X hits on this document

PDF document

PETER C. HARVEY ATTORNEY GENERAL OF NEW JERSEY Richard J. Hughes Justice Complex 25 Market Street PO ... - page 43 / 53

131 views

0 shares

0 downloads

0 comments

43 / 53

both actual and potential, with the exercise of the public's common

right to these natural resources.

208. CCPW contains various hazardous

substances,

including

high concentrations of hexavalent chromium, and is, therefore, an

inherently dangerous material that poses a high degree of risk to

people and the environment.

209. Plaintiffs were not in any way responsible for the CCPW

discharged in Hudson and Essex Counties, New Jersey.

210. Despite use of due diligence, Plaintiffs have been unable

to ascertain which one or more of the Defendants is responsible for

the chromate chemical production waste contamination at various

Hudson and Essex County CCPW Sites in New Jersey; however, all of

that contamination was caused by one or more of the Defendants.

211. The Hudson and Essex County CCPW Sites are all located

within 10 miles of the Defendants’ chromium production facilities.

212. The Defendants were the only generators of CCPW within a

150 mile radius of Hudson and Essex Counties, New Jersey.

213. During the course of their respective operations,

the

Defendants generated hundreds of thousands of tons of CCPW in

the

following amounts: Honeywell and its predecessors

969,500 tons;

Occidental and its predecessors 771,500 tons; and,

PPG and its

predecessors 330,000 tons.

43

Document info
Document views131
Page views131
Page last viewedFri Dec 09 02:34:29 UTC 2016
Pages53
Paragraphs2628
Words10878

Comments