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PETER C. HARVEY ATTORNEY GENERAL OF NEW JERSEY Richard J. Hughes Justice Complex 25 Market Street PO ... - page 7 / 53

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24.

Honeywell,

Occidental

and

PPG,

or

their

predecessors,

took no measures to prevent the CCPW, which was distributed from

their respective Generator Facilities, from being used in a manner

that resulted in harm, or threatened harm, to the health, safety

and welfare of the citizens of the State of New Jersey, and to the

environment.

25.

Plaintiffs

have

identified

at

least

183

sites,

located

in

Hudson and Essex Counties, New Jersey, which are or were

contaminated with CCPW (hereinafter referred to as the “CCPW Site

No. .”)

___

CONTAMINATED SITES

ADMINISTRATIVE CONSENT ORDER SITES (“ACO SITES”)

26. An ACO site is a contaminated site for which a

responsible party has agreed to take some form of remediation of

the site.

27.

The

ACOs,

entered

into

by

Honeywell,

Occidental

and

PPG,

required remedial investigation and feasibility studies, followed

by remedial action pursuant to a DEP-approved plan and with DEP

oversight.

ACO SITES FOR HONEYWELL

28.

Defendant

Honeywell

entered

into

Administrative

Consent

Orders with DEP for the remediation of 22 of the 183 known

contaminated sites.

7

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