Complainant,
V .
MICHEAL MORETON
Respondent
.
BEFORE THE
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
ILLINOIS POLLUTION CONTROL BcRECEIV
CLERK'S OFFICE
EQ
SEP 0 6 2006
AC 04-51
Pollution
Control
Board
(IEPA No
. 83-o4-AC)
-----------------------------------POST-HEARING
BREEF OF RESPONDENT
The respondent, not being trained in law, and unable to afford
legal counsel,will use layman logic to defend the charges .
The complaintants witness testified he had made a previos
trip to this site, and observed a recycling operation in progess
an the inspection ofi February 23, 2004,he observed mobile homes
that he assumed were abandend, but failed to check at the coles
county courthouse to see if the paper work was done tolegally store
them . He t hem observed a stove and a small pile of multy -colored
items, but failed to bend over and pick one up to see whither it was
plastic or metalueHthenobsevered piles of what he called construtio
but from a previous visit, he knew it was pitwash and that
there fora specific purpose . Pit weah is a bi product of a
operation, never been previosly usda, never been used in a
it was
concrete
road,
never been a concrete block, never been any part of a building,
it is a new material until it is used the first time . It is also
recycleable . He observed a mobile home in the process of being dis-
manteld for recycling, and apile of wood that is a bi product
of the recycling process,as are tires from recycling cars
. The 255
tires he estimated that were on the property, would be less than
60 recycled cars, and from his pictures, all but appmoximatey 30
were in or on containers, and all but about 30 were still on the
rims waiting for more recycling
.
The wheel steel and even the tires
are recycleable material . He then took pictures of 2- 55 gallon
barrels and from aprevious visit knew it was hydralic oil from a care
crusher, and a n accidental spill resulting from a repair, it has
since been cleaned up and disposed of .
In all the complaintants witness contered all of his charges .
He acknowleged that respondent was licesed by the secretary of state
at that location . Thaty from previous visit he knew and even observed
respondent in the process of recycling .
And finally, he knew that a problem existed between respondant and
a deputy sherriff, and nowa an ajacent land owner, using the power
of his office to financally hurt me . There are laws to protect
people from this . If they don't want me there, they should take
me in fromt of a judge in coles county, not thru the secr®ry of
state or the pollution control board .
Rspectfully submitted,
MICHEAL L . MORETON
