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PETER C. HARVEY ATTORNEY GENERAL OF NEW JERSEY Richard J. Hughes Justice Complex 25 Market Street PO ... - page 47 / 53

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

discharged in Hudson and Essex Counties, New Jersey.

232. 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.

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

within 10 miles of the Defendants’ chromium production facilities.

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

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

235. 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.

236. 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.

237.

Each

Defendant

knew

or

should

have

known

that

its

respective CCPW was being used locally as fill within Hudson

and

Essex counties.

238. Each Defendant generated CCPW over a period of decades

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

47

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