PART THREE: In May of 2019, Water Gremlin launched a site to educate the community on their pollution control fines and what they were doing for the future. This is the third in a series of NCCG responses to their Frequently Asked Questions.
From Water Gremlin:
Q: What is Water Gremlin’s environmental monitoring process?
A: We have a comprehensive system to monitor outdoor air concentrations of trans-dichloroethylene (t-DCE) – a non-hazardous replacement solvent for TCE – with independent laboratory results reported directly to the MPCA. We measure our usage of t-DCE in real time, so we can make immediate adjustments if needed.
This is not a normal reporting process for companies with permits from the MPCA.
Because of the history of excessive emissions, the MPCA has required Water Gremlin to implement this on-site monitoring , including the VOC air monitors that pull air samples every three days and are monitored by PACE Laboratories. The MPCA is spending incremental resources to monitor and report the VOC emissions; as well as discuss with the community the results.
Also – while the EPA does not classify t-DCE as a “Hazardous Air Pollutant”; this does not mean that t-DCE is not a hazard to human health. T-DCE is not a well-studied chemical. In addition, t-DCE is listed on the TURI (Toxics Use Reduction Institute) list of toxic or hazardous substances. “Toxics Use Reduction Program cautions companies that certain alternatives to TCE also present significant hazards to human health and/or the environment.”
It’s of note that; as DCE is not well studied, air quality testing may not result in actually protecting the public’s health. (We know what the levels being emitted are, yes. But, even the MDH has agreed verbally, that there is a lack of research. And more research on t-DCE would be preferable; for the protection of human health.) Further, “…there is sufficient evidence in experimental animals for the carcinogenicity of 1,2-dichloroethane”. For more details, click here.
From Water Gremlin:
Q: Does Water Gremlin use a pollution control system, and how can you be sure it is working?
A: We are in the process of installing a pollution control system, and we will conduct recurring performance tests to ensure that it is working properly.
Water Gremlin’s former air permit also dictated that a pollution control system be in place.
However, in January of 2018 the MPCA found the pollution control equipment was not working properly and, Water Gremlin had been making unreported releases of pollution since 2002, presumably due to failures of the former pollution control equipment. (Read Stipulation Agreement for details on the number of times the equipment was reported as ‘not working’.)
“Our concern is that this has had some health impacts on people in the community,” said Jeff Smith of the Minnesota Pollution Control Agency (MPCA). …The facility was checked several times a year throughout this time period, but investigators didn’t notice the flaw and the company didn’t report it. “We expect that a facility as sophisticated as they are ought to know their pollution equipment is not working,” Smith said.CBS News story, 2/22/2019; hyper-linked above.
NCCG, including members of the White Bear area community, is watching the additional monitoring results being provided as part of stipulation agreement and are actively engaging in discussions with regulatory, local government and legislatures to help to ensure that the new pollution control is working properly and not emitting excessive pollution.
Additionally, we are advocating for additional VOC air monitors to be installed in the community to better ensure our safety from not only Water Gremlin manufacturing, but also the surrounding manufacturing operations.
All referenced FAQs from Water Gremlin are copied and pasted directly from their website as of June 14, 2019. Our responses based on facts (cited) and our point-of-view (POV) . Our POV is based on an assessment of facts, advice from independent third-party experts and our own experiences.