`
`IN THE UNITED STATES DISTRICT COURT FOR
`THE SOUTHERN DISTRICT OF MISSISSIPPI
`Eastern Division
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`THE UNITED STATES OF AMERICA
`and THE STATE OF MISSISSIPPI,
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`Plaintiffs,
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`v.
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`THE CITY OF HATTIESBURG, MISSISSIPPI,
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`Defendant.
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`
`
`COMPLAINT
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`Case No.
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`2:20-cv-158-KS-MTP
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`The United States of America, by authority of the Attorney General of the
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`United States and through the undersigned attorneys, acting at the request of the
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`Administrator of the United States Environmental Protection Agency (EPA), and
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`the State of Mississippi, by and through the Mississippi Commission on
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`Environmental Quality, acting through the Mississippi Department of
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`Environmental Quality (MDEQ), hereby allege as follows:
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`NATURE OF ACTION
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`1.
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`This is a civil action for injunctive relief and penalties brought
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`under Sections 309(b) and 309(d) of the Clean Water Act (CWA or “the Act”), 33
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`U.S.C. §§ 1319(b) and 1319(d), and under the Mississippi Air and Water
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`Pollution Control Law (MAWPCL) (Miss. Code Ann. §§ 49-17-1 through 49-17-
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`43), against the Defendant, the City of Hattiesburg, Mississippi for unauthorized
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`discharges of pollutants from its wastewater collection and transmission system
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`1
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`(WCTS) in violation of Section 301 of the Act, 33 U.S.C. § 1311, and for
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`violations of conditions established in the National Pollutant Discharge
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`Elimination System (NPDES) permits issued to Hattiesburg by MDEQ pursuant
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`to its EPA-approved permit program under Section 402 of the Act, 33 U.S.C.
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`§ 1342.
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`JURISDICTION, AUTHORITY, VENUE, AND NOTICE
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`
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`2.
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`This Court has subject matter jurisdiction over this action pursuant
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`to Section 309(b) of the Act, 33 U.S.C. §§ 1319(b), and 28 U.S.C. §§ 1331, 1345,
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`and 1355, and over the Parties. This Court has supplemental jurisdiction over the
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`State law claims under the MAWPCL pursuant to 28 U.S.C. § 1367(a) because
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`the State law claims are related to the federal law claims and form part of the
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`same case or controversy.
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`3.
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`The United States has authority to bring this action on behalf of the
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`Administrator of EPA under Section 506 of the Act, 33 U.S.C. § 1366. MDEQ
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`has the authority to bring this suit on behalf of the State of Mississippi in
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`accordance with Miss. Code Ann. §§ 49-2-13, 49-2-21, 49-17-17, and 49-17-43
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`and the common law of Mississippi.
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`4.
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`Venue is proper in the Southern District of Mississippi pursuant to
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`28 U.S.C. §§ 1391(b) and 1395(a), because it is the judicial district where
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`Hattiesburg is located and where the alleged violations occurred.
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`5.
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`Notice of the commencement of this action has been provided to
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`the State of Mississippi pursuant to Section 309(b) of the Act, 33 U.S.C.
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`2
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`§ 1319(b). The State of Mississippi joins this action as a plaintiff, thereby
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`satisfying the requirements of Section 309(e) of the Act, 33 U.S.C. § 1319(e).
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`DEFENDANT CITY OF HATTIESBURG
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`
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`6.
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`Defendant Hattiesburg is a “city” within the meaning of Miss.
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`Code Ann. § 21-1-1 and was incorporated in 1884. Hattiesburg is also a
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`“municipality” as that term is defined by Section 502(4) of the Act, 33 U.S.C.
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`§ 1362(4), and under state law. The City of Hattiesburg is located in both Forrest
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`and Lamar Counties.
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`CLEAN WATER ACT AND MAWPCL STATUTORY REQUIREMENTS
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`7.
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`Section 301(a) of the Act, 33 U.S.C. § 1311(a), prohibits the
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`discharge of any pollutant by any person to waters of the United States, except in
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`compliance with certain sections of the Act, including, where applicable, an
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`NPDES permit issued pursuant to Section 402 of the Act, 33 U.S.C. § 1342.
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`
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`8.
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`Section 402(a) of the Act, 33 U.S.C. § 1342(a), provides that the
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`permit-issuing authority may issue an NPDES permit which authorizes the
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`discharge of any pollutant, but only in compliance with the applicable
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`requirements of Section 301 of the Act, 33 U.S.C. § 1311, and such other
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`conditions as the EPA Administrator determines are necessary to carry out the
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`provisions of the Act.
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`9.
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`Section 402(b) of the Act, 33 U.S.C. § 1342(b), provides that EPA
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`may approve a state NPDES permitting program. The State, through MDEQ, is
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`authorized to issue NPDES permits in Mississippi, and does so in accordance with
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`the MAWPCL, Miss. Code Ann. §§ 49-17-1 et seq., and Commission Regulations
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`3
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`Water Quality Criteria for Intrastate, Interstate, and Coastal Waters, WPC-1 and
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`WPC-2. The State has been authorized by EPA to administer its NPDES permit
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`since May 1, 1974.
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`10.
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`Section 309(b) of the Act, 33 U.S.C. § 1319(b), authorizes the EPA
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`Administrator to commence a civil action for appropriate relief, including a
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`permanent or temporary injunction, when any person is in violation of Section
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`301 of the Act, 33 U.S.C. § 1311, or any permit condition or limitation in an
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`NPDES permit issued pursuant to Section 402 of the Act, 33 U.S.C. § 1342. The
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`MAWPCL provides similar authority to MDEQ at Miss. Code Ann. § 49-17-
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`43(2).
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`11.
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`Section 309(d) of the Act, 33 U.S.C. § 1319(d), and the Civil
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`Monetary Penalty Inflation Adjustments set forth at 40 C.F.R. § 19.4, establish
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`maximum civil penalties for violations of Section 301 or violations of conditions
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`of a permit issued pursuant to Section 402 of the CWA, 33 U.S.C. § 1342. The
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`maximum civil penalty per day per violation of the CWA is $32,500 for violations
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`occurring after March 15, 2004 through January 12, 2009; $37,500 between
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`January 13, 2009 through on or before November 2, 2015; and $55,800 for
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`violations occurring after November 2, 2015.
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`12. Miss. Code Ann. § 49-17-29(2) prohibits any person “to cause
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`pollution of any waters of the state or to place or cause to be placed any wastes in
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`a location where they are likely to cause pollution of any waters of the state”
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`without a valid permit. Miss. Code Ann. § 49-17-43(1) provides that it is illegal
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`to violate any permit provision.
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`4
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`13.
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`The MAWPCL provides that any person that violates the
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`MAWPCL is subject to a civil penalty of up to $25,000 per day per violation.
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`Miss. Code Ann. § 49-17-43(1). Polluters or violators can also be liable for
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`damages including state investigation and enforcement costs, removing any
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`pollution, and compensation for loss of wildlife, fish, aquatic life and any other
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`actual damages caused by the pollution or violation. Miss. Code Ann. § 49-17-
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`43(3) and (4).
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`GENERAL ALLEGATIONS
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`A.
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`
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`The City and its Wastewater Collection and Transmission System
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`14. Hattiesburg is a municipality. It is a city created by or pursuant to
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`Mississippi law and has jurisdiction over disposal of sewage, industrial wastes,
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`and other wastes. Because Hattiesburg is a municipality, at all times relevant
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`herein, Hattiesburg is a “person,” within the meaning of Section 502(5) of the
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`Act, 33 U.S.C. § 1362(5) and Miss. Code Ann. § 49-17-5(3)(b).
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`
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`15.
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`The City’s Wastewater Collection and Transmission System
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`(“WCTS”) transports wastewater to the City’s two wastewater treatment plants
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`(“WWTPs”), the Hattiesburg South Wastewater Treatment Plant (“South
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`Lagoon”) and the Hattiesburg North Wastewater Treatment Plant (“North
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`Lagoon”). At all times relevant herein, Hattiesburg has owned and operated the
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`South Lagoon WWTP located at 1903 East Hardy Street, and the North Lagoon
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`WWTP located at 3401 Lakewood Road, and the associated WCTS, which
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`receive and treat wastewater from residential, commercial, and industrial sources
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`5
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`within Hattiesburg. The WCTS includes gravity sewer lines, force mains, lift
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`stations, pump stations, and manholes.
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`16.
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`Hattiesburg is responsible for the operation and maintenance of its
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`WCTS, including approximately 305 miles of sanitary sewer lines and 75 sanitary
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`sewer lift stations, and associated appurtenances. Hattiesburg’s WCTS are
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`operated subject to NPDES permits issued under Section 402(b) of the Act, 33
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`U.S.C. § 1342 and Miss. Code Ann. § 49-17-29, authorizing the discharge of
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`pollutants from a designated outfall into the Leaf River (South Lagoon permit)
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`and from a designated outfall into the Bouie River (North Lagoon permit) in
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`compliance with the conditions and limitations of those permits.
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`17.
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`The City is the named permittee for NPDES permits associated
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`with its WCTS, NPDES Permit Numbers MS0020303 (South Lagoon) &
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`MS0020826 (North Lagoon). Hattiesburg is permitted to discharge treated
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`sewage from its South Lagoon through a single designated outfall into the Leaf
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`River (Hydrologic Unit Code (HUC) 03170005) and from its North Lagoon
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`through a single designated outfall into the Bouie River (HUC 03170004), in
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`accordance with conditions set forth in the permits. The Bouie River (also known
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`as the Bowie River) is a major tributary of the Leaf River. The Leaf River flows
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`to the Pascagoula River (HUC 03170006) and eventually to Pascagoula Bay
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`before entering the Gulf of Mexico.
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`18.
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`The Hattiesburg WCTS includes discernible, confined and discrete
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`conveyances, including but not limited to any pipe, ditch, channel, tunnel,
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`conduit, well, discrete fissure, or container from which pollutants are or may be
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`discharged.
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`B.
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`Sanitary Sewer Overflows
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`19.
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`On hundreds of occasions since 2007, Hattiesburg admits it has
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`released untreated sewage from its WCTS at locations other than the permitted
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`WWTP outfalls. Such releases from a collection system are referred to as
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`“sanitary sewer overflows” or “SSOs.”
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`20.
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`On multiple occasions, Hattiesburg admits that SSOs constituting
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`“discharges of pollutants,” within the meaning of 33 U.S.C. § 1362(12),
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`discharged from the Hattiesburg WCTS to the Leaf River, the Bouie River, and
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`perennial tributaries of these rivers.
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`21.
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`The Leaf River and the Bouie River and their perennial tributaries,
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`such as Gordon’s Creek, are “navigable waters” and “waters of the United States”
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`under Section 502(7) of the Act, 33 U.S.C. § 1362(7), and also waters of the State
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`of Mississippi.
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`22. The MAWPCL defines “pollution" as “such contamination, or other
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`alteration of the physical, chemical or biological properties, of any waters of the
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`state, including change in temperature, taste, color, turbidity, or odor of the
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`waters, or such discharge of any liquid, gaseous, solid, radioactive, or other
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`substance or leak into any waters of the state unless in compliance with a valid
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`permit issued therefor by the Permit Board.” Miss. Code Ann. § 49-17-5(1)(a).
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`23.
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`“Waters of the state” is defined in Miss. Code Ann. § 49-17-
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`5(1)(f), as “all waters within the jurisdiction of [the State of Mississippi],
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`including all streams, lakes, ponds, impounding reservoirs, marshes,
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`watercourses, waterways, wells, springs, irrigation systems, drainage systems, and
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`all other bodies or accumulations of water, surface and underground, natural or
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`artificial, situated wholly or partly within or bordering upon the state . . . except
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`lakes, ponds or other surface waters which are wholly landlocked and privately
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`owned, and which are not regulated under” the Clean Water Act.
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`24.
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`At times relevant herein, Hattiesburg has caused pollution by the
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`discharge of untreated wastewater including, but not limited to, sewage, from its
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`WCTS.
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`25.
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`At times relevant herein, Hattiesburg has caused pollution by the
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`discharge untreated sewage into “waters of the state” … and has placed “wastes”
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`in locations where they are likely to cause pollution of “waters of the state.”
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`Miss. Code Ann. § 49-17-29(2).
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`
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` 26.
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`Pursuant to Miss. Code Ann. § 49-17-5(1)(b), “wastes” means
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`sewage, industrial wastes, oil field wastes, and all other liquid, gaseous, solid,
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`radioactive, or other substances which may pollute or tend to pollute any waters
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`of the state.
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`C.
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`Permit Conditions
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`27.
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`Pursuant to Section 402(a) of the Act, 33 U.S.C. § 1342(a), and
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`Miss. Code Ann. § 49-17-29, MDEQ issued Hattiesburg NPDES permits subject
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`to certain limitations and conditions set forth in the NPDES permits.
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`
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`28.
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`At all relevant times herein, Hattiesburg’s NPDES permit for the
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`North Lagoon has authorized Hattiesburg to discharge treated municipal
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`8
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`wastewater from North Lagoon Outfall 001 into the Bouie River, subject to
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`certain limitations and conditions set forth in the permit.1 At all relevant times
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`herein, Hattiesburg’s NPDES permit for the South Lagoon has authorized
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`Hattiesburg to discharge treated municipal wastewater from South Lagoon Outfall
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`001 into the Leaf River, subject to certain limitations and conditions set forth in
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`the permit.2
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`29.
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`Hattiesburg’s NPDES permits require Hattiesburg at all times to
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`properly operate, maintain, and when necessary, promptly replace all facilities
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`and systems of collection, treatment and control (and related appurtenances)
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`which are installed or used by Hattiesburg to achieve compliance with the
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`conditions of the permit. Proper replacement includes maintaining an adequate
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`inventory of replacement equipment and parts for prompt replacement when
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`necessary to maintain continuous collection and treatment of wastewater. This
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`provision requires the operation of back-up or auxiliary facilities or similar
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`systems that are installed by Hattiesburg only when the operation is necessary to
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`achieve compliance with the conditions of the NPDES permit. The “Proper
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`Operation, Maintenance and Replacement” requirement is a condition of
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`Hattiesburg’s NPDES permits. See Condition No. T-28 of the 2015 North
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`1 The North Lagoon NPDES permit covering the actions subject to this Complaint was previously
`issued to Hattiesburg by MDEQ on June 7, 2010, and expired on May 31, 2015. The 2015 North
`Lagoon NPDES permit was issued to Hattiesburg by MDEQ on October 14, 2015, and was in
`effect at least through July 31, 2020. The City has submitted an application for another permit.
`
` 2
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` The South Lagoon NPDES permit covering the actions subject to this Complaint was previously
`issued to Hattiesburg by MDEQ on June 7, 2010, and expired on May 31, 2015. The 2015 South
`Lagoon NPDES permit was issued to Hattiesburg by MDEQ on August 19, 2015, and was in
`effect at least through July 31, 2020. The City has submitted an application for another permit.
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`Lagoon NPDES permit and Condition No. T-28 of the previous permit. See
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`Condition No. T-30 of the 2015 South Lagoon NPDES permit and T-28 of
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`previous permit.
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`30. Hattiesburg’s NPDES permits require Hattiesburg to report
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`noncompliance with the permit to MDEQ. The “Noncompliance Notification -
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`Twenty-Four Hour Reporting” condition requires reports of noncompliance
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`including sanitary sewer overflows which may endanger health or the
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`environment to be provided orally within 24 hours from the time Hattiesburg
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`becomes aware of the circumstances, and in writing within five days of the time
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`Hattiesburg becomes aware of the circumstances. The “Noncompliance
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`Notification - Other Noncompliance” condition requires Hattiesburg to report all
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`instances of noncompliance not reported under the 24-hour reporting
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`requirements, at the time monitoring reports are submitted or within 30 days from
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`the end of the month in which the noncompliance occurs. Additional reporting is
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`required under the “Noncompliance Notification - Other Information” condition.
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`See, e.g., Condition Nos. S-4, S-5, and S-6 of the 2015 and previous North
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`Lagoon and South Lagoon NPDES permits.
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`FIRST CLAIM FOR RELIEF
`UNAUTHORIZED DISCHARGES FROM WASTEWATER
`COLLECTION AND TRANSMISSION SYSTEM
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`31.
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`Paragraphs 1 through 30 are realleged and incorporated herein by
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`reference.
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`
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`32. On numerous occasions between February 2007 and the date this
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`Complaint is filed, Hattiesburg discharged untreated sewage to waters of the
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`United States and waters of the State from locations within its WCTS which were
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`not authorized by an NPDES permit.
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`33.
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`Discharges referred to in the Paragraph above each constituted a
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`discharge of pollutants from a point source to waters of the United States and
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`waters of the State, without authorization under an NPDES permit or other
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`exception specified in Section 301(a) of the Act, 33 U.S.C. § 1311(a), in violation
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`of CWA Section 301, 33 U.S.C. § 1311, and Miss. Code Ann. § 49-17-29(2).
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`34. Each day of each unauthorized discharge by Hattiesburg referred
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`to in Paragraph 32 constitutes a separate violation of CWA Section 301, 33
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`U.S.C. § 1311, and Miss. Code Ann. § 49-17-29(2).
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`
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`35. Pursuant to Section 309(d) of the Clean Water Act, 33 U.S.C.
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`§1319(d), and 40 C.F.R. § 19.4, Hattiesburg is liable for civil penalties not to
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`exceed $37,500 per day for each violation that occurred after January 12, 2009
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`through November 2, 2015, and not to exceed $55,800 per day for each violation
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`that occurred after November 2, 2015. Under Miss. Code Ann. § 49-17-43,
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`Hattiesburg is liable for a civil penalty of up to $25,000 per day during which a
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`violation of Miss. Code Ann. § 49-17-29 occurs.
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`
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`36. Unless restrained by an order of the Court, Hattiesburg will
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`continue to violate CWA Section 301, 33 U.S.C. § 1311, and Miss. Code Ann.
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`§ 49-17-29, by discharging untreated sewage from unpermitted and unauthorized
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`discharge points within its WCTS to waters of the United States and waters of the
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`State.
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`11
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`SECOND CLAIM FOR RELIEF
`PLACEMENT OF WASTE IN LOCATIONS LIKELY TO CAUSE
`POLLUTION OF STATE WATERS—STATE ONLY CLAIM
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`37. Paragraphs 1 through 30 are realleged and incorporated herein by
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`reference.
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`
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`38. On numerous occasions between February 2007 and the date this
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`Complaint is filed, Hattiesburg has allowed overflows of untreated sewage to
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`occur from various locations within its WCTS which were not authorized by an
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`NPDES permit.
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`
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`39.
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`As a result of several of those sanitary sewer overflows,
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`Hattiesburg placed or caused to be placed untreated sewage in locations where
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`such sanitary sewage overflows are likely to cause pollution of any waters of the
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`state.
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`40. Each day of such placement of untreated sewage by Hattiesburg
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`referred to above constitutes a separate violation of Miss. Code Ann. § 49-17-
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`29(2).
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`
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`41. Under Miss. Code Ann. § 49-17-43, Hattiesburg is liable for a civil
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`penalty of up to $25,000 per day during which a violation of Miss. Code Ann.
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`§ 49-17-29 occurs.
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`
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`42. Unless restrained by an order of the Court, Hattiesburg will
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`continue to violate Miss. Code Ann. § 49-17-29, by placing or causing to be
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`placed sanitary sewer overflows where they are likely to cause pollution to waters
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`of the state.
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`12
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`THIRD CLAIM FOR RELIEF
`FAILURE TO COMPLY WITH PERMIT CONDITION -
`PROPER OPERATION AND MAINTENANCE
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`
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`43. Paragraphs 1 through 30 are realleged and incorporated herein by
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`reference.
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`
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`44. On hundreds of occasions between February 2007 and the date this
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`Complaint is filed, Hattiesburg has allowed overflows of untreated sewage to
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`occur from various points within its WCTS. Many of the sanitary sewer
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`overflows that occurred are a result of blockages, line breaks, excessive
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`infiltration and inflow, and other deficiencies, arising from the City’s failure to
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`properly operate and maintain its WCTS.
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`
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`45. On numerous occasions since February 2007, Hattiesburg failed to
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`comply with the “Proper Operation, Maintenance and Replacement” condition of
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`its NPDES permits by failing to properly operate and maintain its WCTS, as
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`evidenced by the overflows and discharges referred to in Paragraphs 32, 40, and
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`44.
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`
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`46.
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`Each day Hattiesburg failed to comply with the “Proper Operation,
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`Maintenance and Replacement” permit condition constitutes a separate violation
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`of the CWA and of Miss. Code Ann. § 49-17-43(1).
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`
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`47.
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` Pursuant to Section 309(d) of the Clean Water Act, 33 U.S.C.
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`§1319(d), and 40 C.F.R. § 19.4, Hattiesburg is liable for civil penalties not to
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`exceed $37,500 per day for each violation that occurred after January 12, 2009
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`through November 2, 2015, and not to exceed $55,800 per day for each violation
`
`that occurred after November 2, 2015. Under Miss. Code Ann. § 49-17-43(1),
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`13
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`Hattiesburg is liable for a civil penalty of up to $25,000 per day during which a
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`violation of its NPDES permit occurs.
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`48.
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`Unless restrained by an order of the Court, Hattiesburg will
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`continue to violate the CWA and the MAWPCL by failing to properly operate and
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`maintain its WCTS.
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`FOURTH CLAIM FOR RELIEF
`FAILURE TO COMPLY WITH PERMIT CONDITIONS -
`FAILURE TO REPORT SANITARY SEWER OVERFLOWS
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`49. Paragraphs 1 through 30 are realleged and incorporated herein by
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`reference.
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`50. The NPDES permits for the Hattiesburg sewer system contain the
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`following noncompliance notification requirements: “Noncompliance Notification
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`- Twenty-Four Hour Reporting,” “Noncompliance Notification - Other
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`Noncompliance,” and “Noncompliance Notification - Other Information.”
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`51. On numerous occasions since at least January 1, 2012, Hattiesburg
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`failed to provide the required notification to MDEQ within the timeframes
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`specified by the NPDES permits, of sanitary sewer overflows from its WCTS that
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`were not authorized by the NPDES permits.
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`52. Each day that Hattiesburg failed to comply with the reporting
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`provisions of its NPDES permits constitutes a separate violation of the CWA and
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`of Miss. Code Ann. § 49-17-43(1).
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`53. Pursuant to Section 309(d) of the Clean Water Act, 33 U.S.C.
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`§1319(d), and 40 C.F.R. § 19.4, Hattiesburg is liable for civil penalties not to
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`exceed $37,500 per day for each violation that occurred after January 12, 2009
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`through November 2, 2015, and not to exceed $55,800 per day for each violation
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`that occurred after November 2, 2015. Under Miss. Code Ann. § 49-17-43,
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`Hattiesburg is liable for a civil penalty of up to $25,000 per day during which a
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`violation of its NPDES permit occurs.
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`54. Unless restrained by an order of the Court, Hattiesburg will continue
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`to violate the reporting provisions of its NPDES permits in violation of the CWA
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`and the MAWPCL.
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiffs, the United States of America and the State of
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`Mississippi request that the Court enter judgment on their behalf as follows:
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`A.
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`Pursuant to Section 309(b) of the Act, 33 U.S.C. § 1319(b), and
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`Miss. Code Ann. § 49-17-43, order Hattiesburg to undertake a program to achieve
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`permanent and consistent compliance with all terms and conditions of its NPDES
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`permits, the Clean Water Act, the Mississippi Air and Water Pollution Control
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`Act, and the regulations promulgated thereunder for its sewer system;
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`B.
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`Pursuant to Section 309(d) of the Act, 33 U.S.C. § 1319(d) and 40
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`C.F.R. § 19.4, assess civil penalties against Hattiesburg of up to $37,500 per day
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`for each violation between January 13, 2009 and November 2, 2015, and up to
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`$55,800 per day for each violation occurring after November 2, 2015; and
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`pursuant to Miss. Code Ann. § 49-17-43, assess civil penalties of up to $25,000
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`per day for each violation of Miss. Code Ann. §§ 49-17-29 and 49-17-43(1); and
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`C.
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`Grant the United States and the State of Mississippi such other
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`relief as the Court deems appropriate.
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`Respectfully submitted,
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` BRUCE S. GELBER
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`Deputy Assistant Attorney General
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`Environment and Natural Resources Division
`United States Department of Justice
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`/s/ Valerie K. Mann
`VALERIE K. MANN
`Trial Attorney
`DC Bar Number 440744
`Environment and Natural Resources Division
`United States Department of Justice
`P.O. Box 7611
`Washington, D.C. 20044
`Telephone: (202) 616-8756
`Fax: (202) 514-0097
`Email: valerie.mann@usdoj.gov
`Lead Counsel
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`OF COUNSEL:
`Suzanne Armor
`Associate Regional Counsel
`U.S. EPA, Region 4
`61 Forsyth Street, S.W.
`Atlanta, Georgia 30303
`(404) 562-9701
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`ATTORNEYS FOR THE PLAINTIFF UNITED STATES (CONTINUED):
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` D. MICHAEL HURST, JR.
`United States Attorney for the
`Southern District of Mississippi
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`/s/ Jennifer Case
`JENNIFER CASE
`MS Bar No. 104238
`Assistant United States Attorney
`Southern District of Mississippi
`501 East Court Street, Suite 4.430
`Jackson, Mississippi 39201
`Telephone: (601) 965-4480
`Email: JCase2@usa.doj.gov
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`ATTORNEY FOR PLAINTIFF STATE OF MISSISSIPPI BY AND THROUGH THE
`MISSISSIPPI COMMISSION ON ENVIRONMENTAL QUALITY AND THE
`MISSISSIPPI DEPARTMENT OF ENVIRONMENTAL QUALITY:
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`____________________________________
`GRETCHEN L. ZMITROVICH
`MS Bar ID No. 101470
`Senior Attorney
`Office of Pollution Control
`Mississippi Department of Environmental Quality
`P.O. Box 2261
`Jackson, MS 39225
`Telephone: (601) 961-5050
`Fax: (601) 961-5674
`Email: GZMITROVICH@mdeq.ms.gov
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