Questions were asked in 2012 about Water Gremlin.

Conclusion: The community member was told to worry more about bonfires and car pollution.

Community members were recently asked if we supported Rep Fue Lee’s proposed legislation – MN House 508. The bill would require companies with non expiring permits to have meetings with the MPCA and the community every 5 years to discuss their operations and any questions or concerns that the community may have. We do support this and several in our community either submitted letters of testimony or testified in person.

Below is testimony written by a local citizen who was concerned about TCE emissions from Water Gremlin in 2012. In 2012, she had recently moved to the White Bear area, under the shadows of Water Gremlin and noticed her family members started to experience new, unexplained health issues. She was persistent, in her questioning, as documented below. She was repeatedly brushed aside by both the MPCA and Water Gremlin. It’s possible that if her questions had been asked in a formal setting, they might have been listened too.

Feb. 15, 2021

Dear Representatives,

I am writing to you as a longtime resident of White Bear Lake who expressed written concerns regarding Trichloroethylene (TCE) air emissions to Water Gremlin and the MPCA in February of 2012.  (Of note – I have retained original email documentation, which is likely also on the record at the MPCA.) More specifically, on February 7th, 2012, I sent an email to Water Gremlin with the following questions:

… Can you share with me any data or information you have on what the actual amount of TCE emissions are from Water Gremlin’s White Bear Lake facility? And how often the substance is emitted from the premises? Also, what type of capture/reduction system do you have in place currently? Lastly, do you have any air quality data you can share?

The response I received, in part, reads:

I can tell you that we are compliant with our air emissions permit, we are considered a synthetic minor source in regards to emissions by the state of Minnesota, and our carbon adsorption control system captures 95% + of our TCE emissions. – Dave (last name removed).

The reason I inquired about Water Gremlin, is that a news story on TCE and neurological disorders, caught my attention. (I have a family member who was diagnosed with a chronic neurological condition which may be related to TCE exposure.) After doing some digging, I found that Water Gremlin, a company located near me, had a history of emitting a large volume of the substance into our air.

Is there a connection between our family health issues and area TCE emissions? I don’t know. But I believe it’s likely and I don’t appreciate the possibility, regardless.

I remain discouraged that residents of White Bear Lake and beyond are to ultimately rely on ‘self-reporting’ vs. meaningful regulation via hard scientific data, regular surprise audits and air quality testing. In fact, I raised the following questions in response to Water Gremlin, in my 2012 exchange:

…  What kind of testing is done to ensure the 95 percent capture, and what is the end result in terms of TCE emissions output? Also, does Water Gremlin have any data on the levels of TCE in the ambient air surrounding your facility?

I do not recall a written response from Water Gremlin. However, the MPCA did provide air quality modeling data in a reply, which I’ve touched on below. In their response, the MPCA cc’d Water Gremlin, asserting among other things, that I should me more concerned about an occasional bonfire, than Water Gremlin’s TCE emissions:

Neither the MPCA nor EPA have air quality “standards” for TCE and other air toxics. In Minnesota we take actions, if we believe they are required, under our general authority to ensure air that is safe to breathe. EPA toxicity values are one of the tools we use to determine such safe levels, but we use those tools after carefully considering the evidence upon which they are based.

Let me reiterate what I tried to say earlier. Living a mile away from this facility, the inhalation risks to you and your family are extremely low.

In contrast, the inhalation risks you face from emissions to the air from vehicle traffic on roads and from combustion in your neighborhood (especially things like fireplaces, outdoor burning, wood stoves, outdoor wood boilers, stationary diesel engines, etc.) are many orders of magnitude higher than the risks from this facility.… ~ Greg (MPCA)

The MPCA response was appreciated but frustrating and ultimately proved questionable when it came to TCE inhalation risk being ‘extremely low’.  Additionally, my apprehensions proved valid. I responded to Greg at the MPCA and listed a portion of my reply below:

While I appreciate and share your concern about air quality in general, I am not ready to reject TCE emissions as a potential source of risk for my family simply because other risks exist. I am also concerned for other families in the area, who live closer to the facility. …If it’s of interest to you, part of the reason this facility remains a concern for me personally, is that the other issues you mention (while valid) are a changing source of impact. … The TCE emissions at Water Gremlin are a regular source of the same chemical, day after day. Further, the EPA has reclassified the chemical, considering it “more dangerous than previously thought.” Not to mention, the numbers used for your model are entirely based upon what the company reports to be true, and the facility hasn’t been inspected since 2004.

Shortly thereafter, the MPCA agreed to inspect Water Gremlin (at my request) and reportedly found no significant issues. While I’m grateful that my inquiry prompted the 2012 inspection, I am displeased that no significant issues were discovered at that time, given what we now know.

Also, of note, in the year 2000 (Citizen Name) (a resident located in the ‘area of concern’ prior to it being deemed so) expressed trepidation about Water Gremlin’s use of TCE and other potential hazards. (See attached document entitled MPCA’s response to (Citizen Name) in 2000.) In the document, the MPCA response to (Citizen Name), in part indicates:

Alternatives to TCE that were considered were either cost prohibitive (up to $5,000.00 per drum), or flammable (acetone) which could cause excessive risk to employees and the adjacent community.… 

The pollution control equipment will destruct at least 95% of the TCE evaporated in these processes.

MPCA believes that by issuing this permit, there will be a net benefit to the environment.

In addition, Water Gremlin has been formally accused of firing employees who refused to violate safety and environmental laws:
https://law.justia.com/cases/minnesota/court-of-appeals/2008/opa071615-0902.html

Thus, I continue to take little comfort in trusting companies to do the ‘right thing’ by self-reporting, when the ‘right thing’ is subjective. For example, some may consider saving time and money to be more important than protecting employees and a community. Others may resent regulation and find a way around it – if a way exists.

In hopes to address Water Gremlin on an ongoing basis, vs. perpetually review permit requests and emissions reporting, I’ve asked that a permanent air quality monitor be installed in the area. My request was considered, but ultimately denied by the MPCA due to ‘funding’.

In closing, I do appreciate the progress that has been made along with enhanced oversight. But the bottom line remains the same. I ask again, almost a decade after my original inquiries (and two decades after residents like (citizen name). expressed concerns) … with no scientific, measurable, air quality testing and regular verification of ‘self-reported’ air quality related data, how can we have confidence in the system designed to protect us? And, if it’s a question of adequate staff and funding, let’s provide the MPCA with the necessary tools and funds to act in accordance with their stated mission.

Thank you kindly for your efforts.

Sincerely,
(WBA Citizen)

*Note – names have been omitted from this post for privacy.