ILLINOIS POLLUTION CONTROL BOARD
    RECEgVED
    CLERK’S OFFICE
    ILLINOIS
    ENVIRONMENTAL
    )
    -
    MAY
    172004
    PROTECTION AGENCY,
    STATE OF ILLINOIS
    Complainant,
    )
    Pollution
    Control Board
    v.
    )
    AC
    04—51
    (IEPA
    No.
    83-04-AC)
    MICHAEL MORETON,
    )
    (Administrative Citation)
    Respondent.
    PETITION TO REVIEW
    NOW COMES the Respondent, MICHAEL MORETON, pro se,
    and submits
    this Petition to Review and Contest the Administrative Citation
    filed against him in this subject cause, namely
    Violation
    (1)
    :
    That Respondent caused or allowed the open
    dumping of waste in a manner resulting in litter; and
    Violation
    (2)
    : That Respondent caused or allowed the open
    dumping of waste in a manner resulting in deposition of general
    construction or demolition debris
    •or clean construction or
    demolition debris, and contesting said violations,
    states
    as
    follows:
    1. The Respondent hereby submits that he did not cause or allow
    the alleged violations,
    and/or;
    2. The alleged violations were the result of uncontrollable
    circumstances,
    and/or;
    3. The Respondent is a recycler of metals and other materials,
    with IBT #2450—2782.
    4. The Respondent is also a registered “tire user.”
    5. Respondent purchased the subject property some ten
    (10)
    years ago from which to operate his business and to store salable or
    recyclable materials and equipment.
    6.
    Some items listed by the IEPA proposed violations
    (and shown
    in the pictures)
    are not litter but rather recyclables.
    Wherefore,
    Respondent denies that he has violated IEPA rules or
    regulations,
    and objects
    to the imposition of fines or other
    penalties upon him, and petitions the Illinois Pollution Control
    Board to review said citations.
    Michael Moreton
    —
    Respondent
    CERTIFICATE OF SERVICE
    Respondent hereby certifies that on the
    11th
    day of May,
    2004,
    he did serve
    a copy of his Petition for Review upon the following
    persons or entities,
    as so addressed, by mailing same, postage
    prepaid,
    U.S. Mail,
    from Ashmore,
    Ii.
    Illinois Pollution Control Board
    State of Illinois Center
    100 West Randolph St
    —
    Suite 11—500
    Chicago,
    IL 60601
    Illinois Environmental Protection Agency
    Dorothy Gunn,
    Clerk
    Attn: Michelle M. Ryan
    Division of Legal Counsel
    1021 North Grand Ave. East
    P.O. Box 19276
    Springfield,
    IL 61794—9276
    Michael Moreton
    —
    Respondent

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