In Mid-Valley Pipeline Co. v. S.J. Louis Construction, Inc., the United States District Court for the Eastern District of Kentucky (Northern Division) recently held (among other things) that (a) the Clean Water Act (CWA) allows a pipeline owner to recover penalties, paid to U.S. EPA, from a third party through a contribution or indemnity claim; and (b) a right to contribution exists under federal common law (through the CWA).  See here.