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May 24, 2013

National Emission Standards for Storage Vessels, Equipment Leaks, and Closed Vent Systems

Revisions to the National Uniform Emission Standards General Provisions

The EPA is proposing National Uniform Emission Standards for Storage Vessels and Transfer Operations, Equipment Leaks and Control Devices, herein referred to as Uniform Standards. The EPA is also proposing supplemental revisions to the National Uniform Emission Standards General Provisions, which were proposed with the National Uniform Emission Standards for Heat Exchange Systems, signed by the EPA Administrator on November 30, 2011.

The proposed rules would establish a series of national uniform emission standards for storage vessels and transfer operations, equipment leaks and control devices. EPA expects, in future rulemaking actions, to propose that new source performance standards (NSPS) and national emission standards for hazardous air pollutants (NESHAP) for other source categories will also reference and require compliance with Uniform Standards, as appropriate, provided that the referencing subpart rulemakings demonstrate that the Uniform Standards meet the statutory stringency requirements that would apply to the referencing subpart source category, such as Clean Air Act (CAA) section 112(d), maximum achievable control technology (MACT), section 112(f), residual risk ample margin of safety (AMOS) and section 111(b), best systems of emission reduction (BSER).

© 2013 Andrews Kurth LLP

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Most recently, Paul consulted with the Mongolian national government and various other corporate and individual stakeholders, designing a citizen participation program. At the request of the country’s Secretaries of the Ministries of Environment and Mineral Resources, he has continued to coordinate the first-ever pilot project for Mongolia.

Paul also serves on the American Arbitration Association Panel for environmental, energy and natural resource matters.

He has substantial jury and bench trial experience in federal and state courts involving groundwater and surface...

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