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E�®6n A 7-F.LEVE`, INC. September 23, 2002 County of San Joaquin RAECENED Dept. of Environmental Health Division Mr. Doug Wilson SEP 2 7 2002 Supervisor Health Div. 304 East Weber ENVIROWEN T HEALTH Stockton, CA 95202 PERMIT/SERVICES Re: Proposed Petroleum Equipment Replacement Program Dear Mr. Wilson: As you know, 7 -Eleven, Inc. operates approximately 7 retail gasoline outlets in your jurisdiction. Pursuant to applicable regulatory requirements, 7 -Eleven has conducted tests of secondary containment systems at a number of our locations in California. Based on the results of these tests and our experiences in other states, 7 -Eleven has determined that certain equipment manufactured by Total Containment, Inc. ("TCI") has often been found not to meet regulatory requirements. Accoidingly, 7 - Eleven has decided to replace all TCI product lines that are currently in service in approximately 140 of our 7 -Eleven stores in California, including 7 locations in your jurisdiction. If necessary, 7 -Eleven will also replace TCI sumps and/or tanks at affected stores within your jurisdiction. For your convenience, Attachment A to this letter contains a list of affected stores located in your area. We propose to replace the subject TCI equipment at all of the affected locations by December 31, 2003. As part of this replacement program, we would ask for your authorization to accept 7 -Eleven's determination that TCI secondary containment equipment is generally testing at an unacceptably high failure rate, in lieu of requiring continued site by site testing, and to defer testing of the secondary containment systems at affected locations until such time as the new equipment is installed. 7 -Eleven wishes to be clear, however, that 7 -Eleven will test all of its double -walled tanks by the deadline. Furthermore, the selection and installation of all replacement equipment would conform with technical standards established by the U.S. Environmental Protection Agency and other applicable codes and 7 - Eleven will submit all required permit applications and obtain appropriate agency approvals to perform these upgrades. In addition, all of the affected facilities will be upgraded with Enhanced Vapor Recovery ("EVR") equipment at the time of the proposed replacements. We hope you will consider 7 -Eleven's proposal to comply with the intent of the applicable regulations. 7 -Eleven is prepared to discuss our proposal with you in detail and to enter into such agreements as may be appropriate. We believe that our proposed replacement program is both cost- effective and protective of public health and the environment and we are eager to discuss it with you. If you have any questions or direction, please contact Bob DeNinno, our Environmental Manager for 7 - Eleven stores in your area, at 208/429-8466 or me at 214/841-6592. Thank you for your cooperation.