NC0087912_Plan of Action_20241101

1125 East Morehead Street,Suite#104
Charlotte,NC 28204
office 980.585.1271
Mid Atlantic facsimile LINE.5.1272
MAAONINE.CO
November 1, 2024
Joe R. Corporon, P.G.
North Carolina Division of Water Resources
Raleigh Regional Office—Attn: NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Site Management Practices and Spill Response Plan
Speedway#6973
13960 Capital Boulevard
Youngsville, North Carolina
NPDES Permit No.: NCO087912
Dear Mr. Corporon,
On behalf of Speedway, LLC (Speedway), and in compliance with Section A.(2.) of their National
Pollutant Discharge Elimination System (NPDES) Permit No. NC0087912, Mid-Atlantic
Associates, Inc. (Mid-Atlantic) has prepared this Site Management Practices and Spill Response
Plan (MPSRP). The objective of this plan is to outline the strategies and procedures implemented
at the site to minimize the generation and discharge of wastewater at the diesel dispenser islands,
and to ensure swift and effective response to fuel spills, thereby protecting the environment.
Site Management Practices
The following practices are currently implemented or will be carried out to reduce both the quantity
and contamination level of wastewater generated at the diesel fuel islands, which is ultimately
treated and discharged:
1. Canopy Coverage: The diesel dispenser islands are shielded by a canopy to reduce
exposure to rainfall, thereby minimizing the amount of contaminated runoff.
2. Drainage System: A frame and grate system, connected to a grit separator and oil/water
separator, has been installed to limit stormwater infiltration into the wastewater system.
3. Spill Kits and Dry Absorbents: The facility is equipped with spill kits and dry absorbents,
maintained in accessible locations as per Speedway personnel guidelines.
4. Spill Response: Spills or leaks resulting from vehicle fueling operations are promptly
cleaned using dry absorbents to prevent contamination.
5. Break-Away Hoses: Dispensers are fitted with "break-away" hoses to prevent fuel spills
caused by vehicles driving off with the nozzle still attached.
ENVIRONMENTAL DUE DILIGENCE BROWNFIELDS STORMWATER INDUSTRIAL HYGIENE

Site Management Practices and Spill Response Plan November 1, 2024
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Youngsville, North Carolina
6. Routine Inspections: Regular inspections of the diesel dispenser islands, collection
system, and oil/water separator are conducted by the designated Operator-in-
Responsible-Charge (ORC) or their backup.
7. Periodic Pumping: The oil/water separator is periodically pumped out to maintain
adequate capacity and functionality.
Spill Response Procedures
To effectively manage and mitigate fuel spills at the site, the following procedures will be executed:
1. Immediate Cleanup: Minor spills and leaks during vehicle fueling are addressed
immediately using dry absorbents.
2. Source Control: The source of the spill will be quickly identified and secured, whether by
shutting down or disconnecting the fuel source.
3. Containment: In cases where a spill surpasses the capacity of the frame and grate
system, immediate action will be taken to prevent the spread of fuel. This includes isolating
the downgradient storm drain located in the southeastern corner of the site to prevent fuel
from entering the drainage system. Containment measures may include the use of spill
booms, absorbent pillows, or oil-dry dams.
Notification and Reporting: The on-site Speedway employee will contact the Operations
24/7 Speedway Store Support Center. The Store Support Center is responsible for alerting
the appropriate emergency response teams who will report the spill to relevant
government agencies.
Evaluation, Inspection, and Monitoring of the Oil/Water Separator
The oil/water separator is a critical component of the spill containment and wastewater treatment
system at the site. Proper evaluations and inspections are essential to ensure its effective
operation and to prevent environmental contamination. This section outlines the procedures for
evaluating and inspecting the oil/water separator.
Evaluation
Initial Evaluation:
• Purpose: To assess the current condition and performance of the oil/water separator
and to establish a baseline for future inspections and maintenance.
• Procedure:
o Conduct a visual inspection of accessible exterior portions of the separator to
check for signs of wear, damage, or corrosion.
o Evaluate the separator's efficiency by testing the quality of the treated water
exiting the unit. This can be done by collecting samples and analyzing them for
oil content and other contaminants.
o Review the manufacturer's specifications and maintenance history to ensure
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Site Management Practices and Spill Response Plan November 1, 2024
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Youngsville, North Carolina
the separator is operating within its designed parameter
Performance Evaluation:
• Purpose: To regularly assess the operational efficiency of the oil/water separator to
ensure it is effectively removing oil and other contaminants from wastewater.
• Procedure:
o Monitor the quality of the effluent by conducting periodic water quality tests.
These tests should measure oil concentration, total suspended solids
(TSS), and other relevant parameters.
o Compare the results against regulatory standards and manufacturer
specifications to determine if the separator is performing adequately.
o If performance issues are detected, conduct a detailed assessment to
identify the root cause and implement corrective actions.
• Frequency: Quarterly, or more frequently if required by local regulations or if previous
evaluations have indicated potential issues.
Inspections:
Routine Inspections:
• Purpose: To detect early signs of problems and ensure the separator is functioning
correctly.
• Procedure:
o Visually inspect the oil/water separator for signs of leaks, cracks, or other
damage.
o Check the oil level in the separator and ensure it is within the acceptable
range.
o Inspect the inlet and outlet pipes for blockages or buildup of materials that
could impede flow.
o Verify that control panels, alarms, and monitoring devices are operational,
if applicable.
• Frequency: Monthly, with additional inspections following heavy rainfall or a
significant spill event.
Detailed Inspections:
• Purpose: To conduct a comprehensive examination of the separator, including
internal components that may not be visible during routine exterior inspections.
• Procedure:
o Shut down the separator and remove accumulated oil and
sludge according to manufacturer guidelines and environmental
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Site Management Practices and Spill Response Plan November 1, 2024
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regulations.
o Inspect the internal baffles, plates, and coalescing media for signs of wear,
fouling, or damage.
o Clean the separator's internal components as necessary to maintain
efficiency.
o Inspect seals and gaskets and replace them if signs of deterioration are
observed.
• Frequency: Biannually or as recommended by the manufacturer.
Manual Monitoring:
• Purpose: To provide a hands-on assessment of the separator's performance.
• Procedure:
o Manually check the oil/water separator's effluent quality by taking samples
and visually inspecting them for signs of oil contamination.
o Record the oil levels in the separator and compare them with historical data
to identify unusual trends.
• Frequency: Biannually, with additional checks following significant operational
changes or spill events.
We trust that this plan meets the requirements outlined in Section A.(2.) of Speedway's NPDES
Permit for the Youngsville facility. Should you have questions or require further information,
please do not hesitate to contact us at [phone].
Sincerely,
MID-ATLANTIC ASSOCIATES, INC.
Itt., s .�
Cameron D. Moore, P.G. Raymond S. Marchant, III, P.G.
Project Geologist Principal Geologist
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Emergency Spill Response Numbers
Speedway#6973
13960 Capital Bouleavrd
Youngsville, North Carolina
Mid-Atlantic Project No.: R1464.01
Title Name Telephone Number
Store Operations Support Center Not Applicable 800-643-1948
7-1 1/Speedway Emergency Coordinator Mr. Andy McMillan 919-268-7176
Operators-in-Responsible-Charge (ORCs) Mr. Gary Fischer 919-614-9745
Back-up ORC Mr. Cameron Moore 704-230-0859
Local Fire Department Town of Youngsville Fire Department 911
Local EMC or Response Team Franklin County EMS 911