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PETER C. HARVEY ATTORNEY GENERAL OF NEW JERSEY Richard J. Hughes Justice Complex 25 Market Street PO ... - page 28 / 53

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156. CCPW Site # 206 ("Site # 206") is located at 200 Theodore

Conrad Drive, and is designated as Polarome International, on the

tax maps of the Township of Jersey City, Hudson County, New Jersey.

157.

CCPW

Site

  • #

    207

("Site

  • #

    207")

is

located

at

942,

944

and 946 Garfield Avenue, and is designated as Block 1948, Lot 4B,

42A and 41A, on the tax maps of the Township of Jersey City, Hudson

County, New Jersey.

HEALTH STUDIES

158. Between 1989 and 1997, DEP and the New Jersey Department

of Health (“DOH”) engaged in extensive investigations and studies

into the impact to human health and the environment of exposure to

the constituents of CCPW discharged in and around Hudson County.

The costs incurred by the State of New Jersey, in conducting these

studies, exceeded 2.3 million dollars.

159. The health studies referred to in Paragraph 158, above,

were measures taken to investigate, prevent or mitigate damages to

the public health, safety or welfare, and as such, are cleanup and

removal costs with the meaning of N.J.S.A. 58:10-23.11b.

LIABILITY UNDER THE SPILL ACT

COUNT I

Spill Act

160. Plaintiffs DEP and Administrator repeat each allegation

of paragraph numbers 1 through 159, above, as if set forth in its

entirety herein.

28

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