CLERicS OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
DEC 1 8 2003
PEOPLE OF THE STATE OF ILLINOIS,
LISA MADIGAN, Attorney General
of the State of Illinois,
ONYX ENVIRONMENTAL SERVICES LLC,
a
Delaware limited liability company,)
and AURA
II,
INC.,
a Wisconsin
corporation,
STATE OF ILLINOIS
PoI!~tjo~
Control Board
PCB 04-3
(Enforcement-Multimedia)
NOTICE OF FILING
TO:
Greig R.
Seidor
Chief Legal Officer
Onyx Environmental Services
700 E. Butterfield Road
Suite 201
Lombard, Illinois 60148
Debra A. Slater
Weiss Berzowski Brady
700 North Water Street
Milwaukee,
WI 53018-1815
PLEASE TAKE NOTICE that
I have today filed with the Office
of the Clerk of the Illinois Pollution Control Board a Complaint,
Notice of Filing,
and a Certificate of Service on behalf of the
People of the State of Illinois,
a copy of which is attached and
herewith served upon you.
Section 103.204(f)
of the Pollution Control Board Procedural
Rules,
35
Ill. Adm.
Code 103.204(f) provides:
“Failure to file an
answer to this complaint within 60 days may have severe
consequences.
Failure to answer will mean that all allegations
in the complaint will be taken as if admitted for purposes of
this proceeding.
If you have any questions about this procedure,
•Complainant,
vs.
Respondents
you should contact the hearing officer assigned to this
proceeding,
the Clerk’s Office or an attorney.
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS
•
LISA
MADIGAN
Attorney General
State of Illinois
BY:
_______________
•
ZEMEHERET BEREKET-AB
•
Assistant Attorney General
Environmental Bureau
188 W. Randolph St.,
20th Flr.
Chicago,
IL 60601
(312)
814-3816
DATE:
December 18,
2003
H~\common\EflVirOflrfleI1ta1\Z~EREKET-AB\ONYX NOTICE OF FILING.wpd
THIS FILING IS SUBMITTED ON RECYCLED PAPER
•
CLERIcs OR~ICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
DEC 1 8 2003
PEOPLE OF THE STATE OF ILLINOIS,
)
•
STATE OFILLINOIS
LISA MA.DIGAN, Attorney General
)
Pollution
Control
Board
of the State of Illinois,
)
Complainant,
v.
)
PCB-~
(Enforcement-Multimedia)
ONYX ENVIRONMENTAL SERVICES,
LLC, a Delaware limited liability
company, and AURA II,
INC.,
a
Wisconsin corporation,
Respondents.
COMPLAINT
Complainant,
PEOPLE OF THE STATE OF ILLINOIS, by LISA
MADIGAN, Attorney General
of the State of Illinois,
on her own
motion,
and at the request of the Illinois Environmental
Protection Agency,
complains of Respondents,
ONYX ENVIRONMENTAL
SERVI~S, LLC,
(“Onyx”)
a Delaware limited liability company and
AURA II, INC.,
(“Aura”)a Wisconsin corporation,
as follows:
•
COUNT I
AIR POLLUTION
~•
VIOLATIONS BY ONYX AND AURA
1.
This Complaint is brought on behalf of the PEOPLE OF
THE STATE OF ILLINOIS,
by LISA MADIGAN, Attorney General of the
State of Illinois,
on her own motion, and at the request of the
Illinois Environmental Protection Agency,
pursuant to the terms
1
and provisions of Section 31 of the Illinois
Environmental
Protection Act
(“Act”)
,
415 ILCS 5/31 (2002)
2.
The Illinois Environmental Protection Agency
(“Illinois
EPA”)
is an administrative agency of the State of Illinois,
created by Section 4 of the Act,
415 ILCS 5/4
(2002), and
charged,
inter alia,
with the duty of enforcing the Act.
3.
Respondent, Onyx Environmental Services,
LLC,
(“ONYX”)
is a Delaware Limited Liability Company,
authori~zedto transact
business in the State of Illinois.
4.
ONYX is a provider of integrated environmental
management services,
including the identification and separation
of hazardous waste,
hazardous waste packaging,
removal, disposal,
transportation,
and recycling.
5.
Respondent, Aura II,
Inc.
(“AURA”)
is
a Wisconsin
Corporation, not authorized to transact business in the State of
Illinois.
AURA owns a gold and silver reclamation business at
8035 W.
Calumet Road, Milwaukee,
State of Wisconsin.
6.
In its silver reclamation business, AURA employs
a
process to remove gold and silver from plastic computer parts
utilizing a mixture of hydrochloric and nitric acid solutions.
AURA then adds sulfur dioxide gas to the mixture of hydro-
chloric acid and nitric acids,
which causes the gold and silver
to precipitate.
7.
The resulting solution contains nitric acid,
hydrochloric acid and sulfuric acid,
as well as some residual
2
metals with RCRA hazardous waste numbers: D002, D006,
D007,
D008
and DOll
(“AURA waste”).
8.
Aura owns the waste.
At sometime prior to July 2,
• 2001, AURA,
as owner of the waste, entered into a contract with
ONYX for ONYX to transport AURA waste from the Wisconsin facility
to an off-site waste management facility located in Ohio.
9.
On July
2,
2001,
at or around 7:00 a.m., AURA
transferred 2000 gallons of the AURA waste to an unlined ONYX
tanker for transportation through the State of Illinois to a
waste management facility in Vickery, Ohio.
10.
The AURA waste transferred to the ONYX tanker
contained hydrochloric,
sulfuric,
and nitric acids.
The mixture
of these acids is highly corrosive.
11.
On July 2,
2001,
at or around 9:45 a.m.,
while the ONYX
tanker was passing through the State of Illinois on its way to
Ohio,
the driver of the ONYX tanker was alerted by a passing
motorist that the ONYX tanker was leaking.
12.
On July 2,
2001,
at around 9:49 a.m.,
the driver of the
ONYX tanker pulled into the Lake Forest Plaza Oasis on Interstate
94, near the Village of Libertyville,
in Lake County,
Illinois,
(“the
Site”)
13.
At the site,
the ONYX diver activated the tanker’s
vacuum pump in order to slow the rate of leakage from the tanker.
•
3
14.
Within ten minutes of activating the vacuum system,
the
ONYX
tanker began venting a vapor cloud
out of its pressure
relief valve to the atmosphere.
15.
The vapor cloud was described as brown, red/orange,
or
rust-yellow and was reported to be about 50 feet wide by 50 feet
long
(“acid vapor”)
16.
The cloud of acid vapor persisted for up to
1 to 2
hours before
it was dissipated by the Libertyville Fire
Department through the use of “deluge guns” which sprayed water
onto the cloud of acid vapor.
17.
The nature of the acid vapor caused local emergency
response officials to evacuate the 30-40 workers and customers
from the Site as well as
83 residents from 48 homes within a half
mile radius to the west of the tanker.
18.
The nature of the acid vapor also necessitated the
closure of
1-94,
as well as nearby
St. Mary’s Road,
Bradley Road
and Old School Road in Lake County,
Illinois,
for several hours.
19.
Section 3.315 of the Act,
415 ILCS 5/3.315
(2002),
defines “person” as:
any individual, partnership,
co-partnership,
firm,
company,
limited liability company,
corporation,
association,
joint
stock company,
trust,
estate,
political subdivision,
state agency,
or any other legal
entity,
or their legal representative,
agent or
assigns.
4
20.
ONYX,
a limited liability company,
is
a person as that
term is defined by Section 3.315 of the Act, 415 IL 5/3.315
(2002)
21.
AURA,
a corporation,
is a person as that term is
defined by Section 3.315 of the Act,
415 ILCS 3.315
(2002)
22.
Section 3.165 of the Act,
415
ILCS 5/3.165
(2002),
defines
“contaminant” as,
“any solid,
liquid, or gaseous matter,
any odor,
or any form of energy, from whatever source.”
23.
Section 9(a)
of the Act,
415 ILCS 5/9 (a) (2002)
provides as follows:
No person shall:
(a)
Cause or threaten or allow the discharge or
emission of any contaminant into the environment
in any State so as to cause or tend to cause air
pollution in Illinois, either alone or in
combination with contaminants from other sources,
or so as to violate regulations or standards
adopted by the Board under this Act;
24.
Section 3.115 of the Act, 415 ILCS 5/3.115
(2002),
defines
“air pollution”
as:
the presence in the atmosphere of one or more
contaminants in sufficient quantities and of such
characteristics and duration as to be injurious to
human, plant,
or animal
life,
to health,
or to
property,
or to unreasonably interfere with the
enjoyment of life or property.
25.
Section 201.141 of the Illinois Pollution Control Board
(“Board”) Air Pollution Regulations,
35
Ill. Adm. Code 201.141,
titled,
Prohibition of Air Pollution,
provides as follows:
No person shall cause or threaten or allow the
discharge or emission of any contaminant into the
5
environment
in any State so as, whether alone or in
combination with contaminants from other sources,
to
cause or tend to cause air pollution in Illinois,
or so
as to violate the provisions of this Chapter,
or so as
to prevent the attainment or maintenance of any
applicable ambient air quality standard.
26.
The acid vapor,
emitted into the environment in
Illinois from the unlined ONYX tanker is a contaminant as that
term is defined in Section 3.165 of the Act,
415 ILCS 5/3.165
(2002)
27.
Acid vapors are injurious to human health and to plant
or animal
life.
Acute exposure to acid vapors can cause
irritation to the eyes,
nose,
throat and skin as well as
respiration problems, edema and potentially death.
28.
On or about July 2,
2001, Respondents caused,
threatened or allowed the discharge of acidic vapors and AURA
waste,
contaminants, from the unlined ONYX tanker into the
environment
in Illinois in sufficient quantities so as to cause
or tend to cause air pollution in Illinois.
29.
By causing,
threatening,
or allowing the release of
acidic vapors and AURA waste,
contaminants,
into the environment
in Illinois, Respondents caused or threatened or allowed air
pollution in Illinois,
in violation of Section 9(a)
of the Act,
415 ILCS 5/9(a)
(2002),
and 35
Ill. Code 201.141.
WHEREFORE,
Complainant,
PEOPLE OF THE STATE OF ILLINOIS,
respectfully requests that the Board enter an order in favor of
Complainant and against Respondents with respect to Count
I:
6
1.
Authorizing a hearing in this matter at which time the
Respondents will be required to answer the allegations herein;
2.
Finding that Respondents have threatened,
caused or
allowed air pollution in violation of Section 9(a)
of the Act and
35
Ill. Adm. Code 201.141;
3.
Ordering Respondents to cease and desist from any
further violations of Section 9(a)
of the Act and 35
Ill.
Adrn.
Code 201.1451;
4.
Ordering Respondents to implement procedures for the
selection of tankers,
the cleaning of tankers between loads, and
the approval of tankers by customers seeking to ship acidic or
highly corrosive or reactive wastes or materials;
5.
Assessing a civil penalty of Fifty Thousand Dollars
($50,000.00)
against each Respondent for each and every violation
of the Act and Board regulations and an additional Ten Thousand
Dollars
($10,000.00)
for each day during which each violation
continued;
6.
Taxing all costs in this action,
including attorney,
expert witnesses, emergency response, and consultant fees,
against the Respondents; and
7.
Granting such other relief as the Board deems
appropriate and just.
7
COUNT II
WATER POLLUTION
1-22.
Complainant realleges and reincorporates by
reference herein paragraphs
1 through 22 of Count
I
as paragraphs
1 through 22 of this Count II.
23.
On July
2,
2001, on or about
11:00 a.m.,
the entire
contents of the AURA waste had leaked out of the ONYX tanker and
been released, either to the ambient air,
onto public highways,
or onto the soil,
asphalt and stone surfabes at and around the
Site.
24.
The AURA waste drained for about
1000 feet on the
asphalt parking lot at the Site before reaching two sand dikes
which had been installed to try to prevent the AURA waste from
flowing down the Oasis access ramps.
25.
Only approximately 100 to 150 gallons of AURA waste was
captured by the sand dikes.
26.
Up to 1850 gallons
of AURA waste entered two storm
sewers and a drainage way, which had water in them,
one on the
east and one on the west end of the Site.
27.
The storm sewers lead to a drainage-way which travels
along the shoulder of 1-94 and ultimately the water discharges
into a nearby field.
8
28.
Section 3.345 of the Act,
415 ILCS 5/3.545
(2002),
defines “water pollution”
as:
such alteration of the physical,
thermal,
chemical,
biological or radioactive properties of any waters of
the State,
or such discharge of any contaminant into
any waters of the State,
as will or is likely to create
a nuisance or render such waters harmful or detrimental
or injurious to public health,
safety or welfare, or to
domestic,
commercial,
industrial,
agricultural,
recreational,
or other legitimate uses, or to
livestock,
wild animals, birds,
fish,
or other aquatic
life.
29.
The AURA waste released from the unlined ONYX tanker
entered and impacted storm sewers containing waters and a
drainage way within several hundred yards of the point of
release.
30.
Some residual liquid acid waste remained in the
drainage way until at least July
5,
2001.
31.
Section 3.550 of the Act,
415 ILCS 5/3.550
(2002),
defines “waters
of the State”
as:
all accumulations of water,
surface and underground,
natural, and artificial, public and private,
or parts
thereof, which are wholly or partially within,
flow
through, or border upon this State.
32.
Waters in storm sewers and drainage ways are waters of
the State of Illinois as that term is defined in Section 3.550 of
the Act, 415 ILCS 5/3.550
(2002)
33.
AURA waste discharged from the unlined ONYX tanker into
water containing storm sewers and drainage ways, waters of the
State of Illinois,
contained the heavy metals Cadmium
(USEPA
hazardous waste
“HW” Number D006),
Chromium (USEPA HW
9
Number DOO7),
Lead
(USEPA HW Number D008),
and Silver
(USEPA HW
Number Doll)
(“heavy meals” collectively)
34.
The
AURA.
waste containing the heavy metals can alter
the physical, thermal,
chemical, biological or radioactive
properties of the waters of the State
in the storm sewers and
drainage ways at the Site.
35.
The AURA waste containing the heavy metals, discharged
into the waters of the State from the unlined ONYX tanker,
are
“contaminants”
as that term
is defined in Section 3.165 of the
Act, 415 ILCS 5/3.165
(2002)
36.
Section 12(a)
of the Act,
415 ILCS 5/12(a)
(2002),
provides as follows:
No person shall:
(a)
Cause or threaten or allow the discharge of any
contaminants into the environment in any State so
as to cause or tend to cause water pollution in
Illinois, either alone or in combination with
•matter from other sources, or so as to violate
regulations or standards adopted by the Pollution
Control Board under this Act.
37.
By causing or allowing the
AURA
waste containing the
heavy metals to be discharged from the unlined ONYX tanker and
enter waters of the state, both through storm sewers and drainage
ways, Respondents caused,
threatened,
or allowed water pollution
in Illinois in violation of Section 12(a)
of the Act, 415 ILCS
5/12 (a)
(2002)
10
WHEREFORE,
Complainant,
PEOPLE OF THE STATE OF ILLINOIS,
respectfully requests that the Board enter an order in favor of
Complainant,
and against Respondents with respect to Count
II:
1.
Finding that Respondents have caused, threatened or
allowed violations of Section 12(a)
of the Act;
2.
Ordering Respondents to cease and desist from any
further violations of Section 12(a)
of the Act;
3.
Ordering Respondents to implement procedures for the
selection of tankers,
the cleaning of tankers between loads,
and
the approval of tankers by customers seeking to ship acidic or
highly corrosive or reactive wastes or materials;
4.
Assessing a civil penalty of Fifty Thousand Dollars
($50,000.00)
against each Respondent
for each and every violation
of the Act and an additional Ten Thousand Dollars
($10,000.00)
for each day during which the violation continued;
5.
Taxing all costs in this action,
including attorney,
expert witness,
emergency response, and consultant fees against
Respondents; and
6.
Granting such other relief as the Board deems
appropriate and just.
11
COUNT III
CREATING A WATER POLLUTION HAZARD
II.
VIOLATIONS BY ONYX
1-35.
Complainant realleges and reincorporates by reference
herein paragraphs
1 through 35 of Count
II as paragraphs
1
through 35 of this Count
III.
36.
Section 12
(d)
of the Act,
415 ILCS 5/12(d) (2002),
provides as follows:
No person shall:
•Deposit any contaminants upon the land in such place
and manner so as to create a water pollution hazard;
37.
On July
5,
2001,
three days after the release of the
AURA
waste,
some residual acid was observed on land some 150 feet
into the drainage-way at the site.
38.
ONYX,
by allowing AURA waste to reach the drainage-way
traveling along the shoulder of
1-94,
deposited AURA waste in
such a place and manner so as to create a water pollution hazard.
39.
ONYX,
by allowing AURA waste to remain in the drainage-
way for three days, deposited
AURA
waste into the drainage-way in
such a place and manner so as to create a water pollution hazard.
40.
By causing or allowing the discharge of AURA waste
containing heavy metals,
to be deposited on land in such place
and manner manner
so as to create a water pollution hazard and so
that future migration of the contaminants could occur, Onyx
violated Section 12(d)
of the Act, 415 ILCS 5/12(d) (2002).
12
WHEREFORE,
Complainant, PEOPLE OF THE STATE OF ILLINOIS,
respectfully requests that the Board enter an order in favor of
Complainant and against Onyx with respect to this Count
III:
1.
Authorizing a hearing in this matter at which time
Onyx will be required to answer the allegations herein;
2.
Finding that Onyx has caused or allowed a violation of
Section 12(d)
of the Act;
3.
Ordering Onyx to cease and desist from any further
violations of Section 12(d)
of the Act;
4.
Assessing a civil penalty of Fifty Thousand Dollars
($50,000.00)
against Onyx for each and every violation of the Act
and an additional penalty of Ten Thousand Dollars
($10,000.00)
for each day during which the violation continued;
5.
Assessing all costs against Onyx,
including attorney,
expert witness, emergency response, and consultant
fees expended
by the State in its pursuit of this action; and
6.
Granting such other relief as the Board deems
appropriate and just.
COUNT IV
CAUSING OR ALLOWING OPEN DUMPING AND ABANDONING OF WASTE
1-22.
Complainant realleges and reincorporates by reference
herein paragraphs
1 through 22 of Count
I as paragraphs
1 through
22 of this Count
IV.
23.
The heavy metals,
contained in the AURA waste which
were discharged at the Site by Onyx, were present in the soils in
13
detectable quantities at or near the Site until about October 3,
2001.
24.
Section 3.535 of the Act, 415 ILCS 5/3.535
(2002),
defines
“waste”
as:
any garbage,
sludge from a waste treatment plant,
water supply treatment plant, or air pollution
control facility or other discarded material,
including solid,
liquid,
semi-solid,
or contained
gaseous material resulting from industrial,
commercial, mining and agricultural operations,
and from community activities,
but does not
include solid or dissolved material in domestic
•
sewage,
or solid or dissolved materials •in
irrigation return flows,
or coal combustion by-
products as defined in Section 3.135,
or
industrial discharges which are point sources
subject to permits under Section 402 of the
Federal Water Pollution Control Act,
as now or
hereafter amended,
or source,
special nuclear,
or
by-product materials as defined by the Atomic
Energy Act of 1954,
as amended
(68 Stat.
921)
or
any solid or dissolved material from any facility
subject to the Federal Surface Mining Control and
Reclamation Act of 1977
(P.L.
95-87)
or the rules
and regulations thereunder or any law or rule or
regulation adopted by the State of Illinois
pursuant thereto.
25.
Section 3.385 of the Act,
415 ILCS 5/3.385
(2002),
defines “REFUSE” as waste.
26.
The AURA waste containing the heavy metals deposited at
and around the Site and which remained at the Site from July
2,
2001,
until
about October 3,
2001,
are “wastes” and “refuse”
as
those terms are defined in Section 3.535 and 3.385
of the Act.
27.
Section 3.185 of the Act,
415 ILCS 5/3.185
(2002),
defines
“disposal”
as:
14
The discharge,
deposit,
injection,
dumping,
spilling,
leaking or placing of any waste or
hazardous waste into or on any land or water or
into any well
so that such waste or hazardous
waste or any constituent thereof may enter the
environment or be emitted into the air or
discharged into any waters,
including ground
waters.
28.
Section 3.460 of the Act,
415 ILCS 5/3.460
(2002),
defines
“site”
as follows:
“SITE” means any location, place,
tract of land,
and facilities,
including but not limited to
buildings,
and improvements used for purposes
subject to regulation or control by this Act or
regulations thereunder.
29.
The land on which the AURA waste,
containing the heavy
metals,
was discharged,
deposited,
dumped,
and/or placed is a
“disposal site,”
as that term is defined by Section 3.460 of the
Act.
30.
Section 3.445 of the Act, 415 ILCS 5/3.445
(2002),
defines “sanitary landfill”
as:
A facility permitted by the Agency for the
• disposal of waste on land meeting the requirements
of the Resource Conservation and Recovery Act,
P.L.
94-580, and regulations thereunder, and
without creating nuisances or hazards to public
health or safety, by confining the refuse to the
smallest practical volume and covering it with a
layer of earth at the conclusion of each day’s
operation, or by such other methods and intervals
as the Board may provide by regulation.
31.
The Site, where the AURA waste containing the corrosive
liquid waste was released,
has never been permitted by the
Illinois EPA for the disposal of waste and thus does not meet the
15
definition of a “Sanitary Landfill”
as that term is defined by
Section 3.445 of the Act.
32.
Section 3.305 of the Act, 415 ILCS 5/3.305(2002),
defines “open dumping”
as:
The consolidation of refuse from one or more
sources at
a disposal site that does not fulfill
the requirements of a sanitary landfill.
33.
The refuse was shipped by AURA and hauled by ONYX from
offsite sources and consolidated at a~Site which does not fulfill
the requirements of a “Sanitary Landfill”
as defined in Section
3.445 of the Act, 415 ILCS 5/3.445(2002).
34.
By causing or allowing the wastes consisting of the
corrosive liquid waste containing the heavy metals,
to be
consolidated, deposited, dumped and/or placed on the Site,
from
July 2,
2001 to October 3,
2001, Onyx engaged in open dumping, as
that term is defined in Section 3.305 of the Act.
35.
Section 21(a)
and
(b)
of the Act,
415 ILCS 5/21(a)
and
(b) (2002)
,
provides as follows:
No person shall:
(a)
Cause or allow open dumping of any waste.
(b)
Abandon,
dump,
or deposit any waste upon the
public highways or other public property,
except
in a sanitary landfill approved by the Agency
pursuant to regulations adopted by the Board.
36.
Interstate 1-94 is a public highway and does not
fulfill the requirements of a “Sanitary Landfill” as that term is
defined by Section 3.445 of the Act,
415 ILCS 5/3.445
(2002)
16
37.
Onyx, by causing or allowing AURA waste to be
dumped,
deposited,
or discharged onto
1-94,
dumped or deposited
waste upon a public highway.
38.
Onyx by its actions as alleged herein,
has violated
Section 21(a)
and
(b)
of the Act, 415 ILCS 5/21(a)
and(b) (2002).
WHEREFORE,
Complainant, PEOPLE OF THE STATE OF ILLINOIS,
respectfully requests that the Board enter an order in favor of
Complainant and against Respondent Onyx with respect to this
Count IV:
1.
Authorizing a hearing in this matter at which time
Onyx will be required to answer the allegations herein;
2.
Finding that Onyx has caused or allowed violations of
Section 21(a)
and
(b)
of the Act;
3.
Ordering Onyx to cease and desist from any further
violations of Section 21(a)
and
(b)
of the Act;
4.
Assessing a civil penalty of Fifty Thousand Dollars
($50,000.00) against Onyx for each and every violation of the Act
and an additional civil penalty of Ten Thousand Dollars
($10,000.00)
for each day during which the violation continued;
5.
Assessing all costs against Onyx,
including attorney,
expert witness,
emergency response,
and consultant
fees expended
by the State in its pursuit of this action;, and
17
6.
Granting such other relief as the Board deems
appropriate and just.
PEOPLE OF THE STATE OF ILLINOIS
LISA MADIGAN
Attorney General of the
State of Illinois,
MATTHEW J.
DTJI’~JN, Chief
Environmental Enforcement/
Asbestos Litigation Division
By:
________
ROSEMARIE CAZEAU,
ief
Environmental Bureau
Assistant Attorney General
Of Counsel:
ZEMEHERET BEREKET-AB
Assistant Attorney General
Environmental Bureau
188 West Randolph Street,
~
Floor
Chicago,
Illinois
(312)
814-3816
H: \common\eflViroruflefltal\zbereket-ab\onyx-aura complaint
18
CERTIFICATE OF SERVICE
I,
the undersigned,
certify that
I have served the attached
Complaint, Notice of Filing,
and Certificate of Service via
United States Postal certified mail upon:
Mr. Greig
R.
Seidor
Chief Legal Officer
Onyx Environmental Services
700 E. Butterfield Rd.
Suite 201
Lombard,
Il 60148
Debra A.
Slater
Weiss Berzowski Brady
700 North Water St.
Milwaukee,
WI 53202-4273
ZEMEHERET BEREKET-AB
Assistant Attorney General
Environmental Bureau
188 W. Randolph St.,
20th Flr.
Chicago,
Illinois 60601
H:\commOfl\EIlVirOflfllefltal\Z BEREKET-AB\ONYX NOTICE OF FILING.wpd
