RECEIVED
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
CLERK’S OFFICE
JUN
62003
ABITEC CORPORATION,
)
)
STArE OF ILUNOIS
Petitioner,
)
Pollution Control Bc’ard
)
)
PCB No.
03-95
)
(Permit Appeal
—
Air)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
Respondent.
)
AFFIDAVIT
OF
LAWRENCE E. WERNER
I, Lawrence E. Werner, being duly sworn under oath state as follows:
1.
I have been employed by ACH Food Companies, Inc., or ABITEC Corporation
(“ABITEC”) since June 16, 1997.
2.
I am currently a Commercial Director at ABITEC Corporation.
3.
As part ofmy job responsibilities, I reviewed the Interrogatories and Document
Production Request issued by the Illinois Environmental Protection Agency
(“IEPA”). I assisted in providing responses and gathering documents forthe
Interrogatories where I have knowledge ofthe subject matter.
4.
I have reviewed the Interrogatories and Document Production Request served
upon ABITEC by the IEPA in this matter and, further, having assisted in the
preparation ofABITEC’s responses to this document, fmd that the facts set forth
in ABITEC’s response to IEPA’s Interrogatories and Document Production
Request are true, responsive and complete to the best ofmy knowledge.
Lawrence E. Werner
STATE OF ILLINOIS
)
COUNTY OF COOK
)
Subscribed and Sworn to
Before me this
____
da
f
______________,2003.
Not~~9lic
............................
“OFFICIAL SEAL”
:
TAMMY BOONE
:
:
NotarY Public1 State of illinois
:
:
My Commission Expires 711/03
:
2
CLERK’S ~
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
JUN
~
2003
ABITEC CORPORATION,
)
)
STATE OF ILLINOIS
Petitioner,
)
Pollution Control Board
)
v.
)
PCB No.
03-95
)
(Permit Appeal
—
Air)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent.
)
AFFIDAVIT OF PAUL
MEISNER
I, Paul Meisner, being duly sworn under oath state as follows:
1.
I have been employed by ABITEC Corporation (“ABITEC”)/ACH Foods
Company since July 1998.
2.
I am currently the Plant Controller ofABITEC’s Paris, Illinois facility (“Paris
Facility).
3.
As part ofmy job responsibilities, I reviewed the Interrogatories and Document
Production Request issued by the Illinois Environmental Protection Agency
(“IEPA”). I assisted in providing responses and gathering documents for the
Interrogatories where I have knowledge ofthe subject matter.
4.
I have reviewed the Interrogatories and Document Production Request served
upon ABITEC by the IEPA in this matter and, further, having assisted in the
preparation ofABITEC’s responses to this document, find that the facts set forth
in ABITEC’s response to JEPA’s Interrogatories and Document Production
Request are true, responsive and complete to the best ofmy knowledge.
Paul Meisner
STATE OF ILLINOIS
)
COUNTY OF COOK
MY
COMMISSIONLORRIE
EXPIRES
A.
BLACK
8/15/2005
~ NOTARYPUBUC~TATEOFILLII~OIS
Subscribed and Sworn to
Before me this
5
day of
________________
2003.
Notary Public
2
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ABITEC CORPORATION,
)
RECEILVED
)
CLERK’S
OFF!(~F
Petitioner,
)
JUN
62003
v.
)
PCB No.
03-95
STATE OF ILLINOIS
)
(Permit AppealPoI(th~)onControl
Board
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
Respondent.
)
AFFIDAVIT OF JEFF DETORO
I, JeffDeToro, being duly sworn under oath state as follows:
1.
I am a Project Manager with Trinity Consultants (“Trinity”) and have been
employed at Trinity from 1993 to 2000 as a Project Consultant and from 2001 to
2002 in my current position. In between my employment at Trinity, I worked as
an Air Quality Specialist at Landrum & Brown from 2000 to 2001.
2.
As part ofmy responsibilities as ABITEC’s consultant, I reviewed the
Jnterrogatories and Document Production Request issued by the Illinois
Environmental Protection Agency (“IEPA”). I assisted in providing responses
and gathering documents forthe Interrogatories where I have knowledge ofthe
subject matter.
3.
I have reviewed the Interrogatories and Document Production Request served
upon ABITEC by the EPA in this matter and, further, having assisted in the
preparation ofABITEC’s responses to this document, find that the facts set forth
in ABITEC’s response to IEPA’s Interrogatories and Document Production
Request are true, responsive and complete to the best ofmy knowledge.
JeffDeToro
STATE OF ILLINOIS
)
)
COUNTY OF COOK
)
Subscribed and Sworn to
Before me this
1-1
day of
iun~
,2003.
(~t
Notary Public
-~ /;5/() ~ E x/~
j OFACLAL SEAL
~OXANE WYMA$
~ NOT~W(PU~1C,
~TAT~O~ILLINOIS
c~v
c~s~ot~~x~so7m~
2
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ABITEC CORPORATION,
)
~j”~ ci’~
)
CLERK’S OFrr”~~
Petitioner,
)
JUN .6 2003
v.
)
PCB No.
03-95
)
(Permit Appeal ~irh1TE OF IWNois
ILLINOIS ENVIRONMENTAL
)
0 uflon Control Board
PROTECTION AGENCY,
)
)
Respondent.
)
AFFIDAVIT OF
BERNIE HINKLE
I, Bernie Hinkle, being duly sworn under oath state as follows:
1.
I have been employe by ABITEC Corporation (“ABITEC”)/ACH Foods
Company since July 22, 1997. I have worked at 1800 S. Main Street, ABITEC’S
Paris Facility (“Paris Facility”), since July 2000.
2.
I am currently the Plant Manager ofABITEC’s Paris, Illinois facility (“Paris
Facility).
3.
As part ofmy job responsibilities, I reviewed the Interrogatories and Document
Production Request issued by the Illinois Environmental Protection Agency
(“IEPA”). I assisted in providing responses and gathering documents for the
Interrogatories where I have knowledge ofthe subject matter.
4.
I have reviewed the Interrogatories and Document Production Request served
upon ABITEC by the IEPA in this matter and, further, having assisted in the
preparation ofABITEC’s responses to this document, find that the facts set forth
in ABITEC’s response to IEPA’s Interrogatories and Document Production
Request are true, responsive and complete to the best ofmy knowledge.
I3ernie Hinkle
STATE OF ILLINOIS
)
COUNTY OF C06K
)
Subscribed and Sworn to
Before me this~S~day of
______________,2003.
“OFFICIAL SEAL”
Not~
~Jv~
MY COMM~thEXPiRES 07/27/04
2
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ABITEC CORPORATION,
RE~
)
CLERK’S
diVED
OFFICE
)
Petitioner,
)
JUN
62003
)
PCB(PermitNoAppeal
0395
—
Palk&tioniur)STATE
OFControlILLINOISBoard
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
Respondent.
)
AFFIDAVIT OF
BRAD SIMS
I, Brad Sims, being duly sworn under oath state as follows:
I
am a Manager for Consulting Services with Trinity Consultants (“Trinity”) and
have been employed at Trinity since 2001. From 1993-1998, I was employed by
Earth Tech. In late 1998, Ijoined ENSR Consulting & Engineering (“ENSR”).
While at ENSR, I was the lead consultant for the development ofthe Paris
Facility’s April 1999 permit application (Application forModification to State
Operating Permit #9307011, Sterol Refining Operations) to EPA.
2.
As part ofmy responsibilities as ABITEC’s consultant, I reviewed the
Interrogatories and Document Production Request issued by the Illinois
Environmental Protection Agency (“IEPA”). I assisted in providing responses
and gathering documents for the Interrogatories where I have knowledge ofthe
subject matter.
3.
I have reviewed the Interrogatories and Document Production Request served
upon ABITEC by the IEPA in this matter and, further, having assisted in the
preparation ofABITEC’s responses to this document, find that the facts set forth
in ABITEC’s response to EPA’s Interrogatories and Document Production
Request are true, responsive and complete to the best ofmy knowledge.
Brad Sims
STATE OF ILLINOIS
)
)
COUNTY OF COOK
)
Subscribed and Sworn to
Before me this
‘f
day of
flu./’YLL.
,2003.
~
E ~P
L~0TA~Y
RoxANEwv~m
I~UIS~C,STAflO~
~L~NOIS
~
2
BEFORE THE ILLINOIS POLLUTION CONTROL BOAI~E~~kVEDCLERK’S OFFr~
ABITEC CORPORATION,
)
JUN
620
)3
Petitioner,
)
STATE OF ILLINOIS
Pollutjo~ControlBoard
v.
)
PCB No. 03-95
)
(Permit Appeal
—
Air)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
Respondent.
)
AFFIDAVIT OF DALE
SARRAZIN
I, Dale Sarrazin, being duly sworn under oath state as follows:
1.
I have been employed by ABITEC Corporation (“ABITEC”) and have worked at
1800 S. Main Street, Paris, Illinois (“Paris Facility), since January 1994.
2.
I am currently a Sterol Operations Supervisor at the Paris Facility.
3.
As part ofmy job responsibilities, I reviewed the Interrogatories and Document
Production Request issued by the Illinois Environmental Protection Agency
(“IEPA”). I assisted in providing responses and gathering documents for the
Interrogatories where I have knowledge of the subject matter.
4.
I have reviewed the Interrogatories and Document Production Request served
upon ABITEC by the IEPA in this matter and, further, having assisted in the
preparation ofABITEC’s responses to this document, find that the facts set forth
in ABITEC’s response to IEPA’s Interrogatories and Document Production
Request are true, responsive and complete to the best ofmy knowledge.
Dale Sarrazin
STATE OF ILLINOIS
)
“ÔmãiACs~Ai..
_
SubscribedCOUNTYOFandCOOKSwornto
)
)
L~±~
MYNO
TARY
COMMISSIONPUBLIC,LORRIESTATEA.EXPIRESBLACKOF8
Before me this
5
day of
______________,2003.
Notary Public
4’~c/
2
BEFORE THE ILLINOIS POLLUTION CONTROL BOAI~ECjE~VED
CLERK’S
()FPV’F
ABITEC CORPORATION,
)
)
JUN
.6 2003
Petitioner,
)
STATE OF ILLINOIS
)
Pollution Control Board
v.
)
PCB No.
03-95
)
(Permit Appeal
—
Air)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
.
)
)
Respondent.
)
AFFIDAVIT OF MIKE BEESLEY
I, Mike Beesley, being duly sworn under oath state as follows:
1.
I am an employee ofABITEC Corporation (“ABITEC”)/ACH Foods Company
since December 2, 1994. I have worked at 1800 S. Main Street, ABITEC’S Paris
Facility (“Paris Facility”), since March 1998.
2.
I am currently the Production Manager ofABITEC’s Paris, Illinois facility (“Paris
Facility). In this capacity, I am knowledgeable about the Paris Facility’s
manufacturing processes and products.
3.
As part ofmy job responsibilities, I reviewed the Interrogatories and Document
Production Request issued by the Illinois Environmental Protection Agency
(“IEPA”). I assisted in providing responses and gathering documents for the
Interrogatories where I have knowledge ofthe subject matter.
4.
I have reviewed the Interrogatories and Document Production Request served
upon ABITEC by the IEPA in this matter and, further, having assisted in the
preparation ofABITEC’s responses to this document, find that the facts set forth
in ABITEC’s response to IEPA’s Interrogatories and Document Production
Request are true, responsive and complete to the best ofmy knowledge.
342200/E/2 WX5ZO2 .DOC
Mike BeesleY
STATE OF ILLINOIS
COUNTY OF..CO~
Subscribed and Sworn to
Before me this
~If~±
day of
~
200,~
Notary Public
“OFFICIAL
DEBRA
K. KIRSCH
s~~I
NOTARY PUBLIC, STATE OF ILLINOIS ~
MY COMMISSION EXPIRES 07/27/04
)
)
)
3422001E/2 WX5ZO2_.DOC
2