187. Plaintiffs DEP and Administrator repeat each allegation
of paragraph numbers 1 through 186, above, as if set forth in its
PPG is a "person" within the meaning of N.J.S.A. 58:10-
Plaintiffs DEP and the Administrator have incurred, and
will continue to incur, costs as a result of the discharge and
unsatisfactory storage or containment of hazardous substances at
CCPW Site numbers 63, 65, 107, 108, 114, 121, 132, 133, 135, 137,
143, 146, 147, and 156 (“PPG Sites”).
190. The costs and damages the Plaintiffs have incurred, and
will incur, for the PPG Sites are "cleanup and removal costs"
within the meaning of N.J.S.A. 58:10-23.11b.
191. PPG is the discharger of hazardous substances at the PPG
and is liable, jointly and severally,
without regard to
for all cleanup and removal costs as
a result of the
discharge of hazardous
192. PPG, as the generator of hazardous substances that were
discharged at the PPG Sites, falls within the scope of the
liability imposed on persons "in any way responsible" for the