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PETER C. HARVEY ATTORNEY GENERAL OF NEW JERSEY Richard J. Hughes Justice Complex 25 Market Street PO ... - page 37 / 53

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COUNT IV

Spill Act

187. Plaintiffs DEP and Administrator repeat each allegation

of paragraph numbers 1 through 186, above, as if set forth in its

entirety herein.

    • 188.

      PPG is a "person" within the meaning of N.J.S.A. 58:10-

    • 23.11

      b.

    • 189.

      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

Sites,

and is liable, jointly and severally,

without regard to

fault,

for all cleanup and removal costs as

a result of the

discharge of hazardous

substances

at

the

PPG Sites.

N.J.S.A.

58:10-23.11g.c.(1).

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

37

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