NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION v. E.I DUPONT DE NEMOURS AND COMPANY

District Court, D. New Jersey·Decided December 31, 2024·No. 1:19-cv-14766·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY CAMDEN VICINAGE

NEW JERSEY DEPARTMENT OF

ENVIRONMENTAL PROTECTION, et al., Civil Nos. Plaintiff, 19-14758 (RMB/JBC)

(Pompton Lakes) v. 19-14766 (RMB/JBC) E.I. DUPONT DE NEMOURS AND (Chambers Works) COMPANY, et al., OPINION Defendants.

RENÉE MARIE BUMB, Chief United States District Judge This Opinion addresses E.I. DuPont De Nemours and Company’s and the Dupont entities’ (collectively, “EIDP” or “Defendants”) objections to Special Master Case Management Order Nos. 2, 3 and 4. The Court heard oral argument on those Objections, and now writes to expand on its reasoning. For the reasons stated on the record and below, the Court DENIES EIDP’s objections and ADOPTS the Special Master’s rulings. I. BACKGROUND

Because the Court writes for the parties only, it does not provide a full recitation of the facts. In 2019, the New Jersey Department of Environmental Protection (“NJDEP” or “Plaintiffs”) sued EIDP claiming that it severely contaminated the environment surrounding the company’s Chambers Works facility located in Carney’s Point, New Jersey as well the environment surrounding its Pompton Lakes, New Jersey facility. NJDEP claims that Chambers Works is riddled with chemical contaminants

from its soil to the sky. NJDEP alleges EIDP’s manufacturing, processing, treatment, and disposal of various chemicals—pre- and polyfluoroalkyl substances (“PFAS”) has caused that contamination. PFAS—sometimes called “forever chemicals”—“are a diverse group of chemicals that are generally characterized by being comprised of carbon chains of various lengths and carbon-flourine bonds.” [19-14766, Docket No.

344-1 at 1.] “PFAS encompasses thousands of substances.” [Id.] According to NJDEP, the Chambers Work site is contaminated with PFAS, including perfluorooctanoic acid (“PFOA”), perfluorononanoic acid (“PFNA”), perfluorooctanesulfonic (“PFOS”) and “GenX”—a substance that EIDP developed to replace PFOA. By its Third Amended Complaint, NJDEP seeks, among other things, cleanup costs, costs to

restore the natural environment, and an injunction against EIDP to stop the release of PFAS into the environment at Chambers Works. [Third Am. Compl. (“TAC”) ¶ 7 (19- 14766, Docket No. 332).] II. SPECIAL MASTER ORDER NO. 2

In May 2022, NJDEP moved to compel discovery, seeking an order compelling EIDP to, among other things, “identify, to the extent currently known, all contaminants released from the sites.” [19-14758, Docket No. 244-1.] About six months later, Magistrate Judge Clark granted NJDEP’s motion, but narrowed the definition of “Hazardous Substances, Pollutants, or Contaminants” (collectively, “Contaminants”). [19-14766, Docket No. 252 at 14.] Judge Clark found NJDEP could seek discovery on Contaminants that it had “a reasonable belief that [EIDP] [has] released into the environment and which are included in the environmental hazardous

substance lists adopted by state and federal authorities.” [Id.] NJDEP appealed that ruling on the Contaminants definition, but the Court sent this case and three others that NJDEP filed against EIDP to mediation. [19-14766, Docket Nos. 255, 268.] The Court administratively terminated NJDEP’s appeal of Magistrate Judge Clark’s discovery order.

Mediation was ultimately unsuccessful, and the parties requested the Court to return the cases to active status. [19-14765, Docket No. 245.] The parties requested the Court to appoint a Special Master. [19-14766, Docket No. 290.] The Court granted that request, appointing the requested Special Master “to perform non-dispositive case management and scheduling matters.” [19-14766, Docket No. 292.] The Court then

referred NJDEP’s appeal of Magistrate Judge Clark’s discovery ruling to “the Special Master for resolution.” [19-14758, Docket No. 380.] In doing so, the Court explained it would only address the appeal after “all good faith efforts to resolve the issues with the Special Master have been exhausted.” [Id.] With the Special Master’s assistance, the parties largely resolved NJDEP’s

appeal of Magistrate Judge Clark’s discovery rulings. Yet the definition of PFAS became a sticking point for the parties. EIDP insisted that the NJDEP could only obtain discovery on PFAS relating to the Chambers Works facility if it has “a reasonable belief that [EIDP] released [it] into the environment” as set forth in Magistrate Judge Clark’s discovery ruling, which includes, among other things, PFOA and PFNA. [19-14766, Docket No. 344-11.] Plaintiffs proposed that the PFAS definition would include “any compound that contains, breaks down into, or may

cause the formation in the environment of any of those substances.” [Id.] The Special Master heard the parties’ argument on an acceptable PFAS definition over several hearings. The Special Master ordered a few rounds of briefing and ordered the parties to provide him with the definition of PFAS used in other litigations. The NJDEP proposed the following PFAS definition:

“PFAS” is defined as any per- and polyfluoroalkyl substances, including without limitation, PFOA, PFNA, PFOS, and GenX, that have been used, handled, stored, processed, treated, disposed, emitted, intentionally or unintentionally generated in any manufacturing process, intentionally or unintentionally generated in any waste treatment and/or disposal process, or discharged from the Chambers Works Site, as well as any brought on to the Site as transported waste.

EIDP countered, again seeking a definition that had a “reasonable belief” standard but adding a detection requirement: For the purpose of discovery in this action, PFAS shall be defined as those compounds that Plaintiffs have a reasonable belief have been released into the environment from the Chambers Works site and for which there has been a detection in a known sample.

The Special Master adopted NJDEP’s PFAS definition, reasoning that given NJDEP’s claims, the department “need[s] to know all PFAS used[,] transported to, stored … at Chambers Works.” [19-14766, Docket No. 333 (“SM Order No. 2”).] This is so, according to the Special Master, because NJDEP: (1) seeks to have EIDP investigate, delineate, and remediate the company’s “alleged historical PFAS releases[;]” and (2) seeks “an injunction to cease all PFAS releases from [Chambers Works.]” [Id.] The Special Master found EIDP to be “in the best position to know all

PFAS at the Site[.]” [Id. at 3.] The Special Master also found Chambers Works “unique” because EIDP received PFAS manufactured at other EIDP facilities at Chambers Works and treated off-site PFAS brought to Chambers Works from other facilities and third parties. [Id.]

The Special Master found EIDP’s PFAS definition unworkable, reasoning that it “will inevitably lead to squabbles about whether [the NJDEP has] a reasonable belief or what has been detected in a sample.” [Id.] The Special Master also noted that the NJDEP’s proposed PFAS definition would assist it “to identify where [it] should test for PFAS to find out if PFAS is located on site and/or is being released off-site.” [Id.]

On top of those reasons, the Special Master found that EIDP had not made an undue burden argument on complying with the NJDEP’s proposed PFAS definition. [Id.] A. EIDP’s Arguments EIDP largely makes a procedural challenge to the Special Master’s PFAS definition. [19-14766, Docket No. 344-1 at 8–10.] EIDP contends the Special Master

lacked the authority to adopt a PFAS definition given this Court’s Appointment Order that authorized him only to resolve NJDEP’s discovery appeal. [Id. at 9.] According to EIDP, the Special Master only had the power to help the parties’ resolve their dispute and make a non-binding recommendation on a PFAS definition.

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NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION v. E.I DUPONT DE NEMOURS AND COMPANY, (D.N.J. 2024).

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