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WATER GREMLIN PUBLIC HEALTH ASSESSMENT: PUBLIC COMMENT DRAFT A. Past TCE Air Emissions Water Gremlin TCE Use History Water Gremlin used TCE in,a product. coating process. According to a Water Gremlin air permit application, BTPs from die-cast machines were coated to provide an acid -resistant; leak -proof seal between -the BTPs and battery .cases. The coating solution, which contained TCE, was applied to BTPs by spraying or dipping (Braun; 1999), in a Phase I Environmental Site Assessment conducted in 1995; representatives of Water Gremlin:stated that the coatings had.bee nused since approximately 1985, and that the production of BTPs increased dramatically around 1990 (Braun, 19.55). The re po rt..cites 1992 installation dates for'four above ground storage .tan ks for TCE and mentions another solvent, 1,1,1- trich loroethane (1,1;.1-TCA),. was used prior to TCE (Braun,.1995). The U.S.. Environmenta[ Protection Age ncy.(EPA) Toxics Release Inventory Program data .(provided by Water Grem 11n) indicates that Water Gremlin switched from 1,1,1-TCA to TCE in 1992.(U.S, EPA, 2019a), It is assumed that the.1,1,1-TCA use also resulted in air emissions and potential exposures during the..time:of its use. Water Gremlin is subject to the federal Clean Air Act (through. revisions signed into law in 1990) as well as Minnesota air permitting rules. They submitted anair permit application to. MPCA in 1995 and referenced a.1995 due date for the.application.under the new federal and state air quality rules. In their permit application, Water Gremlin provided their 1994 actual TCE emissions as 119. tons/year. In 1999, they submitted.a new permit application; which stated: that they reduced TCE emissions through pollution .prevention efforts frorn.87 to in 1996 to 53 to in 1998. The purpose of the 1999. Application was to install additional coating machines. and air pollution control equipment to.capture And destroy at least 95% of theirTCE emissions. Water Gremlin received an MPCA air permit in July 2000, which required the installation of a catalytic oxidizer,;With enforceable operating conditions to d.e.stroy atleast 95% of the. TCE eni issions from `the: coating process. Although the catalytic. oxidizer was: installed in August .200O, the..company discovered that the equipment was not working in. November 2000 while attempting to conduct performance testing. They tried to fix it for a number of months,. but ultimately decided to replace it With a different type of control equipment. Rather than destroy TCE emissions,.Water Gremlin applied for an air permit amendment in 2001 to install a fluidized bed recovery system to recover the TCE. MPCA issued a new permit in April 2002 and required a reduction of emissions of at.least 95 percent. A removal efficiency of 98.8% was reported from the performance test conducted that month. But weeks .later, a breakdown was reported, followed by additional breakdowns that summer. In February 2003, the recovery system was rebuilt and put back into operation. According to MPCA records, Water GremI)n.reported multiple shutdowns and breakdowns of the pollution coMrolequipment over subsequent years. Water Gremlin disclosed permit violations to.MPCA in July 2018. MPCA:discovered .(MPCA,.2019) that Water Gremlin likely never met 95% control of emissions and were reusing the. recovered TCE. As a result, Water Gremlin greatly exceeded the intended. permit limit of 9.5 tons -of TCE emissions a year. MPCA requested that Water Grem Iin.shu.t .down operations that emitted TCE.on Jan u a ry. 14,2019 and. Water Gremlin agreed to voluntarily shut down that day. In February, Water Gremlin committed to permanently discontinuing the use of TCE and removed the. remaining TCE. from their facility. What Happens to TCE in the Air? When TICE is emitted as a gasintothe air, It: spreads out and mixes in all directions. It breaks down in a matter of days to weeks. Local weather conditions affect the speed and direction of TCE movement. WE