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PETER C. HARVEY ATTORNEY GENERAL OF NEW JERSEY Richard J. Hughes Justice Complex 25 Market Street PO ... - page 19 / 53

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99.

Defendants

Honeywell,

PPG

and

Occidental

failed

to

comply

with the 1995 Joint Directive (“1995 Joint Directive”) by refusing

to remediate the sites referenced in paragraph 98, above.

100. On January 8, 1998, DEP, pursuant to N.J.S.A.

58:10-

23.11f, issued a Joint Directive to Honeywell, Occidental and PPG

to remediate seven additional CCPW-contaminated sites, known as

CCPW Site numbers 192, 202, 203, 204, 205, 206 and 207, which are

further described elsewhere in this complaint.

101. Defendants Honeywell, PPG and Occidental failed to comply

with the 1998 Joint Directive (“1998 Joint Directive”) by refusing

to remediate the sites referenced in paragraph 100, above.

PUBLICLY FUNDED SITES

102. While the CCPW found at the 183 sites is identifiable, by

virtue of its chemical and physical characteristics, as having been

generated by one or more of the Defendants' chromate chemical

production facilities, the CCPW from any one of the Defendants'

chromate chemical production facilities is physically and

chemically indistinguishable from the CCPW generated at either of

the other defendants’ chromate chemical production facilities.

103. Publicly Funded Sites (“Publicly Funded Sites”) are CCPW-

contaminated sites in which the source of the contamination is one

or more of the Defendants, but the responsibility of any individual

defendant is denied or undetermined.

19

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