EPA 510-D-06-005
 Read The Draft Tribal Strategy
 On June 1, 2006, EPA released a draft tribal strategy and is asking for comments within 30 days, until
 July 1, 2006. View the draft tribal strategy. (PDF file, 14 pages, 138 Kbytes, About PDF files)

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OUST Tribal Strateqv(5>epa.qov

703-603-0175
OUST Draft Tribal Strategy
c/o Renee Wynn
U.S. EPA
1301 Constitution Avenue, N.W.
Room 4402A
Washington, D.C. 20460
(phone 202-566-1 895)
OUST Draft Tribal Strategy
c/o Renee Wynn
U.S. EPA
1200 Pennsylvania Avenue, N.W.
Mailcode:5103T
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Obtain Paper Copy Of The Draft

You may request paper copies of the draft tribal strategy from the National Service Center for
Environmental Publications (NSCEP), EPA's publications distribution warehouse, by calling 1-800-490-
9198; writing to U.S. EPA/NSCEP, Box 42419, Cincinnati, OH 45242-0419; or faxing your request to
NSCEP at 513-489-8695: Ask for EPA 510-D-06-005, "Strategy For An EPA/Tribal Partnership To
Implement Section 1529 Of The Energy Policy Act Of 2005."

Request More Information
For more information about the draft tribal strategy, contact Joe Vescio at yesc/o./osep/?(a)eoa.aov or 703-
603-0003.

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Underground Storage Tank Program                       UST Tribal Strategy
                 Draft For Public Comment Only - 6/01/06
       Strategy For An EPA/Tribal Partnership
                      To Implement
   Section 1529 Of The Energy Policy Act Of 2005

             (Solid Waste Disposal Act Section 9013,
                      42 U.S.C § 69911)
              U.S. Environmental Protection Agency
              Office of Underground Storage Tanks
                      Washington, DC
                      www.epa.gov/oust

                      EPA510-D-06-005
                         June 2006

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Underground Storage Tank Program                              UST Tribal Strategy
	Draft For Public Comment Only - 6/01/06
                               Contents



Introduction	1

Underground Storage Tank Challenges In Indian Country 	3

Goals And Objectives Of The Strategy	4
      Objective 1: Strengthening Relationships, Communication, And Collaboration	4
      Objective 2: Improving Information Sharing	5
      Objective 3: Implementing New UST Provisions Of The Energy Policy Act	6
      Objective 4: Implementing UST Prevention Activities Through EPA's
                Program And By Building Tribal UST Program Capacity	6
      Objective 5: Implementing LUST Cleanup Activities Through EPA's Program
                And By Building Tribal UST Program Capacity	8

For More Information About The Tribal Strategy	... 10
      Background About the Energy Policy Act of 2005	10

Appendix:  List Of Related Executive Orders, Statutes, Documents,
            Policies, And Guidance	11

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 Underground Storage Tank Program                               UST Tribal Strategy
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                                 Introduction

       In the United States there are 561 separate, federally-recognized tribal
 governments, each with its own unique history, culture, and treaties. Of these tribes,
 approximately 175 have federally-regulated underground storage tanks (USTs) on their
 lands. This strategy was developed in coordination with Indian tribes, as required by
 Section 9013 (a) of the Solid Waste Disposal Act (SWDA), and recognizes the number
 and diversity of tribes and the need for flexibility in implementing the UST program to
 address unique tribal issues.  This strategy therefore is intended to provide a basic
 framework that can be used as a foundation for discussing the unique UST program
 implementation issues of different tribal governments and provides a consistent method
 whereby EPA and each tribe can continue to cooperatively work on these issues in  the
 future.

       EPA's Office of Underground Storage Tanks (OUST) is committed to protecting
 human health and the environment in Indian Country while supporting tribes' self-
 government, acting consistent with the federal trust responsibility, and strengthening the
 government-to-government relationships between tribes and EPA.  For more than 20
 years EPA has been fulfilling these commitments by providing financial and technical
 assistance to tribal governments to prevent and clean up releases from USTs,
 assistance and support to tribal governments to build tribal capacity of their UST
 programs, and through EPA's direct implementation of the UST  program in Indian
 Country.

       Since 1995, OUST has implemented several policies, including Office of Solid
 Waste and Emergency Response (OSWER) Directive 9610.15,  Interim Final National
 Policy Statement for Underground Storage Tank Program Implementation in  Indian
 Country, and,  since 1990,  OSWER Directive 9610.11, UST/LUST Enforcement
 Procedures Guidance Manual. These policy statements have provided OUST with a
 framework to implement the UST program in Indian Country and have helped EPA and
 tribes build UST programs throughout Indian Country.

      Tribes have also played a significant role in protecting human health and the
 environment by preventing and cleaning up releases from USTs. Some tribes have
 developed their own UST program authorities. Some tribal UST programs are model
 programs that serve as excellent examples of how a UST program should be run. Many
 tribal members are well trained as UST inspectors and site managers of cleanups.

      In Public Law 105-276, Congress authorized  EPA to enter into assistance
 agreements with federally-recognized Indian  tribes for development and implementation
 of programs to manage USTs. In the same law, Congress also authorized EPA to use
 leaking UST (LUST) Trust Funds to enter into assistance agreements with federally-
 recognized tribes for LUST cleanups in accordance with SWDA,  Section 9003(h)(7).
These authorities have increased tribal opportunities for involvement in the UST

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Underground Storage Tank Program                                UST Tribal Strategy
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program, providing funding and support for development of training programs,
regulation development, and tribal UST staff support.

      With the passage of the Energy Policy Act of 2005 the Agency has been
provided some new tools that may provide greater opportunities for tribal involvement in
the UST program.  As a result of the Energy Policy Act of 2005, EPA, together with
tribal representatives, has developed a new strategy to supplement the program's
existing strategy.  Section 1529 of the Energy Policy Act of 2005 amends the SWDA by
establishing a  new Section 9013 regarding USTs in Indian Country.

       Section 9013(a) requires EPA, in coordination with Indian tribes, to develop and
implement a strategy for implementing the UST program in Indian Country and by
August 8,  2007, report to Congress  on the status of implementation and enforcement of
SWDA Subtitle I in Indian Country.  Specifically, by August 8, 2006, SWDA Section
9013(a)(1) directs EPA to develop and implement, in coordination with Indian tribes, a
strategy:

   •  "[G] iving priority to releases that present the greatest threat to human health or
      the environment, and taking necessary corrective action in response to releases
      from leaking underground storage tanks located wholly within the boundaries of
      an Indian reservation or any other area under the jurisdiction of an Indian tribe;
      and

   »  [T] o implement and enforce requirements concerning underground storage tanks
      located  wholly within the boundaries of an Indian reservation or any other area
      under the jurisdiction of an Indian tribe."

      This strategy along with OUST's existing strategy meet the requirements of
SWDA, Section 9013(a). The new strategy presented here is the result of substantial
involvement from representatives from 41 tribal nations, all EPA Regions with federally-
recognized tribes, and headquarters. The result is a strategy that specifically identifies
key issues and actions for improving implementation of the UST program in Indian
Country.

      In particular, this strategy identifies additional steps that EPA and tribes can take
for improving cleanup and compliance of underground storage tanks in Indian Country
by strengthening relationships between EPA and tribes, by improving information
snaring, and by enhancing tribal capacity for implementing the UST prevention and
cleanup programs. In addition, this strategy provides an additional basis for a
continuing dialog between EPA and tribes to implement the objectives contained in this
document and  for tribes to provide input and recommendations to EPA through the
continuation of work groups or other means.

      This strategy, however, does not address other important issues, such as the
absence of authority under SWDA to treat tribes  as states, above-ground storage tanks,

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 Underground Storage Tank Program                                UST Tribal Strategy
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 or issues regarding Indian Country jurisdictional boundary, issues which can be better
 addressed through other forums.  Rather, it provides a framework that can be used as a
 basis for continued discussion and for measuring progress in Indian Country.
 Moreover, this strategy, and the subsequent actions for implementing the strategy,
 should be viewed as living documents that are open to further refinement as priorities
 and circumstances change.

        Underground Storage Tank Challenges In Indian Country

      USTs within Indian Country, representing less than 1% of the regulated USTs
 nationally, are similar to those within states with facilities ranging from small "mom and
 pop" gas stations to large facilities owned by multi-national companies. Some of the
 tanks and facilities are tribally owned.  At the end of fiscal year 2005 there were
 approximately 2,500 active federally-regulated USTs in Indian Country. Of the more
 than 500 federally-recognized tribes, approximately 175 tribes have federally-regulated
 USTs on their lands.  Of the 175 tribes, about two-thirds have 10 or fewer active USTs;
 only 12 reservations have 50 or more USTs. The nature of tribal UST programs within
 Indian Country varies widely, with robust programs for a few tribes, emerging programs
 for some tribes, and no programs  for other tribes. This diversity in tribal capacity
 creates unique implementation challenges for both tribes and EPA.

      In addition to the active USTs, about 5,300 substandard USTs have been closed.
 Since the inception of the program through September 2005, there have been an
 estimated  1,065 releases confirmed in Indian Country. Of the 1,065 confirmed
 releases, cleanups have been initiated at approximately 975 and completed for 675.
 Although cleanups have been initiated for the majority of the sites, there are
 approximately 400 (or 37% of all)  releases in Indian Country for which cleanups have
 not yet been completed.  Nationally, over 119,000, or 26%, of cleanups remain to be
 completed.

      There are many factors contributing to the cleanup challenge in Indian Country.
 Cleanups can be very expensive,  averaging about $125,000, and the liability for
 cleanups lies with the owner and operator.  A release with significant ground water
 contamination can cost more than $1 million to clean up. Owners and operators in
 Indian Country may lack the  resources to initiate and complete cleanups.  Additionally,
 for LUST sites outside of Indian Country, states typically rely on both LUST funds  and
 their own UST cleanup funds to finance cleanups.  Federal LUST funds are available for
 LUST cleanups in Indian Country.  However, state UST cleanup funds are not always
 available for cleaning  up LUST sites in Indian Country.

      With respect to compliance, rates of UST operational compliance in Indian
 Country vary.  Operational compliance is a measure of a facility's compliance based on
 having the equipment required by  current UST regulations and performing the
 necessary operation and maintenance.  In fiscal year 2005, approximately 58% of active
tanks in Indian Country met leak prevention requirements; 53% met release detection

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standards; and 37% met all requirements.  The national averages were 78%, 73%, and
66% respectively. There are many factors contributing to the lower compliance rates in
Indian Country.  In particular, some owners and operators in Indian Country operate
small facilities that lack the resources to properly operate and maintain their UST
systems:  Additionally, owners and operators may lack the resources to obtain the
needed training to ensure the UST systems are operated and maintained properly.

                  Goals And Objectives Of The Strategy

      The primary goal of the  tribal strategy is to improve human health and the
environment in Indian Country by working with tribes to clean up releases from
underground storage tanks by  giving priority to releases that present the greatest threat
to human  health and the environment, to implement and enforce UST leak prevention
and detection requirements, and to meet the UST program's annual and long-term
goals for cleanup and compliance.  Subject to the availability of appropriated funds,
EPA and tribes intend to work toward achieving these goals through five overarching
objectives.

Objective  1:  Strengthening Relationships, Communication, And Collaboration
Objective  2:  Improving Information Sharing
Objective  3:  Implementing New UST Provisions Of The Energy Policy Act
Objective 4:  Implementing UST Prevention Activities Through EPA's  Program And By
            Building Tribal UST Program Capacity
Objective 5:  Implementing LUST Cleanup Activities Through EPA's Program And By
            Building Tribal UST Program Capacity

Objective 1:  Strengthening Relationships, Communication, And Collaboration

      In fulfilling EPA's commitment to protecting human health and the environment in
Indian Country, consistent with the federal trust responsibility, a major emphasis of this
strategy is to strengthen the relationship between EPA's Underground Storage Tank
program and tribal governments. Improving our mutual understanding of EPA and tribal
governments' needs and constraints through more frequent and meaningful
communication is a key ingredient for better program performance. To that end this
strategy includes the following  actions that, as appropriate, EPA can use to strengthen
relationships,  communication, and collaboration with tribal governments.

   •  Consult with tribal governments during planning and decision making  if such
      decisions affect the lands and resources of tribes;

   •  Cooperate with affected tribes in assessing the impact of UST  plans, projects,
      programs, and activities in Indian Country;

   •  Remove procedural impediments to work directly and effectively with tribal
      governments;

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Underground Storage Tank Program                                UST Tribal Strategy
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   •  Coordinate with other federal departments and encourage cooperation among
      tribes, states, and local governments to resolve environmental issues of mutual
      concern; and

   •  Continue to provide a forum for meeting at least annually, at a national level, to
      discuss key issues and proposed solutions, and increase awareness of EPA and
      tribal needs, priorities, and resources, including expanding the role of tribal
      governments at the UST national conference.

Objective 2: Improving Information Sharing

      A key component in achieving the goals and objectives of this strategy is to
assure that relevant information is shared between EPA and tribes. Information on the
status of tank compliance and cleanups and the process for funding a UST program is
essential in developing a successful program. To  further information sharing, this
strategy includes the following actions that EPA, as appropriate, can use to improve
information sharing with tribal governments:

   •  Develop and implement a communication and outreach plan and an on-line
      website to provide tribes with information on EPA UST programs, including
      information on available funding  and guidance on the process for competing for
      Comprehensive Environmental Response,  Compensation, & Liability Act
      (CERCLA)  104(k) Brownfields grants and obtaining allocations under the
      Brownfields State and Tribal Response Program grants authorized by CERCLA
      128 and which is consistent with all EPA policies including but not limited to
      those governing competition for assistance agreements;

   •  Maintain an inventory of sites on Indian Country lands to help evaluate progress
      toward achieving the goals of this strategy. An inventory of UST sites is
      important for setting priorities for compliance and cleanup (e.g., by targeting
      facilities and releases in sensitive drinking water areas).  Inventories can be used
      to track regular on-site inspections, implementation of closure requirements, and
      appropriate and timely responses to releases and suspected releases. The
      inventory also can be updated to reflect the installation of new tanks, the removal
      or closure of older tanks, the locations of previously unknown tanks, and data
      errors;

   •   Provide tribes with information from the federal facility and public record reports
      required by SWDA sections 9007(b) and 9002(d)  on the status of compliance of
      government-owned tanks.  These reports provide information on location,
      ownership, compliance record, and cleanup status, if applicable (among other
      items), and  may provide a more complete picture of the universe of tank sites in
      Indian Country;

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Underground Storage Tank Program                                UST Tribal Strategy
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   •  To the extent consistent with Agency policies governing competition for
      assistance agreements, share information about available funding sources, the
      process for allocating these funds, and the process for competing for funds.
      Such information sharing may enable tribes to provide more input on tribal
      resource needs and potentially may assist tribes in acquiring more funds to
      implement their UST programs;

   •  Utilize national and regional tribal operations committees to disseminate
      information; and

   •  Conduct consultation with tribes on a government-to-government basis
      consistent with existing EPA policy.

Objective 3: Implementing New UST Provisions Of The Energy Policy Act

      There are key provisions of the new Energy Policy Act that apply to states
receiving federal funding but do not specify Indian Country.  Nonetheless,  EPA's goal is
to implement the objectives of these provisions in Indian Country as an important step in
achieving more consistent program results in release prevention and cleanup in Indian
Country. Both EPA and tribes recognize the importance of having policies that can help
to ensure parity in program implementation between states and in  Indian Country.

      Of particular importance are the Energy Policy Act provisions for leak prevention
and detection. One of the key components of the Energy Policy Act, which will help
ensure parity in program implementation, is to inspect all underground storage tanks.
As discussed in objective 4 of this strategy, EPA will work with tribes to inspect every
UST every three years. In addition, this strategy includes the goal of working with tribal
governments to implement the UST program in Indian Country and the objectives of the
other provisions of the Energy Policy Act, including fuel delivery prohibition,
owner/operator training, and secondary containment of tank systems near drinking
water supplies.

      EPA has responsibility for direct implementation of the UST program in Indian
Country and will work with tribal governments to explore appropriate tools that are
available to implement and enforce these goals.

Objective 4: Implementing UST Prevention Activities Through EPA's Program
             And By Building Tribal UST Program Capacity

      The Agency will continue its efforts to implement and enforce the UST program in
Indian Country and assist tribal governments in building tribal capacity to implement and
enforce their own UST programs. To accomplish this, consistent with EPA's Indian
Policy,  the Agency will continue to "take affirmative steps to encourage and assist tribes
in assuming regulatory and program management responsibilities for reservation lands."

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Underground Storage Tank Program                                UST Tribal Strategy
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      Some tribes already have developed and implemented their own UST programs.
EPA and the tribes intend to continue to work together to encourage the development of
tribal UST programs for tribes interested and capable of implementing a program.  To
that end, this strategy includes the following actions that EPA, as appropriate, can  use
to help tribes build tribal implementation and leak-prevention capacity by providing
resources (consistent with approved Agency budgets), training, federal credentials, or
instituting Direct Implementation Tribal Cooperative Agreements (DITCAs) to conduct
inspections:

   •  Provide resources for building capacity and for implementing UST programs.
      Each year Congress appropriates grant funds for tribes to develop and
      implement programs to manage USTs.  EPA has historically provided these
      funds directly to tribal governments to support prevention activities and to tribal
      consortia as a means to reach multiple tribes that may each only have a few
      USTs on their land. Tribes receiving these grants are able to hire staff or
      continue employing staff dedicated to the UST program.  To the extent consistent
      with approved Agency budgets, EPA intends to continue to provide these funds
      to support their UST prevention activities.

   •  Provide training to enable interested and capable tribes to build capacity for
      developing and implementing their own UST programs. EPA and tribes intend to
      continue to work together to identify training  needs and explore various
      approaches to providing training efficiently. Continuing education and  training is
      important for keeping tribes up to date on the latest compliance measures
      required by the program, to provide a forum for tribes to exchange ideas and
      concerns, and to identify information gaps that a  tribe may have when
      implementing  a UST program.  EPA and  tribes intend to explore the use of in-
      person and web-based training and the use of tribal instructors as a means of
      providing UST inspector training, as well  as advanced training in UST
      inspections, UST equipment standards, health  and safety issues, and other
      subjects, as needed.

   •   Enable interested and capable tribes to conduct inspections and compliance
      assistance.  By August 8, 2007, EPA will work with tribes to conduct on-site
      compliance inspections of all USTs that have not undergone an inspection since
      December 22, 1998, including inspections for temporarily closed facilities. After
      completion of  these inspections, EPA and tribes,  as appropriate, will conduct on-
      site inspections once every three years to determine compliance. As the
      implementing  authority, EPA enforces UST requirements in Indian Country, as
      necessary and appropriate.

         Several tribes have well-trained and experienced UST inspectors and can
      assist EPA's Regions in conducting inspections every three years in Indian
      Country. SWDA enables EPA to authorize tribal government representatives to
      conduct inspections on behalf of EPA. Authorizing tribal inspectors can increase

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Underground Storage Tank Program                                UST Tribal Strategy
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      the geographic coverage and frequency of EPA inspections in Indian Country-
      thus helping to ensure that inspections are conducted every three years-and
      simultaneously increasing the capabilities of tribal inspectors to conduct
      inspections under tribal law. After assessing where and when such
      authorizations are appropriate, EPA can work with tribes to enter into a written
      agreement on inspections and provide federal credentials to qualified tribal
      inspectors. DITCAs can serve as the written agreement as well as outline other
      areas for tribes to assist EPA in other compliance assurance activities. DITCAs
      and inspector credentials should be used, where it is appropriate, and can be
      beneficial to both EPA and tribes.

Objective 5: Implementing LUST Cleanup Activities Through EPA's Program
            And By Building Tribal UST Program Capacity

      EPA's strategic plan establishes an annual goal of 30 Indian Country LUST
cleanups per year.  Although almost two-thirds of all UST releases in Indian Country
have been cleaned up, 390 cleanups remain. To meet EPA's annual goal and continue
to make progress on cleanups, EPA will continue to give cleanup priority to  those
releases presenting the greatest threat to human health or the environment. EPA also
intends to work with tribes to help tribes build their capacity to identify and address
these high-priority LUST sites. To that end, this strategy includes the following actions
that EPA, as appropriate, can use to help build tribal capacity to implement  LUST
cleanup activities. Capacity building can be accomplished  by providing resources for
corrective action, clarifying the corrective action processes, providing adequate
involvement to make sure site cleanups move forward expeditiously, and providing  an
opportunity for tribes to compete for grants (through the Brownfields competitive grant
selection process) for cleaning up contamination at abandoned brownfield sites with
USTs.

   •  Each year, EPA allocates part of its Leaking UST appropriation for grants to
      tribes to assess and clean up USTs in  Indian Country.  EPA has successfully
      used these funds to initiate and clean up two-thirds of all LUST releases in Indian
      Country. To the extent consistent with approved Agency budgets, EPA intends
      to continue to provide these funds to support LUST cleanup activities.

   »  Implement corrective action plans that clarify the cleanup process and provide
      the opportunity for meaningful involvement.  EPA and tribes may generally
      accomplish this in part through the following actions:

         o  Working with interested and capable tribes to effectively develop, adopt,
            and administer tribal codes and cleanup standards and explore "site-
            specific" EPA rulemaking;

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Underground Storage Tank Program                                 UST Tribal Strategy
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         o  Finalizing EPA's cleanup guidance for Indian Country, which includes a
            process for taking unique exposure patterns associated with tribal
            traditions and cultural practices into account;

         o  Reviewing the corrective action process to identify ways to make it more
            streamlined and expedite cleanups (such as multi-site approaches and
            pay for performance cleanups);

         o  Encouraging cooperation between tribes and states to address UST sites
            adjacent to Indian Country;

         o  Promoting  more DITCAs for cleanup to enable tribes to assist EPA in
            conducting corrective action; and

         o  Sharing current and relevant information with tribes.

   •  Each year, EPA provides Brownfields grants for petroleum sites (such as
      Brownfields assessment, cleanup, and revolving loan fund grants) to states and
      tribes based on a competitive grant proposal process.  EPA will continue to inform
      tribes of Brownfields meetings and the process for applying for Brownfields
      grants.

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Underground Storage Tank Program                                        UST Tribal Strategy
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                For More Information About The Tribal Strategy

Visit the EPA Office of Underground Storage Tanks' web site at www.epa.gov/oust or
call 703-603-9900.
                         Background About The Energy Policy Act Of 2005


         On August 8, 2005, President Bush signed the Energy Policy Act of 2005. Title XV, Subtitle B of this
         act (entitled the Underground Storage Tank Compliance Act) contains amendments to Subtitle I of the
         Solid Waste Disposal Act - the original legislation that created the underground storage tank (UST)
         program. This new law significantly affects federal and state underground storage tank programs, will
         require major changes to the programs, and is aimed at reducing underground storage tank releases to
         our environment.

         The underground storage tank provisions of the Energy Policy Act focus on preventing releases.
         Among other things, it expands eligible uses of the Leaking Underground Storage Tank (LUST) Trust
         Fund and includes provisions regarding inspections, operator training, delivery prohibition, secondary
         containment and financial responsibility, and cleanup of releases that contain oxygenated fuel additives.

         Some of these provisions require implementation by August 2006; others will require implementation in
         subsequent years. To  implement the new law, EPA and states will work closely with tribes, other
         federal agencies, tank owners and operators, and other stakeholders to bring about the mandated
         changes affecting underground storage tank facilities.

         To see the full text of this new legislation and for more information about EPA's work to implement the
         underground storage tank provisions of the law, see:  http://www.epa.gov/oust/fedlaws/nrq05 01 .htm
                                               10

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 Appendix: List of Related Executive Orders, Statutes, Documents,
             Policies, and Guidance


 Statutes

 •    42 U.S.C. § 69911, Resource Conservation and Recovery Act, Section 9013, Tanks
     on Tribal Lands

 Regulations

 •    40 CFR Part 280, Technical Standards and Corrective Action Requirements for
     Owners and Operators of Underground Storage Tanks
 •    40 CFR Part 281.12(a)(2), Approval of State Underground Storage Tank
     Programs—Scope

 Presidential Documents

 •    George W. Bush's Indian Policy - Memorandum for the Heads of Executive
     Departments and Agencies, Government-to-Government Relationship with Tribal
     Governments (http://www.epa.gov/indian/pdfs/president-bush-indian.pdf)
 •    Executive Order 13175 -- Consultation and Coordination with Indian Tribal
     Governments (http://www.epa.gov/fedrqstr/eo/eo13175.htm)

 EPA Policies and Initiatives

 •    The 1984 EPA Indian Policy (http://www.epa.gov/indian/1984.htm)
 •    Reaffirmation Memorandum of the 1984 EPA Indian Policy
     (http://www.epa.qov/indian/pdfs/reaffirmation-indian-policv.pdf)
 •    Interim Final National Policy Statement for Underground Storage Tank Program
     Implementation in Indian Country (OSWER Directive 9610.15)
     (http://www.epa.qov/oust/directiv/d961015a.htm), October 23, 1995

EPA Guidance

•    Guidance for Issuing Federal EPA Inspector Credentials to Authorize Employees
     of State/Tribal Governments to Conduct Inspections on Behalf of EPA
     (http://www.epa.gov/compliance/resources/policies/monitoring/inspection/statetriba
     lcredentials.pdf). September 30, 2004
•    Process for Requesting EPA Credentials for State/Tribal Inspectors Conducting
     Inspections on EPA's Behalf, Memorandum from Michael S. Alushin,  Director,
     Compliance Assessment and Media Programs  Division, Office of Enforcement and
     Compliance Assurance, August 5, 2005
                                     11

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     Use of the LUST Trust Fund for UST Release Sites in Indian Country,
     Memorandum from Cliff Rothenstein, Director, Office of Underground Storage
     Tanks, and Susan Bromm, Director, Office of Site Remediation Enforcement,
     February 24, 2005
     UST/LUST Enforcement Procedures Guidance Manual, OSWER Directive
     9610.11, May 1990
                                      12

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