7-Eleven Comments from June 25 th Workshop

7-Eleven, Inc.
July 10, 2014
Mr. William E Burns, Jr
Department of Environmental Protection
2600 Blair Stone Road
Tallahassee, FL 32399-2400
Re: 7-Eleven Comments for Chapter 62-761 DRAFT dated 6/17/14 Dear Mr. Burns: On behalf of 7-Eleven, Incorporated I would like to submit the attached comments for the revised DRAFT Chapter 62-761.430 Incidents and Chapter 62-761.700 Repairs, Operation and Maintenance. Thank you for considering my last comments in your new published Draft. Please contact me if you have any questions. Respectfully, Cathy Wise
Region Environmental Compliance Manager
7-Eleven Fuels Services, Inc.
Environmental Compliance Dept #0148
P.O. Box 711
Dallas, TX 75221
7-ELEVEN FUEL SERVICES, INC. / REGION GASOLINE ENVIRONMENTAL COMPLIANCE SERVICES /
P.O. BOX 711, DALLAS, TX 75221 PHONE #407-247-6750
Attachment 1
Chapter 62-761.430 (4) However, if the investigation goes beyond 45 days of the date of
discovery, the storage tank system shall be placed out-of-service until such time the
investigation is completed and resolved.
I suggest the 45 days be changed to 90 days. Dispenser/STP/Fill sumps and entry boots can be very
expensive and much planning is required for their repair/replacement. Replacement of all the entry
boots takes 5 days for a site with 6 or more dispensers to complete. Diversified boots need to be
specially ordered for each site and the parts can take another week or more to arrive.
Chapter 62-761.700(3)(a)1.e.
Double-walled spill containment systems within five years of (the effective date of the rule) and at intervals not exceeding every 12 months thereafter: f. Single-walled spill containment systems within one year of (the effective date of the rule) and at
intervals not exceeding every 12 month thereafter; and
7-Eleven’s Comment: First I would like to state that I agree with Marshal Mott-Smith, that both
double-walled and single-walled containment systems should have the same testing requirements.
Reason for the Comment: My reasons are the same as Marshall’s and I do not believe I need to
restate them but would like to ask for clarification/interpretation of the drafted rule for testing
double-walled spill containment systems.
The double-walled spill containment systems like the OPW Edge and the Emco Wheaton A1004 can
easily be vac tested. Annual testing for those containment devices should be no problem for
7-Eleven, Inc. On the other hand annual testing for the double-walled spill containment systems to
include Fibrelites (EQ#776) and OPW Multi-ports (EQ #558) will be expensive and onerous. They
are composed of a single-walled spill bucket contained in a sump that holds up to 300 gallons. The
approved test method for the fill sump is hydrostatic. Per the drafted regulation, are you mandating
the large fill sumps to be annually tested? They are part of the double-walled spill containment
system.
Your proposed draft does not single out the testing requirement for these fill sumps like the piping
and dispenser sumps. My suggestion is that you add another line under .700(3)(a)1.d. for the fill
sumps that states, “Below grade fill sumps within five years of (the effective date of the rule) and
every five years thereafter; I believe your intention is for the fill sumps be tested on the same
schedule as the STP and dispenser sumps. This added line would clarify it in the rule. If I’m not
mistaken, proposed 40 CFR has the testing schedule for all tank sumps grouped together.

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