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Cc: Witul, Janice <Witul.Janice@epa.gov> <br />Subject: RE: SPCC and FIFRA Products <br /> <br />Hi Eddie, <br /> <br />Good to hear from you. I’ve copied Janice who is my counterpart, as she has been also doing a bit of work in the FIFRA Program. Janice, if you have any <br />guidance for Eddie, that would be great. Thanks, otherwise, we can get some feedback from HQs. <br /> <br />Thanks, <br /> <br />Pete Reich <br />U.S. EPA Region 9 Oil Program <br />Desk: 415-972-3052 <br />Cell (New!): 415-961-4376 <br />Reich.peter@epa.gov <br />www.epa.gov/oilspill <br /> <br />From: Eddie Phillips <Eddie.Phillips@wilburellis.com> <br />Sent: Thursday, August 10, 2023 7:29 AM <br />To: Reich, Peter <Reich.Peter@epa.gov> <br />Subject: SPCC and FIFRA Products <br /> <br />Hi Pete, <br /> <br />I hope you’re doing well, it’s been a minute since we’ve spoken. I’ve rered from BNSF and am working for an <br />agricultural support business. I was wondering if you could clarify something for us regarding which FIFRA <br />(pescides, herbicides, etc.) are subject to the SPCC requirements. I found this document that states, “The <br />exempon does not include bulk containers storing pescides mixed with adjuvants or crop oil.” I understand that <br />any oil, diesel, gasoline, vegetable, fish, crop oil, adjuvant, etc. and mixtures containing any of them is subject to <br />the requirements, what we’re trying to figure out is whether or not the nearly 2,000 FIFRA products we store that <br />might have some petroleum disllates or other organic solvent or oil in them prior to mixing is also subject to the <br />requirements. <br /> <br />Any guidance you can offer is greatly appreciated. <br /> <br />Thanks, <br /> <br />Eddie