In-depth Resources

Below are links to the official actions taken against Water Gremlin by regulatory agencies. Additionally, you’ll find information that will allow you to dig into TCE and other VOCs in a more technical fashion.

MPCA site – dedicated to the Water Gremlin issue.

MD Dept. Of Health site – dedicated to the Water Gremlin issue

9/30/2022: The American Journal of Public Health published a paper on the response to take-home lead from Water Gremlin. This is significant for multiple reasons. Here are two.

1) it suggests that case, tried in Ramsey county courts established legal precedent for other cases
2) it clearly documents the issue of take home lead and the impact on human health. (A total of 287 workers’ cars were tested; 219 (89%) cars had at least one initial dust wipe result greater than 40 µg/ft2. The highest initial lead level in a car was 42 000 µg/ft2.)

Published 8/1/2022: MAJOR PERMIT NOW OPEN FOR PUBLIC COMMENT: The major permit for Water Gremlin is now open for review. See this link for a summary of key elements of the permit, along with links to the permit and technical support documents. All comments are due by August 20, 2022 at 4:30 PM CT. The method of providing comments is super easy – just click on comments and start typing. UPDATE: Click here to see all of the comments that were submitted.

Published 8/1/2022: PUBLIC HEALTH ASSESSMENT: The MDH, based on very strong interest from the community, conducted a Public Health Assessment, to provide record of what has happened to citizens. You can find the draft version here. And, the final will also be here. (The public comment period has ended and comments are currently being reviewed, as of this posting in July of 2022.)

1,4-dioxane found in private wells win Gem Lake : See release from Mn Dept of Health here. Those impacted have been notified and MDH is working to get information out to the public.It is important to note that this is about 1.25 miles to the southwest of Water Gremlin. This testing does not say that the 1.4 Dioxane came from Water Gremlin–nor does it say it did not come from Water Gremlin. You may look at this map and say ‘Well…there’s nothing that says that this came from Water Gremlin, there’s lots of green next to Water Gremlin.” And, you may be right. HOWEVER, even the MPCA and the MDH is not sure of that. Wells in the area have been tested previously with nothing showing up in them. And, now 1,4 dioxane has appeared. Here’s what we know and why we are watchful.
1)We know that 1,4-Dioxane is an emerging pollutant, so be careful about looking at information about this with dates more than a year or two old.
2) 1,4-Dioxane has been found in the stream on the WG property that feeds into the ground water surrounding these wells.
2) 1,4-Dioxane is highly mobile in water, unlike other pollutants that have been found at Water Gremlin.
3) 1,4-Dioxane does not break down quickly in the water.
4) 1,4-Dioxane at life time values above 1 ppb can cause cancer. Other “smaller” exposures include kidney and liver damage, as well as cancer risk.
5) The homeowners of private wells that have tested above the recommended levels have been advised NOT TO USE THE TAP WATER FOR DRINKING
And, regardless of where the 1,4-Dioxane is coming from – as a community – we should be very concerned that it’s present in an area that does feed into our water supply and in an area that is highly populated.

April 2021, the MPCA and Water Gremlin settled a Stipulation Agreement outlining 23 violations – Fine of $325,000 imposed.

Despite oversight by the Minnesota Pollution Control Agency (MPCA), a company called “Water Gremlin” had longstanding violations of air quality regulations. We found that MPCA did not act on the company’s initial permit application in a timely manner; MPCA’s 2002 permit amendment did not effectively limit the company’s use of a hazardous chemical; MPCA did not require testing after 2002 of the company’s air pollution equipment; and MPCA did not inspect the company as often as it should have or make full use of the company’s self-reported emissions information.


The phasing out of TCE is well underway. To get an update on what is happening across the state, visit the MPCA site providing details on the phasing out of TCE across the state. You can also find a map showing the companies who are still using TCE. And, see our blog post dated 12/29/2020 with the current stats, as provided to us by the MPCA during one of our regularly scheduled stake-holders meetings.

Minor air permit amendment – open for public comment

Water Gremlin is proposing to convert one solvent-based coater to a non-solvent curing process using ultraviolet light. The proposed change will reduce potential emissions of volatile organic compounds, and increase potential emissions of particulates within allowable limits. Due to the increase in particulate emissions, Water Gremlin is required to apply for a minor permit amendment prior to making the change.

The MPCA determined that the minor amendment involved issues that are likely to generate significant
material adverse comment based on concerns raised by the public about changes at the facility. As required
under Minn. R. 7007.0850, subp. 2, D(2), on September 17, 2020, the MPCA notified Water Gremlin that the
minor amendment would be subject to the public notice procedures under Minn. R. 7007.0850, subp.
2(A)(1)-(3) and that because of this, Water Gremlin could not proceed with the change until the permit for
this modification is issued.
Find the notice, the draft permit and the technical support documents here:

May 2020 – here are links to information about tDCE and the new guidelines set forth by the MN. Dept. of Health.


March 4, 2020: Water Gremlin arguments in court as to why they should not pay to clean their workers homes of lead that was brought home, from the job site. The state will ensure that the homes are cleaned of lead coming home from Water Gremlin operations. It’s just a matter of who pays – Water Gremlin? Or Minnesota taxpayers?

Jan 30, 2020: The MCPCA released a Legislative Update on assessments done regarding the use of TCE in the state. Additionally, in a few short months, business in the metro area have been taking note of the increased concern over TCE and are working to make change in their production practices. Some good has happened. More is required.

Administrative Order Allowing Water Gremlin to being using tDCE again.

From notice sent on Jan 9, 2020.
The Minnesota Department of Health (MDH) has prepared maps of estimated TCE in air from the Water Gremlin facility for the years 2009-2018 based on air dispersion modeling from the Minnesota Pollution Control Agency (MPCA). The maps and additional description are available on the MDH website at Health Assessment Series: 2009-2018 TCE in Air Maps (PDF). The maps were created to provide a better understanding of estimated annual average TCE concentrations over time.

Issued to Water Gremlin after a series of inspections relating to the prior Administrative order and Stipulation Agreement. The Nov AO outlines a series of infractions regarding handling of contaminated waste.

Mn. Dept of Health and Dept of Labor and Industry took action on Wednesday, October 30th and shut down Water Gremlin for the max. 72 hours. This was after working with Water Gremlin since early January and, after 12 children of workers were found to have elevated levels of lead in their blood. DOLI petitioned the court to keep Water Gremlin shut down until issues with lead contamination and lead handling procedures were addressed.

Administrative Order served to Water Gremlin and shutting down solvent coating operations on Thursday, August 22.
Items of note include:
“The MPCA Is Extremely Concerned That Water Gremlin Is Actively Releasing tDCE And Has Not Already Stopped The Release.”
28: Water Gremlin’s remedial investigation should not have shown any tDCE concentrations in the soil vapor. Its presence in the soil vapor is alarming because all emissions in the coating room are required to be emitted through the stack, and not under the Facility.
29. The amount of tDCE discovered is of significant concern because Water Gremlin has only been using this new solvent since March 2019.
30. The RI Report also shows there is contamination of hazardous substances at the Facility, including TCE in groundwater and soil vapor and lead in surface water, soil, and sediment.
31: Water Gremlin has no control over the active release of tDCE.
32: Water Gremlin does not know the extent and magnitude of the unauthorized release from its Facility.
Please note: All of this text is copied directly from the Administrative Order. The words speak for themselves.

The stipulation agreement was signed on March 1, 2019 between the MPCA and Water Gremlin. Details on past activities are provided, including the back and forth between Water Gremlin & the MPCA on the amount of emissions. See page 9 for a summary of allowed emissions compared to actual, by year.

MPCA denies Water Gremlin extension to test Pollution Control equipment. If the testing did not happen on July 11, 2019, then Water Gremlin is subject to a $500/day fine.

The work plan was agreed to by the MPCA and Water Gremlin in May of 2019; as a requirement of the stipulation agreement. The work plan outlines all of the past MPCA/Water Gremlin investigations. The last portion of the document provides details on activities that will be completed by WENCK to determine the condition of the work site. NCCG has asked MPCA to work with Water Gremlin to also include testing of the wetland area, owned by Water Gremlin. (In addition to testing being done on Lambert Creek.)

The MPCA website contains several pieces of information, including the area of impact. It’s important to note that NCCG questions the impact zone as the data was provided by Water Gremlin and, from emails & other documentation received through the Freedom of Information Act, Water Gremlin did not retain necessary records. (Click on the link in text above to read the communication from Water Gremlin to the MPCA.)

As part of the stipulation agreement, Water Gremlin was required to install VOC monitors. These are put out every three days and samples are collected and an analysis is conducted by PACE labs. Data is sent directly from PACE to the MPCA. You can see the air monitoring graphics at the link above.

See above images for the upcoming process for the Water Gremlin Air Quality Permit.

MN Tap is working with Water Gremlin as part of the Stipulation Agreement and has recommendations for TCE alternatives.

MN Dept of Health website for Water Gremlin outlines the health issues associated with TCE. Additionally, it provides the results of reviewing cancer, birth defects and lead poisoning of citizens in the White Bear area, compared to the 7 metro county areas. NCCG believes that, while this may be the best data that exists, there are flaws in it and it doesn’t conclusively prove that our community health risk is not elevated due to the 17 years of excessive TCE emissions. See our POV here.

Also – of note. The MDH report does suggest that children of Water Gremlin workers have a higher incidence of lead poisoning.


TCE levels emitted by Water Gremlin may have exceeded Minnesota Department of Health standards since at least 2002 due to faulty pollution control equipment that deteriorated more quickly than expected. Dozens of people within about a 1.5 mile radius could have been exposed to the high levels of TCE.
Page 2 of meeting minutes from a discussion with Water Gremlin leadership and the White Bear Township board. Ultimately, more information would be made public and at least 5,500 people have been exposed to excess levels of TCE over a 17 year period.

To see how Water Gremlin notified White Bear Township of the problem during a Feb 22, 2019 executive meeting, visit the meeting minutes here. Page 2.