Memorandum

Subject:		Telephone conversation between Nathan Topham and Mark DeLaquil

Date:			December 23, 2013

Participants:	 	Nathan Topham, U.S. EPA
			Mark DeLaquil, legal counsel for Association of Battery Recyclers (ABR)

On December 23, 2013, a telephone conversation took place between Nathan Topham and Mark DeLaquil.  Mr. Topham and Mr. DeLaquil discussed two issues related to the direct final rulemaking that was signed on December 20, 2013.  

Mr. DeLaquil asked whether block averages or rolling averages should be used when processing data collected from differential pressure monitors. Mr. DeLaquil also asked about the effective date of the direct final rulemaking. Mr. DeLaquil wanted to know whether the EPA intended for the effective date to occur 60 days after promulgation of the direct final rule in the Federal Register, or whether the amendments would be effective immediately.  


