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PETER C. HARVEY ATTORNEY GENERAL OF NEW JERSEY Richard J. Hughes Justice Complex 25 Market Street PO ... - page 44 / 53

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214. Each Defendant generated CCPW waste at its respective

chromium production facility and arranged for

the

removal

and

disposal of its CCPW from its production plants.

215.

Each

Defendant

knew

or

should

have

known

that

its

respective CCPW was being used locally as fill within Hudson

and

Essex counties.

216. Each Defendant generated CCPW over a period of decades

and disposed of the CCPW over the course of many years, making the

identification of transportation services and other evidence

identifying the respective generator of the waste, at some sites,

impossible.

217. The

CCPW

generated

by

the

Defendants

is

indistinguishable, and all of the CCPW is uniformly harmful t

  • o

    the

public health and the environment.

218. Defendants either assume no remedial responsibility or,

alternatively, blame each other for the contamination at various

Hudson and Essex County CCPW Sites.

219.

Each

Defendant

knew

or

should

have

known

that

its

respective CCPW was being used locally as fill within Hudson

and

Essex counties, and that the uses their CCPW was being put to were

likely to result in great harm.

220. The disposal or use of CCPW as fill created risks that

could not be eliminated through the use of reasonable care.

221. The use of a hazardous substance as fill is not common.

44

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