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fire codes or other standards for good engineering practice that may apply to alternative AST systems. On October 22, 1991, EPA proposed revisions to the SPCC regulation. The proposed revisions do not affect the provisions substantially equivalent to those specifically listed in paragraphs (c) (1) (i) through (c) (1) (vii). OBJECTIVE This memorandum should allow EPA Regional personnel to provide consistent interpretation of the secondary containment provisions of section 112.7 (c) of the SPCC regulation to facilities with generally smaller shop-fabricated ASTs. Alternative AST systems, including equipment and procedures to prevent reasonably expected discharges, should satisfy the secondary containment provisions of the SPCC regulation under most site-specific conditions. DISCUSSION As smaller shop-fabricated ASTs are increasingly appearing in the market, we have observed a number of innovative technologies to reduce the risks of both leaks and spills. Moreover, these smaller shop-fabricated tanks do not pose the same risk of large uncontrolled oil spills to navigable waters as the larger field-erected tanks. Therefore, we believe that there should be many situations in which protection of navigable waters substantially equivalent to that provided by the secondary containment systems listed in section 112.7 (c) could be provided than 12,000 gallons and are installed and operated with protective measures other than secondary containment dikes. For example, some State programs provide an exemption from State spill prevention requirements for ASTs with similar capacities. However, in certain situations, these alternative AST systems might appropriately not be presumed to comply with the provisions of section 112.7 (c). An example of this type of situation is facilities containing four or more ASTs or ASTs with combined capacity greater than 40,000 gallons, where a number of larger tanks are connected by manifolds or other piping arrangements that would permit a volume of oil greater than the capacity of one tank to be spilled as a result of a single system failure. In evaluating these shop-fabricated AST systems, EPA's Office of Solid Waste and Emergency Response (OSWER) has looked at requirements the Agency has established for tanks in situations where traditional secondary containment systems cannot be provided (e.g., USTs covered by 40 CFR Part 280). Additionally, OSWER has evaluated relevant State and local government requirements. OSWER also has considered factors related to alternative AST systems that include adequate technical spill and leak prevention options such as overfill alarms, flow shutoff or restrictor devices, and constant monitoring of product transfers provide protection of navigable waters substantially equivalent to that provided by secondary containment as defined in 40 CFR 1 This is based on similar capacities in proposed National Fire Protection Association standards and consideration of the risks to public Protection Association standards and consideration of the risks to public health or welfare or the environment of spills of potentially larger size.