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  <br />I reached out to Janet Witul with EPA to get her initial guidance on EPA letterhead;  she has reversed <br />course on her previous guidance and has stated that EPA registered pesticides are regulated as oils <br />under SPCC (depending on the ingredients) and the FIFRA products SPCC exemption only occurs at the <br />point when the oil is transferred to application equipment or mixing containers before application. <br />  <br />All this to say Wilbur Ellis was incorrect in our stance of the 440 Oil tank not falling under SPCC rule. I do <br />want you to know that we were action on good faith based on EPA’s email. I will assist the facility in <br />crafting a response for the return to compliance letter. <br />  <br />Please let me know if you have any questions. <br />  <br />Thanks, <br />  <br />Evelyn Watson <br />951-395-4747 <br />  <br />From: Won, Mahew [EHD] <mwon@sjgov.org> <br />Sent: Tuesday, June 11, 2024 4:25 PM <br />To: Evelyn Watson <Evelyn.Watson@wilburellis.com>; Anthony Chica <Anthony.Chica@wilburellis.com> <br />Subject: Re: [EXTERNAL] RE: SPCC and FIFRA Products <br />  <br />Hello Evelyn and Anthony, <br /> <br />After review and discussion with my supervisor, we need some more information for clarification on the <br />440 oil. The SDS provided mineral oil as 99% with other ingredients for the rest of the ingredients. <br />Could you specify what the rest of those ingredients are? Based on what is cited, it seems that if there is <br />any storage at all of a pesticide mixed with oil, it would be regulated under SPCC, unless mixed just <br />prior to application. <br /> <br />How long does the 440 oil normally stay on site? What would be the timeframe between storage and <br />application? <br /> <br />Also if you could provide the guidance/regulations specifically citing that FIFRA products are not <br />regulated under SPCC? <br /> <br />Thank you,