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.
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.