At least one situation comes to mind where it might happen: If I wanted to publish a collection of HOWTOs, e.g., from the LDP. If every one of them included front and back cover texts, that'd be a mountain.
There is no difficulty at all here. This collection would be an aggregate, and here's what the GFDL says about that: If the Cover Text requirement of section 3 is applicable to these copies of the Document, then if the Document is less than one half of the entire aggregate, the Document's Cover Texts may be placed on covers that bracket the Document within the aggregate, or the electronic equivalent of covers if the Document is in electronic form. Otherwise they must appear on printed covers that bracket the whole aggregate. The first alternative would apply here, so each document could have its own "covers". Nothing is cumulative for the whole collection. I made an effort to find and resolve such cumulation issues while revising the GFDL for version 1.2.