NCG510539_PC-2020-0422 Response_20200805

1::)DUNCKLEE
& DUNHAM
VIA EMAIL TO: [e-mail]
August 5, 2020
Mr. Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
450 West Hanes Mill Road, Suite 300
Winston-Salem, North Carolina 27105
ENVIRONMENTAL GEOLOGISTS & ENGINEERS
511 KEISLER DRIVE - SUITE 102
CARY, NORTH CAROLINA 27518
OFFICE: [phone]
W W W DUNCKI,EEDIJNHAM.COM
Reference: Response to Notice of Deficiency (NOD-2020-PC-0422)
Mail Contractors of America, Inc.
717 Camann Street
Greensboro, Guilford County, North Carolina
Certificate of Coverage: NCG510539
Dear Mr. Snider:
NC Department of
Environmental Quality
Received
AUG 10 2020
Winston-Salem
Regional office
Duncklee & Dunham, P.C. (Duncklee & Dunham), on behalf of Mail Contractors of America, Inc.,
(MCA), submits this response to the Notice of Deficiency (NOD) issued by the Division of Water
Resources (DWR) of the North Carolina Department of Environmental Quality (NCDEQ). MCA
currently operates a groundwater remediation system under NC General Wastewater Permit NCG510000
(Certificate of Coverage: NCG510539). The DWR issued the NOD on July 28, 2020, following a July
10, 2020, inspection of the facility. This letter addresses each of the findings presented in the NOD with
the facility's initiated or planned corrective action response.
L Finding: At the time of the inspection, the 2019 permit fee had not been paid. The payment
was due on September 9, 2019. Please pay this past due amount and ensure in the future that the
permit fees are paid in a timely manner.
Response: Duncklee & Dunham made the permit holder aware of the past due amount and
the past due invoice payment was mailed to the DWR on July 28, 2020.
DUNCKLEE & DUNHAM, P.C.

Response to Notice of Deficiency
Mail Contractors of America, Inc.
Greensboro, North Carolina
August 5, 2020
Page 2 of 2
2. Finding: Additionally, there were three permit limit exceedances noted in the quarterly
effluent results table. Total suspended solids (31 mg/L) slightly exceeded the permit limit of 30 mg/L in
August 2018. Naphthalene exceeded the permit limit of 12 ug/L in August 2016 (23 ug/L) and October 2016
(22 ug/L). No other exceedances were noted. Please continue to monitor these constituents and note any
future exceedances.
Response: Duncklee & Dunham monitors the effluent for flow and pH. We collect a sample
of the effluent and have it tested for total suspended solids and naphthalene by an independent analytical
laboratory. We monitor the effluent on a quarterly basis in accordance with the permit requirements. We
provide the facility a copy of our monitoring results and a copy of the analytical laboratory report. We
will continue to monitor these constituents and work with the owner to notify the WSRO of a permit limit
exceedance within 24 hours of our receipt of laboratory analytical data which indicates an exceedance of
a permit limit.
3. Finding: Part II, E. 6. of the permit requires that an exceedance of any permit limitation must
be reported within 24 hours from the time the permittee becomes aware of the condition. The WSRO was not
notified of the exceedances listed above. If these exceedances occur again, please ensure that the
WSRO is notified within 24 hours.
Response: Duncklee & Dunham will work with the owner to notify the WSRO of a permit
limit exceedance within 24 hours of our receipt of laboratory analytical data which indicates an
exceedance of a permit limit.
We trust that the actions implemented by Duncklee & Dunham and MCA address the deficiencies
presented in the NOD. Please contact us at [phone] or via e-mail at colin @dunckleedunham.com
if you have any questions or comments regarding this response.
Sincerely,
Duncklee & Dunham, P.C.
Colin C. arraway,] G.I.T.
Staff Geologist
ec: Jim Salmon
Jim Gonsiewski, NCDEQ — WSRO
P:HMCA\201313 - GreensboroWischage Pemdt\CorrespondenceWOD Response Letter- 20571.doc.
Senior Peer Review:
Thomas S. Dunham, L.G.
Senior Geologist