NCS000202_Email Re USG Spruce Pine NC Permit_20180131

Georgoulias, Bethany
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.xls; 20130412140719856.pdf
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
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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 and attachments 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!
uss
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
<[e-mail]>
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.
USG
John Bolden
Manager, Environmental Projects
USG Corporation
t 312-436-5587

c 312-823-6702
From: Bolden, John
Sent: Thursday, December 14, 2017 1:46 PM
To: 'Pickle, Ken' <[e-mail]>
Cc: Price, David <[e-mail]>; Kenyon, Randy P <[e-mail]>; Stepanian, Alexander
<ASte p a n i s n@ u sg. co m>
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 TSS benchmark. 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 regarding the aluminum benchmark remains unchanged and
we request that NCDENR implement an administrative 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,
uss
John Bolden
Manager, Environmental Projects
USG Corporation
t 312-436-5587
c 312-823-6702
From: Pickle, Ken [mailto:[e-mail]]
Sent: Wednesday, May 08, 2013 9:24 AM
To: Bolden, John <[e-mail]>
Cc: Bennett, Bradley <bradley. ben [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.
o If so, then it seems to me 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.
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.
I think it has been reported that there was a relocation of sampling points, in order to properly
characterize the pollutant load leaving just 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 considering just 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. [e-mail]
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(a)usg corn]
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 IL, 60661
Ph: 312-436-5587
Fax: [phone]
Cell: 312-823-6702
From: Pickle, Ken [mai Ito: ken. pickleCa)ncdenr.gov]
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 DWQ Standards 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. If
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. [e-mail]
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(a)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.pickle(ancdenr.gov]
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 DWQto 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 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. [e-mail]
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: Ruddell, Randy K [mai Ito: RRuddelI(a)usc7 com]
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
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Code:USG45ty
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