In 1985, Manufacturers National Bank of Detroit issued a letter of credit for Z & Z Leasing, Inc., an industrial firm, to enable Z & Z to obtain bond financing from Canton Township, Michigan. After six years of operation, Z & Z was not doing well and had defaulted on its bond obligations. A consultant for the bank found underground storage tanks on Z & Z’s site. The tanks contained a yellowish liquid that was found to be a solvent and a hazardous substance. The bank paid off the Canton township bond obligation and foreclosed on the Z & Z property. By 1993, Z & Z still had not sold the property, and the EPA sought to hold the bank liable as an operator for the costs of cleaning up the tanks. Can the bank be held liable? [Z & Z Leasing, Inc. v. Graying Reel, Inc., 873 F. Supp. 51 ( E. D. Mich. 1995).]