BACKGROUND OVER THE TWO AND A HALF YEARS SPANNING LATE 1979 TO MARCH 1983, FILM RECOVERY SYSTEMS, INC. AND THE OTHER GENER- ATOR DEFENDANTS NAMED IN THE ENCLOSED COMPLAINT, WERE AT ONE TIME OR ANOTHER OPERATORS OF A SILVER RECOVERY BUSINESS AT 1855 GREENLEAF AVENUE, ELK GROVE VILLAGE, ILLINOIS. THEY USED INORGANIC CYANIDE SOLUTIONS TO STRIP SILVER COMPOUNDS FROM X-RAY AND OTHER FILM STOCKS THAT WERE SHREDDED INTO SMALL PIECES, BY PLACING THEM INTO 1000 GALLON TANKS FOR SEVERAL DAYS AT A TIME. THE RESULTING LIQUOR WAS DECANTED INTO ELECTROPLATING TANKS AND PLATED ONTO STAINLESS STEEL ELECTRODES FOR RECOVERY. THE SILVER IN THE SLUDGES GENERAT- ED WAS FURTHER RECOVERED BY SMELTING. ABOUT 65,000 POUNDS OF WASTE CHIPS WERE GENERATED EACH DAY DURING PEAK OPERA- TIONS. THE WASTE CHIPS WERE SUPPOSED TO BE TREATED WITH SODIUM HYPOCHLORITE PRIOR TO DISPOSAL, TO REDUCE THE CYANIDE PRE- SENT ON THEM TO NONREACTIVE LEVELS. AS THE BUSINESS PRO- GRESSED, A CONSCIOUS DECISION WAS APPARENTLY MADE TO REDUCE COSTS BY REDUCING THE LEVEL OF TREATMENT OF THE WASTE. AS A RESULT, THE 16 MILLION POUNDS OF CHIPS, COATED WITH UP TO 400 PPM OF CYANIDE AND 10 PPM OF SILVER, WERE ILLEGALLY GENERATED AND STORED, IN TRAILERS AND WAREHOUSES LEASED BY THE DEFENDANTS, IN COOK AND LEE COUNTIES, ILLINOIS. THE WASTES ARE CLEARLY REACTIVE UNDER 40 C