	
	Comments on Proposed Corrections
	O'Hare, Andrew 
	to:
	Keith Barnett
	10/21/2010 03:43 PM
	Show Details


Keith, 
 
Thank you for the opportunity to review the draft correction language.  My 
comments are reflected on the attached document as strike outs and inserts 
using "track changes."
 
I do not believe that the proposed changes would correct the clinker 
production monitoring issue I e-mailed you about last week.  I believe 
that Section 1350(d)(2) and Section 60.63(b)(2) (discussed below), need 
specific clarifications, as the rule language in both places state: 
"maintain a record... within 30 days of the effective date of this rule (for 
existing sources)." (75 Fed. Reg. 55059 and 75 Fed. Reg. 55035, 
respectively).  
 
The language in Section 60.63(b)(2) is potentially even more confusing, as 
the NSPS does not apply to existing (un-modified) sources.
 
Happy to discuss at your convenience.  
 
Regards,
Andy 
 
 
 
Andrew T. O'Hare, CAE
Vice President, Regulatory Affairs
Portland Cement Association
500 New Jersey, Avenue, NW
Washington, DC 20001
Phone: (202) 408-9494
Fax: (202) 408-0877
Cell: (202) 270-0094
e-mail: aohare@cement.org

