248. Plaintiffs were not in any way responsible for the CCPW
discharged in Hudson and Essex Counties, New Jersey.
249. 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.
250. The Hudson and Essex County CCPW Sites are all located
within 10 miles of the Defendants’ chromium production facilities.
251. The Defendants were the only generators of CCPW within a
150 mile radius of Hudson and Essex Counties, New Jersey.
252. During the course of their respective operations,
Defendants generated hundreds of thousands of tons of CCPW in
Honeywell and its predecessors
Occidental and its predecessors 771,500 tons;
PPG and its
predecessors 330,000 tons.
253. Each Defendant generated CCPW waste
at its respective
chromium production facility and arranged for
disposal of its CCPW from its production plants.
respective CCPW was being used locally as fill within Hudson
255. Each Defendant generated CCPW over a period of decades
and disposed of the CCPW over the course of many years, making the