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container in accordance with good engineering practices, including seeking expert advice,where appropriate. Security The SPCC regulations state that you must"fully fence each facility handling,processing, or storing oil, and lock and/or guard entrance gates when the facility is not in production or is unattended." 40 CFR §112.7(g)(1). You have asked whether two specific sets of circumstances would likely be determined to provide "equivalent environmental protection"to this requirement. The first is where the area of the facility directly involved in the handling,processing and storage of oil is adequately fenced. The second is where the facility is equipped with a"pump house" or "pump shack,"which contains, among other appropriate things, a master disconnect switch from which all power to pumps and containers is cut off when the facility is unattended. With respect to your first scenario, it is our view that, as a general matter, adequately fencing all discrete areas directly involved in the handling, processing and storage of oil would provide equivalent environmental protection to fencing the entire footprint of the facility, since it is potential for harm to this equipment that poses the risk addressed by the fencing requirement. With respect to the second scenario, the approach you suggest would appear to generally provide environmental protection equivalent to fencing for risks associated with the potential for unauthorized access to pumping equipment. In other words, cutting off power in the manner you suggest would likely provide the added layer of protection offered by a fence should the other security measures offered by the rule, in this case 40 CFR §112.7(g)(3)'s requirements for securing pumps,fail. However, because cutting off power as suggested does not address risks to containers,piping and appurtenances not associated with the pumps at the facility, it does not appear to provide protection equivalent to fencing as it relates to risks to such equipment. Conclusion Please note that determinations of"equivalent environmental protection"must be implemented and documented in accordance with 40 CFR §112.7(a)(2). In addition, please be aware that the conclusions drawn in this letter are only for the purposes of meeting the "environmental equivalence" standard in the SPCC regulation. PE's might nevertheless decide to recommend non-destructive shell testing and fencing of the entire footprint of the facility for reasons other than compliance with the SPCC rule(e.g., to protect an owner's investment in equipment or to meet other local, state or federal requirements).