2019 Vol.13 Issue 2 April - Laserfiche WebLink

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Gem Lake News Page 2 of 6 Much of the documentation dated to a time when the records were not available electronically. This required hands-on research through many boxes of records, looking for orders for TCE. In December of last year, the MCPA was informed that WG had not achieved the required 95% control of emissions that was required since at least 2009 and that control equipment was running with unknown efficiency. From December of 2018 through January of 2019, WG exchanged emissions information with the MPCA. On January 11 of this year, WG informed the MPCA that the levels of TCE emissions released varied from time to time between a number that was higher than 5% to complete failure of the scrubbing equipment that was supposed to prevent more than the permitted amount of emissions to be released into the air. The response of the MPCA was to allow them to voluntarily and immediately cease the use of TCE in their operations. (TCE is used as a degreaser in the manufacturing process.) The alternative to a voluntary shutdown would have simply been mandatory shutdown through a formal order from the MPCA. The voluntary shutdown of the production line using TCE happened on January 14, 2019. What are the risks based on the data? TCE is one of the most studied industrial chemicals in use today. It is used primarily to degrease metal parts, but is also found in many household products such as adhesives, paint removers, etc. High levels of exposure to airborne TCE can increase percentages for certain cancers in humans (kidney cancer, non-Hodgkin’s Lymphoma, liver cancer). Several variables go into a person’s risk of contracting an illness. These variables can include an individual’s genetic inclination to get a disease, the length of exposure and the intensity of that exposure. Even with intense exposure to risk factors, a person does not always become ill. My grandmother, for instance, smoked from her teen years to her death in her mid-80’s, without contracting lung cancer. The Minnesota Department of Health estimates that airborne levels of TCE could have been as high as 200 micrograms per cubic meter of air at the locale closest to the facility, which is based on 2018 use, projected to be the highest levels. The Minnesota Department of Occupational Safety and Health sets the allowable level of voluntary exposure to airborne TCE to be 270,000 micrograms five days per week, eight hours a day. While the Minnesota Department of Health sets the levels Gem Lake Responds to Water Gremlin Issue (continued from page 1) of involuntary exposure to TCE, there are several metrics to keep in mind: lifetime and short term exposure. The lifetime level is currently set at 2 micrograms per cubic meter of air. This lifetime exposure would theoretically result in one additional case of cancer out of 100,000 people. The Minnesota Department of Health looks at historical data and assigns general risk of cancer at 45% of Minnesotans likely contracting some form of cancer in their lifetime. This is a general statistic that accounts for exposure to all types of risks, not limited to TCE. In theory, if 45,000 out of 100,000 in Minnesota were exposed to TCE for a lifetime, the cancer statistic could rise to 45,001. Short term exposure is considered incidental and transitory, such as airborne exposure as you are driving through the area. On January 1, 2018, the MPCA announced that the short-term exposure level was going to be reduced from 2,000 to 2 micrograms per cubic meter of air, effectively an unattainable level. Once the new guidelines were announced WG began researching options. It was concluded that even a 75-foot-high stack would not be sufficient to attain the goal of 2 micrograms. While the company was researching alternatives, data revealed that WG’s consumption levels of TCE were excessively high. The permit WG was acting under required 95% of the TCE being used in manufacturing to be recaptured by scrubbers, allowing 5% to be released into the air. Water Gremlin consumption level was estimated by replenishment orders and was revealed to be significantly higher. This prompted WG to notify the MPCA of permit violations in the summer of 2018. Settlement with the MPCA a.k.a. The Stipulation Agreement There was much made of the short time in which the MPCA and WG came to agree to terms and form a Stipulation Agreement (SA). It is the position of the MPCA that the short duration from the time shutting down operations to the resumption of operations is a good thing-and they have valid points. It allowed the MPCA to conduct significant WG oversight. It saved the State of Minnesota from having to pay for a (continued on page 3)