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PETER C. HARVEY ATTORNEY GENERAL OF NEW JERSEY Richard J. Hughes Justice Complex 25 Market Street PO ... - page 17 / 53

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combined site 68, 69, 104, 105 and 130, 70, 94, 100, 101, and 165,

which are further described elsewhere in this complaint (“1994

Honeywell Directive”).

90.

Defendant

Honeywell

failed

to

comply

with

the

1994

Honeywell Directive by refusing pay for the remediation of the

sites referenced in paragraph 89, above.

  • 91.

    On August 3, 1995, DEP, pursuant to N.J.S.A. 58:10-

    • 23.11

      f, issued a Directive to Honeywell to remediate five

additional CCPW contaminated sites, known as CCPW Site numbers 17,

86, 138, 162, and 180, which are further described elsewhere in

this complaint (“1995 Honeywell Directive”).

92. Defendant Honeywell failed to comply with the 1995

Honeywell Directive by refusing to remediate the sites referenced

in paragraph 91, above.

93.

On

January

8,

1998,

DEP,

pursuant

to

N.J.S.A.

58:10-

23.11f, issued a Directive to Honeywell to remediate eight

additional CCPW contaminated sites, known as CCPW Site numbers 187,

188, 189, 196, 197, 198, 199, and 200, which are further described

elsewhere in this complaint (“1998 Honeywell Directive”).

94. Defendant Honeywell failed to comply with the 1998

Honeywell Directive by refusing to remediate the sites referenced

in paragraph 93, above.

17

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