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.
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.
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
160. Plaintiffs DEP and Administrator repeat each allegation
of paragraph numbers 1 through 159, above, as if set forth in its