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Plastic Pellets/Clean Water Act Consent Decree: Federal Appellate Court Interprets Payment/Reporting Provisions | Mitchell, Williams, Selig, Gates & Woodyard, P L L C

San Antonio Bay Estuarine Waterkeeper, et al. v. Formosa Plastics Corporation Texas, et al., No. 20-40575. The question addressed involved payment and reporting obligations. San Antonio Bay Estuarine Waterkeeper and Sylvia Diane Wilson (collectively, “San Antonio Bay”) filed a Clean Water Act citizen suit enforcement action against Formosa Plastics Corporation Texas and Formosa Plastics Corporation USA (collectively “Formosa”) alleging certain violations. Formosa was alleged to have illegally discharged plastic pellets and other materials through its stormwater and wastewater in violation of its Texas Pollutant Discharge Elimination System (“TPDES”) permit. The United States District Court (“Court”) determined that the TPDES permit was violated because the plastics discharged exceeded “trace amounts.” The permit prohibited:

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