                             Summary of Meetings 
                          With Escanaba Paper Company
                                       
Following the publication on August 6, 2012 of the notice of proposed rulemaking regarding Michigan's regional haze plan, EPA held two meetings with the Escanaba Paper Company:
      
August 27, 2012 call  
	Escanaba Paper attendees: Todd Schmidt, Dave Holland (consultant to Escanaba Paper)
	EPA attendees: Douglas Aburano, John Summerhays, 
	Michigan attendees: Bob Irvine, Asad Khan
   	Synopsis:  The primary topic of discussion was the form and magnitude of the limit for Boiler 8.  EPA had proposed a limit reflecting a weighted average (weighted according to fuel use) of a 0.26 pounds per million British Thermal Units (lb/MMBTU) for gas and 0.50 lb/MMBTU for oil.  Escanaba Paper requested a fixed limit irrespective of fuel used. and urged that this limit be between 0.35 and .040 lb/MMBTU, preferably 0.375 lb/MMBTU.

August 30, 2012 call
	Escanaba Paper attendees: Todd Schmidt, Dave Holland (consultant to Escanaba Paper)
	EPA attendees: Douglas Aburano, John Summerhays, 
	Michigan attendees: Bob Irvine, Asad Khan
   	Synopsis:  Again, the primary topic of discussion was the form and magnitude of the limit for Boiler 8.  EPA proposed to promulgate a fixed limit of 0.35 lb/MMBTU, and Escanaba Paper agreed.

November 2, 2012 call
	Escanaba Paper attendees: Todd Schmidt, Dave Holland (consultant to Escanaba Paper)
	EPA attendees: Douglas Aburano, John Summerhays, 
	Michigan attendees: Bob Irvine, Asad Khan
   	Synopsis:  EPA and Escanaba Paper discussed details of the codification of requirements for Escanaba Paper, discussing comments that Escanaba provided by email on November 1, 2012.  EPA committed to use the company's formal identity as Escanaba Paper Company where appropriate.  EPA committed to clarify that the statement in the notice of proposed rulemaking that it viewed the Boiler 9 limit as requiring overfire air did not mean that this particular compliance approach was mandated.  Escanaba Paper asked that the codification expressly allow alternative test methods for the Boiler 9 limit; EPA stated that the intent was for Escanaba Paper, in the context of demonstrating compliance, to have flexibility to use alternate test methods that could be shown to the regulatory agency to provide equivalent, adequate demonstration of compliance.  EPA indicated that this might be done by stating that Method 7 is the reference method.  Escanaba Paper sought a delayed compliance date, but EPA stated that it found no justification for delaying the compliance date for a limit that is already being met.
   

