About Water Gremlin
Water Gremlin manufactures fishing sinkers and battery terminals, and is located at 4400 Otter Lake Road in White Bear Township, Minnesota.
What was the problem at Water Gremlin?
In January 2019, the Minnesota Pollution Control Agency (MPCA) and the Minnesota Department of Health (MDH) investigated community exposures to trichloroethylene (TCE) emitted by Water Gremlin. The investigation showed the company failed to report accurate emissions data for more than 15 years. In addition, they violated their permit and exposed the surrounding neighborhoods to TCE levels above MDH’s health benchmark of 2 micrograms per cubic meter of air. Subsequent investigation has also found pollution in soil, surface water, soil vapor, and shallow groundwater near the facility.
What is TCE and how did Water Gremlin use it?
Trichloroethylene (TCE) is a man-made chemical that can be a liquid or gas. It is mainly used as a solvent in manufacturing to degrease metal parts. It can also be used in the production of other industrial chemicals. A variety of home products may contain TCE, including wood finishes, glues and adhesives, paint or paint removers, spot cleaners, and metal cleaners. Water Gremlin used TCE to clean and coat parts prior to assembly at other facilities.
What was the outcome of the investigation?
On March 1, 2019, Water Gremlin and the MPCA agreed on a settlement for violations of the facility’s air quality permit. This settlement included one of the largest penalties ever issued by the MPCA. The agreement allowed Water Gremlin to switch from TCE to an alternative product called FluoSolv WS, which uses trans-1,2-Dichloroethene (tDCE) as its main ingredient.
Is the company currently in compliance?
The company did comply with the requirement in the agreement limiting daily FluoSolv usage. They also are in compliance with the annual VOC emissions limit of 90 tons per year. They did not meet the required timeline for testing the control equipment after re-starting coating; they asked for and were granted two extensions, but when they requested a third, MPCA denied the request. Testing took place on July 23.
Can the MPCA shut Water Gremlin down?
The MPCA can issue an emergency order to a facility to stop operating some or all of its operations, without notice, in an emergency situation that poses an imminent and substantial danger to human health and the environment (Minn. Stat. § 116.11).
In 2019, the agency has temporarily shut down Water Gremlin twice in response to concerns about human health or the environment. On August 22, 2019, the MPCA ordered Water Gremlin to shut down the coating lines because tDCE (trans-1,2-Dichloroethene) was being released into the soil vapor beneath the building. The company’s coating lines remain shut down. The MPCA continues to closely monitor Water Gremlin’s compliance.
Will the MPCA issue Water Gremlin a new air quality permit?
The company submitted an application for a major amendment to its permit to the MPCA on Feb. 8, 2019. The MPCA does not expect to make a permitting decision until later in 2021, and will inform the public of opportunities to learn more about the permit and provide comments as it takes shape.
Water Gremlin applied for a minor amendment to its permit in 2020 in order to make changes at one coating unit. The amendment was released for public comment in December 2020, and will be incorporated into the more comprehensive permit update in 2021.
tDCE and other VOCs
Is tDCE safe?
While tDCE is considered a safer alternative than TCE, it is still an industrial chemical that has some potential health risks. The MPCA and MDH are responsible for reviewing the scientific evidence and setting health benchmarks and emission limits that are protective of human health for tDCE and many other industrial chemicals.
How is Water Gremlin controlling its tDCE use?
Anticipating community concern, the MPCA imposed stringent requirements on Water Gremlin’s tDCE usage, including preventing the company from using excessive quantities during the first few months while new pollution control equipment was being installed and becoming operational. During this period, Water Gremlin was required to reduce tDCE usage when concentrations measured in outdoor air exceeded an action level set in the agreement.
This action level is not associated with any short-term health benchmarks or emission limit and was never intended to extend beyond the start-up date (May 1) of the new pollution control equipment. The company is not allowed to exceed any health benchmarks or emission limits at any time.
How was the total VOC limit of 90 tons set?
Air quality permits fall into several categories under the federal Clean Air Act. These rules require permits in the “synthetic minor” category to stay under 100 tons of total VOC emissions in any 12-month period. If emissions will exceed that level, it kicks the permit into a different category, which can mean more requirements and fees. Therefore many smaller permittees, including Water Gremlin, choose to operate under synthetic minor permits in order to avoid the potential for additional complexity or cost. As an additional buffer, MPCA policy further limits total VOCs for synthetic minors to 90 tons/12 mos.
Is the company in compliance with the tDCE requirements?
Yes. Water Gremlin reduced its use of tDCE several times in March and April 2019, during the time that the pollution control equipment was being brought online. The company has not exceeded any emission limits for tDCE. MPCA has been working with Water Gremlin intensively over the past several months, and the company has made a number of technical modifications over that time. Final performance testing, which signifies the closing of the fine-tuning period, was completed on July 23, 2019. MPCA is closely monitoring how the tDCE levels collected at outdoor air monitors track with health benchmarks.
How are tDCE emissions controlled?
Water Gremlin is prohibited from exceeding a rolling 12-month limit for volatile organic compounds (VOCs, including tDCE) of 90 tons. Since May 1, 2019, the company has been monitoring VOC emissions directly with a stack monitor. The MPCA also monitors tDCE and total VOC concentrations in outdoor air around the site. Monitoring data is available at https://www.pca.state.mn.us/air/water-gremlin-air-monitoring.
Is Water Gremlin subject to a daily limit on tDCE use?
Under the terms of the stipulation agreement, the company was subject to a daily usage limit of 0.9 tons/day of FluoSolv WS (in which tDCE is the main component) from the time they re-started the coating operation on March 1 until the pollution control equipment began operating on May 1. Now that the equipment is operating, they are subject to the annual VOC limit of 90 tons/year.
Why are there spikes in the air monitoring data?
Air monitoring around the facility measures pollutant concentrations in outdoor air. It does not measure facility emissions directly. Ambient monitoring can be affected by a number of factors, including weather, humidity, wind direction, and the presence of other sources nearby. Consequently, an outdoor air monitor (“ambient monitor”) in a particular location may show higher levels of a pollutant than other nearby monitors. On May 1, 2019, the company installed a monitor in their exhaust stack to measure emissions directly at the source. Stack monitoring is a much more accurate method of tracking facility-specific emissions.
What chemicals will be sampled as part of the performance test?
The test was for emissions of VOCs (tDCE and 57 other VOCs). It accounted for inputs of VOC entering the pollution control equipment and outputs of VOC emitted from the stack. “Capture efficiency” is the percentage of VOCs that are recovered by the pollution control system.
Water Gremlin's pollution control equipment
How does MPCA verify that Water Gremlin’s pollution control equipment is working?
This equipment is checked by performance testing. During performance testing, the pollution control equipment is operated at the maximum production level the company anticipates using with the equipment functioning normally. A probe is inserted directly into the stack to collect and record emissions data. The test is performed by an independent engineering firm, and the data is submitted to MPCA for quality assurance review and a compliance determination. MPCA can use the results of this testing to develop limits in the company’s next operating permit.
Is the company’s pollution control equipment working as designed?
The purpose of performance testing is to check whether the equipment is effective at reducing air pollution from the facility’s emissions and to assure that it will work in all anticipated production scenarios. The performance testing completed in July indicated the pollution control equipment was capturing about 25 percent of the TCE emitted. While this is not as high a percentage as the facility hoped, the company is still bound to its 90 ton per year limit of VOCs.
Why did Water Gremlin receive extra time to test their pollution control equipment?
Water Gremlin was required to test the new equipment within 30 days of operating it. Additional testing requested by the MPCA, as well as troubleshooting and optimization of the equipment, led them to ask for an extension to June 27. MPCA granted this extension. Then, construction of additional pollution control components led them to ask for another extension to July 11. This extension was also granted. The company requested a third extension, which the MPCA denied. Performance testing occurred July 23.
Has Water Gremlin sought approval for a new solvent?
The new permit application MPCA received on August 30, 2019, indicates the company wants the flexibility to use a different solvent other than the FluoSolv WS (tDCE) it’s currently using. The MPCA will need more specific information before approving a different solvent.
What were the results of the investigation?
Water Gremlin completed the first phase of a remedial investigation in August, as required by the stipulation agreement. The investigation found lead on or in soils and subsoils on the property and in surface water and sediments in the ditch on the south end. VOCs were detected in the groundwater and soil vapor blow the building. tDCE vapors were found under the building’s slab at levels high enough to require expedited action to protect the indoor air of those in the building. Shallow groundwater on the property is contaminated with TCE but it is not used for drinking water and does not currently pose a risk to drinking water.
What are the next steps?
MPCA required Water Gremlin to install a vapor mitigation system in the building and they have begun doing so. They will be required to expand sampling of all media (soils, groundwater, surface water and sediment) outward until the extent and magnitude of the contamination is defined.
Is my property affected by vapor intrusion?
At this point there is no indication that vapor intrusion exists off Water Gremlin’s property, but further sampling will be done to confirm that. If it does, Water Gremlin’s environmental contractor will ask permission from neighboring property owners to “follow the plume” onto private property, if necessary. MDH sampled private drinking water wells near the site earlier this year and found no contamination.
Why wasn’t this contamination discovered during previous investigations?
This site was previously investigated twice for lead contamination, in the 1990s and again in the early 2000s. Lead was found on the surface and subsurface but was mostly below the screening levels in use at that time. A small area of lead-contaminated soil was excavated and removed. MPCA required the current remedial investigation in the stipulation agreement as a precautionary check.
With most environmental contaminants, the risk to a person is generally determined by the amount of exposure, duration of exposure, and the toxicity of the substance. Elevated levels of TCE exposure may increase the risk of certain types of cancers (kidney, possibly non-Hodgkin’s lymphoma, and liver) over a lifetime. Visit the Minnesota Department of Health's Water Gremlin web page for more information.
How can I find out more about this situation?
In addition to the information posted online, the MPCA and MDH send periodic updates to email subscribers interested in Water Gremlin. To subscribe, visit https://public.govdelivery.com/accounts/MNPCA/subscriber/new?topic_id=MNPCA_357 and follow the prompts.
You can also contact the MPCA or MDH at 651-201-4897 (leave a message for a call-back) or firstname.lastname@example.org.
If you wish to report an environmental complaint or concern, you may do so via our Citizen complaints form.