From: "Schmidt, Todd" <Todd.Schmidt@newpagecorp.com>

To: John Summerhays/R5/USEPA/US@EPA,

Cc: "'dholland@all4inc.com'" <dholland@all4 inc.com>, Douglas Aburano/R5/USEPA/US@EPA, "'IRVINER@michigan.gov'" <IRVINER@michigan.gov>, "'khana@michigan.gov'" <khana@michigan.gov>

Date: 11/01/2012 12:52 PM Subject: RE: Tentative Codification of Escanaba Paper Requirements

John,

Please consider this our response to the tentative codification of Escanaba Paper Company requirements. I will

schedule a call time at 4 PM eastern time for us to walk through these comments.

First, all references to our operating facility should be “Escanaba Paper Company” (EPC). This is the legal entity

under which all of our permits and reporting obligations are referenced by.

Second, at 40 CFR 52.1183(i)(1), the phrase “(expressed as NO

2 )” is removed in the final rule version. EPC is

interested in knowing why U.S. EPA chose to remove the phrase.

Third, EPC would like to add a disclaimer to 40 CFR 52.1183(i)(6)(vi) that states “40 CFR 60.49b(g) is referenced for

convenience and does not imply that 40 CFR Part 60 Subpart Db applies to the No. 8 or 9 Boilers.”

Fourth, the test method for the No. 9 Boiler is listed as Method 7 at 40 CFR 52. 1183(i)(5). EPC requests a

non

‐ manual method be allowed and be reflected as “... Method 7E, Method 20 or other test method approved by

the Michigan Department of Environmental Quality, Air Quality Division” or other similar verbiage at the end of

condition 5.

Fifth, in previous communication, EPC requested confirmation there was not an implied requirement to operate the

OFA system on the No. 9 Boiler as was suggested in the preamble.

Sixth, EPC prefers that the BART requirements become applicable at the five year date following the FIP

promulgation and not upon the effective date of the rulemaking, or the State of Michigan be allowed to submit a

revised SIP incorporating these emission limits therein under a schedule of compliance deemed mutually acceptable

by both U.S. EPA and Michigan DEQ.

Regards,

Todd Schmidt

Mill Environmental Manager | Escanaba Paper Company: A NewPage Company

Escanaba, MI 49829 | W: 906.233.2929 | C: 906.281.6991 | todd

. schmidt @ newpagecorp

. com

This electronic message contains information from NewPage Corporation or subsidiary companies, which may be
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From: Summerhays.John@epamail.epa.gov [ mailto:Summerhays.John@epamail.epa.gov]

Sent: Thursday, November 01, 2012 12:13 PM

To: Schmidt, Todd

Cc: 'dholland@all4inc.com'; A burano.Douglas@epamail.epa.gov; 'IRVINER@michigan.gov';
'khana@michigan.gov' Subject: RE: Tentative Codification of Escanaba Paper Requirements I am supposed to have the notice to D.C. today. I was OK with you getting me comments by yesterday, but the window is rapidly closing even for making editorial or clarifying changes. Remember, we are under consent decree to sign this in two weeks. We can have a call tomorrow, at 10 or 11 or 2 or 4 EDT, but I'm not sure there's a point in having a call after that. In the meantime, please send me any comments you

have as soon as possible.Regarding compliance dates, BART must be implemented as expeditiously as practicable, which means immediately for limits that are already being met. That's what we did with the SO2 limit for St. Marys Cement that they are already meeting, and I'm not aware of any reason we wouldn't take the same approach for you.

From: "Schmidt, Todd" < Todd

. Schmidt @ newpagecorp

. com >

To: John Summerhays/R5/USEPA/US@EPA,

Cc: "'dholland@all4inc.com'" < dholland @ all 4 inc

. com >, Douglas Aburano/R5/USEPA/US@EPA, "'IRVINER@michigan.gov'" < IRVINER @ michigan

. gov >, "'khana@michigan.gov'" < khana @ michigan

. gov >

Date: 11/01/2012 07:59 AM Subject: RE: Tentative Codification of Escanaba Paper Requirements

John,

I have a few minor comments and/or suggested language changes (generally for clarity and to remove ambiguity).

There are also a couple more substantive items to discuss including dates of compliance.

I believe we should have a conference call to discuss within the next week or two. Generally, the afternoons of next
Monday and Tuesday work and all day on Friday. If you could propose a few dates and times, I will setup a call for

us.

Todd

Mill Environmental Manager | Escanaba Paper Company: A NewPage Company

Escanaba, MI 49829 | W: 906.233.2929 | C: 906.281.6991 | todd

. schmidt @ newpagecorp

. com

This electronic message contains information from NewPage Corporation or subsidiary companies, which may be
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recipient(s) named. If you are not an intended recipient, be aware that any review, disclosure, copying, distribution or
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From: Summerhays

. John @ epamail

. epa

. gov [ mailto : Summerhays

. John @ epamail

. epa

. gov ]

Sent: Wednesday, October 24, 2012 4:32 PM

To: Schmidt, Todd

Cc: 'dholland@all4inc.com'; A burano

. Douglas @ epamail

. epa

. gov ; 'IRVINER@michigan.gov';
Summerhays

. John @ epamail

. epa

. gov ; 'khana@michigan.gov' Subject: Re: Tentative Codification of Escanaba Paper Requirements

I didn't specify a timeframe, but the timeframe you suggest sounds good.

From: "Schmidt, Todd" < Todd

. Schmidt @ newpagecorp

. com >

To: John Summerhays/R5/USEPA/US@EPA,

Cc: "'dholland@all4inc.com'" < dholland @ all 4 inc

. com >, Douglas Aburano/R5/USEPA/US@EPA, "'IRVINER@michigan.gov'" < IRVINER @ michigan

. gov >, "'khana@michigan.gov'" < khana @ michigan

. gov >

Date: 10/23/2012 08:10 PM Subject: Re: Tentative Codification of Escanaba Paper Requirements

Thank you for communicating these tentative requirements. I will review and provide feedback by the end of

business next Wednesday, October 31st.

‐ Todd

Mill Environmental Manager | Escanaba Paper Company: A NewPage Company

Escanaba, MI 49829 | W: 906.233.2929 | C: 906.281.6991 | todd

. schmidt @ newpagecorp

. comThis electronic message contains information from NewPage Corporation or subsidiary companies, which may be
confidential, privileged or otherwise protected from disclosure. The information is intended to be used solely by the
recipient(s) named. If you are not an intended recipient, be aware that any review, disclosure, copying, distribution or
use of this transmission or its contents is prohibited. If you have received this transmission in error, please notify

N ewPage immediately a t postmaster @ newpagecorp

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From : Summerhays

. John @ epamail

. epa

. gov [ mailto : Summerhays

. John @ epamail

. epa

. gov ]

Sent : Tuesday, October 23, 2012 04:30 PM

To : Schmidt, Todd

Cc : Dan Holland < dholland @ A LL 4 INC

. COM >; A burano

. Douglas @ epamail

. epa

. gov <

A burano

. Douglas @ epamail

. epa

. gov >; Irvine, Robert (DEQ) < IRVINER @ michigan

. gov >;
khana @ michigan

. gov < khana @ michigan

. gov > Subject : Tentative Codification of Escanaba Paper Requirements

We have reviewed your comments and developed the attached draft codification of requirements for Escanaba Paper. In general, we are agreeing with the recommendations that Escanaba Paper has made, with one limited exception: With regard to stack tests that are not mandated by the state or by EPA, it is our standard practice not to require the company to report such tests or their results but to require that the company keep records of such tests. As I understand it, this information would primarily be of use if a mandated test showed noncompliance and EPA sought information regarding the duration of noncompliance.

Let us know if you would like to arrange a call to discuss this or any related issues.

Escanaba Paper Codification 10-22.docx