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PETER C. HARVEY ATTORNEY GENERAL OF NEW JERSEY Richard J. Hughes Justice Complex 25 Market Street PO ... - page 2 / 53

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against the above-named defendants, Honeywell International, Inc.

("Honeywell"), Occidental Petroleum Corporation ("Occidental"), and

PPG Industries, Inc. (“PPG”), (collectively "the Defendants"), say:

STATEMENT OF THE CASE

1.

The

Plaintiffs

bring

this

civil

action

pursuant

to

the

Spill Compensation and Control Act, N.J.S.A. 58:10-23.11 to 23.24

("the Spill Act") and common law for declaratory and injunctive

relief and reimbursement of the cleanup and removal costs they have

incurred, and will incur, as a result of the discharge and

unsatisfactory storage or containment of hazardous substances,

including Chromate Chemical Production Waste (“CCPW”), at numerous

sites in the Counties of Hudson and Essex, State of New Jersey.

2.

CCPW contains hexavalent chromium, nickel and vanadium,

along with other hazardous substances as defined by N.J.S.A. 58:10-

23.11b.

The

United

States

Environmental

Protection

Agency

("EPA")

classifies hexavalent chromium in the top 25 percent of known human

carcinogens, more potent than arsenic, benzene, and polychlorinated

biphenyls.

It

is

toxic

not

only

to

humans,

but

also

animals

and

lower life forms, including benthic organisms.

3.

The Defendants have assumed some limited responsibility

for remediation of certain sites contaminated with CCPW in the

counties

of

Hudson

and

Essex,

State

of

New

Jersey.

However,

the

Defendants have denied responsibility for decades of environmental

contamination resulting from their generation, transportation and

2

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