CHILLICOTHE, Ohio — Ohio EPA has issued the City of Chillicothe a notice of violation and placed the city in significant noncompliance with the pretreatment program requirements of its wastewater permit, after a two-day inspection of the Easterly wastewater treatment plant found an undertrained pretreatment coordinator, three quarters of missing industrial user violation reports, and a breakdown in the city’s enforcement against a significant industrial user that went a year without filing required monitoring reports.
The notice of violation, dated October 14, 2026, and signed by Emily Poling, a district representative with Ohio EPA’s Division of Surface Water in the Southeast District Office, follows a Pretreatment Compliance Inspection conducted August 10 and 11, 2026, of the city’s approved pretreatment program. The program governs how industrial users discharge into the Easterly plant under the city’s National Pollutant Discharge Elimination System permit, number 0PD00003, which took effect December 1, 2025. The Easterly plant, at 405 Environmental Way, treats about 2.5 million gallons per day.
Ohio EPA cited three violations of Ohio environmental law and the city’s permit:
First, the agency found that the pretreatment coordinator employed during the inspection was not knowledgeable about the key aspects of the approved pretreatment program, a violation of Ohio Administrative Code 3745-3-03(C)(3) and Part II, Item T.2 of the permit. The inspection report attributes the problem to recent employee turnover, which it said left the coordinator undertrained in the significant components of the program.
Second, the city failed to submit its Quarterly Industrial User Violation reports for January 2026, April 2026 and July 2026 by the 15th day of those months, a violation of Ohio Revised Code 6111.07 and Part II, Item T.10 of the permit. Ohio EPA classified it as a Level II criterion violation and said that, as a result, the city is in significant noncompliance with implementing the pretreatment program requirements. The inspection found that no quarterly reports had been submitted since October 2025; reports for January and April were ultimately received on September 25, 2026, but were deemed incomplete due to inaccuracy, and the report due July 15, 2026, had still not been received. The city’s annual pretreatment reports for 2025 and 2026 were also submitted after their June 15 deadlines, the inspection found.
Third, Ohio EPA found that a significant industrial user did not submit self-monitoring reports within 45 days as required from September 2025 through July 2026, and that the city — the control authority — failed to implement its own Enforcement Response Plan: a notice of violation was not issued to the industrial user within the time frame the plan requires, and the significant noncompliance was not published in the newspaper as required. That is a violation of OAC 3745-3-03(C)(5) and Part II, Item T.9 of the permit, also classified as a Level II criterion violation, and Ohio EPA said the violation, together with the reporting violation, puts the city in significant noncompliance.
The Herr’s Foods file
The inspection report identifies the industrial user as Herr’s Foods, the snack food manufacturer on East 7th Street. Reviewing Herr’s file, inspectors found there are no records of self-monitoring and reporting from September 2025 to June 2026, with the exception of March 2026; that completed chain-of-custody forms were not all available; and that the site inspection and sampling review forms used to determine compliance were not complete. The city failed to investigate and conduct enforcement action, the report said, and no notice of violation was sent to Herr’s by the city. Ohio EPA said it received an email on September 14, 2026, that a notice of violation letter had been sent to Herr’s Foods. In its own file review, Ohio EPA recorded no noncompliance by Herr’s with pretreatment discharge standards; the cited failures were the missing reports and the city’s response to them.
Kenworth, Howmet and Adena findings
Reviewing Kenworth Truck Company’s file, inspectors found the plant’s sampling is split between two locations — a sample box and a manhole — and that sampling taken at the sample box is missing analysis for temperature, total arsenic, hexavalent chromium, total mercury, total selenium, and oil and grease. The permit’s sampling table also lists hexavalent chromium to be sampled using a composite method, where federal rules require a grab sample, and a facility inspection checklist from October 8, 2024, incorrectly identified Kenworth as being subject to categorical standards; Kenworth is a noncategorical user. The inspection also found that Howmet and Adena have expired control mechanisms — their discharge permits — and that Adena has not submitted an industrial waste survey questionnaire for review. The city’s three significant industrial users are Herr’s Foods, Adena and Kenworth.
What happens next
Ohio EPA directed the city to submit, for each violation, a plan describing how it will return to compliance. Within 30 days of receiving the letter, the city must provide documentation of the actions taken or that will be taken to resolve the violations. The agency warned that failure to comply with Chapter 6111 of the Ohio Revised Code may result in an administrative or civil penalty, and that responding to the letter does not waive Ohio EPA’s authority to seek penalties under ORC 6111.09. The inspection report’s recommendations, which Ohio EPA notes are not orders, include ensuring industrial users follow sampling frequencies, following the Enforcement Response Plan for industrial user noncompliance, and having sufficient resources and qualified personnel to fully implement the pretreatment program.
The notice arrives while the Easterly plant is undergoing a complete upgrade of its treatment systems. The inspection documents note the plant itself was previously in significant noncompliance for E. coli, pH and ammonia violations. The pretreatment program Ohio EPA oversees in Chillicothe was originally approved March 29, 1985.
Read the Ohio EPA documents:
Ohio EPA Notice of Violation to the City of Chillicothe — October 14, 2026 (PDF)
Ohio EPA Pretreatment Compliance Inspection report — Chillicothe WWTP-Easterly (PDF)
