`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE MIDDLE DISTRICT OF LOUISIANA
`
`UNITED STATES OF AMERICA,
`
`Plaintiff,
`
`v.
`
`METAIRIE ENERGY COMPANY, INC.,
`and
`
`BERNARD P. ROBICHAUX,
`
`Defendants.
`
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` )
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`Civil Action No.
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`21-126
`
`Judge
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`COMPLAINT
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`The United States of America, acting at the request of the United States Coast Guard,
`
`files this Complaint and alleges the following:
`
`NATURE OF THIS ACTION
`
`1.
`
`The United States seeks repayment by defendants Metairie Energy Company, Inc.
`
`(“Metairie”) and Bernard P. Robichaux (collectively, “Defendants”), as jointly and severally
`
`liable “responsible parties” under Section 1002(a) of the Oil Pollution Act (“OPA”), 33 U.S.C.
`
`§ 2702(a), for over $1.3 million in costs paid by the Oil Spill Liability Trust Fund (the “Fund”)
`
`for a removal action following an August 2016 oil spill (the “Incident”) from Defendants’ oil
`
`facility located in the Choctaw Bayou Oil and Gas Field along the Port Allen Lock in Iberville
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`Parish, Louisiana (the “Facility”). In addition, in the alternative, the United States seeks
`
`repayment from Defendants pursuant to its subrogation rights under OPA Sections 1012 and
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`1015, 33 U.S.C. §§ 2712 and 2715, of these same removal costs paid by the Fund to Oil Spill
`
`Removal Organizations (“OSROs”) and their subcontractors – Oil Mop, LLC (“Oil Mop”);
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`Enhanced Environmental & Emergency Services (“EE&E Services”); A&M Associates, Inc.
`
`(“A&M Associates”); Workbox, LLC (“Workbox”); TREO Staffing, LLC (“TREO”); and
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`Tanner Services, LLC (“Tanner”) (collectively, the “Claimants”) – for their uncompensated oil-
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`spill removal costs incurred under a contractual agreement with Defendants relating to the
`
`Incident.
`
`2.
`
`The United States seeks a judgment against Defendants, jointly and severally, for
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`$1,376,234.29, and all costs incurred by the Fund by reason of this claim, including interest
`
`(including prejudgment interest), administrative and adjudicative costs, and attorney’s fees, and
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`any other relief that may be appropriate.
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`JURISDICTION AND VENUE
`
`3.
`
`This court has jurisdiction over the subject matter of this action and over the
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`parties pursuant to Section 1017(b) of OPA, 33 U.S.C. § 2717(b), and 28 U.S.C. §§ 1331 and
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`1345.
`
`4.
`
`Authority to bring this action is vested in the United States Department of Justice
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`by 28 U.S.C. §§ 516 and 519.
`
`5.
`
`Venue is proper in this District pursuant to Section 1017(b) of OPA, 33 U.S.C.
`
`§ 2717(b), and 28 U.S.C. § 1391(b), because it is the judicial district in which Defendants are
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`located and in which the discharge and the resulting removal action occurred.
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`DEFENDANTS
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`
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`6.
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`Defendant Metairie Energy Company, Inc. is organized under the laws of the
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`State of Louisiana with its principal place of business in the City of Mandeville, Parish of St.
`
`Tammany, Louisiana. Metairie is the owner and operator of the oil facility located in the
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`Choctaw Bayou Oil and Gas Field located at 60825 Highway 1148, Plaquemine, Iberville Parish,
`
`Louisiana. It is listed as “Not in Good Standing” on the Secretary of State’s registry.
`
`7.
`
`Defendant Bernard P. Robichaux is the President of Metairie. Mr. Robichaux is
`
`and was an operator of the Facility at the time of the Incident. He directs the Facility’s
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`operations, including oil handling and discharge activities.
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`STATUTORY AND REGULATORY BACKGROUND
`
`8.
`
`OPA Section 1002(a), 33 U.S.C. § 2702(a), provides that “each responsible party
`
`for . . . a facility from which oil is discharged, or which poses the substantial threat of a
`
`discharge of oil, into or upon the navigable waters or adjoining shorelines . . . is liable for the
`
`removal costs and damages specified in subsection (b) of this section [33 U.S.C. § 2702(b)] that
`
`result from such incident.”
`
`9.
`
`OPA Section 1001(7), 33 U.S.C. § 2701(7), defines “discharge” to mean “any
`
`emission (other than natural seepage), intentional or unintentional” and to include “spilling,
`
`leaking, pumping, pouring, emitting, emptying, or dumping[.]”
`
`10.
`
`OPA Section 1001(9), 33 U.S.C. § 2701(9), defines “facility” to mean “any
`
`structure, group of structures, equipment, or device (other than a vessel) which is used for one or
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`more of the following purposes: . . . storing, handling, processing [or] transferring . . . oil.”
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`11.
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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[.]”
`
`12.
`
`OPA Section 1001(21), 33 U.S.C. § 2701(21), defines “navigable waters” as “the
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`waters of the United States, including the territorial sea[.]”
`
`13.
`
`OPA Section 1001(23), 33 U.S.C. § 1701(23), defines “oil” to mean “oil of any
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`kind or in any form, including petroleum, fuel oil, sludge, oil refuse, and oil mixed with wastes
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`other than dredged spoil[.]”
`
`14.
`
`OPA Section 1001(24), 33 U.S.C. § 2701(24), defines “onshore facility” to mean
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`“any facility (including, but not limited to, motor vehicles and rolling stock) of any kind located
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`in, on or under any land within the United States other than submerged land.”
`
`15.
`
`OPA Section 1001(27), 33 U.S.C. § 2701(27), defines “person” to mean an
`
`“individual, corporation, partnership, [or] association[.]”
`
`16.
`
`OPA Section 1001(30), 33 U.S.C. § 2701(30), defines “remove” and “removal” to
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`mean “containment and removal of oil or a hazardous substance from water and shorelines or the
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`taking of other actions as may be necessary to minimize or mitigate damage to the public health
`
`or welfare, including, but not limited to, fish, shellfish, wildlife, and public and private property,
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`shorelines, and beaches[.]”
`
`17.
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`OPA Section 1001(31), 33 U.S.C. § 2701(31), defines “removal costs” to mean
`
`“the costs of removal that are incurred after a discharge of oil has occurred or, in any case in
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`which there is a substantial threat of a discharge of oil, the costs to prevent, minimize, or mitigate
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`oil pollution from such an incident[.]”
`
`18.
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`OPA Section 1001(32)(E), 33 U.S.C. § 2701(32), defines “responsible party” to
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`include, “[i]n the case of an onshore facility (other than a pipeline), any person owning or
`
`operating the facility.”
`
`19.
`
`OPA Section 1001(26)(A)(ii), 33 U.S.C. § 2701(26)(A)(ii), defines “owner or
`
`operator” to mean, “in the case of an onshore or offshore facility, any person owning or
`
`operating such facility.”
`
`20.
`
`OPA Section 1002(b), 33 U.S.C. § 2702(b), provides that the “removal costs”
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`referred to in Section 1002(a) of OPA, 33 U.S.C. § 2702(a), include “(A) all removal costs
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`incurred by the United States . . . under subsection (c), (d), (e), or (l) of Section 1321 of this title
`
`[Section 311 of the Clean Water Act, 33 U.S.C. § 1321]. . .; and (B) any removal costs incurred
`
`by any person for acts taken by the person which are consistent with the National Contingency
`
`Plan [40 C.F.R. Part 300 (“NCP”)].”
`
`21.
`
`Pursuant to OPA Section 1012(a)(4), 33 U.S.C. § 2712(a)(4), the Fund is
`
`authorized to reimburse persons, including OSROs, for uncompensated removal costs
`
`determined to be consistent with the NCP. The Fund is administered by the Coast Guard’s
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`National Pollution Funds Center (“NPFC”) and financed in part by recoveries from responsible
`
`parties.
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`22.
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`OPA Section 1013(e), 33 U.S.C. § 2713(e), authorizes the promulgation of
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`regulations for the presentation, filing, processing, settlement and adjudication of OPA claims
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`against the Fund. Pursuant to this authority, the Coast Guard has promulgated regulations
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`establishing claims procedures, codified at 33 C.F.R. Part 136.
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`23.
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`OPA Section 1012(f), 33 U.S.C. § 2712(f), provides that “[p]ayment of any claim
`
`. . . by the Fund under this Act shall be subject to the United States Government acquiring by
`
`subrogation all rights of the claimant . . . to recover from the responsible party.”
`
`24.
`
`OPA Section 1015(a), 33 U.S.C. § 2715(a), provides further that “[a]ny person,
`
`including the Fund, who pays compensation pursuant to this Act to any claimant for removal
`
`costs . . . shall be subrogated to all rights, claims, and causes of action that the claimant has under
`
`any other law.”
`
`25.
`
`OPA Section 1015(c), 33 U.S.C. § 2715(c), provides that the United States, in an
`
`action brought under that Section, may seek “any compensation paid by the Fund to any claimant
`
`pursuant to this Act, and all costs incurred by the Fund by reason of the claim, including interest
`
`(including prejudgment interest), administrative and adjudicative costs, and attorney’s fees.”
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`GENERAL ALLEGATIONS
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` The Incident
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`The Facility is part of the Choctaw Bayou Oil and Gas field located at 60825
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`A.
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`26.
`
`Highway 1148, Plaquemine, Iberville Parish, Louisiana, 70756. The Facility is located in the
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`wetlands of the Choctaw Bayou and along the Port Allen Lock. The Facility includes an oil well
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`and a number of 400-barrel above ground storage tanks that contain crude oil or oily water
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`emulsion.
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`27.
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`On August 29, 2016, the Louisiana Department of Natural Resources (“LDNR”)
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`inspected the Facility and discovered that oil from one of the Facility’s above ground storage
`
`tanks (“Tank No. 2”) had discharged from the tank directly into the surrounding wetlands
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`sometime earlier in August 2016.
`
`28.
`
`After the discovery of the Incident, Bernard P. Robichaux ordered workers at the
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`Facility to clean the discharged oil by spraying commercial soaps on the affected wetlands.
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`29.
`
`On January 31, 2017, the EPA assessed the Facility and found that the discharged
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`oil had not been cleaned up. During the assessment, EPA found heavily contaminated vegetation
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`and ponds across approximately 10 acres of wetlands, approximately 400 feet from the Port
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`Allen Lock.
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`30.
`
`The Port Allen Lock is a navigable-in-fact water that flows into Choctaw Bayou,
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`the Intracoastal Waterway, the Mississippi River, and then the Gulf of Mexico.
`
`31.
`
`32.
`
`The impacted wetlands abut the Port Allen Lock.
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`EPA issued a Notice of Federal Interest (“NOFI”) to Metairie on January 31,
`
`2017, and it directed Metairie to notify the National Response Center of the oil discharge and to
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`hire an OSRO to properly remove the oil and resulting contamination.
`
`33.
`
`EPA mobilized the Coast Guard’s Gulf Strike Team to assist with the removal
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`action.
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`34. Metairie hired A&M Associates to act as its spill management team and
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`coordinate removal activities.
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`35.
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`A&M Associates prepared a work plan for the removal action and subcontracted
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`with Oil Mop, EE&E Services, and Workbox. Oil Mop subcontracted with TREO and Tanner to
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`obtain additional personnel to conduct removal activities.
`
`36.
`
`Due to the wide impact of the oil discharge, the impacted area was divided into
`
`zones and boom was placed to prevent further migration of the oil into the Port Allen Lock and
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`surrounding wetlands.
`
`37.
`
` Defendants’ OSROs worked to remove oiled vegetation, move affected wildlife
`
`to areas unaffected by the oil spill, and remove the oil and contaminated soil using boom, sorbent
`
`pads, and vacuum trucks.
`
`38.
`
`A&M Associates facilitated the collection of samples from the impacted soils and
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`sediments as well as samples of the remaining contents of Tank No. 2. The laboratory analytical
`
`results show that the substance discharged from Tank No. 2 was oil as defined by OPA.
`
`39.
`
`On April 13, 2018, the removal was completed and EPA issued the Final
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`Removal Pollution Report.
`
`B.
`
`40.
`
`The Coast Guard’s Costs and Demands for Payment
`
`On February 14, 2017, Oil Mop submitted its bill to Defendants in the amount of
`
`$1,079,398.17. Defendants did not pay the bill.
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`41.
`
`On or about May 18, 2017, Oil Mop presented its claim to the NPFC in the
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`amount of $1,079,398.17.
`
`42.
`
`The NPFC adjudicated Oil Mop’s claim. The NPFC determined that $265.29 of
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`Oil Mop’s claim was inconsistent with the NCP. The NPFC offered Oil Mop $1,079,132.88 for
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`its uncompensated removal costs. Oil Mop accepted the offer, and payment was issued on March
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`7, 2018. As part of the acceptance agreement, Oil Mop assigned, transferred, and subrogated all
`
`rights, claims, interests and rights of action to the United States.
`
`43.
`
`On February 13, 2017, EE&E Services submitted its bill to Defendants in the
`
`amount of $71,169.07. Defendants did not pay the bill.
`
`44.
`
`On or about June 20, 2017, EE&E Services presented its claim to the NPFC in the
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`amount of $71,169.07.
`
`45.
`
`The NPFC adjudicated EE&E Services’ claim. The NPFC offered EE&E Services
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`$71,169.07 for its uncompensated removal costs. EE&E Services accepted the offer and payment
`
`was issued on March 2, 2018. As part of the acceptance agreement, EE&E Services assigned,
`
`transferred, and subrogated all rights, claims, interests, and rights of action to the United States.
`
`46.
`
`On March 2, 2017, A&M Associates submitted its bill to Defendants on in the
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`amount of $229,460.14. Defendants did not pay the bill.
`
`47.
`
`On or about November 9, 2017, A&M Associates presented its claim to the NPFC
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`in the amount of $229,460.14.
`
`48.
`
`The NPFC adjudicated A&M Associates’ claim and determined that $102,570.83
`
`of A&M Associates’ costs were not consistent with the NCP or were unreasonable. The NPFC
`
`offered A&M Associates $126,889.31 for its uncompensated removal costs. A&M Associates
`
`accepted the offer and payment was issued on May 10, 2018. As part of the acceptance
`
`agreement, A&M Associates assigned, transferred, and subrogated all rights, claims, interests,
`
`and rights of action to the United States.
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`49.
`
`The NPFC was notified that due to Defendants’ refusal to pay A&M Associates,
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`A&M Associates could not pay its subcontractor, Workbox.
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`50.
`
`On July 2, 2018, Workbox presented its claim to the NPFC for uncompensated
`
`removal costs related to the Incident in the amount of $2,154.45.
`
`51.
`
`The NPFC adjudicated Workbox’s claim. The NPFC offered Workbox $2,154.45
`
`for its uncompensated removal costs. Workbox accepted the offer and payment was issued on
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`July 18, 2018. As part of the acceptance agreement, Workbox assigned, transferred, and
`
`subrogated all rights, claims, interests, and rights of action to the United States.
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`52.
`
`On November 15, 2018, TREO presented its claim to the NPFC for
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`uncompensated removal costs related to the Incident in the amount of $3,747.65.
`
`53.
`
`The NPFC adjudicated TREO’s claim and determined that $1,510.32 of TREO’s
`
`costs was inconsistent with the NCP or unreasonable. The NPFC offered TREO $2,237.33 for its
`
`uncompensated removal costs. TREO accepted the offer and payment was issued on February
`
`27, 2019. As part of the acceptance agreement, TREO Staffing, LLC assigned, transferred, and
`
`subrogated all rights, claims, interests, and rights of action to the United States.
`
`54.
`
`On December 10, 2018, Tanner presented its claim to the NPFC for
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`uncompensated removal costs related to the Incident in the amount of $1,980.00.
`
`55.
`
`The NPFC adjudicated Tanner’s claim. The NPFC offered Tanner $1,980.00 for
`
`its uncompensated removal costs. Tanner accepted the offer and payment was issued on February
`
`19, 2019. As part of the acceptance agreement, Tanner assigned, transferred, and subrogated all
`
`rights, claims, interests, and rights of action to the United States.
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`56.
`
`On February 18, 2019, Oil Mop submitted a second claim to the NPFC for
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`uncompensated costs incurred by Oil Mop during the NPFC’s adjudication of Oil Mop’s initial
`
`claim.
`
`57.
`
`The NPFC adjudicated Oil Mop’s second claim and offered $12,932.10 for its
`
`uncompensated removal costs. Oil Mop accepted the offer and payment was issued on February
`
`19, 2019. As part of the acceptance agreement, Oil Mop assigned, transferred, and subrogated all
`
`rights, claims, interests, and rights of action to the United States.
`
`58.
`
`In responding to the Incident, the EPA incurred $67,193.63. Those costs were
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`reimbursed by the Fund.
`
`59.
`
`In responding to the Incident, the United States Coast Guard incurred $5,318.27.
`
`Those costs were reimbursed by the Fund.
`
`60.
`
`The NPFC incurred $7,227.25 in costs to adjudicate the claims presented by
`
`Defendants’ OSROs and their subcontractors related to the Incident.
`
`61.
`
`The NPFC issued a Notice of Potential Liability (“NOPL”) to Metairie on June
`
`22, 2018, notifying Metairie of potential liability for oil removal costs. Defendants did not reply
`
`to the NOPL.
`
`62.
`
`NPFC issued a bill to Metairie on July 30, 2018, for the costs paid by the Fund to
`
`the OSROs and their subcontractors, the EPA, and the Coast Guard for their uncompensated
`
`removal costs associated with the Incident. Defendants did not pay.
`
`63.
`
`On August 23, 2018, the NPFC issued a second bill to Metairie for the costs paid
`
`by the Fund (including those costs paid since the July 20, 2018 bill) to the OSROs and their
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`subcontractors, the EPA, and the Coast Guard for their uncompensated removal costs associated
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`with the Incident. Defendants did not pay.
`
`64.
`
`On April 10, 2019, the NPFC issued a third bill to Metairie for the costs paid by
`
`the Fund (including those costs paid since the August 23, 2018 bill) to the OSROs and their
`
`subcontractors, the EPA, and the Coast Guard for their uncompensated removal costs associated
`
`with the Incident. Defendants did not pay.
`
`65.
`
`On September 27, 2019, the NPFC issued a bill to Bernard Robichaux for
`
`removal costs associated with the Incident. Defendants did not pay.
`
`66.
`
`No one has reimbursed the Fund for any of the $1,376,234.29 in removal costs
`
`incurred by the United States.
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`LEGAL CONTENTIONS SUPPORTING CLAIMS FOR RELIEF
`
`67.
`
`Defendants are each “persons” within the meaning of Section 1001(27) of OPA,
`
`33 U.S.C. § 2701(27).
`
`68.
`
`Tank No. 2, is an “onshore facility,” and was a “facility” at the time of the
`
`Incident, within the meaning of Section 1001(9) of OPA, 33 U.S.C. § 2701(9).
`
`69. Metairie is the owner and was the owner of the Tank No. 2 at the time of the
`
`Incident within the meaning of Section 1001(26)(A)(ii) of OPA, 33 U.S.C. § 2701(26)(A)(ii),
`
`and Section 1001(32)(B) of OPA, 33 U.S.C. § 2701(32)(B), and is a “responsible party” within
`
`the meaning of Sections 1002(a) and 1001(31) of OPA, 33 U.S.C. §§ 2702(a) and 2701(32).
`
`70.
`
`Defendants were at the time of the Incident “operators” of Tank No. 2 within the
`
`meaning of Section 1001(26)(A)(ii) of OPA, 33 U.S.C. § 2701(26)(A)(ii), and Section
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`1001(32)(B) of OPA, 33 U.S.C. § 2701(32)(B), and are “responsible parties” within the meaning
`
`of Sections 1002(a) and 1001(32) of OPA, 33 U.S.C. §§2702(a) and 2701(32).
`
`71.
`
`The discharge of oil from Tank No. 2 into the wetlands of the Port Allen Lock
`
`and Choctaw Bayou was a “discharge” or substantial threat of a discharge of “oil” into
`
`“navigable waters” and adjoining shorelines as those terms are defined in Section 1001(7) of
`
`OPA, 33 U.S.C. § 2701(7) (“discharge”), Section 1001(23) of OPA, 33 U.S.C. § 2701(23)
`
`(“oil”), and Section 1001(21) of OPA, 33 U.S.C. § 2701(21) (“navigable waters”).
`
`72.
`
`The actions described above were “removal” actions within the meaning of
`
`Section 1001(30) of OPA, 33 U.S.C. § 2701(30).
`
`73.
`
`The money paid or incurred by the Fund for the removal action conducted in
`
`response to releases of oil from Tank No. 2 into the wetlands of the Port Allen Lock and
`
`Choctaw Bayou were “removal costs” within the meaning of Section 1001(31) of OPA, 33
`
`U.S.C. § 2701(31), and Section 1002(b)(1) of OPA, 33 U.S.C. § 2702(b)(1).
`
`74.
`
`The monies paid by the Fund to reimburse Defendants’ OSROs and their
`
`subcontractors pursuant to OPA Section 1012(a)(4), 33 U.S.C. § 2712(a)(4), were for removal
`
`actions taken by the OSROs and their subcontractors that were consistent with the National
`
`Contingency Plan, 40 C.F.R. Part 300 et seq. The amounts incurred to adjudicate those claims
`
`are recoverable costs under OPA Section 1015(c), 33 U.S.C. § 2715(c).
`
`75.
`
`As a result of the actions described above, the Fund has incurred at least
`
`$1,376,234.29 in unreimbursed removal costs for the Incident.
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`FIRST CLAIM FOR RELIEF
`LIABILITY FOR REMOVAL COSTS
`UNDER OPA SECTION 1002(a)
`
`
`
`76.
`
`As owners and/or operators of the Facility from which oil was discharged into
`
`navigable waters and adjoining shorelines, Defendants are liable, jointly and severally, to the
`
`United States under Section 1002(a) of OPA, 33 U.S.C. § 2702(a), for $1,376,234.29 in removal
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`costs paid or incurred by the Fund as a result of the discharge of oil from the Facility into the
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`wetlands of the Port Allen Lock and Choctaw Bayou in connection with the Incident. Defendants
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`are also liable to the United States under Section 1015(c) of OPA, 33 U.S.C. §§ 2715(c), for all
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`costs incurred by the Fund by reason of the claims, including interest (including prejudgment
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`interest), administrative and adjudicative costs, and attorney’s fees.
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`SECOND CLAIM FOR RELIEF
`LIABILITY FOR REMOVAL COSTS
`UNDER OPA SECTIONS 1012 AND 1015
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`In the alternative, as applied to the OSROs and their subcontractors’ claims, in
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`77.
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`accordance with OPA Sections 1012(f) and 1015, 33 U.S.C. §§ 2712(f) and 2715, and pursuant
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`to the terms of the OSROs’ and their subcontractors’ acceptance of payment of their claims
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`under OPA Section 1012(a)(4), 33 U.S.C. § 2712(a)(4), Defendants are liable to the United
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`States for $1,296,495.14 in compensation paid by the Fund to Defendants’ OSROs and their
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`subcontractors pursuant to OPA and all costs incurred by the Fund by reason of those claims,
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`including interest (including prejudgment interest), adjudicative and administrative costs, and
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`attorney’s fees.
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`Case 3:21-cv-00126-JWD-EWD Document 1 02/26/21 Page 15 of 16
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`REQUEST FOR RELIEF
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`WHEREFORE, The United States respectfully requests that this Court:
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`(1)
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`Enter a judgment of joint and several liability against Defendants and in favor of
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`the United States, in the amount of $1,376,234.29, plus all costs incurred by the Fund by reason
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`of this claim, including interest (including prejudgment interest), adjudicative and administrative
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`costs, and attorney’s fees; and
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`(2)
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`Grant such other relief as may be appropriate.
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`Respectfully submitted,
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`FOR THE UNITED STATES OF AMERICA:
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`JEAN E. WILLIAMS
`Acting Assistant Attorney General
`Environment and Natural Resources Division
`United States Department of Justice
`Washington, D.C.
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`/s/Asia A. McNeil-Womack
`ASIA MCNEIL-WOMACK, Ga. Bar No. 821002
`Trial Attorney
`Environmental Enforcement Section
`U.S. Department of Justice
`P.O. Box 7611 Ben Franklin Station
`Washington, D.C. 20044
`Telephone: (202) 305-0544
`Asia.McNeil-Womack@usdoj.gov
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`Case 3:21-cv-00126-JWD-EWD Document 1 02/26/21 Page 16 of 16
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`BRANDON J. FREMIN
`UNITED STATES ATTORNEY
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`/s/ Chase E. Zachary
`Chase E. Zachary, LBN 37366
`Assistant United States Attorney
`777 Florida Street, Suite 208
`Baton Rouge, Louisiana 70801
`Telephone: (225) 389-0443
`Fax: (225) 389-0685
`E-mail: chase.zachary@usdoj.gov
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`OF COUNSEL:
`PATRICIA KINGCADE
`Attorney Advisor
`National Pollution Funds Center, US Coast Guard
`2703 Martin Luther King Jr. Avenue SE
`Washington, DC 20593
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