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(as compared to a container in contact with soil)' and makes all sides of the container, including the bottom, visible during inspection(e.g., where the containers are mounted on structural supports, saddles, or some forms of grillage)would be considered"equivalent." In a similar vein, we'd also generally believe an approach that combines visual inspection with placement of a barrier between the container and the ground, designed and operated in a way that ensures that any leaks are immediately detected, to be considered"equivalent." For example, we believe it would generally provide equivalent environmental protection to place a shop-built container on an adequately designed, maintained, and inspected synthetic liner.' We believe these approaches would generally provide equivalent environmental protection when used for shop-built containers (which generally have a lower failure potential than field-erected containers), because these approaches generally reduce corrosion potential and ensure detection of any container failure before it becomes significant. In determining the appropriate SPCC plan requirements for visual inspection of containers managed as described above, we suggest that the professional engineer(PE)begin by consulting appropriate industry standards, such as those listed in Steel Tank Institute Standard SP001 and American Petroleum Institute Standard 653.3 Similarly, in assessing whether a shop- built container is well designed, the PE may wish to consult industry standards such as Underwriters Laboratory 142 or American Petroleum Institute Standard 650, Appendix J. Where a facility is considering the use of the above approaches for containers that are currently resting on the ground, or have otherwise been managed in a way that presents risks for corrosion or are showing signs of corrosion,we recommend the facility first evaluate the condition of the 'Additionally,we recommend that special attention be paid to the characteristics of the material used for the support structure to ensure that they do not actually accelerate corrosion. 'Note, however, that a facility may not rely solely on measures that are required by other sections of the rule (e.g., secondary containment)to provide "equivalent environmental protection." Otherwise, the deviation provision would allow for approaches that provide a lesser degree of protection overall. 3Note that the Agency intends in the near future to develop guidance on appropriate visual inspection of shop-built containers. In that guidance, we intend to address issues such as inspection frequency, scope (e.g., internal and/or external), training and/or qualifications of persons conducting the inspections, and other measures that may be appropriate at a given site (e.g., measures to detect the presence of water in a container). We expect to use the referenced industry standards in developing such guidance. It is also important to note, however, that depending on site circumstances, the appropriate requirements for visual inspection may exceed those normally conducted in accordance with recognized industry standards.