Attachment 1: 

May 19, 2011 Petition for Reconsideration 

Correspondence 


Attachment 2: 

Supplemental Information to the May 19, 2011 

Petition for Reconsideration 
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Supplement to Alyeska Pipeline Service Company Petition for 

Reconsideration 

July 14, 2011 

The following discussion supplements Alyeska’s May 19 petition to the Administrator. It is 

being provided in addition to a copy of that petition as information for EPA to incorporate into 

its evaluation that is associated with reconsideration notice as articulated in its federal register 

notice of March 21, 2011. 

In the final rule, EPA created the non-continental liquid fuel subcategory, but units located in 

Alaska were not included. API did raise this issue and make a request that Alaska be included in 

this subcategory. Alyeska is a member of API. In APSC’s letter dated May 19, 2011, we 

petitioned EPA for reconsideration of the decision to exclude Alaska in the definition of unit 

designed to burn liquid fuel that is a non-continental unit in 63.7575. 

 

Basis for Alyeska’s Request

 

As noted in the previous reconsideration correspondence referenced above, the characteristics of 

many boilers and process heaters in Alaska are identical to units located in the areas already 

classified by EPA as non-continental liquid, and are wholly consistent with the characteristics 

identified by commenters and summarized in EPA’s response to comments (76 FR 15635). We 

list those non-continental liquid characteristics below, and also provide relevant information 

specific to the State of Alaska and of our operations. 

 

1. Remote locations without access to natural gas. 

 

Attached is a map showing natural gas transmission lines (pipelines) in the Cook Inlet area of 

Alaska, which includes Anchorage, Alaska, the state’s largest city. The Cook Inlet area gas 

system is the closest to Valdez. The pipeline system extends to Palmer, Alaska, a small town 

which is approximately 30 miles north of Anchorage along the Glenn Hwy. Valdez is 

approximately 305 highway miles from Anchorage. The only other source of natural gas is on 

the North Slope which starts on the north side of the Brooks Mountain Range approximately 675 

miles north of Valdez. A partial map of Alaska is also attached for reference.

Only the above described small portion of Alaska has access to commercial or utility provided 

supplies of natural gas. Most areas of this vast and remote state are without commercially or 

utility provided natural gas, including many of Alaska’s largest cities, such as the state’s capitol, 

Juneau. This is a very unusual characteristic for a US state, but one shared with cities in the noncontinental areas already identified in the boiler rule. 

 

2. Remote facilities that cannot physically access natural gas pipelines, making burning liquid 

fuels unavoidable. 

 

The city of Valdez, including the Valdez Marine Terminal (VMT) is such a city and facility. 

The VMT is located within the city of Valdez, Alaska, but as noted above there is no natural gas 
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service in Valdez or the surrounding area. As a result, the city of Valdez and the VMT are 

forced to burn liquid fuel to meet electric power generation needs. 

3. Units at a facility are designed to burn gaseous fuel, but the gaseous fuel produced at the 

facility, as a product of VMT crude oil storage and crude oil tanker loading processes, is less 

than the energy required to generate power to operate the VMT. 

 

As part of the facility’s crude oil storage and marine loading operations, the VMT produces and 

captures crude oil hydrocarbon vapors for use as gaseous fuel for the production electricity from 

three onsite Alyeska owned and operated 242 MMBtu/hr steam boilers. These processes do not 

produce sufficient fuel to fully meet power needs. Therefore, the gaseous fuel must be 

complemented with distillate fuel. Because of the variability of gaseous fuel production, due to 

variability in crude oil storage volumes and tanker loading operation, the volume of vapors 

provided to the steam boilers varies, but on average the gaseous fuel presently provides 65% of 

the heat input to the boilers.

 

As discussed above, there is no natural gas pipeline delivery system in the Valdez area. More 

accurately the nearest natural gas system is in Anchorage and any pipeline route would be forced 

to closely approximate the highway system. This would involve costs and environmental impacts 

that are too significant to be overcome. 

 

In summary, Alyeska can find no reason why units in Alaska that co-fire gaseous and liquid fuel, 

and also lack access to natural gas pipelines, should be treated differently than other noncontinental units with the same characteristics. 

 

Suggested Subcategory Definition

 

To address the units located in Alaska discussed above, Alyeska suggests the following change 

to the definition of non-continental unit in 63.7575 (emphasis added): 

 

unit designed to burn liquid fuel that is a non-continental unit means an industrial, 

commercial, or institutional boiler or process heater designed to burn liquid fuel located 

in the State of Hawaii, the Virgin Islands, Guam, American Samoa, the Commonwealth 

of Puerto Rico, or the Northern Mariana Islands, and regions of the State of Alaska 

without economically available natural gas distribution systems or pipelines. 

 
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