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.
NOV 6, 2019 MPCA ADMINISTRATIVE ORDER
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.”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.
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.