NCS000202_HISTORICAL FILE_20180719

STORMWATER DIVISION CODING SHEET
PERMIT NO.
�Clj Zo 2 o - z
DOC TYPE
❑ FINAL PERMIT
❑ MONITORING INFO
❑ APPLICATION
❑ COMPLIANCE �,{�N�e
A OTHER - ���5��d'� Coop!; fo'
DOC DATE
❑
YYYYMMDD t(el dOc.

Re: Individual Stormwater Permit Site question
Subject: Re: Individual Stormwater Permit Site question
From: Roger Edwards <[e-mail]>
Date: Wed, 26 Nov 2008 08:27:08 -0500
To: Brian Lowther <[e-mail]>
CC: Keith Haynes <[e-mail]>, [e-mail]
Brian,
When we receive the renewal package we will conduct a site inspection of their
operations.. Over the past 12 to 18 months we have received complaints of turbidity in
the North Toe River. However, we have not identified the source, so this is
application is worthy of further investigation.
Keith & Kevin, please plan to schedule a site inspection at this facility. Let me
know if there are questions for comments.
Thanks,
R. Edwards
Brian Lowther wrote:
Roger,
I am working on renewing an individual permit stormwater permit, NCS000202. The
site is for United States Gypsum Company and located in Spruce Pine, Mitchell
County. The site processes Mica. Their analytical monitoring shows very high TSS
values. The outfall drains to the North Toe River which is on the 303d list for
turbidity. Given these conditions, I wanted check to see if anyone in the
Asheville office was familiar with the site.
Address: 722 Altapass Highway, Spruce Pine, NC28777 .
Please let me know if you have any information about the site. If not, I am almost
done with the staff report and will sent it to your office shortly.
Brian
Roger Edwards - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Roger Edwards <Roger.Edwards(a),ncmai[.net>
NC DENR - Asheville Regional Office
Division of Water Quality - Water Quality Section
of 1 11/26/2008 8:26 AM

Re: Individual "'! �nmvater Permit Site question
W
Subject: Re: Individual Stormwater Permit Site question
From: Kevin Barnett <Kevin. Bamett@ncmaiLnet>
Date: Thu, 12 Mar 2009 13:42:04 -0400
To: Brian Lowther <Brian.Lowther@ncmaiLnet>
CC: Roger Edwards <Roger.Edwards@ncmailnet>,
Cranford <Chuck.Cranford@ncmaiLnet>
Hi Brian:
Keith Haynes <Keith.Haynes@ncmaiLnet>, Chuck
I did this inspection and staff report back in 12/18/2008.
Package was in mail next business day.
Facility has two outfalls.
Needs to sample at outfall before ditch and at outfall above railroad tracks to not be including off site
stormwater running to outfall.
Can apply for ROS after I year of monitoring two outfalls at appropriate discharge point.
No outside vehicle maintenance not out side storage of maintenance materials.
Best regards,
Kevin
Brian Lowther wrote:
Roger,
I noticed 1 hadn't heard back about this permit yet. Can you give me an update on the status of the staff
report?
Brian
Brian Lowther wrote:
1 wanted to follow up about the staff report for NCS000202. Has there been a site visit or is one
scheduled? Please let me know.
Brian
Roger Edwards wrote:
Brian,
When we receive the renewal package we will conduct a site inspection of their operations. Over
the past 12 to 18 months we have received complaints of turbidity in the North Toe River.
However, we have not identified the source, so this is application is worthy of further
investigation.
Keith & Kevin, please plan to schedule a site inspection at this facility. Let me know if there are
questions for comments.
Thanks,
R. Edwards
I of 2 3/12/2009 1:46 I'M

Re: Inclividuall,S_�ormwater Permit Site question
Brian Lowther wrote:
Roger,
1 am working on renewing an individual permit stormwater permit, NCS000202. The site is
for United States Gypsum Company and located in Spruce Pine, Mitchell County. The site
processes Mica. Their analytical monitoring shows very high TSS values. The outfall drains
to the North Toe River which is on the 303d list for turbidity. Given these conditions, I
wanted check to see if anyone in the Asheville office was familiar with the site.
Address: 722 Altapass Highway, Spruce Pine, NC28777
Please let me know if you have any information about the site. If not, I am almost done with
the staff report and will sent it to your office shortly.
Brian
"The time is always right to do what is right"
Martin Luther King, Jr.
Kevin Barnett - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone].
Fax: [phone]
E-mail correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third
parties.
Kevin Barnett <Kevin.BarnettRncmail.net>
NC DBNR - Asheville Regional Office
Division of Water Quality - Water Quality Section
2 of 2 3/12/2009 1:46 1'M

NCS000202 ,
Name:
NPDES Permit Number:
Facility Location:
Type of Activity:
SIC Code:
Receiving Streams:
River Basin:
Stream Classification:
Proposed Permit Requirements:
Monitoring Data:
Facility Location:
Response Requested by (Date):
Central Office Staff Contact:
Special Issues:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
United States Gypsum Co.
NCS000202
Spruce Pines, NC (Mitchell County)
Mica Processing
3295
See Figure 1
French Broad River Basin, Sub -basin 03-04-06
C; Tr
See attached draft permit.
See Table I
See Figure 1
Brian Lowther, [phone]
>Issue�`==Rating
Scale:] eas 'to,10 hard
Compliance history
3
Benchmark exceedance
7
Location (TMDL, T&E
5
slyecies, etc
Other Challenges:
7
• Trying to figure
out the
monitoring
Difficult Rating:
22/40
Coleen H. Sullins Director
Division of Water Quality
Special Issues Explanation:
• The analytical monitoring showed very high TSS values. The pennittee said that the adjacent site was
the source ol'rhe TSS. Also, they arc wetting down some of the piles and roads for dust suppression.
Runoff from this could produce waste water.
Description of Onsite Activities:
The plant processes mica. They get mined ore trucked in from different sources. Then it goes to an open pit to a
loader to a hopper and then to a dryer. From there is goes through the mill and put into 50 lbs. bags and bulk
systems for transport. Two sumps on site collect stormwater to prevent mica from exiting the site.
Page] of 8

NCS000202
Documents Reviewed:
• SPU File
• 2005 French Broad Basinwide Plan
2008 draft 303(d) list
• National Heritage Program's T&E database
• EPA draft 2006 Sector -Specific permit, "Sector E - Glass, Clay, Cement, Concrete, and Gypsum Products."
History:
• 10/01/1994: Date Permit first issued. Analytical monitoring included TSS. Samples were to be taken
annually.
• 09/01/2001: Date Permit re -issued. Analytical monitoring included TSS. Samples were to be taken
annually the first 3 years and quarterly during the 4'" year.
• 06/19/06: Permittee submitted renewal application:
Page 2 of 8

NCS000202
Figure 1: Map of Facility
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NCS000202
United States Gypsum Co
Lab tide: 350 53' 12" N
Longitude: 820 4' 40" W
County: Mtchell
_
F%
`.�.✓
Receping Stream: North Toe River
Stream Cass: C; Tr
S
Sub -basin: 04-03-06 (Frexh Broad River Bain)
Facility Location
NkpScale 1:20,000
Page 3 of 8

NCS000202
Central Office Review Summary:
1. Owner's Other Permits: Air Quality Permit 04314T07
2. General Observations: This facility is the former Diamond Mica plant purchased in 1981. The facility dries and
grinds mica for use in sheet rockjoint compound. Raw mica is purchased from the adjacent Feldspar Corporation
facility and other local sources at approximately 25% moisture.
From the air gualirypermit application review: Purchased mica is delivered on site by dump truck and placed
in the mica storage pit/truck dump. Water sprays on the storage pile are used to keep the material wet to prevent
fugitive dust emissions. Haul roads are also watered to suppress dust.
Using loaders, the wet mica is put into the mica dryer feed hopper. The hopper feeds mica into the natural gas
direct -fired rotary dryer. PM emissions from the mica dryer are controlled by a bagfilter. The dried mica (now
8% moisture) is either stored in three dry storage bins or fed thru the dry feed distribution system into the three
jet grinding mills. Heated air from a No. 2 fuel oil -fired indirect pre -heater is introduced into the grinding mills,
resulting in a final product moisture content of 0%. The screened mica is then sent via the finished product
elevator to four (4) bulk loading bins for loading into railcars or the two baggers.
The raw mica has had No. 2 fuel oil added as a flotation agent during mining. Volatilization of this oil residue
during drying and processing of the mica results in volatile organic compound emissions sufficient to require a
PSD avoidance limit of less than 39,000 tons of dried mica produced per consecutive 12 month period. Strong
diesel fuel oil odors are evident on the plant site, but not off -site.
littp:Hdag.state.nc.us/permits/permit reviews/USG rev 02162005.1)df
Impairment: North Toe River 7-2-(27.7)b is on the 303(d) for turbidity. The river is impaired upstream of the
site. According to the basinwide plan the river is impaired for aquatic life. This site receives runoff from the
Town of Spruce Pine and several dischargers in the watershed, which may have impacted the benthic
community. The North Toe River may also be impacted by road construction activities associated with the
expansion of NC 19 from Burnsville to Spruce Pine. Narrow riparian zones were also noted. It is
recommended that local agencies work with landowners to install BMPs to improve riparian zones and the
overall water quality in the river.
4. Threatened and Endangered: There are no species that are federally endangered or threatened located within a
two mile radius based on the Natural Heritage, Virtual Workroom.
5. Location: The outfall goes to a C; Tr River.
6. Industrial Changes Since Previous Permit: There have been no significant changes since the application was
filed.
7. Analytical Monitoring Notes: Analytical monitoring was done 7 times from 8/19/02 to 8/30/05. TSS was the
only monitoring required. All but one of the recordings was over the current benchmark.
Sector E in the EPA Multi -Sector Permits recommends monitoring for TSS (Flat Glass; Glass and Glassware,
Pressed or Blown; Glass Products Made of Purchased Glass; Hydraulic Cement; Cut Stone and Stone Products;
and Abrasive, Asbestos, and Miscellaneous Nonmetallic Mineral Products (SIC 3211, 3221,'3229, 3231,3241,
3281, 3291-3299). The primary operation at the site is processing Mica. Therefore, the metals Al, Mg and Pb
will be added to the analytical monitoring.
8. Oualitative Monitoring Notes: The monitoring was all the same with no signs of pollutants.
Page 4 of 8

NCS000202
Tablet: Analytical Monitoring - -
Required
Sample
Total Flow
Precipitation
Duration
TSS
Sampling
Date
(MGD)
(in)
(hours)
Benchmark:
Range
100 mg/L
Outfall 1
09/01/01 to
8/19/2002
14.2
0.6
2.3
,490''„
O8/31 /02
09/01/02 to
7/29/2003
6
0.37
2.2
1'40
08/31 /03
09/01/03 to
8/11/2004
6.1
0.35
1.9
6`30
08/31/04
09/01/04 to
11/23/2004
10.7
0.18
3.7
620
11 /30/04
12/1/04to
2/24/2005
5.8
0.11
5.2
90
2/28/05
3/1/05 to
5/10/2005
136.8
0.81
2.2
1600
5/31 /05
6/1/05 to
8/30/2005
121.3
0.75
3.2
120
8/31/05
Over Current Benchmark
Data Not Collected
Page 5 of 8

NCS000202
Revised Permit Recommendations: Analytical nitoring:
1. Maintain monitoring for TSS but of uarterly samplin Al, Mg and Pb have been added to the monitoring.
2. pH has been added to the analytical monitoring req irements.
3. All analytical monitoring has been set to ems=annu during a representative storm event as defined in Part II
Section B. The permittee must also document t e total precipitation for each event. If no discharge occurs
during the sampling period, the permittee must submit a monitoring report indicating "No Flow" within 30 days
of the end of the six-month sampling period. Additionally, samples must be taken a minimum of 60 days apart,
as specified in Table 2.
4. Benchmarks for analytical monitoring have been added to this draft permit. Exceedances of benchmark values
require the permittee to increase monitoring, increase management actions, increase record keeping, and/or
install stormwater Best.Management Practices (BMPs) in a tiered program. If the sampling results are above a
benchmark value, or outside of the benchmark range, for any parameter at any outfall then the facility shall
follow the Tier 1 guidelines which require a facility inspection within two weeks and implementation of a
mitigation plan within two months. If during the term of this permit, the sampling results are above the
benchmark values, or outside of the benchmark range, for any specific parameter at a specific discharge outfall
two times in a row (consecutive), then the facility shall follow the Tier 2 guidelines which require a repetition
of the steps listed for Tier 1 and also immediately institute monthly monitoring for all parameters at every
outfall where a sampling result exceeded the benchmark value for two consecutive samples.
5. The permittee is required to collect all of the analytical and qualitative monitoring samples during
representative storm events as defined in Part 11 Section B. Qualitative monitoring is required regardless of
representative outfall status.
6. The permittee is responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables 1,
4, and 5.
7. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall parameter is in
this permit, however.)
8. Vehicle maintenance monitoring has been revised to semi-annually in order to coincide with analytical and
qualitative monitoring.
Other Proposed Changes to the Previous Permit:
1. Additional guidance is provided about the Site Plan requirements. The site map must now identify if the
receiving stream is impaired and if it has a TMDL established. It must also describe potential pollutants in each
outfall. The map requirements are stated more explicitly. And, the site plan must contain a list of significant
spills that have occurred in the past three years and also must certify that the outfalls have been inspected to
ensure that they do not contain non-stormwater discharges. Additional information is provided in Part 11
Section A.
2. Additional requirements for the Stormwater Management Plan have been specified in Part II Section A. More
details regarding secondary containment are provided.
3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part II Section A.
The plan must also be updated annually to include a list of significant spills and to certify that the outfalls do
not contain non-stormwater discharges.
4. The facility must now implement a semi-annual Facility Inspection Program of the site's stormwater
management controls as specified in Part II Section A.
5. Information regarding the No Exposure Exclusion has been added to this draft permit. If industrial materials
and activities are not exposed to precipitation or runoff as described in 40 CFR § 122.26(g), the facility may
qualify for a No Exposure Exclusion from NPDES stormwater discharge permit requirements. Additional
information is provided in Part I Section A.
Page 6 of 8

NCS000202
Discussions with permittee: Randy Kenyon, [phone], 9/22/08
1. General description of industrial activities? The plant processes mica. They get mined ore trucked in from
different sources. Then it goes to an open pit to a loader to a hopper and then to a dryer. From there is goes
through the mill and put into 501bs. bags and bulk systems for transport. Two sumps on site collect
stormwater to prevent mica from exiting the site.
2. Have there been any changes since filing the application? No
3.Why was all the visual monitoring exactly the same? On their site the storm water is clear but they have to
sample across the railroad tracks on their neighbor's property where the water has more sediment in it.
4. The analytical monitoring for TSS was very high. Any reason for that? Their neighbors have sand and
sediment on the road from their operation and it gets washed into the stormwater.
5. Do you have vehicle maintenance onsite? No
6. What is you SIC code? 3295
Follow up Questions: Randy Kenyon, [phone], 11/24/08
1. The Air Quality Permit showed that piles and haul roads were sprayed for dust suppression. How much water is
this and where does it go? Only during the spring and summer. No run offfrom piles but there is some from the
haul roads. This water runs to the sumps onsite.
Page 7 of 8

NCS000202
Recommendaiions: Based on the documents reviewed, the application information submitted on 06/16/06
sufficient to issue an Individual Stormwater Permit.
Prepared by (Signature) ��-- l Date 1 Z1410f
Stormwater Permitting Unit Supervisor _(� / '/ ✓i Date /2 S m
for Bradley Bennett
Concurrence by Regional
Water Quality Supervisor
Regional Office Staff Comments
Are they sampling in the correct location?
What are the sumps like on site?
Date
Date
Page 8 of 8

I
April 11, 2013
Mr. Ken Pickle, Stormwater Staff Engineer
North Carolina Department of Environment and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: USG Stormwater Permit No. NCS000202 — TSS and Aluminum Benchmarks
Dear Mr. Pickle:
Please accept this letter as a recap of our discussion via teleconference on Thursday, April 0.
United States Gypsum Company (USG) operates a mica processing facility in Spruce Pine, NC
under individual stormwater permit NCS000202. The Plant has four stormwater outfalls which
discharge to property owned by the Feldspar Corporation before eventually discharging to the
North Toe River. Semiannual analytical sampling has been completed for TSS, Aluminum,
Magnesium, Lead and pH. Results are regularly submitted on Discharge Monitoring Reports to
the North Carolina Department of Environment and Natural Resources (NCDENR). Over the
permit term, the benchmarks for TSS and Aluminum have been exceeded more than four times at
multiple outfalls. Concrete sumps were installed in 1999 to trap suspended solids before reaching
the Plant's stormwater outfalls. The project has reduced solids in stormwater effluent
considerably since initial installation. Per the Tiered Program in the stormwater permit, monthly
analytical sampling was implemented starting in 2010.
The initial 2013 storm water sample was below the 100 mg/L TSS benchmark at all outfalls. The
USG Spruce Pine Plant believes that this positive result is due to the elimination of a satellite
mica storage pile towards the end of 2012. The Plant's Stormwater Pollution Prevention Plan
will be updated to reflect this new BMP and mica will not be stored in this location going
forward. We will continue to collect monthly samples to ensure that TSS stays below the permit
benchmark. If. additional benchmark excursions are noted, USG will investigate additional
engineering controls or increased housekeeping.
The Spruce Pine Plant cannot meet the 0.75 mg/L aluminum benchmark. EPA Method 200.7
performed by Pace Analytical Services, Inc., digests the entire sample in a mixture of
hydrochloric and nitric acids and then determines the amount of aluminum present. However,
this method does not relate the actual contribution of mica present in storm water to the dissolved
aluminum content of the North "foe River. Mechanical and/or chemical weathering processes do
not easily liberate aluminum from muscovite mica, the Plant's main raw material. When

Mr. Ken Pickle
NCDENR. Division of Water Quality
Pa e 12
aluminum is liberated it forms either aluminum oxide or aluminum hydroxide, which are both
insoluble in water. USG is unaware of any other onsite sources of aluminum that may contribute
to the stormwater results.
Please see the attached technical memo written by Mr. Roger Sharpe, Director of Geotechnical
and Mining Services at USG, for more details on aluminum in mica. USG is unaware of a
different sample method which does not dissolve mica that may be present in trace amounts.
Filtering the sample will not remove all of the mica, even if the TSS benchmark is maintained.
For the reasons presented within, USG requests that the aluminum benchmark be removed so
that future sample results are not counted as permit excursions. We are willing to work with
NCDENR to reach practical administrative solution to this issue.
Should you have any questions regarding this letter or the attached technical memo, please
contact me at 770-454-1533.
Sincerely,
Randy Ruddell
Plant Manager
United States Gypsum Company
722 Altapass Highway
Spruce Pine, NC 28777
Enclosure
Cc: Chuck Cranford, NCDENR - Asheville Regional Office
Tim Fox, NCDENR — Asheville Regional Office
Randy Kenyon, USG
Roger Sharpe, USG
John Bolden, USG

.,
4IZfl2
TO: Randy Kenyon — Spruce Pine April 1, 2013
Randy Ruddle — Chamblee
John Bolden — Chicago
CC: Greg Kinser — Chicago
Tony Suveg - Chicago
FROM: Roger D. Sharpe — Director, Geotechnical and Mining Services
SUBJECT: Spruce Pine —Aluminum Content of Stormwater Runoff Samples
J�� benc4,v.,ork--�9raG ?
Samples of surface water runoff from 1r he Spruce Pine Plant often.have a dissolved
aluminum content exceeding the limit f 750 ug/L set by the Division of Water Quality
of the North Carolina Department of Environment and Natural Resources. During the
period August 2009 through January 2013 com osite�amples of the four permitted
outfalls varied from 917µg/L toO8,60 µ /L. The analyses represent the total aluminum
content after the samples are digested in a mixture of nitric and hydrochloric acid. This
data does not accurately represent the actual dissolved aluminum content of the runoff
into the North Toe River. Tire predominant mineral in the runoff is muscovite, which is
very resistant to mechanical and chemical breakdown by natural processes. Muscovite
discharger) as runoff does not signifrcandy contribute to the total dissolved aluminum
content of the North Toe River. Background levels of dissolved aluminum in the North
Toe River Watershed (>I50 square miles of mica -bearing rocks) varied from about I00
to 1,600µg/L.
Muscovite (K2A14[Si6AI2O2Qj(OH)4) is one of the most chemically and mechanically
resistant minerals that occurs in the types of rocks underlying the North Toe River
Watershed (NTRW.) It is very robust and remains relatively unaffected during chemical
and physical weathering/erosion of the muscovite -bearing parent rocks. The general
chemical weathering processes for rocks such as granite, pegmatite and mica
schist/gneiss are shown below:
• Feldspars (orthoclase and plagioclase) undergo hydrolysis to form kaolinite clay,
releasing Na and K ions, which are removed by leaching by groundwater.
• Biotite and/or amphibole undergo hydrolysis to form clay and/or vermiculite
and oxidation to form iron oxides.
• Quartz and muscovite are very resistant to weathering and remain as residual
minerals.
The Spruce Pine Plant is located very close to the downstream end of the drainage basin
of the NTRW, which covers more than 150 square miles. The drainage basin is underlain
predominantly by metamorphic rock of the Ashe Metamorphic Suite (AMS) which
includes mica schist and gneiss, quartz -feldspar gneiss, amphibolites gneiss and schist,
minor ultramafrc rocks and marble. The AMS has been intruded by plutons and thick
veins of igneous rock including white granitic rock, known as "alaskite" and pegmatites.
Muscovite is abundant in the mica schist/gneiss, alaskite and pegmatites. A limited
number of samples taken from the Toe River taken upstream of the USG and Feldspar
Corporation plants have total dissolved aluminum values of about 100 to 1,600 µg/L.
This is significant because it represents the total amount of aluminum contributed to the
surface water from a drainage basin over 150 square miles in area.
Tm�al �'eGo✓�/a
�Psire• too— 16601a9ll_ ,dissovved Ai
3150'/ / /L- 5-3, 50,01, 2

When muscovite is removed by erosional processes the crystals abrade into smaller and
smaller particles, remaining suspended in stream and river flow and transported over
great distances. Muscovite has one perfect cleavage plane and is easily split into thinner
and thinner sheets. Muscovite derived from the erosion of the Appalachian Mountains is
found in beach deposits all along the Atlantic and Gulf Coasts. Larger muscovite particles
and/or "books" of crystals may settle into the streamfriver sediments or be carried in the
bed load. The (total) aluminum content of stream sediments in the Spruce Pine area is in
the range of 32,000 to 64,000 µg/L. — Pal rer M o d s fie e P tb4. fa cr I,
Muscovite does not naturally contribute a significant amount of aluminum into fresh
water runoff and stream flow due to its relative insolubility in the common forms,
aluminum oxide and aluminum hydroxide.
• Aluminum mainly occurs as Ala" (aq) under acidic conditions, and as Al(OH)4 (aq)
under neutral to alkaline conditions. Other forms include AlOH2+ (aq) and Al(OH)3
(aq).
• The most abundant aluminum compounds are aluminum oxide and aluminum
hydroxide, and these are water insoluble.
• Aluminum forms during mineral weathering of feldspars, such as and orthoclase,
plagioclase, micas and bauxite subsequently ending up in clay minerals, such as
kaolinite or halioysitc.
• The information below is from a 1929 technical document of the U. S. Department of
Agriculture titled "Alteration of Muscovite and Biotite in the Soil", 1929, USDA
Technical Bulletin 128:
• Muscovite, under ordinary conditions, is one of the least alterable of minerals. .
• The feldspar of a granite may be completely kaolinized, while the embedded
plates of mica retain their brilliancy almost unchanged.
• One of the most frequent alterations [of muscovite] is that of hydration, a part of
the potassium being replaced by hydrogen; or at the same time it may take up
other bases and thus the mineral may pass into vermiculite, a somewhat indefinite
compound to which no formula can lie assigned.
• Muscovite as well as biotite releases potash (potassium) to plants, and both are as
well adapted for supplying potash as potash feldspar. (2) The release of potash to
plants by muscovite is in opposition to the prevailing opinion a<< to the capacity of
this mineral to weather, pointing, as it does, to an actual weathering. This appears
to consist in removal of potash but with preservation of the external physical
properties of the mineral.
• Studies on the laterites of Guinea finds that the weathering of muscovite under
lateritic conditions results in loss of alkalies, particularly of potash, with a
corresponding gain in water, the end product of weathering having essentially the
composition of kaolinite.
Roger D. Sharpe P.G.
TOP. 04412-t—
Director, Geotechnical and Mining Services
United States Gypsum Company

Pickle, Ken
From: Ruddell, Randy K [[e-mail]]
Sent: Friday, April 12, 2013 4:58 PM
To: Pickle, Ken
Cc: Fox, Tim; Cranford, Chuck; Bolden, John; Sharpe, Roger; Kinser, Greg; Kenyon, Randy P;
Nguyen, Tram
Subject: USG Spruce Pine, NC Stormwater Permit No. NCS000202
Attachments: 20130412140719856.pdf
Mr. Ken Pickle,
Attached please find our 2 page letter, recapping our discussion via teleconference on 4/4/2013, in addition to
the 2 page letter we briefly discussed, written by Roger Sharpe, USG Director - Geotechnical and Mining
Services.
I sent to you today (certified mail) a hardcopy of both letters.
Your primary contact with USG Environmental is:
John Bolden
Environmental Services Senior Manager
United States Gypsum Company
550 W Adams St
Chicago IL, 60661
Ph:312-436-5587
Fax:[phone]
Cell: 312-823-6702
Your primary contact at our Spruce Pine plant is:
Randy Kenyon
Operations Manager
U S Gypsum
722 Altapass Hwy
,Spruce Pine, NC 28777
Ph: [phone]
Fax:[phone]
[e-mail]
Thank you for your time. Please feel free to contact us after reviewing this information.
Regards,
Randy Ruddell
USG Plant Manager - Chamblee/Spruce Pine
770-454-1533
Confidentiality Notice: This email is intended for the sole use of the intended
recipient(s) and may contain confidential, proprietary or privileged information.
If you are not the intended recipient, you are notified that any use, review,
dissemination, copying or action taken based on this message or its attachments,
if any, is prohibited. If you are not the intended recipient, please contact the
sender by reply email and destroy or delete all copies of the original message
1

Pickle, Ken
From:
Schimizzi, Nikki
Sent:
Thursday, April 04, 2013 1:02 PM
To:
Pickle, Ken; Fox, Tim; Barnett, Kevin
Cc:
Bennett, Bradley; Georgoulias, Bethany
Subject:
RE: US Gypsum, Spruce Pine
Hi all,
1
I'd be happy to review the0internal memo on aluminum whenever they send it to us. I would also like to ask the DWQ
chemistry lab folks to review it as well since they will be the experts on the testing procedures in question. You can
forward the memo to me and I'll share it with the lab.
Nikki
Please note new e-mail address: [e-mail]
Nikki Schimizzi
Environmental Senior Specialist
NC Department of Environment and Natural Resources
Division of Water Quality -Classification and Standards Unit
1617 Mail Service Center
Raleigh NC 27699
[phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Pickle, Ken
Sent: Thursday, April 04, 2013 12:31 PM
To: Fox, Tim; Barnett, Kevin
Cc: Bennett, Bradley; Georgoulias, Bethany; Schimizzi, Nikki
Subject: RE: US Gypsum, Spruce Pine
OK, here's the content in our phone call this morning.
• On the call: John Bolden US Gypsum Corporate Env. Mgr in Chicago; Tran Lin Corp Env. Staff also in Chicago;
Randy Kenyon, Plant Env.Mgr., Spruce Pine; Randy Ruddle (?), Plant Manager, Spruce Pine; KBP.
• What they want: some DWQ response to their belief that they will never be able to meet the aluminum
benchmark in our stormwater permit; and some modification to the permit on the aluminum.
• What they said:
o They have had continuing aluminum benchmark exceedances of the 0.75 mg/L stormwater benchmark
in our permit. They have an internal paper/memo from a US Gypsum staff geologist explaining that the
EPA lab test method frees up aluminum from the mica (an aluminum mineral) via the acidic digestion
step, and that the aluminum would not be released from the mica when exposed to the natural
processes in the natural environment. Hence the test method and benchmark together grossly over-
state the water quality impact/risk, and some accommodation should be made in the permit
requirements. I requested that theysend us the internal memo. Nikki, would you be available to
evaluate this concept once we receive their internal memo and you can review it?
o They have been sampling monthly in response to their understanding that they have subject to the Tier
2 and Tier 3 provisions of the permit. 1 note that they have been unsuccessful in catching monthly
samples (required by Tier 2), and they hove not previously contacted the ARO (required by Tier 3).
o The plant employs 12 people, and in 2012 they were working approximately 3 days per week.

o They have turned in one DMR for 2013 (although the DMR must be in the database -entry loop, because
it's not in Central Files at the moment.) Reported aluminum values for the four outfalls are lower. They
attribute the reduction to relocating some piles of stuff. Aluminum values are (compare to 0.75 mg/L
benchmark): 0.183 mg/L, 0.88 mg/L, 1.15 mg/L, and_9.59_m_g/L. They say that TSS values are all below
benchmark on the one sampling event in 2013.
• I explained:
o We in Central Office SPU will not act on revising the permit until ARID has provided input on the
question. I advised that ARO would be contacting them'to arrange a site visit. (OK for me to commit
ARO to that visit? If not please advise me.)
o The Individual Stormwater Permit allows us to make changes to the monitoring suite during the term of
the permit, unlike the General Permits. Or we can wait until the permit expiration and renewal on
5/31/14 and 6/1/14 (approx. one year from now.)
o They should send us their internal memo on aluminum. They should construct a written argument
supporting any request.
o Comment on TSS: It's good that TSS has improved, but I'd like to see more than just a single event
showing improvement before we consider any action on the permit requirements on TSS.
o I explained my preference for an engineering solution before we attempt an administrative solution to
their benchmark exceedances.
• Next steps:
o They will send us their internal memo on aluminum, mica, and the EPA test procedure vs natural
conditions.
o They will construct a written argument requesting some action on the aluminum benchmark provisions
in the permit.
o I will contact ARO to ask for a site visit.
o Presumably ARO will make that visit, and then we can pow -wow on what we think about making some
change to the stormwater permit.
o I want to guide them back to the conditions in the permit —they should be sampling more effectively
than one sample during a 12 month monthly sampling period (2012); they should have already
contacted ARO on the basis of more than four exceedances (I presume, I'll track down the DMR data to
be sure); ARID should take the lead in responding to the Tier 3 obligations, and SPU should work with
ARO on that and on whether to make any changes to the permit to adjust the aluminum benchmark.
Let me know if you see a better path forward with these folks.
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickle(ancdenr.gov
Website: http://I)ortal.ncdenr.org/web/wo/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Pickle, Ken
Sent: Thursday, April 04, 2013 9:42 AM

I
To: Fox, Tim; Barnett, Kevin
Cc: Bennett, Bradley
Subject: RE: US Gypsum, Spruce Pine
Two guys,
I just pulled the DMR's from DWQ Central files for this permittee for the year 2012. (The other reports have been
archived off -site on a two year schedule, and we have nothing yet for 2013.) 1 think a longer record may be available in
Google Docs. Here are his reported results for NCS000202:
Jan, Mar, May, June, July, Aug, Sept, Oct - eight reports of "No Flow" Reallylll??? I note that the permit only requires
them to sample twice a year, so I don't know why they're reporting so many times. Unless they're in Tier 2, or under
Tier 3 and your direction as to more frequent sampling. But, I don't see that in the files.
April 2012:
Outfall
Date
rainfall
TSS
Pb
pH
Al
Mg
100 mg/L
0.03 mg/L
6-9
0.75 mg/L
32 mg/L
1
4/7/12
0.55"
'1070.
0.0135
6.7
5.77,
2.47
2
4/7/12
0.55"
360
0.0067
7.1
3.15
1.52
3
4/7/12
0.55"
2530
0.0382
6.8
18.11
5.76
4
4/7/12
0.55"
648
0.0710
7.0
53.5
8.52
So, I'll hear their comments, questions, and requests. And I'll forward to you the essence of our conversation. But I'm
going to defer any action or response to them until you all have a chance to weigh in on what we should do with their
request.
Expect an email from me by lunch today.
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickle(a)ncdenr.gov
Website: http://portal.ncdenr.org/web/wci/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Fox, Tim
Sent: Thursday, April 04, 2013 8:09 AM
To: Barnett, Kevin
Cc: Pickle, Ken
Subject: RE: US Gypsum, Spruce Pine
Ken and Kevin,

I have been to the Quartz facility that borders this site but have not inspected this facility since I started about a year
ago.
I don't have any additional information but I can schedule a site visit with them in the near future.
You can pass on my contact information and I will contact them and see if we can help assist with a site visit.
Thanks,
Tim
Tim Fox - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Surface Water Protection
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel:[phone]
Fax:[phone]
Notice: Email correspondence to and from this address may be subject to the NC Public Records Law and may be
disclosed to third parties.
From: Barnett, Kevin
Sent: Thursday, April 04, 2013 7:50 AM
To: Pickle, Ken
Cc: Bennett, Bradley; Fox, Tim
Subject: Re: US Gypsum, Spruce Pine
Hi Ken.
I have not been back to this facility since that 08 inspection.
Tim, have you inspected this one?
Thanks,
Kevin
Scnt from my Verizon Wireless 4C LTE DROID
"Pickle, Ken" <ken.pickleancdenr. gov> wrote:
Hi Kevin,
I pulled your name out of our SPU file for NC5000202, US Gypsum in Spruce Pine, Mitchell County.

I saw that you visited the site 12/18/2008. Do you know if there has been any USG/DWQ contact since your visit in
December 2008, and since our issuance of the permit on 6/1/09? Is there anything special I should know about this
facility?
They want to talk with me tomorrow at 10:00 about their difficulties meeting the TSS benchmark and the aluminum
benchmark according to just a very brief conversation this afternoon. Are you still tracking these guys?
I:F. ,
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. oickle(�Dncdenr.gov
Website: htto://Portal.ncdenr.org/web/wa/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

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41

Georgoulias, Bethan
From: Bolden, John <[e-mail]>
Sent: Wednesday, January 31, 2018 9:55 AM
To: Georgoulias, Bethany
Cc: Price, David; Kenyon, Randy P; Stepanian, Alexander
Subject: [External] FW: USG Spruce Pine, NC Stormwater Permit No. NCS000202
Attachments: Stormwater Results for Analytical Monitoring 11-14-17.xis; 20130412140719856.pdf
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
[e-mail].
Ms. Georgoulias,
We recently sent storm water sampling results to Mr. Ken Pickle to review, but I understand that he has retired. The
voice message lists your name as someone who may be able to help given Ken's retirement and you were copied on
some of the correspondence with Ken from a few years ago (emails in the string below). Can you please review the
email andattachments and let us know if you are the correct NCDENR contact for this matter? We are interested in
scheduling a conference call meeting with NCDENR per my December email. Thanks!
USG t
John Bolden
Manager, Environmental Projects
USG Corporation
t 312-436-5587
c 312-823-6702
From: Bolden, John
Sent: Friday, January 26, 2018 1:47 PM
To: 'Pickle, Ken' <[e-mail]>
Cc: Price, David <[e-mail]>; Kenyon, Randy P <[e-mail]>; Stepanian, Alexander
<AStepa nian @ usg.com>
Subject: RE: USG Spruce Pine, NC Stormwater Permit No. NCS000202
Ken,
Just checking in to see if you have had a chance to review my email from last month and if you have availability for a call
to discuss our Spruce Pine facility. Please email or call if you have any questions. Thanks.
John Bolden
Manager, Environmental Projects
USG Corporation
t 312-436-5587

14
c 312-823-6702
From: Bolden, John
Sent: Thursday, December 14, 2617 1:46 PM
To: 'Pickle, Ken' <ken. pickle@ ncdenr.gov>
Cc: Price, David <[e-mail]>; Kenyon, Randy P <[e-mail]>; Stepanian, Alexander
<[e-mail]>
Subject: RE: USG Spruce Pine, NC Stormwater Permit No. NCS000202
Ken,
I hope all is well. It has been a few years, but the USG Spruce Pine facility now has three consecutive stormwater results
below the Ts� S h�achmark. Randy Kenyon and his team evaluated several different stormwater controls with the help of
an environmental consultant and has had success reducing solids by using an anionic polymer ("gel logs") in the ditches
prior to outfalls #1 and #4. Unfortunately, aluminum is still above the Plant's permit benchmark and it does not appear
that lowering TSS will bring the Plant below this benchmark. Attached is the most recent stormwater data for your
review.
Below is where I believe we left the issue with NCDENR and attached is the letter which Randy Ruddell sent to you with
our technical argument regarding aluminum. Our position regardine the alumimim henchmark remains unchanPed and
we request that NCDrNR'mnlPment anadministrative solution in our next stormwater permit. We have a new Plant
Manager for the site, David Price, who is copied on this email. Also copied is Alex Stepanian who will be assuming
environmental responsibility for Randy when he retires next year. I understand that the Plant's permit is up for renewal,
so I believe now would be a good time to revisit the aluminum issue and have another conference call. Please feel free
to forward this message on to others that need to be involved and let us know when you have availability to discuss.
Thank you.
Regards,
USG
John Bolden
Manager, Environmental Projects
USG Corporation
t 312-436-5587
c 312-823-6702
From: Pickle, Ken tmailto:[e-mail])
Sent: Wednesday, May 08, 2013 9:24 AM
To: Bolden, John <[e-mail]>
Cc: Bennett, Bradley <[e-mail]>; Georgoulias, Bethany<[e-mail]>;
Kenyon, Randy P <[e-mail]>; Ruddell, Randy K <[e-mail]>; Fox; Tim <[e-mail]>;
Cranford, Chuck <[e-mail]>
Subject: RE: USG Spruce Pine, NC Stormwater Permit No. NCS000202
Thanks, John
Yes, I think a conference call sometime early in June is appropriate. We will not wait until the normal renewal
period to come to a conclusion on the Al issue. We do need time to have the inspection and to distribute the

inspector's written trip report. (Our inspectors always send a copy of the inspection report to the facility, of
course.) Thanks for volunteering to set up the call.
I am assuming that monthly sampling has been triggered by both TSS and Al benchmark exceedances. As you
suggest, since monthly sampling is going to continue anyway until TSS is addressed with three consecutive
'results below the TSS benchmark, I think that we can hold further discussion of the Al issue until the TSS has
been addressed, i.e. until the facility can indeed accumulate three consecutive discharges within the TSS
benchmark. Then we can take up the Al question. We can pursue that expeditiously together, once the TSS has
been addressed,
o It is my hope that the improved performance on TSS may concurrently result in improved performance
on Al.
if so, then it seems tome that could be significant in our consideration of the whole of the site
circumstances, and potentially your argument is strengthened for some administrative response to the
Al benchmark.
o But, we will need to see what the data says.
0 It might be helpful if USG would interpret the TSS vs Al data for us in a short (<5 p?) letter
report. Show that TSS and AL do or do not track each other, and then make the interpretation
of the data set that you think supports your request for action on Al.
1 think it has been reported that there was a relocation of sampling points, in order to properly
characterize the pollutant load leavingjust the USG site, and to exclude the contribution from
Feldspar. We do not seek to make you responsible for your neighbor's pollutant discharges. So;
perhaps this letter report should be confined to consideringjust those historical lab results that
are our best shot at USG -only discharges.
I conclude from your note that your concern is about the cost burden of monthly sampling. I note, however,
that monthly sampling was in effect in 2012, but your cost burden during that year was a single sampling
event. I'm not sympathetic to the cost argument in the face of the actual costs incurred in 2012. My
perspective is that when the argument promises to get real, then we should and will respond to it in accordance
with the best science and understanding that all parties bring to the table, including the legitimate concern for
undue cost burdens for USG.
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. oickle(@ncdenr gov
Website: http://portal.ncdenr.org/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations."
From: Bolden, John [mailto:JBolden@)usg.com]
Sent: Tuesday, May 07, 2013 5:05 PM
To: Pickle, Ken

Cc: Bennett, Bradley; Georgoulias, Bethany; Kenyon, Randy P; Ruddell, Randy K
Subject: RE: USG Spruce Pine, NC Stormwater Permit No. NCS000202
Ken,
We would appreciate your support on the aluminum benchmark before the permit expires. If we are able to keep TSS
below the benchmark for three consecutive events, we can potentially reduce sampling back to once per quarter at the
Spruce Pine Plant. There is no way to reduce aluminum below the benchmark, so we are stuck sampling monthly until an
administrative solution is implemented.
I understand that you would like to wait until the Ashville Regional office performs their inspection. I'd be happy to
arrange another conference call after the inspection so that we can all get together again to review the issues at hand. In
the meantime, if you have any questions about our letter or the technical memo from our geological services
department, please feel free to give myself or Randy Kenyon a call. Thanks.
John Bolden
Environmental Services Senior Manager
United States Gypsum Company
550 W Adams St
Chicago It, 60661
Ph: 312-436-5587
Fax:[phone]
Cell: 312-823-6702
From: Pickle, Ken FinaiIto: ken. oickleancdenr.00v]
Sent: Friday, May 03, 2013 11:16 AM
To: Bolden, John
Cc: Bennett, Bradley; Georgoulias, Bethany
Subject: RE: USG Spruce Pine, NC Stormwater Permit No. NCS000202
Hi John,
Thanks for initiating a follow-up contact.
• 1 routed your information, along with 2012 sampling results (just one event), through co-workers in the
Stormwater Permitting Unit, through the DWQ lab folks, through DWQStandards and Classifications folks, and
through other NC DENR staff with geology/mineralogy backgrounds. They have commented back to me.
• I'm digesting their technical comments.
I'm also waiting to have a conversation with Tim Fox, our inspector in the Asheville Regional Office, after his site
visit scheduled May 30.
I note that the facility's current permit expires May 31, 2014. Given that that is only 13 months away, I wonder if we
might delay resolution until our regularly scheduled permit renewal process? We are currently down 4 permit writers,
leaving what amounts to 4 FTE for permit writing. Essentially we are at half -strength as far as this sort of work is
concerned. I am trying to prioritize my activities to accomplish what is absolutely necessary, and to postpone every
activity that does not immediately have a negative impact on our customers.
Is there some urgency at your end wrt resolving this question quickly? If so, we will press ahead as quickly as I can.
not, let's talk about a protracted time frame for resolution of this question.
Ken

Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pick] e(a)ncdencgov
Website: htto://Portal.ncdenr.orqZweb/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Bolden, John [mailto:JBolden(d)usg.com]
Sent: Friday, May 03, 2013 11:35 AM
To: Pickle, Ken
Subject: RE: USG Spruce Pine, NC Stormwater Permit No. NCS000202
Ken,
Just checking in. Is there anything more that you need from USG at this time? Thanks.
John Bolden
Environmental Services Senior Manager
United States Gypsum Company
550 W Adams St
Chicago IL, 60661
Ph: 312-436-5587
Fax:[phone]
Cell: 312-823-6702
From: Pickle, Ken[mailto:ken. oickleCalncdenr.aov]
Sent: Monday, April 15, 2013 8:24 AM
To: Ruddell, Randy K; Bolden, John; Kenyon, Randy P
Cc: Fox, Tim; Bennett, Bradley; Georgoulias, Bethany
Subject: RE: USG Spruce Pine, NC Stormwater Permit No. NCS000202
Thanks, Randy,
I've already enlisted other folks in DWQ to help me evaluate your request on the aspects that are beyond my
competence. I'll keep John and Randy Kenyon updated as we work our way through it.
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ l Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]

Fax: [phone]
Email: ken [e-mail]
Website: http://Portal.ncdenr.ora/web/wo/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations."
From: Ruddell, Randy K [mailto:[e-mail]]
Sent: Friday, April 12, 2013 4:58 PM
To: Pickle, Ken
Cc: Fox, Tim; Cranford, Chuck; Bolden, John; Sharpe, Roger; Kinser, Greg; Kenyon, Randy P; Nguyen, Tram
Subject: USG Spruce Pine, NC Stormwater Permit No. NCS000202
Mr. Ken Pickle,
Attached please find our 2 page letter, recapping our discussion via teleconference on 4/4/2013, in addition to
the 2 page letter we briefly discussed, written by Roger Sharpe, USG Director - Geotechnical and Mining
Services.
I sent to you today (certified mail) a hardcopy of both letters.
Your primary contact with USG Environmental is:
John Bolden
Environmental Services Senior Manager
United States Gypsum Company
550 W Adams St
Chicago IL, 60661
Ph: 312-436-5587
Fax:[phone]
Cell: 312-823-6702
Your primary contact at our Spruce Pine plant is
Randy Kenyon
Operations Manager
U S Gypsum
722 Altapass Hwy
Spruce Pine, NC 28777
Ph: [phone]
Fax:[phone]
[e-mail]
Thank you for your time. Please feel free to contact us after reviewing this information.
Regards,
Randy Ruddell
USG Plant Manager- Chamblee/Spruce Pine
770-454-1533
Confidentiality Notice: This email is intended for the sole use of the intended
recipient(s) and may contain confidential, proprietary or privileged information.
If you are not the intended recipient, you are notified that any use, review,
dissemination, copying or action taken based on this messageof its attachments,

if any, is prohibited. If you are not the intended recipient, please contact the
sender by reply email and destroy or delete all copies of the original message
and any attachments. Thank you.
Confidentiality Notice: This email is intended for the sole use of the intended
recipient(s) and may contain confidential, proprietary or privileged information.
If you are not the intended recipient, you are notified that any use, review,
dissemination, copying or action taken based on this message or its attachments,
if any, is prohibited. If you are not the intended recipient, please contact the
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,sender by reply email and destroy or delete all copies of the original message
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If you are not the intended recipient, you are notified that any use, review,
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Code:USG45ty
7

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Stormwater Results for Analytical Monitoring
Benchmark Values for
Analytical Monitoring
Benchmark Benchmark Benchmark Benchmark Benchmark
Units Units Units Units Units
Discharge
Characteristics
Total Suspended
Solids 100 mg/L
Aluminum 0.75 mg/L
Magnesium 32 mg/L
Lead 0.03 mg/L
pH 6-9
Dates
May 2018
Outfall #1
114
3.26
1.28
0.0076
7.1
Outfall #2
30.3
0.484
0.242
ND
6.9
Outfall #3
122
2.00
0.546
ND
7.0
Outfall #4
200
3.41
1.19
0.0111
7.1
April 2018
Outfall #1
61.2
2.05
1.22
0.0055
7.4
Outfall #2
3.8
0.244
0.198
ND
7.2
Outfall #3
90.6
3.4
0.69
ND
7.3
Outfall #4
42.8
1.5
1.88
ND
7.2
December 2017
87
1.78
0.657
0.0123
7.1
Outfall #1
Outfall #2
25.4
0.557
0.28
ND
6.8
Outfall #3
63.6
0.843
0.344
ND
6.9
Outfall #4
127
3.62
1.35
0.0135
7.0
October 2017
Outfall #1
45.6
3.86
1.18
0.0127
7.6
Outfall #2
12.3
0.284
0.22
ND
7.1
Outfall #3
11
0.577
0.316
ND
8.0
Outfall #4
89.2
3.65
1.74
0.005
7.1
August 2017
Outfall #1
46.7
0.919
0.595
0.0054
7.2
Outfall #21
ND
ND
0.0165
ND
7.0
Outfall #31
4
0.28
0.328
ND
7.0
Outfall #41
53
2.26
1.51
0.009
6.6
USG - CONFIDENTIAL

Stormwater Results for Analytical Monitoring
Benchmark Values for
Analytical Monitoring
Benchmark r Benchmark Benchmark Benchmark Be
Units Units Units I nchmark
Units Units
Discharge
Characteristics
Total Suspended
Solids 100 mg/L
Aluminum 0.75 mg/L
Magnesium 32 mg/L
Lead 0.03 mg/L
pH 6-9
Dates
May 2017
Outfall #1
36
0.834
3.85
ND
7.1
Outfall #2
32.6
0.438
0.358
ND
6.7
Outfall #3
20.7
0.556
0.382
ND
6.8
Outfall #4
28.3
0.855
2.28
ND
6.9
March 2017
Outfall #1
20.2
1.19
0.936
ND
7.0
Outfall #2
10.5
ND
ND
ND
6.3
Outfall #3
13.3
0.558
0.32
ND
7.0
Outfall #4
43.2
1.89
0.778
ND
7.0
November 2016
102
1.96
1.19
0.0073
7.0
Outfall #1
Outfall #2
5
0.128
ND
ND
6.2
Outfall #3
42.8
0.879
0.505
ND
6.5
Outfall #4
24
1.11
1.22
ND
6.4
August 2016
Outfall #1
7.4
2.7
0.733
0.0073
6.8
Outfall #2
26.2
1.03
0.528
ND
6.8
Outfall #3
14.4
0.528
0.274
ND
6.3
Outfall #4
18.9
2.91
0.717
0.0062
6.7
May 2016
Outfall #1
65
3.05
1.53
0.0091
7.2
Outfall #2
77.8
1.14
0.619
ND
6.8
Outfall #3
168
3.39
1.09
0.0081
6.8
Outfall #4
96.5
3.89
1.92
0.0128
7.0
USG - CONFIDENTIAL

Stormwater Results for Analytical Monitoring
Benchmark Values for
Analytical Monitoring
Benchmark Benchmark Benchmark Benchmark Benchmark
Units Units Units Units Units
Discharge
Characteristics
Total Suspended
Solids 100 mg/L
Aluminum 0.75 mg/L
Magnesium 32 mg/L
Lead 0.03 mg/L
pH 6-9
Dates
February 2016
Outfall #1
317
6.83
1.31
0.0241
7.0
Outfall #2
30.7
0.498
0.133
ND
6.6
Outfall #3
211
6.54
2.11
0.0093
7.2
Outfall #4
66
6.8
1.22
0.0071
7.1
November 2015
Outfall #1
62.6
2.39
1.02
0.0092
6.9
Outfall #2
3.1
0.116
ND
ND
6.3
Outfall #3
57.9
2.81
1.19
0.0056
6.6
Outfall #4
204
3.04
0.71
0.0076
6.8
September 2015
Outfall #1
31
0.564
0.425
ND
6.6
Outfall #2
114
2.17
0.992
ND
6.3
Outfall #3
78
1.73
0.615
ND
6.6
Outfall #4
189
2.98
0.559
0.0113
6.6
August 2015
Outfall #1
46
1.63
1.68
ND
8.9
Outfall #2
11.9
0.903
0.25
ND
7.8
Outfall #3
83.1
0.351
0.395
ND
7.4
Outfall #4
ND
1.14
0.996
ND
7.5
July 2015
Outfall #1
69.5
0.713
0.755
ND
6.7
Outfall #2
53.3
2.53
0.736
ND
6.5
Outfall #3
148
1.07
0.426
ND
6.3
Outfall #41
126
5.71
1.37
1 0.0152
6.8
USG - CONFIDENTIAL

Stormwater Results for Analytical Monitoring
Benchmark Values for
Analytical Monitoring
Benchmark Benchmark Benchmark Benchmark Benchmark
Units Units Units I Units Units
Discharge
Characteristics
Dates
Total Suspended
Solids 100 mg/L
Aluminum 0.75 mg/L
Magnesium 32 mg/L
Lead 0.03 mg/L
pH 6-9
June 2015
Outfall #1
143
2.4
0.855
0.0093
6.9
Outfall #2
76.7
2.91
0.637
ND
6.8
Outfall #3
35.4
0.667
0.288
ND
6.6
Outfall #4
160
4.35
0.982
0.0084
11.1
January 2015
Outfall #1
58
2.08
1.06
ND
7.5
Outfall #2
21
0.596
0.194
ND
6.1
Outfall #3
35
1.34
0.397
ND
6.7
Outfall #4
16.4
0.96
2.89
ND
7.6
October 2014
Outfall #1
32.2
0.783
2.88
ND
7.8
Outfall #2
22.6
0.433
0.201
ND
6.3
Outfall #3
75.7
2.29
0.763
ND
7.5
Outfall #4
48
1.71
1.64
ND
10.2
June 2014
Outfall #1
10.1
ND
0.592
ND
7.1
Outfall #2
4.3
ND
0.175
ND
6.6
Outfall #3
195
0.84
0.39
0.0067
6.2
Outfall #4
780
3.32
1.66
0.029
6.8
May 2014
Outfall #1
6.5
0.262
0.647
ND
7.3
Outfall #2
6
0.306
0.649
ND
7.3
Outfall #3
19.8
0.648
0.288
ND
6.8
Outfall #4
101
7.1
1.61
0.0106
7.2
USG - CONFIDENTIAL

Stormwater Results for Analytical Monitoring
Benchmark Values for
Analytical Monitoring
Benchmark Benchmark Benchmark Benchmark Benchmark
Units Units I I Units I I Units I I Units
Discharge
Characteristics
Total Suspended
Solids 100 mg/L
Aluminum 0.75 mg/L
Magnesium 32 mg/L
Lead 0.03 mg/L
pH 6-9
Dates
March 2014
Outfall #1
19.4
0.318
1.68
ND
7.5
Outfall #2
ND
ND
ND
ND
6.2
Outfall #3
119
7.1
1.14
0.0059
6.8
Outfall #4
9
0.289
0.318
ND
8.8
USG - CONFIDENTIAL

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North Carolina Department of Natural and Cultural Resources
Natural Heritage Program
Governor Roy Cooper Secretary Susi H. Hamilton
NCNHDE-6287
June 19, 2018
Bradley Bennett
NCDEQ
512 N. Salisbury Street
Raleigh, NC 27604
RE: United State Gypsum Co - Spruce Pine; NCS000202
Dear Bradley Bennett:
The North Carolina Natural Heritage Program (NCNHP) appreciates the opportunity to provide information
about natural heritage resources for the project referenced above.
Based on the project area mapped with your request, a query of the NCNHP database, indicates that there are
no records for rare species, important natural communities, natural areas, and/or conservation/managed areas
within the proposed project boundary. Please note that although there may be no documentation of natural
heritage elements within the project boundary, it does not imply or confirm their absence; the area may not have
been surveyed. The results of this query should not be substituted for field surveys where suitable habitat exists.
In the event that rare species are found within the project area, please contact the NCNHP so that we may
update our records.
The attached 'Potential Occurrences' table summarizes rare species and natural communities that have been
documented within a one -mile radius of the property boundary. The proximity of these records suggests that
these natural heritage elements may potentially be present in the project area if suitable habitat exists. Tables of
natural areas and conservation/managed areas within a one -mile radius of the project area, if any, are also
included in this report.
If a Federally -listed species is found within the project area or is indicated within a one -mile radius of the project
area, the NCNHP recommends contacting the US Fish and Wildlife Service (USFWS) for guidance. Contact
information for USFWS offices in North Carolina is found here:
https //www fws gov/offices/Directory/ListOffices cfm?statecode=37.
Please note that natural heritage element data are maintained for the purposes of conservation planning, project
review, and scientific research, and are not intended for use as the primary criteria for regulatory decisions.
Information provided by the NCNHP database may not be published without prior written notification to the
NCNHP, and the NCNHP must be credited as an information source in these publications. Maps of NCNHP
data may not be redistributed without permission.
The NC Natural Heritage Program may follow this letter with additional correspondence if a Dedicated Nature
Preserve, Registered Heritage Area, Clean Water Management Trust Fund easement, or Federally -listed
species are documented near the project area.
If you have questions regarding the information provided in this letter or need additional assistance, please
contact Rodney A. Butler at money butlerancocr coy or 919-707-8603.
Sincerely,
NC Natural Heritage Program
MAILING ADDRESS.
1651 Mall Service Center
Raleigh, NC 27699-1651
Telephone [phone]
www.ncnhp.mg
LOCATION.
121 West Jones Street
Ral"h, NC 27603

Natural Heritage Element Occurrences, Natural Areas, and Managed Areas Within a One -mile Radius of the Project Area
United State Gypsum Co - Spruce Pine
Project No. NCS000202
June 19, 2018
NCNHDE-6287
Element Occurrences Documented Within a One -mile Radius of the Project Area
Taxonomic
EO 10
Scientific Name
Common Name
Last
Element
Accuracy
Federal
State
Gbh
State
Group
01spervation
Occurrence
Status
Status
Rank
Rank
Date
Rank
Amphibian
5832
Cryptobranchus
Eastern Hellbender
2016-07-11
B
3-Medium
Species of
Special
G3G4T
S3
alleganiensis
Concern
Concern
2
alleganiensis
Dragonfly or
33446
Calopteryx amata
Superb Jewelwing
2004-Pre
H?
5-Very
---
Significantly
G4
S1S2
Damselfly
Low
Rare
Freshwater Fish
15461
Etheostoma acuticeps
Sharphead Darter
2009-02-28
E
3-Medium
Species of
Threatened
G3
S1
Concern
Freshwater Fish
20013
Percina squamata
Olive Darter
1964-08
H
3-Medium
Species of
Special
G3
S2
Concern
Concern
Natural
36255
Chestnut Oak Forest
---
2015-09-03
C
3-Medium
---
--
G4
S3S4
Community
(Mesic Subtype)
Reptile
6308
Crotalus horridus
Timber Rattlesnake
1935-06-28
H
4-Low
---
Special
G4
S3
Concern
Natural Areas Documented Within a One -mile Radius of the Project Area
Site Name Representaticnal Rsiang Collective Rating
FRB/North Toe River/Nolichucky River Aquatic Habitat R2 (Very High) C2 (Very High)
Managed Areas Documented Within a One -mile Radius of the Project Area
Managed Ares Name . .. I.. x Owaef .. " Owner Type
Mitchell County Open Space Mitchell County: multiple local government Local Government
Definitions and an explanation of status designations and codes can be found at bBR57L¢c¢hde_¢aNLeSa�estU� nt nVh Io. Data query generated on June 19, 2018: source: NCNHP, 02 April 2018. Please resubmit your
information request if more than one year elapses before project initiation as new information is continually added to the NCNHP database.
Page 2 of 3
14

NCNHDE-6287: United State Gypsum Co - Spruce Pine
June 19, 2018
Project Boundary Q Managed Area (MAREA)
Q Buffered Project Boundary
E] Natural Heritage Element Occurrence (NHEO)
C] NHP Natural Area (NHNA)
Page 3 of 3
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rR

Bennett, Bradley
From: Stepanian, Alexander <[e-mail]>
Sent: Tuesday, July 31, 2018 10:03 AM
To: Bennett, Bradley; Bolden, John
Subject: [External] RE: Permit Renewal for Stormwater NPDES permit NCS000202
Attachments: Stormwater Results for Analytical Monitoring 6-29-18.xls; 15-147drainagejune
2018Model (1).pdf
Bradley,
Sorry for the delay in following up with you on this. Please see highlighted responses below...
Thanks,
Alex Stepanian
Engineering / Loading Manager
United States Gypsum Company
Chamblee Plant
t [phone]
c: [phone]
From: Bennett, Bradley <[e-mail]>
Sent: Wednesday, June 20, 2018 4:26 PM
To: Bolden, John <[e-mail]>; Stepanian, Alexander <[e-mail]>; Kenyon, Randy P
<[e-mail]>
Subject: [EXTERNAL] Permit Renewal for Stormwater NPDES permit NCS000202
Hello, and first let me apologize for how long it has taken us to get going on your permit renewal. A number of issues
over the last few years have led to a backlog on renewal of our Individual permits. I would like to set up a time where I
can call and talk with you about the renewal. I will be working on this process. Since the previous renewal application
came in back in 2013 I'm guessing there may be some changes that we should discuss and possibly have documented for
the renewal. I also realize that there are a few unresolved monitoring issues from the last few years that we need to talk
about as well. In addition, here are a few additional items that would be helpful if you can provide updates:
• 1 have attached a printout of contacts we have in our database for the facility. Can you please review this and
let me know if there are changes to contacts and if the owner/facility information is still accurate? Contact
information is not accurate. Revising on the website and will have signed off this week.
• Federal regulations changed in the last few years to require electronic reporting of data. We are not yet at the
stage of being able to collect stormwater data this way, but we will have to work to get accurate outfall location
information in our system in order to meet federal requirements for electronic reporting when our systems can
handle the data. If you could provide the lat/long coordinates for your facility's outfall points that would be
helpful. All outfalls are located on the facility property which is located at 35.905519,-82.062718 according to
Iatlong.net

If you can provide a summary of monitoring information since your application submittal in December 2013 that
would be help as well. Please see attached results
I am very interested in any changes that may have occurred in your facility or processes since your application
submittal that could affect pollutants discharged in stormwater runoff. Processes at the plant remain
unchanged
If there have been changes, a new site map showing the most up to date layout of activities, outfalls and
drainage will be needed. Please see attached map
I work part time and I am generally in the office three days a week. Maybe we can find a day/time that works over the
next week or so to talk.
Thanks
Bradley Bennett
Stormwater Program
NC Division of Energy, Mineral & Land Resources Phone: [phone]
512 N. Salisbury Street Fax: [phone]
1612 Mail Service Center Email: bradley benneft(@,ncdenr.gov
Raleigh, NC 27699-1612
Email correspondence to and from this address may be subject to public records laws
Confidentiality Notice: This email is intended for the sole use of the intended
recipient(s) and may contain confidential, proprietary or privileged information.
If you are not the intended recipient, you are notified that any use, review,
dissemination, copying or action taken based on this message or its attachments,
if any, is prohibited. If you are not the intended recipient, please contact the
sender by reply email and destroy or delete all copies of the original message
and any attachments. Thank you.
Code:U5G45ty