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 Water Gremlin’s violation?
In January 2019, the Minnesota Pollution Control Agency (MPCA) and the Minnesota Department of Health (MDH) investigated community exposures to 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.
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 valued at more than $7 million, 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 DCE (trans 1,2-Dichloroethylene) 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. 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.
Will the MPCA issue Water Gremlin a new air quality permit?
The company submitted an application for a new permit to the MPCA on February 8, 2019. The new permit will contain requirements for all emissions from the facility, including DCE. MPCA staff are developing the permit and expect to have a draft version ready for public comment in Fall 2019. The MPCA will inform the public of opportunities to learn about the permit as it takes shape.
DCE and other VOCs
Is DCE safe?
While DCE is considered a safer alternative than TCE, it still 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 DCE and many other industrial chemicals.
How is Water Gremlin controlling its DCE use?
Anticipating community concern, the MPCA imposed stringent requirements on Water Gremlin’s DCE 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 DCE usage when concentrations measured in outdoor air exceeded an action level set in the agreement.
These action levels are not associated with any health benchmarks or emission limits and were never intended to extend beyond the start-up date (May 1) of the new pollution control equipment. The company must use larger quantities of DCE under operating conditions to properly test the equipment. Even so, the company is not allowed to exceed any health benchmarks or emission limits during the testing period.
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 DCE requirements?
Yes. Water Gremlin reduced its use of DCE in March and April 2019, as the MPCA required. The company has not exceeded any emission limits for DCE. 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 DCE levels collected at ambient air monitors track with health benchmarks.
How are DCE emissions controlled?
Water Gremlin is prohibited from exceeding a rolling 12-month limit for volatile organic compounds (VOCs, including DCE) of 90 tons. Since May 1, 2019, the company has been monitoring VOC emissions directly with a stack monitor. The MPCA also monitors DCE 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 DCE use?
Under the terms of the settlement agreement, the company was subject to a daily usage limit of 0.9 tons/day of FluoSolv WS (in which DCE 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 working toward optimizing it, and are subject to the annual VOC limit of 90 tons/year.
Why are there spikes in the 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 is for emissions of VOC (DCE and 57 other chemicals). It accounts for inputs of VOC entering the pollution control equipment and outputs of VOC emitted from the stack. “Capture efficiency” is the portion of VOC that is 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 stack test is performed by an independent engineering firm, is observed by MPCA staff, and the data is submitted to MPCA for quality assurance review. MPCA will use the results of this test to develop the DCE 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. Installing the new equipment is not as easy as just flipping a switch, and since operating it on May 1, the company has been working to optimize the equipment.
Companies routinely test their equipment for higher performance demands than they ever intend to use. This is because their permits include “headroom” so that they do not get in a situation of being up against their emission limits. The limits that are written into the permit are protective of human health and the environment.
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.
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 email@example.com.