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PETER C. HARVEY ATTORNEY GENERAL OF NEW JERSEY Richard J. Hughes Justice Complex 25 Market Street PO ... - page 6 / 53

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18. Each Defendant knew or should have known that its

respective CCPW was being used locally as fill within Hudson and

Essex Counties.

19.

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.

20. The

CCPW

generated

by

the

Defendants

is

indistinguishable, and all of the CCPW is uniformly harmful to the

public health and the environment.

21.

Defendants

either

assume

no

remedial

responsibility

or,

alternatively, blame each other for the contamination at various

22. According to analytical testing, each

of the three

generator facilities (the “Generator Facilities”)

produced CCPW

Hudson and Essex County CCPW Sites.

that was comprised of three to seven percent hexavalent chromium

and other hazardous substances.

23.

Honeywell,

Occidental

and

PPG,

or

their

predecessors,

each distributed a portion of their CCPW from their operations as

fill material for use in construction and development projects at

residential, commercial and recreational areas throughout Hudson

and Essex Counties.

6

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