A great deal has happened during the past 15 months since we discovered our noncompliance and reported it to the Minnesota Pollution Control Agency (MPCA) on July 30, 2018.
We are working hard to improve our environmental performance, share updates regularly, and implement changes in our operations. We have committed to the MPCA and our community that we will continue to thoroughly assess all aspects of our operation and our property to identify and address any issues of concern. We will work with third-party experts and the MPCA to accomplish this assessment and share our work with our community. We are steadfast in our commitment to rebuild trust, protect our workers and our neighbors, and continue to be a productive member of the community.
Following are important details of activities that have transpired:
- Water Gremlin identified its noncompliance and voluntarily reported it to the MPCA on July 30, 2018. The MPCA website might cause confusion because it indicates that the noncompliance was discovered through a January 2019 “investigation” and does not mention the self-audit, voluntary disclosure and detailed information we shared with the MPCA between July 2018 and January 2019.
- Water Gremlin informed the MPCA in July 2018 that we planned to investigate and implement a transition away from using a volatile organic compound (VOC) coating process and toward a non-hazardous air pollutant and non-VOC process. We continue to work diligently to deliver on that commitment.
- On September 16, 2019, Water Gremlin issued a community update sharing that MPCA-approved testing showed no t-DCE or TCE vapor concentrations beyond the footprint of our building at levels representing concern or requiring action. Soil vapor results from locations selected by the MPCA nearest to residential homes indicated no concentrations above risk level of either TCE or t-DCE. The MPCA has had those full soil vapor test results since September 3, 2019.
- We have converted a portion of our operations to produce battery terminals with water-based coatings. This means that 40% of our battery terminal operations are VOC-free.
- Water Gremlin proactively communicated its plan to the MPCA to achieve compliance with air emission limits through pollution prevention rather than solely through pollution controls.
- When soil vapor testing showed vapors below our building slab, Water Gremlin responded to the MPCA’s concerns by voluntarily agreeing to cease coating with t-DCE until more information was gathered on the extent of any vapor concerns.
- To address vapor concerns, Water Gremlin took quick action to retrofit its equipment to improve vapor capture in the building and to capture and control any t-DCE vapors that might be in the air space below our slab. Those vapors are routed and captured in a carbon filter system, which has been operating since August 23, 2019.
Our priorities – listed in order – include (1) protecting people, (2) protecting the environment and (3) getting back to work to ensure employment for our 340 workers. We believe that priorities one and two have reached a point where we can resume full operations. We look forward to continued conversations with the MPCA and promise to share updates with you along the way.