Underground Storage Tank Program                  UST Tribal Strategy
       Strategy For An EPA/Tribal Partnership
                     To Implement
   Section 1529 Of The Energy Policy Act Of 2005
              U.S. Environmental Protection Agency
              Office of Underground Storage Tanks
                      Washington, DC
                     www. epa.gov/oust

                      EPA-510-R-06-005
                        August 2006

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Underground Storage Tank Program                        UST Tribal Strategy
                               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	5
      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 and Tribal
                UST Programs  	7
      Objective 5: Implementing LUST Cleanup Activities Through EPA and Tribal
                LUST Programs  	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                                   A-1

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Underground Storage Tank Program                          UST Tribal Strategy
                                Introduction

      In the United States there are over 560 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 underground
storage  tank 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 underground storage tank program implementation issues of different tribal
governments and provides a consistent method whereby the U.S. Environmental
Protection Agency (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 underground
storage  tanks, supporting tribal governments in building capacity to  improve their tribal
underground storage tank programs, and directly implementing the  underground
storage  tank program in Indian Country.

      Since 1995, OUST has implemented several EPA policies, including Office of
Solid Waste and Emergency Response (OSWER) Directive 9610.15A, Interim Final
National Policy Statement for Underground Storage Tank Program Implementation in
Indian Country, Guidance on the Enforcement Principles Outlined in the 1984 Indian
Policy, and, since 1990, OSWER Directive 9610.11, UST/LUSTEnforcement
Procedures Guidance Manual. These policy statements have provided OUST with a
framework to implement the underground storage tank program in Indian Country and
have helped EPA and some tribes build underground storage tank 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 underground storage  tanks.
Some tribes have developed their own underground storage tank program authorities,
while others are working toward development of their own programs. Some tribal
underground storage tank programs are model programs that serve as excellent
examples of how an underground storage tank program should be run.  Many tribal
members are well trained as underground storage tank inspectors and site managers  of
underground storage tank cleanups.

      In the Departments of Veterans Affairs and Housing and Urban Development,
and Independent Agencies Appropriations Act, 1999 (Public Law 105-276) Congress

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Underground Storage Tank Program                           UST Tribal Strategy
authorized EPA to enter into assistance agreements with federally-recognized Indian
tribes for development and implementation of programs to manage underground
storage tanks.  In the same law, Congress also authorized EPA to use leaking
underground storage tank (LUST) Trust funds to enter into assistance agreements with
federally-recognized tribes for leaking underground storage tank cleanups in
accordance with SWDA, Section 9003(h)(7).  These authorities have increased tribal
opportunities for involvement in the underground storage tank program and provided
funding and support for development of training programs, regulation development, and
tribal underground storage tank staff.

      The passage of the Energy Policy Act of 2005 gives EPA new tools that may
provide greater opportunities for tribal involvement in the underground storage tank
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 underground storage tanks in Indian
Country.

       Section 9013(a) requires  EPA,  in coordination with Indian tribes,  to develop and
implement an underground storage tank program strategy in Indian Country and by
August 8, 2007, to 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 and 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 Regional offices with
federally-recognized tribes, and EPA headquarters. The result is a strategy that
specifically identifies key issues and actions for improving implementation of the
underground storage tank program in Indian Country.

      In  particular, this strategy identifies additional steps that EPA and tribes can take
to further the cleanup and compliance of underground storage tanks  in Indian Country
by strengthening relationships between EPA and tribes,  by improving information
snaring, and by building tribal capacity to improve the implementation of the

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Underground Storage Tank Program                          UST Tribal Strategy
underground storage tank prevention and cleanup programs. In addition, this strategy
provides an additional basis for a continuing dialogue 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.
Following issuance of this strategy, EPA plans to continue to work with tribes to develop
steps to implement the concepts presented here and to begin addressing questions that
may still need to be answered.

      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,
or issues regarding Indian Country jurisdictional boundaries, 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

      Underground storage tanks within Indian Country, representing less than 1% of
the federally-regulated underground storage tanks nationally, are similar to those within
states and include facilities ranging from small "mom and pop" gas stations to large
ones 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 underground storage tanks in Indian Country. Of the more than 560 federally-
recognized tribes,  approximately 175 tribes have federally-regulated underground
storage tanks on their lands.  Of the 175 tribes, about two-thirds have 10 or fewer active
underground storage tanks; only 12 tribes have 50 or more underground storage tanks.
The nature of tribal underground storage tank 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 programs creates unique
implementation challenges for both tribes and EPA.

      In addition to the active underground storage tanks,  about 5,300 substandard
underground storage tanks in Indian Country 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 (26%) of cleanups remain to be completed.

      There are many factors contributing to the cleanup challenges 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  groundwater
contamination can cost more  than $1  million to clean up. Owners and operators in

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Underground Storage Tank Program                          UST Tribal Strategy
Indian Country may find it difficult to initiate and complete cleanups.  Additionally, for
leaking underground storage tank sites outside of Indian Country, states typically rely on
both LUST Trust funds and their own underground storage tank cleanup funds to
finance cleanups. However, state underground storage tank cleanup funds are not
always available for cleaning up leaking underground storage tank sites in Indian
Country. Federal LUST Trust funds are available for leaking underground storage tank
cleanups in Indian Country. In fact,  since the early 1990s,  EPA has been providing
LUST Trust funds to tribes for leaking underground storage tank oversight and to help
build leaking underground storage tank program capabilities; more recently, EPA has
provided LUST Trust funds to a few tribes to conduct cleanups.

      With respect to compliance, rates of underground storage tank operational
compliance in Indian Country vary.  Operational compliance is a measure of a facility's
compliance based on having the equipment required by current underground storage
tank 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 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 underground storage tank systems. Additionally,
owners and operators may lack the resources to obtain the needed training to ensure
the underground storage tank 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 underground storage
tank leak prevention and detection requirements according to EPA's enforcement
principles outlined in the guidance listed on page 1; and to meet the underground
storage tank 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 and Tribal UST
            Programs
Objective 5:  Implementing LUST Cleanup Activities Through EPA and Tribal LUST
            Programs

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Underground Storage Tank Program                          UST Tribal Strategy
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' responsibilities, 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 underground storage
      tank plans, projects, programs, and activities in Indian Country;

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

   •  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 to increase awareness of EPA
      and tribal needs,  priorities,  and resources, including expanding the role of tribal
      governments at the underground storage tank 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 an underground
storage tank 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 underground storage tank
      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

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Underground Storage Tank Program                           UST Tribal Strategy


      including, but not limited to, those governing competition for assistance
      agreements;

   •  Maintain an inventory of sites in Indian Country to help evaluate progress toward
      achieving the goals of this strategy. An inventory of underground storage tank
      sites is important for setting priorities for compliance and cleanup (e.g., by
      targeting facilities and releases in sensitive drinking water areas such as source
      water areas). For example, 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;

   •  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 underground storage tank 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

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Underground Storage Tank Program                           UST Tribal Strategy
underground storage tank every three years. In addition, this strategy includes the goal
of working with tribal governments to implement and enforce the underground storage
tank 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 underground storage tank
program in Indian Country and will work with tribal governments to explore appropriate
tools to meet the objectives in this strategy.

Objective 4:  Implementing UST Prevention Activities Through EPA and Tribal
UST Programs

      The Agency will continue its efforts to implement and enforce the underground
storage tank program in Indian Country and assist tribal governments in building tribal
capacity to implement and enforce their own underground storage tank 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."

      Some tribes already have developed and implemented their own underground
storage tank programs. EPA and the tribes intend to continue to work together to
encourage the development of tribal underground storage tank 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 underground
      storage tank programs.  Each year Congress appropriates grant funds for tribes
      to develop and implement programs to manage underground storage tanks.
      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 underground storage tanks on their land.
      Tribes receiving these grants are able to hire staff or continue employing staff
      dedicated to the underground storage tank program.  To the extent consistent
      with approved Agency budgets, EPA intends to continue to provide these funds
      to support these underground storage tank prevention activities;

   •  Provide training to enable interested and capable tribes to  build capacity for
      developing and  implementing their own underground storage tank  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 are important for keeping tribes up to date on the latest compliance
      measures required by the program, providing a forum  for tribes to exchange

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Underground Storage Tank Program                          UST Tribal Strategy
      ideas and concerns, and identifying information gaps that a tribe may have when
      implementing an underground storage tank 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 underground storage tank inspector training,
      as well as advanced training in underground storage tank inspections,
      underground storage tank 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 underground storage tanks 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
      underground storage tank requirements in Indian Country, as necessary and
      appropriate.

   •  Several tribes have well-trained and experienced underground storage tank
      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 the geographic coverage and frequency of EPA
      inspections in Indian Country-thus helping to ensure that  inspections are
      conducted every three years-and simultaneously increase 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 appropriate,
      and can be beneficial to both EPA and tribes.

Objective 5:  Implementing LUST Cleanup Activities Through EPA and Tribal
LUST Programs

      EPA's strategic plan establishes an annual goal of 30 Indian Country leaking
underground storage tank cleanups per year.  Although almost two-thirds of all
underground storage tank releases in Indian Country have been cleaned  up, 390
cleanups remain.  To meet EPA's annual goal and keep on making 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 them build their capacity to identify and  address these high-priority leaking
underground storage tank sites. To that end, this strategy includes the following actions
that EPA, as appropriate, can use to help build tribal  capacity to implement leaking
underground storage tank cleanup activities.  Capacity building can be accomplished by
                                       8

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Underground Storage Tank Program                          UST Tribal Strategy
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 underground storage
tanks, and by providing resources for corrective action.

   •  Each year, EPA allocates part of its LUST Trust Fund appropriation for tribes to
      assess and clean up underground storage tanks in Indian Country.   EPA has
      successfully used these funds to initiate and clean up two-thirds of all leaking
      underground storage tank releases in Indian Country.  To the extent  consistent
      with approved Agency budgets,  EPA intends to continue to provide these funds
      to support leaking underground storage tank 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;

         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 to expedite cleanups (such as multi-site approaches and
            pay for performance cleanups);

         o  Encouraging cooperation between tribes and states to address
            underground storage tank 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
                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, the Act 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.qov/oust/fedlaws/nrq05 01 .htm
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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/fedrgstr/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.gov/indian/pdfs/reaffirmation-indian-policy.pdf)
•   Interim Final National Policy Statement for Underground Storage Tank Program
    Implementation in Indian Country (OSWER Directive 9610.15A)
    (http://www.epa.gov/oust/directiv/d961015a.htm), October 23, 1995

EPA Guidance

•   Guidance on the Enforcement Principles Outlined in the 1984 Indian Policy,
    (http://www.epa.gov/compliance/resources/policies/state/84indianpolicy.pdf),
    January 17, 2001
•   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,
                                     A-1

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Underground Storage Tank Program                         UST Tribal Strategy
    Compliance Assessment and Media Programs Division, Office of Enforcement and
    Compliance Assurance, August 5, 2005
    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
                                    A-2

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