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HomeMy WebLinkAboutNC0032867_Enforcement_20190625ROY COOPER Governor MICHAEL S. REGAN Secretory LINDA CULPEPPER Director Certified Mail # 7018 0360 0002 2099 1284 Return Receipt Requested Laeeq Khan, President Maliks International Inc 3425 Carmoustie Dr Chambersburg, PA 17202 NORTH CAROLINA Enotrotenotitt ! Qaitr!' June 25, 2019 SUBJECT: Notice of Violation and Assessment of Civil Penalty for Violations of North Carolina General Statute (G.S.: and NPDES WW Permit No, NC0032867 Maliks International. Inc Kings Mountain Travel Plaza Case No. MV-2019-0021. Cleveland County Dear Mr. Khan: 6) This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $1,162.46 (i,052.00 civil penalty + $110.46 enforcement costs) against. Maliks International Inc. This assessment is based upon the following facts: a review has been conducted of the Discharge Monitoring Report (DIM-R.) submitted by Maliks International Inc for the month of February 2019. This review has shown the subject faei to be in violation of the discharge limitations and/or monitoring requirements found in NPDES WW Permit No, NC0032867. The violations, which occurred in February 2019, are summarized in Attachment A to this letter. Based upon the above facts, I conclude as a matter of law that Maliks International Inc violated the terms, conditions or requirements of NPDES WW Permit No. NC0032867 and G.S. 143-215.1(a)6) in the manner and extent shown in Attachment A. In accordance with the maximums established by G.S. 1.43-215.6A(a)(2), a civil penalty may be assessed against any person who violates the teens,. conditions or requirements of a permit required by G.S. 143-215.1(a). D rtrnent of Elvrtsrarrtenta Que tp ( D unsoa of Water Resraw;rees Office ( 610 EsA Etta Ase ue„ Sulte 301 (MOW esv,Je, North Caao l to 28115 MN* Based'Clings of fact and conclusions of law, and in accordance with authority provided by the Secretary of the Department of Environmental Quality and the Director of the Division of Water Resources, I, W. Corey Basinger, Regional Supervisor, Mooresville Regional Office hereby make the following civil penalty assessment against Maliks International Inc: "1.50.00 for 2 of the 2 failures to properly monitor BOD, 5-Day (20 Dee. C) 7 Concentration in violation of Permit No. NC0032867. $140.00 for 2 of the .2 failures to properly monitor Chlorine, Total Residual in violation of 'Permit No. NC0032867. S168..00 for 2 ofthe 2 failures to properly monitor Coliform, Fecal , M1C Broth, 44.5 C in violation of Permit No. NC0032867. $0.00 for 0 of the 2 failures to properly monitor Flow in condut or Iry treatment plant in violation of Permit No. NC0032867, $ 5. .00 :for 2 of the 2 failures to properly monitor Nitroeen, Ammonia Total (as N) - Concentration in violation of Permit No. NC0032867. $2Q0.00 for 2 of the 2 failures to properly monitor Oil Si, Grease in violation of Permit No. NC0032867. $120.00 for 2 of the 2 failures to properly monitor pg: in violation of Permit No. NC0032867, $124.00 for 2 of the 2 failures to properly monitor Solids, Total Suspended - Concentration in violation of Permit No. NC0032867. $1,„052.00 TOTAL CIVIL PENALTY $110.46 Enforcement Costs U. 162..46 TOTAL AMOUNT DUE Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty 1, have taken into account the Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-282.1(b), which are: (1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property resulting from the violation; (2) The duration and gravity of the violation, (3) The effect on ground or surface water quantity or quality or on air quality; (4) The cost of rectifying the damage; (5) The amount of money saved by noncompliance; (6) Whether the violation was committed willfully or intentionally; (7) The prior record of the violator in complying or failing to comply with programs over which the Environmental Management Commission has regulatory authority; and (8) The cost to the State of the enforcement procedures. Within. thirty (30) days of receipt of this notice, you must do one of the following: (1) Submit payment of the penalty, OR (2) Submit a written request for remission, OR (3) Submit a written request for an administrative hearing Option 1: Submit payment of the penalty: Payment should be made directly to the order of the Department of Environmental. Quality (do not include waiver form). Payment of the penalty will. not foreclose further enforcement action for any continuing or new violation(s). Please submit payment to the attention of: Wastewater Branch Division of Water Resources 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Option 2: Submit a written request for remission or mitigation including a detailed justification for such request: Please be aware that a request for remission is limited to consideration of the five factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual statements contained in the civil penalty assessment document. Because a remission request forecloses the option of an administrative hearing, such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation and agreement that no factual or legal issues are in dispute. Please prepare a detailed statement that establishes why you believe the civil penalty should be remitted, arid submit it to the Division of Water Resources at the address listed below, In determining whether a remission request will be approved, the following factors shall be considered: ( I) whether one or more ofthe civil penalty assessment factors in NCGS 143B-282,1(h) was wrongfully applied to the detriment of the petitioner; (2) whether the violator promptly abated continuing environmental damage resulting from the violation; (3) whether the violation was inadvertent or a result of an accident; (4) whether the violator had been assessed civil penalties for any previous violations; or (5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions. Please note that all evidence presented in support of your request for remission must be submitted in writing, The Director of the Division of Water Resources will review your evidence and inform you of his decision in the matter of your remission request. The response will provide details regarding the case status, directions for payment, and provision for further appeal of the penalty to the Environmental Management Commission's Committee on Civil Penalty Remissions (Committee). Please be advised that the Committee cannot consider information that was not pan of the original remission request considered by the Director. Therefore, it is very important, that you prepare a complete and thorough statement in support of your request for remission. In order to request remissionou usto1eteanduitc1oseeueeon of Civil Penalties, Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form within thirty(30) days of receipt of this notice. The Division of Water Resources also requests that you complete and submit the enclosed "Justification for Remission Request." Both forms should be submitted to the following address: Wastewater Branch Division of Water Resources 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Option 3: File a petition for an administrative h arings with the Office of Administratve Hearines; If you wish to contest any statement in the attached assessment document you must tile a petition for an administrative hearing. You may obtain the petition form from the Office of Administrative Hearings. You must tile the petition with the Office of Administrative Hearings Within thirty (30) days of receipt of this notice. A petition is considered tiled when it is received in the Office of Administrative Hearings during normal office hours. The Office of Administrative Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m., except for official state holidays. The petition may be 'filed by facsimile (fax) or electronic mail by an attached file (with restrictions) - provided the signed original, one (1.) copy and a filing fee (if a filing fee is required by 'NCGS 5150B-23,2) is received in the Office of .Administrative Hearings within seven (7) business days following the faxed or electronic trans -mission. You should contact the Office of Administrative Hearings with all questions regarding the filing fee and/or the details of the tiling process. The mailing address and telephone and fax numbers for the Office of Administrative Hearings are as follows: 6714 Mail Service Center Raleigh, NC 27699 6714 Id: (919) 431-3000 Fax: (919)431-3100 One (1) cop y ofthe petition must also be served on DEO as follows: Mr. William F. Lane, General Counsel Department of Environmental Quality 1601 Mail Service Center Raleigh, North Carolina 27699-1601 Please indicate the case number (as found on page one of this letter) on the petition. Failure to exercise one of the options above within thirty (30) days of receipt of this letter, as evidenced by an internal date/time received stamp (not a postmark), will result in this matter being referred to the Attorney General's Office for collection of the penalty through a civil action. Please be advised that additional penalties may be assessed for violations that occur after the review period of this assessment. If you have any questions, please contact Ori Tuvia with the DilliSiort of Water Resources s Office at (704) 663.1699 or via email at ori tuvadncdenr.gov: AT1AC 1 1 SITS Sincerely, W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Mooresville Regional Office Division of Water Resources, NCDEQ Cc: WQS Mooresville Regional Office - Enforcement File NPDES Compliance Enforcement Unit - Enforcement File of the Mooresville Regional JUSTIFICATION FOR REMISS 0, REOUEST Case Number: MV-2019-0021 Assessed Party: Maliks International Inc Permit No.: NC0032867 County: Cleveland Amount Assessed: $1 16 .46 Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission, Waiver of Right to an Administrative Hearing, and Stipulation of Facts' form to request remission of this civil penalty. You should attach any documents that you believe support your request and are necessary for the Director to consider in evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper procedure for contesting .whether the violation(s) occurred or the accuracy of any of the factual statements contained in the civil penalty assessment document, Pursuant to N.C.G.S. § 143B-282.1(e), remission of a civil penalty may be granted only when one or more ofthe .following five factors apply. Please check each factor that you believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the factor applies (attach additional pages as needed). (a) one or more of the civil penalty assessment factors in N.C.G.S. 1.43B-282.1(b) were wrongfully applied to the detriment of the petitioner (the assessment actors are listed in the civil penalty assessment document); (b) the violator promptly abated continuing environmental damage resulting from the violation ,e„ explain the steps that you took to correct the violation and prevent future occurrences); (c) the violation was inadvertent or a result of an accident (Le., explain why the violation was unavoidable or something you could not prevent or prepare for); (d) the violator had not been assessed civil penalties for any previous violations; (e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions tie., explain. how payment oft -he civil penalty will .prevent you from performing the activities necessary to achieve compliance), EXPLANATION: STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY COUNTY OF CLEVELAND IN THE MATTER OF ASSESSMENT OF CIVIL PENALTIES AGAINST Ma!Ho International Inc Kings Mountain Travel Plaza PERMIT NO. NC0032867 WAIVER OF RIGHT TO AN ADMINISTRATIVE HEARING AND STIPULATION OF FACTS CASE NO. MV-2019-1021 Having been assessed civil penalties totaling $1,162.46 for violation(s) as set forth in the assessment document of the Division of Water Resources dated June 25, 2019, the undersigned, desiring to seek remission of the civil penalty, does hereby waive the right to an administrative hearing in the above -stated matter and does stipulate that the facts are as alleged in the assessment document. The undersigned further understands that all evidence presented in support of remission of this civil penalty must be submitted to the Director of the Division of Water Resources within thirty (30) days of receipt of the notice of assessment. No new evidence in support of a remission request will be allowed after (30) days from the receipt of the notice of assessment. This the day of 20 ADDRESS SIGNATURE TELEPHONE PERMIT: NC0032861 FACILITY: ings Moontain Travel; P aza ATTACHMENT A Maliks International Inc CASE U -2019-0021 REGION: Moo vine COUNTY: Cleve!and MONITORING VIOLATIONS) SAMPLE LOCATION: Outfalt 001 - Effluent Violation Report Date Month/Yr Parameter Unit of Limit Calculated % Over Violation Penalty Frequency Measure Value Value Limit Type Amount 2/2/2019 2-2019 BOD, 5-Day (20 Deg. Weekly C) - Concentration 2/9/2019 2-2019 BOD, 5-Day (20 Deg. Weekly C) - Concentration 2/2/2019 2-2019 Chlorine, Total Residual mg/1 mg/I 2 X week ugll 2/9/2019 2-2019 Chlorine, Total Residual 2/2/2019 2-2019 Coliform, Fecal MF, MFC Broth, 44.5 C 2 X week ugll Frequency $75.00 Violation Frequency $75.00 Violation Frequency $70.00 Violation Frequency Violation $70.00 Weekly #/100rn1 2/9/2019 2-2019 Colrf©rm, Fecal MF, Weekly MFC Broth, 44.5 C 2/212019 2-2019 Flow, in conduit or thru Weekly mgd treatment plant 2f9/2019 2-2019 Flow, in conduit or thru treatment plant Weekly Frequency Violation mgd Frequency Violation Frequency Violation Frequency Violation $84.00 $84.00 $0.00 $0,00 2/2/2019 2-2019 Nitrogen, Ammonia Weekly mg/1 Total (as N) - Concentration 2/9f2019 2-2019 Nitrogen, Ammonia Weekly mg/l Total (as N) - Concentra'tion 2/2/2019 2-2019 Oil & Grease 219/201 2-2019 Oil & Grease 2/2/2019 2-2019 pH Weekly eldy mg/l Weekly su 2/9/2019 2-2019 pH Weekly su Frequency Violation Frequency Violation Frequency Violation $75.00 $75.00 $100.00 Frequency Violation $100.00 Frequency Violation Frequency Violation $60.00 2/2/2019 2-2019 Solids, Total Suspended - Concentration Weekly mg/I 2/9/2019 2-2019 Solids, Total Weekly mg./I Suspended - Concentration Frequency Violation Frequency Violation $62,00 $62.00 DMR REVIEW RECORD Mooresville Regional Office Facility Name: Kings Mountain Travel Plaza Permit Number: NC0032867 Report Period: February 2019 Prior Assessments: 1 Enforcement Factor: 1,0U OutfaI # Outfall Description Waterbody Name Waterbody Classification 001 Effluent to Dixon Branch Dixon Branch Monitoring Frequency Violations Sample I...ocation: Outfall 001 Effluent Violation Date Parameter Frequency 2/2/2019 BOD, 5-Day (20 Deg. C) - Concentration Weekly Unit of Measure Action 2/9/2019 BOD, 5-Day (20 Deg. CI - Concentration Weekly mg/I 2/2/2019 Chlorine, Total Residual 2 X week ug/I 2/9/2019 Chlorine, Total Residual 2 X week ug/l 2/2/2019 Coliform, Fecal MF, MFC Broth, 44.5 C Weekly #/100m1 2+9/2019 Coliform, Fecal MF, MFC Broth, 44,5 C Weekly #/100m1 2+2/2.019 Flow, in conduit or thru treatment plant Weekly mgd 2/9/2019 Flow, in conduit or thru treatment plant Weekly mgd 2/2/2019 Nitrogen, Ammonia Total (as N) - Concentration Weekly mg/I 2/9/2019 Nitrogen, Ammonia Total (as N) - Concentration Weekly mg/I 2/2/2019 Oil & Grease Weekly mg/ 2/9/2019 Oil & Grease Weekly mg/I 2/212019 pH Weekly su 2/9/2019 pH Weekly su 2/22019 Solids, Total Suspended - Concentration Weekly mg/I 2/9/2019 Solids, Total Suspended Concentration Weekly mg/I Page 1 of 4 Other Viola n /Staff Remarks: o11 Supervimr Remarks: Coar plete l by: Assistant Regional Supervistar Sign -off: Regional al Stye riot Si off: a Page 2 of 4 Prior 12-:Month Enforcement History Per. t Number: NC0032867 Report Period: Febru Limit Violation Sarnple Location: Outtatl 001 - ftuent Violation Report Date Period Parameter Violation Type NOD NOV CPA 2/28/2018 2-2018 BOD, 5-Day (20 Deg. C) - Concentrati©n Sample Location: Outfall 002 - Effluent Monthly Average Exceeded NOV-2018-LV-0463 Violation Report Violation Date Period Parameter Type NOD 3/1/2018 3-2018 Solids, Total Suspended - Concentration Daily Maximum Exceeded NOV CPA NOV-2018-LV-0553 Other Violation Sample Location: Violation Report Violet' Date Period Parameter Type NOD NOV CPA 2/1/2018 Violation detected during inspection N©V-2018-PC-0'030 211 /2018 211/2018 Violation detected during inspection NOV-2018-PC-00 Violation detected during inspection NOV-2018-PC-0030 2/1/2018 Violation detected during inspection NOV-2018-PC-0030 8/8/2018 8/8/2018 802018 8/8/2018 Violation detected during inspection Violation detected during inspection N©V-2018-PC-0323 NOV-2018-PC-0323 Violation detected during inspection NOV-2018-PC •0323 Violation detected during inspection N©V-2018-PC-0323 8/8/2018 Violation detected during inspection N©V-2018-PC-0323 8/8/2018 Violation detected during inspection NOV-2018-PC-0323 1217/2018 Permit conditions violation NOV-2019-PC-0337 Page 3 of 4 Other Violation Sample Woe n Violation Report Date period Parameter Violation Type NOD NOV CPA 1/25 211p Violation detected curing inspe hen NOV- i119-P -00 8 PC-2019-0025 Page 4 of ROY COOPER 6ovrrnw MICHAEL S. REGAN dry. I.INDA CULPEPPE.R Certified Mail # 7018 0360 0002 2099 1239 Return Receipt Requested Laeeq Khan, President Maiiks International Inc 3425 Carmoustie Dr Chambersburg, PA 17202 NOR rH CAROL INA Err**rommntod Quality May 6, 2019 SUBJECT: NOTICE OF VI©LATION & INTENT TO ASSESS CIVIL PENALTY Tracking Number: NOV-2019-MV-0082 Permit No, NC0032867 Kings Mountain Travel Plaza Cleveland County Dear Mr. Khan. A review of the February 2019 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s) indicated below: Monitoringyiolation(s): Sample Location Parameter 001 Effluent BOD, 5-Day (20 Deg. C Concentration (C0310) Monitoring Date Frequency Type of Violation 2/2/2019 Weekly Frequency Violation 001 Effluent Chlorine, Total Residual (50060) 2/2/2019 2 X week Frequency Violation 001 Effluent Coliform, Feca MF, MFC Broth, 2/2/2019 Weekly Frequency Violation 44.5 C (31616) 001 Effluent Flow, in conduit or thru treatment 2/2/2019 Weekly Frequency Violation plant (50050) 01 Effluent Nitrogen, Ammonia Total (as N) - 2/2/2019 Weekly Frequency Violation Concentration (C0610) 001 Effluent Oil & Grease (00556) 2/2/2019 Weekly Frequency Violation 001 Effluent pH (00400) 2/2/2019 Weekly Frequency Violation Monitoring Violation(s): Sample Location Parameter Monitoring Date Frequency Type of Violation 001 Effluent Solids, Total Suspended - Concentration (C0530) 2/2/2019 Weekly Frequency Violation 001 Effluent BOD, 5-Day (20 Deg. C) - 2/9/2019 Weekly Frequency Violation Concentration (C0310) 001 Effluent Chlorine, Total Residual (50060) 2/9/2019 2 X week Frequency Violation 001 Effluent Coliform, Fecal MF, MFC Broth, 2/9/2019 Weekly Frequency Violation 44.5 C (31616) 001 Effluent Flow, in conduit or thru treatment 2/9/2019 Weekly Frequency Violation plant (50050) 001 Effluent Nitrogen, Ammonia Total (as N) - 2/9/2019 Weekly Frequency Violation Concentration (C0610) 001 Effluent Oil & Grease (00556) 2/9/2019 Weekly Frequency Violation 001 Effluent pH (00400) 2/9/2019 Weekly Frequency Violation 001 Effluent Solids, Total Suspended - Concentration (C0530) 2/9/2019 Weekly Frequency Violation A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) 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. If you wish to provide additional information regarding the noted violation, request technical assistance, or discuss overall compliance please respond in writing within ten (10) business days after receipt of this Notice. A review of your response will be considered along with any inforrnation provided on the submitted Monitoring Report(s), You will then be notified of any civil penalties that may be assessed regarding the violations. If no response is received in this Office within the 10-day period, a civil penalty assessment may be prepared. Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent, Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or potential problems due to planned maintenance activities, taking units off-line, etc. tio k: Deps, of E evtv Q4", Ay vS=Vr, cif R*,sou,c4s ?,,*zrl* R.„44 44,, nit fo!; 610 E C.M.r A. V.410: Sqa 3OL P�.,4etA-4 No Zal 70441:63 -169 I you have any questions concerning this matter or to apply for an SOC, plea contact Ori Tuvia of the ooresville Regional Office at 704-663-1699: Sincerely, DocuSignedby: Al4CC681AF27425 W. Corey Basinger, Regiona SUperVi Water Quality Regional Operations on Mooresville Regional Office Division of Water Resources, NCDEQ WQS Mooresville Regional Office - Enforcement File NPDES Compliance/Enforcement Unit - Enforcement File U.S. Postal Service" CERTIFIED MAIL' RECEIPT Domestic Mail Only SENDER: COMPLETE TH t. P MARKS INTERNATIONAL INC. 3425 CAIRMODUSTIE DRIVE Clt'AM9ERSa3CKG PA 17202 T N: LALECI KHAN, PRESIDENT dwr/o 5/6/19 MARKS INTERNATIONAL INC. 3425 CAf2MOUST) E DRIVE CHAMBERSBURG PA 17202 AYTN: mAEEQ KHAN, PRESIDENT 516/ 19 11 0) 8 0 l02 2099 12 July 20 N 7 q-02-C 'LIVERY DIVISION OF "WATER RESOI.RCES - CWII. PENALTYASSESSMENT Violator: Maliks International Inc Facility Name: Kings Mountain Travel PI Permit Number: NC0032867 County: Cleveland Case Number: MV-2(}I9-002.1 ASSESSMENT FACTORS 1) The degree and extent of harm to the natural resoure property resulting from the violation; Alva- ,ae 2) The duration and g ; 0 h+e violation; of the State, to the public health, or to private ,F it, . ,r `t t,'--CS 1 ,r F;.,.�fi ✓Tr`++r-,l -. 8 to 4-6 fILRw" tor /_ ere 3) The effect on ground or surface water quantity or quality or on air quality;. 4) The cost of rec tr ing the damage; 114 5) The a nount of money saved by noncompliance; 6) Whether the violation was committed illfbtly or intentionally; r..4"- b9,c, .L j' 7 The prior record of the violator i o plying or failing to comply ith program +Per which the Environmental Management Commission has regulatory authority; and February 1 2018 - I OV-2918-FCC- 939, Inspection Violations August 8, 2018 - N '-2918-P d9323x Inspection Violations Deco r 2018 — N V®2 19- V-0329, TSS It violation/ Enforcement January 2 19 N V 2019-MV-0929, 'lonitar n frequency violations,' Enforcer rrent 8) The cost to the a e of the enf rrcn ent procedures St 10.46 Enforcement Cost 1 Maur staff time.... hour supervisor time Administrative /CO staff cost.. Total enforce 37.74 7.72 15.00 ent cost $ 110.46 ger, Regional Superviso Water Quality Regional Operations Section Mooresville Regional Office Division of Water Resources, N IW U.S. Postal Service' CERTIFIED MAIL' RECEIPT Domestic Mali Only Fttr clel'very intomiatle MALIKS INTERNATIONAL INC. 3425 CARMOUSTIE ©RIVE CHAMBERSBURG PA 17202 ATTN: LAEEQ KHAN dwr/ot 6 '2 Ps SENDER: WPLETE THIS SECTION ALIK5 INTERNATIONAL INC, 3425 CARMOUSTIE ©RIVE CHAMBERSBURG PA 17202 ATTN LAEEQ KHAN dwr/ot 6/26/19 2-003-91)47 Soe Reverse fur Instructi COMP F re ON DELIVERY