In re Eagle-Picher Holdings, Inc.

345 B.R. 860, 2006 Bankr. LEXIS 1393, 46 Bankr. Ct. Dec. (CRR) 250, 2006 WL 2050342
CourtUnited States Bankruptcy Court, S.D. Ohio
DecidedJune 13, 2006
DocketNo. 05-12601
StatusPublished

This text of 345 B.R. 860 (In re Eagle-Picher Holdings, Inc.) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Eagle-Picher Holdings, Inc., 345 B.R. 860, 2006 Bankr. LEXIS 1393, 46 Bankr. Ct. Dec. (CRR) 250, 2006 WL 2050342 (Ohio 2006).

Opinion

ORDER RE: OBJECTIONS TO CONFIRMATION ON CUSTODIAL TRUST ISSUES

J. VINCENT AUG, JR., Bankruptcy Judge.

This matter is before the Court on the United States of America, on behalf of the Environmental Protection Agency’s (“EPA”), supplemental objection to confirmation of the Debtors’ joint plan on custodial trust issues (Doc.2053), the Debtors’ response (Doc.2094, 2106), and the Official Committee of Unsecured Creditors’ join-der to the Debtors’ response (Doc.2097). A trial was held on June 1, 2, and 5, 2006.

Also before the Court are the parties’ motions in limine (Does.2098 and 2109). These motions were both DENIED at the start of the trial. The Debtors’ motion for an order waiving the length limitation of its brief (Doc.2092) is hereby GRANTED. The Debtors’ motion for a hearing on its motion in limine (Doc.2099) is hereby DENIED as MOOT.

The Debtors own sixteen properties with various environmental problems. Initially, the Debtors proposed to simply abandon these properties as burdensome to the estate. This proposal was met with fierce opposition from federal and state environmental regulatory agencies. The Debtors then proposed to transfer the properties to trust entities (“Custodial Trusts”) with each Custodial Trust being funded to a level acceptable to the appropriate agencies. Admirably, the parties were able to agree on the amount of funding for all but two sites, one in Urbana, Ohio and the other in Sidney, Ohio.

Thus, the issue before the Court is the adequacy of the Debtors’ proposed funding for the two Custodial Trusts for the Ohio sites. The Debtors propose to fund the Urbana Custodial Trust with $45,000 and the Sidney Custodial Trust with $900,000. The EPA proposes an amount of $1,842,720 for the Urbana Custodial Trust and a range of $5,855,256 to $9,330,420 for the Sidney Custodial Trust.

Contrary to the Debtors’ contention, the issue is not whether the EPA is entitled to an administrative expense claim. Rather, the issue is whether the Debtors have proposed a plan that is forbidden by law. See 11 U.S.C. § 1129(a)(3). The Debtors bear the ultimate burden of proof on this issue. As to the specific issue of whether the Custodial Trusts are adequately funded, the parties differ sharply on the legal standard to be applied. The EPA contends that the funding amounts must allow for the Custodial Trustee to bring each site “into compliance” with state and federal law. See Doc.2053, p. 4-5. The Debtors contend that the EPA must prove that the sites pose an “imminent and identifiable harm to public health and safety.” See Doc. 2106, p. 15.

The definitive case is Midlantic National Bank v. New Jersey Department of Environmental Protection, 474 U.S. 494, 507, 106 S.Ct. 755, 88 L.Ed.2d 859 (1986) wherein the Supreme Court held:

a trustee may not abandon property in contravention of a state statute or regu[862]*862lation that is reasonably designed to protect the public health or safety from identified hazards.

The footnote to the holding states:

This exception to the abandonment power ... is a narrow one. It does not encompass a speculative or indeterminate future violation of such laws that may stem from abandonment. The abandonment power is not to be fettered by laws or regulations not reasonably calculated to protect the public health or safety from imminent and identifiable harm.

Id. at 507, n. 9, 106 S.Ct. 755.

The Supreme Court offered additional guidance by stating:

the Bankruptcy Court does not have the power to authorize an abandonment without formulating conditions that will adequately protect the public’s health and safety.

Id. at 507, 106 S.Ct. 755.

Midlantic has spawned two lines of cases. One line of cases holds that abandonment is appropriate unless there is a showing of an imminent danger to public health and safety while the other line of cases holds that abandonment is appropriate only upon a showing of full compliance with the applicable environmental laws. In re Smith-Douglass, Inc., 856 F.2d 12, 15 (4th Cir.1988). Thus, it is not surprising that the parties in this case have advanced different legal standards. As our analysis below reveals, under the specific facts of this case, the two standards create a distinction without a difference. Therefore, for the purposes of this decision, we will adopt the EPA’s “tougher” full compliance standard.

Although the defense of laches is inapplicable against a governmental entity in an action by that entity to enforce a public right or to protect a public interest, inactivity on the part of a regulatory agency may be relevant to compliance. See In re Anthony Ferrante & Sons. Inc., 119 B.R. 45, 50 (D.N.J.1990)(citing In re Franklin Signal Corp., 65 B.R. 268, 274 (Bankr.D.Minn.1986) and In re Purco, Inc., 76 B.R. 523, 533 (Bankr.W.D.Pa.1987)(“court infers from the [state’s] lack of interest that there is no threat to the public health or safety”)).

Some courts have also considered whether or not the debtor has any unencumbered assets with which to finance any cleanup work. See In re MCI, Inc., 151 B.R. 103, 107 (E.D.Mich.1992). The parties offered no evidence on this issue, so we are unable to consider this factor.

I. Urbana

The Urbana site is a 2.86 acre area which includes a 15,000 square foot U-shaped area surrounding a city water tower. The U-shaped area was initially used as a borrow pit in 1966 for the construction of a porcelain manufacturing facility known as the Chi-Vit facility. From 1966 until 1976, when an off-site disposal area became available, the borrow pit was used for on-site disposal of Chi-Vit’s off-spec metal oxides, raw materials, and general rubbish. The site was eventually covered with topsoil. It is now a lawn. A few bare spots in the grass are visible.

In 1988, Chi-Vit management purchased the Urbana site from the Debtors, except for the U-shaped disposal site. As a part of this transaction, several environmental investigations were performed, including the installation of ten wells for groundwater testing. Dames & Moore performed a phase I investigation in July 1989, a phase II investigation in November 1989, and a phase III investigation in April 1990. ERM-New England performed a supplemental environmental site assessment in September 1992.

[863]*863The Dames & Moore investigations showed the presence of two volatile organic compounds in the groundwater, including trichloroethylene (“TCE”) in excess of the drinking water standards. However, the Dames & Moore report concluded that the source of TCE was from a known TCE plume in the Urbana area and not from the U-shaped disposal site. The ERM-New England report confirmed that the TCE source was off-site.1 The Dames & Moore investigation also showed arsenic at an “above action” level in one well (MW9) and lead at an “above action” level in a second well (MW6). Both arsenic and lead are defined as hazardous substances.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

In Re Anthony Ferrante & Sons, Inc.
119 B.R. 45 (D. New Jersey, 1990)
White v. Coon (In Re Purco, Inc.)
76 B.R. 523 (W.D. Pennsylvania, 1987)
In Re Franklin Signal Corp.
65 B.R. 268 (D. Minnesota, 1986)
Matter of MCI, Inc.
151 B.R. 103 (E.D. Michigan, 1992)

Cite This Page — Counsel Stack

Bluebook (online)
345 B.R. 860, 2006 Bankr. LEXIS 1393, 46 Bankr. Ct. Dec. (CRR) 250, 2006 WL 2050342, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-eagle-picher-holdings-inc-ohsb-2006.