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Pacific Gas and US Company 77 BFz= Sr=e' • S z S„- <br /> Sz- Fra':.s- C v.e C',br-z etre 3 z <br /> X73 266P <br /> March 29, 1991 <br /> Mr. Jeffrey Zelikson <br /> Director, U.S. Environmental Protection Agency <br /> Region IX <br /> Hazardous Waste Management Division <br /> 75 Hawthorne Street <br /> San Francisco, CA 94105 <br /> Dear Mr. Zelikson: <br /> I am the chief financial officer of Pacific Gas and Electric Company (PG&E) <br /> located at 77 Beale Street in San Francisco, California. This letter is in <br /> support of the use of the financial test of self-insurance to demonstrate <br /> financial responsibility for taking corrective action and compensating <br /> third parties for bodily injury and property damage caused by sudden <br /> accidental releases in the amount of at least $1 million per occurrence and <br /> $2 million annual aggregate and nonsudden accidental releases in the amount <br /> of at least $3 million per occurrence and $6 million annual aggregate <br /> arising from operating underground storage tanks. <br /> Underground storage tanks at the PG&E facilities listed in Attachment 1 are <br /> assured by this financial test or a financial test under an authorized <br /> State program by this owner or operator. <br /> A financial test is also used by this owner or operator to demonstrate <br /> evidence of financial responsibility in the following amounts under other <br /> EPA regulations or state programs authorized by EPA under 40 CFR Parts 271 <br /> and 145: <br /> EPA Regulations Amount <br /> Closure (Sections 264.143 and 265.143) . . . . . . . . . . . .5 8,351,000 <br /> Post-Closure Care (Sections 264.145 and 265.145) . .$ N/A <br /> Liability Coverage (Sections 264.147 and 265.147) . <br /> Sudden. . . . . .$ 2,000,000 <br /> Nonsudden. . .$ 6,000,000 <br /> Corrective Action (Section 264. 101(b)) . . . . . . . . . . . .$ N/A <br /> Plugging and Abandonment (Section 144.63) . . . . . . . . .$ N/A <br />