Case 1:22-cv-00731-UNA Document 1 Filed 06/03/22 Page 1 of 14 PageID #: 1
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`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`UNITED STATES OF AMERICA
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`and the
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`STATE OF DELAWARE,
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`Plaintiffs,
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`v.
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`HERCULES INCORPORATED
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`CHAMPLAIN CABLE CORPORATION
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`THE CHEMOURS COMPANY FC, LLC
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`WASTE MANAGEMENT OF DELAWARE, INC.
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`SC HOLDINGS, INC.
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`CYTEC INDUSTRIES, INC.
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`ZENECA INC.
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`BAYER CROPSCIENCE INC.
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`BP AMOCO CHEMICAL, INC.
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`CHEVRON U.S.A. INC.
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`CNA HOLDINGS LLC
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`E.I. DU PONT DE NEMOURS AND COMPANY
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`ESSCHEM, INC.
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`FMC CORPORATION
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`THE GOODYEAR TIRE & RUBBER COMPANY,
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`HONEYWELL INTERNATIONAL INC.
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`CLARIOS LLC
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`KHLC, INC.
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`M.A. HANNA PLASTIC GROUP, INC.
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`NEW CASTLE COUNTY
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`OCCIDENTAL CHEMICAL CORPORATION
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`VERIZON DELAWARE LLC
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`Defendants.
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`COMPLAINT
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`Case 1:22-cv-00731-UNA Document 1 Filed 06/03/22 Page 2 of 14 PageID #: 2
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`The United States of America, by and through the undersigned attorneys, by the authority
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`of the Attorney General of the United States, and at the request of and on behalf of the United
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`States Environmental Protection Agency (“EPA”), and the State of Delaware, by and through the
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`Attorney General of Delaware and its undersigned attorneys, at the request of the Department of
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`Natural Resources and Environmental Control (“DNREC”) (collectively, the “Agencies”), allege
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`the following:
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`STATEMENT OF THE CASE
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`This is a civil action brought pursuant to Sections 106 and 107(a) of the
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`1.
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`Comprehensive Environmental Response, Compensation, and Liability Act, 42 U.S.C. §§ 9606
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`and 9607(a), as amended (“CERCLA”), and 7 Del.C. § 9109, relating to the Delaware Sand and
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`Gravel Superfund Site (“the Site”) located in New Castle County, Delaware. Pursuant to Section
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`106 of CERCLA, 42 U.S.C. § 9606, and 7 Del.C. § 9109, the Agencies seek injunctive relief
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`requiring Defendants to remedy conditions that may pose an imminent and substantial
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`endangerment to the public health or welfare or the environment because of actual and
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`threatened releases of hazardous substances into the environment at or from the Site. In addition,
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`the United States seeks to recover unreimbursed costs incurred by it for activities undertaken in
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`response to the release or threatened release of hazardous substances and related contamination
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`at and from the Site, pursuant to Section 107(a) of CERCLA, 42 U.S.C. § 9607(a). Finally, the
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`Agencies seek a declaratory judgment, pursuant to Section 113(g)(2) of CERCLA, 42 U.S.C. §
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`9613(g)(2), declaring that Defendants are liable for any future response costs that the United
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`States and the State of Delaware may incur in connection with response actions that may be
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`performed pertaining to the Site.
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`2
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`Case 1:22-cv-00731-UNA Document 1 Filed 06/03/22 Page 3 of 14 PageID #: 3
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`JURISDICTION AND VENUE
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`2.
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`This Court has jurisdiction over the subject matter of this action pursuant to 42
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`U.S.C. § 9613(b), and 28 U.S.C. §§ 1331 and 1345.
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`3.
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`Venue is proper in this district pursuant to 42 U.S.C. § 9613(b) and 28 U.S.C. §
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`1391(b) and (c) because the claims arose and the threatened or actual releases of hazardous
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`substances occurred in this district.
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`DEFENDANTS
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`Defendant Hercules Incorporated is a Delaware corporation that, at times relevant
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`4.
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`to this action, was engaged in the business of chemical manufacturing in the State of Delaware.
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`5.
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`Defendant Champlain Cable Corporation, formerly known as Haveg Industries,
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`Inc., is a Delaware corporation which, at times relevant to this action, was engaged in the
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`business of chemical manufacturing in the State of Delaware.
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`6.
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`Defendant The Chemours Company FC, LLC (“Chemours”), a Delaware
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`corporation, is a successor in interest to E.I. du Pont de Nemours & Co., Inc., which, at times
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`relevant to this action, was engaged in the manufacture of chemicals in the State of Delaware.
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`7.
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`Defendant Waste Management of Delaware, Inc., formerly known as Trash
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`Removers, Inc., is a Delaware corporation that, at times relevant to this action, was engaged in
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`the business of transporting and disposing of hazardous substances in the State of Delaware.
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`8.
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`Defendant SC Holdings, Inc., a Pennsylvania corporation, is the successor in
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`interest to SCA Services, Inc., which, at times relevant to this action, was engaged in the
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`business of transporting and disposing of hazardous substances in the State of Delaware.
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`3
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`9.
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`Defendant Cytec Industries, Inc., a Delaware corporation, is the successor in
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`interest to American Cyanamid Company, which, at times relevant to this action, was engaged in
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`the business of chemical manufacturing in the State of Maryland.
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`10.
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`Defendant Zeneca Inc., a Delaware corporation, is the successor in interest to ICI
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`Americas, Inc., which, at times relevant to this action, was engaged in the business of chemical
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`manufacturing in the State of Delaware.
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`11.
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`Defendant Bayer CropScience Inc., a New York corporation, is the successor in
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`interest to Stauffer Chemical Company, which, at times relevant to this action, was engaged in
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`the business of chemical manufacturing in the State of Delaware.
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`12.
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`Defendant BP Amoco Chemical Company, now known as INEOS US Chemicals
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`Company, is a Delaware corporation that, at times relevant to this action, was engaged in the
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`business of manufacturing petroleum products in the State of Pennsylvania.
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`13.
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`Defendant Chevron U.S.A. Inc., a Pennsylvania corporation, is the successor in
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`interest to Gulf Oil Corporation, which, at times relevant to this action, was engaged in the
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`business of manufacturing petroleum and natural gas products in the State of Pennsylvania.
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`14.
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`Defendant CNA Holdings LLC, a Delaware corporation, is the successor in
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`interest to American Hoechst Corporation, which, at times relevant to this action, was engaged in
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`the business of manufacturing chemicals in the State of Delaware.
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`15.
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`Defendant E.I. du Pont de Nemours & Company is a Delaware corporation that, at
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`times relevant to this action, was engaged in the manufacture of chemicals in the State of
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`Delaware.
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`4
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`16.
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`Defendant Esschem, Inc., a Delaware corporation, is the successor in interest to
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`Sartomer Resins, Inc., which, at times relevant to this action, was engaged in the business of
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`manufacturing dental resins in the State of Pennsylvania.
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`17.
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`Defendant FMC Corporation is a Delaware corporation that, at times relevant to
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`this action, owned and operated facilities in Marcus Hook, Pennsylvania and Newark, Delaware.
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`18.
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`Defendant The Goodyear Tire & Rubber Company, an Ohio corporation, is the
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`successor in interest to Motor Wheel Corporation, which, at times relevant to this action, was
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`engaged in the business of manufacturing wheels and rims for automobiles and light trucks in the
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`State of Delaware.
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`19.
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`Defendant Honeywell International Inc., a Delaware corporation, is the successor
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`in interest to Allied-Signal Inc., which, at times relevant to this action, was engaged in the
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`business of chemical manufacturing in North Claymont, Delaware and Marcus Hook,
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`Pennsylvania.
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`20.
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`Defendant Clarios LLC, a Delaware corporation, is the successor in interest to the
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`Johnson Controls Battery Group, Inc., formerly known as Globe Union, Inc., which, at times
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`relevant to this action, was engaged in the business of manufacturing batteries in the State of
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`Delaware.
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`21.
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`Defendant KHLC, Inc., a Delaware corporation, is the successor in interest to
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`Ludlow Corporation, which, at times relevant to this action, was engaged in the business of
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`textile manufacturing in the State of Delaware.
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`22.
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`Defendant M.A. Hanna Plastic Group, Inc., a Michigan corporation, is the
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`successor in interest to Cadillac Plastic Group, Inc., the successor to Electric Hose & Rubber,
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`5
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`Case 1:22-cv-00731-UNA Document 1 Filed 06/03/22 Page 6 of 14 PageID #: 6
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`Co., which at times relevant to this action, owned and operated a facility in Wilmington,
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`Delaware.
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`23.
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`Defendant New Castle County is a political subdivision of the State of Delaware
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`that operated a municipal landfill adjacent to the Site, and since 1977 has owned a parcel that
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`includes a portion of the Site property.
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`24.
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`Defendant Occidental Chemical Corporation (“Occidental”) is a New York
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`corporation that, at times relevant to this action, was engaged in the business of manufacturing
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`chemicals. Occidental is the successor in interest to Diamond Shamrock Chemical Corporation,
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`which manufactured chemicals in the State of Delaware.
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`25.
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`Defendant Verizon Delaware LLC, a Delaware corporation, is the successor in
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`interest to The Diamond State Telephone Company, the successor to the Bell Telephone
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`Company, which at times relevant to this action, was engaged in the business of manufacturing
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`telecommunications equipment, including outside plant equipment, in the State of Delaware.
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`26.
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`Each of the defendants referenced above, or their predecessors in interest, either
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`1) was an owner of facility from which hazardous substances were released; 2) by contract,
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`agreement, or otherwise, arranged for disposal or treatment, or arranged with a transporter for
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`transport for disposal or treatment, of hazardous substances owned or possessed by such
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`defendant or predecessor at the Site; or 3) accepted hazardous substances for transport to
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`disposal or treatment facilities, within the meaning of Section 107(a)(3) & (4) of CERCLA, 42
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`U.S.C. § 9607(a)(1), (3) & (4).
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`6
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`Case 1:22-cv-00731-UNA Document 1 Filed 06/03/22 Page 7 of 14 PageID #: 7
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`GENERAL ALLEGATIONS
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`The Site is a former sand and gravel quarry spreading over approximately 27
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`27.
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`acres. Sometime after quarrying operations ceased, the Site was operated as a privately owned
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`waste landfill until 1976.
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`28.
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`During the time of its operation as a landfill, liquid and solid wastes and other
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`hazardous substances were disposed of at the Site. This includes approximately 550,000 cubic
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`yards of industrial and municipal wastes and construction rubble, and approximately 15,000
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`drums containing liquids and sludge from chemical production, manufacturing and petroleum
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`refining processes, which were found on the Site after the landfill’s closure.
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`29.
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`Hazardous substances, including benzene, ethylbenzene, xylenes, bis(2-
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`chloroethyl)ether ("BCEE") and 1,4-dioxane, have been detected in soils at the Site. A plume of
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`groundwater contaminants extends from beneath a portion of the Site known as the Drum
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`Disposal Area through an aquifer (known as the Upper Potomac Aquifer) southward toward a
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`well field operated by the Artesian Water Company that lies nearly one mile downgradient.
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`30.
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`Groundwater contaminants of concern at the Site are benzene, ethylbenzene,
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`xylenes, 1,2,4-trimethylbenzene, 1,3,5-trimethylbenzene, 1,4-dioxane, BCEE, naphthalene, N,N-
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`dimethylaniline, arsenic, cobalt, iron and manganese. Among these contaminants, BCEE, 1,4-
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`dioxane and manganese are of particular concern due to their mobility, persistence and potential
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`impact on public water supply wells. Groundwater samples collected from the Upper Potomac
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`Aquifer beneath the Site in 2013 contained BCEE at concentrations up to 690 micrograms per
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`liter (µg/L), 1,4-dioxane at concentrations up to 2,800 µg/L, and manganese at concentrations up
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`to 12,800 µg/L.
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`7
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`31.
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`Groundwater monitoring data also indicates that 1,2-dichloroethane and dissolved
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`metals, primarily iron, manganese and cobalt, are being discharged into the Upper Potomac
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`Aquifer under the Site from sources beneath the Army Creek Landfill, a former municipal waste
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`disposal operation operated by New Castle County located adjacent to the Site’s western border.
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`32.
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`After being notified by DNREC of likely soil and groundwater contamination at
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`the Site in or about November 1979, EPA conducted inspections, monitoring, evaluations,
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`assessments, sampling, analysis, and other removal actions at the Site. Pursuant to Section 105
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`of CERCLA, 42 U.S.C. § 9605, EPA placed the Site on the National Priorities List, set forth at
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`40 C.F.R. Part 300, Appendix B, by publication in the Federal Register on September 8, 1983, 48
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`Fed. Reg. 40650.
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`33.
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`In 1988, EPA selected a remedy for the Site in a Record of Decision. The remedy
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`was modified by a Record of Decision amendment in 1993 (“1993 ROD Amendment”) and an
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`Explanation of Significant Differences in 2003. Among other things, the remedy, as modified,
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`included a slurry-wall containment system with in-situ soil treatment by soil vapor extraction and
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`bioventing at the Drum Disposal Area.
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`34.
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`On June 14, 1995, this Court entered a Remedial Design/Remedial Action
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`Consent Decree (“1995 Consent Decree”), which resolved the claims of a complaint brought by
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`the United States and the State of Delaware in 1989 (Civ. No. 89-562-SLR). The 1995 Consent
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`Decree required the settling defendants to install the slurry wall and implement other elements of
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`the remedy set forth in the 1988 Record of Decision, as amended by the 1993 ROD Amendment.
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`35.
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`In a Five-Year Review Report for the Site, dated September 21, 2005, EPA
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`concluded that the slurry wall remedy at the Drum Disposal Area of the Site was not functioning
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`as designed due to gaps in the native clay unit that furnishes the base of the slurry-wall
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`8
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`containment system. In the next Five-Year Review Report for the Site, dated September 16,
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`2010, EPA concluded that additional response actions were required due to the failure of the
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`constructed remedy to meet performance standards at the Drum Disposal Area, and
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`recommended the performance of a feasibility study to develop a comprehensive source control
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`and groundwater remediation strategy.
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`36.
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`A group of defendants known as the DS&G Remedial Trust completed a
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`Supplemental Site Characterization Report-Revision 2 (“SSCR”) in January 2016, and thereafter
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`completed a Feasibility Study – Revision 1 (“FS”) in May 2016.
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`37.
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`Based on the findings of the SSCR and FS, EPA amended the remedy set forth in
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`the original 1988 Record of Decision, as amended by the 1993 ROD Amendment. The
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`Amended Record of Decision issued on December 12, 2017 sets out various response actions
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`aimed at controlling and reducing groundwater contamination at the Site.
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`FIRST CLAIM FOR RELIEF
`(Response Costs Under CERCLA Section 107(a))
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`The allegations contained in Paragraphs 1-37 are re-alleged and incorporated by
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`38.
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`reference herein.
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`39.
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`Section 107(a) of CERCLA, 42 U.S.C. § 9607(a), provides in pertinent part:
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`*
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`*
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`Notwithstanding any other provision or rule of law, and subject only to the
`defenses set forth in subsection (b) of this section –
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`(1)
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`(2)
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`the owner and operator of a vessel or a facility,
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`any person who at the time of disposal of any hazardous substance owned
`or operated any facility at which such hazardous substances were disposed
`of,
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`any person who by contract, agreement, or otherwise arranged for disposal
`or treatment, or arranged with a transporter for transport for disposal or
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`(3)
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`Case 1:22-cv-00731-UNA Document 1 Filed 06/03/22 Page 10 of 14 PageID #: 10
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`treatment, of hazardous substances owned or possessed by such person, by
`any other party or entity, at any facility or incineration vessel owned or
`operated by another party or entity and containing such hazardous
`substances, and
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`any person who accepts or accepted any hazardous substances for
`transport to disposal or treatment facilities . . . or sites selected by such
`person, . . .
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`from which there is a release, or a threatened release which causes the incurrence
`of response costs, of a hazardous substance, shall be liable for—
`all costs of removal or remedial action incurred by the United States Government
`. . . not inconsistent with the national contingency plan . . . .
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`The disposal of wastes at the Site constitutes a release of hazardous substances
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`(4)
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`40.
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`within the meaning of Section 107(a) of CERCLA, 42 U.S.C. § 9607(a).
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`41.
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`The actions taken by the United States and the State of Delaware in connection
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`with the Site constitute “response” actions within the meaning of Section 101(25) of CERCLA,
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`42 U.S.C. § 9601(25), and the United States and the State of Delaware have incurred response
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`costs in connection with such response actions.
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`42.
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`Defendants are liable under CERCLA Section 107(a) of CERCLA, 42 U.S.C. §
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`9607(a) for the response costs incurred by the United States and the State of Delaware.
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`SECOND CLAIM FOR RELIEF
`(Declaratory Judgment Under CERCLA Section 113(g)(2))
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`The allegations contained in Paragraphs 1-42 are re-alleged and incorporated by
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`43.
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`reference herein.
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`44.
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`CERCLA Subsection 113(g)(2), 42 U.S.C. § 9613(g)(2), specifies that in any
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`action for recovery of costs under CERCLA Section 107, 42 U.S.C. § 9607, “the court shall enter
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`a declaratory judgment on liability for response costs . . . that will be binding on any subsequent
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`action or actions to recover further response costs . . . .”
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`10
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`45.
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`The United States and the State of Delaware will continue to incur response costs
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`associated with the Site, including governmental enforcement costs that are recoverable as
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`response costs under CERCLA.
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`46.
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`The United States and the State of Delaware are entitled to entry of a declaratory
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`judgment that Defendants are jointly and severally liable to the United States and the State of
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`Delaware for future response costs incurred by the United States and the State of Delaware in
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`connection with the Site, to the extent that such costs are incurred in a manner not inconsistent
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`with the National Contingency Plan.
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`THIRD CLAIM FOR RELIEF
`(Injunctive Relief Under CERCLA Section 106)
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`The allegations contained in Paragraphs 1-46 are re-alleged and incorporated
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`47.
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`herein by reference.
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`48.
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`U.S. EPA has determined that there is or may be an imminent and substantial
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`endangerment to the public health or welfare or the environment because of actual and
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`threatened releases of hazardous substances into the environment at and from the Site.
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`49.
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`Pursuant to CERCLA Section 106(a), 42 U.S.C. § 9606(a), Defendants are subject
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`to injunctive relief to abate the danger or threat presented by releases or threatened releases of
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`hazardous substances into the environment at and from the Site.
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`FOURTH CLAIM FOR RELIEF
`(Injunctive Relief Under 7 Del.C. § 9109)
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`The allegations contained in Paragraphs 1-499 are re-alleged and incorporated
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`50.
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`herein by reference.
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`11
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`51.
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`The State of Delaware has determined that there is or may be an imminent and
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`substantial endangerment to the public health or welfare or the environment because of actual
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`and threatened releases of hazardous substances into the environment at and from the Site.
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`52.
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`7 Del. C § 9109(b) provides, “Whenever the Secretary determines that there exists
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`an imminent danger that requires immediate remedy to protect public health or welfare or the
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`environment, the Secretary may seek such injunctive relief or issue an order without prior notice
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`or opportunity to submit a proposed settlement agreement.” Accordingly, Defendants are
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`subject to injunctive relief to abate the danger or threat presented by releases or threatened
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`releases of hazardous substances into the environment at and from the Site.
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`WHEREFORE, Plaintiffs, the United States of America and State of Delaware, pray that
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`PRAYER FOR RELIEF
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`this Court:
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`1.
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`Enter judgment in favor of the United States and the State of Delaware and
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`against the Defendants for all costs, including prejudgment interest, incurred by the United States
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`and the State of Delaware for response actions and natural resource damages and assessment
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`costs in connection with the Site and not otherwise reimbursed;
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`2.
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`Enter a declaratory judgment that the Defendants are liable for all future response
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`costs and natural resource damages and assessment costs incurred by the United States and the
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`State of Delaware in connection with the Site;
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`3.
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`Enter a declaratory judgment that the Defendants are liable for injunctive relief to
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`abate the danger or threat presented by releases or threatened releases of hazardous substances
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`into the environment at and from the Site;
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`4.
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`Award the United States and the State of Delaware their costs of this action; and
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`Grant suchotherand furtherrelief as this Court deems to be just and proper.
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`Respectfully submitted,
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`TODD KIM
`Assistant Attorney General
`Environment and Natural Resources Division
`U.S. Departmentof Justice
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`fdlh
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`W. SITHER
`JOHN
`Senior Counsel
`Environmental EnforcementSection
`Environment and Natural Resources Division
`U.S. Department of Justice
`P.O. Box 7611
`Ben Franklin Station
`Washington, D.C. 20044-7611
`Ph: 202-514-5484
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`DAVID C. WEISS
`United States Attorney
`District of Delaware
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`/s/ Laura D. Hatcher
`LAURA D. HATCHER
`Civil Chief
`District of Delaware
`1007 Orange Street, Suite 700
`P.O. Box 2046
`Wilmington, DE 19899-2046
`Ph: 302-573-6277
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`OF COUNSEL:
`BEN COHAN
`Senior Assistant Regional Counsel
`U.S. EPA - RegionIII
`4 Penn Center
`Philadelphia, PA 19103
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`____________________________________
`KAYLI H. SPIALTER
`Deputy Attorney General
`Environmental Unit
`Delaware Department of Justice
`391 Lukens Drive
`New Castle, DE 19720
`Ph: 302-395-2660
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`
`14
`
`