NC0032867_CEI_NOV2020PC0073_20200204

ROY COOPER
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MICHAEL S. RECAN
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5. DANIEL SMITH
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NORTH CAROLINA
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5 February 2020
CERTIFIED MAIL # 7018 0360 0002 2099 1543
RETURN RECEIPT REQUESTED
Laeeq Khan, President
Malik's International, Inc.
3425 Carnoustie Drive
Chambersburg, PA 17202
Subject: Notice of Continuing Violation and Recommendation for Enforcement
NOV-2020-PC-0073
Kings Mountain Travel Plaza WWTP
NPDES Permit NCO032867
Cleveland County
Dear Mr. Khan:
Enclosed please find the Compliance Evaluation Inspection report for the inspection conducted on January
28, 2020, by Ori Tuvia. The cooperation of your system operators Daniel Dougherty and Ron Haynes during the
site visit was much appreciated.
Previous inspection dated August 8, 2018, resulted in the issuance of a Notice of Violation (NOV-2018-
PC-0323 dated August 15, 2018). The following violations noted during the previous inspection have not been
resolved and require immediate attention:
In accordance with Part II, Section C.2 of the subject permit, proper Operation and Maintenance
(O&M) of the WWTP is required. The following treatment units/equipment/components are listed
in the permit and were found to be non -operational at the time of the inspection and need to be
addressed:
• Two septic tanks were not operational, leaking, and not piped nor valved. The two septic
tanks must be properly sealed to avoid leaching wastewater to the ground and properly piped
so they can be used as indicated in the permit.
• The facility has two (2) permitted aeration basins: Only one of the aeration basins was
operational. The second aeration basin had no blowers and was being used as a sludge
storage tank. Additionally, the aeration basin grating was insufficient. Grating should be
properly installed to ensure the safety of the ORC/operators and DWR staff (image 2).
State of North Carolina I Environmental Quality I Water Resources I Water Quality Regional Operations
Mooresville Regional Office 1 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115
704 663 1699

• The ORC indicated that the aerobic digester and a holding tank may be leaking. The tanks
should be tested for leaks and if found to be leaking they should be immediately repaired and
properly maintained.
• At the time of the inspection, the flow meter chart recorder was not operational.
In addition to the previously observed continuing violations, the following maintenance issues were
observed and require immediate action:
• At the time of the inspection, the flow meter was not operational. The flow meter censor was
underwater and not operational (see image 1). The flow meter is a permitted treatment
component listed in the permit.
• There are several concerns regarding Outfall 002:
o It is not clear what path the discharge line takes once it leaves the oil grease separator
until it reaches the effluent pipe;
o At the time of the inspection, the oil grease separator needed to be pumped out (and
properly disposed);
o Connecting pipes to the oil grease separator need to be cleaned out as they were
observed to have a build-up of sludge (Image 3) .
An additional issue documented at the time of the inspection was that Mr. Ron Haynes has been operating
the plant without being officially designated as an ORC or Backup ORC. All personnel that operate the wastewater
treatment system must be officially designated for the system. You may designate more than one Backup ORC.
A Notice of Violation and Notice of Recommendation for Enforcement, pursuant to G.S. 143-215.6A,
may result in a civil penalty of not more than twenty-five thousand dollars ($25,000.00) per day, per violation
and may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or
requirements of any permit issued pursuant to G.S. 143-215.1. You are requested to respond to this Notice in
writing within ten (10) days of receipt indicating your Plan of Action to ensure future compliance.
The report should be self-explanatory; however, should you have any questions concerning this report,
please do not hesitate to contact Ori Tuvia at [phone], or at ori.tuviakncdenr.gov.
Sincerely,
DocuSigned by:
A14CC681 AF27425...
W. Corey Basinger
Regional Supervisor
Mooresville Regional Office
Division of Water Resources
Attachment: CEI report
Cc: Ron Haynes (E-copy)
MRO Files (Laserfiche)

Image 1. Broken flow meter Image 2. Unsafe grating aeration basin 2
Image 3. Cleanout part of outfall 002 full black substance

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 2 15 1 3 I NCO032867 111 12 I 20/01/28 I17 18 I S I 19 I G I 201 I
211111 I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I f6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating 131 QA ---------------------- Reserved -------------------
67
2.0 70 71 [.. I 72 73 L_LJ74 751 I I I I I I I80
u u
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES oermit Number)
01:50PM 20/01/28
18/09/01
Kings Mountain Travel Plaza
400 Dixon School Rd
Exit Time/Date
Permit Expiration Date
Kings Mountain NC 28086
04:15PM 20/01/28
23/08/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Daniel James Dougherty/ORC/704-477-5514/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Dan Dougherty, /ORC/704-477-5514/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
DocuSigned by:
Ori ATuvia DWR/MRO WQ/704-663-1699/ 2/5/2020
i
EBB057A2DE017498...
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
W. Corey Basinger DWR/Division of Water Quality/704-235-2194/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
DocuSigned by:
A14CC681AF27425...
2/5/2020
Page#

NPDES yr/mo/day Inspection Type (Cont.)
NCO032867 I11 121 20/01/28 117 18 ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
New permit effective June 22, 2018 lists the following treatment components: Two septic tanks with
piping and valves, two aeration basins each equipped with two positive displacement blowers, an
aerobic digester, a holding tank, and One flow measuring system comprised of a 22-1/2-degree
V-notch weir and Flow Meter with totalizer and chart recorder. At the time of the inspection: Two septic
tanks were non -operational, leaking, not piped, nor valved. The two septic tanks must be properly
sealed to avoid leaching wastewater to the ground, and piped so they can be used as indicated in the
permit. The facility has two (2) permitted aeration basins: Only one of the aeration basins was
operational, the second basin had no blowers and was used as a storage tank to store sludge.
Additionally, the aeration basin grating was insufficient, floor grating should be properly installed to
ensure the safety of the ORC/operators and DWR staff. The ORC indicated that the aerobic digester
and a holding tank may be leaking. The tanks should be tested for leaking and if found to be leaking
they should be fixed and properly maintained. At the time of the inspection the flow meter was not
operational. flow meter censor was underwater. Properly operating flow meter is needed to determine
the discharge from the treatment plant.
Page#

Permit: NCO032867 Owner - Facility: Kings Mountain Travel Plaza
Inspection Date: 01/28/2020 Inspection Type: Compliance Evaluation
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
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0
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application?
Is the facility as described in the permit?
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0
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# Are there any special conditions for the permit?
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0
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Is access to the plant site restricted to the general public?
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Is the inspector granted access to all areas for inspection?
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Comment: See Summary.
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
0
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Is all required information readily available, complete and current?
0
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Are all records maintained for 3 years (lab. reg. required 5 years)?
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0
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Are analytical results consistent with data reported on DMRs?
0
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Is the chain -of -custody complete?
0
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Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported CM
Are DMRs complete: do they include all permit parameters?
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Has the facility submitted its annual compliance report to users and DWQ?
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(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
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on each shift?
Is the ORC visitation log available and current?
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Is the ORC certified at grade equal to or higher than the facility classification?
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Is the backup operator certified at one grade less or greater than the facility classification?
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Is a copy of the current NPDES permit available on site?
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Facility has copy of previous year's Annual Report on file for review?
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Page# 3

Permit: NCO032867
Inspection Date: 01/28/2020
Record Keeping
Owner - Facility: Kings Mountain Travel Plaza
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: Missina records for the period of Auaust 2014 - Auaust 2017. were addressed durina a
previous inspection under NOV-2018-PC-0030. Records reviewed for September 2019 -
December 2019 were complete and well maintained. As was discussed in a previous
meeting, it is the responsibility of the permitee, not the ORC, to maintain all permit related
documents. Mr. Ron Haynes has been operating the plant without being officially designated
as an ORC or Backup ORC. All personnel that operate the wastewater treatment system
must be officially designated for the system (you can designate more than one Backup
ORC).
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
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0
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Is sample collected below all treatment units?
0
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Is proper volume collected?
E
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Is the tubing clean?
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0
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# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
0
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Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
0
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representative)?
Comment: The subject permit requires effluent grab sampling.
Laboratory
Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
0
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Are all other parameters(excluding field parameters) performed by a certified lab?
0
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# Is the facility using a contract lab?
0
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# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
0
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Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
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0
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Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
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0
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Comment: Water Tech Labs has been contracted to perform lab sa
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ❑ 0 ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: The facility must have all treatment units listed in the permit maintained and operational.
Septic Tank Yes No NA NE
Page# 4

Permit: NCO032867
Inspection Date: 01/28/2020
Owner - Facility: Kings Mountain Travel Plaza
Inspection Type: Compliance Evaluation
Septic Tank
Yes No NA NE
(If pumps are used) Is an audible and visual alarm operational?
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0
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Is septic tank pumped on a schedule?
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0
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Are pumps or syphons operating properly?
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0
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Are high and low water alarms operating properly?
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N
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Comment: Two septic tanks were non -operational, leaking, not piped, nor valved.
Aeration Basins
Yes No NA NE
Mode of operation
Ext. Air
Type of aeration system
Fixed
Is the basin free of dead spots?
S
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Are surface aerators and mixers operational?
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0
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Are the diffusers operational?
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0
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Is the foam the proper color for the treatment process?
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0
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Does the foam cover less than 25% of the basin's surface?
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0
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Is the DO level acceptable?
0
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Is the DO level acceptable?(1.0 to 3.0 mg/1)
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0
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Comment: Only one of the two permitted aeration basins was operational. The second aeration basin is
used for storing sludge, and has no operational blowers (two permitted).
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
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Is flow meter calibrated annually?
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Is the flow meter operational?
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(If units are separated) Does the chart recorder match the flow meter?
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0
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Comment: At the time of the inspection the flow meter was not operational.
Flow meter censor was
underwater and not operational. In addition, the flow meter chart recorder was not
operational (as indicated in previous inspection)
Disinfection -Tablet
Yes No NA NE
Are tablet chlorinators operational?
0
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Are the tablets the proper size and type?
0
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Number of tubes in use?
2
Is the level of chlorine residual acceptable?
0
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Is the contact chamber free of growth, or sludge buildup?
0
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Is there chlorine residual prior to de -chlorination?
0
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Page# 5

Permit: NCO032867 Owner - Facility: Kings Mountain Travel Plaza
Inspection Date: 01/28/2020 Inspection Type: Compliance Evaluation
Disinfection -Tablet Yes No NA NE
Comment:
De -chlorination Yes No NA NE
Type of system ? Tablet
Is the feed ratio proportional to chlorine amount (1 to 1)? 0 ❑ ❑ ❑
Is storage appropriate for cylinders? S ❑ ❑ ❑
# Is de -chlorination substance stored away from chlorine containers? ❑ ❑ ❑
Comment:
Are the tablets the proper size and type? 0 ❑ ❑ ❑
Are tablet de -chlorinators operational? 0 ❑ ❑ ❑
Number of tubes in use? 2
Comment:
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
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0
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Are the receiving water free of foam other than trace amounts and other debris?
0
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If effluent (diffuser pipes are required) are they operating properly?
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0
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Comment: Right of way to outfall 001 was well maintained. It still not clear the path discharge takes
once it leaves the oil grease separator until it reaches outfall 002.
Standby Power
Is automatically activated standby power available?
Is the generator tested by interrupting primary power source?
Is the generator tested under load?
Was generator tested & operational during the inspection?
Do the generator(s) have adequate capacity to operate the entire wastewater site?
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
Is the generator fuel level monitored?
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Comment: Facility staff indicated that power outlets do not work properly and light is needed for night
operation
Solids Handling Equipment
Is the equipment operational?
Is the chemical feed equipment operational?
Yes No NA NE
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Page# 6

Permit: NC0032867
Inspection Date: 01/28/2020
Solids Handling Equipment
Owner - Facility: Kings Mountain Travel Plaza
Inspection Type: Compliance Evaluation
Yes No NA NE
Is storage adequate?
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Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
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0
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Is the site free of sludge buildup on belts and/or rollers of filter press?
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0
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Is the site free of excessive moisture in belt filter press sludge cake?
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0
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The facility has an approved sludge management plan?
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0
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Comment: Sludge holding tanks were not being used at the time of the inspection. Facility
staff
indicated that additional study of the sludge holding tank is needed as it may be leaking.
Page# 7