throbber
Case: 1:21-cv-05424 Document #: 1 Filed: 10/13/21 Page 1 of 16 PageID #:1
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`Plaintiffs,
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`v.
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
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`) Civil Action No. 21-cv-5424
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`UNITED STATES OF AMERICA
`and THE STATE OF ILLINOIS,
`ex rel. KWAME RAOUL, Attorney General,
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`BUCKEYE PIPE LINE COMPANY, L.P.
`and WEST SHORE PIPE LINE COMPANY,
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`Defendants.
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`COMPLAINT
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`The United States of America, by the authority of the Attorney General of the United
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`States and through the undersigned attorneys, acting at the request of the Administrator of the
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`United States Environmental Protection Agency (“EPA”), the United States Army Corps of
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`Engineers (“Corps”) and the Secretary of the United States Department of the Interior (“DOI”)
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`on behalf of the United States Fish & Wildlife Service (“FWS”), and the State of Illinois (the
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`“State”), ex rel. Kwame Raoul, Attorney General of the State of Illinois, on his own motion and
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`at the request of the Illinois Environmental Protection Agency (“IEPA”) and the Illinois
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`Department of Natural Resources (“IDNR”), file this Complaint and allege as follows:
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`NATURE OF THE ACTION
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`1.
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`This is a civil action for penalties and injunctive relief under the Clean Water Act
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`(“CWA”), 33 U.S.C. § 1251 et seq. and for damages for injury to, destruction of, loss of, or loss
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`of use of, natural resources, and the unreimbursed costs of assessment thereof under the Oil
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`Pollution Act (“OPA”), 33 U.S.C. § 2701 et seq. against Buckeye Pipe Line Company, L.P.
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`(“Buckeye”) and West Shore Pipe Line Company (“West Shore”) (collectively “Defendants”)
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`with respect to the discharges of crude oil and the violations of a permit issued pursuant to CWA
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`Section 404(a) that occurred beginning on or about December 13, 2010, near Lockport, Will
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`County, Illinois.
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`2.
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`This action is commenced under CWA Section 311(b)(7), 33 U.S.C. § 1321(b)(7),
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`to obtain civil penalties against Defendants for discharging oil in violation of CWA Section
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`311(b)(3), 33 U.S.C. § 1321(b)(3), and under CWA Section 404(s), 33 U.S.C. § 1344(s), to
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`obtain injunctive relief and penalties for violating a condition or limitation set forth in a permit
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`issued by the Corps pursuant to CWA Section 404(a), 33 U.S.C. § 1344(a).
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`3.
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`In this action, the United States seeks to require Defendants, at their own expense
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`and at the direction of the EPA and the Corps, to restore and/or mitigate the damages caused by
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`their unlawful activities, and to pay civil penalties, as provided in 33 U.S.C. §§ 1321(b) and
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`1344(s).
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`4.
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`The United States also commences this action on behalf of the Department of the
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`Interior, a federal agency that has been designated by the President to act on behalf of the public
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`with respect to a variety of natural resources and their supporting ecosystems belonging to,
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`managed by, appertaining to, or otherwise controlled by the United States (“Federal Trustee”).
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`Exec. Order No. 12580 as amended by Exec. Order 12777; 40 C.F.R. § 300.600. The Secretary’s
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`trusteeship includes, but is not limited to, the following natural resources and their supporting
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`ecosystems: migratory birds; certain anadromous fish, endangered species and marine mammals;
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`federally owned lands and minerals; and certain federally managed water resources. 40 C.F.R.
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`§ 300.600(b)(2).
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`5.
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`The Secretary of the Interior has delegated to the Regional Director of the FWS,
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`Region 3, the authority to act as the authorized official for all natural resources within the
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`trusteeship of the Department of the Interior with respect to natural resource damage assessment
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`activities related to the discharge of oil in or around Will County, Illinois.
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`6.
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`The United States, through DOI and FWS, is a trustee for certain natural
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`resources in and around Line 257 located near Lockport, Will County, Illinois.
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`7.
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`The State of Illinois, ex rel., Kwame Raoul, Attorney General of the State of
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`Illinois, is a state of the United States, a body politic and a sovereign entity. Kwame Raoul is the
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`duly elected, qualified and sworn Attorney General of the State of Illinois, having the powers
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`and duties prescribed by the IL. CONST. art. V., § 15 (1970), and having all the powers and
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`duties of the Attorney General at common law. The Attorney General possesses both the
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`statutory and common law powers to bring this action on behalf of the State of Illinois, its
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`governmental agencies, and its people.
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`8.
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`The Illinois Department of Natural Resources is an agency of the State of Illinois
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`and has been designated by the Governor as a co-trustee of the State of Illinois’ natural
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`resources.
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`9.
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`The Illinois Environmental Protection Agency is an agency of the State of Illinois
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`and has been designated by the Governor as a co-trustee of the State of Illinois’ natural
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`resources.
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`JURISDICTION, AUTHORITY AND VENUE
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`This Court has jurisdiction over the subject matter of the United States’ claims in
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`10.
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`this action pursuant to 28 U.S.C. §§ 1331, 1345, and 1355; CWA Sections 311(b)(7)(E), 311(n),
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`and 404(s), 33 U.S.C. §§ 1321(b)(7)(E), 1321(n), and 1344(s); and OPA Section 1017(b), 33
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`U.S.C. § 2717(b). The Court has personal jurisdiction over the Defendants.
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`11.
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`Authority to bring this action is vested in the United States Department of Justice
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`by CWA Section 506, 33 U.S.C. § 1366, and by 28 U.S.C. §§ 516 and 519.
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`12.
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`Venue lies in this District pursuant to 28 U.S.C. §§ 1391(b) and (c), and 1395(a)
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`because the discharge of oil occurred in this judicial district and because Defendants conduct
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`business in this judicial district. See also 33 U.S.C. § 1321(b)(7)(E). Venue is also proper in this
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`district pursuant to CWA Section 404(s), 33 U.S.C. § 1344(s), because Defendants conduct
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`business in this district. Venue is also proper in this district pursuant to 33 U.S.C. § 2717(b),
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`because this is the judicial district in which the discharges of oil occurred.
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`13.
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`Notice of commencement of this action has been given to the State of Illinois,
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`pursuant to CWA Section 404(s)(3), 33 U.S.C. § 1344(s)(3).
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`DEFENDANTS
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`14.
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`Defendant Buckeye is a limited partnership organized under the laws of the State
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`of Delaware and conducts business in Illinois with its headquarters in Emmaus, Pennsylvania.
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`15.
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`Defendant West Shore is a corporation organized under the laws of the State of
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`Delaware with its headquarters in Lemont, Illinois.
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`STATUTORY AND REGULATORY BACKGROUND – CLEAN WATER ACT
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`16.
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`CWA Section 311(b)(3), 33 U.S.C. § 1321(b)(3), prohibits the discharge of oil or
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`hazardous substances into or upon the navigable waters of the United States or adjoining
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`shorelines in such quantities that have been determined may be harmful to the public health or
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`welfare or environment of the United States.
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`17.
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`Pursuant to CWA Section 311(b)(4), 33 U.S.C. § 1321(b)(4), EPA has determined
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`by regulation that discharges of oil in such quantities as may be harmful to the public health or
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`welfare or environment of the United States include discharges of oil that “(a) Violate applicable
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`water quality standards; or (b) Cause a film or sheen upon or discoloration of the surface of the
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`water or adjoining shorelines, or cause a sludge or emulsion to be deposited beneath the surface
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`of the water or upon adjoining shorelines.” 40 C.F.R. § 110.3.
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`18.
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`Pursuant to CWA Section 311(b)(7)(A), 33 U.S.C. § 1321(b)(7)(A), “[a]ny person
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`who is the owner, operator, or person in charge of any . . . onshore facility . . . from which oil . . .
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`is discharged in violation of paragraph (3), shall be subject to a civil penalty . . . .”
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`19.
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`CWA Section 311(b)(7)(A), 33 U.S.C. § 1321(b)(7)(A), as modified by the Civil
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`Monetary Penalty Inflation Adjustment Rules of 2008 and 2013, 73 Fed. Reg. 75,340 (Dec. 11,
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`2008) and 78 Fed. Reg. 66,643 (Nov. 6, 2013), and 40 C.F.R. § 19.4, provides that any person
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`who is the owner, operator, or person in charge of an onshore facility from which oil is
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`discharged in violation of CWA Section 311(b)(3), shall be subject to a civil penalty of up to
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`$1,100 per barrel discharged for discharges occurring between January 13, 2009 and December 6,
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`2013.
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`20.
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`CWA Section 404(a), 33 U.S.C. 1344(a), authorizes the Secretary of the Army,
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`acting through the Corps, to issue permits for the discharge of dredged or fill material into
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`navigable waters (“CWA Section 404 permit”).
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`21.
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`Regulations codified at 33 C.F.R. § 323.2(c) define “dredged material” as
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`“material that is excavated or dredged from waters of the United States.” The term “discharge of
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`dredged material” means “any addition of dredge material into, including redeposit of dredged
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`material other than incidental fallback within, the waters of the United States.” 33 C.F.R.
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`§ 323.2(d)(1).
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`22.
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`Regulations codified at 33 C.F.R. § 323.2(e)(1) define “fill material” as “material
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`placed in waters of the United States where the material has the effect of (i) Replacing any
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`portion of a water of the United States with dry land; or (ii) Changing the bottom elevation of
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`any portion of a water of the United States.”
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`23.
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`Regulations codified at 33 C.F.R. § 323.2(f) define “discharge of fill material” as
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`“the addition of fill material into waters of the United States.”
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`24.
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`CWA Section 502(7), 33 U.S.C. § 1362(7), defines “navigable waters” as “the
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`waters of the United States, including the territorial seas.”
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`25.
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`“Waters of the United States” has been defined to include, inter alia, “(a) All
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`waters that are currently used, were used in the past, or may be susceptible to use in interstate or
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`foreign commerce . . . (f) Wetlands adjacent to waters identified in paragraphs (a) through (e) of
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`this section . . . .” 40 C.F.R. §§ 110.1 & 122.2 (1993); 33 C.F.R. § 328.3(a) (1993).
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`26.
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`“Wetlands” have been defined as “those areas that are inundated or saturated by
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`surface or groundwater at a frequency and duration sufficient to support, and that under normal
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`circumstances do support, a prevalence of vegetation typically adapted to life in saturated soil
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`conditions . . . .” Wetlands generally include swamps, marshes, bogs and similar areas. 40 C.F.R.
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`§§ 110.1 & 122.2 (1993); 33 C.F.R. § 328.3(b) (1993).
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`27.
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`“Adjacent” has been defined to mean “bordering, contiguous, or neighboring.
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`Wetlands separated from other waters of the United States by man-made dikes or barriers,
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`natural river berms, beach dunes, and the like are ‘adjacent wetlands.’” 33 C.F.R. § 328.3(a)
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`(1993).
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`28.
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`Each day that dredged or fill material remains in the place where it was
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`discharged in violation of a permit issued under CWA Section 404(a) constitutes an additional
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`and continuing violation of CWA Section 404(s), 33 U.S.C. § 1344(s).
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`29.
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`CWA Section 404(s), 33 U.S.C. § 1344(s), authorizes the commencement of a
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`civil action for appropriate relief, including civil penalties up to $25,000 per day of violation,
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`and temporary and permanent injunctive relief, against any person who violates any condition or
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`limitation set forth in a permit issued by the Army Corps of Engineers under CWA Section
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`404(a), 33 U.S.C. § 1344(a).
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`STATUTORY AND REGULATORY BACKGROUND – OIL POLLUTION ACT
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`30.
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`OPA Section 1002(a), 33 U.S.C. § 2702(a), provides that “each responsible party
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`for a . . . facility from which oil is discharged, or which poses a substantial threat of a discharge
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`of oil, into or upon the navigable waters or adjoining shore lines . . . is liable for the removal
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`costs and damages specified in [33 U.S.C. § 2702(b)] that result from such incident.”
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`31.
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`OPA Section 1001(7), 33 U.S.C. § 2701(7), provides: “‘discharge’ means any
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`emission (other than natural seepage), intentional or unintentional, and includes, but is not
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`limited to, spilling, leaking, pumping, pouring, emitting, emptying, or dumping.”
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`32.
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`OPA Section 1001(23), 33 U.S.C. § 2701(23), states, “‘oil’ means oil of any kind
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`or in any form, including, but not limited to petroleum, fuel oil, sludge, oil refuse, and oil mixed
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`with wastes other than dredged spoil, but does not include any substance which is specifically
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`listed or designated as a hazardous substance under subparagraphs (A) through (F) of Section
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`101(14) of the Comprehensive Environmental Response, Compensation and Liability Act
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`(42 U.S.C. § 9601) and which is subject to provisions of that Act.”
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`33.
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`OPA Section 1001(9), 33 U.S.C. § 2701(9), defines “facility” as “any structure,
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`group of structures equipment, or device (other than a vessel) which is used for one or more of
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`the following purposes: exploring for, drilling for, producing, storing, handling, transferring,
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`processing, or transporting oil. This term includes any motor vehicle, rolling stock or pipeline
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`used for one or more of these purposes.”
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`34.
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`OPA Section 1001(14), 33 U.S.C. § 2701(14), defines “incident” to mean “any
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`occurrence or series of occurrences having the same origin, involving one or more . . . facilities
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`. . . resulting in the discharge or substantial threat of discharge of oil.”
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`35.
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`OPA Section 1001(32)(F), 33 U.S.C. § 2701(32)(F), provides that “‘responsible
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`party’ means . . . (F) In the case of a pipeline, any person owning or operating the pipeline.”
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`36.
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`OPA Section 1001(27), 33 U.S.C. § 2701(27), defines “person” to include a
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`corporation.
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`37.
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`Section 1002(b)(2) of OPA, 33 U.S.C. § 2702(b)(2), provides that “damages”
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`referred to in Section 1002(a) of OPA, 33 U.S.C. § 2702(a), include “[d]amages for injury to,
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`destruction of, loss of, or loss of use of, natural resources, including the reasonable costs of
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`assessing the damage, which shall be recoverable by a United States trustee, a State trustee, an
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`Indian tribe trustee, or a foreign trustee.”
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`38.
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`OPA Section 1001(20), 33 U.S.C. § 2701(20), provides: “‘natural resources’
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`includes land, fish, wildlife, biota, air, water, ground water, drinking water supplies, and other
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`such resources belonging to, managed by, held in trust by, appertaining to, or otherwise
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`controlled by the United States . . . [or] any State or local government . . . .”
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`39.
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`OPA Section 1001(21), 33 U.S.C. § 2701(21), provides that “‘navigable waters’
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`means the waters of the United States, including the territorial sea.”
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`FACTUAL ALLEGATIONS
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`40.
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`Line 257 is a 12-inch, 3.5 mile long subsurface pipeline owned by West Shore
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`and operated by Buckeye. At all times relevant to this action, the sole function of Line 257 was
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`to transport crude oil from a Shell Oil terminal facility in Lockport, Illinois, to a Citgo oil
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`refinery in Lamont, Illinois.
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`41.
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`On or about December 13, 2010, Line 257 developed a hole in a segment of
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`pipeline running below the ground surface between New Avenue and railroad tracks north of
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`Lockport, Will County, Illinois.
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`42.
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`The hole developed on Line 257 at a time when crude oil was not actively being
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`pumped through the pipeline.
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`43.
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`Later that day or early the next morning, when crude oil started pumping into
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`Line 257 from the Shell terminal, oil was discharged from the pipeline.
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`44.
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`The discharge of crude oil from Line 257 flowed into a drainage ditch, through a
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`culvert under the railroad tracks, and into a wetland adjacent to the Illinois & Michigan Canal.
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`45.
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`Approximately 1,857 barrels or more of crude oil were discharged from Line 257
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`before the hole was identified and the leak stopped (the “Discharge Incident”).
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`46.
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`Defendants are each a “person” within the meaning of CWA Sections 311(a)(7)
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`and 502(5), and OPA Section 1001(27). 33 U.S.C. §§ 1321(a)(7), 1362(5), and 2701(27).
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`47. West Shore’s pipeline designated as Line No. 257 is an “onshore facility” within
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`the meaning of CWA Section 311(a)(10), 33 U.S.C. § 1321(a)(10), and is a “facility” within the
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`meaning of OPA Section 1001(9), 33 U.S.C. § 2701(9), because it was and is used for
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`“producing, storing, handling, transferring, processing, or transporting oil.”
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`48. West Shore is the “owner” of Line No. 257 from which oil was discharged within
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`the meaning of CWA Section 311(a)(6), 33 U.S.C. § 1321(a)(6), and OPA Section 1001(26),
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`33 U.S.C. § 2701(26).
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`49.
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`Buckeye is the “operator” of Line No. 257 from which oil was discharged within
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`the meaning of CWA Section 311(a)(6), 33 U.S.C. § 1321(a)(6), and OPA Section 1001(26),
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`33 U.S.C. § 2701(26).
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`50.
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`The release of crude oil from Line No. 257 near Lockport, Illinois, on or around
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`December 13 and 14, 2010, constituted a “discharge” of oil within the meaning of CWA Section
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`311(a)(2), 33 U.S.C. § 1321(a)(2).
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`51.
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`Crude oil is “oil” within the meaning of CWA Section 311(a)(1), 33 U.S.C.
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`§ 1321(a)(1), and constitutes “oil” within the meaning of OPA Section 1001(23), 33 U.S.C.
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`§ 2701(23).
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`52.
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`In the course of responding to the discharge of oil, Defendants, among other
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`actions, placed sumps, booms, straw bales, and groundwater monitoring wells, and excavated
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`trenches, in the wetland adjacent to the Illinois & Michigan Canal.
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`53.
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`Following the initial response to the spill, Defendants discharged dredged and/or
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`fill materials at the spill site, without a CWA Section 404 permit.
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`54.
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`On or about June 27, 2013, the United States Army Corps of Engineers granted
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`Defendants a Partial After-The-Fact authorization under Regional Permit 13.
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`55.
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`After receiving the Partial After-The-Fact authorization under Regional Permit 13,
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`Defendants conducted activities that impacted waters of the United States beyond the scope of
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`their June 27, 2013, authorization.
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`56.
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`The discharges of dredged and/or fill described in paragraph 55 occurred in a
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`wetland, as defined in 40 C.F.R. § 122.2 and 33 C.F.R. § 328.3(c)(4).
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`57.
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`The wetland into which Defendants discharged dredged and/or fill material is
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`adjacent to the Illinois & Michigan Canal, a navigable-in-fact water, and is therefore a water of
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`the United States. 40 C.F.R. §§ 110.1 & 122.2 (1993); 33 C.F.R. § 328.3(b) (1993).
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`58.
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`The crude oil discharged from Line 257 resulted in a discharge or substantial
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`threat of discharge into or upon the navigable waters or adjoining shorelines within the meaning
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`of OPA Section 1002, 33 U.S.C. § 2702.
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`59.
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`Each Defendant is a “responsible party” within the meaning of OPA Section
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`1001(32)(B), 33 U.S.C. § 2701(32)(B), with respect to the Discharge Incident.
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`60.
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`“Natural resources” as that term is defined in OPA Section 1001(20), 33 U.S.C.
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`§ 2701(20), held in trust by Federal, State and Tribal Trustees, have been injured, destroyed, or
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`lost as the result of the Discharge Incident, within the meaning of 33 U.S.C. § 2702(b)(2).
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`FIRST CLAIM FOR RELIEF
`(Civil Penalties under CWA Section 311(b) Related to Discharge of Oil)
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`Paragraphs 1 through 60 are re-alleged and incorporated herein by reference.
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`On or about December 13, 2010, damage to Line 257 near Lockport, Illinois,
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`61.
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`62.
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`resulted in the discharge of oil in a harmful quantity into the navigable waters and/or adjoining
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`shorelines of the United States in violation of CWA Section 311(b)(3), 33 U.S.C. § 1321(b)(3).
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`63. West Shore, as the owner of Line 257 at the time of this discharge, is liable for a
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`civil penalty of up to $1,100 per barrel discharged, pursuant to CWA Section 311(b)(7)(A),
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`33 U.S.C. § 1321(b)(7)(A), and 40 C.F.R. § 19.4.
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`64.
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`Buckeye, as the operator of Line 257 at the time of this discharge, is liable for a
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`civil penalty of up to $1,100 per barrel discharged, pursuant to CWA Section 311(b)(7)(A),
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`33 U.S.C. § 1321(b)(7)(A), and 40 C.F.R. § 19.4.
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`SECOND CLAIM FOR RELIEF
`(Civil Penalties Under CWA Section 404(s))
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`Paragraphs 1 through 60 are re-alleged and incorporated herein by reference.
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`Although Buckeye received a Partial After-The-Fact authorization on June 27,
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`65.
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`66.
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`2013, Buckeye conducted activities that exceeded the scope of that authorization.
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`67.
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`By exceeding the scope of the Partial After-The-Fact authorization, Buckeye
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`violated a condition or limitation of that authorization.
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`68.
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`Each instance of Buckeye exceeding the scope of the Partial After-The-Fact
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`authorization constitutes a violation of CWA Section 404(s), 33 U.S.C. § 1344(s).
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`69.
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`Buckeye is liable for civil penalties under CWA Section 404(s), 33 U.S.C.
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`§ 1344(s).
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`THIRD CLAIM FOR RELIEF
`(Injunctive Relief under CWA Section 404(s))
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`Paragraphs 1 through 60 are re-alleged and incorporated herein by reference.
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`Although Buckeye received a Partial After-The-Fact authorization on June 27,
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`70.
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`71.
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`2013, Buckeye conducted activities that exceeded the scope of that authorization.
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`72.
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`By exceeding the scope of the Partial After-The-Fact authorization, Buckeye
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`violated a condition or limitation of that authorization.
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`73.
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`Each instance of Buckeye exceeding the scope of the Partial After-The-Fact
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`authorization constitutes a violation of CWA Section 404(s), 33 U.S.C. § 1344(s).
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`74.
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`The United States is entitled to injunctive relief, pursuant to CWA Section 404(s),
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`33 U.S.C. § 1344(s).
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`FOURTH CLAIM FOR RELIEF
`(Liability under OPA Section 1006 for
`Assessment Costs and Natural Resource Damages)
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`Paragraphs 1 through 60 are re-alleged and incorporated herein by reference.
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`As a “responsible party,” each Defendant is strictly liable to the United States and
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`75.
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`76.
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`the State of Illinois pursuant to OPA Section 1002(b)(2)(A), 33 U.S.C. § 2702(b)(2)(A), for
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`damages for injury to, destruction of, loss of, or loss of use of, natural resources, including the
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`reasonable costs of assessing the damages resulting from the Discharge Incident.
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`PRAYER FOR RELIEF
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`WHEREFORE, the United States prays that this Court:
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`A.
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`Impose civil penalties under Section 311(b) of the Clean Water Act on each
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`Defendant in an amount up to $1,100 per barrel of oil discharged as alleged in this Complaint;
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` 13
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`Case: 1:21-cv-05424 Document #: 1 Filed: 10/13/21 Page 14 of 16 PageID #:14
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`B.
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`Issue an order pursuant to CWA Section 404(s), imposing civil penalties on each
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`Defendant of up to $25,000 for each day that Defendants are in violation of a permit issued
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`under CWA Section 404(a).
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`C.
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`Issue an order pursuant to CWA Section 404(s) compelling Defendants to restore
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`the wetlands that were damaged due to Defendants’ violation of a permit issued under CWA
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`Section 404(a).
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`AND WHEREFORE, the United States and the State of Illinois prays that this Court:
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`D.
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`Enter a judgment, pursuant to OPA Sections 1002(a) and 1006, 33 U.S.C.
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`§§ 2702(a) and 2706, awarding the United States and the State of Illinois damages for injury to,
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`destruction of, loss of, or loss of use of natural resources, including the reasonable costs of
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`assessing such injury, destruction, loss, or loss of use, which will be binding on this action and
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`on any subsequent action or actions to recover assessment costs or damages;
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`E. Grant such other and further relief that this Court deems just and proper.
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`Respectfully submitted,
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`FOR THE UNITED STATES OF AMERICA
`
`TODD KIM
`Assistant Attorney General
`Environment and Natural Resources Division
`U.S. Department of Justice
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` s/Michael J. Zoeller
`MICHAEL J. ZOELLER
`Environmental Enforcement Section
`Environment and Natural Resources Division
`U.S. Department of Justice
`P.O. Box 7611
`Washington, D.C. 20044-7611
`(202) 305-1473
`michael.zoeller@usdoj.gov
` 14
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`Case: 1:21-cv-05424 Document #: 1 Filed: 10/13/21 Page 15 of 16 PageID #:15
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` s/Daniel Dertke (with consent)
`DANIEL DERTKE
`Environmental Defense Section
`Environment and Natural Resources Division
`U.S. Department of Justice
`P.O. Box 7611
`Washington, D.C. 20044-7611
`(202) 514-0994
`daniel.dertke@usdoj.gov
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`JOHN R. LAUSCH, JR.
`United States Attorney
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`OF COUNSEL:
`RICHARD CLARIZIO
`Associate Regional Counsel
`U.S. Environmental Protection
` Agency, Region 5
`77 West Jackson Boulevard
`Chicago, IL 60604-3590
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`KEVIN J. JERBI
`Assistant District Counsel
`U.S. Army Corps of Engineers
` Chicago District
`231 S. LaSalle Street, Suite 1500
`Chicago, IL 60604
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`KIMBERLY GILMORE
`Attorney-Advisor, Office of the Solicitor
`U.S. Dept. of the Interior
`Three Parkway Center, Rm 385
`Pittsburgh, PA 15220
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`
` s/Jonathan C. Haile (with consent)
` By: JONATHAN C. HAILE
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`Assistant United States Attorney
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`Northern District of Illinois
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`219 South Dearborn Street, Fifth Floor
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`Chicago, IL 60604
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`Voice: (312) 886-2055
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`jonathan.haile@usdoj.gov
`
` 15
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`

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`Case: 1:21-cv-05424 Document #: 1 Filed: 10/13/21 Page 16 of 16 PageID #:16
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`PEOPLE OF THE STATE OF ILLINOIS,
`ex rel. KWAME RAOUL, Attorney
`General of the State of Illinois,
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`MATTHEW J. DUNN, Chief
`Environmental Enforcement/
`Asbestos Litigation Division
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`By: s/Stephen J. Sylvester (with consent)
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`STEPHEN J. SYLVESTER, Chief
`Assistant Attorney General
`Environmental Bureau
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`OF COUNSEL:
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`GERALD T. KARR
`Assistant Attorney General
`Environmental Bureau
`69 W. Washington Street, 18th Floor
`Chicago, Illinois 60602
`(312) 814-3369
`gerald.karr@ilag.gov
`
`
`
` 16
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`

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