Contributor: Alan L. Jirik, CHMM Business Title: Director of Environmental Affairs Contact Information: Corn Products International 6500 Archer Ave. Bedford Park, IL 60501 Phone: 708 563 6707 Fax: 708 563 6842 Email: Alan_Jirik@achmmchicago.org Affiliation: Corn Products International manufactures products serving a wide array of industries from foods and beverages to paper and building materials. The Company produces sweeteners for the soft drink, brewing and food industries, including dextrose and high fructose corn syrup. Corn Products is the world's leading producer of anhydrous dextrose used by the pharmaceutical industry for making intravenous solutions. The Company's starch products are used by the paper, textile, corrugating and food industries. Biography: Mr. Jirik's career in the field of air pollution control spans the period from before the initial adoption of the Amendments that created PSD in the late 1970's. He has been active in national issues including the NOx SIP call, and local issues involving the Chicago ozone attainment demonstration. On behalf of Corn Products, Mr. Jirik focuses on rule negotiation, policy and permitting issues. He gained his CHMM certification in the late 1980's, and is active in local trade groups including the Industrial Water Waste and Sewage Group (IWWSG) and the Illinois Environmental Regulatory Group (IERG). His undergraduate degree is in meteorology with a Masters Degree in Urban and Environmental Studies.

Title of Presentation: NSR Enforcement, Federally Permitted Release Reporting Author: Alan L. Jirik, CHMM Key Words: air pollution, New Source Review (NSR), Federally Permitted Releases (FPR), EPA policy, enforcement initiatives Abstract: Recent Federal Clean Air Act enforcement initiatives have heightened awareness of how policy interpretations affect enforcement, and the collateral issue of whether "changes" in policy should be subject to public notice or even full rule making procedures. Two recent initiatives highlight the enforcement/policy interpretation question: the NSR enforcement initiative launched with great fan fare against the utility industry, and a USEPA Region 7 initiative over what constitutes a "Federally Permitted Release". The paper will provide the background on these enforcement initiatives, review their current status, examine some of the policy issues they raise, and from a practical point of view, discuss how to deal with such issues from the perspective of managing compliance at manufacturing operations. Title of Presentation: The Chicago VOM Trading Program: First in the Nation Author: Alan L. Jirik, CHMM Key Words: air pollution, emissions trading, emissions reductions, ozone nonattainment, VOC, VOM, RACT Abstract: The Chicago area has been designated nonattainment for ozone since the first Clean Air Act. After nearly 20 years of enacting RACT rules, the prospect of achieving further reductions using command and control seemed daunting. Faced with the need to achieve significant additional VOM emission reductions, the IEPA chose an innovative approach: a cap and trade emission reduction system to reduce emissions 12%, with trading to minimize the cost of controls. The year 2000 marked the first year of implementation and operation of the ERMS system, and overall the system worked quite well. There were 35 trades involving 57 companies that traded 164.3 tons of VOM. The average price was $758 per ton, well below market estimates for traditional RACT. The paper will explain how the ERMS system works; the environmental protections that were built into the system, and examine the results of the first year of trading activities.