Under the proposed terms, Sherwin-Williams would secure an additional $4.22 million in financial assurance within 30 days after the court enters the modification. The amount represents the estimated cost of the groundwater work and would be added to financial assurance already required for other cleanup obligations.

The proposed amount is funding assurance for remediation, not a newly assessed fine or civil penalty. The amendment would become effective only after court approval following public notice and comment.

Groundwater Treatment and Monitoring

EPA selected the Operable Unit 3 remedy in September 2025. It addresses deep groundwater beneath the former manufacturing plant area through in-situ treatment, with potential approaches including chemical oxidation, chemical reduction or sequestration and enhanced bioremediation.

The accompanying statement of work includes investigation before design, installation of injection points, additional monitoring wells, long-term groundwater monitoring, institutional controls and five-year reviews. Natural attenuation would address areas where active groundwater treatment is not implemented. 

The original consent decree was entered in April 2019. It resolved federal past-cost claims involving the Sherwin-Williams/Hilliards Creek, Route 561 Dump and United States Avenue Burn sites in Gibbsboro and Voorhees. The agreement also allows additional remedies selected by EPA to be incorporated through later amendments.

DOJ lists Nov. 2, 2026, as the end of the public-comment period. The proposed modification and supporting documents are available through the department’s consent-decree website.

Sources: Department of Justice, Federal Register

The proposal illustrates how environmental cleanup obligations at former coatings-manufacturing properties can expand as additional remedies are selected, making it relevant to manufacturers tracking regulations, site liabilities and remediation costs.