BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
Complainant,
V.
)
No.
MAGELLAN PIPELINE COMPANY, L.P.,
a limited partnership,
Respondent.
NOTICE OF FILING
(VIA ELECTRONIC FILING)
PLEASE TAKE NOTICE that we have today, September 6, 2005,
filed with the office of the Clerk of the Illinois Pollution
Control Board by electronic filing the following Complaint, a
copy of which is attached and hereby served upon you.
Failure to tile an answer to this complaint within 60 days
may have severe consequences.
Failure to answer will mean that
all allegations in the complaint will be taken as if admitted for
purposes of this proceeding.
If you have any questions about
this procedure, you should contact the hearing officer assigned
to this proceeding, the Clerk's Office or an attorney.
Respectfully submitted,
PE PLE OF THE STATE OF ILLINOIS
LI
MADIGAN
trney Gen
al of the
e of Ill
ois
BY:
ISTOPHER GRANT
A istant Attorney General
Environmental Bureau
188 W. Randolph St.,
2Qth
Flr.
Chicago, IL 60601
(312) 814-5388
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BEFQRE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
Complainant,
V.
)
No.
MAGELLAN PIPELINE COMPANY, L.P.,
a limited partnership,
Respondent.
COMPLAINT
Complainant, PEOPLE OF THE STATE OF ILLINOIS, by LISA
MADIGAN, Attorney General of the State of Illinois,
complains of the Respondent, MAGELLAN PIPELINE COMPANY,
L.P., as follows:
Count I
IMPROPER
DISPOSAL
OF
HAZARDlOUS
WASTE
1.
This Complaint is brought on behalf of THE PEOPLE
OF THE STATE OF ILLINOIS by LISA MADIGAN, Attorney General
of the State of Illinois, on her own motion and at the
request of the Illinois Environmental Protection Agency
("Illinois EPA") pursuant to the terms and provisions of
Section 31 of the Illinois Environmental Protection Act
("Act"), 415 ILCS 5/31 (2004).
2.
Illinois EPA is an administrative agency of the
State of Illinois, established by Section 4 of the Act, 415
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ILCS 5/4 (2004)
,
and is charged,
inter
alia,
with the duty
of enforcing the Act, and regulations promulgated by the
Illinois Pollution Control Board ("Board").
3.
Respondent, MAGELLAN PIPELINE COMPANY, L.P.
("Magellan") is a limited partnership. The general partner
of Magellan is Magellan Midstream Management, LLC, a
Delaware limited liability company, duly authorized to
transact business in the State of Illinois.
4.
Respondent Magellan owns and operates a petroleum
products distribution terminal located at 1222 U.S. Route
30, Amboy, Lee County, Illinois ("Site").
5.
At the Site, Magellan operates petroleum product
storage and distribution tanks, pipelines, and other
equipment.
6.
During June and July 2004, Magellan was engaged in
equipment replacement and Žehabilitation of its gasoline
storage tanks at the Site.
7.
As part of its tank rehabilitation project, the
Respondent arranged for the removal of an internal floating
roof vapor barrier, consisting of a metal framework and
laminated Styrofoam 'pontoons'
.
The vapor barrier was
designed to prevent migration of gasoline fumes. However,
the Styrofoam 'pontoons' also absorb petroleum components
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from the stored fuel.
8.
During the June-July, 2004, Site rehabilitation,
the Respondent and its contractors removed Styrofoam
pontoons from tanks at the Site, and deposited the discarded
material (herinafter "waste Styrofoam") into disposal
containers.
9.
On or about July 2, 2004, the Respondent tested
the waste Styrofoam using the Toxicity Characteristic
Leaching Procedure ("1TCLP"1)
The test results indicated
that the waste Styrofoam had a benzene concentration of 6.3
milligrams per liter ("mg/i"1)
10.
On July 16, 2004, Magellan arranged for two
disposal containers to be picked up by Waste Management of
Illinois, Inc. ("WMI")
,
and transported to Prairie Hill
Recycling & Disposal ("Prairie Hill"), a municipal solid
waste landfill located in Whiteside County, Illinois.
The
two disposal containers held.a total of 2,680 pounds of
discarded waste Styrofoam.
11.
The permitted owner of Prairie Hill is the County
of Whiteside, Illinois.
WMI, a Delaware corporation, is the
permitted operator of Prairie Hill.
Prairie Hill is not
permitted by Illinois EPA for the storage, treatment or
disposal of hazardous waste, and, at all times relevant to
3
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this Complaint, had not been assigned a USEPA hazardous
waste identification number.
12.
On July 20, 2004, WMT picked up two container
loads of waste Styrofoam from the Site.
The waste Styrofoam
was transported to, and disposed of, in an active disposal
cell of the Prairie Hill landfill.
At the end of daily
operations on July 20, 2004, the waste Styrofoam was covered
with soil.
13.
On July 22, 2004, WMT reported to Illinois EPA
that Prairie Hill had accepted and disposed of hazardous
waste.
The hazardous waste was identified as the two loads
of waste Styrofoam accepted from the Respondent on July 20,
2
004 .
14.
Section 21 of the Act, 415 ILCS 5/21 (2004),
provides, in pertinent part, as follows:
No person shall:
(e) Dispose, treat, store or abandon any waste, or
transport any waste into this State for disposal,
treatment, storage or abandonment, except at a
site or facility which meets the requirements of
this Act and of regulations and standards
thereunder.
15.
Section 3.315 of the Act, 415 ILCS 5/3.315 (2004),
provides, as follows:
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"PERSON" is any individual, partnership, co-
partnership, firm, company, limited liability
company, corporation, association, joint stock
company, trust, estate, political subdivision,
state agency, or any other legal entity, or their
legal representative, agent or assigns.
16.
The Respondent is a "person" as that term is
defined by Section 3.315 of the Act, 415 ILCS 5/3.315
(2004).
17.
Section 3.535 of the Act, 415 ILCS 5/3.535 (2004)
provides, in pertinent part, as follows:
"Waste" means any means any garbage, sludge from a
waste treatment plant, water supply treatment plant or
air pollution control facility or other discarded
material, including solid, liquid, semi-solid, or
contained gaseous material resulting from industrial
commercial, mining and agricultural operations ...
18.
The waste Styrofoam was discarded by the
Respondent, and is "waste" as that term is defined by
Section 3.535 of the Act, 415 TLCS 5/3.535 (2004).
19.
Pursuant to authority granted under the Act, and
in conformance with the Resource Conservation and Recovery
Act ("RCRA"), 42 U.S.C. 6901 et
seq.,
the Illinois Pollution
Control Board has promulgated regulations applicable to the
disposal of solid waste, codified at 35 Ill. Adm. Code
Subtitle. G, Chapter I ("Board Waste Disposal regulations").
20.
Section 721.102 of the Board Waste Disposal
regulations, 35 Ill. Adm. Code 721.102, provides, in
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pertinent part, as follows:
721.102
Definition of Solid Waste
a)
Solid waste.
1)
A solid waste is any discarded material that
is not excluded by Section 721.104 (a) or that
is not excluded pursuant to 35 Ill. Adm. Code
720.130 and 720.131.
2)
A discarded material is any material that is
described as follows:
A)
Abandoned, as explained in
subsection (b) of this Section;
b)
A material is a solid waste if it is abandoned in
one of the following ways:
1)
It is disposed of;
21.
The waste Styrofoam was abandoned through disposal
in a landfill, and was therefore 'discarded'
.
The waste
Styrofoam is therefore 'solid waste' as that term is defined
and used in the Board Waste Disposal regulations.
22.
Section 721.120 of the Board Waste Disposal
regulations, 35 Ill. Adm. Code 721.120, provides, in
pertinent part, as follows:
a)
A solid waste, as defined in Section 721.102,
which is not excluded from regulation as a
hazardous waste under Section 721.104(b), is a
hazardous waste if it exhibits any of the
characteristics identified in this Subpart C.
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23.
Section 721.124 of the Board Waste Disposal
regulations, 35 Ill. Adm. Code 721.124, provides, in
pertinent part, as follows:
Section 721.124
Toxicity Characteristic
a)
A solid waste (except manufactured gas plant
waste) exhibits the characteristic of
toxicity if, using the Toxicity
Characteristic Leaching Procedure (TCLP)
...
the
extract from a representative sample of the
waste contains any of the contaminants
listed in the table in subsection (b) of this
Section at a concentration equal to or greater
than the respective value given in that
table ....
b)
A solid waste that exhibits the
characteristic of toxicity has the USEPA
hazardous waste number specified in the
following table that corresponds to the toxic
contaminant causing it to be hazardous.
MAXIMUM CONCENTRATION OF CONTAMINANTS FOR THE
TOXICITY CHARACTERISTIC
USEPA
Contaminant
CAS No.
Regulatory Level
Hazardous
(mg/Li)
Waste No.
D018
Benzene
71 -43-2
0.5
24.
The waste Styrofoam had a TCLP-tested benzene
concentration of 6.3 mg/L, greatly exceeding the maximum
benzene concentration listed in 35 Ill. Adm. Code 721.124.
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The waste Styrofoam was therefore 'hazardous waste', with
the USEPA Hazardous Waste number of D0le.
25.
Section 3.185 of the Act, 415 ILCS 5/3.185(2004),
provides, as follows:
"Disposal" means the discharge, deposit, injection,
dumping,
spilling, leaking or placing of any waste or
hazardous waste into or on any land or water or into
any well so that such waste or hazardous waste or any
constituent thereof may enter the environment or be
emitted into the air or discharged into any waters,
including ground waters.
26.
Respondent's arrangement for the transport and
disposal of hazardous waste at the Prairie Hill facility
constituted 'disposal' as that term is defined by Section
3.185 of the Act, 415 ILCS 5/3.185 (2004).
27.
The Respondent disposed of hazardous waste at
Prairie Hill, a facility not permitted for the disposal of
hazardous waste, and therefore not meeting the requirements
of the Act.
The Respondent thereby violated Section 21(e)
of the Act, 415 ILCS 5/21(e) (2004).
WHEREFORE, Complainant, PEOPLE OF THE STATE OF
ILLINOIS, respectfully requests that the Board enter an
order in favor of Complainant and against the Respondent,
MAGELLAN PIPELINE COMPANY, L.P., on Count I:
1.
Authorizing a hearing in this matter, at which
time the Respondent will be required to answer the
8
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allegations herein;
2.
Finding that the Respondent has violated Section
21(e) of the Act;
3.
Ordering the Respondent to cease and desist from
any further violation of Section 21(e) of the Act;
4.
Assessing against the Respondent a civil penalty
of Fifty Thousand Dollars ($50,000.00) for each violation of
Section 21(e) of the Act, and an additional civil penalty of
Ten Thousand Dollars ($10,000.00) for each day of violation;
5.
Ordering the Respondent to pay all costs,
including attorney, expert witness, and consultant fees
expended by the State in its pursuit of this action; and
6.
Granting such other relief as the Board deems
appropriate and just.
Count II
FAILURE TO PREPARE A HAZARDOUS WASTE MANIFEST
1-25.
Complainant realleges and incorporates by
reference herein, paragraphs 1 through 13, and paragraphs 15
through 26 of Count I, as paragraphs 1 through 25 of this
Count IT.
26.
The Respondent arranged for the transportation of
the waste Styrofoam to Prairie Hill for disposal.
However,
the Respondent failed to prepare a manifest for the waste
9
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Styrofoam prior to its July 20, 2004 shipment off-Site, and
delivery to Prairie Hill.
27.
Section 21(f) of the Act, 415 ILCS 5/21(f) (2004)
provides, in pertinent part, as follows:
No Person Shall:
(if) Conduct any hazardous waste-storage,
hazardous waste-treatment, or hazardous
waste-disposal operation:
(2) in violation of any regulations or
standards adopted by the Board under.
this Act;
28.
The Respondent disposed of the waste Styrofoam at
Prairie Hill, and therefore 'conducted a hazardous waste
disposal operation'.
29.
Section 3.205 of the Act, 415 ILCS 5/3.205 (2004),
provides, as follows:
t"Generatorr" means any person whose act or process
produces waste.
30.
The Respondent's tank rehabilitation activities
produced the waste Styrofoam, a solid waste and a hazardous
waste. Magellan is therefore a 'generator' of hazardous
waste.
10
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31.
Section 722.120 of the Board Waste Disposal
regulations, 35 Ill. Adm. Code 722.120, provides, in
pertinent part, as follows:
a)
A generator that transports hazardous waste or
offers hazardous waste for transportation for off-
site treatment, storage, or disposal must prepare
a manifest before transporting the waste off-site.
32.
The Respondent failed to prepare a hazardous waste
manifest prior to transport and disposal of the waste
Styrofoam off-Site.
The Respondent thereby violated Section
722.120(a) of the Board Waste Disposal regulations, 35 Ill.
Adm. Code 722.120(a), and thereby also, violated Section
21(f) (23 of the Act, 415 ILCS 5/21(f) (2) (2004).
WHEREFORE, Complainant, PEOPLE OF THE STATE OF
ILLINOIS, respectfully requests that the Board enter an
order in favor of Complainant and against the Respondent,
MAGELLAN PIPELINE COMPANY, L.P., on Count II:
1.
Authorizing a hearing in this matter, at which
time the Respondent will be required to answer the
allegations herein;
2.
Finding that the Respondent has violated Section
21(f) (2) of the Act, and 35 Ill. Adm. Code 722.120(a);
3.
Ordering the Respondent to cease and desist from
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any further violation of Section 21(f) (2) of the Act, and 35
Ill. Adm. Code 722.120(a);
4.
Assessing against the Respondent a civil penalty
of Twenty Five Thousand Dollars ($25,000.00)for each day of
violation of Section 21(f) (2) of Act, and 35 Ill. Adm. Code
722.120(a);
s. ordering the Respondent to pay all costs,
including attorney, expert witness and consultant fees
expended by the State in its pursuit of this action; and
6.
Granting such other relief as the Board deems
appropriate and just.
Count III
OFFERING HAZARDOUS WASTE TO A FACILITY
THAT DOES NOT HAVE AN EPA IDENTIFICATION NUMBER
1-28.
Complainant realleges and incorporates by
reference herein, paragraphs 1 through 25, paragraph 27,
arid paragraphs 29 through 30 of Count II, as paragraphs 1
through 28 of this Count III.
29.
Section 722.112 of the Board Waste Disposal
regulations, 35 Ill. Adm. Code 722.112, provides, in
pertinent part, as follows:
USEPA Identification Numbers
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c)
A generator must not offer its hazardous waste to
transporters or to treatment, storage or
disposal facilities that have not received a
USEPA identification number.
30.
On July 20, 2004, the Respondent offered hazardous
waste for transport and disposal to Prairie Hill, a facility
that had not been assigned a USEPA hazardous waste
identification number. The Respondent thereby violated
Section 722.112(c) of the Board Waste Disposal regulations, 35
Ill. Adm. Code 722.112(c), and thereby also, violated Section
21(f) (2) of the Act, 415 TLCS 5/21(f) (2) (2004).
WHEREFORE, Complainant, PEOPLE OF THE STATE OF ILLINOIS,
respectfully requests that the Board enter an order in favor
of Complainant and against the Respondent, MAGELLAN PIPELINE
COMPANY, L.P., on Count III:
1.
Authorizing a hearing in this matter, at which time
the Respondent will be required to answer the allegations
herein;
2.
Finding that Respondent has violated Section
21(f) (2) of the Act, and 35 Ill. Adm. Code 722.112;
3.
ordering the Respondent to cease and desist from
any further violation of Section 21(f) (2) of the Act, and 35
Ill. Adm Code 722.112;
4.
Assessing against the Respondent a civil penalty
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Twenty Five Thousand Dollars ($25,000.00)for each day of
violation of the Section 21(f) (2) of Act, and 35 Ill. Adm Code
722.112;
S.
Ordering the Respondent to pay all costs, including
attorney, expert witness and consultant fees expended by the
State in its pursuit of this action; and
6.
Granting such other relief as the Board deems
appropriate and just.
Count IV
VIOLATION OF BOARD WASTE EVALUATION REQUIREMENTS
1-28. Complainant realleges and incorporates by
reference herein paragraphs 1 through 28 of Count III, as
paragraphs 1 through 28 of this Count IV.
29.
On or about July 2, 2005, the Respondent tested the
waste Styrofoam, and determined the waste had a TCLP-tested
benzene concentration of 6.3 mg/l.
However, the Respondent
failed to evaluate its test results to determine whether the
waste Styrofoam was a characteristic hazardous waste, pursuant
to 35 Ill. Adm. Code, Part 721, Subpart C. The Respondent
also failed to determine the appropriate USEPA hazardous waste
number for the waste Styrofoam.
30.
35 Ill. Adm. Code 722.111 provides, in pertinent
part, as follows:
14
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Hazardous Waste Determination
A person that generates a solid waste, as defined in 35
Ill. Adm. Code 721.102, must determine if that waste is
a hazardous waste using the following method:
c)
For purposes of compliance with 35 Ill. Adm. Code
728, or if the waste is not listed as a hazardous
waste in Subpart D of 35 Ill. Adm. Code 721, the
generator must then determine whether the waste is
identified in Subpart C of 35 Ill. Adm. Code 721
by either of the following methods:
1)
Testing the waste according to the methods set
forth in Subpart C of 35 Ill. Adm. Code 721,
or according to an equivalent method approved
by the Board under 35 Ill. Adm. Code 720.121;
or
2)
Applying knowledge of the hazard
characteristic of the waste in light of the
materials or processes used.
d)
If the generator determines that the waste is
hazardous, the generator must refer to 35 Ill. Adm.
Code 724, 725, 728, and 733 for possible exclusions
or restrictions pertaining to the management of the
specific waste.
31.
Section 728.109 of the Board Waste Disposal
regulations, 35 Ill. Adm. Code 728.109, provides, in
pertinent part, as follows:
Special Rules for Characteristic Wastes
a)
The initial generator of a solid waste must
determine each USEPA hazardous waste number
(waste code) ap plicable to the waste in order
to determine the applicable treatment
standards under Subpart D of this Part ....
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c)
In addition to any applicable standards
determined from the initial point of
generation, no prohibited waste that exhibits
a characteristic under Subpart C of 35 Ill.
Adm. Code 721 must be land disposed, unless
the waste complies with the treatment
standards under Subpart D of this Part.
32.
The Respondent tested the waste Styrofoam and
determined that
it
contained a TCLP-tested benzene
concentration of 6.3 mg/l. However, the Respondent failed to
compare its test results to the toxicity characteristic
standards contained in 35 Ill. Adm. Code 721.124, which would
have identified the material as hazardous waste.
34.
By failing to fully evaluate the waste Styrofoam,
as alleged herein, the Respondent violated Section 722.111 of
the Board Waste Disposal regulations, 35 Ill. Adm. Code
722.111, and thereby also, violated Section 21(f) (2) of the
Act, 415 ITJCS 5/21(f) (2) (2004).
35.
By failing to determine the USEPA hazardous waste
number applicable to the waste Styrofoam prior to sending the
waste off-site for disposal, the Respondent violated Section
728.109(a) of the Board Waste Disposal regulations, 35 Ill.
Adm. Code 728.109(a), and thereby also, violated Section
21(f) (2) of the Act, 415 TLCS 5/21(f) (2) (2004)
36.
As a direct result of the Respondent's failure to
16
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determine that the waste Styrofoam was a characteristic
hazardous waste, and its failure to assign the waste a USEPA
hazardous waste number, the waste Styrofoam was improperly
land-disposed at Prairie Hill.
The Respondent thereby
violated Section 728.109(c) of the Board Waste Disposal
regulations, 35 Ill. Adm Code 728.109(c), and thereby also,
violated Section 21(f) (2) of the Act, 415 ILCS
5/21 (f) (2) (2004).
WHEREFORE, Complainant, PEOPLE OF THE STATE OF ILLINOIS,
respectfully requests that the Board enter an order in. favor
of Complainant and against the Respondent, MAGELLAN PIPELINE
COMPANY, L.P., on Count IV:
1.
Authorizing a hearing in this matter, at which time
the Respondent will be required to answer the allegations
herein;
2.
Finding that the Respondent has violated Section
21(f) (2) of the Act, and 35 Ill. Adm. Code Sections 722.111,
728.109(a), and 728.109(c);
3.
ordering the Respondent to cease and desist from
any further violation of Section 21(f) (2) of the Act, and 35
Ill. Adm. Code Sections 722.111, 728.109(a), and 728.109(c);
4.
Assessing against the Respondent a civil penalty of
Twenty Five Thousand Dollars ($25,000.00)for each day of
17
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violation of Section 21(f) (2) of the Act, and 35 Ill. Adm.
Code Sections 722.111, 728.109(a), and 728.109(c);
5.
ordering the Respondent to pay all costs, including
attorney, expert witness and consultant fees expended by the
State in its pursuit of this action; and
6.
Granting such other relief as the Board deems
appropriate and just.
PEOPLE OF THE STATE OF
ILLINOIS
ex
rel.,
LISA MADIGAN,
Attorney General of the
State of Illinois,
MATTHEW J. DUNN, Chief,
Environmental Enforcement/
Asbestos Litigation Division
Assistant Attorney General
OF COUNSEL:
CHRISTOPHER GRANT
Assistant Attorney General
Environmental Bureau
188 West Randolph Street,
2
0
th
Floor
Chicago, IL 60601
312 814-3532
18
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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
Complainant,
V.
)
No.
MAGELLAN PIPELINE COMPANY, L.P.,
a limited partnership,
Respondent.
CERTIFICATE OF SERVICE
I,
CHRITSTOPHER GRANT, an attorney, do certify that I caused
to be served this
6th
day of September, 2005, the foregoing
Complaint and Notice of Filing upon person listed below, by
registered certified mail, by placing same in. an envelope bearing
sufficient postage with the United States Postal Service located
at 100 W. Randolph, Chicago Illinois a d addres ed to:
HRISTOPHER GRANT
Service List:
Magellan Midstream Management, LLC
C/O CT Corporation System
208 S. La Salle Street, Suite 814
Chicago, IL 60604-1101
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