April 25, 2017

Mr. Gene Parks, Registered Agent
Sanimax USA LLC
505 Hardman Ave S
South Saint Paul, MN  55075    

RE:	Letter of Warning - Sanimax USA LLC, South Saint Paul, Dakota County

Dear Mr. Parks: 

This is a Letter of Warning (LOW) issued by the Minnesota Pollution Control Agency (MPCA) to 
Sanimax USA LLC (Regulated Party) for alleged violations of Minnesota’s spill reporting requirements at the Regulated Party’s Facility located in South Saint Paul, Dakota County, Minnesota. The MPCA has sufficient information to allege that the Regulated Party has violated the following provisions of state statutes, rules, or permit conditions: 

1.	Minn. Stat. 115.061, Subd. 1A

DUTY TO NOTIFY AND AVOID WATER POLLUTION.  (a) Except as provided in paragraph (b), it is the duty of every person to notify the agency immediately of the discharge, accidental or otherwise, of any substance or material under its control which, if not recovered, may cause pollution of waters of the state, and the responsible person shall recover as rapidly and as thoroughly as possible such substance or material and take immediately such other action as may be reasonably possible to minimize or abate pollution of waters of the state caused thereby. 

(b) Notification is not required under paragraph (a) for a discharge of five gallons or less of petroleum, as defined in section 115C.02, subdivision 10. This paragraph does not affect the other requirements of paragraph (a). 

The Regulated Party failed to immediately report the release of approximately 60-gallons of fat in the railcar containment area on April 12, 2017 at 11:30 p.m. The Regulated Party did not report the release until April 13, 2017 at 5:13 p.m. The release was reported approximately 17 hours and 43 minutes late.

To address the alleged violations cited in this LOW, the Regulated Party is to complete the following actions:

1.	Within 30 days after receipt of this letter, the Regulated Party shall submit written documentation to the MPCA, verifying that it shall immediately report future reportable releases to the Minnesota Duty Officer at 800-422-0798 or 651-649-5451 and that staff have been trained on the release reporting requirements and processes. Please review MPCA fact sheet:  Reporting spills and leaks. The fact sheet is available on the internet at: http://www.pca.state.mn.us/index.php/view-document.html?gid=2807

If you believe the allegations in this LOW are incorrect, please respond in writing within ten days after receiving this LOW and explain any inaccuracies. 

Please contact me at 651-757-2163 or jason.moran@state.mn.us if you have any questions about the LOW.

Sincerely,
Jason Moran
This document has been electronically signed.
Jason Moran
Emergency Management Unit
Saint Paul Office
Remediation Division

JM:lam 

cc:	Activity ID NON20170002 @ AI ID 4387