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Resolution 3: The current response plan was on site for review in electronic format in the 7- Eleven Efile Cabinet. Also, a copy of the current response plan was confirmed to be on site by the stores assigned Designated Operator on 9/7/2016. Item 4: During your inspection you were unable to locate the Designated Operator inspections for 2016. Resolution 4: Copies of these inspections were on site in the white binder. Copies of the inspection reports are also attached for your records. Item 5: During your inspection you observed a union leaking inside of dispenser 1/2. Resolution 5: On 9/21/2016 Walton Engineering was on site to address the leaking union, but the technician was unable to locate any leaking unions within the dispenser. As a precaution, the technician tightened vapor adaptors and piping. A copy of the work order is attached for your records. Item 6: During your inspection you observed liquid in the STP sump, and the 87 and 91 fill sumps. According to your inspection report you requested that we ensure all sumps are maintained free of liquid. You also noted that this is a repeat violation. Resolution 6: The liquid was removed by Tanknology at the time of the inspection. As stated in my 11/4/2015 and 11/12/2014 response letters, 7-Eleven believes this violation to have been written in error. In this instance, the underground storage tanks were installed on 6/23/2003. 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. " RECEIVED OCT 14 2016 7-Eleven,Inc. ENVIRONMENTAL HEALTH P.O.Box 711—Dallas,Texas 75221-071 l DEPARTMENT