Marion Watch

TOXIC TIDES III: HOW OHIO EPA SANITIZED GALION’S CHRONIC SEWAGE BYPASSES, ERASED FEDERAL OVERSIGHT, AND LEFT A CITY POISONED

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When a municipal utility grid collapses, raw human waste floods residential basements, industrial heavy metals leach into the soil, and carcinogens flow through household taps.

When the state regulatory agency tasked with protecting the public steps in, its statutory duty is to enforce the law.

In Galion, Ohio, the state regulator did the exact opposite: it laundered the city’s paperwork.

On September 25, 2026, Ohio EPA Director John Logue entered a final action into the Director’s Journal, officially issuing National Pollutant Discharge Elimination System (NPDES) Permit Modification 2PD00030*RD (Application No. OH0025313) to the City of Galion, effective October 1, 2026.

On the surface, the modification reads like routine bureaucratic maintenance.

In reality, it is the final execution of the administrative maneuver exposed by Marion Watch earlier this summer: the Regulatory Shield.

Buried on Page 5 of the Ohio EPA’s accompanying Fact Sheet is a written admission of regulatory complicity: the state officially deleted the past-due “No Feasible Alternatives” (NFA) bypass elimination schedule and the municipal pretreatment schedule directly out of Galion’s federal discharge permit.

The state did not fix a single pipe.

It did not stop the raw sewage bypasses.

It did not fully remediate the lethal workplace safety citations, the $41.63 million wastewater plant collapse, or the six active Safe Drinking Water Act violations at the water plant.

It simply erased the public permit schedule that was flagging the city as a chronic violator in Washington, after coaching the city on how to do so.


The Fact Sheet Confession: Scrubbing the Federal Dashboard

To understand the severity of what the Ohio EPA just did, residents need to understand what regulators mean by the “Federal Dashboard.”

Under the federal Clean Water Act, the U.S. EPA operates a nationwide public tracking system known as ECHO (Enforcement and Compliance History Online) and an internal federal database (ICIS-NPDES). Think of this system as an automated national credit report and alarm board for every municipal utility in America—monitored by federal prosecutors in Washington, U.S. EPA regional enforcers, environmental watchdogs, and the public.

When a city’s federal discharge permit contains a Schedule of Compliance—a binding timeline of mandatory engineering and construction deadlines to stop illegal pollution—the federal computer system automatically tracks every deadline on that list. If a city blows past a mandatory report deadline by 30 days or a construction milestone by 90 days, the federal database automatically trips an alarm, flagging the facility in Significant Noncompliance (SNC).

Galion was hopelessly trapped in SNC status, with good reason.

The city missed its April 1, 2024 deadline to submit a “No Feasible Alternatives” (NFA) analysis to eliminate unauthorized plant bypasses, and blew past its legal deadlines to submit its 1st Report of Construction Progress (due April 2025) and 2nd Report of Construction Progress (due April 2026).

Rather than enforcing the permit, the Ohio EPA handed municipal leadership an administrative eraser.

In a July 1, 2026 inspection report, state regulators issued Recommendation #2, explicitly advising Galion to apply to remove the overdue compliance schedule from its permit and coaching officials that “taking this step will help the facility resolve its current SNC status.”

The city followed the state’s instructions to the letter. In the formal modification application submitted by newly hired Wastewater Superintendent Renee Bodkins, the administration admitted its motive in writing: “Requesting that the Schedule of Compliance be removed from the permit to keep Galion out of significant noncompliance.”

On September 25, 2026, the Ohio EPA granted the request. Page 5 of the Fact Sheet states:

“This permit modification proposes to remove the section named ‘A. Bypassing: No Feasible Alternatives Analysis and Schedule’ in Part I,C Schedule of Compliance in the current permit. The removal of this section is warranted as the overdue milestones are now covered by Director’s Final and Finding Order’s (DFFO’s) issued on November 6, 2025. Section ‘B. Municipal Pretreatment Schedule’ in Part I,C Schedule of compliance is being removed in this modification as well.”


GALION, OHIO EPA FACT SHEET


On the Permit vs. Off the Permit: What Changed on October 1, 2026

Moving a compliance schedule out of a federal permit and into a localized state order (a DFFO) is not a harmless clerical update. Look at the real-world difference between keeping those deadlines on the permit versus taking them off the permit effective October 1, 2026:

  • What Having the Schedule ON the Federal Permit Did (Before Removal): As long as the bypass and pretreatment deadlines were written inside Galion’s federal NPDES permit, the U.S. EPA’s automated system kept a bright red SNC warning light flashing over Galion on national oversight screens. Those unresolved red flags also hurt the Ohio EPA’s own federal enforcement scorecard, creating mounting pressure for federal regulators to step in and investigate why the state hadn’t forced repairs. Most importantly, because those deadlines were part of a federal permit, the Clean Water Act gave everyday citizens and downstream property owners the legal right to file a federal Citizen Suit in U.S. District Court to enforce those missed deadlines and demand a federal judge take control of the cleanup.

  • What Having the Schedule REMOVED Actually Does (Issued Sept. 25, Effective Oct. 1): By deleting Part I,C Schedule of Compliance from the federal permit and shifting the deadlines into a state-level DFFO—which quietly pushed the NFA analysis deadline back to June 14, 2027, and paused a $47,990 civil penalty ($27,990 for the NFA analysis and $20,000 for project implementation) in abeyance—the Ohio EPA unplugged the federal alarm. Because those overdue dates no longer exist inside the permit table, the federal computer system clears the schedule violation flag, making it appear on national dashboards as though Galion’s noncompliance has been resolved. Simultaneously, removing those milestones from the federal permit acts as a lawsuit shield—stripping citizens of their ability to sue in federal court over those missed deadlines and locking enforcement entirely behind closed doors in Columbus.

There are far deeper legal, financial, and public health consequences tied to this Regulatory Shield—and why a state-level DFFO is wholly inadequate for a municipal collapse of this magnitude.

Marion Watch Investigates is currently finalizing a separate, comprehensive national analysis comparing Galion’s water and wastewater failures against municipalities across the United States.

In that upcoming report, we will break down the full mechanics of this state shield, why it is a severe problem for citizens, and exactly what it means when measured against national enforcement standards.

Crucially, this modification does not exempt Galion from reporting future sewage bypasses.

Under Part I.B and Part III of Permit 2PD00030*RD, the city remains legally required to monitor and report every gallon of sewage that bypasses the plant at Stations 602 and 603 on monthly electronic Discharge Monitoring Reports (eDMRs), and must notify the Ohio EPA within 24 hours of any unanticipated bypass or daily maximum exceedance (or within 30 minutes at 800-282-9378 if a spill endangers health or the environment).

Under Ohio Revised Code (ORC) § 6111.99, falsifying monitoring methods or knowingly making false statements on compliance reports remains a crime punishable by up to $25,000 per violation and one year in prison.

GALION, OHIO INSPECTION REPORT JULY 1, 2026


epa Entered Director’s Journal 9/25/26


The Engineering Contradiction: “100% Separate Sewers” vs. Concrete Weirs

The state’s paperwork cleanup collapses when measured against the mechanical reality documented in the permit’s own Fact Sheet.

On Page 5 of the Fact Sheet, the Ohio EPA declares: “The City of Galion has 100% separate sewers.”

In a properly separated sewer system, rainwater enters street grates and flows directly to creeks, while household sewage stays sealed inside sanitary pipes. 

Rainwater should never enter sanitary lines. 

Yet, two paragraphs above that claim, the state codifies the permanent structures Galion uses to dump sewage into the headwaters of the Olentangy River (River Mile 85.96)—a low-flow basin of less than 15 square miles that feeds drinking water and habitats for 250,000 downstream Ohioans:

  • Station 603 (Secondary Bypass > 6.8 MGD): Diverts partially settled wastewater around the activated sludge tanks and secondary clarifiers, skipping biological treatment before mixing in Tertiary Lagoon No. 1.
  • Station 602 (Total Plant Bypass > 8.5 MGD): Controlled by a permanent, “set-in-place weir with no operator adjustments,” diverting raw waste past both primary and secondary treatment after basic screening.

In the monitoring tables for Stations 602, 603, and 604, the permit states: “Discharge through this station is prohibited” under 40 CFR 122.41(m) unless unavoidable to prevent loss of life or severe property damage and where reasonable engineering judgment could not have prevented it.

The contradiction is irreconcilable: the Ohio EPA labels bypasses “prohibited” on paper while licensing unadjustable concrete weirs that guarantee raw sewage pours into the Olentangy River whenever it rains. Furthermore, on September 3, 2026, the Ohio EPA rubber-stamped a “No Exposure Certification” (2GRN00858*AG) terminating the plant’s industrial stormwater permit (2GR00548) on the sworn claim that zero industrial wastes are exposed to rain—even as citywide smoke testing sent sanitary smoke billowing out of street storm grates and state inspectors documented solid waste choking a catch basin south of the digesters. 

Yet another Marion Watch prophecy fulfilled. 


EPA MODIFICATION LETTER 10/1/26


The Master Ledger: What the “Regulatory Shield” Was Built to Hide

As extensively documented in prior Marion Watch articles, this paperwork shield masks an unprecedented volume of active environmental, safety, and public health violations across both the Wastewater and Water Treatment Plants including:

Wastewater Treatment Plant (WWTP) & Sewer Collection Violations

  • 68+ Documented Permit & Compliance Breaches (Jan 2023 – May 2026): The July 1, 2026 EPA inspection logged 48 effluent limit violations (for Total Phosphorus, Total Suspended Solids, Ammonia-Nitrogen, pH, and an Oil & Grease spike 14x the legal limit), 16 loading violations, 2 frequency violations (missing October 2024 CBOD samples), 1 code event, and 3 overdue construction milestones.
  • “Too Numerous to Count” Fecal Discharges: Outfall 001 E. coli discharges exceeded four times the legal limit in September 2025 (1,194 vs. 284 #/100 mL) and triggered an official “AK” Code Event on June 6, 2024, meaning bacteria levels entering the Olentangy River were “too numerous to count.” Meanwhile, annual toxicity bioassay bench sheets for Ceriodaphnia dubia and Pimephales promelas remain unreconciled publicly, and the city has not responded to our request for this information.
  • Hundreds of Millions of Gallons Bypassed: All top 10 daily flows between 2023 and 2026 exceeded the plant’s 8.5 MGD peak capacity (peaking at 11.363 MGD and 11.310 MGD; an 8.33 peaking factor over the 1.16 MGD dry baseline). Single-day bypasses hit 52.9 MG in August 2023, over 200 MG in April 2025 (peaking at 74.42 MG/day), and over 133 MG in May 2025. Overloading in the 1908 clay Olentangy Trunk is so severe that manhole lids are left unbolted and blow into the river, while leaking lines have caused streets on North Market, Fairview, Jefferson, and Church to sink 3 to 5 inches.
  • Falsified 2024 Annual SSO Report & Unreported Bike Path Spill: The city failed to report a “C-lift failure” that spilled raw sewage onto a public bike path, and certified under penalty of law on February 3, 2025, that zero Sanitary Sewer Overflows occurred in 2024—contradicting its own eDMR log of a verified May 9, 2024 SSO.
  • Staffing Violations, Whistleblower Retaliation, & Unlicensed Crews: On April 6, 2026, veteran Class III Superintendent Patrick Hickman resigned and notified the EPA as required by his license, refusing to risk his certification for an administration operating with only 4 of 8 required staff. Despite authorizing a 4% merit raise four months earlier, Safety-Service Director Nicole Ward marked his file “Ineligible for rehire” and “Insufficient notice given.” EPA audits subsequently confirmed the city violated Class III minimum staffing laws (logging 39.5 of 40 required hours in July 2025), failed to log collection system maintenance prior to May 2023 or staffing hours prior to May 2026, relied on a 1984 O&M manual, and handed physical sewer and water main maintenance to an unlicensed Street Department supervisor.
  • The $41.63 Million GPD Engineering Collapse: GPD Group’s 153-page audit proved the WWTP—bordering family homes and the Galion Meadows Skilled Nursing facility—requires $41.63 million just to fix existing equipment. Critical failures include: 1954 anaerobic digesters ($6.73M) with dead gas compressors, cracked covers, and one completely failed, unrepairable digester venting explosive methane and carcinogenic VOCs beside rusted 480V electrical panels (MCC-DI); bowing CMU block aeration walls ($2.35M) leaching raw sewage into groundwater; final clarifiers violating Ten States Standards overflow limits (1,500 vs. 1,200 gpd/sf); a missing 14-inch magnetic influent flow meter; an unpermitted direct river overflow pipe at Lift Station “A”; no Stormwater Pollution Prevention Plan (SWP3); a missing effluent sampler thermometer; residual sludge in decommissioned tanks; a sunken Lagoon #1 baffle curtain; a rusted-through sludge dryer jacket; and taxpayer funds used to maintain a private owner’s lift station.

Workplace Safety: 8 Major PERRP / OSHA Citations & Code Breaches

  • 7 Citations for Lethal Chlorine Gas Mishandling (29 CFR 1910.119): Issued April 3, 2025 (Visit #1116313) for storing over 1,500 pounds of Chlorine gas with no Process Safety Information (PSI), no Process Hazard Analysis (PHA), no written operating procedures, no employee training, no mechanical integrity program, no Emergency Action Plan (29 CFR 1910.38), and no Management of Change (MOC) procedures.
  • 1 Citation for Confined Space Violations: Ordering workers into Lift Station “A”, clarifiers, and aeration basins without a permit program.
  • Disabled Safety Gear & Illegal HVAC: GPD and whistleblower records documented removed makeup air ventilation in the Chlorine Building replaced with an illegally ducted wall heater; tied-up emergency shower pull-chains in the Admin Building; an undersized 40-gallon water heater; an empty, broken eyewash station and no shower in the Secondary basement where failed 1981 Worthington pumps spray raw sewage under plastic sheets (risking “Sewage Worker’s Syndrome”); a missing local disconnect on the centrifuge pump; missing backflow preventers in four buildings; yellow-painted hot water pipes violating Ten States Standards; and a lack of certified training for working at heights, lockout/tagout, and Hazard Communication.

Industrial Pretreatment Collapse & Ordinance 925.34 Sabotage

  • 100% Unsampled Industrial Users (Aug 14, 2026 EPA Audit): The city failed to sample Categorical Industrial Users since 2022, sampled 0% of its three recognized SIUs (Carter Machine, Galion LLC, A&G Manufacturing) in 2025, failed to follow up on Industrial Waste Surveys, allowed A&G to operate on an expired permit, and “lost” the 2022 permit application for federally regulated ammunition manufacturer Galion, LLC (operating unpermitted since Feb 2022 and never resampled after a Jan 2026 zinc violation).
  • The 1990 Sewer Use Ordinance Shield & Toxic Biosolids: Operating under an untouched 1990 ordinance that omits 2005 federal pretreatment rules and allows copper dumping at 3.2 mg/L (nearly 5x the 0.652 mg/L state limit), unmonitored industrial heavy metals flood the WWTP, leaving its dried Class A biosolids too contaminated with cadmium, hexavalent chromium, and lead for land application.
  • Ordinance 925.34 Violations by the City’s Own Water Plant: Corroborated by Patrick Hickman, a February 2024 EPA pretreatment inspection (“white wastewater” batches), and the GPD report, the city’s own Water Treatment Plant is the largest violator of municipal Ordinance 925.34—dumping corrosive lime and ferric chloride slugs into the sanitary sewer that destroyed city pumps, clogged digester pipes, killed the biological treatment biomass, and caused the total failure of the WWTP digester (while an engineering questionnaire to investigate the water plant was quietly dropped without Hickman’s authorization).

Water Treatment Plant (WTP) Violations: 6 Active EPA Citations, 65% Water Loss, & Carcinogenic Spikes

  • 6 Unresolved Ohio EPA Violations (June 4, 2026 NOV): Carrying potential civil penalties of up to $25,000 per day per violation under ORC Chapter 6109, the state cited Galion for unresolved 2023/2024 violations:
  1. Clearwell Maintenance Deficiencies: Sediment buildup, seized sluice gates, and a leaking south access hatch in finished drinking water storage (deadlines March/Dec 2027).
  1. Amann Raw Water Pump Station Deficiencies: Structural and mechanical failure requiring complete building demolition to the foundation and removal of all pumps (deadline July 12, 2027; conditional EPA plan approval DDAGW-6896 issued Aug 12, 2026).
  1. High Service Pump #5: Unmaintained and inoperable (deadline March 1, 2027).
  1. Northwest Clearwell Access Hatch: Lacks a sanitary seal to protect finished water (deadline March 1, 2027).
  1. Backflow Prevention Noncompliance: Failed to require annual testing, maintain records, or inspect installations (deadline Jan 12, 2027).
  1. Failure to Conduct On-Site Investigations: Failed to inspect commercial/industrial properties every five years for cross-connections (deadline Jan 12, 2027).
  • 24-Point EPA Site Visit List & 65% Water Loss: The WTP suffers from failed clarifiers (cracked concrete on Clarifier 2, bent mixer shaft, algae on launders), a failed lime slaker and recarbonation valves, leaking ferric chloride and caustic soda bulk tanks (relying on temporary totes), a failing Powers Reservoir Intake roof, missing chemical jar testing, and security lapses/graffiti at Amann Reservoir. Meanwhile, the city suffers a staggering 65% non-revenue water loss (driven by leaking mains and continuous hydrant flushing used to artificially dilute TTHM levels) and $9 million in neglected assets (3,000 unexercised distribution valves)—When the City Treasurer questioned these figures in February 2024, she was told by the Mayor and Council to “stay in her lane.” Having declined a major EPA loan in 2021, the city rushed to pass $3.74 million in emergency bonds in April 2026 ($1.1M mandatory for the WWTP) alongside consecutive 20% sewer rate hikes. Even after City Council passed Ordinance 2026-68 on September 22, 2026, to stop draining $90,000–$112,000 in utility funds for general fund administrative salaries, the city still lacks the $2 million needed to run sewer lines to a 40-to-50-acre industrial site at SR 61 and U.S. 30 just disqualified by JobsOhio.
  • Carcinogenic Disinfection Byproducts & Chromium-6: Because failing WTP clarifiers cannot filter raw organic matter before chlorination, the plant manufactures extreme levels of carcinogens. On July 9, 2026 (Q3 2026), TTHMs exceeded the 80 ppb federal limit at DS202 (95.4 ppb), DS201 (89.8 ppb), and DS203 (81.5 ppb), which the city dismissed using 4-quarter averaging. EWG data (2021–2023) confirmed TTHMs at 485x health guidelines (72.7 ppb), HAA9 at 439x (26.3 ppb), HAA5 at 229x (22.9 ppb), Chloroform at 143x (57.3 ppb), Bromodichloromethane at 204x (12.2 ppb), Atrazine at 2.2x (0.224 ppb), and Hexavalent Chromium at 76x health guidelines (1.52 ppb)—exceeding the 1.19 ppb average residential plume in Erin Brockovich’s Hinkley, California disaster.

The Math of Erasure: From Eighth Avenue to the Sitting Mayor’s Kitchen Sink

The common thread uniting fifty years of Galion utility crises is statistical and regulatory dilution: when contamination cannot be stopped, the numbers are watered down.

The Eighth Avenue “Six-Dollar Sink” & Epidemiological Dilution

In the Eighth Avenue area near Moccasin Run, the city bills residents a monthly $6.00 “Storm Water” fee on a street where municipal storm sewers physically do not exist. When I&I surges back up the nearby lift station, raw sewage mixes with agricultural runoff in residential yards, suffocating maple tree roots via high Biochemical Oxygen Demand, burning bark with chemical surfactants (cambial necrosis), coating trunks in neon-green hyper-eutrophic lichen, and breeding Phytophthora molds. Worse, contaminated water breaches foundations, off-gassing VOCs and pathogens into the home of a young child recovering from a resected left parietal Pilocytic astrocytoma brain tumor.

Yet state health reports claim “no stand-out environmental commonalities” by blending Galion’s 10,000 residents on a failing industrial grid with 30,000 rural Crawford County residents—flattening a county mortality rate of 182.5 per 100,000 (25% above national baselines), kidney cancer rates 35% higher than the Ohio average, bladder cancer rates 31% higher (the primary biomarker for TTHMs), and local pediatric brain tumor rates double the regional baseline. It is the exact same geographic washout state officials used in the 1980s when they “lost” citizen medical records and expanded study boundaries into rural townships to dilute Harvard/Boston University epidemiologist Dr. Theodore H. Ingalls’ study linking Galion’s Fairview Avenue Multiple Sclerosis cluster (30–40 cases) to industrial cadmium and hexavalent chromium.


The Insider Lead Ring & The New September 2026 Mayoral Tap (LC208 & LC248)

Marion Watch recently exposed this exact dilution tactic inside the city’s federal Lead and Copper Rule compliance program—a rigging operation whose foundation was poured back in 2017, when 36 names were quietly bleached off an official state map in 24 hours to hide a manipulated compliance baseline:

  • The 2025 “Unknown” Lie vs. The Bleached 2017 Map: In December 2025, Superintendent James Warner mailed notices claiming service lines were “Lead Status Unknown.” Yet on February 28, 2017—ahead of the March 2017 House Bill 512 deadline—the city submitted an unredacted master map to the Ohio EPA Northwest District Office (where District Inspector Ralph Baker oversaw regional compliance) shading lead zones in red and listing 36 specific sample sites (LC201–LC236) with owner names. Just 24 hours later, on March 1, 2017, the city submitted a “Revised” map—stamped “RECEIVED” by the Ohio EPA—bleaching the 36 names, deleting a false engineering note claiming all mains and lines were PVC/HDPE plastic, and erasing the red lead corridor along Portland Way South.
  • The Law They Ignored in 2017: Under federal and state law (40 CFR § 141.86 and OAC 3745-81-86), utilities are legally required to pull 100% of their samples from high-risk “Tier 1” lead homes. Testing safe, non-lead zones when known lead zones exist in the city is flatly illegal.
  • 64% Illegally Planted in the “Green Zone”: Despite hundreds of homes sitting inside the city’s red lead corridor, 23 of the 36 houses tested were planted inside low-risk green zones explicitly mapped as “Non-Lead Service Connections” to mathematically dilute the city’s failure rate from day one.
  • Over 30% City Insiders & Family (The Closed-Loop Pool, 2017–2026): At least 11 of the 36 sample sites (nearly a third of the entire testing pool) belonged directly to city officials, utility operators, and their family members—and the city repeatedly re-sampled this locked-in pool in 2017, September 2025, and August/September 2026.
  • The Green Zone Dilution Shield: Those low-risk green-zone tests included the homes of then-Mayor Tom O’Leary (LC223), late City Council President Carl Watt (LC233), Water Plant Lab Tech Doug Streeter (LC202), Wastewater Crew Chief Mark Armstrong (LC212), Fire Captain Todd Eagle (LC226), Service Department Operator Terry Miller (LC210), and a relative of the Water Superintendent.
  • The Red Zone Gatekeepers: Only 13 of the 36 sites (36%) actually sat inside the red lead corridor—and even those were heavily buffered by insiders, including then-WTP Superintendent Paul Campbell (LC201, who tested his own tap and signed his own federal certification, alongside relatives at LC203, LC206, and LC214), the then-Police Chief and current Mayor Brian Saterfield (LC208), and Billie Bodkins (LC209, a relative of current WWTP Superintendent Renee Bodkins).
  • The Falsification Trap: Certifying non-lead green-zone homes to the state as legal “Tier 1” lead sites—while simultaneously mailing notices to citizens claiming the city’s pipes are “Unknown” (which federal law also strictly bans from Tier 1 testing)—crosses directly from a regulatory violation into potential state and federal falsification (ORC § 2921.13 / 18 U.S.C. § 1001).
  • Diluting the 51 µg/L Plumber’s Spike: When a bathroom sink sample at LC222 (Portland Way South)—the home of licensed local plumber Dave Fox—spiked to 51 µg/L of lead (over 3x the 15 µg/L federal limit) in August 2026, the locked-in pool of safe insider taps mathematically diluted the failure to keep the city below the 10% federal action trigger. Warner delivered Fox’s notice nine days late with an unedited, blank placeholder template for medical blood testing (“Health screenings are available through (list agency name[s])…”), and returned eight days after the spike to pull a “Special non-compliance sample” from Fox’s kitchen sink to log a <2.0 µg/L reading.

Newly obtained Ohio EPA verification records signed by James Warner on September 18, 2026, prove this insider dilution continues in real time.

On September 2, 2026—just six days after the August 27 “Special sample” sink switch at LC222—the Water Department went directly to 332 W. Church Street (LC208), the personal residence of sitting Mayor Brian Saterfield. Originally placed on the unredacted 2017 map when Saterfield was Chief of Police, the sitting Mayor’s kitchen sink returned a <2.0 µg/L reading, with Warner checking “yes” on the September 18 state form certifying the Mayor’s home was also sampled in the previous monitoring period.

Alongside Mayor Saterfield’s home (LC208), Warner listed one other site on the September 18, 2026 form: LC248, also marked “yes” as having been sampled in a previous monitoring period. Because the unredacted 2017 map ended at LC236 (and the 2017 state appendix ended at LC239) and the city’s September 16, 2025 form listed LC244 as “NO, New”, additional public records—specifically the city’s updated SMP ID Master Spreadsheet—are required before drawing conclusions on the physical address and sampling history of LC248. Remarkably, even Mayor Saterfield’s September 18, 2026 consumer notice packet still contained the unedited, blank medical screening template.


GALION, OHIO LEAD TEST 9/18/26


The Verdict: Regulatory Capture Institutionalized

The journalization of NPDES Permit Modification 2PD00030*RD on September 25, 2026, answers the central question of this investigation: the Ohio EPA is actively allowing conditions it is legally mandated to stop.

Under Ohio Revised Code Chapter 6111, the Clean Water Act, the Safe Drinking Water Act, and the Public Trust Doctrine, an environmental agency has no legal authority to use permit modifications to sanitize an active record of chronic non-compliance.

Whether it is expanding geographic boundaries to dilute Dr. Ingalls’ MS cluster, sampling Mayor Brian Saterfield’s kitchen sink to pad the Lead and Copper Rule compliance pool days after a 51 µg/L spike, rubber-stamping a “No Exposure” stormwater exemption while sanitary smoke billows out of street grates, or deleting overdue bypass elimination schedules from an NPDES permit to scrub a facility from federal SNC dashboards, the mechanism is identical: manipulate the paperwork so the city can delay paying to fix the pipes.

The paperwork in Columbus has been laundered, but the physical receipts remain in Galion. Marion Watch Investigates will continue auditing every monthly eDMR filing, enforcing public records requests which have mysteriously ceased entirely, and holding both municipal leadership and the Ohio EPA accountable to the law.