An Ohio Environmental Protection Agency audit has documented broad deficiencies in Galion’s oversight of industrial wastewater, including years without City-conducted sampling, expired industrial discharge permits and an enforcement plan that could not be located and was not being implemented. The 46-page audit was conducted July 15 and 16 and transmitted to the mayor and City Council on August 14. Ohio EPA reviewed the City’s sewer-use ordinance, examined industrial-user files and visited two of the three significant industrial users regulated through Galion’s approved pretreatment program.
Those three users are Carter Machine Co., A&G Manufacturing and Galion, LLC.
The City of Galion’s response and the original Ohio EPA letter and supporting material are both below.
What the audit examined
Ohio EPA’s pretreatment program regulates industrial facilities that send wastewater into publicly owned sewage-treatment systems. Galion is responsible for identifying significant industrial users, issuing permits, reviewing monitoring reports, conducting its own sampling and inspections and enforcing applicable requirements.
I is important to note that this is not a drinking-water audit. It concerns industrial wastewater entering the sewer system and the City’s treatment plant. The audit also does not report that the deficiencies caused pollutants to pass through the treatment plant or interfere with its operation. Section I of the checklist reports no known industrial-discharge incidents involving interference, pass-through, fires, explosions, structural damage, excessive pollutant concentrations, toxic fumes or worker-safety problems. It does not state that Galion’s treated discharge violated its NPDES limits. The document therefore establishes failures in the system intended to detect and address industrial noncompliance. It does not establish that those failures produced contaminated drinking water or environmental harm.
Sampling and inspections had lapsed
Page 2 of Ohio EPA’s August 14 letter states that Galion is required to sample and inspect each significant industrial user at least once a year. According to the audit, the City had not sampled those users since 2022 and had not inspected them for an “indeterminate amount of time.”
The City mailed industrial-waste surveys to suspected users in January 2025 and again in March 2026. The audit states that the City had not followed up in person with businesses that failed to respond or supplied inadequate information.
Ohio EPA also noted corrective work. Page 1 says the City had updated several forms, made changes to its permit document and hired a consultant after the previous inspection because of what the agency described as “inadequate implementation” of the program. The City plans to assume day-to-day administration after the new wastewater superintendent is fully trained.
An ordinance still rooted in 1990
The audit found that most of Galion’s sewer-use ordinance has not been updated since 1990. Page 2 states that a majority of federal pretreatment requirements adopted in 2005 had never been incorporated. Missing provisions involve such matters as significant noncompliance, best-management practices, representative sampling and the handling of discharges that could suddenly send unusually concentrated pollutants into the sewer system. The audit’s legal review identifies numerous definitions and permit, reporting and sampling provisions requiring revision.
Ohio EPA also found that Galion’s ordinance lists a copper limit of 3.2 milligrams per liter instead of the approved 0.652 milligrams per liter. The number in the ordinance is nearly five times the approved limit. The audit identifies this as an error in the City’s legal standard; it does not state that wastewater containing copper at that concentration was discharged into the plant.
The City submitted an Enforcement Response Plan to Ohio EPA in 1990 but could not produce it during the audit. Section I states that the plan was not being implemented. Section III describes effective enforcement as “inadequate” and “not occurring.”
Two industries lacked current permits
Page 3 summarizes the status of the City’s three significant industrial users. It states that Carter Machine Co. has a permit that became effective December 1, 2025. Its previous permit expired in January 2024, and its renewal application was submitted in May 2025. Ohio EPA reported that Carter had completed its required sampling and reporting. Also A&G Manufacturing allegedly did not have a current permit. Its previous permit expired June 22, 2025, and an application submitted three months earlier had not resulted in a new permit. The audit states that no sampling had occurred since the previous inspection.
Galion, LLC’s permit expired February 1, 2022. The company submitted a renewal application that May, but page 3 states that the application was “lost by the City.”
Galion, LLC had conducted sampling, but the results were not routinely submitted. Laboratory forms were supplied in May 2026 after the City requested the missing information.
The audit also identifies a January 2026 zinc violation that was not resampled within the required 30 days. The detailed checklist states that later quarterly sampling showed the company back in compliance for zinc.
Required public notice did not occur
Ohio EPA determined that A&G Manufacturing and Galion, LLC met the definition of significant noncompliance because of failures to submit required self-monitoring reports. Galion’s ordinance does not contain an updated definition of significant noncompliance, and the City had not applied that classification or published the required public notice. On page 4, Ohio EPA states that both companies would have been required to be identified publicly if the proper state definition had been applied. The classification cited by the audit concerns reporting failures. It is not a finding that either company caused pollutants to pass through the treatment plant or created an ongoing environmental emergency.
Several recommendations had been made before
Ohio EPA issued 12 recommendations but expressly stated that they were “not Orders.” Five appear in bold because they had also been included in previous inspections. Those repeated recommendations concern maintaining an accurate inventory of industrial users, verifying important discharge information during inspections, including all approved local limits in permits, keeping every significant industrial user under a current permit and ensuring that required sampling and monitoring reports are completed. The remaining recommendations include resuming annual City sampling and inspections, adopting the missing 2005 federal requirements, revising the sewer-use ordinance, correcting the copper limit, updating the Enforcement Response Plan and collecting required reports from dental offices.
The audit does not impose a completion schedule or state that Ohio EPA has begun formal enforcement proceedings.
The checklist estimates that Galion was devoting the equivalent of 0.58 full-time positions to the program, including 0.5 for the consultant, with an annual operating budget of approximately $50,000. It anticipates that spending will decrease when the City no longer relies on the consultant. The document also states that the City is willing to provide funding and that the consultant will assist until City personnel are sufficiently trained.
The City responds
1831Galion gave the City advance notice of this coverage and invited it to respond in whatever manner it considered appropriate. Safety-Service Director Nicole Ward’s response is published in full below, without change.
1831Galion has also requested records concerning the 2024 inspection, the City’s corrective actions, subsequent sampling and inspections, current permits and proposed updates to the ordinance and Enforcement Response Plan. Those records had not been received at the time of writing. This story will be updated as additional records become available.
Finally, the entire communication from the Ohio EPA can be ready below Ms. Ward’s response.
City of Galion’s response
The City appreciates the opportunity to respond.
We have been working with Wessler Engineering over the last 18 months to make necessary changes to the industrial pretreatment program as a whole. This work was initiated after an audit by the Ohio EPA 2024 with a goal of bringing it into full compliance.
The EPA’s recent regularly-scheduled audit pointed out additional work that still needs to be completed. However, we have made progress and continue to do so. This includes:
- Sending Industrial Waste Surveys to every commercial user in town to ensure we have an accurate list of all required permittees in the City.
- Providing new permit applications to those industrial users whose permits have expired and inspecting each facility in person to confirm processes haven’t changed and each is compliant.
- Updating our sewer ordinance to be compliant with all current EPA mandates and limits. A draft has already been created with further updates to be made after our recent audit was concluded. We anticipate that being submitted to council for passage by year-end.
The City is working closely with the Ohio EPA, Wessler and local businesses to ensure the program meets all requirements and that all OEPA requirements are followed when the program is fully implemented. Our new superintendent intends to oversee the program internally. It is important to note there were no violations noted during their visit, only recommendations.
It is also important to point out that there is no evidence that any permittee was discharging any industrial waste during any period when their permit was expired. Carter Machine and Galion, LLC continued to perform their regular testing and reporting even without renewed permits. Galion, LLC has submitted their application since the time of OEPA’s letter and we are working closely with A&G Manufacturing to determine their status as an industrial user.
While we are aware our industrial pretreatment program still requires updates, we are confident we are moving in the right direction with the assistance of OEPA, Wessler Engineering and our community partners.
Again, we appreciate the opportunity to respond and are happy to provide additional clarification if requested.