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Item 4: During your inspection you observed liquid in the 87 turbine sump. According to your inspection report you requested that 7-Eleven ensure all sumps are maintained free of liquid. Resolution 4: The liquid was removed by Tanknology at the time of the inspection. As stated in my 11/4/2015 response letter, 7-Eleven believes this violation to have been written in error. In this instance, the underground storage tanks were installed on April of 1998. UST systems installed prior to 7/1/2003 were not designed or constructed to prevent the intrusion of water into portions of the secondary systems. These systems were designed and constructed to contain liquid or debris until discovered so that the liquid and debris could be managed and disposed of properly. Section 25291(e) of the California Health and Safety Code, which was noted on the inspection report, and Title 23 of the California Code of Regulations acknowledge this exception. Specifically,these provisions state: California Health and Safety Code—25291(e): "If water could enter into the secondary containment by precipitation or infiltration, the facility shall contain a means of monitoring for water intrusion and for removing the water by the owner or operator. This removal system shall also prevent uncontrolled removal of this water and provide for a means of analyzing the removed water for hazardous substance contamination and a means of disposing of the water, if so contaminated, at an authorized disposal facility. " Title 23, California Code of Regulations, Chapter 16—2631(d)(4): "The secondary containment system shall be equipped with a collection system to accumulate, temporarily store, and permit removal of any liquid within the system. " In this instance, since the underground storage tanks were installed on April of 1998 they are regulated by Section 25291(e) of the California Health and Safety Code and Title 23 of the California Code of Regulations and it is not a violation for liquid to be observed in the turbine sump. This letter should address the item(s) noted on the Inspection Report. 7-Eleven assumes that all issues regarding this report have been resolved and are closed. The submittal of this response by 7-Eleven, Inc. shall not constitute, nor be deemed to constitute, an admission of liability or responsibility with respect to the alleged violations and, in addition, evidence of this settlement may not be used in any administrative or judicial proceeding or otherwise. Very truly yours, 7-Eleven, Inc. A"y„ Stephen Boyd Region Gasoline Environmental Compliance Manager Enclosures: Test report and RTC form 7-Eleven,Inc. P.O.Box 711—Dallas,Texas 75221-0711