Management Commission
Ryan D. Turner, NC Environmental Management Commission
Charles H. Peterson, NC Environmental Management Commission
John Sutherland, NC Division of Water Resources
Frank McBride, Wildlife Resources Commission
Carolinas Commercial Fishermen's Association
NC Division of Coastal Management
Bill Holman, CWMTF
Wi tam Ross, Secretary, NC DENR
etlands Division, NC DENR
Senator Marc Basnight
Senator Luther Jordan
Senator R. C. Soles
Representative Dewey Hill
Representative Thomas Wright
Representative David Redwine
James Coffey, NC DENR, DSW
John Dorney, NC DENR, DWQ
Gregory T. Thorpe, PhD, NC DENR, DWQ
Danny Smith, NC DENR, DWQ
Brunswick County Commissioners
Je&,t,- D
lpl?
Swamp Watch Act ion Team
CERTIFIED MAIL
March 8, 2002
US Army Corps of Engineers
Wilmington District
Angie Pennock
P. O. Box 1890
Wilmington, North Carolina 28402
200 Benson Road NE
Leland, N.C. 28451
[e-mail]

ar .,
b, rTLr ; .. .
RE: Action ID No. 200100853, Application of Riegel Ridge, LLC for permit to construct municipal solid waste
landfill in the Green Swamp
Dear Ms. Pennock:
A landfill is not a "water-dependent" activity. The Corps' rules (40 CFR § 230.10(3)) specify that the discharge of
dredge and fill material is not permitted for activities that are not water dependent. They further provide that
"[p]racticable alternatives that do not involve special aquatic sites are presumed to be available, unless clearly
demonstrated otherwise. Given the size of the proposed project and the large impact to wetlands (Honey Island
Swamp, South Brunswick Estuaries, the Peedee Aquifer outcropping, the Surficial Aquifer, and the Waccamaw River), a
detailed analysis of practicable alternatives must be provided, in accordance with Regulatory Guidance Letter, No. 93-2,
"Guidance on Flexibility of the 404(b)(1) Guidelines and Mitigation Banking" 11 (August 23, 1993), which provide in
relevant part that "The amount of information needed to make such a determination and the level of scrutiny required by
the [Section 404(b)(1) Guidelines] is commensurate with the severity of the environmental impact and the scope/cost of
the project." The guidance establishes less stringent alternatives review for projects that would have only minor impacts.
It also provides that "[g]enerally, as the scope/cost of the project increases, the level of analysis should also increase."
Corps' rules require detailed analysis of alternatives for this proposed project.
The applicant's Application, dated October 15, 2001, stated that a detailed alternative sites analysis was not included as
it was their understanding the site suitability issues were under the jurisdiction of the NC DENR Division of Solid
Waste Management and that these issues would not be re-evaluated by the USACE as part of the application. The Public
Notice issued by the Corps, therefore, did not contain the alternative sites analysis, presumably because it was thought to
be in the possession of NC DENR Division of Solid Waste. When questioned about the analysis, however, NC DSW
had not seen anything purporting to be an alternative sites analysis. A Public Notice Amendment was subsequently
issued by the Corps, addressing only the subject of the analysis but with no information. When we subsequently
requested a copy of the study through the Freedom of Information Act, we learned that the analysis had not been
received by the Corps until December 18''. Upon receiving the analysis (a study dated 1994), we find that the applicant
neglected to identify one of the formerly rejected 13 sites as being in the Green Swamp and that their own research stated
it would be likely to find that 92.5% of the Green Swamp was composed of hydric soils, making it unsuitable for a
landfill. The site they rejected in 1994 was near Livingston Creek and thought at that time to be too much of an impact
on groundwater. Given that the Livingston Creek site was not directly connected to the Honey Island Swamp,
Brunswick Estuaries, or the Waccamaw River, we are puzzled that only six years later, an area sited on the very edge of
Honey Island Swamp and draining into Brunswick Estuaries and the Waccamaw River seems to be their ideal spot to
pile a 107-acre, 280-foot mountain of solid waste and toxic leachate.
Kill theEnWronment&OurChildren Will DieWithIt ••••••••••••••••••••••••••••
March 8, 2002
Page 2
Had this detailed alternative sites analysis been favorable to siting a landfill in the Green Swamp, it would be a mute
point. However, the Applicant's own study rejected the Green Swamp site and clearly deemed the swamp as an
unfavorable place for a solid waste landfill, much less a regional landfill. Given that we, the public, were unable to
comment on this study because it was not given to us and, in fact, was not even in the possession of the State or the
Corps at the time of the issuance of either the Notice or Amended Notice, we find the Public Notice and the Public
Notice Amendment incomplete and hereby request that an additional comment period be opened for the public to give an
informed comment on this new information. V
Sincerely,
Gean M. Seay, Co-Founder
Swamp Watch Action Team
cc: John Hankinson, EPA
William L. Cox, Wetlands Section Chief, USEPA
Kathy Matthews, USEPA/EAB
Garland Pardue, US Fish & Wildlife
William Straw, FEMA
Dept of Interior, US Fish & Wildlife Service
Senator John Edwards
Mike McIntyre, US House of Representatives
Michael Easley, Governor, NC
NC Environmental Management Commission
R D. Turner, NC Environmental Management Commission
harles H. Peterson, NC Environmental Management Commission
John Sutherland, NC Division of Water Resources
Frank McBride, Wildlife Resources Commission
Carolinas Commercial Fishermen's Association
NC Division of Coastal Management
Bill Holman, CWMTF
William Ross, Secretary, NC DENR
Wetlands Division, NC DENR
Senator Marc Basnight
Senator Luther Jordan
Senator R. C. Soles
Representative Dewey Hill
Representative Thomas Wright
Representative David Redwine
James Coffey, NC DENR, DSW
John Dorney, NC DENR, DWQ
Gregory T. Thorpe, PhD, NC DENR, DWQ
Danny Smith, NC DENR, DWQ
Brunswick County Commissioners

Swamp Watch
March 8, 2002
Danny Smith
NC DENR Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1718
200 Benson Road NE
Leland, N.C. 28451
[e-mail]

RE: Action ID No. 200100853, Application of Riegel Ridge, LLC for permit
to construct municipal solid waste landfill in the Green Swamp
Dear Mr. Smith:
As you may be aware, our organization as consistently opposed the siting of a regional landfill in the
Green Swamp. We have this date requested a new public notice, based on information that has just
come' to hand.
We have on numerous occasions to countless agencies requested a public hearing in Brunswick
Coun on the above referenced permit. Although this site is proposed to be located in Columbus
County, it is Brunswick County that will bear the brunt of the environmental destruction.
As your name has recently appeared as the person to contact, we would like, once again, to go on
record as requesting that a hearing be held in our county.
Sin. ere y,
JGan M. Seay, Co-Found
regory T. Thorpe, Ph_.
Brunswick County Commissioners
NC Environmental Management Commission
Kill the Environment & Our Children Will Die With It.
Swamp Watch Act on Team
CERTIFIED MAIL
March 8, 2002
US Army Corps of Engineers
Wilmington District
Angie Pennock
P. O. Box 1890
Wilmington, North Carolina 28402
200 Benson Road NE
Leland, N.C. 28451
[e-mail]
RE: Action ID No. 200100853, Application of Riegel Ridge, LLC for permit to construct municipal solid waste
landfill in the Green Swamp
Dear Ms. Pennock:
A landfill is not a "water-dependent" activity. The Corps' rules (40 CFR § 230.10(3)) specify that the discharge of
dredge and fill material is not permitted for activities that are not water dependent. They further provide that
"[p]racticable alternatives that do not involve special aquatic sites are presumed to be available, unless clearly
demonstrated otherwise." Given the size of the proposed project and the large impact to wetlands (Honey Island
Swamp, South Brunswick Estuaries, the Peedee Aquifer outcropping, the Surficial Aquifer, and the Waccamaw River), a
detailed analysis of practicable alternatives must be provided, in accordance with Regulatory Guidance Letter, No. 93-2,
"Guidance on Flexibility of the 404(b)(1) Guidelines and Mitigation Banking" 11 (August 23, 1993), which provide in
relevant part that "The amount of information needed to make such a determination and the level of scrutiny required by
the [Section 404(b)(1) Guidelines] is commensurate with the severity of the environmental impact and the scope/cost of
the project." The guidance establishes less stringent alternatives review for projects that would have only minor impacts.
It also provides that "[g]enerally, as the scope/cost of the project increases, the level of analysis should also increase."
Corps' rules require detailed analysis of alternatives for this proposed project.
The applicant's Application, dated October 15, 2001, stated that a detailed alternative sites analysis was not included as
it was their understanding the site suitability issues were under the jurisdiction of the NC DENR Division of Solid
Waste Management and that these issues would not be re-evaluated by the USACE as part of the application. The Public
Notice issued by the Corps, therefore, did not contain the alternative sites analysis, presumably because it was thought to
be in the possession of NC DENR Division of Solid Waste. When questioned about the analysis, however, NC DSW
had not seen anything purporting to be an alternative sites analysis. A Public Notice Amendment was subsequently
issued by the Corps, addressing only the subject of the analysis but with no information. When we subsequently
requested a copy of the study through the Freedom of Information Act, we learned that the analysis had not been
received by the Corps until December 18t`. Upon receiving the analysis (a study dated 1994), we find that the applicant
neglected to identify one of the formerly rejected 13 sites as being in the Green Swamp and that their own research stated
it would be likely to find that 92.5% of the Green Swamp was composed of hydric soils, making it unsuitable for a
landfill. The site they rejected in 1994 was near Livingston Creek and thought at that time to be too much of an impact
on groundwater. Given that the Livingston Creek site was not directly connected to the Honey Island Swamp,
Brunswick Estuaries, or the Waccamaw River, we are puzzled that only six years later, an area sited on the very edge of
Honey Island Swamp and draining into Brunswick Estuaries and the Waccamaw River seems to be their ideal spot to
pile a 107-acre, 280-foot mountain of solid waste and toxic leachate.
Kill the Environment & Our Children VI/ill Die With It • • • • • • • • • • • • • • • •

March 8, 2002
Page 2
Had this detailed alternative sites analysis been favorable to siting a landfill in the Green Swamp, it would be a mute
point. However, the Applicant's own study rejected the Green Swamp site and clearly deemed the swamp as an
unfavorable place for a solid waste landfill, much less a regional landfill. Given that we, the public, were unable to
comment on this study because it was not given to us and, in fact, was not even in the possession of the State or the
Corps at the time of the issuance of either the Notice or Amended Notice, we find the Public Notice and the Public
Notice Amendment incomplete and hereby request that an additional comment period be opened for the public to give an
informed comment on this new information.
Sincerely,
Gean M. Seay, Co-Founder
Swamp Watch Action Team
cc: John Hankinson, EPA
William L. Cox, Wetlands Section Chief, USEPA
Kathy Matthews, USEPA/EAB
Garland Pardue, US Fish & Wildlife
William Straw, FEMA
Dept of Interior, US Fish & Wildlife Service
Senator John Edwards
Mike McIntyre, US House of Representatives
Michael Easley, Governor, NC
NC Environmental Management Commission
Ryan D. Turner, NC Environmental Management Commission
Charles H. Peterson, NC Environmental Management Commission
John Sutherland, NC Division of Water Resources
Frank McBride, Wildlife Resources Commission
Carolinas Commercial Fishermen's Association
NC Division of Coastal Management
Bill Holman, CWMTF
William Ross, Secretary, NC DENR
Wetlands Division, NC DENR
Senator Marc Basnight
Senator Luther Jordan
Senator R. C. Soles
Representative Dewey Hill
Representative Thomas Wright
Representative David Redwine
James Coffey, NC DENR, DSW
John Dorney, NC DENR, DWQ
Gregory T. Thorpe, PhD, NC DENR, DWQ
vDanny Smith, NC DENR, DWQ
Brunswick County Commissioners
Swamp Watch
March 8, 2002
MAR 1 5 2002
WETLAWS c U?
?'RTE? UALITY SECi`:=;
Danny Smith
NC DENR Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1718
200 Benson Road NE
Leland, N.C. 28451
[e-mail]
M,4R ? ? D
DIV or 2002
oIREC OR "s oQU
At/Ty
FILE
RE: Action ID No. 200100853, Application of Riegel Ridge, LLC for permit
to construct municipal solid waste landfill in the Green Swamp
Dear Mr. Smith:
As you may be aware, our organization as consistently opposed the siting of a regional landfill in the
Green Swamp. We have this date requested a new public notice, based on information that has just
come to hand.
We have on numerous occasions to countless agencies requested a public hearing in Brunswick
Coun on the above referenced permit. Although this site is proposed to be located in Columbus
County, it is Brunswick County that will bear the brunt of the environmental destruction.
As your name has recently appeared as the person to contact, we would like, once again, to go on
record as requesting that a hearing be held in our county.
Sincerely,
Gean M. Seay, Co-Founder
cc:(egory T. Thorpe, PhD.
Brunswick County Commissioners
NC Environmental Management Commission
1911 the Environment & Our Children Will Die With It • • • • . • • • • • • • • • • • • •
200 Benson Road NE
Leland, N.C. 28451
[e-mail]
Swamp Watch Acfi*on Team
CERTIFIED MAIL
March 8, 2002
US Army Corps of Engineers
Wilmington District
Angie Pennock
P. O. Box 1890
Wilmington, North Carolina 28402
RE: Action ID No. 200100853, Application of Riegel Ridge, LLC for permit to construct municipal solid waste
landfill in the Green Swamp
Dear Ms. Pennock:
A landfill is not a "water-dependent" activity. The Corps' rules (40 CFR § 230.10(3)) specify that the discharge of
dredge and fill material is not permitted for activities that are not water dependent. They further provide that
"[p]racticable alternatives that do not involve special aquatic sites are presumed to be available, unless clearly
demonstrated otherwise." Given the size of the proposed project and the large impact to wetlands (Honey Island
Swamp, South Brunswick Estuaries, the Peedee Aquifer outcropping, the Surficial Aquifer, and the Waccamaw River), a
detailed analysis of practicable alternatives must be provided, in accordance with Regulatory Guidance Letter, No. 93-2,
"Guidance on Flexibility of the 404(b)(1) Guidelines and Mitigation Banking" 11 (August 23, 1993), which provide in
relevant part that "The amount of information needed to make such a determination and the level of scrutiny required by
the [Section 404(b)(1) Guidelines] is commensurate with the severity of the environmental impact and the scope/cost of
the project." The guidance establishes less stringent alternatives review for projects that would have only minor impacts.
It also provides that "[g]enerally, as the scope/cost of the project increases, the level of analysis should also increase."
Corps' rules require detailed analysis of alternatives for this proposed project.
The applicant's Application, dated October 15, 2001, stated that a detailed alternative sites analysis was not included as
it was their understanding the site suitability issues were under the jurisdiction of the NC DENR Division of Solid
Waste Management and that these issues would not be re-evaluated by the USACE as part of the application. The Public
Notice issued by the Corps, therefore, did not contain the alternative sites analysis, presumably because it was thought to
be in the possession of NC DENR Division of Solid Waste. When questioned about the analysis, however, NC DSW
had not seen anything purporting to be an alternative sites analysis. A Public Notice Amendment was subsequently
issued by the Corps, addressing only the subject of the analysis but with no information. When we subsequently
requested a copy of the study through the Freedom of Information Act, we learned that the analysis had not been
received by the Corps until December 18`h. Upon receiving the analysis (a study dated 1994), we find that the applicant
neglected to identify one of the formerly rejected 13 sites as being in the Green Swamp and that their own research stated
it would be likely to find that 92.5% of the Green Swamp was composed of hydric soils, making it unsuitable for a
landfill. The site they rejected in 1994 was near Livingston Creek and thought at that time to be too much of an impact
on groundwater. Given that the Livingston Creek site was not directly connected to the Honey Island Swamp,
Brunswick Estuaries, or the Waccamaw River, we are puzzled that only six years later, an area sited on the very edge of
Honey Island Swamp and draining into Brunswick Estuaries and the Waccamaw River seems to be their ideal spot to
pile a 107-acre, 280-foot mountain of solid waste and toxic leachate.
Kill theEnvironment &OurChildren Will DieWithIt. ••••••••••••••••••••••••• •.
March 8, 2002
Page 2
Had this detailed alternative sites analysis been favorable to siting a landfill in the Green Swamp, it would be a mute
point. However, the Applicant's own study rejected the Green Swamp site and clearly deemed the swamp as an
unfavorable place for a solid waste landfill, much less a regional landfill. Given that we, the public, were unable to
comment on this study because it was not given to us and, in fact, was not even in the possession of the State or the
Corps at the time of the issuance of either the Notice or Amended Notice, we find the Public Notice and the Public
Notice Amendment incomplete and hereby request that an additional comment period be opened for the public to give an
informed comment on this new information.
Sincerely,
Gean M. Seay, Co-Founder
Swamp Watch Action Team
cc: John Hankinson, EPA
William L. Cox, Wetlands Section Chief, USEPA
Kathy Matthews, USEPA/EAB
Garland Pardue, US Fish & Wildlife
William Straw, FEMA
Dept of Interior, US Fish & Wildlife Service
Senator John Edwards
Mike McIntyre, US House of Representatives
Michael Easley, Governor, NC
NC Environmental Management Commission
Ryan D. Turner, NC Environmental Management Commission
Charles H. Peterson, NC Environmental Management Commission
John Sutherland, NC Division of Water Resources
Frank McBride, Wildlife Resources Commission
Carolinas Commercial Fishermen's Association
NC Division of Coastal Management
Bill Holman, CWMTF
William Ross, Secretary, NC DENR
Wetlands Division, NC DENR
Senator Marc Basnight
Senator Luther Jordan
Senator R. C. Soles
Representative Dcwey Hill
Representative Thomas Wright
Representative David Redwine
James Coffey, NC DENR, DSW
Jo orney, NC DENR, DWQ
egory T. Thorpe, PhD, NC DENR, DWQ
Danny Smith, NC DENR, DWQ
Brunswick County Commissioners
Warren L Cheek
3498 B saver Creek Drive SE
Southport, NC 28461
March 23, 2002
Dr. Gregory J Thorpe, PhD., Acting Director
PIC DENR Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1787
Dear Dr. Thorpe:
strongly oppose the new LANDFILL that is being considered primarily in
Brunswick County. I am also strongly opposed to the public hearing on the
landfill in Columbus County since the greatest impact will be on the residen' , of
Brunswick County. I would hate to think that this was being done because , e
people in Columbus County would voice fewer objections since the LANDF6 L
will be downstream from them.
However, that is not the case with those of us in Brunswick County. The
Peedee Aquifer would be greatly effected by such LANDFILL and you know that
any assurances to the contrary are not based on fact
believe the LANDFILL should not be considered in t1is part of Erunv vick
County and at the very least, the public hearing should be resch eduled for
Brunswick County, where the resi Dents have a greater interest i i the outcome.
Sincerely,
Warren L. "Cheek

T - d 9286-692 (016) '>jaay0 uaJJeM dz T s 60 00 ca Jew
Mar 23 02 08:13p Warren Cheek
Warren L Cheek
3498 Beaver Creek Drive SE
Southport, NC 28469
March 23, 2002
Mr. Danny Smith
NC DENR Division of Water Quality
1697 Mail Service Center
Raleigh, NC 27699-1787
Dear Mr. Smith:
[phone] p.1
LwJEN CUP
-?. T1 N
I strongly oppose the new LANDFILL that is being considered primarily in
Brunswick County. I am also strongly opposed to the public hearing on the
landfill in Columbus County since the greatest impact will be on the residents of
Brunswick County. I would hate to think that this was being done because the
people in Columbus County would voice fewer objections since the LANDFILL
will be downstream from them.
However, that is not the case with those of us in Brunswick County. The
Peedee Aquifer would be greatly effected by such LANDFILL and you know that
any assurances to the contrary are not based on fact.
I believe the LANDFILL should not be considered in this part of Brunswick
County and at the vory least, the public hearin j should be rescheduled for
Brunswick County, vhere the residents have g greater interest in the outcome.
Sincerely,
Warren L Cheek
i??
?,?.
., ?• ,'
;. ?,...
. ?.
Mar 23 02 03:13p Warren Cheek
Warren L Cheek
3498 Beaver Creek Drive SE
Southport, NC 28461
March 23, 2002
Mr. Danny Smith
NC DENR Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1787
Dear Mr. Smith:
L L
MAR
282(V
WWI
I strongly oppose the new LANDFILL that is being considered primarily in
Brunswick County. i am also strongly opposed to the public hearing on the
landfill in Columbus County since the greatest impact will be on the residents of
Brunswick County. I would hate to think that this was being done because the
people in Columbus County would voice fewer objections since the LANDFILL
will be downstream from them.
However, that is not the case with those of us in Brunswick County. The
Peedee Aquifer would be greatly effected by such LANDFILL and you know that
any assurances to the contrary are not based on fact.
I believe the LANDFILL should not be considered in this part of Brunswick
County and at the very least, the public hearing should be rescheduled for
Brunswick County, where the residents have a greater interest in the outcome.
Sincerely,
19101 253-9826 p.1
/4444W
Warren L. Cheek
.r
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we do NOT want a dump in the Green Swamp!
Subject: we do NOT want a dump in the Green Swamp!
Date: Mon, 25 Mar 2002 17:53:51 -0500
From: "Margaret Meinzer" <[e-mail]>
To: <[e-mail]>
dear director Thorpe:
1) we do NOT want a dump located in the Green Swamp! (Columbus/Brunswick County borders)
2) we DO want a public hearing on this issue held in Brunswick County.
we live in Lockwood Folly golf/waterway community, Brunswick County, near Holden Beach...down-river from the
proposed dump site in the Green Swamp. our fresh water source and ecological well-being is already fragile! this
proposed site would contaminate our groundwater sending toxic leachate into the coastline of both south and north
carolina.
how can this proposal:
1) reach this stage of being considered viable,
2) pass EPA standards,
3) meet approval by any county or state officials?
we are ordinary citizens, not ecological experts on water quality, but we can already taste and smell the
contamination and stench-effect of this proposal.
please, please STOP this dump site from being located in the center of our fresh water source! thank you.
Peggy and Hartley Meinzer
3343 Channelside Drive, SW
Supply, NC 28462-2106
1 of 1 3/26/02 8:46 AN

March 25, 202
To: Gregory J. Thorpe
Acting Director
NC DENRivision Of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1718
Tel: 919 - 733 - 7015
Fax: 919 - 73 -3 - 2496
Fr: Michael & Carol Kirsche
2686 Four Oak Road
Southport, NC 28461
(910) 253 - 9740
Sj: Potential Contamination ofPeedee Aquifer
Dear Sir:
`?NI111Wb3d 3J-? ay i
0000 _ adb
N01103S .1111Ynb
We.axe-"OPPOSED" to-the_tandfill that -.isbeing discussed for Columbus County, NC.
We strongly urge you to:
(1) Oppose_this_proposal'and.danot_allow the Peedee Aufifer to become a landfill
(2) Schedule a hearing in Brunswick County.
Thankyou for understanding that-we-cannot_in-gaad.conscience- allow gur natural resources to be
contaminated or polluted or destroyed by a few people outside of our county who have selfish
interests as their primary objective;,versus.the..noble ideal.af.preserving, our natural resources and
ensuring the quality of Brunswick County residents drinking water for generations.
Sincerely,
Michael R. Kirsche
Carol J.. Kirsche..
To: Danny Smith NC DENR Division of Water Qualit.From: Bradford J. Brown 910-253-7290
FACSIMILE COVER PAGE
Date: 03/28/02
Time: 14:05:50
Page: 1
To: Danny Smith
Company: NC DENR Division of Water Quality
Fax #: [phone]
From: Bradford J. Brown
Address: 4198 Shearwater Way SE
Southport, NC 28461,
USA
Fax #: [phone]
Voice #: 910-253-7290
Message:
03/28/02 14:05:52 Page 1 of 1
? J
r APR 4 2002
-.Y TER ER OUAti7v c?UPn.Dear Sir,
Please reconsider your approval for New York City dumping their garbage in the
Green Swamp located in Columbus county. This landfill just adds to NC being the
landfill state of the United States. The landfill is located at the head of Bruinswick
County aquafire water supply.
We definitly oppose this new landfill and hold you and your department personally
responsible for the violation in the Green Swamp if it is approved.
Please investigate and oppose this new invasion of our enviroment. If we had true
recycling and reuse of our garbage to generate electricity we would be much better
off, Let NYC find another way. Virginia turned them down, but maybe they think more
of their precious land than we do.
Your meeting on April 18th in Whiteville will be attended, see you their.
Bud Brown
To: Gregory J.Thorpe, P Director NC DENR Division From: Bradford J. Brawn 910-253-7290
FACSIMILE COVER PAGE
Date: 03/28102
Time, 14:04:24
Page: 1 '0
To: Grego J.Thorpe, P Director
Company: NC ENR Division of Water Quality
Fax #: [phone]
From: Bradford J. Brown
Address: 4198 Shearwater Way SE
Southport, NC 28461
USA
Fax [phone]
Voice 910-253-7290
Message:
03/28/02 14:04:28 Page 1 of 1
Dear Sir,
Please reconsider your approval for New York City dumping their garbage in the
Green Swamp located in Columbus county. This landfill just adds to NC being the
landfill state of the United States. The landfill is located at the head of Bruinswick
County aquafire water supply.
We definitly oppose this new landfill and hold you and your department personally
responsible for the violation in the Green Swamp if it is approved.
Please investigate and oppose this new invasion of our enviroment. If we had true
recycling and reuse of our garbage to generate electricity we would be much better
off, Let NYC find another way. Virginia turned them down, but maybe they think more
of their precious land than we do.
Your meeting on April 18th in Whiteville will be attended, see you their.
Bud Brown

i
1
Dear Sir' t9`?tt;s;?J tG(r
Re: Potential contamination of the Peedee Aquifer
Danny Smith
NC DENR Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1718
We have been alerted to an impending plan to create a landfill in Columbus County in the
Green Swamp.
It is truly frightening to think of a 300-foot plus high mountain of garbage over such a
precious resource and the probable contamination of same.
It appears to us that this project must be stopped, or at least relocated, and that
responsible officials and residents of Brunswick County who have NONTHING to gain
and
EVERYTHING to loose should discuss this immediately in a public hearing.
Please give your serious and timely attention to our concerns
Sinc ely,
p4 , JW
r/ V )"(;Gary and Sharron Powell
3046 Irwin Drive SE
Southport, NC 28461
A
o90
k : Potential contamination of the Peedee Aquifer
egory J. Thorpe, PhD. Acting Director
C DENR division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1718
Mc ?? 0-2-
APR 1 0 20
W+'?S GROUP
WATER UALITY SECTION
We have been alerted to an impending plan to create a landfill in Columbus County in the
Green Swamp.
It is truly frightening to think of a 300-foot plus high mountain of garbage over such a
precious resource and the probable contamination of same.
It appears to us that this project must be stopped, or at least relocated, and that
responsible officials and residents of Brunswick County who have NONTHING to gain
and
EVERYTHING to loose should discuss this immediately in a public hearing.
Please give your serious and timely attention to our concerns
Sin erely,
I
'raV Gary and Sharron Powell
3046 Irwin Drive SE
Southport, NC 28461
!o' 0
o,RFF?gT 4?oo? o
COORS Qu
??F y
R-ECA?P ED ETlos s I
?,? r?TER OUP ?
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1
NON-DISC ?-;ARGE PERM" TING
r

•'? ,?
GREEN SWAMP TRAGEDY
Subject: GREEN SWAMP TRAGEDY
Date: Sat, 13 Apr 2002 17:38:10 -0400
From: "George W. Presant" <[e-mail]>
To: <[e-mail]>
WE DO NOT WANT A DUMP IN THE GREEN SWAMP AND WE WANT A PUBLIC HEARING IN BRUNSWICK
COUNTYM
GEORGE W. PRESANT
FLORENCE PRESANT
SUPPLY, NC 28462
I of 1 4/13/02 8:09 PM
t c F
N. C. Division of Water Quality
1650 Mail Service Center,
Raleigh, NC 27699-1650
Dear Sirs;
April 13, 2002
1= 3''
t APR 1 7 2002
i_
WETlAW WouP
WRTER OuRa SECbN
I am a very concerned citizen of Columbus County about the
proposed Regional Landfill' to be sited in the Green Swamp, a
National Natural Landmark. There are many questions about the
suitability of the site for a landfill. No answers, except it will be state
of the art. One would wonder about the artist. It is quite obvious
from the number of landfills within the service area accepting waste,
Including the huge Sampson County Landfill, that Columbus County
does not need a Regional Landfill. A County only landfill in a suitable
location, Coupled with responsible waste reduction efforts, and
properly operated, I would not object to. But to site a Regional
Landfill of such magnitude in a sponge that has served us well in
filtering and maintaining: our groundwater supply is absurd.
We are in a drought, 18 inches last year and already over 3 inches
this year. Yet with all the ditching, during Hurricane Floyd, the entire
proposed footprint of the landfill was under water. In this area we
can hardly expect that to not happen again. What measures will be
taken to deal with this? Can the toxins in the leachate be controlled?
No one is going to examine every load of waste for content. It is my
understanding that vaccine syringes and certain. other hospital waste:
are no longer considered Hazardous and is suitable for disposal in
landfills. With the known track record of Waste Management Inc, can
we expect better?` I understand the present plans are for the
leachate to be taken to a treatment center where some of the toxin
will be removed and the rest released into what? The residue,
including those creatures that eat those toxins, will be returned to the
4. ? A
,; L .. .?
r s
landfill. I've seen a jar of untreated leachate and a jar of treated
leachate. The color was the same in both samples. The untreated
had solids the treated did not have. All of this is cause for concern,
but the greater concern Is the admitted leakage from the best liners
known when they are news with the unknowns of what will happen
when these same less than perfect liners are stressed with the
pressures of the weight of 260' of no telling what, and subjected to
chemicals, some common household varieties that can degrade those
liners. My biggest concern is groundwater contamination. The
aquifers and phreatic slope. What is known about them in the area?
When our wells are contaminated, who will pay for water treatment
facilities and piping to fill our water needs? These state of the art
liner systems cannot insure that no contamination will occur, however
they are better than no liner. No one knows what time will do to them.
You can rest assured that sometime sooner or later they will fail
some already have. The cost of trying to clean up and furnishing
water will far exceed any money the County can expect to get from
the landfill, the driving:: force behind it. Can we afford to put a landfill
of this magnitude in such an unstable location When less than 2% of
what is expected to go in it will come from Columbus. County? How
much will that one dollar a ton cost us taxpayers? I may not live to
find out, but children and grandchildren might be expected to ask,
WHY DID THEY ALLOW THIS TO HAPPEN?
Sincerely,
/Carolyn K. Maipass
.b 0
GRANT H. EGLEY
2690 Bella Coola Road, Lake Waccamaw, NC 28450
April 15, 2002
John Dorney
NC Division of Water Quality
2321 Crabtree Blvd., Suite 250
Raleigh, NC 27604-2260
Dear Mr. Dorney:
AR! 7
t?
This concerns the proposal by Riegel Ridge, LLC to place a solid waste landfill in the Green
Swamp approximately six miles southeast of Lake Waccamaw, NC. As a resident of the town of
Lake Waccamaw, I oppose locating a potentially very large landfill in this environmentally
sensitive location for several reasons. I cannot attend the public hearing on this subject in
Whiteville on April 18th and, therefore, will mention my main concerns now.
I think the following questions should be satisfactorily answered before any approval for the
landfill is granted:
• Does the ground water in the area of the landfill flow toward or away from Lake
Waccamaw?
• How will the leachate produced by the landfill be handled?
• How will ditching that is already in the area affect surface water flow around the landfill?
• What precautions will be taken to prevent contamination of nearby water supplies from
catastrophic rainfall events (hurricanes, tropical storms, flooding, etc.)?
• Who will monitor operation and maintenance of the landfill?
My reason for asking these particular questions is that the proposed site of the landfill is in a
wetlands area that is subject to periodic flooding. Also, the location is nearby to Lake
Waccamaw, an Outstanding Resource Water. State regulations restrict off site activities that
might negatively impact this valuable resource. I do not want to see the waters of Lake
Waccamaw become contaminated. Above all, I am concerned about the potential adverse impact
on area drinking water supplies.
I appreciate your taking these questions and concerns under consideration.
Sincerely yours
Grant H. Egley
Cc: Angie Peacock
Wilmington District, Corps of Engineers
Subject:
Date: Wed, 17 Apr 2002 15:42:44 -0400
From: "Fran Fuchs" <[e-mail]>
To: [e-mail]
Dear Mr. Smith,
I am a resident of Brunswick County and live on the Lockwood Folly
River. I am concerned about the proposed land fill in the Green Swamp which
will heavily impact on the streams, rivers, ecology and drinking water of
this area. I moved to this area to take advantage of the pristine waters and
to get away from the polution up north. Since the beaches and surrounding
areas depend on clean water for fishing, recreation and tourism it is most
important that we have a say in what is going on. I request that you have a
hearing in the beach areas of Brunswick County, since this is the area that
will be most affected by this this proposed dump which will be an
environmental disaster. Please consider this request, since many people who
live in this area are retired and will find it difficult to trave the 40
miles to Whiteville.
Thank you for your consideration.
Sincerely,
Fran Fuchs
58 Oyster Shoals Ct.
Supply, NC
Chat with friends online, try MSN Messenger: http://messenger.msn.com
1 of 1 4/17/02 4:10 PM
Green Swamp Proposed Dump Site
Subject: Green Swamp Proposed Dump Site
Date: Wed, 17 Apr 2002 15:28:12 -0400
From: "Fran Fuchs" <[e-mail]>
To: [e-mail], [e-mail], [e-mail]
Dear Sir,
I am a transplant from New York to Southern Brunswick County. I enjoy i
living in a community that borders on the Lockwood Folly River and the
intracoastal. One of the reasons that I moved to this area was because of
the pristine waters, which allow me to drink water, fish and swim without
concern for serious water polution. Now it has come to my attention that a
dump site is proposed in the Green Swamp. This is unacceptable. This area is
a source of drinking water that extends from the Waccamaw River through
South Brunswick County communities into South Carolina. The Green Swamp is
one of the reatest remaining sources of freshwater in the continent and any
contamination to the surface in this area, would mea aquifer contamination.
Send and receive Hotmail on your mobile device: http://mobile.msn.com
1 of 1 4/17/02 4:10 PM
E. FRANCES DUNN-CARSON
TIMOTHY CARSON
210 Nancy St.
Lake Waccamaw, NC 28450
April 20, 2002
To Whom It May Concern:
MAY 3 2002
Recently my husband and I were at the hearing in Whiteville, regarding the landfill project in the
Green Swamp. We are completely opposed to the project. All of the reasons that were given are
completely sound reasons. We agree with everyone of them, plus we have a few of our own.
First and foremost, you know as well as we do that nothing lasts forever. It does not matter how
hi-tech the liner is supposed to be. It will not last forever. This is a legacy that should not be left to our
future generations to have to deal with the mess we leave.
Second, from what we understand, this is to be like a big bowl, well you know what happens to a
bowl that is full, and then more liquid is added! Suppose we have another Hurricane Floyd! All that rain,
even if it is not on a flood plain, will cause it to overflow. That will start the contamination. Once it starts
it is all ready too late. A good example of this is when Floyd dropped all that rain, and flooded a lot of the
territory, just remember what happened with all the hog waste ponds.
Third, It was brought up about the seagulls, and how much contamination from their waste, and
the contamination that will be transported on their bodies to the waters of Lake Waccamaw and the rivers.
There also might be a problem with rats.
As someone said at the hearing, the words swamp and landfill do not go together. It does not
matter how much you drain the area; it is still a swamp. This feeds the ground water, that feeds the lake,
the rivers, wells for all the individuals in the area, and water systems for all the towns along the way, all the
way to the ocean. A sponge is still a sponge, even if it is dry, and no matter how "High Tech", you don't
build a prison next to an elementary school.
We also saw a sign for Careen Swamp, it read Green Swamp Preserve, we always thought if
something was a preserve, it was not to be used for commercial use. This is wetlands and we can't believe
that it is not under protection from this sort of thing. If it isn't it should be.
This is a beautiful area, and it has so much to offer. We really can not believe that anyone can
think that this is a good idea. We can not believe that someone would want to destroy such a natural
wonder. We can not believe some one could be so selfish to destroy so much for everyone else, just for
there own benefit.
With all the opposition to this proposal, we can not believe it will pass. If it does there is some
thing wrong with the system to allow this to happen. There must be some way to stop it.
We appreciate the time you have taken to hear out some very concerned residents of the area and
hope you will vote with your conscience, and against this travesty!
Very truly yours,
APR 6 20op
-M.
April 23, 2002
Mr. and Mrs. David Helms
2818 Park Avenue
Wilmington, North Carolina
Mr. Danny Smith
Division of Water Quality-Dept. Of Environment and Natural Resources
2321 Crabtree Blvd
Raleigh, North Carolina 27604-2206
Re: Green Swamp Proposed Landfill Site
Dear Mr. Smith.
We are residents of New Hanover County, but are extremely concerned about the proposed
landfill site in the Green Swamp.
We oppose putting the landfill in the above swamp for the following reasons:
1. The proposed site does not have a clay base.
2. The traffic on Hwy 211 is bumper to bumper during vacation season. What will happen
to that tourist business, when they have to follow dump trucks hauling trash to the site? I imagine
these tourists will either find water areas north or south of North Carolina to spend their tourist
money.
3. The fact that a swamp is a swamp is a real no brainer, when it comes down to an
appropriate location. Why is this site even being given a thought?
4. What we do not know about the leakage is too much of a gamble for now and for the
future.
Please consider the above, and find a site that would not endanger our fixture.
YOU, 44
Cat and David Helms
113 RLancaster Real Estate
REALTOW 2413 Robeson Street, Unit 1
April 23, 2002 FAYETTEVILLE, NORTH CAROLINA 28305
Phone: [phone] APR 2 9 2002
Mr. Danny Smith Pax: [phone]
Division of Water Quality-Dept. Of Environment and Natural Resources WETL,t -
gfr
2321 Crabtree Blvd. e
Raleigh, North Carolina 27604-2206
Re: Green Swamp Proposed Landfill Site
Dear Mr. Smith:
I am a resident of Cumberland County, but have always had an interest in Columbus County and
Lake Waccamaw, North Carolina, because my mother was from the Lake and my grandparents
continued to live at the Lake. Any vacation time we had, we spent at the lake around family, and
now as grandparents ourselves, we continue to enjoy any available time with family at the Lake.
I am opposed to the proposed site of the landfill at Green Swamp. At the hearing in Whiteville
last week, the Water Quality Committee members heard approximately 55 opponents of the
landfill, and 5 spoke in favor of the landfill. I know that two of the five who spoke in favor of the
landfill were commissioners who had voted for the site, and had no choice but to show support.
Many interesting facts were brought out that I feel reinstate reasons for NOT placing the landfill
in the Greenswamp:
1. The mere fact that this is a swamp and the people who provide the lining have indicated
there is no guarantee that the lining will NOT leak.
2. The fact that a clay base is absent in this area contributes to the above leakage being
even more probable.
3. The impact in the form of droppings and residue on the feet of seagulls that will surely i
damage the water quality.
4. In our local paper, two items that President Bush's "Clear Skies Plan" address (to
polish our environment) are acid rain, and mercury levels in our waters. Both acid rain
and high mercury levels have constantly been mentioned as monumental concerns of the
landfill.
5. There are species of fish and wildlife that have practically become extinct except in this
site area. (Ex: silver slide, venus fly trap)
6. In a 1994 study, this site was deemed inappropriate for a landfill-why has this decision
so quickly been reversed?
7. Most importantly, with the real doubts about the unknowns, why would a site that has
ditches that empty into the Waccamaw River Basin, even be considered? This may not
affect those making the decision now, but it will definitely be an issue that will need to
be addressed in the future if this is site is allowed to be used.
8. If this decision is made, it will be TOO LATE to try to correct in the future, and I
believe "Kill our Water, Kill our Children" definitely summarizes the fate of this site.
Thank you for having your representatives hold a hearing and for addressing our concerns
rtaining to this site.

C

April 23, 2002
Mr. and Mrs. Trey Edge
2623 Mirror Lake Drive
Fayetteville, North Carolina 28303
Mr. Danny Smith
Division of Water Quality-Dept. Of Environment and Natural Resources
2321 Crabtree Blvd.
Raleigh, North Carolina 27604-2206
Re: Green Swamp Proposed Landfill Site
Dear Mr. Smith:
We are residents of Cumberland County, but enjoy visiting at Lake Waccamaw. We oppose the
proposed landfill site in the Green Swamp.
The reasons we oppose the site for the landfill are as follows:
1. The proposed site does not have a clay base.
2. The lining is not guaranteed and WILL leak-it is just a matter of time. I have children
who enjoy swimming in the lake at the present time. I want them to have the opportunity to
continue to enjoy water sports in CLEAN WATER in the future.
3. Not only will the liner leak, but there are numerous unknowns about what will happen
with the water quality, the air quality, and the endangered species should this site be allowed.
4. The contamination created by the seagulls who will frequent the site is a major issue.
What disease will they deposit in the waters surrounding the landfill? Why chance this, when
another less endangered area can be found?
Thank you for your concern and attention to this.
Best regards,
Kensley anTrey Edge
Subject:
Date: Thu, 25 Apr 2002 21:29:48 -0400
From: Pat <[e-mail]>
To: [e-mail]
Dear Mr. Smith:
We were unable to attend the
KS. However, we would like
protesting the costruction o
habitat is essential to the
Brunswick County.
Yours truly,
John and Patricia Wendler
4211 Silverleaf Dr. SE
Southport, NC 28461
hearing due to a family commitment in Wichita,
to add our voices to the multitude who are
f a landfill in the Green Swamp. That natural
preservation of a healthy environment in
1 of 1 4/26/02 9:15 AM
1008 Lake Shore Drive
Lake Waccamaw, NC 28450
25 April 2002
Mr. Danny Smith
2321 Crabtree Road
Raleigh, NC 27604-2260
Re: Riegel Ridge Landfill
Dear Sir:
1. The landfill will endanger the Lake.
The soils are wet, and area is ditched. Drainage from this area will find their
way into Lake Waccamaw.
2. The area is to be dug is 25 feet deep; this is about 10-15 feet lower than the
bottom of the lake.
3. There is no way, that when a hole comes in the plastic liner, that it can be
repaired, especially 25 feet down.
4. Water table for this area is probably no more than 5 feet from the surface. So,
you are dealing in water.
5. No one I know is in favor of this proposal to build this landfill.
6. If this landfill is built. The total costs of undoing the damage will be very
expensive.
7. I am very much against this landfill.
Thank You,

Earl Williamson
April 27, 2002
#c
APR 3 0 2002
TO. Greg Thrope w
Acting Director, Division of Water Quality w?reR aro 1
From: Mason Malpass, citizen of Columbus County
RE: Riegel Ridge Landfill, Columbus County, DWQ Project No, 01-
1680.
Dear Sir;
Having attended and spoken at the April 18 hearing, many con-
cerns were mentioned by other speakers, most of which are good
solid concerns that also concern me. Most were in detail and 1 proba-
bly could not add additional input to. I was glad someone mentioned
the numerous wells that have been drilled on the proposed site with
no regard to sealing to prevent surface water direct access to ground
water. Nothing was done to sear any of the many wells I observed,
and many were in 6 inch holes of varying depths, similar to the one in
picture # 14, enclosed. this picture was taken in mid-June of 2001.
The water in the hole around the pipe was at the same level as the
water inside the pipe, in mid and late June within 12 inches of the
ground surface. When checked April 22, 2002, the water levels were
30 inches from the ground surface. In 2001, the area had 18 inches
less than normal rainfall for the year. Thus far this year, we are over
51/a inches below normal to date.
Enclosed are other pictures taken in mid and late June, 2001. #2.
as near as I can determine, is within the proposed landfill footprint. It
is not in a ditch. It is approximately 100 ft from the 2nd gated existing
road into the property, and approximately 500 ft from Roberts Road.
Known as a Pitcher Plant. #4. 9,10, 11, 13, 14, and 15, were taken
in Mid and late June 2001, in a 125 ft diameter circle, beginning
? ?f
approximately 400 ft from Roberts Road and on to 525 ft there from.
#4 is a Cyprus Tree. #9 is another well showing water does and has
entered around it. #s 10, 11, and 15, one week after 1 1h inch rain. #
13, l don't know the name of this plant, we called them Hard Heads
when I was growing up. And if you were walking in front of someone
while passing some of these, you understood why they were called
that. I can't give exact locations for the next pictures which were all
taken in late June 2001, but none were on the proposed footprint.
Most were near proposed borrow pit areas. # 17, is or was a pretty
pond Now dry. As near as I can determine, between two borrow Pit
areas. #1`9, and 20, about 75 ft from pond on or very near a Borrow
area. #21, 23, and 24 are acknowledged and are to be protected.
How I don't know if 25 ft deep borrow pits are 50 ft away.
When you look at the amount of dirt washed into roadside ditches,
I wonder what Honey Island Swamp will look like after a major rain
event during construction of a project of this magnitude.
From the enclosed Newspaper article, you can see that water
quality is becoming important in Southeastern N. C., at least for
poultry drinking water. Can we afford to take a chance at siting a
landfill in such a sensitive area? What would happen if a builder
erected a 26 story building on than site on a foundation of clay even
with a plastic liner? If it didn't turn over first it would sink.
In spite of what proponents would have us think, some lined land-
fills have had major problems with leaking, all have problems of other
kinds, and all will eventually leak. To permit a project of this
magnitude in such a site without a through Environmental Impact
Statement would be unconscionable The Green Swamp is too great
a treasure to destroy. It already has been seriously wounded, let us
not kilt it.
Sincerely,
Mason B. Malpass
_/M A
M. B. Malpass
1283 "Green Swamp Rd N
k.?r. ?...k.. Bolton, NC 28423-8588
Charles Hickman
199 Central Avenue
Lake Waccamaw, NC 28450
Danny Smith
N. C. Division of Water Quality, Non-Discharge Branch
Water Quality, 401 Wetland Unit '
r; /APR 3 0 ?hn)
2321 Crabtree Blvd.,
Raleigh, N. C. 27604 i
WA ???,-T???STMGISIO?tC1TP'ON
April 29, 2002
Dear Mr. Smith
I know that making decisions sometime can be tough especially when both
sides of an argument make good points, as is the case concerning the
proposed landfill in Columbus County. I can only hope that you are a
wise man who can see further than just a couple of decades and have the
vision and forward thinking ability to help protect the many
generations who may be adversely effected by misplaced refuse.
Our world is changing everyday and there are many new processes being
developed for disposing of waste in a positive manner. There really is
no reason to risk the dangers associated with establishing a landfill
in the Green Swamp of Columbus County. The entire area called Green
Swamp is one of the most important natural resources we have in North
Carolina.
As I have learned since this proposed landfill surfaced, the Green
Swamp has already suffered from the extensive draining and chemical
spraying by our paper companies. These practices have caused numerous
adverse effects on the water quality causing fish kills from time to
time and water quantity in the Waccamaw River.
Our river suffers from low water much of the year now because of the
extensive drainage system located in the Green Swamp. Nature intended a
slow release of water from the swamp, which in turn would keep the
river at a much higher level for longer periods of time.
If we allow the landfill to be established in such a sensitive part of
our world, we are taking on a tremendous risk that could affect
hundreds of thousands of people who reside along the Waccamaw River.
This 158-mile river would be at risk from the time the first shovel
full of dirt is turned in the construction process until some unknown
time when our children's children are forced to cough up the money to
undo the process. I do not think that it is even a remote possibility
to in fact create a process that would remove the trash and re-
establish a swamp, but if it were, the price tag would no doubt be in
the 100's of millions at today's cost.
I humbly ask you to oppose the placement of trash and refuse of any
kind being placed in such an ecologically sensitive area.
Thank you,
c
!L J?
Charles Hickman
Green Swamp Landfill
Subject: Green Swamp Landfill
Date: Wed, 1 May 2002 21:01:41 -0400
From: "Jeffrey Chapman" <[e-mail]>
To: <[e-mail]>
Dear Mr. Smith,
I was not able to attend the meeting held in Whiteville on April 18th but
I have received reliable information about the discussions and feel that I
need to speak to the issue myself.
I am a professional engineer and have had dealings with land fills in New
Jersey and in California. I know there are many people around here that
"don't care how we did it up North" or even perhaps on the West coast,
however, this situation is a very serious exposure to the health and
welfare of the citizens and environment of both North and South Carolina.
I have chosen to live here in Southport for several reasons. The
environment is the primary one.
I could go on and on about the moral issues involved but lets take the
more simple. and straight forward road. Someone purchased several hundred
acres of land for a specific use and now has the idea that he/they can
receive a higher profit from a source which they have no real right to.
You as the commissioners of the NC Division of Water Quality don't have to
let anyone do what they want to do to improve their standard of living
(monetarily) at the expense of others. It is not their "god given right"
to expect the citizenry of NC or SC to be exposed to this potential health
hazard and degrading of our drinking water. What new future are you going
to create by allowing dumping in this great aquifer. In addition, the
residual pollution from trucks and upset garbage from accidents on these
narrow two lane roadways and loss of lives from trucks hitting
automobiles. Also, why haven't we heard about the effects from "foreign"
garbage and toxic wastes from outside these two states? Are we supposed
to think that the owners will be satisfied with the "local" sources when
much more money can be gained from tipping fees of areas outside NC and
SC. There will be barging from northern ports into the Cape Fear River
ports, transfer of material (with spills into waterways and along roadways
from the transfer sites), over roads in the cities and towns of Brunswick
County to get to the landfill site.
Mr. Smith, it seems to me that you and your associates have a greater
responsibility to the citizens of NC to nourish places which nature
provides to balance our needs for clean water and air free from the
residual effects of a landfill on/in such an important pristine space as
the Green Swamp. There are other recourses for us to use to get rid of
our garbage and building debris. Please vote to not allow this perverted
attempt to bring toxins into our water aquifers and ocean fishing
industry.
Respectfully submitted,
Jeffrey C. Chapman
4506 Fieldstone Circle SE
Southport, NC 28461
Fl 5/2/02 9:13 AM
GRANT H. EGLEY
2690 Bella Coolo Road, Lake Woccomow, NC 28450 [phone]
Danny Smith
NC Division of Water Quality
Non-Discharge Branch, Water Quality
401 Wetland Unit
2321 Crabtree Blvd.
Raleigh, NC 27604
Dear Mr. Smith;
May 1, 2002 ,
?:l MAY 3 M t ,
I object to the proposed regional landfill in the Green Swamp. I appreciate the difficulty of
your position in making the decision about a permit.
The Columbus County Commissioners and the Reigel Ridge organization want to have the
landfill in the Green Swamp location. However, I do not believe that they have considered the
long-term effects of locating a landfill in those wetlands. Many private citizens are
concerned by the environmental threat of a large regional landfill in the Green Swamp.
Those who are concerned are looking to you with your expertise to make the right decision to
protect our water quality. We trust that you will make that right decision.
I just want to briefly make two points. One concerns leachate. I understand that this leachate
is apt to be toxic. What are the plans for safe disposal of leachate. Where is the disposal site?
What are the safeguards for containment of the leachate during heavy rainfalls or floods?
Will the leachate<be trucked away from the site? If this is so, what will happen when the road
is impassable as it was during Hurricane Floyd?
My second point concerns the size of the landfill. Is there a maximum size? With the county
and the Riegel Ridge Corporation both profiting from the operation of this landfill, there is no
incentive to minimize its size. The more trash that goes into the landfill, the more cash that
they receive. Thus, there is a reverse incentive to put more trash into the landfill. This only
increases the threat to our environment and water quality. This is wrong! The county should
be encouraging reduction in the amount of trash we generate or obtain from other counties,
not encouraging more trash. In my opinion, the combination of the,size and the location of
the landfill should be a basis for denial of the permit request.
Please consider these points in making your decision.
Sincerely,
c
Grant H. Egley

Cc; Angie Pennock, Corps of Engineers
?0 W E z
5-6-02
MAY ` 8 W
North Carolina Division of Water Quality
ATTN: Danny Smith WETLANDS GROUP
Water...Quality, 401 Westland Unit WATER UALITYSECTfON
2321 Crabtree Blvd.
Raleigh, N.C. 27604
I am writing to express. my disapproval of the landfill proposed by Riegel Ridge
Corporation in the Green Swamp at Clewis Corner in Columbus County. I am
concerned that the proposed landfill will harm the delicate environment in the
Green Swamp where dozens of endangered and/or rare species of plants and
animals live. I am also concerned that it may damage the environment of areas that
surround the Green Swamp, including but not limited to Lake Waccamaw State
Park, the State of North Carolina Black Bear Game Preserve, the Juniper Creek
drainage basin, and the Waccamaw River wilderness areas that extend into South
Carolina. The Green Swamp is recognized as an important and unique
environment by: (1) The Nature Conservancy, (2) The North Carolina Natural
Heritage Program, and (3) The North Carolina Parks and Wildlife Department.
Please intervene on my behalf to represent and protect our collective public
interest. As a member of the collective public constituency, I petition those who
were elected by our votes to represent our interests, to voice these interests in the
state and federal legislative forums, to protect the Green Swamp from the
damaging effects of this proposed trash dump. I petition our elected public officials
to legislatively prevent the establishment of the landfill proposed by Riegel Ridge
Corporation in the Green Swamp at Clewis Corner in Columbus County.
Respectfully,

Renaissance
Management Group, LLC
May 7, 2002
North Carolina Division of Water Quality
Attn. Danny Smith
NC Division of Water Quality, Non-Discharge
Water Quality, 401 Wetland Unit
2321 Crabtree Blvd.
Raleigh, NC 27604
Dear Sir:
Executive Search Division
936 West Fourth Street, Suite 300
Winston-Salem, North Carolina 27101
Telephone: [phone]
Fax: [phone]
eMail: [e-mail]
4
MAY-9? ?
T/
7 F-U NDS GROUP
I am writing to express my grave concern and firm opposition to the action of the County
Commissioners of Columbus County, NC to permit the private development of a huge, regional
landfill in the Green Swamp, a designated National Natural Landmark.
I am not a resident of Columbus County, but I am a frequent visitor to the area and as a
business owner and a citizen of North Carolina, I place great value on protecting our state's
water resources. Lake Waccamaw, the state's only Outstanding Resource Water, will be put at
a completely unjustified risk by a landfill of this size in such close proximity. The landfill will
generate millions of gallons of toxic pollutants which will threaten precious water resources that
we absolutely cannot afford to lose. In addition to Lake Waccamaw and the Green Swamp, this
landfill's drainage threatens Juniper Creek, the Waccamaw River Basin and much of the water
resources of Brunswick County.
This landfill, aside from the obvious problems that it would cause as an eyesore, a source of
odors and excess traffic, threatens an area of great and unique biological diversity. Lake
Waccamaw is the home of over 100 species of fish and mussels, several of which are found
nowhere else in the world. The Green Swamp, home of deer. black bear. and large wild cats, is
also one of the last remaining refuges for carnivorous plants, like the Venus flytrap and the
pitcher plant, and many rare and endangered species.
Please help us stop this landfill location, in an area prone to hurricanes and flooding, adjacent to
pristine and vulnerable water resources.
Yours sincerely,
Hampde D. Kenan
HDK/shw
May 7, 2002
Mr. Danny Smith
N.C. Division of Water Quality
Non-Discharge Branch
Water Quality, 401 Wetland Unit
2321 Crabtree Blvd.
Raleigh, NC 27604
Dear Mr. Smith,
F
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t
I would like to express my deep concern about the proposed landfill in the
Great Greenswamp of North Carolina. This is a National Natural Landmark,
as recognized by the Department of the Interior, and is a refuge for many
wild animals and many endangered species of plants.
It also feeds beautiful Lake Waccamaw, the largest natural lake between
Maine and Florida. It is North Carolina's only Outstanding Resource Water.
The threat that this proposed landfill poses to the Green Swamp, Lake
Waccamaw, and the wildlife and plants, not to mention the effect it would
have on the quality of life of the nearby humans, is too great to allow this to
happen.
Please do not permit this potential tragedy to occur. North Carolina needs to
preserve its natural treasures, and these are some of the greatest we have.
Thank you for your consideration!
Sincerely,
S00 ti ??
??, IJ c .2 x.273
May 7, 2002
Mr. Danny Smith
N.C. Division of Water Quality
Non-Discharge Branch
Water Quality, 401 Wetland Unit
2321 Crabtree Blvd.
Raleigh, NC 27604
Dear Mr. Smith,
1 t
MAY - 9 2002
WETLANDS GROUP
?git4TE? gtr„Lin scr?or!
I would like to express my deep concern about the proposed landfill in the
Great Green Swamp of North Carolina. This is a National Natural
Landmark, as recognized by the Department of the Interior, and is a refuge
for many wild animals and many endangered species of plants.
It also feeds beautiful Lake Waccamaw, the largest natural lake between
Maine and Florida. It is North Carolina's only Outstanding Resource Water.
The threat that this proposed landfill poses to the Green Swamp, Lake
Waccamaw, and the' wildlife and plants, not to mention the effect it would
have on the quality of life of the nearby humans, is too great to allow this to
happen.
Please do not permit this potential tragedy to occur. North Carolina needs to
preserve its natural treasures, and these are some of the greatest we have.
Thank you for your consideration!
Sincerely,

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MAY 1 0 2002
WETLAWS you-
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DUMP'?.
To the editor; t
It has recently come to my atten-
tion that some big waste company
-has cut a deal with Columbus
County government officials to
build. a huge landfill in the Green
Swamp, right on the border of
Brunswick County. '
This dump will border nearby
Lake Waccamaw and the Wacca-
maw River, leaching thousands of
gallons of possibly toxic waste into
our aquifer. That's the water that '
the people of Ash area and Wacca-
maw Elementary School drink.
This landfill will have a pro-
found impact on Brunswick and
Horry counties, yet we weren't
even consulted on this decision..
Forget about beach traffic clogged
on 211. Forget about the very deli-
cate ecosystem destroyed. Forget
about tourism and the trickle-down
effect this will have on our econo-
my.
Instead, think about those
Columbus County elected officials
who are selling their constituents
down the river-all for a few mil-
lion bucks. Smells awfully fishy to
me now, but it will smell worse for
all of us later.
It is illegal to pick just one
Venus'-flytrap, but it's OK to
dump a mountain of toxic waste
on it? Go figure.
Columbus County is big enough
that it can find a more suitable
place for the landfill. It has no right
to dump on Brunswick County.
Everyone needs to come on board
on this one.
/?Y 4e&r It'?
ke e4qe /?Cz

Tara Murphy
Carolina Shores
PLUMBING, ELECTRICAL & LIGHTING SUPPLIES • WATER TREATMENT • MOBILE HOME SUPPLIES
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Ms. Angie Pennock
Biologist
U. S. Army Corps of Engineers
Ms. Pennock,
First, I want to thank you for taking the time to meet with me at the site, and then later
with our group, this past August 13. As I stated then, I recognize your role as an
impartial reviewer for the Riegel Ridge landfill permit application, and appreciate your
commitment in ensuring that a full and thorough review is completed. Our meeting that
day focused on two items from our previous discussions; (1) endangered and protected
species and (2) wetlands delineation. I left with actions to obtain additional information
on these two topics. Additionally, we touched on several items which were discussed at
an earlier meeting with the applicant and documented in your meeting minutes. I have
additional information for your consideration in this regard as well.
Endangered and Protected species
This matter pertained to the findings of the Endangered and Threatened species (E & T)
report issued by the applicant as part of their submittal to the NC Division of Solid Waste
Management. In an area known for rare and protected species, the applicant had
identified only a single colony each of two species of special concern, one of venus fly
traps and one of scale leaf gerardia, and none having the threatened or endangered taxon.
Several of our group have performed our own limited site studies in an effort to
determine the efficacy of the E & T report. We selected the versus fly trap as the focus of
our study, largely because of the distinctive and well known appearance of this plant. In
our first effort, in February of 2001, four of us spent approximately two hours looking
over portions of the site. In this short period of time we were able to identify two
additional colonies of fly traps, including one having literally hundreds of plants. These
findings were reported to Ms. Sherri Coghill in a letter at that time. In a later site visit,
conducted during the blooming season for the fly trap, we found more colonies, and
hundreds of additional plants.
Our site meeting on August 13th of this year included inspections of some of these fly
traps. At that meeting, the applicant's consultant proposed that these colonies may not
have been present at the time of his inspections, but rather dormant in seed or bulb form,
and emerged only after the site surveys for the E & T report were completed, due to more
favorable conditions resulting from clear cutting. My investigation into this matter
supports that this is not likely the case. First, I found no substantiation for the theory that
fly traps could remain dormant and invisible in seed or bulb form for years throughout
the pine tree life cycle, emerging only during those years following a clear cut. It is
generally acknowledged that this plant does tend to become smaller and therefore more
obscure under a pine canopy (much like the first colony we inspected by the Robert's
Road), and more vigorous and visible after clear cutting or thinning. I also revisited my
notes, and confirmed that we identified the first two additional colonies in February, of
2001. Given that the consultant's last formal surveys of the site were conducted during
the fall of 2000, for these two colonies to have not existed at the time of those surveys
would mean that they actually emerged and developed during the winter of 2000.
Clearly, the only logical explanation for the additional colonies of fly traps is that they
existed at the time of the E & T surveys, and were simply overlooked. Identification of
some of these plants might have been more difficult under the conditions existing at the
time of the surveys and I sympathize with the consultant in this regard, but certainly
"parting the grass" is not an undue burden in conducting this type of investigation.
The consultant's theory does raise an interesting point regarding the E & T report's
assessment of the potential for dormancy. The Natural Heritage Program has identified a
number of rare and protected plants and animals known to exist in the vicinity of the
proposed landfill site. Should the normal life cycle of a particular species include
extended periods of dormancy, then the fact that plant isn't apparent at the time of the
survey does not mean it doesn't exist on the site and won't be impacted. It follows that
the E & T report should identify and assess this with regard to the potential existence of
that plant on the site (No such discussion is provided for the fly trap, or any other of the
species involved).
Summarizing, the work that has been done to this point with regard to endangered and
protected species cannot be characterized as thorough and sufficient. Even the consultant
at our meeting eventually acknowledged that there were likely colonies of fly traps
interspersed throughout the site, although the E&T report identifies only a single colony.
There is no basis, certainly none provided in the E&T report, for stating that similar
findings would not result from additional scrutiny of the site for other species, including
some which may carry the "Endangered" or "Threatened" taxon.
Wetlands delineation
The latter portion of our site visit on August 13'h involved inspection of an area on the
southeast portion of the landfill "footprint" which appeared to be relatively low lying.
We also looked at hydrology data, stamped by a professional engineer and provided by
the applicant to the DENR Solid Waste Management Division, which includes a site map
depicting the results of a comprehensive survey of surface water levels against surface
elevation for the entire site on the dates March 18 & 19, 1999. This data clearly shows
that on the dates of study the water table in much of the landfill footprint was within 12
inches of the surface. Based on interpolation of hydraulic gradients and the topographical
information on the site map, I estimate that as much as 20 acres of the 100 acre landfill
footprint may fall in this category (see attached markup of map from site hydrogeologic
report).
Angie, your feedback at our site meeting was that the data in the hydrology report would
only be pertinent in the context of seasonal conditions (i.e., wetness) that existed at that
time. That is, a high water table resulting from abnormally wet season conditions ivould
not be a suitable basis for delineation. I have since researched historical weather records
to determine what seasonal conditions did actually exist at that time. I was able to locate
daily rainfall records from Wilmington, NC and Florence, SC, for the period in question.
This data establishes that both the months of February and March of 1999 were
abnormally, with rainfall well below normal. Specifically, rainfall was
approximately an inch below the 3 - 4 inch normal for both months at each of the two
recording stations, and even then the only significant rainfall event of March occurred at
the end of the month, after the site surveys (see attached National Weather Service data).
I further reviewed the data to determine if the data from these two stations would be
considered representative relative to the proposed landfill site. The Wilmington station is
approximately 20 miles due east of the proposed site, while Florence is approximately 75
miles due west. I found that the data from both stations virtually mirrored each other
over this time frame, with any significant rainfall at one site being represented by a
comparable measurement at the other. Indeed, a close inspection of data affirms that the
degree of correlation is in fact so great that it is simply not credible that conditions on the
proposed landfill site would not be represented by the data from these two stations. As a
general observation, the data denotes the degree to which precipitation during this time of
the year is driven by regional movement of weather systems, as opposed to localized
precipitation by storm cells as typically occurs during summer months.
Summarizing this issue, site data clearly shows that in March 1999, on the third and
fourth days of the recognized growing season in Columbus County, the water table in
much of the landfill footprint was within 12 inches of the surface. Given the low
evapotranspiration rates occurring at this time of the year, it is unlikely that the water
table would have been significantly lower over the next 8 days, and reasonable to believe
that 12 consecutive days of "wetness" did exist in these areas. More importantly, weather
data shows that this occurred over a period of time when seasonal conditions were
abnormally dry. Obviously, "normal" precipitation would be expected to result in still
higher water table measurements. Given that hydrophytic vegatation and hydric soils are
present in abundance, it follows that these areas meet all three delineation criteria and
should be reclassified as wetlands. The site hydrology data discussed above is stamped
by a PE as a part of the site hydrology report and again by Mr. Drietzler as part of the site
suitability report, and is considerably more comprehensive than the largely subjective
determinations reflected in the site wetlands delineation (as reflected in the information
provided to our attorney under FOIA). Notably, this site hydrology data was not
provided by the applicant to the Corps of Engineers for use in its wetlands delineation.
Flooding / Flood Plain issues
Your minutes from a recent meeting with the Corps and other reviewers notes Mr.
Drietzler as stating that the site was not flooded during Hurricanes Floyd or Fran.
However, site data in the hydrogeologic report included in the application submitted to
the Solid Waste Management Division clearly shows that a number of wells on the site
could not be accessed for measurement due to flooded conditions, and specifically
attributes this due to flooding from Hurricane Floyd. Notably; the dates of these
attempted measurements (Sept 29th and 301i) occurred nearly a full month after the
passage of Hurricane Floyd, and two of the sites in question are actually in the landfill
footprint. (See attached excerpt from site hydrogeologic report). Clearly, the data
supports that much of the site was flooded during Hurricane Floyd. To the best of my
knowledge, there is no data to support Mr. Drietzler's claim that the site did not flood
during Hurricane Fran.
In conclusion, it is my understanding that, as of this time, no application has been
submitted to the Army Corps of Engineers with regard to the proposed landfill. I am
bringing this information forward on a preliminary basis because these specific topics
have already been brought up and discussed with you by the applicant. In the matters of
endangered and threatened species and flood susceptibility, it may be feasible to simply
evaluate these impacts during normal review of the application at the time it is submitted.
However, since wetlands delineations are made by the Corps and form the basis for
determinations regarding the application, it follows that this issue should be resolved
prior to assessing the sufficiency of any application submittal.
c
e;.
cc. Sherri Coghill - DENR Solid Waste Management
John Runkle - Attorney at Law
Derb Carter - Southern Environmental Law Center
w/out attachments:
John Dorney - DENR Water Quality Division
JoAnne Steenhuis - DENR Water Quality
Respectfully Submitted,
9-11
Jeff Lane, Chairman,
Friends of the Green Swamp
Colonel James W. DeLoney - U. S. Army Corps of Engineers
Wayne Wright - U. S. Army Corps of Engineers