EPA
                United States
                Environmental Protection
                Agency
        Office of
        Underground Storage Tanks
        Washington, D.C. 20460
   EPA/530/UST- 88/005
   December 1988
Dollars
Sens

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 &EPA
                    UPDATE:

                    Underground Storage Tank
                    Financial Responsibility
TO „ _ „ „* ol
* manciai
                    Subtitle I of the Resource Conservation and Recovery Act requires
                    ownersand operators of underground storage tanks (USTs) to meet
Responsibility     certain financial responsibility requirements for cleanup and third-
rrkmnliarifp Dates  party damages resulting from leaks that may occur. EPAphasedin
Compliance Uates  gj^jgj responsib&ty requirements for USTs over a two-year
                    period because of concerns about the unavailability of financial
                    assurance mechanisms to large portions of the regulated commu-
                    nity The phase-in was designed to achieve the maximum balance
                    between tne need to ensure financial capability for UST releases
      I              and the necessary time for owners and operators to obtain ass\ir-
      I              ance mechanisms.

      I              Petrol eum marketers owning 1 000 or more USTs and non-market-
                    ers with more than $20 million in tangible net worth were required
                    to comply in January 1989. Petroleum marketers owning between
                    100 and 999 USTs were required to comply in October 1989.
Extension of
Compliance
for Some UST
Owners
                    The Agency has decided to extend the compliance dates of the two
                    remaining groups: petroleum marketers owning between 13 and 99
                    USTs who were required to comply April 26, 1990, and all other
                    owners, including local governments, who were required to comply
                    October 26,1990.

                    The Agency will publish rules to extend these groups' compliance
                    dates for one year each. Those owners and operators who had to
                    comply by April 26, 1990, now have until April 26, 1991-Those
                    owners and operators who had to comply by October 26,1990, now
                    have to comply by October 26,1991.


                    The Agency believes that extending the financial responsibility
                    compliance dates will not adversely affect human health and the
                    environment, as the technical requirements for USTs will remain
                    in effect. These requirements include leak detection, tank upgrad-
                    ing and corrective action.	'

MARCH 14,1990
United States Environmental Protection Agency, Office of Solid Waste & Emergency Response,
Office of Underground Storage Tanks
Washington, D.C. 20460                                      Repnduc** « R*cyd*d Papa-
Objectives of
EPA

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UPDATE: Underground Storage Tank Financial Responsibility


In extending the third and fourth compliance dates, the Agency desires to provide short-term
       uOT owners and operators to whom methods of financial assurance are not available
        mpliaiKe groups generally represent the small gas stations and convenience stores
        needTaTeff^ctive financial responsibility mechanism. EPA continues to work
      er wKh Confess and the states to enable small businesses to remain economically
      wbih fat thfsame time, ensuring that mechanisms exist to pay for the cleanup of
leaking tanks.

Rationale for Extensions

Information collected  by the Agency from the UST insurance **»*«*
           and the states indicates that the owners and operators in toe third I
                                                                        fourth
     unity and the states indicates tat te owners an
compliance groups need more time to comply with the financial responsibility requirement
^ AgTn^Ss fearned that only about two percent of the third compliance group curTenUy
havelnsuSnce, and recent contractions in the insurance market have demonstrated that the
availability of insurance is likely to be further constrained.
 Many
             and operators cannot obtain insurance because they cannot meet Usurers'
          n  requirements. The Agency knows of eleven states that have "tabbed
financial assistance programs to help owners and operators upgrade or ^P1*?. *** ^8g
TheAgencyisencouragedbythese efforts and is developing matonals to help addifaonal states
AatmayS to establish financial assistance programs.  Extending the compliance dates
^D^o^ more time for funds to become available to owners and o^rators who cannot
obtain insurance because of strict underwriting requirements.
 The Agency beeves that states have taken the lead by sponsoring assurance ^ to help
 owners to comply with the requirements and to clean up release*.  While 34 sta tes have
 erected legislation creating state assurance funds only 7 have received •»"•*»»""'
 as compliance mechanisms. States need additional time to have their tods approved and to
 ^e them operational The Agency will use the additional time provided by the compliance
 date extensions to work actively with the states to accomplish these tasks.

 Finally, the Agency is in the process of developing several additional «^anisms, includmg
 self-assurance ? mechanisms, that local governments can use to comply ™* *^"J£j!
 responsibility reqtlirements.  EPA hopes  to finalize these mecfcmisms by ^October ^ 1990,
 hoover, h^vernments may need additional time to ^^^^^^
 mechanisms, because they operate on fixed budgetary cycles. Extending their compliance
 date by one year will provide this needed relief.

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Background
 Action Taken
 today
 Discussion
                   United Statas
                   Environmsntal Protection
                   Agancy
                    Solid Wast* and
                    Emargancy Response
                    Washington, DC 20460
                    OS-42
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Rationale
Contact
Worksheet Test - A financial worksheet has been developed that recognizes
the unique financial structure of government entities.  Local governments can
use readily available financial data to complete the worksheet and calculate a
score. Governments with scores at or above a selected level will be allowed to
self-insure.

Governmental Guarantee - A local government will be allowed to obtain a
guarantee fiom its state or another local government with which it can demon-
strate a "substantial governmental relationship."  In order to serve as guarantor,
a local government must qualify using the bond rating or worksheet test

Fund Balance Test - Local governments may self-administer an UST response
fund if appropriate safeguards are met

Because several of the mechanisms contained in the original financial respon-
sibility rule promulgated on October 26,1988 do not apply to local govern-
ments (e g., the corporate test for setf-insurance), the  Agency has developed a
rule which addresses the unique financial characteristics of local governments,
and which allows financially capable entities the opportunity to self-insure.

For additional information, contact EPA's RCRA/Superfund Hotline, Monday
through Friday, 8:30 a.m. to 7:30 p.m. EST. The national toU-free number is
800 424-9346; for the hearing impaired, the number is TDD 800 553-767i.

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                   Snvtr onrwfllai P»<*dte<»
Background
Action Taken Today


Discussion
                   Environmental
                   Fact  Sheet
EPA Concerned  About Small

Businesses:   Extends  Compliance

Date For Underground StorageTank

Financial  Responsibility


      Subtitle 1 of the Resource Conservation and Recovery Act (RCRA)
require* owners and opera lor* of underground storage tank* (USTs) lo show
ih/oueh insurant coverage Of other acceptable financial rnechanisms thai fcey
can oav for cleanups and third-party damage* resultine from any leak* that may
occur In final regulation* published on October 26. 1588, the Environmental
Projection Agency (EPA) pnased in the financial responsibility requirements over
a 2 year perild because c/concems about the unavailability of financial assurance
mechanism* to large portion* of the regulated community. The phase-in (with it»
four distinct group* of tank owners) was designed to achieve a balance between
the need to ensure the financial capability to pay for UST releases and the tun*
necessary for owners and operators to obtain assurance mechanisms.

      The phase-in set different compliance dates far the tour compliance
woups. Petroleum marketers ownfrg 1000 of more USTs and non-marketers with
more than $20 million in tangible net worth were required »^P    *""
1989. Petroleum marketers owning between 100 and 999 USTs were
comply in October 1 9 W.
      In 1990, EPA revised its regulation* by ulendins «« «°mpn*«ce« *»*
 petroleum marketer* owning between 13 and 99 USTs from Apnl 26. 1990. to
 April 26. S991. The compliance date for petroleum marketers owning between 1
 arSl2 USTs at more than one facility or fewer than )00 USTs at a »*$•!*&*
 and non-marketers with less than $20 million in net worth was extended from

 October 26. 1990. to October 26. 1991.

      On December 16. 1991. EPA finalized an extension of the Oclooer 26. 1991

 compliance date to December >1, 1991.

      The Agency is concerned about the ability of small businessesto have
 obtained financial assurance by October 26. 1991. lh finalizing the December >1,
 1993 extension, the Agency desires to provide short-term relief to UST owners a^d
 operators to whom methods of financial assurance are not currently readOy
 available. This compliance group includes the owners and operators of the
 smallest gasoline and service station* who are generaHy most in need of an
 effective financial responsibility mechanism. ETA is working with «£»
 enable small businesses to remain economically wabJe while, at the same
 ensuring that mechanism* exist to pay for the cleanup of leaking tank*.
                                     -over-

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Rationale For
Proposing An
Extension
Contact
    A*er*y believes that lhl» exfcnjlon erf the ««ip11*r
deveJop £5 submit toir funds for EPA review. EPA wffl us« the addlHonaS tfrr*
to actively work with to States to accomplish this.
       This extension to December 31. 1993 win also place the final com
date for financial responsibility after to final complianeedatefor EPA , $ 1
detection rwuiremenal By regulatJon. afl tanks (regulated under jubbde lol
MXUmusi bt tested by Oecimber 23. 1993. Tanks tot m«t to leak dent**
requirements are more l&ely to meei Insurers' underwitinftcnteria.

       Additionafly. an extension will provide tfme for EPA to explore how or
whether to adopt some variation to Option 2 (considered to to proposed rule).
Such an approach may give certain subgroups an additional extension of the
federal financial responsibility requirementa.

       For additional Information, contact EPA's RCXA Hotline. Monday
throuih Friday, 1:30 am to 7:30 pm BST. The national toB-free number is 8pO»
SSSiiJorlfc ^^hearingimpaired. *e number to TOD «OO.J53.76?1 to Washing-
ton, O.C, tht number b 7C3-9W-9810.

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      DOLLARS  AND  SENSE

A Summary of the Financial Responsibility Regulations
       for Underground Storage Tank Systems
           U.S. Environmental Protection Agency
           Office of Underground Storage Tanks
                  December 1988

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This document was prepared for the U.S. Environmental Protection
Agency under contract #68-01-7344.

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                      TABLE OF CONTENTS
What Are These Regulations All About? 	1




Who Is Affected By These Regulations?	3




How Do You Comply With The Financial Responsibility Requirements? 	6




What Records Must You Keep Or File With The Implementing Agency? 	9




Samples of Financial Responsibility Forms	10




Videos, Brochures, And Handbooks On USTs	13




Financial Test Options	15

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 WHAT ARE THESE REGULATIONS  ALL ABOUT?


The U.S. Envkonmental Protection Agency (EPA) has published final regulations concerning financial
responsibilities if you own or operate underground storage tank systems containing petroleum. (EPA
plans to develop similar regulations for tanks containing hazardous substances in the future.)  Al-
though the full regulations appear in the Federal Register (October 26, 1988), this brochure provides a
brief summary and answers some important questions about your financial responsibilities.
Why Has EPA Written  These

New Regulations?

Several million underground storage tank sys-
tems (USTs) in the United States contain petro-
leum. Tens of thousands of these USTs, in-
cluding their piping,  are currently  leaking.
Many more are expected to leak in the future.
Leaking USTs can cause fires or explosions
that threaten human safety.  In addition, leak-
ing USTs can contaminate nearby ground wa-
ter.  Because many of us depend on ground
water for the water we drink, Federal legisla-
tion  seeks to safeguard our nation's ground-
water resources.
       !
Congress responded in  1984 to the problem of
leaking USTs by adding Subtitle I to the Re-
source Conservation and Recovery Act.  Sub-
title  I requires EPA to  develop regulations  to
protect human health and the environment  from
leaking USTs and specifically mandates re-
quirements for financial responsibility.
What Is  "Financial
Responsibility" And Why Is It
Necessary For  You?

Financial responsibility  means  that if you own
or operate an UST, you must ensure, either
through  insurance or other means explained
below, that there will be money to help pay for
the costs of third-party  liability and corrective
action caused by a leak from your tank. These
costs could include cleaning up leaked petro-
leum, correcting environmental damage, sup-
plying drinking water, and compensating
people for personal injury or property  damage.
Financial responsibility  also protects vou.  If
your UST leaks, you may be faced with high
cleanup  costs or with lawsuits  brought by third
parties.  Having financial responsibility means
that money will be available to meet these
costs.

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What  Kinds Of Tanks Are
Covered By The Rule?


Financial responsibility must be shown for all
USTs containing petroleum products.  USTs  are
defined by law to be tank systems with at least
10 percent of their volume below the surface of
the ground.  The term  "tank systems" also
includes the piping connected to the tank.
What Kinds Of Tanks Are Not
Covered?

Some tank systems have  been exempted or
deferred from the financial responsibility rule:

  + USTs containing hazardous wastes
     already regulated under RCRA.

  4> UST systems containing electrical
     equipment and hydraulic lifts.

  ^ Wastewater treatment USTs that are
     regulated by the Clean Water Act.

  *• USTs with a capacity of less than  110
     gallons, and tanks holding a minimal
     concentration of regulated substances.

  + USTs that serve as emergency back up,
     hold regulated substances for only a short
     time, and are expeditiously emptied  after
     use.

  4 Field-constructed tanks.
 USTs containing radioactive materials
 and USTs used as backup diesel tanks at
 nuclear facilities.

 Airport hydrant  fueling systems.

 Farm or residential tanks with capacity of
 1,100 gallons or less storing motor fuel
 which is not for resale.

 Tanks for storing heating oil which is
 used on-site.

 Septic tanks.

 Certain pipeline systems, such as those
 regulated under the Natural  Gas Pipeline
 Safety Act of 1968.

 Surface impoundments, pits, ponds,  or
 lagoons.

 Storm or waste water collection systems.

 Flow-through  process tanks.

 Liquid trap and other lines used in oil or
 gas production.

 Storage tanks on  or above the floor of an
underground area, such as a  basement or
tunnel.
                                           -2-

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  WHO  IS AFFECTED  BY THESE REGULATIONS?
Do  You Have To Show
Financial  Responsibility?

Either the owner or the operator of the tank
must show financial responsibility, but not both
if the owner and operator are different indi-
viduals or firms. It is the responsibility of the
owner and operator to decide which of them
will  show  financial  responsibility.

Federal and State governments and their agen-
cies that own USTs are not required to docu-
ment financial responsibility. Local govern-
ments, however, must comply with the new
rule.

If you owned or operated a tank that was prop-
erly  closed before the date for compliance that
applies to  you, then the  financial responsibility
requirements will not apply  to your closed tank.


What Do You Have To  Do?

The  new financial responsibility regulations
require you to show that you have one of the
following:

   *• at least $1 million  to cover the costs of a
      leak  or spill from your underground
      storage tank if you are a PETROLEUM
      MARKETER (page 43334 of the Federal
      Register of October 26, 1988); or

   + at least $500,000 if you are NOT A
      MARKETER (page 43330 of the Federal
      Register of October 26, 1988).

You may show that you have this coverage by
using insurance or any of the other methods of
coverage explained in this brochure.  The
amount of financial responsibility that you
must show does not limit your total liability for
damages caused by a leak from your  tank sys-
tem.
When  Must You Comply With
The Financial  Responsibility
Requirements?

The rule takes effect 90 days after its publica-
tion in the Federal Register (i.e., January 24,
1989). The date when you will have to show
financial responsibility, however, depends on
the compliance category that you fall into, as
shown below:

   + If you fall into one of the following
     groups, you must show financial
     responsibility on the same day that the
     rule becomes effective on January 24,
     1989:  1) petroleum marketing firms that
     own 1,000 or more USTs; and 2) any
     other UST owners that report a tangible
     net  worth of $20 million  or more to the
     SEC, Dun and Bradstreet, the Energy
     Information  Administration, or the Rural
     Electrification Administration.

   4 If you are a petroleum marketing firm that
     owns 100 to 999 USTs, you must show
     financial responsibility by October 26,
     1989.

   + If you are a petroleum marketing firm that
     owns 13 to 99 USTs at more than one site,
     you must show financial responsibility by
     April 26, 1990.

   * If you fall into one of the following
     groups, you must show financial
     responsibility by October 26, 1990:
      1) petroleum marketing firms owning 1  to
      12 USTs or those having fewer than 100
     USTs at one site; 2) all other UST owners
     with a tangible net worth of less than $20
     million; and 3) local governments.
                                           -3-

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 What Happens If You Install A
 New UST Before Your
 Scheduled  Compliance Date?


 The regulations require that you show financial
 responsibility for a new UST when  you notify
 EPA that you have installed the tank.  If you in-
 stall a new UST before the date when you must
 first show financial responsibility as described
 above, then you must only show financial re-
 sponsiblity for the new tank by that compliance
 date. You may ignore the line on the new tank
 notification form  concerning financial responsi-
 bility.


 What  Amount Of Money Are
 You Responsible For?

The amount of money for which you must show
financial  responsibility depends on the type of
business you operate, the  amount of throughput
of your tank, and the number of tanks you
have:

   *• If your tank is used in petroleum
     production, refining  or marketing (for
     example,  service stations and truck stops),
     then you must be able to show  that you
     have $1 million of "per occurrence"
     coverage.  "Per occurrence" means the
     amount of money that must be available
     to pay the costs of one occurrence.

  + You must also have coverage for an
     annual aggregate amount. The annual
     aggregate amount is the total amount of
     financial responsibility that you must
     have to cover all leaks that might occur in
     one  year.  The amount of aggregate
     coverage that you must have depends on
     the number of tanks that you own or
     operate.  The annual aggregate  limits are:

     ~ 1 to 100 tanks, $1 million annual
       aggregate;  or
    -- 101 or more tanks, $2 million annual
       aggregate.
 For example, if you own or operate three serv-
 ice stations with a total of 18 tanks, then you
 must have financial responsibility in the
 amount of $1 million per occurrence and $1
 million annual aggregate. If you own or oper-
 ate 50 service stations with a total of 200 tanks,
 you must have financial responsibility in the
 amount of $1 million per occurrence and $2
 million annual aggregate.
    > If your tanks are located at a facility not
      engaged in petroleum production, refining
      or marketing, and your facility has a
      monthly throughput of more than 10,000
      gallons, then you must show that you
      have $1  million of "per occurrence"
      coverage. If the facility has a monthly
      throughput of 10,000 gallons or less, then
      you  must show that you $500,000 of "per
      occurrence" coverage and $1 million or
      $2 million of annual aggregate coverage
      depending on the number of tanks you
      own or operate, as  discussed above.
For example, if you are an automobile dealer
With four small tanks with a total monthly
throughput of 10,000  gallons, then you would
only need to have financial responsibility  in the
amount of $500,000 per occurrence and $1
million annual aggregate. If you have 30  deal-
erships with a total of 110 tanks, you would
need to have financial responsibility in the
amount of $500,000 per occurrence,  but you
would need $2 million annual aggregate.
The chart on page 5 displays these
financial  responsibility  requirements.
                                           -4-

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  IMPORTANT REQWREMENTS AND MINIMUM
        DEADLINES FOR YOUR FINANCIAL
                  RESPONSIBILITY

                WHAT YOU MUST HAVE
    WHO
 PETROLEUM
  MARKETER
THROUGHPUT
 OF FACILITY
   PER
OCCURRENCE
 COVERAGE
                                           AGGREGATE
                                            COVERAGE
 PETROLEUM
NON-MARKETER
                 10,000
                GALLONS
                OR LESS
                MONTHLY
                                             $1 MILLION IF
                                             YOU HAVE 100
                                             OR FEWER
                                             TANKS;
                                 OR
                               $2 MILLION IF
                               YOU HAVE
                               MORE THAN
                               100 TANKS
    A
  JANUARY 1989
   MARKETERS
  —'.WITH 1000 —
  —I- TANKS; -I—

  NON-MARKETERS
  WITH NET WORTH
   OF $20 MILLION
                WHEN YOU MUST HAVE IT
    A
I OCTOBER 1989


I I I I
• MARKETERS -
• WITH 100-999 -
— j- TANKS 4—

    A
I APRIL 1990


1 I I I
' MARKETERS ~
• WITH 13-99 -
—I. TANKS -j—

A
OCTOBER 1990


MARKETERS
" WITH 1-1 2
• -I TANKS-


NON-MARKETERS
WITH NET WORTH
OF LESS THAN
~ $20 MILLION! 	
- AND LOCALI 	
GOVERNMENTS


                          — 5 —

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  HOW DO  YOU COMPLY WITH THE  FINANCIAL
            RESPONSIBILITY   REQUIREMENTS?
How Can You Show Financial
Responsibility  For Your
USTs?
You can demonstrate financial responsibility
for your USTs in several ways:

  + Show that your firm can meet the costs of
     potential releases. If your Firm has a
     tangible net worth of at least $10 million,
     you can prove your financial
     responsibility by passing one of these two
     financial tests described on page 15.

  •* Show that someone else is responsible for
     cleanup and damage costs. You may
     arrange to have someone else be
     responsible for paying the costs of leaks
     from your USTs. This may be done in a
     number of ways (all are described in
     detail in the rule):

     1. Obtain insurance coverage from an
        insurer or a risk retention group
        (page 8); or
     2. Obtain a guarantee for the amount you
        are responsible for from  a corporate
        parent, grandparent, sibling, or from
        another firm with whom  you have a
        substantial business relationship.  The
        provider of the guarantee has to pass
  one of the financial tests described on
  page 15; or
3. Obtain a surety bond for the amount
  you are responsible for; or
4. Obtain a letter of credit for the
  amount you are responsible for.

Use State funds. If your State has
established a State fund that will pay for
the cleanup costs of a leak from your tank
systems, then you may not need
additional coverage to show you can pay
for the same costs (page 7). You need to
check to see if the State fund covers your
tanks. You may also still need to show
financial responsibility for the costs of
compensating those injured by leaks,
unless the State fund would also pay for
those  costs.

Use State approved methods. You may
also use any method of coverage
approved by  your State.

Set up a trust fund. You may set up a
fully-funded trust fund to cover your
financial responsibility  requirement.
                                                   YOUR WALL OF
                                                      PROTECTION
                                          -6--

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Can You Use A Combination
Of Methods To Show
Financial   Responsibility?

You may also use a combination of methods to
show financial responsibility.  The methods
you choose must cover all the costs that you are
responsible for (both third-party  liability and
corrective action) and add up to the amount of
coverage you are required to show. If the
methods you choose cover different costs (for
example, the insurance policy  covers damages
to other people and property and the guarantee
covers cleanup costs), then each  method must
provide  the total amount of responsibility that
you must demonstrate.
What About State Funds?
Some States have established programs to pay
for cleanup costs from petroleum leaks.  These
State funds often may be used by owners and
operators of USTs to demonstrate financial
responsibility.  In most States, however, funds
will pay only part of cleanup costs.  In addi-
tion, few States will pay for third-party dam-
ages caused by petroleum leaks.
You should contact your State environmental
agency to determine if the State has a fund that
you may use to show financial responsibility.
Find out what the State will pay for and what
amount of financial responsibility you  must
obtain. In several States, for example, you
must demonstrate financial responsibility for
the first $100,000 of cleanup costs before the
State will  demonstrate financial responsibility
for the remaining costs.  Most State funds will
not pay more than $1 million per occurrence.

If you don't know how to reach your State Co-
ordinator, call EPA's Hotline for the phone
number of your State Coordinator (1-800-424-
9346)
What Happens If Your
Coverage  Is Cancelled?

If your method  of financial responsibility is
cancelled,  you must find another mechanism to
replace it within 60 days after you receive the
notice of cancellation.  If you cannot get an-
other mechanism in that time,  then you must
notify the  implementing Agency or the State.

Your coverage or insurance contract must spec-
ify that the provider of coverage or insurance
may only  cancel your coverage by sending you
a notice by certified mail. For guarantees,
surety bonds, or letters of credit, cancellation
can only occur  120 days after you receive the
notice.  Insurance policy coverage can be
cancelled  60 days after you receive the notice.

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 Can You Get  Private
 Insurance  Coverage For Your
 USTs?

 Private insurance coverage for USTs is still
 limited, but there are several major insurers
 who offer policies. Insurers are often selective
 in the tanks they will cover.  If you want to
 purchase insurance, you may be required to
 meet certain conditions for coverage.  For ex-
 ample, your insurer may ask you to test your
 tank for tightness, or  he may require certain
 improvements in your tank system, such as
 liners,  cathodic  corrosion protection, and leak
 detection.  Some insurers simply will not pro-
 vide coverage for certain types of  tanks, like
 tanks that are more than 20 years old.

 You may also be able to get insurance coverage
 through a risk retention group.  A  risk  retention
 group is an insurance  company formed by busi-
 nesses or individuals with similar risks to pro-
 vide insurance coverage for those risks.  To
join a risk retention group, you will probably
 be asked to make a one-time payment ~ called
 a capital contribution ~ and thereafter pay an-
 nual premiums as with any other insurance
policy.
 If you are interested in purchasing insurance
 through either a private insurer or a risk reten-
 tion group to show financial responsibility for
 your USTs, you should contact your insurance
 agent.  You may want to take with you the
 sample Endorsement or Certificate of Insurance
 that appear on pages 11 and 12.  These docu-
 ments are examples of policies that meet EPA
 financial responsibility requirements.   If you
 belong to a trade association, it may also be
 able to provide you with information about
 insurers and risk retention groups that cover
 USTs.
                  ASK THE EXPERT
                               INSURANCE
                                 BROKER
INSUKANCt
  A6ENT
INSURANCE
PROVIPER

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      WHAT RECORDS MUST YOU KEEP  OR FILE
          WITH THE IMPLEMENTING AGENCY?
You must keep records of the type of coverage
you have at your tank site or your place of busi-
ness.  In addition, you must maintain a certifi-
cation of financial responsibility (see page 10).
You must keep both of these records until your
tanks are properly closed.

You only need to report and/or file copies of
these records with EPA in the following cases:

   ^  You install a new tank system.

   +  You have confirmed that a tank system is
     leaking.
 You receive notice that a method of
 coverage you have will be cancelled or
 will not provide sufficient coverage, and
 you are unable to get other coverage.

• EPA or a State agency requests your
 records.
                                        ..9..

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      SAMPLES  OF FINANCIAL  RESPONSIBILITY
                                       FORMS
                     CERTIFICATION OF FINANCIAL RESPONSIBILITY

   [Owner or operator] hereby certifies that it is in compliance with the requirements of Subpart H of 40 CFR Part 280.

   The financial assurance mechanism[s] used to demonstrate financial responsibility urister Subpart H of 40 CFR Part
280 Is [are] as follows:

   [For each mechanism, list the type of mechanism, name of issuer,, mechanism mtff&fa- (if applicable), amount of
coverage, effective period of coverage and whether the mechanisn|j$iyers "taking corradve aeftori" and/or
"compensating third parties for bodily injury and property damage cattf&j by" either "sud^ift Accidental releases" or
"non-sudden accidental releases" or "accidental  released,"} ..
                                        •J,,            >".'•,,- '"-*:
[Signature of owner or operator]                          s       "
                                  *    w   s
[Name of owner or operator]
                                        !•
                                        ,  -
[Title]
[Date]
The owner or operator must update this certification whenever the financial insurance mechanisrn(s) used to
demonstrate financial responsibility change(s).
                                          -10-

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                                                 ENDORSEMENT
Name:   !     [name of each covered location]
Address:;       [address  of each covered location]
Policy  Number:	

Period of Coverage:       [current policy  period]
Name of [Insurer or Risk Retention Group]:
Address of [Insurer or  Risk  Retention Group]:
Name of  Insured:
Address of Insured:
Endorsement:

  1. This endorsement certifies that the policy to which
  the endorsement is  attached  provides liability
  insurance covering the following underground  storage
  tanks:

  [List the number of tanks at each facility and the
  name(s)  and address(es) of the facihty(ies) where Urn*.
  tanks are located. If more  than  one instrument (5 used'
  to assure different tanks at any one facility, for,
  tank covered by  this instrument, list the tank',--f
  identification number provided in  tb$ 'iotificaticf ('
  submitted pursuant to 40 CFR 280I&S,
  corresponding state  requirement, an<$ Jhd
  address  of  the facility 1     ^         ,"-

  for  [insert: "taking corr«np3$e stu!;ft&>"s and/ove.

  The limits of liability are [insert  the dollar amount of
  the "each occurrence" and "annual aggregate"  limits
  of  the Insurer's of Group's liability; if the amount of
  coverage is different for different types  of coverage or
  for different underground storage tanks or locations,
  indicate  the amount of coverage for each type of
  coverage and/or for each  underground  storage tank or
  location], exclusive of legal defense costs. This
  coverage is provided  under [policy  number]. The
  effective  date of said policy is  [date].

  2.  The insurance afforded with respect  to such
  occurrences is subject to all of the terms and
  conditions of the policy; provided, however, that any
  provisions  inconsistent with subsections (a) through
  (e) of this Paragraph  2 are hereby amended to
  conform  with subsections (a) through (e):

      a.   Bankruptcy  or Insolvency of the insured shall
      not relieve the ["Insurer" or "Group"] of its
      obligations under the policy to which this
                                                                  endorsement
     b.  The ["Insurer"  _sr "Gldap"] is liable for the
     pjiy.ment of amourtte'Jwithin  any  deductible
     t|pcabie to  the  polfey to tee" provider of
     cttftWiye action or a $«1*4flfed third-party, with a
     rigrtf '«rfjreimbursem«nt Bf ? the insured for any such
  '"•(>aymMt'niade tfir fte ["Insurer" or "Group"]. This
     jM-ovision; ^ftgff'riif apply with respect to that
, ^.Jmount of. Jfty deductible for which coverage is
T*" demonstrated under another mechanism or
     combination of mechanisms as specified in 40
'     CFR  280.95-280.102.

     c.  Whenever requested by [a Director of an
     implementing  agency], the ["Insurer"  or "Group"]
     agrees to furnish to [the Director]  a signed
     duplicate original  of the policy and all
     endorsements.

     d. Cancellation or any other termination of the
     insurance by the ["Insurer"  or "Group"] will be
     effective only upon written notice and only after  the
     expiration of  60 days after a copy of such written
     notice is  received.

     [Insert for claims-made  policies:

     e. The  insurance covers claims for any occurrence
     that commenced  during the term of the policy that
     is discovered and reported  to the ["Insurer"  or
     "Group"] within six months  of the effective date  of
     the cancellation or termination of  the policy].

 I hereby certify that the wording of this instrument is
 identical to the wording in 40 CFR 280.97(b)(1) and that
 the ["Insurer" of "Group"] is  ["licensed to transact the
 business of insurance or  eligible to provide insurance
 as an excess or surplus  lines insurer in one or more
 states".]

 [Signature of authorized  representative of Insurer or
 Risk Retention Group]

 [Name of person signing]

 [Title  of person signing],  Authorized
                                                        -11-

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