WHITE BEAR TOWNSHIP — A spokesman for Water Gremlin, the manufacturer sidelined for chemical emissions infractions, wants the community to know they are working to make things better.
“Water Gremlin has been here for 70 years. We’ve always pictured ourselves to be responsible environmental stewards,” professed Carl Dubois, vice president of international manufacturing. “When we got the information at the most senior levels that we have a historical emissions problem, we were mortified. We are responsible and we accept accountability for it. Most importantly, we’ve committed to doing everything to make it right.”
Part of that commitment has been finding an alternative solvent for the company’s battery terminal coating process.
On March 1, Water Gremlin agreed to stop use of trichloroethylene (TCE), a toxic chemical it spewed into the air for at least 17 years at levels that violated the company’s clean air permit. A switch to FluoSolv WS, a less dangerous solvent containing a chemical called tDCE, has not been the replacement it was looking for. In late August, the Minnesota Pollution Control Agency (MPCA) ordered the company to cease its coating operation after tDCE vapor was found under the plant floor.
According to Dubois, the company is looking at a water-based, wood emulsion product to replace the solvent. Its purpose is to inhibit corrosion until the battery is made, and it seems to be working.
Water Gremlin provides most of the terminal posts for batteries manufactured in North and South America. “There are few other sources,” said Dubois, who oversees manufacturing at the township factory and one in Italy. “Battery plants shut down when we can’t make shipments. They are feeling the ripples very quickly.”
As customers agree to use of the water-based product, Water Gremlin is busy retrofitting its coating machines.
But first things first. Before the company can resume operation, it must satisfy the MPCA that the tDCE vapor issue has been mitigated.
Water Gremlin has been working with an environmental consulting firm to construct a system that extracts the vapor. Work started Aug. 20 and the system is now operational, said Aaron Benker, resource manager for Maple Plain-based Wenck, an environmental consulting and engineering firm.
“We believe we’ve extracted what there was for vapor under the slab,” Benker reported, “but that doesn’t mean MPCA has greenlighted a coating restart.”
Dubois said the company is still trying to understand all the conditions for restart. “One of the things they want is to understand the coating room. Does it comply as a complete enclosure? Testing has to be done to demonstrate that.”
MPCA also wants more groundwater, sediment and soil vapor sampling done along the north property line. The soil vapor is done and reported to MPCA, but the water sampling is pending, Benker said.
Thus far, samples as prescribed by MPCA have come back showing no TCE or tDCE contamination.
“We expect groundwater to be the same,” Benker said.
Samples are analyzed by an independent third-party laboratory and sent directly to MPCA and Wenck.
Company planned to outsource
When Water Gremlin self-reported the emissions problem in 2018, there was a commitment the company would lead its customers to water-based and other nonvolatile organic compound (VOC) replacements as soon as possible, Dubois said.
FluoSolv is the product a Hudson, Wisconsin, company was going to use in a contractual arrangement with Water Gremlin to coat its parts. The company CEO changed his mind about the agreement after learning from local media the process involved unsafe chemicals.
Dubois said the plan to outsource was never a secret and told MPCA its plans Aug. 6.
“We sat down with MPCA Aug. 6 and explained that results of our pollution controls were not effective for tDCE. It was designed and built for TCE and had already been underway for five months when we agreed to stop using TCE. We told MPCA we had done everything we could to make it effective. We weren’t happy at 25% efficiency, so we were changing our plan. We said we were going to govern how much we use to stay under the annual 90-ton emission limit as a VOC by rapid conversion to water-based materials and by outsourcing. We never got to implement the outsourcing part.”
There’s no active plan to find another contract plant, nor are there active plans to relocate, Dubois added.
Question of timeliness
When asked why it took so long for Water Gremlin to self-report last year, Dubois said until 2018, the company believed it was in compliance with its air quality permit.
“In June 2018, a new environmental health and safety manager was hired. So now we have data coming in front of new eyes,” he said. “We couldn’t make that data make sense. As soon as we said, ‘this doesn’t look right, it doesn’t look good,’ we engaged a third party to help us investigate and create a voluntary self-report. That is what we turned in July 30, 2018.
“We did the right thing when the information came to light to different people. Self-reporting works. Rarely does a company nefariously try to hide their data. That was not the case here.”
The company is still working to make its pollution control equipment work. But as Dubois puts it, the equipment got demoted. “It doesn’t have to function as a pollution control device for us to stay under 90 tons anymore. That is what we explained to MPCA Aug. 6.”
Water Gremlin is amending its permit application to show its VOC usage at 90 tons without benefit of pollution controls.
As far as legacy pollutants, Dubois pointed out that Water Gremlin has been operating for 70 years, long before there were clean air acts to protect the environment. “We will never know the historic practices used in the ’50s and ’60s,” he said.
MPCA tested for TCE and lead in soil and shallow groundwater on the site in the ’90s, an investigation that closed in 2004. Wenck is using that data to compare new sample results.
“We use the data in our analysis: Are concentrations higher today or consistent?” Benker said. “I would say, and I believe MPCA is in agreement, most of the contamination related to TCE and lead looks very consistent. What does that tell us? That we’re not seeing new sources of contamination since last time that investigation happened.”
Benker maintains that levels of TCE contamination in groundwater and soil are quite low for the facility, especially given the duration of operation and use. “We’re not seeing anything from new sources,” he iterated.
Vapor intrusion values new
Only Minnesota and New York have vapor intrusion values for tDCE. “Minnesota developed it just for this site,” noted Benker. “There was no standard before that.”
Regulatory understanding of vapors has been emerging since 2004, the consultant continued. “So vapor assessment is generating data not comparable to past reports. The primary concern of vapor is receptors, or residential homes. As laid out on MPCA maps, new data is making sure vapor hasn’t migrated off the site and confirming that there isn’t a risk.”
Sampling for soil vapor will continue. Benker said the company is obligated to continue monitoring along property lines during the heating season, probably in November.
He also noted: Minnesota has some of the most stringent air quality and vapor standards in the country.
“We think of California as leading the nation in environmental regulations,” Dubois said. “They have a value of 600 micrograms per cubic meter for TCE. Minnesota has adopted 2 micrograms.
“We didn’t know that until we self-disclosed. Part of what they explained in January is here is the new air quality standard we’ve adopted of 2 micrograms. We’re like, ‘really?’ We could ask, ‘why weren’t users of TCE informed of that?’ When we assessed air modeling for a 95% pollution control efficiency to achieve 2 micrograms, the conclusion was we wouldn’t be able to do that. That is why we sought an alternative solvent. FluoSolv didn’t have an air quality standard, either, when we selected it, so MPCA, in order to be protective of public health, established one at that time.”
Area of health concerns
Asked about TCE health concerns by residents within a 1.5-mile radius of the plant (a perimeter established by MPCA), Dubois said the company regrets being cause for concern.
“We cannot characterize the incidence data. We look to the Department of Health just as much as residents do for guidance about historical exposure levels.”
The company vice president did not attend the Aug. 27 MPCA community meeting at Central Middle School but has watched parts of the video online. Asked what he thought about the assistant commissioner’s comment that Water Gremlin can’t be trusted to do the right thing, Dubois said the statement was “unfortunate.”
He contends that the company has worked closely with the regulatory agencies every step of the way. “We’ve met all their requests, so it’s frustrating to still be characterized that way,” Dubois said. “We’re just going to keep putting one foot in front of the other and continue to work cooperatively with them. We understand it’s part of the accountability. We’ve lost a lot of public trust and have to work to rebuild that.”
In the meantime, he said the company is committed to making VOC usage a thing of the past.
“We’re trying to demonstrate through our actions that we mean what we say. We’re dragging the rest of the battery industry with us to use non-VOC alternatives. We will get there. We won’t have problems with compliance like this in the future.”