BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RECEE
CLERK'S
OFFICE
IV
D
APR
.
2 2 2008
STATE OF ILLINOIS
Pollution Control Board
v.
AET ENVIRONMENTAL INC., a Colorado
Corporation, and E.O.R. ENERGY, LLC, a
Colorado limited liability company,
Respondent.
NOTICE OF FILING
PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of the
Pollution Control Board the Respondent's Answer to the Complainant's Complaint and my
Appearance on behalf of AET ENVIRONMENTAL INC., a Colorado Corporation, copies of
which are hereby served upon you.
jp
Lori M. DeVito
jitty
lcAA114, 2007
Lori M. DeVito
AET Environmental, Inc.
14 Lakeside Lane
Denver, CO 80212
(303) 333-8521
PEOPLE OF THE STATE OF ILLINOIS,
Complainant,
PCB 07-95
Enforcement
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
Complainant,
AET ENVIRONMENTAL INC., a Colorado
Corporation, and E.O.R. ENERGY, LLC, a
Colorado limited liability company,
PCB 07-95
Enforcement
RECEIVED
CLERK'S
OFFICE
APR' 2 2 2008
STATE OF KIINOIS
Pollution Control Board
Respondent.
APPEARANCE
I hereby file my appearance pro se, as a non-attorney, on behalf of AET
ENVIRONMENTAL, INC., a Colorado Corporation.
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Lori M. DeVito
Lori M. DeVito
AET Environmental, Inc.
14 Lakeside Lane
Denver, CO
80212
(303) 333-8521
Notary Public
CERTIFICATE OF SERVICE
I, the undersigned, certify that I have served the attached Respondent's Answer to
Complainant's Complaint and my Appearance on behalf of AET ENVIRONMENTAL INC., a
Colorado Corporation, by first class mail on April 14, 2008 upon the following party:
Michael D. Mankowski
Assistant Attorney General
Illinois Attorney General's Office
500 S. Second St.
Springfield, Illinois 62706
Lori M. DeVito
NOTARY.`,_
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Environmental
A 11
April 14, 2008
John T. Therriault, Assistant Clerk
Illinois Pollution Control Board
James R. Thompson Center, Ste. 11-500
100 West Randolph
Chicago, Illinois 60601
RE: People v. AET Environmental, Inc., a Colorado corp., and E.O.R. Energy, LLC, a Colorado
limited liability company.
PCB 07-95
Dear Sir:
Enclosed for filing please find the original and five copies of a Notice of Filing and
RESPONDENT"S answers to COMPLAINANT"S REQUEST TO ADMIT FACTS BY AET
ENVIRONMENTAL, INC., in regard to the above-captioned matter. Please file the originals
and return file-stamped copies to me in the enclosed, self-addressed envelope.
Sincerely,
Lori M. DeVito
encl.
Denver:
Salt Lake:
Las Vegas:
Panama City:
Source Environmental, Inc.
14 Lakeside Ln. • Denver, CO 80212 • 303-333-8521
3653 So. 700 W • Salt Lake City, UT 84119 • 801-281-3507
3725 West Teco Ave. • Las Vegas, NV 89118 • 702-436-6228
3160 Airport Rd. • Panama City, FL 32405 • 850-873-8070
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
Complainant,
AET ENVIRONMENTAL INC., a Colorado
Corporation, and E.O.R. ENERGY, LLC, a
Colorado limited liability company,
Respondent.
PCB 07-95
Enforcement
RECEIVED
CLERK'S OFFICE
APR
.
2 2 2098
STATE
OF ILLINOIS
Pollution Control Board
RESPONDENT'S ANSWER TO COMPLAINANT'S COMPLAINT
The Respondent, AET ENVIRONMENTAL INC., a Colorado Corporation, arguing on its
own
behalf,
herein responds to the Complainant's Complaint
as
provided in Section 103.204(d) of
the Board's rules.
COMPLAINANTS REQUEST TO ADMIT FACTS BY AET ENVIRONMENTAL, INC.
1.
In response to item 1, the Respondent is without knowledge or information
as
to the
definition of "hazardous waste broker" sufficient to form a belief
as
to the truth of the allegations.
2.
In response to item 2, the Respondent is without knowledge or information sufficient as to
the meaning of the term "handles" to form a belief
as
to the truth of the allegations.
3.
In response to item 3, the Respondent admits the allegations.
4.
In response to item 4, the Respondent admits the allegations.
5.
In response to item 5, the Respondent admits the allegations.
6.
In response to item 6, the Respondent admits the allegations.
7.
In response to item 7, the Respondent admits the allegations.
8.
In response to item 8, the Respondent admits the allegations.
9.
In response to item 9, the Respondent admits the allegations.
10.
In response to item 10, the Respondent admits the allegations.
11.
In response to item 11, the Respondent admits the allegations.
12.
In response to item 12, the Respondent admits the allegations.
13.
In response to item 13, the Respondent admits the allegations.
14.
In response to items 14, the Respondent admits the allegations.
15.
In response to item 15, the Respondent is without knowledge or information sufficient to
form a belief as to the truth of the allegations.
16.
In response to item 16, the Respondent believes the statements to be true but has no direct
knowledge or information sufficient as to form an opinion as to the accuracy of the statements.
17.
In response to item 17, the Respondent believes the statements to be true but has no direct
knowledge or information sufficient as to form an opinion as to the accuracy of the statements.
18.
In response to item 18, the Respondent believes the statements to be true but has no direct
knowledge or information sufficient as to form an opinion as to the accuracy of the statements.
19.
In response to item 19, the Respondent believes the statements to be true but has no direct
knowledge or information sufficient
as
to form an opinion as to the accuracy of the statements.
20.
In response to item 20, the Respondent does not understand the meaning of "hired to
remove" nor believes that the date of July 15, 2002 is correct.
21.
In response to item 21, the Respondent denies that it was hired to dispose of any materials.
22.
In response to item 22, the Respondent admits to having a supplier deliver totes to Luxury
Wheels in July of 2002.
23.
In response to item 23, the Respondent admits the totes were ordered from Grief Bros and
were delivered directly to Luxury Wheels.
24-25. In response to items 24 and 25, the Respondent believes the statements to be true.
26.
In response to item 26, the Respondent is without knowledge or information sufficient to
form a belief
as
to the truth of the allegations.
27.
In response to item 27, the Respondent denies the allegations.
28.
In response to item 28, the Respondent denies the allegations.
29.
In response to item 29, the Respondent believes the statement to be true but is without
sufficient knowledge or information to form a belief and to the truth of the allegations.
30.
?
In response to item 30, the Respondent denies that the statement fully discloses the
creation of the profile as to the involvement of all parties.
31-32. In response to item 31 and 32, the Respondent believes the statement to be correct.
33.
?
In response to item 33, the Respondent denies the allegation.
34-41. In response to item 34 through 41, the Respondent believes the statements to be
substantially true.
42.
?
In response to item 42, the Respondent denies that the statement fully discloses the
creation of the manifest as to the involvement of all parties.
43-46. In response to items 43 through 46, the Respondent believes the statements to be
substantially correct.
47.?
In response to item 47, the Respondent denies the allegation.
48-49. In response to items 48 and 49, the Respondent believes the statements to be substantially
correct.
50.
In response to item 50, the Respondent does not have sufficient knowledge or information
to attest to the validity of the statement due to the overly broad and ambiguous nature of the
statement.
51.
In response to item 51, the Respondent denies the allegation.
52.
In response to item 52, the Respondent denies the allegation.
53.
In response to item 53, the Respondent denies the allegation.
54.
In response to item 54, the Respondent denies the allegation.
55.
In response to item 55, the Respondent does not have sufficient knowledge or information
as
to the nature of the description to attest to the truth of the statement.
56-59. In response to items 56 through 59, the Respondent believes the statements to be
substantially correct.
60.
In response to item 60, the Respondent is without sufficient knowledge or information in
order to develop a belief
as
to the accuracy of the statement.
61.
In response to item 61, the Respondent denies the allegation.
62.
In response to item 62, the Respondent denies the allegation.
63.
In response to item 63, the Respondent denies the allegation but
was modified at the direction of the generator.
64.
In response to item 64, the Respondent denies the allegation but
was modified at the direction of the generator.
65.
In response to item 65, the Respondent denies the allegation but
was modified at the direction of the generator.
admits that the manifest
admits that the manifest
admits that the manifest
66.
In response to item 66, the Respondent admits to statement.
67.
In response to item 67, the Respondent admits to statement.
68.
In response to item 68, the Respondent denies the allegation.
69.
In response to item 69, the Respondent denies the allegation but admits that a profile was
created at the direction of the generator for Safety Kleen.
70-72. In response to items 70 through 72, the Respondent believes the statements to be correct
73.
In response to item 73, the Respondent denies the allegation.
74.
In response to item 74, the Respondent admits to statement.
75-84. In response to items 75 through 84, the Respondent believes the statements to be
substantially correct.
85.
In response to item 85, the Respondent denies the allegation.
86.
In response to item 86, the Respondent denies the allegation.
87-88. In response to items 87 and 88, the Respondent denies the allegation.
89.?
In response to item 89, the Respondent denies the statement, the material arrived in a semi
trailer and was not moved.
90-92. In response to items 90 through 92, the Respondent admits that the statements are
substantially correct.
93.
In response to item 93, the Respondent denies the allegation.
94.
In response to item 94, the Respondent admits to the statement.
95.
In response to item 95, the Respondent denies the allegation.
96.
In response to item 96, the Respondent denies the allegation.
97.
In response to item 97, the Respondent denies the allegation.
98-106.In response to items 98 through 106, the Respondent denies the allegations.
107. In response to item 107, the Respondent does not have sufficient knowledge or
information so as to form a belief as to the truth of the statement.
108.
In response to item 108, the Respondent denies the truth of the statement.
109. In response to item 109, the Respondent denies the truth of the statement.
110. In response to item 110, the Respondent denies the truth of the statement.
111. In response to item 111, the Respondent deems the allegation to be ambiguous and is
without sufficient knowledge or information in order to develop a belief as to the truth of the
statement.
112.
In response to item 112, the Respondent deems the allegation to be ambiguous and is
without sufficient knowledge or information in order to develop a belief as to the truth of the
statement.
113. In response to item 113, the Respondent denies the allegation.
114. In response to item 114, the Respondent denies the allegation but admits that material was
added at the direction of the generator.
115.
In response to item 115, the Respondent denies the allegation but admits that material was
added at the direction of the generator.
116.
In response to item 116, the Respondent denies the allegation but admits that the material
was redistributed for the later convenience of use at the direction on the generator.
117.
In response to item 117, the Respondent admits to the statement.
118.
In response to item 118, the Respondent admits to the statement.
119.
In response to item 119, the Respondent denies the allegation.
120.
In response to item 120, the Respondent denies the allegation.
121.
In response to item 121, the Respondent denies the allegation.
122.
In response to item 122, the Respondent believes the statement to be correct.
123.
In response to item 123, the Respondent is without knowledge or information sufficient in
order to develop a belief as to the truth of the statement.
124.
In response to item 124, the Respondent denies the allegation.
125.
In response to item 125, the Respondent deems the allegation to be ambiguous and is
without sufficient knowledge or information in order to develop a belief as to the truth of the
statement
126.
In response to item 126, the Respondent denies the allegation.
127.
In Response to item 127, the Respondent deems the allegation to be ambiguous and is
without sufficient knowledge or information in order to form a belief as to the truth of the
statements.
128 to
137.
In response to items 128 through 137, the Respondent believes the statements to be
substantially correct, and all were performed at the direction of the generator.
138.
In response to item 138, the Respondent is without knowledge or information sufficient to
know the accuracy of the statement.
139.
In response to item 139, the Respondent admits to the statement.
Respectfully submitted,
Lori M. Devito
Lori M. Devito
AET Environmental, Inc.
14 Lakeside Lane
Denver, CO 80212
(303) 333-8521
