
 From:
O'Hare, Andrew <AOhare@cement.org>
 To:
Keith Barnett/RTP/USEPA/US@EPA
 Date:
10/15/2010 09:37 AM
 Subject:
Another Compliance Deadline Issue



Keith, 
 
Another issues has been brought to my attention regarding the effective date/compliance date matter.  
 
This involves the requirements for clinker production monitoring requirements, specifically the provisions in Section 63.1350(d)(2).  The language in (d)(2), appears to require that these clinker monitoring systems need to be in place within 30 days of the effective date.  In PCA's comments on the proposal, we requested that the Agency clarify this matter and explain that it was 30 days after the COMPLIANCE date, not the effective date.  In the EPA response to comments document, excerpt below (page 215), the agency explains that the compliance date is 3 years from the date of promulgation in responding to the comment suggesting that the clinker monitoring requirement be implements 30 days after the COMPLIANCE date.  
 
Please let me know if you have any questions.  This matter also needs to be addressed in the clarification that you are presently preparing to address the compliance/effective date matter. 
 
Regards,
Andy 
 
 
 
Page 215, Comment Response Document


