October 9, 2017

Robert Morris
Chief Executive Officer 
1010 Dale St N 
St Paul, MN  55117

RE:	Letter of Warning - Hood Packaging Corp., Arden Hills, Ramsey County
	Hazardous Waste Generator ID - MNR000102509

Dear Mr. Morris:

This is a Letter of Warning (LOW) issued by the Minnesota Pollution Control Agency (MPCA) to 
Hood Packaging Corp. (Regulated Party) for alleged violations of Minnesota’s hazardous waste regulations at the Regulated Party’s facility located in Arden Hills, Ramsey County, Minnesota. 
The MPCA has sufficient information to allege that the Regulated Party has violated the following provisions of state rules:  

1.	Minn. R. 7045.0292 subp. 1. B. 1 [ACCUMULATION OF HAZARDOUS WASTE], 
which references Minn. R. 7045.0626 USE AND MANAGEMENT OF CONTAINERS

Subp. 2. Condition of containers.  Containers used to store hazardous waste must meet the following requirements:

B.	have lids, caps, hinges, or other closure devices of sufficient strength and construction so that when closed they will withstand dropping, overturning, or other shock without impairment of the container's ability to fully contain the hazardous waste.

On August 24, 2017, the MPCA staff observed and documented that the Regulated Party failed to store hazardous waste in storage containers that had lids or other closure devices of sufficient construction that when closed they would withstand dropping, overturning, or other shock without impairing the container’s ability to fully contain the hazardous waste. There were two black 55-gallon hazardous waste containers in the storage room with lids incapable of fully containing the contents if dropped or overturned.

2.	Minn. R. 7045.0855, STANDARDS FOR USED OIL GENERATORS

	Subp. 2. Storage
		
C.	Used oil generators shall not store used oil in units other than containers or tanks and must ensure that the following requirements for containers and tanks are met. Containers and tanks used to store used oil at generator sites must be in good condition and not leaking. Containers must be closed, except for containers that receive used oil directly from used oil filter crushing equipment or oil and water separation equipment. Containers must be placed on a surface that is reasonably impervious to used oil. Containers, aboveground tanks, and fill pipes of underground tanks used to store used oil at generator sites must be marked with the words "Used Oil."
On August 24, 2017, the MPCA staff observed and documented that the Regulated Party failed to close a container of used oil. One 55-gallon container of used oil was stored with an open funnel. 

3.	Minn. R. 7045.0990, USED OIL FILTERS

	Subp. 3. Requirements for generators

A.	Used oil filter generators must store used oil filters in closed, leakproof containers labeled with the words "Used Oil Filters."

On August 24, 2017, the MPCA staff observed and documented that the Regulated Party failed to store used oil filters in containers that were closed and labeled with the words “Used Oil Filters.” Used oil filters were stored in a white plastic bucket without a lid and label. 

4.	Minn. R. 7045.0275, MANAGEMENT OF HAZARDOUS WASTE SPILLS.

Subp. 3. Spills; duty to recover. Any person who generates a hazardous waste that spills, leaks, or otherwise escapes from a container, tank, or other containment system, including its associated piping, shall recover the hazardous waste as rapidly and as thoroughly as possible and shall immediately take other action as may be reasonably possible to protect human life and health and minimize or abate pollution of the water, air, or land resources of the state.

On August 24, 2017, the MPCA staff observed and documented that the Regulated Party failed to recover as rapidly and thoroughly as possible hazardous waste that had leaked, spilled, or was otherwise not contained. Less than a liter of uncontained hazardous waste solvent was observed on the floor around the centrifuge. 

To address the alleged violations cited in this LOW, the Regulated Party is to complete the following actions within 15 days after receipt of this LOW:

1.	Submit photos of the two 55-gallon drums in the storage area stored closed with lid rings.

2.	Submit a photo of the 55-gallon drum of used oil with a latched funnel.  

3.	Submit a photo of the closed and labeled container of used oil filters. 

4.	Submit a photo of the cleaned centrifuge area.

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 218-302-6647 or raj.heck@state.mn.us if you have any questions about the LOW.

Sincerely,
Rajminder Heck
This document has been electronically signed.
Rajminder Heck
Environmental Specialist
Duluth Office
Industrial Division

RH:ss

cc:	Laura Piotrowski, Ramsey County Public Health
	John Elling, MPCA
	Brian Gove, MPCA
Activity ID NON20170001 @ 2556