October 5, 2018

Kerry DeKeyser
Sanimax USA, LLC
2099 Badgerland Drive
Green Bay, WI 54303

RE:	Alleged Violations Letter
	Sanimax USA LLC, South Saint Paul, Dakota County

Dear Kerry DeKeyser:

On August 1, 2018, the Minnesota Pollution Control Agency (MPCA) staff inspected your facility and reviewed your file as part of a routine inspection and identified the following alleged violations.

This letter describes actions you should take to correct the violations and also requests further information.

Please respond within ten days with facts or circumstances we should consider in determining whether and what level of enforcement action is appropriate.

Alleged Violations

1.	Failure to conduct a performance test for PM2.5 on the Ring/Blood Dryer within 180 days of permit issuance. Test was due by September 18, 2016, and was not completed until September 30, 2016.

2.	Failure to conduct a performance test for Opacity on Boiler No. 3 within 180 days of permit issuance. The performance test has not been conducted.

3.	Failure to submit the construction notification for Boiler No. 3 on time. Construction began on February 22, 2016, and the notification was not submitted until September 7, 2016, which is 
169 days late.

4.	Failure to submit the startup notification for boiler No. 3 on time. Boiler No. 3 started up on December 12, 2016, and the notification was submitted on February 23, 2017, which is 59 days late.

5.	Failure to submit a notification for equipment removal for Boiler No. 1. A notification was never submitted.

6.	Failure to get permit before commencing construction. The Regulated Party submitted a notification that construction began on Boiler No. 3 on February 22, 2016. The Regulated Party’s permit for the construction of Boiler No. 3 was not issued until March 22, 2016.

7.	Failure to maintain liquid flow rate greater than 65 gallons per minute for TREA28. The Regulated Party reported that TREA28 did not maintain the minimum liquid flow rate for 75 of 154 operating days of a 6-month reporting period.

Reporting Period	Control Equipment	Number of Readings Taken	Number of Readings out of Compliance	Percent Deviations	
2nd Half 2015	TREA27 Water Flow	306	48	16%	
2nd Half 2015	TREA26 Differential Pressure	306	36	12%	
2nd Half 2015	TREA28 Water Flow	306	75	25%	
1st Half 2016	TREA27 Differential Pressure	146	6	4%	
1st Half 2016	TREA28 Water Flow	154	75	49%	
1st Half 2016	TREA30 Water Flow	152	18	12%	
2nd Half 2016	TREA27 Differential Pressure	306	48	16%	
2nd Half 2016	TREA26 Differential Pressure	306	36	12%	
2nd Half 2016	TREA28 Differential Pressure and water Flow	306	75	25%	
1st Half 2017	TREA27 Water Flow	396	18	5%	
1st Half 2017	TREA26 Differential Pressure and Water Flow	396	24	6%	
1st Half 2017	TREA28 Differential Pressure and Water Flow Rate	396	90	23%	
2nd Half 2017	TREA27 Differential Pressure and Water Flow	468	18	4%	
2nd Half 2017	TREA26 Differential Pressure and Water Flow	468	54	12%	
2nd Half 2017	TREA28 Differential Pressure and Water Flow 	468	39	8%	
1st half 2018	TREA26 Differential Pressure	125	96	77%	
1st half 2018	TREA26 Water Flow	125	3	2%	
1st half 2018	TREA26 Visible Emissions	127	20	16%	
1st half 2018	TREA27 Differential Pressure	200	2	1%	
1st half 2018	TREA27 Visible Emissions	127	15	12%	
1st half 2018	TREA30 Differential Pressure	515	205	40%	
1st half 2018	TREA30 Visible Emissions	123	10	8%	
1st half 2018	TREA28 Differential Pressure	454	147	32%	
1st half 2018	TREA28 Visible Emissions	151	20	13%	

8.	Failure to take immediate corrective action to return TREA28 to return water flow rate to permitted limits. The Regulated Party reported that TREA28 was out of compliance for 60 straight days in a reporting period.

9.	Failure to conduct Visible Emissions Checks. The Regulated Reported on the first half 2018 semiannual deviations reports that the following visible emissions checks were not completed:

Control Equipment	Number of days operated	Number of Readings Missed	Percentage of Missed Readings	
TREA31	130	115	88%	
TREA34	130	115	88%	
TREA26	166	39	30%	
TREA35	130	115	88%	
TREA27	166	39	30%	
TREA29	130	115	88%	
TREA30	162	39	24%	
TREA28	190	39	21%	
TREA32	130	115	88%	
TREA33	130	115	88%	

10.	Failure to conduct visible emissions checks during day light hours. The Regulated Party submitted visible emissions check records that were conducted during nighttime hours.

11.	Failure to document periodic inspections for baghouses. The Regulated Party submitted periodic inspection records that did not have the date the inspection was completed.

Corrective Action

Within 30 days you must:

1.	Submit a plan to ensure performance tests are completed on time.
2.	Submit documentation that an opacity performance test has been scheduled for Boiler No. 3.
3.	Submit a plan to ensure that notifications will be submitted on time.
4.	Submit a notification for the removal of Boiler No. 1.
5.	Submit a signed statement that the Regulated Party understands that construction activity cannot commence until a permit has been issued.
6.	Submit an updated operation and maintenance plan for TREA28 to ensure that the minimum liquid low rate is maintained, and ensures that corrective actions are completed as soon as possible to return equipment to proper operation.
7.	Submit a plan to ensure staff only conduct visible emissions checks during daylight hours, and that all visible emissions checks are conducted.
8.	Submit a plan to ensure that periodic inspections are documented appropriately.

Information Needed

In order to further determine compliance, the MPCA staff needs more information.

Submit within 30 days to the Minnesota Pollution Control Agency, Dan Dietrich 520 Lafayette Road North, St. Paul, MN 55155-4194 or to dan.dietrich@state.mn.us:

1.	Submit daily visible emissions checks records from February 1, 2016 to August 1, 2018. Provide any information about visible emissions checks being completed at night.

Responding to this letter and completing the corrective actions, does not prevent us from issuing an enforcement action. We reserve the right to pursue any and all remedies available under law as an appropriate response to these violations.

We will contact you to discuss next steps in this process. In the meantime, please contact me by phone at 651-757-2370 or by email at dan.dietrich@state.mn.us if you have any questions or need assistance.

Sincerely,
Dan Dietrich 
This document has been electronically signed.
Dan Dietrich, Environmental Specialist 3
Air Compliance Unit
St. Paul Office
Industrial Division

DD:lam 

cc:	Cory Boeck, MPCA
Brent Rohne, MPCA 
Activity ID INS20170004 @ 4387