State of Illinois, Ogle County

Affidavit

County of Ogle

Complainant,

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)

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) AC No.:08­

v.

Veolia ES Orchard Hills Landfill, Inc.'

Respondent

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Affiant, being first duly sworn, voluntarily deposes' and states as follows:

1. Affiant is afield inspector employed by the County of Ogle and has been so

employed at all times pertinent hereto.

·2

.. On, July 28, 2008 between 11 :40 a.m. and 1:25 p.m., Affiant conducted an

inspection·

of a·solidwaste landfill, located in Ogle County, Illinois and known as

Veolia ES Orchard Hills Landfill,

Inc., b'y t4e Illinois Environmental Protection

Agency - site no. 1410175005.

3. Affiant inspected said Veolia ES Orchard Hills Landfill, Inc. site by an on-site

inspection which included walking and photograp'hing the site.

4. As a result

of the activities referred to in Paragraph 3 above,Affial1t conlpleted the

Inspection Report fonn attached hereto and made a part hereof, which, to the best

of

Affiant's knowledge and belief, is an accurate representation of Affiant's

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observations and factual conclusions with respect to said Veolia ES Orchard Hills

Landfill, Inc. site.

5.That on previous occasions, Joy K. Bliton

of the Ogle County Solid Waste

Management Department, has reminded the operation managers

of the above described

facility that the south slope

of Phase VI needs better cover (inspections on December 4,

2007, February 22, 2008, March 13, 2008, and April 14, 2008), that the erosion gullies

on that slope needed repair (inspection on April 14, 2008) and that tires were noted

amongst the waste (inspections on September 24, 2007 and June 26, 2008).

Repairs had been made

in response to the comments but then above conditions re­

occurred.

Jo)TK:litOt;,S(;l~d

~~

Waste Mgmt. Specialist/Env. Eng.

Ogle County Solid Waste Management Dept.

Subscribed and Sworn to Before Me

this \

c::;;.

Dayof~,.aOr:l:c.

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