&EPA
United States
Environmental Protection
Agency
Region 10
1200 Sixth Avenue
Seattle WA 98101
EPA-10-AK-Valdez-NPDES-79
April 1980
EPA 910/9-79-064
Final
Environmental
Impact Statement
Alaska Petrochemical Company
Refining and Petrochemical Facility
Valdez, Alaska
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FINAL ENVIRONMENTAL IMPACT STATEMENT
Alaska Petrochemical Company
Refinery and Petrochemical Facility,
Valdez, Alaska
Prepared by
U.S. Environmental Protection Agency
Region 10
Cooperating Agency
U.S. Department of the Army, Corps of Engineers
With Technical Assistance from
CCC/HOK-DOWL
4040 B Street
Anchorage, Alaska 99503
Regional Administrator
April 25, 1980
Date
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U. S. ENVIRONMENTAL PROTECTION AGENCY
REGION X
A
1200 SIXTH AVENUE
o
T
UJ
SEATTLE, WASHINGTON 98101
April 25, 1980
REPLY TO
ATTN OF:
M/S 443
To All Interested Government Agencies, Public Officials, Public Groups
and Citizens
Pursuant to Section 102(2)(c) of the National Environmental Policy Act
of 1969 and implementing Federal Regulations, I am forwarding for your
review and comment this final Environmental Impact Statement (EIS) for
the Alaska Petrochemical Company's (Alpetco) Proposed Refinery and
Petrochemical Facility in Valdez, Alaska. Alpetco has applied for a
National Pollutant Discharge Elimination System (NPDES) permit to
discharge wastewater to navigable waters pursuant to the provisions of
the Clean Water Act and hence is subject to the provisions of the
National Environmental Policy Act (83 Stat. 852) under Section 511(c)(1)
of the Clean Water Act.
After a careful review of all comments received on the draft EIS, draft
permit, and other associated documents, EPA recommends issuance of the
NPDES permit with certain conditions. Mitigating measures resulting from
the EIS process have been incorporated into the final NPDES permit as
conditions of that permit. The final NPDES permit will be issued on
Friday April 25, 1980 and become effective on May 25, 1980 unless a
request for an evidentiary hearing (pursuant to 40 CFR 124.74) is granted.
The draft EIS has not been substantially revised as a result of the
comments received, therefore changes have been made to it by incorpora-
tion, additions or deletions as appropriate. This final EIS also contains
a summary of the project, discussion of issues raised during the review
period, response to individual comments and the final NPDES permit.
The Environmental Protection Agency will announce the availability of
this final EIS in the Federal Register on Friday April 25, 1980, initiating
a 30-day review and comment period. Comments on this final EIS and
EPA's recommended action are welcomed and should be submitted to the
Environmental Evaluation Branch, Mail Stop 443, at the above address.
ie at the close of the 30-day cormient period.
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TABLE OF CONTENTS
Page
SECTION I - SUMMARY
Executive Summary 1
SECTION II - ADDITIONS AND REVISIONS
Introduction 7
Index 8
Additions and Revisions 9
Mitigation Measures 45
SECTION III - COMMENTS AND RESPONSES - EIS
Introduction 59
Index . 60
Comments and Responses 61
SECTION IV - COMMENTS AND RESPONSES - PERMITS
Introduction 143
Index 144
Comments and Responses - NPDES 145
Introduction to NPDES Permit 157
NPDES Permit 160
State Certificate of Reasonable Assurance - NPDES 184
State Letter of Alaska Coastal Management Program
Consistency - NPDES 185
Introduction to PSD Considerations 186
Comments and Responses - PSD 187
PSD Preliminary Determination 188
PSD Technical Analysis 192
PSD Final Determination 226
PSD Permit 227
State Air Quality Permit to Operate 227
State Letter of Alaska Coastal Management Program
Consistency - PSD 248
Introduction to Sections 10 and 404 Permits 249
Comments and Responses - Sections 10 and 404 . 250
State Certificate of Reasonable Assurance - Section 10 .... 284
1' i i
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TABLE OF CONTENTS
Continued
Page
State Letter of Alaska Coastal Management Program
Consistency - Section 10 285
State Certificate of Reasonable Assurance - Section 404 . . . 287
State Letter of Alaska Coastal Management Program
Consistency - Section 404 288
SECTION V - PUBLIC HEARINGS
Introduction 291
Transcript of Hearing 292
Public Testimony 326
SECTION VI - LIST OF PREPARERS
List 329
Background on COE Personnel 334
SECTION VII - EIS DISTRIBUTION LIST
List of Recipients
Federal 335
State 337
Local 339
Interested Groups 339
iv
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TABLES OF CONTENTS
TO OTHER VOLUMES OF THIS
ENVIRONMENTAL IMPACT STATEMENT
DRAFT ENVIRONMENTAL IMPACT STATEMENT
Introduction
Purpose of the Proposed Project
The Proposed Project
Alternatives Including the Proposed Project
Existing Conditions
Environmental Consequences
Mitigation Measures
Summary of Permits and Regulatory Programs
Coordination
ATTACHMENT A
List of Preparers
Bibliography
Abbreviations
Glossary of Terms
ATTACHMENT B
Memorandum of Understanding
NPDES Permit Application and Draft Permit
PSD Permit Application Submittal Letter
COE Sections 10 and 404 Permit Applications
COE Public Hearing Notice
ATTACHMENT C
PSD Permit Application
APPENDIX VOLUME I
Geotechnical
Hydrology
Ecosystems
Oceanography
APPENDIX VOLUME II
Socio Economics
Refinery Processes
Archaeology
Acoustics
V
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The Anchorage Historical and Fine Arts Museum provided historical photographs of
the Valdez area which appear on the divider pages. Cooperation and assistance
of museum personnel are appreciated. Following are descriptions or captions for
the photographs.
Summary
Upper falls and canyon of Solomon Gulch
Additions and Revisions
Filling sacks to turn the Valdez Glacier Stream flood
Comments and Responses - EIS
Valdez Pier with Valdez Glacier in background, 1909
Comments and Responses - Permits
A trail barn
Public Hearings
The Thirtieth Infantry Band giving Valdez a concert
List of Preparers
A townsperson posing with Valdez's own pet bear in front of P.S. Hunt's
photography studio. Hunt is responsible for a great number of photographs
taken around Valdez in the early 1900s.
EIS Distribution List
The first horse sleighs to arrive in Valdez from Fairbanks, December 20,
1905
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SUMMARY
ENVIRONMENTAL IMPACT STATEMENT
New Source NPDES Permit for the
Alaska Petrochemical Company
Refinery and Petrochemical Facility, Valdez, Alaska
U. S. Environmental Protection Agency
Region 10
Seattle, Washington
( ) Draft Environmental Impact Statement
(X) Final Environmental Impact Statement
Type of Action:
(X) Administrative
( ) Legislative
Summary Description of Administrative Action:
The United States Environmental Protection Agency (EPA) has been considering the
issuance of a New Source National Pollution Discharge Elimination System (NPDES)
permit for wastewater discharge from the proposed Alaska Petrochemical Company
(Alpetco) Refinery and Petrochemical Complex in Valdez, Alaska. The issuance of
such a permit is a type of federal action which is subject to the National Envi-
ronmental Policy Act of 1969 (NEPA). Pursuant to NEPA and implementing regula-
tions issued by the Council on Environmental Quality (CEQ) and the EPA, an
Environmental Impact Statement (EIS) has been prepared to evaluate the potential
impacts of the proposed action on the environment.
EPA's NPDES regulations [40 CFR 122.47 (c) (2)] require that the EIS include a
recommendation on whether the NPDES permit is to be issued, denied, or issued
with conditions, and further, that such action shall occur only after a complete
evaluation of the projected impacts and of the recommendations contained in the
Final EIS. EPA recommends the issuance of an NPDES permit with conditions.
Conditions to the permit are discussed in Section IV. EPA's final decision will
be made following the close of the 30-day comment period on this Final EIS, to
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ensure that views and comments of interested parties and agencies accompany the
proposal through the agency's final decision-making process.
The 30-day review and comment period on this Final EIS begins when the Notice
appears in the Federal Register. This Notice announces the availability of the
Final EIS. The Notice in the Federal Register also initiates the 30-day period
during which requests for evidentiary hearings on the NPDES permit can be made
(pursuant to 40 CFR 124.74).
In addition, the U.S. Department of the Army Corps of Engineers, Alaska Dis-
trict, is exerting jurisdiction over this action under Section 10 of the River
and Harbor Act of 1899 which provides for control over structures or work in or
affecting navigable waters of the U.S.; and under Section 404 of the Clean Water
Act which provides for regulation of the discharge of dredged or fill material.
Action by the Corps of Engineers could be issuance of the permits, or issuance
of the permits with stipulations. The Corps intends to adopt this Final EIS to
fulfill its NEPA obligations if its concerns are satisfied in the final docu-
ment .
The Draft EIS became available on December 7, 1979. This Final EIS expands upon
or revises certain issues from the Draft EIS; however, this volume is not
intended to stand alone. Because few substantive changes to the draft document
have been noted, this Final EIS summarizes the proposed project and anticipated
impacts, and provides updated information in the form of revisions or additions
to specific portions of the DEIS. Data from the remainder of the Draft EIS are
necessary to make a complete evaluation of the proposed project. If Alpetco's
proposal receives all clearances to proceed to detailed design and construction,
EPA would still have the option of supplementing this EIS should the detailed
design phases reveal new information which would substantially alter the con-
clusions or recommendations of this document.
Summary Description of the Proposed Project
The Alaska Petrochemical Company (Alpetco) proposes to build a grassroots
(entirely new) refinery and petrochemical facility in Valdez, Alaska, to process
150 thousand barrels per day of Alaska North Slope crude oil into the maximum
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practicable quantity of refined products to supply the West Coast petroleum
fuels market. Royalty crude oil would be purchased from the State of Alaska
under an existing contract ratified by the Alaska legislature in June 1978.
It is estimated that the proposed project would require three years and $1.8
billion to construct. The plant would be fully operational in early 1984.
The proposed location is a 1,400-acre tract of land owned by the City of Valdez
which lies north of the Richardson Highway and adjacent to Valdez Glacier
Stream. Facilities there would include a process area, a tankage area contain-
ing about 77 tanks of various types, an industrial wastewater treatment facil-
ity, a power plant, an administration building and support facilities such as a
fire station and warehouses. A temporary construction camp to house 2,500
workers would be located in the northern portion of the plant site during con-
struction. Other facilities would include a products shipping dock near Solomon
Gulch on the south shore of Port Valdez, and a construction barge dock at an old
city dock location at the former Valdez townsite. A tract of land adjacent to
the barge dock would be leased as a staging area during construction.
Feedstock for the facility would be provided via a 20-inch pipeline connection
from the trans-Alaska pipeline to on-site storage. All product storage also
would be on site. Refined products would be carried in small-diameter pipelines
to the products dock.
Projected Impacts
Air pollutant concentrations would increase somewhat in the plant vicinity. EPA
has made a preliminary and final determination, however, that construction of
the Alpetco plant would not cause air quality deterioration beyond acceptable
limits if the best available control technology is employed in all process
units. Notice of the final determination was published in the Federal Register
1 April 1980. Also, an average of 7.4 million gallons per day of treated indus-
trial wastewater would be discharged into Port Valdez. It is expected that the
rotating biological contactors treatment unit, a proven technology, would pro-
duce a treated effluent which meets EPA refinery effluent standards and State of
Alaska receiving water standards.
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Shipping of refined products would add approximately 128 vessels per year to the
Port Valdez marine traffic. General marine cargo would be transported via the
Valdez city dock. The increased vessel traffic would be well within the capa-
bility of the existing Coast Guard Vessel Traffic System to provide navigational
assistance.
The available supply of permanent housing in Valdez would not be sufficient to
accommodate growth during the early years of refinery construction and opera-
tion. Positive economic impacts would affect employment, the proposed new city
dock and public revenues. Municipal services seem adequate to meet the result-
ing population growth. Valdez community support for the proposed facility is
strong.
Although in a seismically active area, the proposed site has no seismic con-
straints to construction of a safe facility assuming proper design and construc-
tion practices. The soils generally are well graded and have a low potential
for frost heave and would not be a construction problem. There is a sufficient
supply of groundwater to supply the refinery's needs without affecting the sur-
rounding area.
The National Marine Fisheries Service and U. S. Fish and Wildlife Service have
determined that there are no endangered species that would be threatened by the
proposed facility. Several salmon-spawning streams adjacent to the site would
have to be protected by design and operating procedures.
Other impacts from noise, odor, solid waste disposal and visual effects do not
appear significant.
The facility poses no known threat to any property listed in, or eligible for
inclusion in, the National Register of Historic places.
Alternatives Considered
The constraints of the Agreement for the Purchase and Sale of Alaska Royalty
Crude Oil between Alpetco and the State of Alaska require that the proposed
refinery be constructed within Alaska. The merits of 12 locations throughout
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Alaska were considered during final site selection. Valdez was selected as the
site for the proposed facility, primarily due to the community support received,
the proximity to the crude supply, the deep-water port, no evidence of insur-
mountable environmental problems, and an existing infrastructure to accommodate
anticipated growth.
From four alternative access routes on the south and west sides of the site the
existing Valdez Glacier Stream Haul Road is proposed as the primary access to
the facility. Section II contains a detailed discussion of several issues re-
lating to these alternatives. Solomon Gulch on the south shore of Port Valdez
was selected over Ammunition Island on the north shore and Allison Point adja-
cent to the Alyeska Marine Terminal as the site for a tanker dock for shipping
refinery products.
In order to best meet potential West Coast market demands and to minimize the
production of unmarketable residual heavy fuel oils, a slate of products is
planned consisting of about 52% unleaded gasoline, 20% jet fuel and 28% other
fuel and chemical products. More than one hundred variations of several process
schemes were evaluated to arrive at an ultimate process design. Coal, fuel oil
and by-product gas were considered as energy sources.
Opportunities For Comment
Comments from other agencies and private citizens have been solicited relative
to the proposed project, and consolidated public hearings have been conducted.
Copies of the Draft EIS and the Draft NPDES permit were on file for public
inspection beginning December 7, 1979, at EPA Region 10 headquarters in Seattle,
WA; the Alaska Operations Office of EPA in Anchorage; the City of Valdez public
library; and the City of Juneau public library. In addition, the Prevention of
Significant Deterioration (PSD) permit application, regarding air quality, has
been available since December 18, 1979, at the same three locations as well as
at the public library in Fairbanks. Also, the Corps of Engineers issued public
notices on October 19, 1979, regarding Sections 10 and 404 permit applications.
In an effort to review the entire project as a whole, consolidated public hear-
ings were conducted to receive comments on the Draft EIS and the four major
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federal permits, NPDES, PSD, Section 10 and Section 404. The comment periods on
the EIS and on the air and water quality prmits were extended to a common clo-
sure date of February 16, 1979, to assure that all issues were considered to-
gether. Public hearings were conducted in Anchorage on January 29, 1980; Valdez
on January 30, 1980; and Juneau on January 31, 1980. Records of those hearings
comprise Section V of this Final EIS.
Copies of this Final EIS are on file and available for public review at EPA
Region 10, Room 11D, 1200 Sixth Avenue, Seattle; Alaska Operations Office of
EPA, Room E535, 701 "C" Street, Anchorage; the Alaska District Corps of Engi-
neers, Regulatory Functions Branch, Building 21-700, Room 113, Elmendorf Air
Force Base; the Alaska Department of Environmental Conservation Office in
Juneau; and public libraries in Valdez, Juneau and Fairbanks.
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SECTION II
This section contains additions to and revisions of material contained in the
Draft EIS. These discussions are a result of comments received during the Draft
EIS review period. The discussions are presented in the order in which they
appeared in the Draft EIS. Each discussion begins a new page which bears a
heading that ties it to the draft document, k change in typestyle sudh as this
will indicate the material that has been revised or inserted. Where the entire
entry in this section is an addition or revision and no previous material is
repeated, the regular typestyle is used.
Discussions entitled "Additions" are intended to expand upon information con-
tained in the Draft EIS. Discussions entitled "Revisions" are intended to
replace the entire discussion which appears under the part or subpart noted in
the title. In the case of a discrepancy between material in this Final EIS
volume and information in the Draft EIS or a permit application which predates
the Final EIS, the material contained herein should be considered the most
recent and accurate information.
This section of additions and revisions includes a Mitigation Measure Summary.
Many of these measures were identified in the draft EIS Section 7.1. Alpetco is
committed to comply with these measures, and the measures are included as condi-
tions of the NPDES permit.
The following index lists all discussions which have been expanded upon or
revised in this FEIS.
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INDEX TO SECTION II
DEIS FEIS
Page No. Page No.
14 Revision of Section 3.3.4 - Pipelines 9
16 Revision of Figure 3.3-5 10
51 Revision of Section 3.8 - Spill Prevention & Control .... 11
86 Revision of Section 4.3.3 - Air Quality Standards
Compliance, Subsection BACT, Subpart FCCU 12
104 Revision of Section 4.3.8 - Alternate Transportation
Routes, Subsection Pipeline Routes 13
120 Revision of Section 5.2.2 - Groundwater, Subsections
Regional Conditions and Site Conditions 17
125 Revision of Section 5.3.3 - Physical Hydrology,
Subsection Circulation 20
Revision of Section 5.6.1 - Elements of the Ecosystem
141 Subsection Marine, Subpart Benthos 22
142 Subsection Marine, Subpart Marine Fish 24
143 Subsections Primary Production & Trophic Structure .... 25
149 Subsection Terrestrial Assemblages, Subpart Wetlands ... 27
163 Revision of Section 5.8.5 - Land Use, Subsection
Regional Land Use & Regional Development 29
187 Revision of Section 6.2.2 - Groundwater 31
192 Additions to Section 6.3.2 - Operation Effects, Subsections
Zone of Initial Dilution & Near-Field Circulation .... 34
202 Addition to Section 6.4.1 - Impacts of Wastewater
Discharge, Subsection General 36
209 Revision of Section 6.5.2 - Air Quality - Operation
Effects, Subsection Modeling Results 38 #
210 Revision of Table 6.5-1 41
212 Revision of Table 6.5-2 42
223 Revision of Section 6.8.1 - Ecosystems - Marine,
Subsection Operations Impacts, Subpart Normal Operations . 43
236 Revision of Section 6.8.4 - Wetlands 44
264 Revision of Section 7.1 - Mitigation Measures Summary ... 45
284 Addition to Section 9.4 Exhibits 50
1-179 Addition to Technical Appendix Vol. I Hydrology 51
A-12 Addition to Attachment A 57
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REVISION OF SECTION 3.3.4 PIPELINES
There would be 10 products pipelines and one crude supply line which
would be constructed in a combination of buried and above ground modes.
The crude supply line from the Alyeska Pipeline to the Dayville Road
and the entire pipeline bundle from the Richardson Highway in a west-
erly direction to the point of departure from Dayville Road would be a
buried configuration. The remaining sections of pipeline from the pro-
posed plant site to the Richardson Highway and from the point of depar-
ture from Dayville Road to the products dock would be constructed above
ground on a two-level structure (see Figure 3.3-5 Revised). Approxi-
mately half of the length of the pipeline would be constructed in a
buried mode and the remaining half in the elevated configuration.
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TYPICAL PIPELINE CONFIGURATIONS (REVISED) Figure 3.3-5
10
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REVISION OF SECTION 3.8
SPILL PREVENTION AND CONTROL
3.8 SPILL PREVENTION AND CONTROL
Prevention of spills of oil and related petroleum products is one of
the prime objectives both in the design and the operation of the pro-
posed facility and includes but would not be limited to: siting and
design criteria for all facilities; operating procedures and their pe-
riodic review; inspection and monitoring of facilities; personnel
training; revision of operating procedures (where required); and rede-
sign of facilities (if necessary).
Among specific design parameters are: impervious containment dikes
around all tankage (feedstock and product) with a capacity to contain
the stored material plus storm water or sncwmelt; containment of storm
water from the process area(s); ability to treat contaminated storm
water in the wastewater treatment facility; leak-detection systems
capable of detecting small volume or slow rates of leakage for the
pipeline system; and appropriate use of valves to minimize potential
spill volumes particularly at stream crossings.
(At this point the text resumes as it appears on DEIS p. 51.)
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REVISION OF SECTION 4.3.3
AIR QUALITY STANDARDS COMPLIANCE
SUBSECTION - BEST AVAILABLE CONTROL TECHNOLOGY
SUBPART - FCCU
FCCU: As discussed in Section II, p. 38, the PSD permit preliminary
determination made one alteration to the originally proposed best
available control technology. The standard determined to be BACT will
require a 95 percent removal of SO2 from the FCCU tail gas. This level
of SO^ removal cannot be accomplished utilizing the proposed equipment
for this particular process unit alone, even in conjunction with hydro-
treating the feedstock. The company must determine how it expects to
achieve this level of control; however it need not make that determin-
ation at this time. The company must, however, remain within the total
emissions levels specified by the permit regardless of the technology
chosen. There are options available to Alpetco to achieve the emis-
sions levels, including changing their process design to eliminate the
FCCU and the use of additional control technologies on the FCCU. In
the latter instance, such control could include a flue gas scrubbing
system. EPA believes that if Alpetco chooses to add controls to the
FCCU, then the most likely control able to achieve 95 percent removal
is a wet scrubber system. A wet scrubber system also would provide
particulate removal which would be at least equivalent to the degree of
control achieved with an electrostatic precipitator, and thus eliminate
the need to install a redundant control device. It is expected that
the FCCU feed hydrotreater would remain in the system. A brief discus-
sion of the wastewater impacts from a wet scrubber system are included
in Section II, p. 36.
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REVISION OF SECTION 4.3.8
ALTERNATE TRANSPORTATION ROUTES RELATIVE TO THE SITE,
SUBSECTION - PIPELINE ROUTES
Pipeline routes: From the intersection of the Richardson Highway and
Dayville Road there are two alternative routes to enter the site with
the crude and products pipelines. The preferred route begins directly
north of the intersection and continues northward to the site. The
alternate route is parallel to and south of the Richardson Highway from
its intersection with Dayville Road, continuing northwesterly to an
existing levee along Valdez Glacier Stream, then along vehicular route
#2 to the proposed site (see Figure 3.3-1, DEIS p. 10). (Note: The
above paragraph is repeated from DEIS p. 104. The remainder of this
discussion is a revision of the previous material, but because of its
length, the script type is not used.)
The preferred route as proposed is located within a 290 m (950 ft) wide
corridor immediately adjacent to the southeast boundary of Robe River
residential subdivision and a 122 m (400 ft) wide corridor from there
to the site. The access road adjoining this pipeline route would be
restricted from the general public and the lines therefore would be
accessible just to company officials. Adjacent to the subdivision, the
pipelines and a service road would be placed as far toward the east
side of the wider corridor as possible, to provide a buffer between the
corridor and the subdivision. This route crosses two anadromous fish
streams, Robe River and Corbin Creek (Robe), as well as two streams
which do not bear spawning fish, Corbin Creek (Glacier) and an unnamed
tributary to the area drainage system. Approximately 1,554 m (5,100
ft) of the total 3,353 m (11,000 ft) length would cross wetland areas.
The remainder of the route contains suitable soils and avoids marsh
and other wetland areas.
The alternative pipeline route, which is approximately one mile longer
than the preferred route, is located adjacent to the south side of the
Richardson Highway right-of-way. Due to aesthetic, security and pro-
perty access reasons the segments of the pipeline along the highway
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would be constructed in a buried mode. The alternative route could not
be proposed within the right-of-way on either side of the Richardson
Highway, because the Copper Valley Electric Association (CVEA) has
secured right-of-way on the south side to install a new transmission
line; and an existing power line occupies right-of-way on the northern
side. The alternate route would involve crossing approximately 2,800
lineal feet of undeveloped private property on the south side of the
highway. The alternate route also would require three crossings of
Robe River due to the meandering of the channel immediately west of
Dayville Road, and a crossing of Corbin Creek (Glacier). Robe River is
an anadromous fish stream and part of the Robe Lake Drainage System.
This route enters the plant site at the southwest corner, which is less
compatible with the preferred site layout than an entrance into the
southcentral part of the site. Approximately 1,981 m (6,500 ft) of the
total 4,877 m (16,000-ft) length of the alternate route would be across
wetlands.
The relative geophysical risks of the two routes also were considered.
The preferred route has undergone no known damage or identifiable phys-
ical alterations as a result of the Great Alaskan Earthquake of 1964.
The alternate route showed severe responses to the 1964 seismic event.
Following the earthquake, the largest individual logitudinal fissure
segments observed occurred near the alternate pipeline route (USGS
Professional Paper 542-C). The evidence indicates that a pipeline sys-
tem constructed in this area would be much more vulnerable to damage
from a future seismic event than would the preferred route.
Although the crude supply line would be in continuous operation, the
products lines would remain empty when products were not being trans-
ferred to the dock. A typical tanker loading scenario would be one in
which two or more cargos are loaded simultaneously. Using two simul-
taneous cargos as the worst case, and using average tanker size and
loading rate data, there would be flow in some part of the product
pipeline system 16 percent of the time. As more simultaneous loadings
occur, that percentage drops. The possibility of a seismic event
occurring at a time when the products pipeline system is charged there-
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fore becomes more remote. The risks of a spill due to gunshot or other
accidental damage or vandalism to a line likewise becomes very remote
considering that the 16 percent figure assumes only two of the 10 lines
are in operation. With shut-off valves at stream crossings, leak
detection systems, and other construction and design stipulations to be
imposed by the State of Alaska, the risk of a spill becomes very small.
The preferred route was determined to be the alternative that would
have the highest operational integrity and lowest risks of a spill.
The preferred pipeline route does cross an area that is more sensitive
environmentally than does the alternate route. However, the overall
line length is a mile shorter, and several measures would be adopted to
mitigate potential threats to the Robe Lake Drainage System and the
salmon fishery it supports. In response to various comments on the
DEIS and discussions with the Alaska Department of Fish and Game, the
proposed pipeline design configuration has been changed in this area
from buried to an above-ground mode (see FEIS Section II, p. 9). The
elevated configuration would minimize the possibility of long-term
undetected leaks into the groundwater and surface water systems. It
also would allow frequent visual surveillance of the integrity of the
pipelines and more rapid response and attention to maintenance require-
ments than would the buried mode. To further assure that all prudent
precautionary measures are taken to ensure the integrity of the pipe-
lines through the Robe Lake Drainage System, the Alaska Department of
Fish and Game will require that the following package of design and
construction stipulations for the pipeline system be made conditions of
the State of Alaska right-of-way lease for the area in which the lines
would be constructed: The pipelines shall be above ground throughout
the Corbin Creek (Robe) drainage with shut-off valves at the Corbin
Creek and Robe River crossings; the pipelines shall be elevated across
Corbin Creek (Robe) and Robe River; the access road shall be used only
for pipeline maintenance and inspection purposes once the facility is
complete; and Alpetco shall establish a coho salmon run of value equal
to the Corbin Creek (Robe) run, in conjunction with activities of the
Alaska Department of Fish and Game and/or Valdez Fisheries Development
Association, within 36 months of plant start-up.
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Certain economic considerations and the probability of obtaining clear
right-of-way also were compared. The initial construction cost for the
additional mile of pipelines necessary for the alternate route would be
approximately $2 million; but particularly important would be the
additional costs, added risks, and other factors involved with main-
taining and operating the additional length of pipelines. Right-of-way
across 853 m (2,800 lineal ft) of private property might be difficult
to obtain for the alternate route and may require exercising eminent
domain proceedings which particularly from a public relations stand-
point would be highly undesirable, whereas the preferred route likely
would have clear right-of-way through the lease of state land. A com-
parison of some of these factors for the two routes appears in Table
4.3-6.
Table 4.3-6
COMPARISON OF ALTERNATE PIPELINE ROUTES
CRITERIA
Total route length
Lineal ft. of route across
wetlands
Total number of stream
crossings
Number of anadromous
fish stream crossings
Lineal ft. of route across
private property
ROUTE 1
11,000 ft.
5,100
2
0
ROUTE 2
16,000 ft.
6,500
3
2,800
In addition to the two routes discussed above, the U. S. Department of
the Interior Fish and Wildlife Service has suggested a third alternate
route in its comments to the Corps of Engineers on the Section 404 per-
mit. A discussion of the suggested route is in Section IV, p. 272-281.
16
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REVISION OF SECTION 5.2.2 GROUNDWATER
SUBSECTIONS - REGIONAL GROUNDWATER CONDITIONS
SITE GROUNDWATER CONDITIONS
5.2.2 Groundwater
Regional groundwater conditions; The developable areas of the Valdez
region are located in the larger valleys which have been carved by re-
cent glacial action. The floors of these valleys are formed predomi-
nantly of very permeable sands and gravels, deposited by the glacial
outwash streams. These permeable deposits compose the aquifers invest-
igated for the proposed project. Recharge to the aquifers comes from
the streams which flow through the valleys, as well as from the high
amount of direct rainfall occurring during the summer months. During
winter, many of the streams dry up as glacial melt and rainfall cease.
Thus, recharge to the aquifers occurs primarily during summer months.
The water table elevation declines during winter months due to the
reduction of recharge, even where no man-made withdrawals are made.
Due to the low density of Valdez population and the absence of signifi-
cant water-using industry in the region, very little use is being made
of the existing groundwater resources. The nearest residential wells
are 3.6 km (2% mi) south of the proposed refinery production wells.
The only sizable uses include that of the Valdez municipal water supply
wells, which withdraw a quantity estimated to be less than 3,785,000
liters per day (lpd) (1 million gallons per day [mgd]), and two inter-
mittently used industrial wells located in gravel pits approximately
1.6-2.4 km (1-1.5 mi) northwest of the site. Due to the high rates of
runoff and recharge experienced during summer months, it appears that
very substantial quantities of Water could be withdrawn before a sig-
nificant lowering of the water table would result.
Site groundwater conditions: The site is underlain by two major aqui-
fer systems: an upper aquifer, and a lower aquifer. The upper aquifer
is highly permeable. Test pumping at rates approaching 7,600 liters
17
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per minute (1pm) (2,000 gpra) for 72 hours was not sufficient to cause
measurable drawdown of the water table in observation wells 150 m (500
ft) from the pumped well. An observation well 15 m (50 ft) from the
pumped well showed 1.2 m (4 ft) of drawdown during the test. The
static water level (level of standing water in wells drilled into this
aquifer) was found to vary from more than 18 m (60 ft) deep near the
northern edge of the site, to the ground surface near the southern
edge.
The upper aquifer appears to be the winter water source of Corbin Creek
(Robe) and Brownie Creek, the streams which originate near the southern
edge of the site. Investigations during the spring of 1979 noted that
upper reaches of the Valdez Glacier Stream bed were dry, as were beds
of other streams that traverse the proposed site; but open water was
appearing in lower reaches of the Valdez Glacier Stream bed slightly
upstream of the Richardson Highway bridge. The only known winter
stream recharge to this aquifer in the vicinity of the site is a flow
of approximately 0.14 cms (5 cfs) which enters at the eastern edge of
the site via the Corbin Creek (Glacier) channel and promptly permeates
the porous material of that streambed. In addition, some snowmelt and
winter rains are believed to enter the soil directly with little or no
runoff. Due to the highly seasonal nature of the groundwater recharge
and the slope of the groundwater table, the water table elevation
fluctuates rather widely over the year. Groundwater level data
recorded during 1979 and 1980 verifies this fluctuation. The decline
of water levels between August 1979 and March 1980 ranges from 8 m (27
ft) in the northwest part of the site, to .24 m (0.8 ft) near the head-
waters of Corbin Creek (Robe). It is expected that the level would
continue to drop for another two months, until significant recharge
begins.
The lower aquifer seems to be separated from the water table aquifer by
a layer of silty sand/sandy silt which varies in thickness from 10 -
112 feet. There is abundant water in the upper aquifer, and existing
wells drilled in this region of the valley probably have penetrated
only the upper aquifer. The static level of the lower aquifer lies
18
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much flatter than that of the upper formation, and in fact has about
2.7 m (9 ft) of artesian head near the southern boundary of the site.
A 24-hour pump test at 1,250 1pm (330 gpm) was performed in a 15-cra
(6-in) well drilled into the formation near the north edge of the site.
The well drawdown recovery data indicated that, although of good perme-
ability, the formation apparently has little if any recharge within the
vicinity of the project site. Drawdown of the lower aquifer was noted
over most of the site, but no detectable drawdown occurred in the upper
formation. These factors indicate that the two aquifers are quite
thoroughly separated throughout the site and perhaps throughout most of
the valley. However, water level data recorded during the winter of
1979-1980 showed the decline of the static water level in the lower
formation has matched almost precisely the decline of the upper
aquifer. This correlation could be coincidental, but also suggests
that some form of low-capacity interconnection could exist in the
vicinity of the site.
Logs of the wells and test holes and other field data appear in Appen-
dix Vol. I. FEIS Section II, p. 51, is an Addition to Appendix Vol. I
which presents results of the 1979-1980 winter hydrologic monitoring
program.
19
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REVISION OF SECTION 5.3.3
PHYSICAL HYDROLOGY
SUBSECTION CIRCULATION
Circulation: Circulation patterns in the eastern end of Port Valdez
are summarized based on continuous recording current measurements in
the eastern port area (taken from May through July 1979) and the rela-
tion of these measurements to concurrent measurements taken at Valdez
Narrows. Flows are east-west due to tidal currents except at the far
eastern end, where flows turn north-south, parallel to the shoreline at
the eastern port boundary. Two layers exist which flow opposite each
other; the layer interface Is approximately 20-50 m (66-164 ft) deep.
Data from both this summer's study and earlier studies in the vicinity
of Jackson Point indicate currents at depths greater than 15 m (50 ft)
are generally low, 0.015 meters per second (m/s) (.05 ft/sec), which is
at or below the limit of detection of the current meters.
Significant flow events at Valdez Narrows were found to affect current
direction changes at the eastern end of the port near the proposed dis-
charge. These events cause either northerly (counterclockwise) or
southerly (clockwise) circulation patterns parallel to the eastern port
boundary, with layers flowing opposite to each other. For example, a
large flow event occurred at Valdez Narrows on May 18-20, 1979. In the
eastern port area, the upper layer direction changed from southerly to
northerly, with the reverse occurring in the lower layer.
Similarly, low flows at Valdez Narrows are associated with low velo-
cities in the eastern end of the port. For example, a "quiet" period
occured from about June 17 to about July 15, 1979. During this period,
currents were at or below the threshold value (lowest recordable value)
of the current meters. Such periods could normally be expected to
occur for one to two months each year during the summer under strat-
ified conditions and when storm-driven circulation is at a minimum.
There are a limited amount of oceanographic data available which pre-
cisely define flow events and circulation characteristics during that
20
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period because the velocities are below the detection limits of the
current meters.
21
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REVISION TO SECTION 5.6.1 TERRESTRIAL ASSEMBLAGES
SUBSECTION MARINE, SUBPART BENTHOS
Benthos: The major benthic habitats within Port Valdez are clas-
sified as: (1) intertidal and subtidal rock, (2) intertidal mud and
sand flats, (3) subtidal mud slopes, and (4) deep sedimentary basin.
Rocky shore and a narrow subtidal shelf line much of the western half
of Port Valdez. In the east, this habitat is reduced to small patches
of rocky substrate. A broad and steep sloping incline from the basin
floor culminates in intertidal mud and sand flats, stream deltas, and
marsh lands.
The intertidal rocky habitat supports a typical temperate community of
low diversity. Brown and red algae, blue mussels, barnacles, and
snails are the visually dominant species. Many of these species
exhibit seasonal and spatial patterns of variation in population den-
sity. Barnacle densities vary throughout the fjord, probably as a
result of sediment deposition patterns, rook texture, wave action, and
intensity of predabion. Red algae, sea stars, and sea urchins
increase in abundance toward the west, where there is less variation in
salinity. Seasonal variations in density stem from activity and repro-
ductive cycles stimulated by annual changes in temperature and photo-
period (day-length) as well as differential mortality rates.
The rocky subtidal habitat, which is confined mainly to submerged
extensions of intertidal areas, has not been extensively studied.
Species typically found in more temperate waters have been recorded in
Port Valdez. In areas where kelp are present, they visually dominate
with seasonal averages ranging from 15 to 55 percent cover (Dome and
Moore, 197?). Invertebrate fauna in the rocky subtidal includes sea
anemones, bryozoans, and sun stars. Resident or transient fish Buch as
greenling, tomcod, sculpins, and ronquils are common to this community.
The intertidal and mud and sand flats of Port Valdez, though visually
less heterogenous than rocky intertidal areas, support many species of
polychaetes (annelid worms), crustaceans, and bivalve molluscs.
22
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Animals which depend on organic materials at the water/sand interface
or in the sediments, such as worms and crustaceans, dominate in the
eastern portion of Port Valdez.
The assemblage of the mud slope is distinct from that of the intertidal
shelf, but grades into the deep sedimentary basin assemblage. The
dominant organisms in all three habitats are bivalve molluscs and poly-
chaetes. The mud slope also is used by tanner crabs for foraging and
mating, and the abundance of very young individuals indicates that this
habitat may be a nursery area. Tanner crabs are exploited commercially
in Prince William Sound, but the local population will not support a
fishery within Port Valdez. Dungeness crab also are present and sup-
port a significant recreational fishery. A detailed description of the
habitat can be found in the Appendix Vol. I.
(At this point the text resumes as it appears on DEIS p. 141.)
23
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REVISION OF SECTION 5.6.1
SUBSECTION MARINE
SUBPART MARINE FISH
Marine fish: Fishes inhabitating the deepwater region of Port
Valdez are poorly known. The limited data suggest that demersal fishes
such a yellowfin sole, flathead sole, sculpins, tomcod, and pollock are
moderately abundant (Smith and Stoker, 1969). Other fish occasionally
caught by fishermen include lingcod, greenling, and halibut (Alyeska,
1977). Starry flounder may constitute the most common fish found in
the intertidal. Other species that migrate into Port Valdez include
red, silver, pink, chinook, and chum salmon and Pacific herring.
Revving spawn on aquatic-vegetation around the perimeter of Port
Valdez. The important salmon species play a significant role within
the marine system prior to spawning in adjacent tributary streams.
Salmon are discussed in greater detail within the freshwater subsection
of Section 5.6.1 and in Section 5.6.4.
24
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REVISION OF SECTION 5.6.1
SUBSECTIONS PRIMARY PRODUCTIVITY AND TROPHIC STRUCTURE
Primary production: Rates of net primary production within portions of
Port Valdez have been reported to be impressively high (Eedburn, 1976).
However the relationship of open-water phytoplankton production in Port
Valdez to near-shore marine systems in Valdez Arm or Prince William
Sound is uncertain. Recent Studies (Alexander, 1979) suggest that
average primary productivity within open-water areas of the eastern
port is relatively low during late summer and fall. On the other hand,
primary production from attached plants within discrete areas along the
margin of Port Valdez may be quite high (e.g.., salt marshes and pro-
tected bays). Mudflat assemblages appear to depend primarily on plant
material from marsh grasses and phytoplankton. Such assemblages also
depend to a lesser degree on local benthic algae and seagrass. This is
a consequence of the bathymetry, salinity, turbidity, and substrate of
Port Valdez, which impose specific developmental limitations on marine
plant resources and restrict them primarily to the western end of the
port.
Trophic structure: Seasonally low levels of primary productivity
within the open-water limit the energy flow through the ecosystem.
Organic matter originating from the margin of Port Valdez probably is
important in maintaining the overall productivity of the ecosystem.
Phytoplankton, benthic diatoms, algae, sea grasses, and marsh and ter-
restrial plants all contribute to the supply of organic energy at the
base of the food web.
Energy pathways in Port Valdez are divided into two primary systems,
linked only at their terminal points. Both rely primarily on the con-
sumption of plant material. The pelagic system depends mainly on the
primary consumption of living plant material to transfer organic energy
from plant to animal tissues, as is the case in classic terrestrial
food webs. In sharp contrast, in the benthic system most of the plant
material is converted to organic debris, or detritus, by physical
25
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action and/or microbial degradation. Detritus then is ingested by both
suspension feeders and deposit feeders primarily for the colonizing
bacteria, which constitute a nitrogen-rich diet. The detritus is sub-
sequently egested, usually having been ground into smaller particles.
In a few days, following bacterial recolonization, the particles may be
reingested to begin the cycle anew.
Predators on primary consumers in the shallow benthic system include
starry flounders, sea ducks, dabbling ducks, geese, shoreblrds, sea
stars and marine snails. Shorebirds and salmon fry prey on harpact-
icoid copepods. Starry flounder and sea ducks feed extensively on the
intertidal clams and crustaceans. Starry flounder subsequently are
eaten by seals and sea lions, and salmon fry are the prey of fish and
diving marine birds. Few members of this group are strict residents of
the fjord. Thus, it appeats that much of the energy transformed by
consumers in the shallow habitats ultimately is transported to other
systems, sometimes quite far removed from Port Valdez.
(At this point the text resumes as it appears on DEIS p.145.)
26
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REVISION OF SECTION 5.6.1
SUBSECTION - TERRESTRIAL ASSEMBLAGES
SUBPART - WETLANDS
Wetlands: The Corps of Engineers (COE) describes wetlands as "those
areas that are inundated or saturated by surface or ground water at a
frequency and duration sufficient to support and that under normal cir-
cumstances do support, a prevalence of vegetation typically adapted for
life in saturated soil conditions" (Federal Register Vol. 42, #138,
Tuesday, 19 July 1977). The proposed project site, being located con-
tiguous to various streams, marshes and headwaters, does contain wet-
land areas that meet the above description. The wetlands affected by
this project are categorized in three groups. The first is saltwater
marshes, which are those shoreline areas in the intertidal zone and
tidally influenced areas. Second are the freshwater marshes, which are
those upland marsh areas not directly contiguous to or associated with
streams or creeks. And third are the watercourse wetlands, which are
those areas immediately adjacent to streams and creeks which are sus-
ceptible to inundation due to seasonal flooding. Among the eastern
Port Valdez wetlands, the saltwater marshes probably have the greatest
relative value. They are extraordinary natural systems in which tidal
energy circulates nutrients and feeds shoreline organisms. Grasses
thrive in the tidal marshes, supplying nutrients to the system and pro-
viding a waterfowl habitat. The freshwater marshes and watercourse
wetlands directly affected by this project function primarily as
sources of groundwater recharge and as links in the food chain.
Detritus is carried through the marsh and is consumed by microorganisms
and in turn by larger animals.
Delineation of the wetlands was based on COE criteria. Seasonally
flooded land, all permanently flooded land, lands of saturated soil,
intertidal lands and lands currently supporting hydrophytic species
were included. In areas of high surface water infiltration rates and
high groundwater percolation rates, the distribution of certain plant
species was used only as a general guide. Wetland limits in these
27
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cases were defined by the flood debris line, the silt line, or an
estimate of the one- to two-year flood recurrence elevation. For
purposes of estimating the acreages for watercourse wetlands, the
limits were assumed to be 50 feet on each side of a stream or Greek
aenterline. In areas of braided stream channels, the outer limits of
the channel pattern were used. Valdez Glacier Stream, Slater Creek,
Corbin Creek (Glacier), Corbin Creek (Robe), Robe River, Lowe River,
Abercrombie Creek and unnamed tributaries attendant to these systems
have wetlands which are delineated as mentioned above. DEIS Figure
5.6-1 shows the wetland areas relevant to the proposed project.
28
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REVISION OF SECTION 5.8.5 LAND USE
SUBSECTION - REGIONAL LAND USE AND RESOURCE DEVELOPMENT
5.8.5 Land Use
The purpose of this section is to examine land use and development pat-
terns in the region and in Valdez, with an emphasis on long-term
changes and emerging patterns of land use in Valdez. This section also
describes scenic and recreation resources in the region.
Regional land use and resource development: With the exception of iso-
lated communities, most of the area around Valdez is wilderness (see
Figure 3.2-1). Southwest of the city is the Chugach National Forest.
To the north and east are mountains and glaciers of the Chugach Moun-
tains, much of which has been selected for ownership by Ahtna Regional
Native Corporation. Widely separated communities in the area include
Cordova, 72 km (45 mi) southwest, the native village of Tatitlek, 37 km
(23 mi) south, and Glennallen, 160 km (100 mi) north of Valdez. A
fisheries-related economy supports most residents of towns in Prince
William Sound, with secondary support coming from government, tourism,
private services, timber and mineral development - not necessarily in
that order. Most employment in Valdez is derived from government and
the transportation industry (which includes the Alyeska Pipeline Ser-
vice Company). Because of its isolation from other towns in the region
and its ties to state government, Valdez influences and is influenced
more by its connections to cities outside of the region, than by any
activities within the region.
With respect to resource development feasibility in remote areas, prox-
imity to a nearby community is not normally an important factor. Al-
though there might be significant timber and mineral resources in the
area, the actual presence or scarcity of a resource is less important
than are other variables. Available export markets, restrictions on
land ownership and use, climatic conditions, and transportation prob-
lems all affect the feasibility and timing of resource development.
29
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Valdez, for example, hopes to overcome some of these limitiations by
construction of new port facilities for export of agricultural products
and timber which could be trucked over the Richardson Highway from in-
land locations.
Analyses which consider all of these factors, however, indicate little
potential for significant new resource development in the region during
the assumed 1990 impact horizon of the proposed Alpetco facility. The
Alaska Department of Natural Resources estimates that most coastal tim-
ber and mineral resources will not be developed for at least 25 years
in Prince William Sound (Alaska Department of Transportation and Public
Facilities [ADOTPF]). Isolated mineral claims north of Valdez are
mostly inactive, and areas of highest mineral development potential are
in the Wrangell Mountains, 160 km (100 mi) to the northeast (ADEC,
Division of Water Programs, 1978). Timber development potential, with
the exception of approximately 40 hectares (100 acres) southeast of
Port Valdez is rated low (ADOTPF, Oct. 1978).
With respect to fisheries, the Valdez Fisheries Development Association
has begun implementing plans to increase pink and chum salmon stock for
commercial fishery enhancement with the opening of a hatchery at City
Limits Creek. The group has plans for a similar facility at Solomon
Gulch, and also is pursuing a hatchery for king and silver salmon to
enhance the sport fishery.
Although some resource development is possible (e.g., timber and min-
eral development on regional and village-selected lands near Tatitlek,
or construction of more fish hatcheries to increase both commercial and
recreational yields of salmon), it is not expected to significantly
impact settlement patterns in Valdez or in other communities in the
region.
30
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REVISION OF SECTION 6.2.2
GROUNDWATER
6.2.2 Groundwater
Short-term effects: The effects of construction of the proposed facil-
ity on the groundwater resources of the area would fall into two main
categories: effects on water table, and effects on recharge. Initial
estimates of construction water usage average less than 154 thousand
gpd for full-scale concrete pouring operations for approximately two
years of construction, and up to 4 million gpd for the maximum expected
hydrotesting requirements. Since most construction activities would
occur during the summer high-recharge period, and are of a short-term
nature, this level of water usage should not significantly affect the
upper aquifer.
The high permeability of the surface materials makes it imperative that
spills of construction fuels or toxic substances be prevented. The
groundwater would be very susceptible to contamination.
Long-term effects: Two 12-inch diameter production wells each with
approximately 1,400 gpm capacity are proposed for operation of the
refinery. It is anticipated that the proposed withdrawal of approxi-
mately 1.7 mgd of water from the upper aquifer would have little impact
upon the quality and the available quantity of water from that aquifer.
The greatest impact on the water table likely would be a slight
increase in the fluctuation of elevation which normally occurs during
winter months when recharge is at its annual minimum. Data indicate
that this lowering would not exceed 2.5 ft. near the headwaters of
Corbin Creek (Robe) over a six-month period of pumpage during which no
significant recharge occurs. Drawdown in the site area due to pwnpage
of the design rates would produce an increase of 25 percent or less in
the groundwater level fluctuation which normally occurs over the course
of a year. Barring any major spills of hydrocarbons or toxic sub-
stances, the quality of the groundwater would not be affected.
31
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If water for the facility were withdrawn from the lower aquifer, it
could deplete that aquifer. However, no such withdrawal is planned.
The lower aquifer could be used to meet minor water supply demands or
infrequent high capacity demands, but its long-term production capabil-
ity probably is limited severely by its apparent low recharge rate.
Due to its depth and the protective, confining layer of silt, the lower
aquifer should be immune from contamination by surface activities.
It is expected that the wetlands and small creeks, mainly Corbin Creek
(Robe), near the southern edge of the site which apparently depend on
the upper aquifer for part of their existence, would be affected only
slightly by withdrawal of the design flow rates from that aquifer.
Whatever drawdown of the aquifer did occur during the winter months due
to withdrawal would be expected to cause only a slight down-slope shift
of the point at which the stream heads, or first appears. There is
evidence that there is a great variation in the natural winter season
flow in Corbin Creek (Robe). Observations during March 1979 revealed a
measurable flow in this creek, while during March 1980 there was no
measurable flow in the upper reaches of the creek. With this variable
natural condition it is difficult to predict the effect and signifi-
cance of groundwater withdrawal on this creek. If adverse effects
occur, their magnitude would be greatest in late winter, just prior to
spring breakup (thawing).
There is a lack of available winter water table data upon which to base
a more conclusive impact determination. The water well, stream flow
and snow depth monitoring program conducted during for the 1979-1980
winter period provides one year's data for these predictions of effects
on the streams.
Due to the gradient, or slope, of the water table of the upper aquifer,
and its significant elevation above sea level (approximately 21 m [70
ft] on the site), the relatively small drawdown of the water table in
the area due to withdrawal of water for refinery operation would not
cause intrusion of saltwater into the aquifer. The lower aquifer also
has a water pressure level considerably above sea level (approximately
32
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20 m [65 ft]), thus it would be necessary to lower the pressure in that
aquifer by nearly 30 m (100 ft) to provide the elevation difference
necessary to allow the possibility of saltwater intrusion.
Currently, there are no significant withdrawals of water from the upper
aquifer in the general vicinity of the site and no known withdrawals
from the lower aquifer. Due to the considerable recharge available
from Valdez Glacier Stream, rather significant withdrawals (on the
order of 10 ragd or more) would be required in the developable area west
of the site to cause any area-wide effect on the groundwater table
which could affect the supply available for the proposed facility.
33
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ADDITIONS TO SECTION 6.3.2 OPERATION EFFECTS
SUBSECTIONS - ZONE OF INITIAL DILUTION AND NEAR-FIELD CIRCULATION
The following material should be inserted following Table 6.3-1 which appears on
DEIS p. 192.
due to the very low measured ambient currents during the worst case,
stratified summertime conditions the calculations do not conclusively
indicate that a 75:1 dilution could be obtained at the proposed dif-
fuser site. Because of these uncertainties the NPDES permit (see FEIS
Section IV, p. 166, Item g) requires Alpetco to design and locate a dif-
fuser that will continually achieve a minimum dilution of at least 75:1
at all points along the boundary of the mixing zone. If it is deter-
mined that worst case conditions cannot continually achieve a 75:1
dilution, the permitee may request from EPA and ADEC a reduction in the
dilution rate upon showing that Alaska Water Quality Standards for
marine waters will be achieved (see p. 167, Item h) so that the bound-
ary conditions are continually maintained. To evaluate the ability to
achieve this rate of dilution Alpetco would be required to submit a
report containing all data relative to the determination of dilutions
(including worst case) and the design and location of the diffuser
system six months prior to diffuser construction. The report would be
submitted for evaluation to both the Environmental Protection Agency
and the Alaska Department of Environmental Conservation.
Near-field circulation: To determine pollutant concentrations in the
eastern end of the port, outside of the ZID, a circulation model
(Adams, et al, 1979) is used. This model accounts for pollutant trans-
port and spreading, and uses near-field model results as input. A sim-
ulation for July 5, 1979, is shown in Figure 6.3-2. This date repre-
sents summer stratified conditions (the most critical in terms of init-
ial dilution) and low exchange at Valdez Narrows (the most critical in
terms of pollutant build-up). Results are presented as contours of di-
lution of the proposed discharge water; dilutions range from 100 to
500. This is a typical pattern observed with the plume oriented toward
34
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the south. The effluent discharge is assumed to be trapped in a con-
stant layer at a depth of about 40 m (131 ft) below the surface to pro-
vide conservative results.
The additional studies referenced above as conditions of the NPDES per-
mit will further investigate the current and circulation character-
istics of eastern Port Valdez.
35
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ADDITION TO SECTION 6.4.1
IMPACTS OF WASTEWATER DISCHARGE
This material should be added at the conclusion of the Subsection entitled
General, DEIS p. 202.
In an FCCU regenerator unit wet scrubber system as described in Section
II, p. 12, the gas from the regenerator would be contacted with a cir-
culating water stream in a tower. The sulfur oxides dissolve into the
water while particulates are removed from the gas, forming a suspension
in the water. Because of the buildup of particulates in the circulat-
ing water stream, it is necessary to purge some of the water. This
purge water must then be treated to settle particulates and lower
oxygen demand. The estimated purge water constituents from such a sys-
tem would be:
Constituent Concentration
- Na+ 1,800 ppm wt
++ ++ ++
- Ca , Mg , Fe 3 ppm
- SO^ 100 ppm
- SO^ 3,450 ppm
- C0^ 165 ppm
- CI", NH4+, CN~ F 1.0 ppm
Sulfides, Oil, Phenol Neg
COD 20 mb/1
The solids content in the purge stream is not expected to be large
enough to cause concern. If solids content were a problem, a settling
pond, a corrugated plate separator or a tube settling device are con-
ventionally used for solids removal. If the organic content of the
purge water stream were high, it could be run through the biological
treatment system. The organic content should be quite low, however,
36
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and would not be expected to require biological treatment. It would be
necessary to run the purge water stream through an aeration tank to
convert oxygen-consuming sulfites to sulfates. Because of climatic
reasons there is no practical method of treatment for the sodium sul-
fates which would be in the final effluent stream. The quantities of
sodium sulfates should be relatively small (less than A parts per thou-
sand) compared to the seawater salt concentrations in Port Valdez
(32-34 parts per thousand). State water quality standards would not be
violated.
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REVISION OF SECTION 6.5.2
SUBSECTION MODELING RESULTS
Modeling Results - The primary effects of atmospheric emissions:
Part C (Prevention of Significant Deterioration) of the Clean Air Act
requires the preconstruction review of any major emitting facility.
The proposed refinery qualifies as a major emitting facility under the
Clean Air Act definition. EPA has received a PSD application from
Alpetco.
The PSD regulations require that the applicant demonstrate that the
proposed source will apply the best available control technology, and
will not cause a violation of any National Ambient Air Quality Standard
(NAAQS) or PSD increment.
Following review and analysis of the PSD application, EPA has deter-
mined that Alpetco proposes to install the best available control
technology (BACT) in all process units except the fluid catalytic
cracker regenerator. In this case, EPA has determined that BACT will
require additional control to clean the flue gas from that unit and to
effect a lower sulfur dioxide emission. The emission limits for that
unit were set at 95 percent efficiency for the removal of sulfur
dioxide from the tail gas.
In order to demonstrate that no violation of the NAAQS' or PSD incre-
ments would occur, atmospheric dispersion modeling was conducted. Dis-
persion modeling was performed for significant sources of TSP, sulfur
dioxide, nitrogen dioxide, and carbon monoxide emissions. Ambient con-
centrations during operation of the proposed facility were determined
by adding maximum predicted ground level concentrations from the exist-
ing sources to the maximum predicted ground level concentrations for
the proposed facility. These results are summarized in Table 6.5-2
(DEIS p. 212). In addition, Table 6.5-1 (DEIS p. 210) presents a sum-
mary of dispersion model predictions of PSD increment consumption based
on Alpetco's original PSD application for the Alpetco facility, com-
pared to the Class II maximum allowable increments.
38
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Significant uncertainties exist concerning dispersion processes in the
Valdez area due to complexities of terrain and meteorology. These
uncertainties translate directly to the model estimates. The VALLEY
and MCRSVAL models indicate possible violations of short-term NAAQS and
PSD increments for SO^ while the RADM model indicates compliance.
However, these model predictions are based on Alpetco's original pro-
posal, which assumes the fluid catalytic cracking unit (FCCU) has no
additional SO^ control beyond hydrotreating the feed to the unit.
Running the MCRSVAL model using 95 percent SO removal on the FCCU
regenerator as per the BACT determination, predicts no violations of
the short term SO^ increments would occur (see Table 6.5-1 Revised and
Table 6.5-2 Revised).
EPA has accepted the MCRSVAL model for application as a screening model
in Valdez, because the "Guidelines on Air Quality Models" (EPA-450-2-
78-027) does not contain an appropriate model. However, EPA also
determined that the MCRSVAL model is not a refined model in the sense
indicated by the "Guidelines." Therefore, lacking both an approved
refined model and adequate detailed data to perform the air quality
analysis using a refined model, screening models had to be relied upon
to determine compliance to the standards and increments. Based upon
the results of the screening model analyses, it appears that the pro-
posed Alpetco sources would not cause or contribute to a violation of
the NAAQS or PSD increments. Therefore, EPA proposes to approve the
Alpetco request to construct the proposed facilities, pursuant to
Title 1, Part C of the Federal Clean Air Act "Prevention of Significant
Deterioration of Air Quality" (PSD). EPA's PSD preliminary and final
39
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determinations and technical analysis discuss this subject in detail.
The EPA preliminary and final determinations and technical analysis are
included in Section IV, Response to Comments on Permits. The notice of
final determination was published in the Federal Register on 1 April
1980. This initiated the final 60-day appeal period on this permit.
If no appeals are made, the permit will be unencumbered at that time.
40
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Table 6.5-1 Revised
SUMMARY OF PSD INCREMENT CONSUMPTION FOR THE ALPETCO FACILITY
AFTER APPLICATION OF BACT
(|jg/m3 )
Pollutant Averaging Period
Increment, Consumption
Class II Maximum
Allowable Increment
MCRSVAL Consumption
VALLEY"
Annua1
20
10
24
SO,
24-Hour
91
83
370
TSP
3-Hour
512
507
Annua1
19
24-Hour
37
20
72
" VALLEY Model data in this table do not reflect levels to be expected after
the application of BACT. This model was not run using the BACT determina-
tion. Please see Section IV, Technical Analysis for PSD.
41
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Table 6.5-2 Revised
SUMMARY OF NAAQS COMPLIANCE FOR THE ALPETCO FACILITY
C(jg/m3)
Pollutant Averaging Period
Standards,
so2
TSP
no2
CO
Predi cti ons
Annual 2lf-Hour
3-Hour
Annua
1 2^-Hour Annua
1 8-Hour
1-Hour
National Primary
Standard
80 365
75
260
100
10,000
*+0, 000
National Secondary
and Alaska Standard
80 365
1,300
60
150
100
10,000
kO,000
MCRSVAL Prediction
28 301
2,665x
--
--
73
225
VALLEY Prediction~x
21 122
k
ifO
28
—
* The probability of
Technical Analysis
this violation occurring is
(p. 25 of the Technical Anal
very
1ys i s)
smaII. PI ease
for a complete
see Section IV,
d i scuss i on.
PSD
The VALLEY predictions are not updated as the model was not run using the refined grid.
Please see this section and Section IV, Technical Analysis for PSD, for a complete dis-
cuss i on.
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REVISION OF SECTION 6.8.1
SUBSECTION NORMAL OPERATIONS
Normal operations: The impacts of discharge from the wastewater
treatment facility at the proposed refinery are described In Section
6.4.
Normal operations at the products dock should have little impact on
water quality and marine biota. There could be some short-term distur-
bance of finer bottom sediments due to propellor wash; however, this
effect would be very local and of negligible significance. Occasional
small product spills probably should be considered a normal occurrence
(see Section 6.10.7). It is expected that cleanup operations would
recover most of the spilled material and prevent it from contaminating
the shore. Marine organisms and or marine assemblages may suffer tem-
porary adverse effects during small spill incidents. Such effects may
inalu.de direct mortality, reduction in growth and reproductive capabil-
ity, and interruption of normal ecological processes. The significance
of these effects would depend on the size and frequency of spills and
the nature of the spilled product. Evidence to date suggests that
marine assemblages are able to recover relatively quickly from spill
damage, provided that the initial impact is not too severe (Nelson-
Smith, 1972). It is likely that any adverse effects resulting from the
infrequent small spills described in Section 6.10.7 would be temporary.
(At this point, the text resumes as it appears on DEIS p. 223.)
43
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REVISION OF SECTION 6.8.4 WETLANDS
Wetlands: Various refinery facilities would affect wetland areas
delineated on and adjacent to the proposed refinery site. Bridge and
pipeline crossings of Valdez Glacier Stream, Robe River, Corbin Creek
(Robe), and Corbin Creek (Glacier) would cross areas of freshwater and
watercourse wetlands. In addition, a flood control levee would be con-
structed adjacent to Valdez Glacier Stream.
Slater Creek, with seasonal flows from north to south across the site,
would be diverted into Valdez Glacier Stream near the northern edge of
the site. Storage tanks would occupy portions of the abandoned Slater
Creek watercourse wetland areas. A portion of the Slater Creek water-
course wetland would reestablish with the creek diversion.
Saltwater wetland areas would be affected by construction of the pro-
ducts dock, construction barge dock and effluent outfall pipe. In each
case, the impacts would be localized and of short duration. At the
products dock, driving of steel-jacketed piles would cause a distortion
of surface sediments and resuspending of fine silts in the immediate
vicinity of each pile. Dredge and fill operations for the barge dock
would cause destruction of the existing benthic fauna in an area of
approximately an acre, but the area is populated only sparsely and the
impacts would be minimal. Placement of the effluent outfall pipe would
require digging a trench through an intertidal area which is populated
sparsely with an assemblage accustomed to heavy seasonal suspended
sediment loads. Effects there also would be minor.
The approximate acreage of each wetland type which would be affected
directly by the proposed project are:
Saltwater Wetlands 4-1/2 acres
Freshwater Wetlands 80 acres
Watercourse Wetlands 176 acres
All other wetlands fall outside of the areas proposed for development
and would not be affected.
44
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REVISION OF SECTION 7.1
MITIGATION MEASURES SUMMARY
Numerous mitigation measures have been identified in this EIS, and are presented
as a list of suggestions in Section 7.1, DEIS p. 264-273. As those measures
were suggested, Alpetco committed to implement many of them; others either were
outside of Alpetco's authority to implement, or would be taken into considera-
tion by Alpetco as project planning reached the appropriate level of detail.
The status of each item as of December 1979 is noted in the listing as "com-
mitted," "not yet committed," or "other authority."
The manner in which the mitigation measures are presented has been changed for
the Final EIS. The format is an outline of requirements, rather than a list of
suggestions, with several measures grouped into categories of design criteria;
groundwater supplies; construction related activities; and spill prevention,
control and countermeasure. Some related items from the original list were
combined into single mitigative measures; some have been made more specific.
Most "not yet committed" items now are committed activities. Measures which are
a normal part of permitting stipulations are not repeated here, such as DEIS
items 14 and 15 which refer to use of BACT to control air emissions. Those
measures outside of Alpetco's authority to implement also are not repeated.
The resulting list of mitigative measures follows. These measures are attached
to the NPDES permit and therefore are subject to permit Part B.8 Noncompliance
Reporting (see Section IV, p. 171).
The permittee shall meet the following mitigative measures:
A. Design Criteria
1. The final structural design of refinery components shall incorporate a
ground motion analysis which assesses the dynamic behavior of the coupled
site/refinery components.
45
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2. Culverts, bridges, and other drainage structures on fish streams shall be
designed to assure that water velocities will not impede fish passage,
and culverts shall be installed in concert with the natural streambed to
prevent "perched" conditions which impede fish passage.
3. Noise abatement components on refinery equipment shall be used.
4. Implement a sediment and erosion control program for all disturbed soil
surfaces to minimize erosion and subsequent siltation into the streams.
5. The crude supply and product pipelines shall be aligned to minimize the
number of stream crossings, and shall be buried to reduce the risk of
hydrocarbon spills from accidental pipeline damage and vandalism. How-
ever, the crude supply and products pipelines from the plant site to the
Richardson Highway shall be elevated to avoid in-water crossing of the
Robe Lake System anadromous fish streams.
B. Groundwater Supplies
1. The point of groundwater withdrawal shall be located near the north edge
of the site so that drawdown in the vicinity of the Brownie and Corbin
(Robe) Creeks is minimized. The groundwater drawdown shall be monitored
during plant operations.
2. Additional water to Corbin (Robe) and Brownie Creeks shall be provided to
maintain winter flow if the water table is lowered.
3. Pollution of the groundwater source shall be mitigated by the provision
of impervious diking and surfacing of areas where hazardous materials are
stored.
C. Construction Related Acitivities
1. Construction work at the products dock shall be scheduled between June 1
and July 15 to avoid the intertidal spawning period for salmon in Solomon
Gulch Creek.
46
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2. Trenching activities for burial of the effluent pipeline in the inter-
tidal zone shall be scheduled to avoid the pink salmon run in nearby
Sewage Lagoon Creek.
3. Buried pipeline stream crossings shall be installed during the least
biologically sensitive time of the year employing the construction method
that is least damaging for that type of stream. A stream bypass flume
shall be utilized to carry stream flows during pipe burial at Dayville
Flats Creek. Construction at most streams in the area shall be conducted
between June 1 and July 15. Construction at the Lowe River shall take
place between March 1 and June 15.
4. Construction activities which could affect the streams during no-flow or
very low-flow periods shall be scheduled to minimize the problems associ-
ated with increases in erosion and turbidity.
5. Dredging activities for the construction barge dock shall be conducted
outside the period of April 7 to June 7 to avoid disturbance of juvenile
salmonids present during that time span. Operations shall be conducted
with a clamshell to avoid fish entrainment problems, and material shall
be deposited inland.
6. Construction and fill material shall be disposed of only in approved
landfill sites.
7. Any damage to the Richardson Highway and Dayville Road in the vicinity of
the Alpetco operations shall be repaired to its preconstruction condition
at the close of construction.
D. Spill Prevention, Control and Countermeasure
1. The permittee shall develop and implement a spill prevention, control
and countermeasure plan, and an oil and hazardous substances spill con-
tingency plan for offshore and onshore operations to reduce the chances
of spillage of petroleum hydrocarbons and to maximize the effectiveness
of control and cleanup measures in the event of a spill. (Current regu-
47
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lations require the plan to be prepared within six months after the date
the facility begins operation and to be fully implemented not later than
one year after facility startup [see 40 CFR 112.3(b)]; however, under
regulations proposed 1 September 1978, any facility which becomes opera-
tional after the effective date of those regulations would be required to
have the plan prepared before the facility begins operation and to have
the plan fully implemented within six months of the date of startup [see
40 CFR 151.3(b)].)
2. Positive-seal liners shall be used in all ponds containing hazardous
materials.
3. The permittee shall containerize any hazardous materials temporarily
stored on-site, using sealed 50-gallon drums or similar sealable and
transportable containers. (This shall be done according to the provi-
sions of the Resource Conservation and Recovery Act.)
4. Leak detection systems capable of detecting small volumes and slow rates
of leakage, and the proper use of valves in the pipelines shall be used
to minimize potential spills.
E. The permittee shall assist in establishing an interdisciplinary team of
engineers, fishery biologists, and hydrologists to provide early review of
construction plans and schedules.
F. The permittee shall establish training programs to meet the staffing require-
ments of the proposed facility during its construction and operations phases.
G. Collect rain runoff and snowmelt along the eastern periphery of the site and
direct it to a point on Corbin Creek (Glacier) minimizing the potential for
contamination of a portion of the surface runoff.
H. Fences shall be installed around the construction camp and all permanent
facilities and garbage disposal areas to help minimize human/bear inter-
action.
48
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I. The permittee shall leave a buffer zone of undisturbed natural vegetation
with minimum radius of 91 m (300 ft) around all bald eagle nest sites to
reduce disturbance and prevent "blowdown" of nest trees. Pipeline construc-
tion activities shall not be conducted in the vicinity of active bald eagle
nests during the nesting period if the nests are active.
J. The permittee shall to the extent possible, locate project facilities away
from nesting areas or resting areas for migrating birds.
K. If any historical or archaeological site is discovered, the permittee shall
stop construction work at the location and contact the appropriate author-
ities.
49
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4791 Business Park Boulevard
Suite 1
Anchorage, Alaska 99503
907-276-2335
Woodward-Clyde Consultants
Addition to Section 9.4 - Exhibits
February 21, 1980
DOWL Engineers
4040 B Street
Anchorage, Alaska 99503
Attention:
Mr. John Paulson
Re :
Flood Insurance Study for Valdez, Alaska
Dear Mr. Paulson:
In our telephone conversation of today, you requested information
on the status of the flood study that Woodward-Clyde Consultants is
conducting for the City of Valdez. The following paragraphs provide
this information.
Phase I of the project has been completed. It involved reviewing the
Flood Insurance Study conducted for the Federal Insurance Administra-
tion and making recommendations to the City on its accuracy and com-
pleteness. We found several aspects of the study which were inadequate
to accurately describe the flooding potential at Valdez.
Phase II of the project is very near completion. During this phase,
field data were collected and reduced on (1) the physical character-
istics of the glacier dammed lakes in the drainage basins above Valdez,
and (2) the geometry of the Lowe River and Valdez Glacier Stream flood-
plains. Also during this phase, we provided assistance to the City
of Valdez in their appeal of the FlA-sponsored study.
Phase III of the flood study will involve the analysis of data to
provide flood estimates and corresponding elevations. This phase is
expected to begin this spring and will take roughly 10 months to com-
plete. We do not believe that any results will be available in a time
frame to be useful to you in your Environmental Impact Statement.
Very truly yours,
Senior River Engineer
LAR/jb
Consulting Engineers, Geologists
and Environmental Scientists
Offices in Other Principal Cities
-------
ADDITION TO APPENDIX VOLUME I
SECTION - GROUNDWATER HYDROLOGY
The major pump test of the aquifer was performed during summer 1979 on well B-2
at a rate of 1,550 gpm and continued for 48 hours. This test caused approx-
imately 16 ft. of drawdown in the pumped well and about 4 ft. in well B-3,
located 50 ft south of the pumped well. After about 10 hour's pumping, the
water level in well B-3 had virtually stabilized. No measurable influence was
noted in the nearest observation wells tapping the same formation, located north
and west of the pumped well (B-l, 650 ft north and A-l, 870 ft west). It was
noted, however, that the water level in well B-4, located 550 ft south (down-
gradient) was drawn down 1.8 ft over the duration of the test. No measureable
effects were detected in any of the other wells over the site which tap the
upper aquifer.
Transmissivity (T) of the formation was computed using both the straight-line
and Theis curve-matching techniques applied to the data from observation well
B-3. The results of these computations were 1,860,000 gpd/ft and 1,489,000
gpd/ft, respectively, considerably higher than one would expect of a formation
whose specific capacity is in the range of 100 gpm/ft. The rapid initial drop
of the water level combined with the very flat time versus water level curve
(after the first few seconds) ruled out the use of the straight line method for
the determination of Storativity (S). When computed by the curve matching
technique, however, a value of S * 6.63 x 10 ^ resulted. This value is much
too low for even a poor artesian aquifer, thus must not be considered to
represent the true conditions.
Computations of T and S based on the drawdown data from well B-4 yielded the
following results:
By Straight Line method -
T = 307,770 gpd/ft
S - 0.034
51
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By Theis Curve-matching method -
T = 262,200 gpd/ft
S = 0.064
Although these "T" values are approximately what one would expect of an aquifer
with a specific capacity of 100 gpm/ft, the "S" values are still considerably
lower than would be expected of this type of formation.
It is felt that the unrealistically high value of "T" computed from B-3 data,
and the low values of "S" were caused by some combination of:
1. A water table formation whose horizontal permeability is grossly greater
than its vertical permeability, causing the rapid initial drop when pumping
began - a "slow draining" aquifer.
2. Extensive recharge sources are nearby (Slater Creek 800 ft ± east and
Glacier Stream 1,700 ft ± west of the pumped well). These recharge sources
probably caused, to some degree, the early stabilization of water levels
during the pump test. This effect may also have contributed to a flatten-
ing of the drawdown curve, possibly increasing the values of "T" which were
indicated near the pumped well.
Although the low "S" values and the characteristic shape of the plot of water
level versus log time give the impression that the upper aquifer may in fact be
a confined or artesian formation, the following factors suggest that that is not
the case:
1. During a preliminary pump test on the upper, unconfined, aquifer at well
B-3 (production zone 109 to 139 ft below surface) an eight-hour pump test
at a rate of 318 gpm caused a drawdown of three ft below the static level.
The water level virtually stabilized within approximately 15 minutes after
pumping began. It was later discovered that the discharge from this pump
test all had percolated into the ground within less than 200 ft from the
well. This fact was not detected until the pump test had been completed.
It is apparent that the pump discharge was being circulated back to the
52
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water table very near the well, as indicated by the rapid stabilization of
pumping level.
2. During the 24 hour pump test of the lower aquifer at well B-3, the dis-
charge of approximately 300 gpm all soaked into the ground within approx-
imately 100 ft of the well. During this 24-hour period, the water level in
well B-2, 50 ft to the north which taps only the upper unconfined aquifer,
was noted to rise approximately 0.3 feet.
3. No water level fluctuations were noted in the upper aquifer which could be
identified as being caused by barometric fluctuations.
4. No confining formation above the aquifer was identified during drilling.
Effects of Long-Term Pumpage
It is recognized that pumpage during winter months when there is no significant
recharge to the aquifer will cause a lowering of the water table over the site
in addition to the fluctuations which normally occur during the year due to
natural causes. If reliable values of "T" and "S" are available, the Theis
non—equilibrium well formula may be used to compute the drawdown due to pumpage
at any reasonable distance from the pumped well, after any particular duration
of pumpage.
Although the values of T and S determined during the pump test were not entirely
satisfactory, the values computed from the data from well B-4, 550 ft down
gradient from the pumped well, appear to be the most nearly correct, with the
error being in the conservative direction. Using those factors, the drawdown to
be expected near the headwaters of Corbin Creek (Robe) 5000 ft from the pumped
well, is computed to be approximately 2.5 ft over a six month period of pumping
during which no significant recharge occurs.
This computation is based on the following assumptions:
1. T and S values computed from well B-4 data by the two methods were
averaged: T « 285,000 gpd/ft and S ¦ 0.05.
53
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2. Pumping rate used was 1.7 mgd or 1,200 gpm.
3. Aquifer conditions are reasonably uniform over the site.
4. Since one edge of the site is known to have bedrock boundaries, most
likely impervious, the drawdown computed for the typical no-boundary
condition was doubled to correct for the influence that these assumed
impervious boundaries could possibly have on the drawdown in that
area.
is computation should be very conservative, since it is based on a storativity
efficient which is unrealistically low. If an "S" of approximately 0.2, which
would be more appropriate for the existing conditions were used, the same com-
putations and assumptions would indicate an expected drawdown of approximately
1.2 ft.
In either case the expected drawdown must be viewed in comparison with the
natural water table fluctuations which occur over the site. As of March 1980
water level data has been monitored during most of the 1979-1980 winter season.
The water table in well B-8 near the south edge of the site has fallen approxi-
mately 9 ft between October 1979 and March 1980. Since another 2 ± months
remain before significant recharge may be expected, the total drop could be as
much as 10-12 ft. It can be seen then that the drawdown expected due to the
design pumpage rates would only be an increase of 25 percent or less of the
fluctuation which occurs naturally. It would seem that an increase in water
level fluctuation of this relative magnitude could have little overall effect on
the flow of the groundwater fed streams, Corbin Creek (Robe) and Brownie Creek,
which head near the south edge of the site.
As noted in paragraph 2 of the Mitigation Measures section on DEIS p. 189, if
the pumpage from the unconfined aquifer on the site were found to be causing
significant decrease of the flow rates in the streams (Brownie Creek and Corbin
[Robe]) arrangements could be easily and quickly made to replace the flow
deficit with groundwater or storm retention water. Although incontrovertable
computations cannot be assembled to prove the contentions outlined above, it
seems clear that the withdrawal of the design rates from the unconfined aquifer
54
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under the site should cause little or no measurable effect to the groundwater-
fed streams in the area.
Zero Recharge Scenario
If a season of almost zero recharge were to occur, it is likely that water
levels in the area of the production well could be drawn down dangerously near
the well screen. This situation would undoubtedly seriously affect the flow of
Corbin Creek (Robe) and Brownie Creek, possibly requiring the tapping of the
lower aquifer to make up the flow deficit in those streams. In considering the
normal sources of recharge to the unconfined aquifer, however, this possiblity
seems rather remote. If very little rainfall were received, it would be ex-
pected that less cloudy weather would occur, thus considerably increasing the
thawing degree days available for the melting of snowpack and glaciers which
feed the streams traversing the area. On the other hand, if the weather were
more cloudy than normal, the rainfall would likely be greater than normal,
adding to stream flow and recharge. The increased rainfall would also enhance
melting of snowpack and glaciers, thus adding to stream flow as well. The only
condition which would significantly affect stream flow and recharge would be a
drastic change in weather patterns such that little or no melting of the snow-
pack and glaciers would occur during summer months. Occurrence of this condi-
tion has a sufficiently remote possibility of occurrence as to be beyond the
scope of this report.
Impermeable Layer Separating Aquifers
Virtually all of the deeper holes drilled over the site encountered a layer of
silty sand/sandy silt which is quite firm and quite impermeable. The thickness
of this formation varied from approximately 10 ft near the eastern edge of the
site to approximately 112 ft near the northern edge of the site at well B-3. In
all cases there was a difference in static water level between the permeable
materials below the silt and those above. The difference ranged from a minimum
of 1-2 ft at B-5 to 27 ± ft at B-3. The pump test performed on the lower for-
mation at well B-3 caused no detectable drawdown of water levels in the upper
formation; however, measurable effects were detected in the lower formation over
most of the site. The semi-log plot of water level versus log time since pump-
55
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ing began showed indications that the cone of influence encountered impervious
boundaries approximately 10 hours after pumping began. These factors point to
the conclusion that the upper and lower aquifers are quite thoroughly separated
over the entire site, and quite likely over most of the valley. Reviewing the
water level data recorded by the monitoring program during the winter months of
1979-1980 indicates, however, that at the locations which are still available
for monitoring of the lower aquifer, the decline of its static water level has
matched that of the upper aquifer almost precisely. While this correlation
could be purely coincidental, it seems more likely that some form of low capa-
city interconnection exists in the vicinity of the site.
56
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ADDITION TO EIS
ATTACHMENT A - BIBLIOGRAPHY
Alexander, V., 1979. Phytotoxiclty studies. In: Continuing Environmental
Studies of Port Valdez, Alaska 1976-1979. University of Alaska, Institute
of Marine Science, Report No. R79-2: pp. 7-1 - 7-28.
Smith, R. and S. Stoker. 1969. Pelagic fauna and the benthic fauna of the sub-
tidal zone. In; Baseline data survey for Valdez pipeline terminal envi-
ronmental data study, (D. W. Hood, ed.) University of Alaska, Institute of
Marine Science, Report No. R69-17.
Dames & Moore. 1977. Final data report - Subtidal monitoring program for Port
Valdez 1976. For: National Marine Fisheries Service, Anchorage.
Nelson-Smith, A. 1972. Oil Pollution and Marine Ecology. Elek Science,
London.
57
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SECTION III
This section responds to comment letters regarding the DEIS received from the
public sector and from local, state and federal agencies. All letters are
reprinted in their entirety. Letters which do not require a specific response
are marked with a box and the words "comment noted." Where further explanation
or references are necessary, the comment letter is followed by responses to
specific issues which were raised in that letter.
The format of the responses is to briefly restate the nature of the comment;
respond to it; restate the next comment from that letter; respond to it, and so
forth. The designations "C" and "R" in the margins represent "Comment" and
"Response" respectively and are followed by sequential numbers, so that R1 is
the response to CI, and so on. The comments also have been numbered in the
lefthand margin of the original letter.
Comment letters from the public sector are considered first, followed by let-
ters from local, state, and then federal agencies. The following index provides
a listing of the letters received.
59
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INDEX TO SECTION III
Page
Letter from Joseph LeBeau 61
Response to Mr. LeBeau 65
Letter from State of Alaska 68
Response to State of Alaska 81
Letter from U. S. Department of Agriculture, Forest Service 96
Letter from U. S. Department of Agriculture,
Soil Conservation Service 97
Letter from Advisory Council on Historic Preservation 98
Response to CHP 99
Letter from U. S. Department of Transportation,
Federal Aviation Administration 100
Response to DOT - FAA 101
Letter from U. S. Department of Commerce,
National Marine Fisheries Service 102
Response to USDOC - NMFS 109
Letter from U. S. Department of the Interior,
Office of the Secretary 118
Response to USD0I 124
Letter from U. S. Department of Housing and Urban Development,
Office of Community Planning and Development 132
Response to HUD - 0CPD 133
Letter from U. S. Department of the Army,
Corps of Engineers, Alaska District 135
Response to COE 138
60
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RECEIVED
t:b i i98o
S.R. Box 5439 L
Knik, Alaska 99687
January 29, 1980
Ms. Deborah Kirk
Environmental Evaluation Branch
Mail Stop 443
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
RE: Environmental Impact Statement - Alpetco Refinery,
Valdez, Alaska
Several questions and points for further study have been
raised while reviewing the Environmental Impact Statement
for the proposed Alpetco refinery in Valdez.
The Alyeska ballast water treatment facility in Valdez
has proven to be quite successful in removing the heavier
hydrocarbons in the primary separators. Experience with
the VMT ballast water plant indicates that 99% of the
treatment occurs in the ballast water storage tanks/API
separator. The Alyeska plant has not successfully added
alum and polyelectrolyte to form floe in the dissolved air
flotation basin, but it produces floe quite nicely in the
impound basins which were added as an afterthought by
A.I. Snow. I suspect that Alpetco will not be any more
successful than Alyeska has been in using this technique.
I wonder if we could ask Alpetco which chemicals will be
used in their actual operation, and whether or not they
expect a problem with the desulfibrio bacteria.
The dissolved air process has proven largely successful
for removing aromatic hydrocarbons at the Alyeska facility.
The dissolved air rapidly saturates with aromatics and
"reduces by approximately one-half the remaining fraction
of petroleum, which usually corresponds to less than one
percent of the total organic load."
Ihor Lysyj, et al., Preprint Paper #77,
197 9 Oil Spill Conference, Los Angeles.
I suggest that instead of dissolving a limited amount of
61
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Page two
January 29, 1980
air into the ballast water, that a flotation basin using
compressed oil-free air to sparge the ballast the length
of the flotation basin be implemented. This process
would be an adaptation of a laboratory technique observed
by myself and reported by Lysyj, "Determination of
Aromatic and PAH Content of Oily Wastewaters."
Ihor Lysyj and Edward C. Russell, under
U.S. Army Contract DAAK-02-74-C-0311.
This should remove a great deal of the aromatic load for
the RBC.
The ballast water loaded in Parita Bay is at approximately
80°F and when it is processed in Valdez in the summer months,
the temperature is closer to 62°F.
I suspect that the winter ballast temperatures will be
cooler yet. If we assume that the ballast loaded on the
West Coast is in the neighborhood of 60°F, what will the
temperature drop to when the ballast is processed at the
Alpetco plant site after settling on shore at Solomon Gulch
and then transiting the 5.3 miles of pipeline to the
treatment plant?
The efficiency of the RBC should be explored in the 40°F
to 60°F ballast water temperature range. It may be neces-
sary to remove the aromatics through some additional pro-
cessing.
The dirty ballast load will be significantly higher in the
winter for ships transiting the Gulf of Alaska, segregated
ballast or not.
One of the I.M.S. studies indicated that fish could not be
maintained alive in the ballast water effluent discharge
stream from VMT. (Personal conversation with George Perkins
and Ihor Lysyj, 1978.)
The location of the ballast water diffuser is in the soil
deposition zone for the Valdez Glacier Stream and the Lowe
River. "Six of the 2,300 earthquakes have produced signi-
ficant effects in Port Valdez and on the Valdez Glacier/Lowe
River outwash delta. Some of these effects included strong
62
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Page three
January 29, 1980
ground shaking, submarine slides and seiching ..."
Page 110, DEIS Alpetco, 1979.
"It was also reported that a ship, which was anchored at
the mouth of the Lowe River in 1898, was unable to reach
bottom at the same location with 200 feet of cable after
the 1899 earthquake."
Page 156, EIS Appendix I, pertaining to the
September 3, 1899 earthquake epicenter near
Yakutat Bay, the low frequency motion pre-
cipitated a massive subaqueous flow slide.
On February 14, 1908, approximately ten years later,
another earthquake just north of Port Pidalgo occurred and
severed the submarine cables linking Valdez, Sitka, and
Seward. No evidence of faulting was shown in Port Valdez
so it is currently thought that the cables were severed as
a result of the liquefaction of the sediments similar to
that which occurred in 1899.
Ibid, Page 1-57, EIS Appendix I.
On September 21, 1911, another quake centered between
Seward and Whittier occurred and the submarine cables
were severed "several seconds after the earthquake stopped.
Ibid, Page 1-57, EIS Appendix I.
On January 31, 1912, a fourth quake occurred and the sub-
marine cables were broken.
On February 23, 1925, the submarine cables were severed
again.
On March 27, 1964, a massive submarine slide occurred and
destroyed the Valdez dock facility. The old townsite ap-
pears to be close enough to the Alpetco ballast water dif-
fuser to present a foreseeable failure as a result of a
submarine slide due to liquification of the bearing soils.
It appears, after reviewing the data, that the ballast
63
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Page four
January 29, 1980
water diffuser should be moved to a point where it will
not be subject to submarine slide induced failure.
As I recall from reading the U.S.G.S. report on the 1964
earthquake, a large area of land between Robe River and
the Valdez Glacier Stream dropped four to six feet in
elevation. This is probably not a very good area in which
to bury a pipeline.
The recreational impacts from locating the dock facility
near Solomon Gulch have not been discussed, nor has the
economic impact to the charter boat operators as a result
of the lost salmon fishing charters. The institution of
an exclusion zone for private boats in this area is to be
almost assured to protect the lives and property at 'the
dock site because of the explosion hazard.
Experience with the tanker loading operation indicates
that the greater the number of tanks, the greater the risk
of tank overtopping (overfilling). The DEIS attempts to
compare the risk of loading 150,000 bbls. into ten large
tanks with 145,000 bbls. split into many different, smaller
tanks.
Product carriers are generally much smaller than crude
carriers and have a greater number of tanks to enable them
to transport a larger variety of products.
The number of port calls does not equate with the number of
tanks, nor with ship age, nor with travel through the Gulf
of Alaska in the treacherous winter months.
Please send me a copy of the completed Final Environmental
Impact Statement.
Sincerely,
DEIS, Page 253
DEIS, Page 255
64
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RESPONSE TO COMMENTS BY JOSEPH P. LeBEAU
CI Comments on page 1 of Mr. LeBeau's letter regarding the Alyeska Terminal
experience in the use of alum and polyelectrolite to form floe particles
and how it will relate to Alpetco's successful use of these techniques.
R1 Alpetco's proposed treatment system is considerably more sophisticated than
that currently in use at Alyeska. The rotating biological contactor (RBC)
treatment unit proposed by Alpetco has proven to be an effective activated
sludge system. An RBC unit is in operation as part of the best practicable
technology effort to achieve effluent standards in a heavy crude refinery
in California which is required to meet strict NPDES effluent discharge
standards. The RBC is a proven technology and is expected to meet NPDES
and State of Alaska receiving water quality standards. Wastewater is
pumped into the dissolved air flotation tank and receives a chemical treat-
ment with alum and polyelectrolite. Large diameter, rotating perforated
discs are partially immersed in the mixed liquor in each channel of the
tank system to provide constant mixing and efficient aeration. The floc-
culation attainable with aeration discs can help maintain large sludge floe
particles which are conducive to solids capture, thus permitting higher
mixed liquor suspended solids concentrations. It is expected that the RBC
unit will achieve reasonable aromatic hydrocarbon reduction levels. For
illustration, the above example west coast plant is removing more than 80
percent hexane solubles and 99 percent phenols to meet all EPA require-
ments, except for ammonia. Ammonia is generated, rather than consumed as
expected, in the biological process.
C2 The efficiency of the RBC should be explored in the 40°F to 60°F ballast
water temperature range. It may be necessary to remove the aromatics
through some additional processing.
R2 Comment so noted. It is conceivable that heat may have to be added to the
ballast water flow prior to treatment.
65
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C3 The dirty ballast load will be significantly higher in the winter for ships
transiting the Gulf of Alaska, segregated ballast or not.
R3 Comment so noted. The water treatment plant is sized for the worst case
ballasting situation, which is non-segregated tankers during the winter
season. The introduction of product tankers with segregated ballast tanks
would reduce substantially the ballast water flow to the treatment plant.
C4 Comment from the bottom of page 2 of Mr. LeBeau's letter regarding the
location of the wastewater discharge diffuser with respect to risks imposed
by seismic activity and submarine slides.
R4 The NPDES permit will require the applicant to submit a report containing
all data relative to the determination of dilutions and design and location
of the diffuser system at least six months prior to beginning diffuser con-
struction. This will include geotechnical and bathymetric studies. This
will allow EPA to determine if reasonable precautions are being taken in
the siting in the outfall discharge line.
C5 The recreational impacts from locating the dock facility near Solomon Gulch
have not been discussed nor has the economic impact to the charter boat
operators as a result of the lost salmon fishing charters. The institution
of an exclusion zone for private boats in this are is to be almost assured
to protect the lives and property at the dock site because of the explosion
hazard.
R5 DEIS Page 102, Paragraph 3, indicates the mouth of Solomon Gulch Creek will
be about 609 m (2,000 ft.) from the nearest edge of the proposed products
dock facility. This distance is expected to be sufficient to prevent a
serious impact on the sport fishing and charter business activities that
may occur near the mouth of Solomon Gulch Creek. The U. S. Coast Guard
currently imposes a 200 yard safety zone around all tankers at berth at the
Alyeska tanker terminal or in transit to or from the dock. The Coast Guard
indicates it's reasonable to assume a similar safety zone would be estab-
lished around the Alpetco products dock. Considering the 2,000-foot dis-
tance from Solomon Gulch, the nearest safety zone still would be approxi-
mately one-quarter of a mile away.
66
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C6 Comments on Page 4 of Mr. LeBeau's letter regarding tanker loading opera-
tions, risk of tank over-topping and variables used in the spill prediction
analysis.
R6 The intent of the spill prediction analysis on DEIS Page 253 was not to
compare directly the risks of spills from loading crude oil tankers (with
fewer numbers of large tanks) to those of loading product tankers (with
greater numbers of smaller tanks). Even though the circumstances sur-
rounding the loading of crude tankers versus product tankers differ
slightly, there is no other accepted approach that is comprehensive enough
to consider all variables involved. Certainly the number and size of tanks
in the ships would affect the frequency of loading spills. However, the
number of port calls seems the most relevant variable and an analysis based
on this fairly represents the spill risks present during loading opera-
tions. Ship age certainly would influence this analysis but during the
forthcoming time period when the trend will be toward newer and larger pro-
duct tankers, it can be assumed that not accounting for ship age adds a
degree of conservatism to the analysis. The U.S. Coast Guard currently is
conducting two studies on the relationship between tanker size and the risk
of spills. These conclusions will not be available until 1981.
67
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JAY S. HAMMOND, Governor
OFFICE OF THE GOVERNOR
DIVISION OF POLICY DEVELOPMENT AND PLANNING
February 21, 1980
Mr. Alex Smith, Acting Director
Air & Hazardous Division
Environmental Protection Agency
Region X
Mail Stop 529
1200 Sixth Avenue
Seattle, Washington 98101
Subject: Alpetco Refinery and Petrochemical Facility DEIS
Dear Mr. Smith:
The State of Alaska has completed review of the subject Draft Environ-
mental Impact Statement (DEIS). The DEIS reflects the coordination
which has occurred to date between the Environmental Protection Agency
(EPA), Alpetco and the State of Alaska, as coordinated by the Alaska
Department of Environmental Conservation (DEC) and the Alaska Department
of Natural Resources. The State has appreciated the opportunity to work
closely with EPA during the preparation and earlier preliminary reviews
of the DEIS. Our comments during this official review make reference to
earlier drafts. It should be recognized that many of the State's concerns
have been incorporated in the DEIS, and that the following remarks
reflect on only the remaining areas of concern.
Besides the following comments which refer to the DEIS document itself,
the DEIS, as it reflects EPA's authority to issue its appropriate federal
permits [National Pollutant Discharge Elimination System (NPDES) and
Prevention of Significant Deterioration (PSD)] for the project, has also
been reviewed for consistency with the Alaska Coastal Management Program
(ACMP). The State's decision with regard to the project's consistency
or not with ACMP will be made later this month when the relevant analyses
have been conducted by ADEC, the Alaska Department of Fish and Game (ADF&G)
and the Office of Coastal Management (OCM).
HABITAT IMPACTS AND MITIGATION MEASURES:
A large proportion of the necessary mitigation has already been Incor-
porated into both the facility design and the construction and operation
plans of the Alpetco facility as a consequence of the Scoping process,
formal interagency meetings and informal discussions with Alpetco, and
other agency Input and review concerning the design of the Alpetco
facility. Alpetco has been quite responsive to most recommendations for
preventive mitigation. Some mitigatory aspects (I.e., rerouting or
POUCH AD
JUNEAU, ALASKA 99811
PHONE: 465-3512
FEB 27 1980
IIS 6 HAZARDOUS MUEIMIS DIV.
01-A3LH
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Mr. Alex Smith
-2-
February 21, 1980
mitigating the effects of the south access road/pipeline corridor, and
mitigation of general fish, wildlife, and habitat losses) are requiring
considerable ADF&G analysis and review and are being made the subject of
separate correspondence. Most mitigation proposed in the DEIS is neces-
sarily general and a final determination of the adequacy of many provi-
sions must await more specific design plans. Insofar as the adequacy of
proposed mitigation can presently be evaluated, the general scope is
comprehensive. General recommendations for additional preventive miti-
gation measures are noted under "Mitigation", below. Significant "Tech-
nical and editorial comments" for both the main volume and Appendix 1
have also been noted.
Impacts
1. Section 6.3.4, Unavoidable Adverse (Oceangraphic) Impacts, p. 199.
The statement "Significant adverse impacts may occur in the immediate
vicinity of the diffuser.", which was contained in the preliminary
draft but deleted in the DEIS, should be reinserted in the FEIS.
Section 6.4 (Wastewater Discharge) provides ample justification for
this statement.
2. Section 6.8.1, Unavoidable Environmental (Marine Operation) Impacts,
p. 228. The premilinary draft contained the statement "3. Effluents
from the refinery and the ballast water treatment facility would
increase levels of BOD and dissolved petroleum hydrocarbons in the
water immediately surrounding the outfall. Hydrocarbon levels in
tissues of organisms such as the clam Macoma balthica living imme-
diately downstream (relative to prevailing currents) of the outfall
may Increase, potentially causing several subtle impacts." This
was deleted from the DEIS. Since this 1s a very definite probability
and a very significant impact, it should be reinserted 1n the EIS.
Moreover, as was noted in our review of the preliminary draft, the
statement should be strenthened to include the effects of other
waste stream pollutants such as heavy metals.
3. Section 6.8.2, Freshwater Operation Impacts, p. 229. The statement:
"Continuous use of fresh water drawn from on-site wells might lower
groundwater levels and, consequently, reduce flows in Corbin Creek
(Robe) and Brownie Creek." does not adequately emphasize the
problem. Operational groundwater use will undoubtedly lower the
water table. The Hydrology report estimates a winter drawdown of 6
feet, and presumably this drawdown would occur over a relatively
large area surrounding the well. Although drawdown would be con-
siderably less at the southern boundary of the site, there 1s still
a significant probability that drawdown will be sufficient to
reduce the availability of groundwater which is the source of both
Corbin Creek (Robe) and Brownie Creek. Groundwater provides the
sole source of winter flow in the critical Corbin Creek (Robe) coho
spawning area. Even a very slight temporary lowering of the water
table could readily cause major losses of eggs at the heads of
Corbin Creek (Robe) and possibly Brownie Creek.
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Mr. Alex Smith
-3-
February 21, 1980
The DEIS also states (p. 188) that, even though flow could be lost
in the upper 200 feet of Corbin Creek (Robe), it would have little
if any effect on total downstream flow. The basis for this statement
is not understood. Loss of at least some flow into Robe Lake would
seem inevitable. Since the rearing capability of Robe Lake is
already stressed to its limit, even a slight flow reduction could
produce severe adverse effects to salmonids overwintering in Robe
Lake.
4. Section 6.8.2, Freshwater Operation Impacts, p. 231. Additional
discussion of the potential for and problems resulting from ground-
water pollution is needed. Due to the very high permeability of
the soil throughout the area, spills anywhere on the facility site
or along the pipeline corridor could contaminate the groundwater
system. The potential for pollution is not limited to stream
crossings as suggested in this section. Spills from buried pipelines
and in areas where the pollutants have entered the groundwater
system are extremely difficult if not impossible to clean up, and
provide a source of long-term pollution. Since the groundwater
system provides a major source of water input to many streams,
particularly Corbin Creek (Robe), Brownie Creek, and Robe Lake,
major adverse impacts on spawning and nursery areas could occur.
Local residents also use this same groundwater system for their
water supply.
5. Sections 6.8.3, Terrestrial Operation Impacts, p. 235. No mention
is made of impacts resulting from fencing along the pipeline corridor.
Fences erected to protect the pipeline may also inhibit or preclude
wildlife movements and consequently usage of large areas of habitat.
6. Potential conflicts with some fisheries enhancement proposals in
eastern Port Valdez are not discussed. For example, the Valdez
Fisheries Development Association has been developing plans for a
coho rearing facility at Corbin Creek (Glacier), and various other
proposed or potential sites were identified by the ADF&G in its
March 1979 report "Fish, Wildlife, and Habitat Resources in Eastern
Port Valdez, and Recommendations for Further Study and Monitoring
Programs for the Alpetco Refinery."
Mitigation
1. The routing of the south access road is of major concern to the
ADF&G and 1s still the subject of ongoing discussion with both
Alpetco and EPA. Results of those discussions will hopefully be
complete in time for inclusion of the State's position 1n the FEIS.
2. Impermeability of containment dikes and pads underlying tankage and
pipelines is a major concern which 1s not adequately addressed.
All tanks and pipelines which carry potential pollutants should be
both surrounded and underlain by impermeable containment barriers.
This is particularly important for the products pipelines between
the facility and the dock.
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Mr. Alex Smith
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February 21, 1980
~ 3. Leak detection systems for pipelines should be addressed more
specifically. Detection systems must be capable of detecting small
C9 volume or slow rates of leakage. It is also recommended that the
crude supply pipeline be designed to accomodate periodic hydrotesting
± as a definitive test of pipeline integrity.
~ 4. Present plans call for burying the products pipelines in wetland
areas. Since leakage from buried pipeline is particularly difficult
cto to detect and control, and could cause major pollution of the
groundwater system, strong consideration should be given to elevating
A the pipeline in vulnerable areas.
~ 5. Pipeline crossings of anadromous streams (possible mitigating
measure #4, p. 186) should be scheduled to coincide with the period
between fry emergence/outmigratlon and adult spawning. For most
streams in the Port Valdez area, this period is June 1 to July 15.
C*11 Inwater work outside of this period could expectedly cause considerable
mortality of Incubating eggs and/or sac fry. The Lowe River,
however, has a relatively low sensitivity between March 1 and
June 15 (the river's low water period), and inwater construction
A would would be permissible in the Lowe River during this period.
~ 6. A buried pipeline crossing of Robe River (discussed in Section
6.8.2, p. 228) 1s not justified given the fisheries sensitivity of
the stream. Even with inwater construction during the June 1 to
July 15 time period, fisheries conflicts would be significant with
deposition of fines (sediments) in downstream spawning areas. A
buildup of silt in downstream spawning areas would lead to Increased
egg to fry development mortalities. We recommend that the pipeline
be elevated above the stream and protected adequately to avoid
vandalism problems. An elevated crossing would also allow easy
A detection of leakage 1n comparison to a buried crossing.
* 7. In addition to avoidance of construction impacts, the pipeline
should be routed a sufficient distance away from bald eagle nests
to preclude disturbance from pipeline surveillance vehicles and
4 activities during operation of the pipeline.
~ 8. Continuous monitoring of groundwater drawdown near the heads of
Corbln Creek (Robe) and Brownie Creek should be made a requirement
of the water use permit, and plans should Include a commitment to
mitigate any fisheries problems which may occur due to drawdown.
Proposed mitigation, including the feasibility of mitigation,
should be addressed in more detail.
C12
C14
~ 9. We do not foresee any measureable conflict with construction work
at the products dock near Solomon Gulch Creek. Pile driving should
C15 have no appreciable Impact on adult migration and/or spawning, and
special timing of dock construction work (possible mitigating
4 measure #2, p. 227) should not be necessary.
* 10. Dredging activity at the temporary barge dock should be scheduled
C16 for any time outside of the period April 7 to June 7. Between
April 7 and June 7, there 1s considerable nearshore rearing
71
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Mr. Alex Smith
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February 21, 1980
C16 activity by juvenile salmonids. It is also recommended that suction
4 dredges not be used in order to prevent fish entrainment problems.
* 11. Emplacement of containment booms around tanker vessels while in
port should be mandatory. The loading facility should be designed
C17 and spill containment procedures developed to prevent the spread of
spills, which frequently occur in loading operations, away from the
A s i te.
Technical and editorial comments
~ 1. Section 4.3.8, Alternate Transportation Routes Relative to the
Site - Pipeline Routes. The discussion of Alpetco's preferred
route does not adequately point out the sensitive habitats found
along the route. Although the discussion notes only two stream
crossings, there will be at least four crossings in the area north
of the Richardson Highway: (1) Corbin Creek (Glacier), (2) a
tributary to Corbin Creek (Robe), (3) main channel of Corbin Creek
(Robe), and (4) Robe River. Moreover, the wetlands and other areas
crossed along this route are considerably more sensitive than along
the alternative route because contamination of the groundwater in
this area could readily pollute Corbin Creek (Robe), Robe Lake,
Robe River near its headwaters, and the water supply to Robe Lake
subdivision.
C18 This section also states "The preferred pipeline route was selected
as having the least direct environmental impact." We do not agree.
Alpetco's preferred route would cross a totally undeveloped and
sensitive area, whereas two-thirds of the alternate route follows
the Richardson Highway and most of the remaining third follows the
Valdez Glacier Stream level. Direct disturbance due to construction
and operation impacts (siltation, displacement, etc.) will undoubtedly
be greater along Alpetco's preferred route, particularly at crossings
of Corbin Creek (Robe). The Robe Lake subdivision may also experience
considerably more noise disturbance if Alpetco's preferred route Is
followed. In addition to direct Impacts, potential impacts along
Alpetco's preferred route are considerably greater than along the
alternate route. Carefully developed mitigation measures will be
necessary to reduce impacts along Alpetco's preferred route to an
^ acceptable level.
~ 2. Freshwater Aquatic Habitats, p. 1-276. Paragraph 4, which states
"Attempts to capture juvenile salmon (1n Robe Lake) since 1975 have
C19 been unsuccessful..." does not reflect the most recent data. In
March of 1978, coho salmon, Dolly Varden, and stickleback were
A taken under the ice with minnow traps.
~ 3. Freshwater Aquatic Habitats, p. 1-227. Paragraph 3 states "The
current value of the (Robe) lake to the substantial salmon resources
C20 the Robe Lake draina9e questionable without further Investi-
gation." This statement tends to unnecessarily downplay the impor-
tance of Robe Lake. The lake 1s definitely utilized for rearing,
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Mr. Alex Smith
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February 21, 1980
however, the magnitude of usage has not been adequately assessed.
C20 Moreover, Robe Lake provides critical migratory access to Corbin
Creek (Robe) and Brownie Creek, both of which are highly important
± to the overall productivity of the Robe Lake system.
~ 4. Table 5: Fish Stream Summary with Sensitive Time Periods, p. I-
285. The moderate sensitivity periods on the streams listed below
extends from June 1 to July 15. The rest of the year is highly
sensitive with eggs and/or pre-emergent fry in the gravel.
a. Corbin Creek (Robe)
b. Brownie Creek
c. Robe River
d. City Limits Creek
C21 e* City Limits Clough
f. Ess Creek
g. Siwash Creek
h. Loop Road No. 2 Stream
i. Loop Road No. I Stream
j. Sewage Lagoon Creek
k. Dayville Flats Creek
l. Solomon Gulch Creek
m. Allison Creek
A n. Abercrombie Creek
~ 5. Table 2, Summary of Fry Outmigration Trapping Results, p. 1-427.
Pink fry catches were lower than chum salmon in two of the four
streams checked, but it should be clearly pointed out both on the
table and in the text that the low counts of pink salmon fry were
the progeny of an even year adult migration. Even year migrations
4 are considerably smaller than 1n odd numbered years.
C22
Transportation issues
~ With respect to Air Transportation as discussed on p. 175, paragraph 1
of the DEIS, the State 1s not aware of any plans to develop an Instrument
landing system, although VER navigational aids are being considered to
A alleviate two cancelled operations.
Several surface transportation related Issues are Identified below:
C23
~ On p. 250, of the DEIS, paragraph 1 makes a reference to movement of
refinery modules weighing 40 to 100 tons (with one unit of 500 tons).
Units of up to 75 tons are regulated by State Troopers. Units in excess
of this amount must be cleared through the Department of Transportation
C24 and Public Facilities with attendant monitoring of the route during
movement.
The proposed "Planned Reinforcement" of roadway should be outlined so as
a determination can be made as to its adequacy.
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Mr. Alex Smith
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February 21, 1980
On p. 250 of the DEIS, paragraph 3, the statement that the existing
highway capacity is 1700 vehicles per hour is misleading. Present
capacity is level C which provides stable flow for a maximum of 1400
vehicles per hour under optimum conditions. Existing mitigating factors
e.g. interrupted flow, and truck traffic reduce this volume to approximately
800 vehicles per hour. 1700 vehicles per hour on this facility would be
level of service D or a condition approaching unstable flow. Clearly
this will present a problem that will require careful analysis to avoid
conflicts in future traffic movement.
On p. 262-263, several mitigating measures are proposed for the project
construction period. Using the DEIS numbering, our comments are:
CIA On number 1, we assume this would be the responsibility of either Alpetco
or construction firm in activity.
For number 3, simply reducing existing speed limits is not sufficient to
Insure safe intermixing of construction and general traffic. It would
be the responsibility of the contractor to insure that an adequate
flagging operation was instituted.
For the operating hours of the construction period, suggestion number 1
could be considered.
Suggestion number 2 would be a definite consideration, particularly in
light of reducing traffic congestion. However, the responsibilities for
capital and operating expenditures would have to be worked out, as well
^ as the requirements of the operation.
Community and Coastal Management Planning
~ The City of Valdez has committed itself to taking an active role in
preparing for the potential impact of the construction and operation of
the Alpetco refining and petrochemical facility. This positive response
involves the city's financial participation in necessary capital improvements
and services, programmed staff increases and initiation of a local
comprehensive plan, coastal management program and revision of zoning
ordinances. These varied strategies, among others, are designed to
mitigate the anticipated primary and secondary impacts of project activities
including increased demands on public services, rapid changes 1n land
use and the prospect of severe housing shortages within the city, both
short- and long-term.
Specific comments on the DEIS follow:
P. 172, first paragraph - The statutory reference used 1s Inaccurate.
± It should read: Chapter 84, Section 46.40.010-210.
~ p. 172, second paragraph - It is stated that the district coastal management
program is not expected to prevent development within new Industrial and
OA. residential areas being considered under the comprehensive planning
v.*© process. This statement needs further explanation. The recently completed
Phase I Coastal Management document does not identify any areas in
74
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Mr. Alex Smith
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February 21, 1980
Valdez as unsuitable for development, but devises a system for classifying
land uses for a particular zoning district into three categories:
Acceptable - Conditionally Acceptable - Unacceptable. Thus, with development
of the Phase II Coastal Management document, the subject lands will be
evaluated and the above system will be used to determine allowable land
uses.
P. 172, third paragraph - The Alaska Department of Community and Regional
Affairs does not approve district coastal management plans. The Department's
C26 role 1s to provide technical and grant assistance to communities which
develop district plans. The district program approval process 1s briefly
as follows: the municipality gives conceptual approval to its district
program and submits it to the Alaska Coastal Policy Council; the Office
of Coastal Management, Office of the Governor, reviews the document and
provides a recommendation to the Council; public comment is solicited
and the Council approves or disapproves the program 1n whole or 1n part;
the Council then submits the program to the State Legislature; the
district program goes into effect when the district makes any required
4 changes 1n the program and formally adopts it by ordinance.
AIR, LAND & WATER QUALITY ISSUES:
~ With respect to pollution related matters, the State has identified air,
water, and solid waste as potential areas of concern. For activities
affecting each of these areas, the State has regulatory responsibility.
C27 Alpetco has applied for the State A1r Quality Permit, and a Certificate
of Reasonable Assurance under Section 401 of the Clean Water Act. A
solid waste permit will also be necessary, but is not germane to the
* project at this time and should be applied for at a later date.
There were several inconsistencies between the DEIS and the PSD application,
which the DEC reviews while issuing its State Air Quality Control Permit
to Operate. We point these Inconsistencies out, with other comments on
the DEIS, to ensure a consistency between relevant documents pertaining
to the Alpetco project.
~ On p. 21 of the DEIS 1t states that low Btu gas will be 35% of the plant
fuel, on p. 77 1t says 25%, 1n the PSD application on p. 3-15 1t said
LZo "major portion," and the December 11, 1979, letter from Alpetco to EPA
^ reported 25%.
* On p. 22 of the DEIS 1t states that there will be two sulfur recovery
C29 plants each capable of handling all the H2S. The PSD document does not
A describe two such plants, a "large11' and "small" plant are indicated.
* The DEIS states that S02 emissions from the sulfur recovery plant will
C30 be 100 ppm, as does the PSD application. However, the December 11
A letter says this 1s wrong, the S02 emissions will be 150 ppm.
* On pp. 24-25 of the DEIS is states that 1n-s1tu catalyst regeneration
C31 will cause SO, emissions of about six tons 1n about four days. These
"extra" emissions, amounting to an Increase of 30%, were apparently not
75
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Mr. Alex Smith
-9-
February 21, 1980
included in the "worst case" impact analysis for the PSD application.
« on O l/~1 TT 11
~
C33
A
C38
A
A
~
This comment is applicable to p. 302 in Appendix Volume II as well
~ On p. 33 of the DEIS is a table of estimated annual total pollutant
emissions. The PSD application in Table 6.3-2 lists 215 tonsCO/year
from the refinery (340 including the power plant), while the DEIS lists
1213 tonsCO/year from the refinery (1335 including the power plant) as
C32 does the November supplement. Total HC emissions in the DEIS and PSD
application are listed as 60 tons/year while in November supplement say
828 tons/year are from point sources tanks and terminal activities plus
an estimated 190 or 1240 tons/year "fugitive" hydrocarbon emissions from
A seals, pumps, etc.
~ On p. 38 of the DEIS the loading rate of anticipated tankers is estimated
to be 120-475 BBL/min (7200-28,500 BBL/hr) while the PSD document at
pp. 4-6 indicates the loading rate of a 50,000 DWT tanker is about
40,000 BBL/hr.
~ On p. 83 and again on p. 84 of the DEIS it states that only National
C34 Ambient Air Quality Standards apply to the project. State Air Quality
A Standards and PSD increments also apply.
~ On p. 84 of the March 15, 1978, New Source Performance Standards (NSPS)
for Sulfur Recovery Plants are not included in the discussion of applicable
C35 standards included in Subpart J. (p. 11-487 does describe these standards).
The NSPS for Stationary Gas Turbines are said to be proposed, however
4 they were final on September 10, 1979.
T
On p. 87 of the DEIS there is no indication that scrubbing will be used
to reduce the incinerator's SOg emissions.
T^e fla1r's steam injection system would be more appropriately described
v»«J/ as a control of smoke (products of incomplete combustion).
~ The Best Available Control Technology (BACT) discussion is very brief
and so general as to provide almost no information, particularly when
compared with the wastewater treatment discussion and even the description
of dock siting alternatives.
~ On p. 89 of the DEIS it says construction phase wastes can not be incin-
erated, but will be disposed of in the Valdez landfill which on p. 176
C39 "is nearing capacity." We wonder why incineration to reduce volume was
not considered, as Alyeska did. Similar statements appear at pp. 218
and 219.
A
C40
A
fj* Why is "in lieu of open burning" mentioned when pages 89-90 imply no
¦ nnpn hiirn-ina will nrrnr.
On p. 219 there 1s no discussion that more stringent emission controls
then those briefly mentioned in 4.43 might be imposed.
open burning will occur.
On pp. 208-214 PSD increments, and Class I areas are mentioned with no
C42 previous discussion to explain these complex aspects. A fairly good
76
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Mr. Alex Smith
-10-
February 21, 1980
introduction to PSD is given on pp. 11-497 and 498 which could be used
C42 here. The mention of Class I areas on p. 214 is especially "lonely"
since there is no indication of what a Class I area is, let alone where
± they are or why they were a consideration.
* On p. 235 terrestrial mitigation measures don't include the possibility
that more stringent emission controls might be imposed. This omission
is particularly troublesome since Tables 6.5-1 and 6.5-2 indicate that
A violations of Air Quality Standards and Increments are possible.
~
£44 In part F item (15) should have an "X" in the "not yet committed" column
A since more stringent controls might be Imposed.
C45 There was no discussion of odor.
<46
~
APPENDIX VOLUME II:
P. 11-296 Decoking of atmospheric and vacuum crude heaters is said to
produce CO, COg and Hg — is no ^0 or SOg produced?
P. II-486-9 NSPS Discussion
- Why does the Fluid Cat Cracker Unit (FCCU) discussion say opacity
pjy is limited to 20% averaged for 5 minutes? ADEC regulations say
20% except for 3 min/hr, NSPS says 30% except for 6 min/hr - the
A more stringent applies.
- The Steam Generator discussion does not include the opacity
if standard (NSPS) which applies.
C49 - The Gas Turbine NSPS became effective on September 10, 1979.
* P. 11-490 1t says S02 emissions estimates are based on 100% fuel oil as
ren worst case. Nowhere 1n the PSD application does 1t say S0« emissions
v«au are anything greater than from burning process gas (see p. 4-1, 4r9 and
A November supplement).
~ The following 1s the pertinent excerpt of the prepared text delivered at
C51 a public hearing on the DEIS in Juneau on January 31, 1980, by the ADEC
A on the water quality aspects of the proposal:
ADEC "1s responsible for establishing and enforcing water quality standards
for all state waters. Standards of particular Importance 1n this permit
are aromatic hydrocarbons, cyanide, several potentially toxic heavy
metals, pH and suspended sediments. Aromatic hydrocarbons shall not
exceed 10 ug/1 1n the water or cause deleterious effects to biota 1n
sediments; toxic substances shall not exceed 0.01 LC5Q of the most
sensitive life stage Identified by DEC 1n the area, suspended sediments
shall not exceed ambient levels at the boundary of the mixing zone. The
purpose of the receiving water monitoring program 1s to ensure that our
standards are maintained outside the mixing zone and that the components
of the effluent, Individually or collectively, do not cause significant
alterations in the chemical and biological environment.
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Mr. Alex Smith
-11-
February 21, 1980
"The development of the proposed monitoring program was based on five
principles:
"1. A desire to detect any subtle changes in water quality and evaluate
the type and magnitude of any sublethal responses of key indicator
species chronically exposed to low levels of aromatic hydrocarbons
and heavy metals.
"2. To develop the capability to detect and to evaluate gradients in
responses of organisms at varying distances from the diffuser.
"3. To utilize the information from previous marine reconnaissance
studies in Port Valdez as an aid in selecting representative stations,
and subsequently, in developing a more cost effective monitoring
program.
"4. To provide for adequate chemical characterization of the sedimentary
environment in conjunction with biological sampling, emphasizing
compounds with long residence times such as substituted naphthalenes
and polynuclear aromatic hydrocarbons.
"5. To provide an improved statistical basis for detecting change by
adopting a program of rigorous sampling at a few representative
stations rather than broad reconnaissance at numerous stations
throughout the Port.
"In developing the specific tasks of the monitoring program which I
shall discuss shortly, the department has benefited greatly from previous
marine studies in Port Valdez, most notably the preliminary biological
Investigations of Dames and Moore for the ALPETCO project and those of
the Institute of Marine Science conducted to fulfill the monitoring
requirements of the ALYESKA ballast water discharge permit. These
sampling efforts have isolated certain biological assemblages or station
groupings that share several common affinities and have guided us 1n
selecting a few representative stations within these groupings for
comprehensive followup.
"The IMS studies, 1n pointing to the apparent absence of any detectable
changes (on a gross, short term level) in community structure and blomass,
suggested that gross community changes should be deemphaslzed 1n lieu of
detecting subtle changes on the Individual species level. For this
reason, sampling stations 1n this permit are located as near the diffuser
outfall as practicable and address subtldal and intertldal Indicator
species, keying on major life history events (gametogenesis, spawning
periods, growth) while retaining basic abundance and zonatlon studies.
"With these concepts 1n mind, the department has endeavored to establish
a statistically supportable monitoring program providing the maximum
amount of Information for the money. The program 1s designed primarily
to provide evidence of any subtle variations 1n normal species life
history functions, be it changes in fecundity, growth, or spawning
periodicity of major Invertebrates, as a function of distance from the
78
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Mr. Alex Smith
-12-
February 21, 1980
proposed diffuser. The community studies should provide ample basis for
detecting any major changes in community structure. The sampling stations
are located on the assumption that the outfall location as proposed in
the DEIS will be the ultimate location.
"The monitoring program consists of six main elements:
1. Abundance and zonation studies conducted three times per year
at three permanently established muddy intertidal transects,
both adjacent and distant from the outfall;
2. Shallow subtidal extensions of these stations, to be occupied
at the same frequency;
3. Benthic studies at 5 stations In the far eastern Port with 8
replicate grabs/station;
4. Studies of key biological events 1n the life histories of
selected Intertidal and subtidal Indicator species, Including
reproductive phenology and seasonal and animal growth;
5. Hydrocarbon and heavy metal characterization of sediments,
water and biota at all biological sampling stations plus a
suite of stations very near the diffuser;
6. Assessing the 'condition Index' or condition factor of two
common bivalve species, one found intertidally and another
subtldally.
"This later concept 1n pollution monitoring 1s a measure of an organism's
overall physiological fitness and 1s defined as the ratio of the organism's
dry weight divided by its shell volume. The Index has been used success-
fully by several researchers 1n controlled, long-term experiments to
evaluate organism response to hydrocarbon stress. We have chosen to
apply this relatively Inexpensive approach as part of our overall moni-
toring strategy."
The outstanding Issues for the State are the determination of consistency
of the major federal permits with ACMP, and the selection of the route
for the south access road/pipeline corridor. Work 1s progressing on
both of these Issues and we will contact you when the necessary determinations
have been made.
We again wish to thank EPA and Alpetco for its coordination with the
State during the development of the DEIS. Thank you for the opportunity
to comment.
>9
State-Federal Coordinator
79
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Mr. Alex Smith
-13-
February 21, 1980
cc: Deborah Kirk, EPA
Glenn Akins, DEC
Richard Logan, ADF&G
Murray Walsh, OCM
Commissioner McAnerney, CRA
Kit Duke, DOT/PF
Dennis Dooley, DOT/PF
80
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RESPONSE TO COMMENTS BY THE STATE OF ALASKA
CI EIS Section 6.3.4, p. 199, the statement "significant impacts may occur in
the immediate vicinity of the diffuser" should be reinserted in the FEIS.
Rl The referenced statement, as contained in an earlier review draft of the
EIS, is hereby reinstated in the FEIS.
C2 Comment #2, p. 2 of the comment letter, concerning Section 6.8.1, Marine
Operation Impacts.
R2 It was determined that the referenced statement was unnecessary in Section
6.8, as this effect had been discussed previously. Section 6.4, DEIS p.
200-207, discusses wastewater effluents and their potential impact upon
organisms such as the clam Macoma balthica existing immediately downstream
from the wastewater outfall.
C3 Comment #3 on p. 2 of the comment letter regarding Section 6.8.2, Fresh-
water Operation Impacts.
R3 See FEIS Section II, p. 31.
C4 On page 3 of the comment letter regarding Section 6.8.2, concerning the
potential for problems resulting from groundwater pollution due to spills
on the facility site or along the pipeline corridor.
R4 Regarding the potential for groundwater pollution, Section 3.8, DEIS p. 51,
discusses containment dikes around tankage, ability to treat contaminated
stormwater, leak detection systems for the pipelines and the use of valves
in pipelines as major preventative measures. Elevating the product pipe-
line bundle (see FEIS p. 9 & 15) further reduces the potential for
groundwater pollution. These would be used to reduce the potential for,
and resulting impact from, spills. Alpetco has further strengthened the
integrity of the diking system around tanks by committing in mitigation
item B(3), to provide impervious diking and surfacing of areas where haz-
81
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ardous materials are stored (see Section II, p. 46). Section 6.8.2, DEIS
p. 230 and 231, also presents predicted risks associated with spills from
tanks and pipeline systems. Please refer to FEIS Section II, p. 15-16,
for additional discussion that has been added concerning possible problems
resulting from groundwater pollution.
C5 EIS Section 6.8.3, Terrestrial Operation Impacts, p. 235. No mention is
made of impacts resulting from fencing along the pipeline corridor. Fences
erected to protect the pipeline may also inhibit or preclude wildlife move-
ments and, consequently, usage of large areas of habitat.
R5 No fencing is proposed along the pipeline corridor. The only fencing pro-
posed for the project is that shown on Figure 3.3-1 around the perimeter of
the plant site itself. There are, however, certain segments of the pipe-
line (see FEIS Section II, p. 9) which now are proposed to be constructed
in an above-ground configuration. This change has been made in response to
other concerns. It is not anticipated that these elevated pipeline seg-
ments would have a significant impact upon wildlife movement. They do not
cross any known migratory routes.
C6 Comment #6, on p. 3 of the letter concerning potential conflicts with some
fisheries enhancement proposals in eastern Port Valdez that are not dis-
cussed.
R6 The potential project is not considered to be in conflict with sites pro-
posed by the Valdez Fisheries Development Association for coho rearing
facilities. The two known sites closest to the proposed project are at
Corbin Creek (Glacier) and at Solomon Gulch Creek. If anything, the prox-
imity of the project facilities to these potential fishery sites would
increase their attractiveness as coho rearing areas due to the potential
for the Alpetco facility to provide a heat and power source which may be
desirable in the rearing facility. The proposed project would not be in
physical conflict with any of the streams proposed for enhancement in the
referenced March 1979 ADF&G report. The EIS assessment of impact upon
those existing streams remains the same whether or not the stream eventu-
ally is selected for enhancement.
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C7 The routing of the south access road is of major concern to the ADF&G and
is still the subject of ongoing discussion with both Alpetco and EPA.
Results of those discussions will, hopefully, be complete in time for
inclusion of the state's position in the FEIS.
R7 Please see FEIS Section II, p. 15, which represents the results of discus-
sions between the State of Alaska, EPA and other interested federal
agencies. These discussions were conducted over the past few months while
the FEIS was under preparation.
C8 Impermeability of containment dikes and pads underlying tankage and pipe-
lines is a major concern which is not adequately addressed. All tanks and
pipelines which carry potential pollutants should be both surrounded and
underlain by impermeable containment barriers. This is particularly impor-
tant for the products pipelines between the facility and the dock.
R8 Please see R4 above. The referenced sections and response in R4 adequately
address the potential severity of the problem and available precautionary
measures that are proposed. Mitigation measure B(3) indicates that Alpetco
is committed to provide impervious diking and surfacing of spill-suscep-
tible areas which should satisfy the concern on tankage in this comment.
It is premature in the engineering design phase of this project to discuss
details on the design and construction of the dikes. The committment by
Alpetco to provide impermeable surfaces on these structures is the best
assurance of precautionary measures that can be provided at this time. See
FEIS Section II, p. 15 regarding product pipeline design stipulations, and
precautions that will be taken against spills.
C9 Leak detection systems for pipelines should be addressed more specifically.
Detection systems must be capable of detecting small volume or slow rate of
leakage.
R9 See FEIS Section II, p. 11, for the additional statement added to the dis-
cussion on leak detection for pipeline systems.
83
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CIO Present plans call for burying the products pipelines in wetland areas.
Since leakage from buried pipelines is particularly difficult to detect and
control and could cause major pollution of the groundwater system, strong
consideration should be given to elevating the pipeline in vulnerable
areas.
RIO See FEIS Section II, p. 13-16. The configuration of the pipelines in these
areas has been revised to provide for elevated construction.
Cll Comment #5 on page 4 of the letter concerning scheduling construction
activities in anadromous fish streams for noncritical periods.
Rll See FEIS Section II, p. 45-49. These time period restrictions have been
included in the FEIS mitigation measures and are conditions of the NPDES
permit.
C12 Comment #6 on page 4 of the letter concerning a buried pipeline crossing of
Robe River not being justified, given the fisheries sensitivity of this
stream.
R12 See FEIS Section II, p. 9 and 15. The pipeline configuration in this area
has been modified to an elevated crossing, per the recommendation.
C13 In addition to avoidance of construction impacts, the pipeline should be
routed a sufficient distance away from bald eagle nests to preclude distur-
bance from pipeline surveillance vehicles and activities during the opera-
tion of the pipeline.
R13 The nearest the products pipeline route comes to existing eagles nests is
in an area adjacent to Dayville Road just south of Dayville Flats. Any
Alpetco traffic in this area for pipeline surveillance reasons would be
very minimal relative to total Dayville traffic. As a result, the effect
of Alpetco surveillance on existing eagle nests would be insignificant. Of
more significance would be the construction activities on the pipeline,
which would be a short-term effect, and general highway traffic increase
generated by operation of the Alpetco products dock. Even this general
84
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traffic increase, however, would be small relative to the present daily
traffic on Dayville Road.
C14 Continuous monitoring of groundwater drawdown near the heads of Corbin
Creek (Robe) and Brownie Creek should be made a requirement of the water
use permit and plans should include a committment to mitigate any fisheries
problems which may occur due to drawdown. Proposed mitigation, including
the feasibility of mitigation, should be addressed in more detail.
R14 Should groundwater drawdown endanger the natural flow in the subject creeks
during the low recharge winter season, it would be possible to mitigate
fisheries problems this could create. Section 6.2.2, DEIS p. 189, Mitiga-
tion Measure #2, discusses the two possibilities for replenishing water in
the streams. Both of these methods have been under lengthy consideration
from a feasibility standpoint, and the well water technique appears the
most likely method of supplying water to the streams. Alpetco has com-
mitted to the appropriate mitigation to achieve this. Your comment on the
water use permit is noted; however, this would have to be an internal State
of Alaska action by the Department of Natural Resources.
C15 We do not see any measurable conflict with construction work at the pro-
ducts dock near Solomon Gulch Creek. Pile driving should have no appreci-
able impact on adult migration and/or spawning, and special timing of dock
construction work (possible mitigation measure #2, DEIS p. 227) should not
be necessary.
R15 Comment so noted.
C16 Dredging activity at the temporary barge dock should be scheduled for any-
time outside of the period April 7 to June 7. Between April 7 and June 7,
there is considerable near-shore rearing activity by juvenile salmonids.
It is also recommended that suction dredges not be used in order to prevent
fish entrainment problems.
85
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Rl6 Comments so noted. See FEIS Section II, p. 45-49.
C17 Emplacement of containment booms around tanker vessels while in port should
be mandatory. The loading facility should be so designed, and spill con-
tainment procedures developed, to prevent the spread of spills which fre-
quently occur in loading operations, away from the site.
R17 We anticipate Alpetco would be required to take similar precautionary mea-
sures around their products dock as are being required during the Alyeska
tanker loading operations. Spill containment booms are on standby at the
Alyeska terminal, but are not deployed as a routine procedure during load-
ing operation. They are mobilized only during a spill incident. This also
should be an adequate procedure in the Alpetco spill control plan. Con-
tainment booms are more appropriate for crude oil spills, which have wide-
spread dispersion characteristics, than for product spills, which have more
limited natural dispersion. Lighter distilled petroleum products dissipate
much more readily through evaporation and dissolution than surface disper-
sion.
C18 Comment #1 under Technical and Editorial Comments, p. 5 of the letter.
R18 The statement on DEIS p. 104 concerning the number of stream crossings on
the preferred route was misunderstood. This paragraph was only comparing
crossings of resource streams, and the statement read "this route would
involve crossing two anadromous fish streams." It is true that there are
at least four total stream crossings, but two of these, Corbin Creek
(Glacier) and an unnamed drainage tributary, are not fish spawning streams.
Regarding the comment on sensitivity of the wetlands, please see FEIS Sec-
tion II, p. 27 and 44 for further information on mitigation and pipeline
alternatives. This section responds to comments on the wetlands as well as
those questioning the selection of this route as having the least environ-
mental impact. The right-of-way corridor for the preferred pipeline route
was selected intentionally to leave a substantially undisturbed buffer zone
between the secondary access road and pipeline route and Robe River Subdi-
vision, specifically to avoid extraneous noise and physical interference
during construction. EIS Section 6.6.1 indicates that construction sounds
86
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might be noticeable at Robe River Subdivision, but the effect would not be
serious and would be of short duration. This would also be the case if the
pipeline were to follow the Richardson Highway route. Operational traffic
from pipeline surveillance vehicles would be infrequent and should not be
noticeable in Robe River Subdivision.
C19 Freshwater Aquatic Habitats, EIS Appendix Vol. I, p. 1-276, paragraph 4
which states "attempts to capture juvenile salmon (in Robe Lake) since 1975
have been unsuccessful..." does not reflect the most recent data. In March
of 1978, coho salmon, dolly varden and stickleback were taken under the ice
with minnow traps.
R19 The information is appreciated. The conclusions were based on the result
of the ADF&G summer sampling program, but did not include information from
the winter sampling program. Substantial numbers of juvenile coho were
caught in the winter of 1978 and again in 1980, suggesting that Robe Lake
does play a significant role as winter coho salmon rearing habitat.
C20 Freshwater Aquatic Habitats, EIS Appendix Vol. I, p. 1-227, paragraph 3
states "the current value of the (Robe) lake to the substantial salmon
resources in the Robe Lake drainage is questionable without further invest-
igation." This statement tends to unnecessarily downplay the importance of
Robe Lake. The lake is definitely utilized for rearing; however, the mag-
nitude of usage has not been adequately assessed. Moreover, Robe Lake pro-
vides critical migratory access to Corbin Creek (Robe) and Brownie Creek,
both of which are highly important to the overall productivity of the Robe
Lake system.
R20 The paragraph was not intended to downplay the importance of Robe Lake to
salmon, but rather to point out the lack of data addressing the topic. The
lake probably is significant to rearing fish, as stated in the last sen-
tence of paragraph 3. Certainly the lake also is important as a migratory
corridor; this fact seemed self evident since the lake is in the path of
migrating fish.
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C21 Fish Stream Summary with Sensitive Time Periods, EIS Appendix Vol. I, p.
1-285, Table 5: the moderate sensitivity periods on the streams listed
below extend from June 1 to July 15. The rest of the year is highly sensi-
tive with eggs and/or pre-emergent fry in the gravel (See list A through N
in the comment letter).
R21 Comments so noted.
C22 Comment #5 on page 6 of the letter.
R22 Comment so noted.
C23 The state is not aware of any plans to develop an instrument landing sys-
tem, although VFR navigational aide is being considered to alleviate two
cancelled operations.
R23 The statement in Section 5.8.6, DEIS p. 185, regarding the improvement to
the airport landing system should read, "A LDA/DME (localizer type direc-
tional aide with distance measuring equipment) was installed in 1979."
C24 Comments on p. 6 and 7 of the letter regarding several surface transporta-
tion related issues.
R24 These statements are of an informative nature. Emphasis of the issues is
appreciated and the comments have been noted.
C25 Regarding DEIS p. 172, 1st paragraph - the statuatory reference used is
incorrect. It should read: Chapter 84, Section 46.40.010-210.
R25 The correction is so noted and hereby incorporated in the FEIS.
C26 Comments regarding the District Coastal Management Program.
R26 Clarification on the operation of the District Coastal Management Programs
is appreciated; the comments have been noted. Further explanation was
requested for the following statement from DEIS p. 172: "The plan is not
88
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expected to prevent development within the new residential and industrial
areas identified above, but could affect the siting of individual build-
ings." The statement is intended to indicate that the Valdez District
Coastal Management Program which now is pending final preparation probably
will not exclude development within the proposed industrial zone identified
by the City of Valdez and within which the Alpetco site is located but that
the Program's system for classifying land uses might affect the location of
components within the industrial development area.
C27 Alpetco has applied for the state Air Quality Permit and a certificate of
reasonable assurance under Section 401 of the Clean Water Act. A Solid
Waste Permit will also be necessary, but it is not germane to the project
at this time and should be applied for at a later date.
R27 As one of the requirements in the State Royalty Oil Contract regarding sub-
mittal of permit applications by December 18, 1979, Alpetco did submit an
application for a waste disposal-solid waste management permit on October
16, 1979 to the southcentral regional office of the Department of Environ-
mental Conservation. A waste disposal-solid waste permit to cover the
operation and maintenance of a solid waste incinerator was issued on
February 2, 1980. Based on Alpetco's current plans, no other activity
would require a permit.
C28 On p. 21 of the DEIS it states that low BTU gas will be 35% of the plant
fuel, on page 77 it says 25%, in the PSD application on page 3-15 it said
"major portion", and the December 11, 1979 letter from Alpetco to EPA
reported 25 percent.
R28 The correct number is 25 percent, DEIS p. 21 hereby stands corrected.
C29 On page 22 of the DEIS, it states there will be two sulfur recovery plants,
each capable of handling all of the the HgS. The PSD document does not
describe two such plants, a "large" and "small" plant are indicated.
R29 The main refinery sulfur recovery unit consists of two sulfur recovery
plants, with both in operation at all times to provide immediate access to
89
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one unit if the other shuts down. Each unit alone is fully capable of
treating all of the normal feed.
C30 The DEIS states that SO2 emissions from the sulfur recovery plant will be
100 ppm, as does the PSD application. However, the December 11 letter says
this is wrong, the S02 emissions will be 150 ppm.
R30 The EIS should be clarified to indicate that the 100 ppm refers to SO2
emissions from the Flexicoker tail gas sulfur removal unit, while 150 ppm
refers to the S02 emissions from the main refinery sulfur recovery plant.
C31 On DEIS p. 24-25, it is stated that in situ catalyst regeneration will
cause S02 emissions of about 6 tons in about 4 days. These "extra" emis-
sions, amounting to an increase of 30 percent were apparently not included
in the "worst case" impact analysis for the PSD application. This comment
is applicable to p. 302 and Appendix Vol. II as well.
R31 The comment should read, "these extra emissions amount to an increase of
0.3 percent" not 30 percent, as indicated in the comment letter. An
increase of 0.3 percent would not have a significant effect upon the worst
case impact analysis for the PSD application.
C32 On DEIS p. 33 is a table of estimated annual total pollutant emissions.
The PSD application in Table 6.3-3 lists 215 tons of CO per year from the
refinery (340 including the power plant) while the DEIS lists 1,213 tons of
CO per year from the refinery (1,335 including the power plant) as does the
November supplement. Total HC emissions in the DEIS and PSD application
are listed as 60 tons per year, while in the November supplement it is
listed as 828 tons per year, from point source tanks and terminal activ-
ities, plus an estimated 190 or 1,240 tons per year "fugitive" hydrocarbon
emissions from seals, pumps, etc.
R32 The November PSD supplement contains the correct numbers for CO and HC.
C33 On page 33 of the DEIS, the loading rate of anticipated tankers is esti-
mated to be 120-475 bbl/min (7,200 -28,500 bbl/hr) while the PSD document
90
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on page 4-6 indicates the loading rate of a 50,000 dwt tanker is about
40,000 bbl/hr.
R33 The loading rates indicated on DEIS p. 33 are correct.
C34 On page 83 and again on page 84 of the DEIS, it sates that only national
ambient air quality standards applied to the project. State air quality
standards and PSD increments also apply.
R34 This acknowledges that State Air Quality Standards as well as PSD incre-
ments also apply to the proposed project. The referenced statements do not
exclude these other standards, but rather serve to introduce a discussion
of the four sets of National Air Quality Standards which specifically apply
to this project. The state standards are referenced in Section 5.4.2
Existing Ambient Air Quality, DEIS p. 133, and they are listed in Attach-
ment C.
C35 On page 84 of the DEIS the March 15, 1978 New Source Performance Standards
(NSPS) for sulfur recovery plants are not included in the discussion of
applicable standards included in the subpart J (p.11-47 does describe the
standards.) The NSPS for stationary gas turbines are said to be proposed,
however, they were final on September 10, 1979.
R35 Comment so noted. The New Source Performance Standards for sulfur recovery
plants, as discussed in EIS Appendix II, p. 11-47, should be included as
part of the NSPS discussion, subpart J on DEIS p. 84.
C36 On page 87 of the DEIS, there is no indication that scrubbing will be used
to reduce the incinerator's SO2 emissions.
R36 Although the primary function of the scrubbing system is to remove parti-
culates, it also would control SO2 emissions.
C37 The flair's steam injection system would be more appropriately described as
a control of smoke (products of incomplete combustion).
91
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R37 Comment so noted.
C38 The best available control technology (BACT) discussion is very brief and
so general as to provide almost no information, particularly when compared
with the wastewater treatment discussion and even the description of dock
siting alternatives.
R38 An extensive report containing additional detailed BACT information was
submitted to the State of Alaska, Department of Environmental Conservation
in response to their questions on February 20, 1980.
C39 On p. 89, it says "construction wastes cannot be incinerated, but will be
disposed of in the Valdez landfill which on page 176 'is nearing capa-
city1 We wonder why incineration to reduce volume was not considered, as
Alyeska did. Similar statements appear on p. 218 and 219.
R39 This statement should be clarified to refer only to those wastes generated
prior to completion of the incinerator.
C40 On p. 219, there is no discussion that more stringent emission controls
than those briefly mentioned in 4.4.3 might be imposed.
R40 The statement that emissions would be controlled by methods described in
Section 4.4.3 was a brief reference to the more detailed discussion in the
section, Best Available Control Technology. Air emissions will be con-
trolled by employing BACT as described in this section (see "Revision to
Subpart FCCU" in FEIS Section II). This item has been the subject of
separate correspondence with the State of Alaska, and is discussed at
length in the PSD preliminary and final determinations and technical analy-
sis (see FEIS Section IV).
C41 Why is "in lieu of open burning" mentioned when pages 89-90 imply no burn-
ing will occur?
R41 The reference is intended to point out that there are several land clearing
methods that could and should be employed in preference to open burning.
92
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C42 On pages 208 through 214, PSD increments and Class I areas were mentioned
with no previous discussion to explain these complex aspects. A fairly
good introduction to PSD is given on pages 11-497 and 498 which could be
used here. The mention of Class I areas on page 214 is especially "lonely"
since there is no indication of what a Class I area is, let alone where
they are or why they were a consideration.
R42 The prevention of significant deterioration (PSD) program is a regulatory
program requiring preconstruction approval of new plants with significant
potential emissions to be built in clean air areas. PSD air quality incre-
ments are numerical limitations that restrict increases of pollution above
existing baseline concentrations. One of the chief components of the PSD
program is the area classification system. All areas in the country meet-
ing air quality standards are classified according to existing land use and
future growth goals as Class I, Class II, or Class III, with varying limi-
tations on growth for each class. The Class I category includes pristine
areas such as national parks and wilderness areas, and is subject to the
tightest control. Class II covers most of the country attaining the NAAQS
and provides for moderate industrial growth. The Act also allows for Class
III areas, where the larger PDS increment would allow more intense indus-
trial development. With Valdez being a Class II area, air emissions dis-
charged in this location must meet the specific concentrations relating to
that classification. There are not Class I areas close enough to the area
to be affected by the proposed project.
C43 On p. 235, Terrestrial Mitigation Measures do not include the possibility
that more stringent emission controls might be imposed. This omission is
particularly troublesome since Tables 6.5-1 and 6.5-2 indicate that viola-
tions of air quality standards and increments are possible.
R43 Regardless of whether more stringent emissions controls might be imposed,
the Terrestrial Mitigation Measures will remain the same. If more strin-
gent controls are imposed, the mitigation measures remain on the conserva-
tive side.
93
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C44 In part F, item (15) should have a "X" in the "not yet committed" column
since more stringent controls might be imposed.
R44 The applicant is required by law to be committed to best available control
technology (BACT) regardless of whether more stringent controls might later
be imposed.
C45 There was no discussion of odor.
R45 The odors that typically are associated with refineries are caused largely
by sulfur compounds. A second, less obvious odor in refineries is caused
by aromatic compounds. Odors are caused not solely by the presence of
sulfur or aromatic compounds within the refinery, but by their exposure and
subsequent emission to the air. Because aromatics tend to be part of the
process stream, they are not a major contributor to refinery odors. Normal
maintenance that concentrates on spills and leaks coupled with floating
roofs on product tanks will control odors from aromatics. Most of the odor
associated with refineries is due to two sulfur compounds. One is hydrogen
sulfide, produced as a result of desulfurization processes. All hydrogen
sulfide-bearing streams are combined and treated in the Claus unit of the
sulfur plant, where it is reacted to form elemental sulfur. The presence
of hydrogen sulfide emissions in any refinery is rare and must be regarded
as an extreme emergency condition. The second sulfur compound present in
refineries is sulfur dioxide, which has a characteristic rotten egg odor
similar to that of hydrogen sulfide. Sulfur dioxide (and in lesser amounts
sulfur trioxide) is a product of burning any fuel that contains sulfur.
Sulfur dioxide is therefore present in substantial amounts in any refinery
that burns liquid fuels containing sulfur. For this reason, sulfur dioxide
is a major contributor to the odors typically associated with refineries.
As documented in the sulfur emissions estimates, Alpetco would not normally
burn liquid fuels and therefore would have an unusually low sulfur emission
rate for a large, highly complex refinery.
C46 Appendix Vol. II, p. 11-296. Decoking of atmospheric and vacuum crude
heaters is said to produce CO, CO2 and Hg — is no H2O or SO2 produced?
94
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R46 All water produced is in the form of steam. Very minor amounts of S02 are
produced in the approximate range of 6 t/yr.
C47 Appendix II, p. 11-26 through 49, why does the fluid cat cracker discussion
say opacity is limited to 20% average for 5 minutes? ADEC regulations say
20% except for 3 min/hr, NSPS says 30% except for 6 min/hr -the more
stringent applies.
R47 Five minutes is incorrect. It should read three minutes.
C48 Appendix II, p. 11-46 through 49, the steam generator discussion does not
include the opacity standard (NSPS) which applies.
R48 Opacity is limited to 20 percent averaged for three minutes.
C49 Appendix II, p. 11-46 through 49, the gas turbine NSPS became effective on
September 10, 1979.
R49 Comment so noted.
C50 Appendix II, p. 11-490 says S02 emission estimates are based on 100 percent
fuel oil as worst case. Nowhere in the PSD application does it say that
SC>2 emissions are anything greater than from burning process gas (see page
4-1, 4-9 in November PSD application supplement).
R50 The 100 percent number is incorrect. The PSD application contains the cor-
rect information.
C51 The remainder of the comment letter is the pertinent excerpt of the pre-
pared text delivered at the public hearings on the DEIS in January 1980 by
the ADEC on the water quality aspects of the project.
R51 The contents of the State hearing testimony is published for information
purposes only and no response is warranted.
95
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RECEIVED
JAN 31 1980
United States Department of Agriculture
FOREST SERVICE
P.O. Box 1628, Juneau, Alaska 99802
1950
pr> V.
January 29, 1980
r
Ms. Deborah Kirk
United States Environmental
Protection Agency, Region X
1200 Sixth Avenue
L Seattle, Washington 98101
In re: M/S 443
Dear Ms. Kirk:
We have reviewed the Draft Environmental Impact Statement for
the Alaska Petrochemical Company Refining and Petrochemical Facility,
Valdez, Alaska.
No significant adverse effects to adjacent Chugach National Forest
lands are expected, other than the potential hazard associated with
additional tanker traffic. We have no specific information
relating to the facility which would further strengthen the draft.
Thank you for the opportunity to review and comment on this
document.
Sincerely,
COMMENT
NOTED
96
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United States
Department of
Agriculture
Soil
Conservation
Service
Professional Center - Suite 129
2221 East Northern Lights Boulevard
Anchorage, AK SSSOk (907) 276-^6
January 22, 1980
RECEIVED
Donald P. Dubois
Regional Administrator
U.S. Environmental Protection Agency
Region 10
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Dubois:
We have reviewed your DEIS on the Alaska Petrochemical Company, Refining
and Petrochemical Facility, Valdez, Alaska.
We find the DEIS to be well written and documented.
JAN 2 8 1980
Y-r
State Conservationist
cc: Kenneth L. Williams, Director, WTSC, Portland, Oregon,
Norman Berg, Administrator, SCS, USDA, Washington, D.C.
COMMENT
NOTED
JAM S 6 *'»80
97
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Advisory
Council On
Historic
Preservation
Received
J'^ *1 1980
This response does not constitute
Council comment pursuant to
Section 106 of the fictional Historic
Preservation Act, nor Section 2(b)
of Executive Order 11593.
1522 K Street NW.
Washington D.C.
20005
Reply to: P. O, Box 25085
Denver, Colorado 80225
~
C1
A
January 15, 1980
Ms. Deborah Kirk
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue, Mail Stop 443
Seattle, Washington 98101
Dear Ms. Kirk:
This is in response to your request of November 1, 1979, for
comments on the draft environmental statement (DES) for the
Alaska Petrochemical Company's (ALPETCO) proposed Refinery
and Petrochemical Facility, Valdez, Alaska.
The Council has reviewed the DES and notes that the Environmental
Protection Agency had determined that the proposed undertaking
will not affect properties included in or eligible for inclusion
in the National Register of Historic Places. Accordingly, the
Council has no further comment to make at this time. It is
suggested, however, that the final environmental statement
contain the Alaska State Historic Preservation Officer's
concurrence in the EPA's determination of no effect.
Should you have any questions or require additional information
regarding this matter, please contact Mrs. Jane King of the
Council staff at (303) 234-4946, an FTS number.
Sincerely,
Louia/$< Wall
Chia, Western Division
of Project Review
98
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RESPONSE TO COMMENTS BY THE ADVISORY COUNCIL
ON HISTORIC PRESERVATION
CI The final environmental statement should contain the Alaska State Historic
Preservation Officer's concurrence in the EPA's deterrainaton of no effect.
R1 A letter from the Alaska State Historic Preservation Officer appears in
Section 9.4, DEIS page 298. The letter confirms that there are no known
properties in the project area which are listed in or eligible for inclu-
sion in the National Register of Historic Places.
99
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DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION
ALASKAN REGION
r\ *-r ,r
701 C STREET BOX 14
ANCHORAGE, ALASKA 98613
RECEIVED
'"! i 0 1930
Ms. Deborah Kirk
U.S. Environmental Protection Agency
Environmental Evaluation Branch
Mail Stop 443
1200 Sixth Avenue
Seattle, Washington 98101
Dear Ms. Kirk:
We have completed our review of the draft EIS on the proposed Alaska
Petrochemical Company facility at Valdez. We offer the following
comments for your consideration as you prepare your final EIS.
~ Section 5.8.6 Transportation Systems. Air, page 175. We suggest
^ that your reference to the landing aid at the Valdez Airport be
CI rewritten as follows: "A LDA/DME (Localizer type Directional Aid with
a Distance Measuring Equipment) was installed in 1979."
~ 6.5 Air Quality Visibility Effects, page 211. Since the proposed
site appears to be less than one mile east of the Valdez Airport and
the prevailing wind is described as being from the northeast from
October through April, we suggest that the paragraph on visibility
effects be expanded to include comments on any potential impacts on
4 visibility at the airport.
Thank you for the opportunity to review and comment on your draft EIS.
Sincerely,
Chief, Planning and Appraisal Staff
100
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RESPONSE TO COMMENTS BY U.S. DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION
CI We suggest that your reference to the landing aide at the Valdez airport be
rewritten as follows: "A LDA/DME (localizer type directional aide with
distance measuring equipment) was installed in 1979."
R1 Comment so noted. The reference on DEIS p. 175 hereby is changed to the
above wording.
C2 Since the proposed site appears to be less than one mile east of the Valdez
Airport and the prevailing wind is described from the northeast from
October to April, we suggest that the paragraph on visibility effects be
expanded to include comments on any potential impacts on visibility at the
airport.
R2 The discussion on DEIS p. 211 and 213 describes potential air quality vis-
ibility effects and concludes that the impact on visibility should be
relatively minor. This conclusion also applies to potential impacts on
visibility at the airport. No impairment of aircraft activity is expected.
101
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S^TES 0»
UNITED STATES DEPARTMENT OF COMMERCE
The Assistant Secretary for Science and Technology
Washington, D C. 20230
[202) 377383t}tlx 4335
March 6, 1980
Mr. Donald P. Dubois ?
Regional Administrator •}
I 7
U.S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Dubois:
The Department of Commerce reviewed the draft environmental impact
statement by the Environmental Protection Agency relative to the
"Alaska Petrochemical Company, Refining and Petrochemical Facility,
Valdez, Alaska", and forwarded comments to you in our letter of
February 13, 1980.
Since that time, additional information has developed which is
pertinent to the project. This additional information from the
National Oceanic and Atmospheric Administration is enclosed for
your consideration.
We are pleased to have been offered the opportunity to review
this statement.
Sincerely,
7
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. »!
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3. Proposed Project
3. Land Requirements and External Appearance
4. Pipelines
* Page 14, paragraph 2. We believe this section should elaborate on the
r*A specific design and route of the product line, Figures depicting the route
of the line and the crossing sites for Corbin Creek (Robe), the Robe River,
A the Lowe River, and Abercrombie Creek should be presented.
Jf Additionally, a Site Preparation section should be included under Proposed
C5 Project which describes planned river diversions, canals and dikes in some
A detail.
4. Refinery Processes
3. Control of Waste Streams
~ Page 26, paragraph 5. The reference to contaminated storm runoff should
be expanded to define what contaminants could be involved. Physical separation
C6 of oil and grease from this water may not be an acceptable method of treat-
ment in certain cases. This section should identify a snow removal disposal
A site and discuss treatment of runoff from this site.
8. Spill Prevention and Control
~ Page 51, paragraph 4. Containment dikes should be discussed in detail, including
specific assurance that diked impoundments would have the capacity for con-
C7 taining all petroleum products plus record amounts of rainfall or snowmelt
runoff. Inadequate dike capacity has been a common cause of pollution in other
A locations where tanks or lines have ruptured.
4. Alternatives
3. Plant Design Alternatives
7. Alternate Products Dock Sites
~ Page 102, paragraph 6. The research plans for FY 1982 by the NOAA office of
Marine Pollution Assessment may not be implemented and would have no specific
relationship to the proposed ALPETCO project. The paragraph should be re-
A written to reflect the above information.
5. Existing Conditions
6. Ecosystems
General. This section presents many concepts and discussions which have been
over-simplified or inaccurate. Source references are often lacking, and much
of the material is not relevant to the subject of potential environmental effects
of the proposed refinery. We offer the following to assist in its revision.
104
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~ Page 140, paraqraph 2. Much of this section describes the entire Port
C9 Valdez area, and the boundaries of the "study area" should be extended
A to the west.
1. Elements of the Ecosystem
~ Page 141, paragraph 1. Variations in barnacle densities vary more by rock
surface texture (smooth vs rough), local differences in aspect relative to
wave impact (creating a localized shearing effect of waves and wave born
p«ff\ debris) and differences in the intensity of predation by starfish (Evasterias)
'"and snails (Thais). The assertion that sea star abundance is dependent on
salinity is questionable, especially for Evasterias troschelii, one of the
most common species. Seasonal variations in densities also depend to a great
A extent on mortality rates.
141, paraqraph 2, Observations by the NMFS indicate that kelp cover
vll may vary from 100 percent in some areas to 0 percent in others. The range
A of "15 to 55 percent" should be documented and clarified.
* Page 141, paragraph 3. There is a large assemblage of filter-feeders on the
£*(2 Dayville Flats at the east end of Port Valdez, including mussels and filter-
feeding polychaetous annelids. The mollusk, Macoma balthica, which is very
A abundant, is a filter-feeder as well as a deposit-feeder.
£13 Page 141, paragraph 4. A Dungeness crab population supports an important
4 recreational fisheryand formerly supported a small commercial fishery.
Cj4
C]5
Page 142, paragraph 4. Alexander is not listed as a reference in Appendix A.
Page 142, paragraph 5. Smith and Stoker is not listed as a reference in
Appendix A.
~ Pacific herring spawn on Fucus around the perimeter of Port Valdez, All
_ salmon species except kings spawn in Port Valdez streams and occur seasonally
C16 as both juveniles and adults. Anadromous salmon are not normally considered
to be either "pelagic" or "marine" and their importance in Port Valdez is not
4 adequately stressed in the paragraph.
~ Page 144, paragraph 2. The last paragraph on page 143 describes primary
productivity in Port Valdez as "impressively high," while the next paragraph
on page 144 calls primary productivity within Port Valdez "low." This
discrepancy should be clarified or corrected.
The statement that primary productivity is low may not apply to the salt marsh
***** ecosystem near the landward end of the estuary. Salt marshes are generally
1-1/ considered to be highly productive systems. The paragraph seems to imply that
all of Port Valdez should be classed as low in primary productivity. Some
Port Valdez sites, such as the salt marsh and the Mineral Creek flats with
abundant mussel beds, are examples of highly productive systems, Many energy
inputs to estuaries are terrestrially derived and detrltal material 1s not
necessarily bound up 1n the sediments but provides microorganism enrichment
which contributes to the food supply of deposit-feeders.
105
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No evidence is presented that the Port Valdez estuary is low in productivity.
Statements are apparently based on the assumption that because light in the
marine environment is seasonally limited by glacial flour from streams during
the late spring and summer months phytoplankton blooms must be inhibited,
therefore resulting in low primary production. The rapid growth of abundant
marine benthic macro-algae during the winter months when glacial flour is absent
is not recognized. Spring phytoplankton blooms occur prior to the drop in water
transparency caused by glacial runoff in Port Valdez.
C17 The statement that low-levels of primary productivity reflect low species
diversity is not necessarily correct. It does not follow that one is related
to the other; in fact a substantial body of recent evidence suggests that
productivity and diversity are negatively correlated. The frequency of popu-
lation reduction is a more important influence on diversity.
An example of a highly productive system within Port Valdez is the Dayville
mudflats, where densities of the Macoma balthica are equal to some of the
highest reported in the literature, exceeding 5,000/m2, and densities of
harpacticoid copepods are equivalent to those on productive tideflats in south-
it ern British Columbia.
* Page 144, paragraph 3. Benthic suspension feeders (e.g. mussels) filter
riftphytoplankton as well as suspended organic matter so the two systems are not
^ ""necessarily sharply divided. Mussels are abundant at many intertidal sites
A in Port Valdez.
Page 144, paragraph 4. Dabbler ducks, geese, and marine snails should be
added to the list of animals which use the marshes and mudflats extensively.
4. Commercial, Recreational, and Subsistence Use of Systems
Page 155. No mention of subsistence activity, per se, occurs here.
8. Socioeconomics
5. Land Use
* Page 164. paragraph 3. The statement concerning a major decline in fish
^/%-stocks is not true. Fish stocks are cyclical and there is no evidence that
CZ I Prince William Sound is any less productive than it ever was. A record run
A and commercial catch of pink salmon occurred in 1979.
6. Environmental Consequences
3. Oceanography
2. Operation Effects
~ Page 197, paragraph 2. Transport of dissolved hydrocarbons should be discussed
in addition to surface slicks, since refined products, high in water solubles,
would be the main potential source of spills from the product dock area.
A Absorption to bottom sediments should be discussed, as it is on p. 226, para. 4.
106
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4. Wastewater Discharge
1. Impacts of Wastewater Discharge
~ Page 200. We believe this section should discuss the existing Alyeska
effluent discharge, addressing how it differs from the proposed ALPETCO
C23dl'scharge' anc' potential for additional environmental impact caused by
A**the combined discharge and possible synergistic effects (since the Alyeska
effluent moves counter-clockwise in Port Valdez toward the vicinity of the
~ ALPETCO diffuser discharge point.)
~ Page 204, paragraph 2. Oil and grease method is not an adequate method
for measuring total hydrocarbons. Effluent should be characterized by Gas
C24chromotography, including heavy metals, total aromatic hydrocarbons, total
monoaromatics, total polyaromatics, and individual compounds benzene,
A toluene, xylene, napthalene, etc.
~ Page 204, paragraph 5. Accumulation of hydrocarbon, Ni (Nickel), and other
C25heavy metals in sediments around the diffuser is likely to occur, providing
A the potential for accumulation in the food web.
Cj6
Page 207, paragraph 1. Flatfish do not actively avoid petroleum hydrocarbons.
8. Ecosystems
1. Marine
^^^.Paqe 220, paragraph 5. There is an error in the sentence which ends at top
v-2/of p. 221. Salmon do not spawn April to mid-May in Solomon Gulch Creek. Per-
¦A haps the statement was intended to refer to fry migration from the stream.
C^8
Page 225, paragraph 5. Reproductive stages of macro-algae are sensitive to
low-levels of hydrocarbons.
7. Mitigation Measures
2. Monitoring Programs
~ General. This section on monitoring should be specifically cross referenced
to Attachment B, Draft NPDES, pp. B-36-B-57 (especially p. B-55 describing
intertidal monitoring).
C29 a requirement for ALPETCO to provide funds for monitoring would be desirable,
since NMFS is no longer being funded by the U.S. Fish and Wildlife Service to
continue the intertidal monitoring, Perhaps future costs could be shared by
A ALPETCO and Alyeska; this is implicit in the NPDES.
~ Attachment B; p. B-55, 56, 57. The provision for monitoring biological
populations and water quality is excellent. We suggest that an additional
point be added to 2, a. (2). Biological Studies of Individual species line 5,
C30as follows: ."and (c) mortality, including quantitative estimates of the
abundance and distribution populations of Macoma and associated organisms, and
comparisons with previous estimates gathered over the past 10 years at the
NOAA/NMFS Dayville monitoring site."
107
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C30
We suggest this addition for the following reasons: Recognition of
sublethal effects of effluent based only on changes in health is only
correlative evidence, dependent on coincidence of health changes with
increases in toxic substances in the tissues of organisms. Correlation
does not necessarily prove that the toxic substances are responsible for
a change in health. A hypothetical example of this problem would be a
decline in growth rate of Macoma and an increase in toxic substances in
the tissues, when the decline in growth was the result of reduction of
the food supply available to the organisms, i.e., toxic substances
reduced the bacterial or plankton populations the clam utilizes for food
without directly affecting the clam.
It is therefore important to monitor the abundance and distribution of
the population (not only the health of individuals). For example, the
clams may surface due to the presence of a toxic substance and disappear
as a result of predation. The only useful evidence in such a case would
be data which show a decrease in abundance coinciding with an increase
of refinery-derived substances in the environment.
Annual and seasonal population estimates at the NOAA/NMFS site from
1970-79 show a remarkably stable population of large Macoma at the
higher tidal elevations. With this backlog of data, any later change in
the abundance or distribution of the clam population would be measur-
able, and studies to determine the cause could be implemented. (See
A Attachment B; p, B-55 in Section 2, a. (2) under mortality.)
~ Sufficient leeway should be incorporated in the permit to initiate addi-
tional studies on particular aspects of the biology of the mudflat
¦ community to evaluate changes in population abundance or health of
A individuals within reasonable limits in terms of time and cost.
C$2 Page B-56. Reference - Stekoll, Clement and Shaw.
Page B-56. Add: "Macoma shall be . . . from the Old Valdez dock to an
a mtertTdal location near the diffuser."
~ Page B-57. (2). We suggest SDecifvinq Mytilus edulis or Limanda aspera
C34 (yellowfin sole) as additional species. NMFS has previous data from
A Port Valdez on hydrocarbon levels in these species.
C$5 Page B-57. Footnote 2, paragraph 1. (Lees, et al.) is missing.
CLEARANCE: / . , ,o , SIGNATURE AND DATE:
/ —Sv-? i(/ ¦¦ r — —
( , F/HP:JWRote ~r WUy- ,v ->
108
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RESPONSES TO COMMENTS BY U. S. DEPARTMENT OF COMMERCE,
NATIONAL MARINE FISHERIES SERVICE
CI We believe that two activities not described at length in the DEIS are
highly important to the safe construction and operation of the project.
These are the development of an oil spill contingency plan and establish-
ment of an interdisciplinary team to review plans for all stream crossings.
We assume input from NMFS and other resource agencies will be sought during
development of these two matters.
R1 In the mitigation measures summary, items 26 and 30 on DEIS p. 269-270 and
items D(l) and E on FEIS p. 47 and 48, Alpetco is committed to develop both
of these plans. Both matters must include input from NMFS and other rele-
vant resource agencies.
C2 The term "grassroots" refinery should be defined.
R2 A grassroots refinery is an entirely new facility built from the ground up
as compared to the modification or expansion of an existing refinery.
C3 Section 2.1 should describe the 5,000 barrel discrepancy between crude
input and total daily refined product output, and the eventual fate of this
material.
R3 The proposed facility would process 150,000 bpd of crude oil into approxi-
mately 145,000 bpd of refined products. The by-product fuels burned for
energy requirements in the plant account for the discrepancy of 5,000 bar-
rels per day. Most of the fuels burned in the plant are not commercially
marketable from this location.
C4 Section 3.4.1, p. 14, we believe this section should elaborate on the spec-
ific design and route of the product line. Figures depicting the route of
the line and the crossing site for Corbin Creek (Robe), the Robe River,
Lowe River and Abercrombie Creek should be presented.
109
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R4 The right-of-way corridor shown on Figure 3.2-2, DEIS p. 9, indicates the
route of the product pipelines and crude supply line. Figure 3.3-5, DEIS
p. 16, shows the sizes, functions, and configurations of the pipeline in
both the buried and elevated modes. A leak detection system is planned as
are cutoff valves at important stream crossings (see FEIS Section II,
p. 11). It is premature to present more definitive engineering design on
the pipeline system at this time. The pipeline system would cross Corbin
Creek (Robe) and the Robe River in an elevated mode and cross the Lowe
River and Abercrombie Creek in a buried mode (see FEIS Section II, p. 15).
C5 A site preparation section should be included under the proposed project
section which describes planned river diversions, canals and dikes in some
detail.
R5 EIS Attachment B (p. B-114 and B-115) shows a map of the proposed flood
control levee, drainage, ditching and proposed diversion of Slater Creek.
There are also cross section details showing a method proposed for con-
struction of these items. It is premature to present more definitive
engineering designs at this time.
C6 The reference in Section 3.4.3, DEIS p. 26, to contaminated storm runoffs
should be expanded to define what contaminants could be involved. Physical
separation of oil and grease from this water may not be an acceptable
method of treatment in certain cases. This section should identify a snow
removal disposal site and discuss treatment of runoff from the site.
R6 Physical separation alone of oil and grease from contaminated storm water
would not be an acceptable degree of treatment. However, this effluent
then would pass through the biological treatment system (see Wastewater
Treatment Flow Diagram, Figure 3.4-3, DEIS p. 32) which would complete the
treatment process and would meet the effluent limitation requirements. The
contaminants in the storm water runoff are similar but are present in
lesser amounts to those in other waste streams in the refinery and could
consist of anything from oil and grease to a wide array of hydrocarbon
materials. It isn't normally of great concern to know exactly what all the
110
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constituents are because the skimmers, separators and biological treatment
system will treat this influent to acceptable standards. The snow that
falls within the process area and is susceptible to contamination would be
melted rapidly due to escape heat from the refinery systems. Consequently,
this snowfall would be handled as contaminated storm runoff, rather than
bulk snow removal. Snow removed from non-contaminated areas would be dis-
posed of in the area identified for snow storage on Figure 3.3-1, DEIS p.
10.
C7 Containment dikes should be discussed in detail, including specific assur-
ance that diked impoundments would have the capacity for containing all
petroleum products, plus record amounts of rainfall or snowmelt runoff.
Inadequate dike capacity has been a common cause of pollution in other
locations where tanks or lines have ruptured.
R7 The project description is revised to state that impervious containment
dikes would be provided with provisions for additional rainfall and snow-
melt capacity as stated in your comment (see FEIS Section II, p. 11).
The engineering and construction details that would be employed to achieve
this criteria are not yet identified. The lack of cohesive, relatively
impervious clay-type soils in the Valdez area, which would be a key element
in conventional dike construction, will necessitate detailed consideration
for alternate construction techniques for these containment dikes. For
this reason particularly, it is premature to know the detailed method of
design and construction of the dikes.
C8 Regarding EIS Section A.3.7, p. 102, the research plans for FY 1982 by the
NOAA Office of Marine Pollution Assessment may not be implemented and would
have no specific relationship to the proposed Alpetco project. The para-
graph should be rewritten to reflect the above information.
R8 Thank you for the information on this item. The statement in the EIS was
intended only to acknowledge that a possibility exists that a relevant mon-
itoring program would be undertaken. No specific relationship to the
Alpetco project should be implied.
Ill
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C9 EIS Section 5.6, much of this section describes the entire Port Valdez area
and the boundaries of this study area should be extended to the west.
R9 The descriptions in Section 5.6 of Existing Conditions in the described
study area would also apply in part to other locations in the greater Port
Valdez area. Because the specific study effort, and especially the field
observations and sampling, were intended for and done in only the described
study area, it would be inappropriate and possibly inaccurate in some
selected cases to extend the study boundaries west, which would suggest
that the description applies to the entire Port Valdez area with the same
degree of confidence as the original study area.
CIO Comment from page 3 of the letter concerning DEIS p. 141, paragraph 1.
RIO Your comments have been noted and the paragraph has been rewritten to
accommodate the comments. See FEIS Section II, p. 22.
Cll Page 141, paragraph 2: Observations by the NMFS indicate that kelp cover
may vary from 100 percent in some areas to 0 percent in others. The range
of "15 to 55 percent" should be documented and clarified.
Rll The original statement, "Kelps visually dominate with about 15 to 55 per-
cent cover depending on the season" is hereby modified for clarity to read
"In those areas where kelp are present, they visually dominate with sea-
sonal averages ranging from 15 to 55 percent cover." Please see FEIS Sec-
tion II, p. 22.
C12 Page 141, paragraph 3: There is a large assemblage of filter-feeders on
the Dayville Flats, including mussels and filter-feeding polychaetous
annelids. The mollusc, Macoma balthica, is a filter-feeder as well as a
deposit-feeder.
R12 Thank you for the information. The second sentence of that paragraph has
been modified for clarity. Please see FEIS Section II, p. 23.
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C13 Page 141, paragraph 4: A Dungeness crab population supports an important
recreational fishery and formerly supported a small commercial fishery.
R13 The DEIS p. 156 indicates a minor subsistance fishery exists for Dungeness
crab and halibut. However, the following sentence should be added to the
referenced paragraph for clarity: "Dungeness crabs also are present and
support a significant recreational fishery."
C14 Alexander is not listed as a reference in Appendix A.
R14 The reference is inserted in the FEIS. See Section II, p. 57.
C15 Smith and Stoker is not listed as a reference in Appendix A.
R15 The reference is inserted in the FEIS. See Section II, p. 57.
C16 Page 142, paragraph 5: Pacific herring spawn on Fucus around the perimeter
of Port Valdez. All salmon species except kings spawn in Port Valdez
streams and occur seasonally both as juveniles and adults. Anadromous
salmon are not normally considered to be either pelagic or marine and their
importance in Port Valdez is not adequately stressed in the paragraph.
R16 The importance of salmon species was not intentionally overlooked in this
discussion; rather, since project related concerns deal primarily with the
spawning and rearing grounds of the salmon, the salmon discussion is pre-
sented under the section on freshwater systems. However, further reference
in this section and mention of the herring would be appropriate, and the
paragraph has been revised accordingly. Please see Section II, p. 24.
C17 Page 144, paragraph 2: Concerning primary productivity in Port Valdez.
R17 The referenced discussion on primary productivity is somewhat confusing.
The matter has been clarified with a revision which appears in Section II,
p. 25.
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C18 Page 144, paragraph 3: Benthic suspension feeders such as mussels filter
phytoplankton as well as suspended organic matter, so the two systems are
not necessarily sharply divided.
R18 The intent was not to suggest a sharp division between the systems. The
first sentence of that paragraph should be qualified to read as follows:
"Energy pathways in Port Valdez are divided into two primary systems."
Please see FEIS Section II, p. 25.
C19 Page 144, paragraph 4: Dabbler ducks, geese, and marine snails should be
added to the list of animals which use the marshes and mudflats exten-
sively.
R19 Thank you for the information. The first sentence of the referenced para-
graph has been expanded. Please see FEIS Section II, p. 26.
C20 Page 155: No mention of subsistence activity per se occurs here.
R20 Subsistence activity is mentioned at the top of DEIS p. 156. Recreational
use is much more important than subsistence; therefore, there is little
need to stress subsistence aspects.
C21 Page 164, paragraph 3: The statement concerning a major decline in fish
stocks is not true. Fish stocks are cyclical and there is no evidence that
Prince William Sound is any less productive than it ever was. A record run
and commercial catch of pink salmon occurred in 1979.
R21 Please see FEIS Section II, p. 30, for a revision of the referenced para-
graph.
C22 Page 197, paragraph 2: Transport of dissolved hydrocarbons should be dis-
cussed in addition to surface slicks, since refined products, high in water
solubles, would be the main potential source of spills from the product
dock area. Absorption to bottom sediments sould be discussed as it is on
p. 226, paragraph 4.
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R22 Given the present level of knowledge about the action of refined products
in seawater and about the transport of dissolved hydrocarbons, together
with the extreme variability of spill circumstances, we feel that further
qualification or quanitification is not possible with any degree of reli-
ability. It seems reasonable to assume that the same factors which affect
surface slick movement would play a role in the transport of refined pro-
ducts. The possibility of absorption to bottom sediments is not discussed
in this section because the section concerns itself only with the effects
of spills as they relate to circulation. The effects of spills on living
organisms, due to such factors as absorption to bottom sediments, appropri-
ately appears in the section concerning impacts on marine organisms (DEIS
p. 220-228)(See also FEIS Section III, p. 86, item R17).
C23 DEIS p. 200: This section should discuss the combined Alyeska and Alpetco
discharges and any possible synergistic effects.
R23 The two discharges are nearly two miles apart. Considering the average
daily discharge volume for the two facilities, the distance between them
and the size and flushing characteristics of the receiving waters, it is
not expected that the total effects of the two discharges would be any
greater than the sum of the two parts. Further study of this possibility
would not be warranted.
C24 Page 204, paragraph 2: Oil and grease method is not an adequate method for
measuring total hydrocarbons.
R24 True. However, the referenced paragraph addresses only oil and grease,
and is not intended as a discussion of the treatment technology for total
hydrocarbons. The NPDES permit establishes limitations for numerous
effluent consitituents and establishes monitoring and reporting require-
ments to ensure these standards are achieved. The permit also requires use
of gas chromatography/mass spectrophotometry for measuring total hydrocar-
bons. Please see the Draft NPDES permit in Attachment B, pages B-37 -
B-67, particularly p. B-47, and the final permit in Section IV, FEIS
p. 160.
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C25 Page 204, paragraph 5. Accumulation of hydrocarbon, nickel, and other
heavy metals in sediments around the diffuser is likely, providing poten-
tial for accumulation in the food web.
R25 The topic of toxic materials in the sediments versus benthic organisms and
subsequent food web transfers is adequately discussed on pages 205-206
under the heading, "Overall Ecological Impacts." Exposure to nickel is
mentioned specifically in Section 6.4.3.
C26 Page 207, paragraph 1: Flatfish do not actively avoid petroleum hydrocar-
bons .
R26 Comment noted.
C27 Page 220, paragraph 5: There is an error in the sentence which ends at the
top of p. 221. Salmon do not spawn April to mid-May in Solomon Gulch
Creek. Perhaps the statement was intended to refer to fry migration from
the stream.
R27 Thank you for the comment. That statement indeed was intended to refer to
the period of out-migration of fry. Pink salmon spawn there from late June
to late August with activity peaking in late July.
C28 Page 225, paragraph 5: Reproductive stages of macro-algae are sensitive to
low levels of hydrocarbons.
R28 Comment noted.
C29 This section on monitoring should be specifically referenced to Attachment
B, draft NPDES permit.
R29 The discussions indicate air and qater quality monitoring will be according
to provisions of the NPDES and PSD permits. Final versions of theBe per-
mits appear in Section IV of this FEIS. Monitoring discussions in the
NPDES permit begin on p. 167. PSD compliance monitoring is discussed on p.
232. Alpetco is required to develop and implement the studies in Section E
116
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of the NPDES permit and Approval Condition 5 of the PSD permit. Alpetco
will bear the costs of the development and implementation of the monitoring
program.
Remaining comments in the letter concern the draft NPDES permit, and the
responses are contained in Section IV. Please see p. 152.
117
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ER-79/1178
RECEIVE
United States Department of the Interior i, • REGION >
OFFICE OF THE SECRETARY \ 3 1900
P. O. Box 120
Anchorage, Alaska 99510 WATER DIVISION
February 8, 1980
Mr. Donald P. Dubois
Regional Administrator K F ? f; Tt*
Environmental Protection Agency
1200 6th Avenue ; t. '¦ r\ ivjq
Seattle, Washington 98101 ...
Hit:, KM.
V.
Dear Mr. Dubois: ' '' "VtTQft
In response to your recent request, we have reviewed the Draft
Environmental Impact Statement for Alaska Petrochemical Company's
(ALPETCO) Refinery Complex and Support Facilities.
In terms of overall content, we believe the Draft Environmental
Impact Statement sufficiently addresses most of the environmental
issues of concern to this department. However, there are certain
sections of this statement in which we believe additional informa-
tion should be provided. We offer the following specific comments
for your consideration.
~ Section 3.5.3 (Page 37) Pipeline System:
:i It should be clarified whether the crude oil pipeline, between the
Alyeska Pipeline connection and the point of intersection with the
A products line bundle, will be above ground or buried.
~ Section 3.5.4 (Page 38) Products Dock:
We suggest this section be expanded to discuss where oil, fuel
and/or ballast water will be temporarily stored. We believe it
best that petroleum products be stored within the site complex
and not on the products dock. Dock storage of petroleum products
would increase the chance for spills and/or leakage caused by
A seismic activity within the port.
~ Section 3.5.5 (Page 39) Transportation - Marine:
We believe the length of the tldelands lease should be discussed.
The Corps of Engineers' Public Notice (Port Valdez 85) states that
:3 a portion of the dock will be removed; it will not be reverted to
** city ownership as indicated in the statement. Clarification of
this issue is needed. . We recommend that the final statement include
an assessment of the environmental damage which may result in removing
A the dock, should this be an alternative. HECEIVED
r B 14 1980
118
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Section 3.8 (Page 51) Spill Prevention and Control:
Paragraph two mentions specific design parameters involved in spill
prevention. This section should be expanded to consider installing
emergency shut-off valves at all stream crossings.
The contingency plan for spills does not include spillage of hazardous
solid waste products (i.e. sulfur, spent catalyst) being removed
from the plant site. We suggest that the plan be expanded to include
procedures to handle possible spillage of solid waste between the
plant site and the waste disposal site (or manufacturer, if returned).
Section 4.3.4 (Page 88) Alternate Methods of Solid Waste Disposal -
Available Disposal Techniques:
This section should be expanded to discuss whether hazardous waste
disposal sites are planned within the Valdez area. We recommend
that if a hazardous waste disposal site is needed that it be located
within the plant perimeter and away from streams intersecting the
perimeter boundary. Containment barriers should be constructed
around all liquid hazardous wastes.
Section 4.3.8 (Pages 103-104) Alternate Transportation Routes:
We believe design criteria for each alternative should be included
in this section. This is particularly important for Alternative #3
which concerns a major floodplain. Design criteria for the bridge
and access road from the Glacier Stream Haul Road to the plant site
should be discussed in detail.
We believe Alternative #2 would be the most environmentally acceptable
route. This route would utilize the existing levee off the Richardson
Highway, adjacent to the east side of Valdez Glacier Stream, and
eliminate the need for a bridge across Valdez Glacier Stream and its
floodplain. However, if the primary access route (Alternative #3)
is selected, pertinent flood control design criteria should be
included for review.
We believe the discussion on pipeline crossings should be expanded.
Time of crossing, spawning areas, and siltation should be fully
discussed. We recommend that stream crossings be conducted between
1 June and 15 July so as not to disrupt fry emergence and spawning
activities. Construction work (in-water) outside of this time
period could result in extreme sedimentation in the downstream
spawning areas which would seriously inhibit aeration within the
spawning gravel. In addition, we recommend elevating the pipeline
crossing of the Robe River above the stream or rerouting it to
alleviate severe siltation within a major spawning area.
We suggest you consider the feasibility of an alternative route for
the pipeline bundle. A possible route would be Alternative #2,
paralleling our proposed access route along the existing levee, via
the Richardson Highway. In-water construction would be permissible
in the Lowe River between 1 March and 15 June due to the reduced
water flow during this period.
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3
Section 5.2.2 (Page 120-122) Groundwater:
~ The final statement should utilize data that can be derived from
tests (such as the test pumping described on page 121) to determine
the hydraulic characteristics, especially coefficients of trans-
missivity and storage, for the unconfined aquifer. From these
characteristics, the ultimate drawdown over a season of almost zero
recharge or over the life of the facility could be calculated. The
reported four feet of drawdown at a distance of fifty feet from a
well pumping up to two thousand gallons per minute for 72 hours is
somewhat characteristic of a slow-draining, unconfined aquifer; this
figure does not necessarily indicate the ultimate effects of operating
withdrawals.
The nature, thickness, and probable distribution of materials between
the confined and unconfined aquifers (pages 120-122), as indicated
by logs of wells and test holes, should be discussed. This would
permit an evaluation of the significance of leakage between the
aquifers. Aquifer characteristics based on the testing mentioned
(page 122) should be included to permit evaluation of the potential
A for impacts.
~ Section 5.3.5 (Page 127) Sedimentology:
The dilution and discharge studies conducted do not seem adequate to
explain effluent movement. It is understood that studies were only
C 1 1 conducted when stratified conditions existed. We believe that dye
plume tests should be conducted in winter, when the water column is
not stratified, to predict effluent dispersal. This would give a
better indication of dispersal when the water column is not well
A mixed.
Section 5.6.1 (Page 146-147) Elements of the Ecosystems:
~ Information on primary productivity in the Valdez Glacier Stream is
lacking and assumptions are inferred by the following statement
contained in the draft: "Detailed information on ecosystem struc-
C12 ture is lacking. Production of the plants and stream dwelling
Invertebrates can be assumed to be small." We believe the assess-
ment of the biological factors inherent in this stream should be
A expanded in the final statement.
~ It is mentioned in the draft statement that the Lowe River should be
considered highly productive, yet components of the system, except
for spawning data, are poorly known. The statement that ..biologi-
cal communities are probably well-developed" should be explained.
We suggest that the procedures for assessing riverine ecosystems be
A discussed.
_J Section 5.6.4 (Page 156) Commercial, Recreation, and Subsistence Use
14 of Systems - Terrestrial:
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4
C14
C15
We suggest that the statement address the appropriateness of restrict-
ing the discharge of firearms within a specified radius of the plant
site, pipeline routes, and products dock to lessen the chance of
damage to the system and possible environmental contamination. High
powered rifles may have the potential to puncture the products and
crude oil pipeline (this has been the case concerning the Alyeska
pipeline).
Section 5.8.5 (Page 173) Land Use - Land Use Planning:
Reference is made to a one-year study to refine the Department of
Housing and Urban Development - Federal Insurance Administration
maps concerning flood potential and the 100-year floodplain. It
should be further discussed as to how the new information will be
~ used.
~ Section 5.8.7 (Page 176) Utilities Systems - Solid Waste:
It is mentioned that ALPETCO may utilize the city's landfill site
for some non-hazardous solid waste. Since the present city land-
fill is nearing capacity, we suggest that alternative disposal
A measures be discussed.
~ Section 6.1.2 (Page 179) Long Term Effects:
In the event of an earthquake, liquefaction in the area of the pipe-
^ line system may result in a great risk to the environment. The
C1/ draft statement seems to circumvent this problem by suggesting
several mitigation measures which could be implemented. We believe
these after-the-fact measures do not adequately address the initial
liquefaction problem. We suggest that you provide more detail
A regarding this concern.
Section 6.4.1 (Page 200) Impacts of Wastewater Discharge:
~ This new operation will begin without knowledge of specified pol-
lutant concentrations in the discharge. This makes it extremely
difficult to assess potential Impacts to fish and wildlife resources
or to recommend specific stipulations. The best practical techno-
logy (in effluent design) as required by the Environmental Protec-
tion Agency does not insure protection of marine resources, Pollutant
loading in Port Valdez may present a very real threat in future years.
We suggest the statement indicate what baseline studies, monitoring,
and review will be accomplished to help understand the ongoing cause
and effect relationships the introduced contaminants will have on
the estuarine system.
The estimated concentration of ammonia would probably cause no
significant harm to fish or wildlife, but should it be at or nearly
at the daily limitations specified we would have cause for concern.
Toxicity of ammonia has been demonstrated to increase with increased
salinity. Therefore, it is believed that standard accepted ammonia
concentrations may be too high for sufficient protection in the
C18
121
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marine environment. Even if a sufficiently high dilution factor is
achieved along the boundaries of the mixing zone, the ammonia concen-
trations, if at or near the discharge level limit presently proposed,
would exceed accepted safe levels. We therefore suggest you discuss
the modification of allowable discharge limits for ammonia.
Chromium may also approach toxic limits, in which case we would
Vrf lO again be concerned. Not only has chromium been reported toxic to a
variety of marine flora and fauna, it has also been reported to be
bioaccumulative. Cyanide concentrations in the water column should
not exceed 5 mg/1.
We strongly urge that bioassays be conducted to determine maximum
allowable concentrations of these compounds. We suggest that these
A key concerns be addressed in the final document.
~ Section 6.5 (Page 208) Air Quality:
Conflicting ideas exist concerning potential impacts from air pollu-
tants due to industrial emissions. We believe there is a need for
further study in this area. Knowledge about SO- loading, particu-
late problems, and related contaminant impacts In the Valdez area
C19 can only be termed "speculative." The Department of the Interior,
through the Fish and Wildlife Service's Office of Environmental
Contaminant Evaluation, has proposed baseline studies to examine the
air contamination issue. The objectives of this study are outlined
in the Department of Interior's comments regarding the Prevention of
Significant Deterioration permit application. This proposed study
A should be addressed in the final statement.
~ Section 6.8.1 (Page 223) Marine - Construction Barge Dock:
It is important that timing for construction be compatible with
pnA salmon spawning and rearing in adjacent streams. Dredging should
not occur between 7 April and 7 June. We also believe it important
that dredging be performed by "clamshell" dredge and that spoil
material be deposited at a specified upland site. We suggest these
A points be discussed in this section.
~ Section 6.8.2 (Page 229) Freshwater - Operation Impacts:
The continuous use of water drawn from on-site wells may lower
groundwater levels, thus affecting the amount of available water in
C21 Corbin Creek (Robe) and Brownie Creek. No information on ground-
water was obtained during the winter. This period is critical to
the survival of salmon eggs in these two streams. We recommend that
the groundwater study be expanded to assess the impacts of ground-
4 water fluctuations during the winter months.
Section 6.10.6 (Page 246) Land Use - Recreation:
~ The Draft Environmental Impact Statement appears to be incomplete in
C22 its discussion of project related impacts to existing and/or planned
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6
recreational opportunities at or adjacent to the proposed facility,
products dock, and construction barge dock. The final statement
should identify any recreation impacts (including mitigation measures
and the enhancement of recreatopn opportunities), or clearly state
that there are none. For example, the Lower Solomon Gulch Falls,
22 adjacent to the proposed products dock, is recognized as a major
scenic resource. However, there is no clear indication of the
degree of impact, if any, that the project will have on those who
wish to visit the resource. The potential impacts to recreational
boaters from the increased marine traffic associated with the con-
struction and operation of the project should also be discussed.
We believe the draft adequately addressed cultural resources.
Additional Departmental comments will be provided by the U.S. Fish
and Wildlife Service after review of the Corps of Engineers Section
402 and Section 10/404 permit applications. These comments will be
mainly concerned with roadway/pipeline access routes, construction
barge dock, wastewater outfall pipe, and stream diversions. As we
have indicated in our above review comments, we believe more
detailed information is needed on these aspects of the proposed
project. For your convenience, we are also attaching an outline
identifying the key points for which additional information is
needed in order for us to complete our review of the permit appli-
cations, Please send this information to the Area Director, U.S.
Fish and Wildlife Service, 1011 East Tudor Road, Anchorage, Alaska
99503.
Thank you for the opportunity to comment on this draft statement.
We hope our comments will be helpful when preparing the Final
Environmental Impact Statement.
Sincerely,
Regional Environmental Officer-Alaska
Enclosure
The referenced attachment concerns Sections 10 and 404 permits
and is reprinted and responded to in Section IV. Please see p. 255.
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RESPONSE TO COMMENTS BY THE U.S. DEPARTMENT OF THE INTERIOR
CI It should be clarified whether the crude oil pipeline, between the Alyeska
pipeline connection and the point of intersection with the products line
bundle, will be above ground or buried.
R1 The crude oil supply line would be buried from the Alyeska pipeline connec-
tion to the Richardson Highway, and would be elevated from the Richardson
Highway to the plant site.
C2 We suggest this section be expanded to discuss where oil, fuel and/or bal-
last water will be temporarily stored. We believe it best that petroleum
products be stored within the site complex and not on the products dock.
Dock storage of petroleum products would increase the chance for spills
and/or leakage caused by seismic activity within the port.
R2 All tankage would be located on-site with the possible exception of two
small tanks which might be located onshore near the products dock site.
These two tanks would be for the purposes of accumulating slop oil skimmed
from ballast tanks during deballasting operations and of functioning as a
surge tank for the deballasting system. All storage of crude oil, refined
products, or ballast water would be located on-site. There would be no
storage facilities on the products dock.
C3 We believe the length of the tidelands lease should be discussed. The
Corps of Engineers public notice (Port of Valdez 85) states that a portion
of the dock will be removed; it will not be reverted to city ownership as
indicated in the statement. Clarification of this issue is needed. We
recommend that the final statement include an assessment of the environ-
mental damage which may result in removing the dock, should this be an
alternative.
R3 The length of the tidelands lease at the site of the products dock accord-
ing to the lease application submitted to the Alaska Department of Natural
Resources on September 26, 1979, is a period of 25 years or until expira-
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tion of the term of the Alpetco royalty oil contract, which is anti-
cipated to be June 2005. The tidelands lease with the City of Valdez for
the construction barge dock would expire upon completion of construction of
the proposed plant. Upon expiration of the construction barge dock lease,
ownership of the dock would revert to the City of Valdez as indicated on
DEIS p. 39. This updates information to the contrary in the Corps
of Engineers, Section 10, permit application.
C4 Paragraph 2, Section 3.8, mentions specific design parameters involved in
spill prevention. This section should be expanded to consider installing
emergency shut-off valves at all stream crossings.
R4 The above-referenced paragraph discusses the "appropriate use of valves to
minimize potential oil spills." This does refer to the use of shut-off
valves at stream crossings. Please see FEIS Section II, p. 11. It is
premature in the planning phase of the project to know the specific design
parameters and methods of operation of the valves and detection system.
C5 The contingency plan for spills does not include spillage of hazardous
solid waste products (i.e. sulfur, spent catalyst) being removed from the
plant site. We suggest that the plan be expanded to include procedures to
handle possible spillage of solid waste between the plant site and waste
disposal site (or manufacturer, if returned).
R5 The spill prevention, control and countermeasure plan is to include mea-
sures for all possible types of spills including those mentioned above.
C6 Section 4.3.4 should be expanded to discuss whether hazardous waste dis-
posal sites are planned within the Valdez area. We recommend that if a
hazardous waste disposal site is needed, it be located within the plant
perimeter away from the streams intersecting the perimeter boundary.
Containment barriers should be constructed around all liquid hazardous
space.
R6 There are no hazardous waste disposal sites planned within the Valdez area
for the proposed facility. See Section 4.3.4, DEIS p. 87, for the current
status on an Alaska State Hazardous Waste Management Program.
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C7 We believe design criteria for each alternative transportation route should
be included in Section 4.3.8. This is particularly important for Alterna-
tive No. 3 which concerns a major floodplain. Design criteria for the
bridge and access road from the Glacier Stream Haul Road to the plant site
should be discussed in detail.
R7 It is premature in the normal development of the project to have detailed
engineering design criteria for the transportation route alternatives. The
screening process which led to selection of a preferred route was based on
several parameters discussed in Section 4.3.8. One exception is the design
criteria which would govern the primary access road and bridge across
Valdez Glacier Stream. As discussed in paragraph 3, DEIS p. 183, the road
and bridge for the stream crossing would be designed and constructed to be
consistent with the guidelines of the HUD Flood Insurance Program. This
program currently restricts construction of any facility which would raise
the elevation of the base (100-Year) flood more than one foot at any point
in the community. The bridge span would be designed to pass the maximum
expected spring runoff flow, and the bridge approach roads would be
designed at an elevation to allow flood waters to pass over the top of the
roadway before water exceeds the HUD flood level increment.
C8 We believe Alternative No. 2 would be the most environmentally acceptable
transportation route. This route would utilize the existing levee off the
Richardson Highway, adjacent to the east side of Valdez Glacier Stream, and
eliminate the need for a bridge crossing across the Valdez Glacier Stream
and its floodplain. However, if the primary access route (Alternative
No. 3) is selected, pertinent flood control design criteria should be
included for review.
R8 See FEIS Section II, p. 13-16, and response R7 above.
C9 Regarding last two paragraphs on page 2 of the comment letter which discuss
pipeline stream crossings and pipeline bundle routes.
R9 Comments on recommended stream crossing time periods are so noted. See
Section II, p. 45-49, Mitigation. The recommendation regarding elevating
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the pipeline crossing above Robe River is so noted and has been done.
CIO Page 3, paragraphs 1 and 2 regarding groundwater and hydraulic character-
istics .
RIO See FEIS, Section II, p. 51-56.
Cll The dilution and discharge studies conducted do not seem adequate to
explain effluent movement. It is understood that studies were only con-
ducted when stratified conditions existed. We believe that dye plume tests
should be conducted in winter, when the water column is not stratified, to
predict effluent dispersal. This would give a better indication of dis-
persal when the water column is not well mixed.
Rll The field data that was collected does represent the stratified condition
during the summer of 1979. However, the model that was run incorporates
this data and previous data that were collected by the Institute of Marine
Science, including data regarding unstratified conditions. The most criti-
cal state would be during the summer stratified conditions. It should be
noted that during the winter (nonstratified conditions), the water column
is well mixed. Regarding further study in predicting effluent dispersal,
the NPDES permit requires the applicant to submit a report containing all
data relative to the determination of dilutions and the design and location
of the diffuser system six months prior to beginning diffuser construction.
The permit also requires the permitee to develop and implement a study
which will measure the actual diffusion and dispersion characteristics
achieved by the outfall diffuser system no more than three months after
start-up of the refinery facility.
C12 Information on primary productivity in the Valdez Glacier Stream is lacking
and assumptions are inferred by the following statement contained in the
draft: "Detailed information on ecosystem structure is lacking. Produc-
tion of the plants and stream dwelling invertebrates can be assumed to be
small." We believe the assessment of the biological factors inherent in
the stream should be expanded in the final statement.
127
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RX2 Valdez Glacier Stream has no flow during winter, reaches its peak flows in
approximately June or July and has variable but generally diminishing flows
throughout the rest of the year. The streambed is cobble with very little
silt deposition occurring. The stream is heavily laden with glacial silt
and is opaque. This rather harsh physical environment has not allowed the
establishment of a significant biological community. The stream is not
used for spawning, nor as a migratory passage for spawning fish. There are
no marshes associated with this stream, nor are attached macro algae pre-
sent in the river. Primary productivity has been assumed to be small
because of the severely limiting physical conditions.
C13 It is mentioned in the draft statement that the Lowe River should be con-
sidered highly productive, yet components of the system, except for spawn-
ing data, are poorly known. The statement that "... biological commun-
ities are probably well developed" should be explained. We suggest that
the procedures for assessing riverine ecosystems be discussed.
R13 Lowe River is considered productive because of its spawning values and the
extensive shellfish community at its delta. The direct effects on the
river system from the proposed project are rather limited and have been
discussed in the EIS and the technical appendices. Appropriate mitigation
measures have been adopted. The discussions concerning procedures used to
evaluate the natural environment of this area are contained in the Appendix
Vol. I.
C14 We suggest that the statement address the appropriateness of restricting
the discharge of firearms within a specified radius of the plant site,
pipeline routes, and products dock to lessen the chance of damage to the
system and possible environmental contamination. High powered rifles may
have the potential to puncture the product and crude oil pipelines.
R14 Action has been taken by the City of Valdez to remove the most immediate
firearm threat to the proposed facility. The present firing range located
south of the plant site is in the process of being moved to a new, safer
location. Any further restrictions would be the responsibility of the
appropriate state or local authorities.
128
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C15 Reference is made to a one-year study to define the Department of Housing
and Urban Development - Federal Insurance Administration maps concerning
the flood potential and the 100-year floodplain. It should be further dis-
cussed as to how the new information will be used.
R15 The ongoing flood study being performed for the City of Valdez by Woodward-
Clyde Consultants will not be concluded or arrive at any conclusions prior
to publication of this Final EIS. See the letter on p. 50, Section II,
indicating the status of the study. Ultimately, the height and configura-
tion of the flood control levee could be altered by the results of this
study.
C16 It is mentioned that Alpetco may utilize the city's landfill site for some
non-hazardous solid waste. Since the present city landfill is nearing
capacity, we suggest that alternate disposal measures be discussed.
R16 Section 6.7.1, DEIS p. 218, discusses the action the City of Valdez is
taking to provide for future municipal solid waste disposal needs including
those Alpetco needs the city has committed to handle.
C17 In the event of an earthquake, liquefaction in the area of the pipeline
system may result in a great risk to the environment. The draft statement
seems to circumvent this problem by suggesting several mitigation measures
which could be implemented. We believe these after the fact measures do
not adequately address the initial liquefaction problem. We suggest that
you provide more detail regarding this concern.
R17 In EIS Appendix I, p. 1-81, paragraphs 2 and 3, the potential for a lique-
faction condition is described in terms of the fine-grained soils and high
water table. This issue was raised most importantly because these condi-
tions are prerequisites for liquefaction under strong seismic ground
shaking. There is, however, no known evidence of previous liquefaction in
the immediate vicinity of the pipeline route into the plant. The area that
is theorized to have experienced previous seismically induced liquefaction
is located approximately 4,000 ft up Corbin Creek (Glacier) from the pipe-
line route. This issue was raised to indicate the prudence of later per-
129
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forming a more detailed soils design study to establish safe design cri-
teria for pipeline construction in this area. If the area is determined to
be sufficiently susceptible to liquefaction, safe construction is not pre-
cluded but rather subjected to more restrictive design standards.
C18 The last two paragraphs on page 4 and the first three paragraphs on page 5
of the comment letter regarding impacts of wastewater discharge.
R18 See FEIS Section IV, p. 150, item R2.
C19 Fourth paragraph on p. 5 of the comment letter regarding potential impacts
from air pollution due to industrial emissions.
R19 The Department of the Interior through the Fish and Wildlife Service office
did not comment on the Prevention of Significant Deterioration (PSD) permit
application. The baseline studies proposed to examine the air contamina-
tion issue in general were not presented. See letter in Section IV,
p. 187, regarding their statement on air quality.
C20 It is important that timing for construction be compatible with salmon
spawning and rearing in adjacent streams. Dredging should not occur
between 7 April and 7 June. We also believe it important that dredging be
performed by clam shell dredge and that spoil material be deposited at a
specified upland site. We suggest these points be discussed in this sec-
tion.
R20 Comment so noted. See FEIS, Section II, p. 45-49, Mitigation Measures.
C21 The continuous use of water drawn from on-site wells may lower groundwater
levels, thus affecting the amount of available water in Corbin Creek (Robe)
and Brownie Creek. No information on groundwater was obtained during the
winter. This period is critical to the survival of salmon eggs in these
two streams. We recommend that the groundwater study be expanded to assess
the impacts of groundwater fluctuations during the winter months.
130
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R21 See Section 6.2.2, DEIS p. 188, regarding winter season observation of
groundwater levels. See FEIS Section II, p. 51-56, for results of those
observations.
C22 The draft Environmental Impact Statement appears to be incomplete in its
discussion of project related impacts to existing and/or planned recrea-
tional opportunities at or adjacent to the proposed facility, products
dock, and construction barge dock. The final statement should identify any
recreation impacts (including mitigation measures and the enhancement of
recreation opportunities), or clearly state that there are none. For
example, the lower Solomon Gulch Falls, adjacent to the proposed products
dock, is recognized as a major scenic resource. However, .there is no clear
indication of the degree of impact, if any, that the project will have on
those who wish to visit the resource. The potential impacts to recrea-
tional boaters from the increased marine traffic associated with the con-
struction and operation of the project should also be discussed.
R22 The site for the proposed facility has been a relatively inaccessible
wilderness area. The main recreational values in the general vicinity
would be possible occasional hunting on-site, and use of the Valdez Glacier
Wayside campground located across Valdez Glacier Stream from the northwest
corner of the proposed plant site. The plant site would no longer be
available for hunting; however, it is not currently known for its sport
hunting value. Primary impacts on the campground would be increased traf-
fic on the access road, and visual and noise effects noted in Section
6.6.1, DEIS p. 215. There are no present recreational opportunities at the
construction barge dock site. Lower Solomon Gulch Falls is valuable for
its scenic view. The products dock facility would not interfere with
access to this scenic resource; however, access would experience temporary
interruption during the construction period. The net increase in vessel
traffic in Port Valdez would be 128 vessels per year, or one every 2.8
days. This number considers the decrease which would occur in tanker
traffic calling at the Alyeska Terminal to haul an equivalent amount of
crude oil from Valdez. This is a relatively small increase in traffic and
is well within the Coast Guard navigational control system in Valdez. It
is not expected to impose significant impacts on recreational boaters in
the harbor.
131
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«»«•» o»
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
=> # '> REGIONAL OFFICE
ARCADE PLAZA BUILDING, 1321 SECOND AVENUE
SEATTLE, WASHINGTON 98101
January 24, 1980
REGION X IN REPLY REFER TO:
Office of Community Planning IOC
and Development
C1
RECEIVED
Ms. Deborah Kirk 25 1980
Environmental Evaluation PDA eic
Branch, M/S 443 wa-rs
U.S. Environmental Protection
Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Ms. Kirk:
Re: Draft Environmental Impact Statement
Alaska Petrochemical Company
Valdez, Alaska
We have reviewed the impact statement issued on December 7, 1979.
Your impact statement adequately covers our areas of concern. Your
statement will be sent to our office in Anchorage so that they will be
fully aware of the impact on housing that is described in the statement.
The statement also notes the impact on floodplains and wetlands, however,
does not mention the need for compliance with Executive Order 11988 and
Executive Order 11990. It may be appropriate to review the eight step
process and to indicate in the final statement that the process has been
or will be complied with prior to project implementation.
Thank you for the opportunity to comment.
Sincere
bart C. Sealia
ivector
gional Office of CPD
cc: John Duffy / with copy of impact statement
Newton Chase
AREA OFFICES
Portland, Oregon • Seattle, Washington • Anchorage, Alaika • Boise, Idaho
Insuring Office
Spokane, Washington
132
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RESPONSE TO
COMMENTS BY U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT,
OFFICE OF COMMUNITY PLANNING AND DEVELOPMENT
CI The DEIS does not mention the need for compliance with Executive Order
11988 and Executive Order 11990. It may be appropriate to review the
eight-step process and to indicate in the final statement that the process
has been or will be complied with prior to project implementation.
R1 The above mentioned eight-step process is contained in the "Water Resources
Council, Floodplain Management: Guidelines for Implementing Executive
Order 11988 (43 CFR Part VI)." The same guidelines apply to EO 11990,
Protection of Wetlands; however, EO 11990 does not apply to this agency's
proposed action (pursuant to EO 11990 Section 1(b)). Nonetheless, the
order was used in guiding the analyses and, in effect, has been complied
with. The DEIS, this Final EIS and the subsequent Record of Decision will
satisfy fully the requirements of EO 11988 and the guidelines.
The eight steps, simply stated, are: determine if the proposed action is in
a floodplain; provide for public review; identify and evaluate alterna-
tives; identify impacts; minimize impacts and restore and preserve the
natural conditions of the floodplain or wetlands; reevaluate alternatives;
provide for public explanation of the findings; and implement a decision
based upon the above steps. Step 7 - Findings and Public Explanation,
identifies nine issues which an agency must address. The relevant discus-
sions appear throughout the Draft and Final EIS documents under appropriate
headings and are summarized below.
1) Describe why the action must be located in a floodplain: Due to size
requirements and terrain limitations there were no suitable non-flood-
plain alternative sites in Valdez.
2) Describe the significant factors which were considered including
alternative sites and actions: Much of the material contained in the
Draft and Final EIS documents is pertinent, particularly Sections 4.1
and 4.2.
133
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3) Indicate whether the actions conform to applicable state or' local
floodplain protection standards: There currently are no applicable
state or local regulations; however available draft programs currently
under review were used as design criteria. The final floodplain pro-
grams should be available during detailed design of the facility. The
facility design would comply with those programs.
4) Indicate why National Flood Insurance Program criteria are demon-
strably inappropriate for the proposed action: Not applicable.
5) Provide for publication in the Federal Register or other appropriate
vehicle: Notice of availability of the DEIS appeared in the December
7, 1979 Federal Register; in addition, public notices appeared in
newspapers, and hearings were conducted, in Anchorage, Juneau and
Valdez.
6) Provide for a brief comment period: In this case, comments on all
issues in the DEIS were accepted for inclusion in the FEIS from
December 7, 1979, to February 16, 1980.
7) Describe how the action will be designed or modified to minimize harm
within or to the floodplain: Mitigation measures pertinent to flood-
plain aspects of this project appear in Section II of this FEIS.
Design features relative to floodplain considerations are discussed in
various sections of the EIS.
8) Indicate how the action affects natural or beneficial floodplain
values: Wetlands in eastern Port Valdez provide waterfowl habitat and
function as sources of groundwater recharge and as links in the food
chain. Some habitat and groundwater recharge losses would be expected
at the immediate project site, where wetland areas would be altered or
lost by the proposed project, but the effects are anticipated to be
minor. Please see Section II of this FEIS, p. 27 and 44.
9) List other involved agencies and individuals: A List of Preparers
comprises Section VI of this FEIS.
134
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REPLY TO
ATTENTION OF:
DEPARTMENT OF THE ARMY
ALASKA DISTRICT. CORPS OF ENGINEERS
P.O. BOX 7002
ANCHORX6E, ALA- ~, ,, „ ,
20 FEB 1980
received
' r; p 251980
NPAEN-PL-EN
Mr. Donald P. DuBois
Regional Administrator
U.S. Environmental Protection Agency
Region X
ATTN: M/S 443
1200 Sixth Avenue
Seattle, Washington 98101
M:, >°0
OFFICII OF
regional administrator
RECEIVED
Dear Mr. DuBois:
The Alaska District, Corps of Engineers has reviewed the Draft
Environmental Impact Statement (DEIS) for the Alaska Petrochemical
Company's (ALPETC0) proposed refinery and petrochemical facility in
Valdez, Alaska. As requested by the Environmental Protection Agency
(EPA), the Corps of Engineers has affected the EIS preparation process
as a cooperating agency to the extent of defining jurisdiction under
Section 404 of the Clean Water Act of 1977 and Section 10 of the
Rivers and Harbors Act of 1899. Similarly, as requested by EPA,
wetlands and other waters of the United States directly affected by
the proposed action were delineated according to the Alaska District.
The Corps intends to adopt the final EIS to fulfill our obligations
under NEPA. Most of our concerns have been addressed in the Draft
Environmental Impact Statement as a result of earlier coordination.
The following comments represent items that were not included or
reflect the very dynamic nature of development plans in the Port of
Valdez area and our increasing concern for wetland conservation in the
region. Addressing these comments will insure that the final EIS
adequately describes the impacts on elements which are subjects of
concern to Corps' regulatory authorities.
~ a. To fulfill the requirements of the Section 404(b)(1)
guidelines additional information must be provided in the existing
conditions discussion of wetlands (page 149). This additional
ci information should include a general discussion of the various wetland
types affected by the proposed project and a discussion of the
function and relative value of the various types. The discussion of
135
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NPAEN-PL-EN
Mr. Donald P. DuBois
20 FEB 1980
wetlands in the environmental consequences portion of the DEIS (page
236) should present the acreages of each wetland type which will be
directly impacted by the proposed action.
b. The proposed action will provide a most important stimulus
for economic growth and development in the Port of Valdez area.
Although this indirect effect is beneficial, it also constitutes an
action which will likely result in future wetland losses. Likewise,
the direct and most probable indirect effects of the proposed action
will act in a cumulative sense with past wetland alterations. This
arena of effect assessment is, of course, problematic because of the
level of the state of the art for such analysis. Nevertheless, the
indirect and cumulative effects of the proposed action are important
in this case and must be addressed in the final EIS. There is a
significant need for timely environmental planning at the local level
to avoid unacceptable impacts on aquatic systems and wetlands in the
area and to reduce the number of unauthorized fills which would
otherwise occur. In this light, the following specific examples
(these are not the only occurrences) of the need to expand discussions
of effects are provided.
(1) In the environmental consequences section, the number of
acres of undeveloped land necessary for development as an indirect
effect of the proposed action should be stated with a discussion of
the likelihood of wetland modifications and the efforts of planning
authorities to deal with the issue.
(2) Page 223, paragraph 4: The statement that "Marine
organisms may suffer temporary adverse effects during small spill
incidents" does not provide enough information. The rationale for
stating that effects will be temporary should be given as should the
nature of the effects and their significance.
(3) Page 223, paragraph 5: The cumulative impacts of this and
other actions in the Valdez area on the movement patterns of marine
fish, birds and mammals should be discussed. These actions considered
individually may cause only "minor disruptions;" however, all actions
proposed for the area when considered cumulatively may cause
significant adverse impacts to marine organisms.
(4) Page 225, paragraphs 1, 2, 3, and 4: The average reviewer
has little knowledge of the relationship of these organisms to
commercially important species. Therefore, the impacts of a product's
spill on these organisms and the significance of these impacts should
be described. Organism mortality should be quantified if possible.
136
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NPAEN-PL-EN
Mr. Donald P. DuBois
20 Ft"3 T980
C6
~
~
C 7
~
C8
C9
A
CIO
c. The alternative relating to the expansion of existing
Alaskan refineries should be discussed even though it may be beyond
the capability of the applicant and outside the jurisdiction of the
Corps of Engineers.
d. Under Corps of Engineers regulations an environmentally
preferred alternative must be identified. In this regard, the
currently proposed project with one modification is so identified.
That modification would be to construct the road and pipeline
according to Alternative Route Number 2, as indicated on Figure 3.3-1,
in a manner which would constitute the least effect on wetlands. In
addition, it is recommended that mitigation measures 10 and 25 (as
discussed in the Mitigation Measure Summary-Section 7 of the EIS) be
included as EPA permitting stipulations. Initiation of these measures
will provide further protection to the valuable fisheries resource.
e. According to 40 CFR 1502.11 (a) the Corps of Engineers
should be identified as a cooperating agency on the cover sheet of the
EIS. The summary description on page viii should identify the Corps
as being a cooperating agency and it should note that the Corps is
exerting jurisdiction under Sections 10 and 404. The Corps actions
should be identified as being issuance of Section 10 and 404 permits
or issuance of permits with stipulations. Denial of a permit
application is considered "no action" on the part of the Corps. The
discussion of the Corps' regulatory program on page 3 should note that
the Corps intends to adopt the EIS to fulfill its NEPA obligations if
its concerns are satisfied in the final document.
f. The names of Corps of Engineers personnel who participated
in preparation of the EIS should be included in the list of
preparers. This information is attached.
I appreciate the opportunity to comment on this DEIS and hope that
these comments will be of value in preparation of the final document.
If I can be of further assistance, please do not hesitate to contact
me directly. If further details are desired by your staff, contact
can be made with Mr. Ben Kutscheid or Mr. Phil Brna at (907) 752-2572.
Sincerely
1 Incl
As stated
LEE R. NUNN
Colonel, Corps of Engineers
District Engineer
137
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RESPONSE TO COMMENTS
BY THE U. S. DEPARTMENT OF THE ARMY
CORPS OF ENGINEERS
CI To fulfill the requirements of Section 404 (b)(1) guidelines, additional
information must be provided in the existing conditions discussion of wet-
lands (DEIS, page 149). This additional information should include a gen-
eral discussion of the various wetland types affected by the proposed pro-
ject and a discussion of the function and relative value of the various
types. The discussion of wetlands in the environmental consequences of the
DEIS (page 236) should present the acreages of each wetland type which will
be directly impacted by the proposed action.
R1 The referenced discussions have been expanded to reflect your comments.
Please see FEIS Section II, p. 27 and 44.
C2 In the environmental consequences section (DEIS Section 6.0), the number of
acres of undeveloped land necessary for development as an indirect effect
of the proposed action should be stated with a discussion of the likelihood
of wetland modifications and the efforts of planning authorities to deal
with the issue.
R2 EIS, Subsection 6.10.6, Subpart Production of Housing (DEIS p. 249), pre-
dicts that a need would exist for 708 additional living units beginning in
1984 to meet demand created by the proposed project. It is difficult to
predict with any accuracy what portion of this demand would be satisfied by
single family units and what portion by mobile homes and multiple family
units. As a worst case scenario, assume all 708 units were single family
homes, at an average lot size of 9,000 sq. ft. This would be 146 acres of
development required to meet the demand. For the sake of discussion,
through the use of high density and multiple unit dwellings, assume that
only two-thirds of this acreage would be required to fulfill the demand.
Based on this scenario, secondary residential development would consume 97
acres in the Valdez area. It is not possible to state with any accuracy
what secondary conmiercial or industrial development may be generated as a
138
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result of the proposed project. Any future industrial activity occuring in
Valdez likely would be established somewhere within the boundaries of the
industrial use zone currently being defined in the general airport/Alpetco
site vicinity by the City of Valdez. There are approximately 4,500 total
acres being committed by the city for this use. There do not appear to be
any large scale wetland conflicts within any of the known proposed Valdez
residential or industrial development zones. Any future development pro-
posed in a wetland area would be the subject of a future Corps of Engineers
Section 404 action.
C3 DEIS, p. 223, paragraph 4: the statement that "marine organisms may suffer
temporary adverse effects during small spill incidents" does not provide
enough information. The rationale for stating that effects will be tempor-
ary should be given, as should be the nature of the effects and their sig-
nificance .
R3 The referenced paragraph has been expanded in response to your comments.
Please see FEIS Section II, p. 43.
C4 DEIS, page 223, paragraph 5: the cumulative impacts of this and other
actions in the Valdez area on the movement patterns of marine fish, birds
and mammals should be discussed. These actions considered individually may
cause only "minor disruptions"; however, all actions proposed for the area
when considered cumulatively may cause significantly adverse impacts to
marine organisms.
R4 Prediction of cumulative impacts cannot be dealt with quantitativly. It is
possible that noise and activity at the Alpetco facility combined with
future actions in the area could disrupt habitat and movement patterns of
fish, birds and mammals. However, a future action almost certainly would
be subject to the provisions of the National Environmental Policy Act, and
it is expected that potential adverse impacts would be identified and
avoided or mitigated if such a threat became imminent.
C5 DEIS, page 225, paragraphs 1, 2, 3 and 4; the average reviewer has little
knowledge of the relationship of these organisms to commercially important
139
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species; therefore, the impacts of a product spill on these organisms and
the significance of these impacts should be described. Organism mortality
should be quantified if possible.
R5 The ecological inter-relationships between various organisms in Port Valdez
are discussed throughout the EIS and its technical appendices. Although
CEQ regulations require making a worst-case analysis of impacts, there is
not adequate research and information available to do this.
C6 The alternative relating to the expansion of existing Alaskan refineries
should be discussed even though it may be beyond the capability of the
applicant and outside the jurisdiction of the Corps of Engineers.
R6 Terms of the Royalty Crude Oil Contract between Alpetco and the State of
Alaska require the state to provide and Alpetco to purchase a minimum 85
percent of the state's royalty crude oil with a conditional option on an
additional 5 percent, and require construction of a refinery and petrochem-
ical facility in Alaska. These conditions make the crude unavailable to
other refiners. However, even if the crude were available, the possibility
of a significant expansion seems remote. Expansion of the North Pole
refinery to 150,000 bpd or construction of a 150,000 bpd Tanana Valley
refining facility would be prohibitive due to the difficulties of marketing
and transportation. Product quantities would be excessive for the local
Interior Alaska market, and the costs of transporting products to ice free
ports in Cook Inlet or Prince William Sound would be too great to make such
an undertaking economically viable. It is more conceivable that the Tesoro
or Chevron refinery at Nikiski on Cook Inlet could be expanded to satisfy
the objectives of the Alpetco project. However, modifications would be
necessary for the facilities to produce petrochemicals and process the
heavy, sour Alaska North Slope crude; and some West Coast refiners have
indicated that the cost of those modifications result in higher refining
costs than would have resulted from the continued and increased purchases
of more expensive foreign sweet crude. Since expansion of an existing
facility seems neither likely nor economical, further discussion of the
possibility would not be relevant considering the parameters of the pro-
posed project.
140
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C7 Regarding the comment that the secondary road and pipeline route be mod-
ified according to Alternative Route #2, as indicated on DEIS figure 3.3-1.
R7 Please see FEIS, Section II, p. 13-16.
C8 It is recommended that mitigation measures 10 and 25 (as discussed in the
mitigation measure summary - Section 7.1 of the EIS) be included as EPA
permitting stipulations.
R8 Both mitigation measures have been changed from a not-yet-committed to a
committed status and a list of mitigation measures has been attached to the
NPDES permit. Please see FEIS Section II, p. 45-49.
C9 Corps of Engineers comment e.
R9 Please see FEIS cover sheet and p. 2.
CIO Corps of Engineers comment f.
RIO See FEIS Section VI.
141
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SECTION IV
This section responds to comments received concerning the major federal permits
which apply to this project. All letters are reprinted in their entirety.
Letters which do not require a specific response are marked with a box and the
words, "comment noted." Where further explanation or references are necessary,
the comment letter is followed by responses to the specific issues which were
raised in that letter.
The format of the responses is to briefly restate the nature of the comment;
respond to it; restate the next comment from that letter; respond to it, and so
forth. The designations "C" and "R" in the margin represent "Comment" and
"Response" respectively and are followed by sequential numbers, so that R1 is
the response to CI and so on.
Comments on the draft NPDES (water discharge) permit are presented first, fol-
lowed by an explanation of changes which have been made to the permit. The
final permit follows, printed in its entirety. The PSD (air quality) permit is
considered next. An introduction and comment letter are followed by EPA's PSD
Preliminary Determination, Technical Analysis, and Final Determination. This
section concludes with comments and responses regarding Sections 10 and 404
permits.
143
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INDEX TO SECTION IV
Page
Letter from Alaska Department of Fish & Game - NPDES 145
Letter from U.S. Department of the Interior,
Fish & Wildlife Service - NPDES 146
Response to letter from USDOI - FWS 150
Letter from U.S. Department of Commerce,
National Marine Fisheries Service - NPDES 152
Response to Letter from USDOC - NMFS 155
Introduction to NPDES Permit 157
NPDES Permit 160
State of Alaska Certificate of Reasonable Assurance - NPDES 184
State Letter of Alaska Coastal Management Program Consistency - NPDES . . 185
Introduction to PSD Considerations 186
Letter from U.S. Department of the Interior, FWS - PSD 187
PSD Preliminary Determination 188
PSD Technical Analysis 192
PSD Final Determination 226
PSD Permit 227
.State of Alaska Air Quality Control Permit to Operate 235
State Letter of Alaska Coastal Management Program Consistency - PSD . . . 248
Sections 10/404 249
Letter from U.S. Department of Commerce, NMFS - Sections 10/404 251
Response to Letter from USDOC - NMFS 253
Request for Information from U.S. Department of the Interior,
Office of the Secretary . 255
Response to Request for Information from USDOI 257
Letter from the U.S. Department of the Interior, FWS - Section 404 . . . 262
Response to Letter from USDOI-FWS 272
Letter from City of Valdez - Pipeline Route 281
Letter from the EPA - Section 10 282
Letter from the EPA - Section 404 283
State Certificate of Reasonable Assurance - Section 10 284
State Letter of Alaska Coastal Management Program Consistency - Section 10 285
State Certificate of Reasonable Assurance - Section 404 287
State Letter of Alaska Coastal Management Program Consistency - Section 404 288
Letter from U.S. Department of Commerce, NMFS - Section 404 289
Letter from Alaska Department of Fish and Game - Section 404 290
144
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NPDES
-------
December 12, 1979
DEC 1 8 i379
Pif.nMHS BRANCH
t c>a • REGION 10
United States Environmental Protection Agency
Region 10
1200 Sixth Avenue
Seattle, Washington 98101
Gentlemen:
Re: Public Notice No. AK-002763-4/Alaska Petrochemical Company
The Alaska Department of Fish and Game has reviewed the subject NPDES
permit application.
We believe the proposed effluent standards are sufficient to protect
marine life in Port Valdez Arm and have no objection to permit issuance.
Thank you for consulting us.
Sincerely,
Ronald 0. Skoog, Commissioner
BY: Bruce M. Barrett
Projects Review Coordinator
Habitat Protection Section
COMMENT
NOTED
145
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UNITED STATES
DEPARTMENT OF THE INTERIOR
FISH AND WILDLIFE SERVICE
1011 E. TUDOR RD.
ANCHORAGE, ALASKA 99503
(907) 276-3800
JAN *980
Mr. Michael M. Johnston, Chief
New Source Permit Section (M/S 521)
U.S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Johnston:
Our office has reviewed the National Pollutant Discharge Elimination
System (NPDES) permit application No. AR-002763-4 made by the Alaska
Petrochemical Company (ALPETCO) for a new source permit and the accomp-
anying proposed NPDES permit as provided in the draft Environmental
Impact Statement. Because the permit is for a new pollutant source in
which the exact identity and concentration of substances in the effluent
is not defined; because the area involved (Port Valdez) is an important
estuarine system for many species of fish and wildlife including many
migratory birds and marine mammals; and because the area is already
subject to pollutant discharges from at least two sources (City of
Valdez and Alyeska's Ballast Waste Water Treatment Plant) we recommend
the following:
granting the NPDES permit for a period until the facility
is in operation, at which time the permit would be subject to review
in order to examine the final effluent to modify the existing permit
if deemed necessary;
establishing allowable concentrations of substances in the water
column by conducting flow-through bioassays using water from the
receiving body. Concentration limits should be set for 1/100 the
96-hour TI^ value for nickel, aluminum, cadmium, zinc, and
chromium. Factors for ammonia and sulfide should be 1/20 the 96-hour
IN REPLY REFER TO:
~
C1
1)
C2
2)
R7-1
146
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2
TL value and for cyanide 1/10 the 96-hour TL value. Recommended
species for testing Include pink salmon (juvenile) and blue mussels
(larval) collected near the discharge site, whereby test results for
C2 the most sensitive species would be used in the final determinations.
Pink salmon are the most abundant anadromous fish species in Port
Valdez and blue mussels are a major prey item of sea ducks utiliz-
A ing the area.
Again, because ALPETCO will be beginning a new operation without known
or specified pollutant concentrations in the discharge it is difficult
to assess potential impacts to fish and wildlife resources or recommend
specific stipulations. We can, however, comment on the wastewater
treatment plant discharge limitations as specified on page 3 of the
draft NPDES permit.
~ The ammonia limitations as given in the draft permit allow substantially
more ammonia to be discharged than ALPETCO expects (ALPETCO estimates
7.0 mg/1 as a daily average ammonia effluent concentration whereas the
permit allows roughly 38 mg/1 as an average and nearly 83 mg/1 as a
daily maximum for ammonia). The estimated concentration of 7.0 mg/1 of
ammonia would probably cause no significant harm to fish or wildlife,
but should it be at or nearly at the daily limitations presently specified
in the draft permit we would have cause for concern.
When ammonia is dissolved in water.it reaches an equilibrium of this
nature: NHg + ^0 ^ NHo . 1^0 ^ NH^ + 0H~ whereby NIL is un-ionized
ammonia, NH^ is ionized ammonia, and 0H~ is hydroxide ions (U.S. Environmental
Protection Agency 1976). NH^ is the most toxic to fish although NH
has also been acclaimed as toxic to some degree to aquatic organisms
(Tabata 1962). The U.S. Environmental Protection Agency (1976) has set
.02 mg/1 un-ionized ammonia as criteria for the protection of freshwater
aquatic life. Toxicity of ammonia has been demonstrated to increase
with increased salinity for fingerling coho salmon (Katz and Pierro
1967) therefore suggesting standard accepted ammonia concentrations for
freshwater may be too high for sufficient protection in the marine
environment. Burrows (1964) found progressive gill hyperplasia in
fingerling chinook salmon during a six week exposure to 0.3 mg/1 of
total ammonia (expressed as NH^; .002 mg/1 was NHg)•
Essentially, even if the dilution factor of 75:1 is achieved along the
boundaries of the mixing zone (as specified in the last paragraph, page
7 of the draft permit) the ammonia concentrations if at or near the
C3
147
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3
C3
A
~
C4
~
C5
~
discharge level limit presently proposed would exceed accepted safe
levels. We therefore suggest a modification of the allowable discharge
limit for ammonia to be determined by bioassay as recommended in number
2 of this letter.
Although chromium is not identified in ALPETCO's fact sheet as a potential
component of the discharge it is listed as an effluent characteristic in
the draft NPDES permit with a discharge limitation of 17.3 pounds and
29.5 pounds of total chromium and 1.1 pounds and 2.4 pounds of hexavalent
chromium given as daily averages and daily maximums respectively. Here
again, if the actual discharge were to approach these limitations we
would be concerned. Not only has chromium been reported toxic to a
variety of marine flora and fauna, it has also been reported to be
bioaccumulative. Lowman, et al. (1971) reported marine chromium concen-
tration factors of 1,600 in benthic algae, 2,300 in phytoplankton, 1,900
in zooplankton, 440 in molluscan soft parts, and 70 in fish muscle. It
is recommended that chromium concentrations not be allowed to exceed
0.1 mg/1 even within the mixing zone (18 AAC 70.032 provides that mixing
zones be disallowed where the substance discharged is bioaccumulative
in food chains - Alaska Department of Environmental Conservation, 1979).
Cyanide concentrations have been limited to 0.38 mg/1 as a daily maximum
by the draft permit whereas ALPETC0 has estimated that 0.5 mg/1 of cyanide
will be a daily average. We again strongly urge that bioassays be
conducted to determine maximum allowable cyanide concentrations, but if
necessary in lieu of that we would support the permit stipulation as
written on page 8, "cyanide in the water column shall not exceed 5 ug/1."
The waters of Port Valdez are not only aesthetically pleasing, but also
support an abundance of wildlife which is subject to a variety of both
consumptive and nonconsumptive uses. At a time when development in the
Valdez area is rapidly expanding, it is important to carefully examine
all of the resources present, the potential impacts facing those
resources, and the options that are viable to any proposed alterations.
We appreciate your critical review of our recommendations and the oppor-
tunity to review this draft NPDES permit.
cc:Robert Bowker, USFWS, Anchorage
Tom Trent, ADF&G, Anchorage
Ron Morris, NMFS, Anchorage
Bill Lamoreaux, EPA, Anchorage
148
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Literature Cited
Alaska Department of Environmental Conservation. 1979. Water Quality
Standards. Alaska Water Pollution Control Program. 34 pp.
Burrows, R. E. 1964. Effects of accumulated excretory products on
hatchery reared salmonids. Bureau of Sport Fisheries and Wildlife
Research Report 66. U.S. Government Printing Office, Washington, D.C.
Katz, M. and R. A. Pierro. 1967. Estimates of the acute toxicity of
ammonia-urea plant wastes to coho salmon, Oncorhynchus kisutch.
Final Report, Fisheries Research Institute, University of Washington,
Seattle.
Lowman, F. G., et al. 1971. Accumulation and redistribution of radionu-
clides by marine organisms. Page 161 in Radioactivity in the marine
environment. National Academy of Sciences, Washington, D.C.
Tabata, K. 1962. Toxicity of ammonia to aquatic animals with reference
to the effect of pH and carbon dioxide. (In Japanese with English
summary). Bull. Tokai Reg. Fish. Res. Lab. 34:67.
U.S. Environmental Protection Agency. 1976. Quality Criteria for Water.
Washington, D.C. 256 pp.
149
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RESPONSE TO COMMENTS
BY U.S. DEPARTMENT OF THE INTERIOR
FISH AND WILDLIFE SERVICE
CI Grant the NPDES permit only until startup in order to reexamine the final
effluent and modify the existing permit if deemed necessary.
R1 The permit will expire five years from its effective date of May 25, 1980,
which would be approximately one year after plant startup. The data col-
lected from the actual discharge during this one year period of operation
will be critical for evaluation before the next permit can be prepared.
Although the permit remains at a full allowable five years, the intent of
the FWS comment should be satisfied.
C2 Allowable concentrations in the water column be established by flow-through
bioassays.
R2 In order to take advantage of the proposed approach, the levels would need
to be determined by actually using treated effluent water from the refinery
complex. No such data could be generated for several years. Also, cur-
rently there is no uniformly acceptable methodology established to conduct
such tests; however, EPA is currently considering this issue. The National
Marine Fisheries Service, Auke Bay Laboratory, may soon be contracted by
EPA to address the issue of toxicity and methodology. EPA and ADEC have,
however, examined the probable discharge levels for the more significant
parameters and compared these discharge levels (including a dilution fac-
tor) to those reported in the literature and have determined that permit
limits will keep discharges to sufficiently low levels to protect the
marine environment. A complete reevaluation of this issue will be made
before a second permit is issued and special attention will be made to
EPA's priority pollutants list. EPA has modified the permit to include a
new condition (E.3.) allowing for a permit modification to require bioassay
monitoring, should appropriate methodology be developed at a later date.
C3 Concern was expressed regarding the ammonia discharge limitations.
150
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R3 EPA and ADEC have reevaluated the available literature on ammonia and the
draft permit limit for ammonia and have made several changes. First, the
original limit was based on national guidelines and, therefore, was a
treatment technology limit - not a water quality limited condition. This
original effluent limit now has been replaced by an un-ionized ammonia
limit of 2.3 mg/1 daily maximum with the additional stipulation that the
permittee can obtain a relaxation to that limit up to 7.0 mg/1 upon the
showing that the mixing zone boundary condition of 0.03 mg/1 for NH3 will
be maintained continually. Also, the mixing zone boundary condition of
0.03 mg/1 has been added as a separate condition for the purposes of pro-
tecting the receiving water. This is roughly the criterion the American
Fisheries Society recommends for protecting salmonid fish.
C4 If chromium limits cannot be established by bioassay, an effluent concen-
tration at or below 0.1 mg/1 for hexavalent chromium is recommended.
R4 The permit limit hexavalent chromium of 1.1 pounds per day average and 2.4
pounds per day maximum has been reviewed with relation to flow levels with
the conclusion that these levels are sufficient to meeting an effluent
limit of 0.1 mg/1 in the discharge. Under average conditions and with a
flow of 2.5 mgd, the concentration would be 0.05 mg/1.
C5 If allowable cyanide concentrations cannot be determined by bioassay, we
support the permit stipulation as written on page 8, "cyanide in the water
column shall not exceed 5 ug/1."
R5 NPDES permit item A.h.(4) stipulates that "cyanide in the water column
shall not exceed 5 ug/1." Please see R2 above and permit Part E.3 regard-
ing bioassays.
151
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Following are the final two pages of the DEIS letter of comment received from
the U.S. Department of Commerce, National Marine Fisheries Service. The entire
letter appears in Section III, p. 102. Comments beginning with C30 concern the
draft NPDES permit, so are reprinted here for reference. Responses to these
comments follow.
152
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4. Wastewater Discharge
1. Impacts of Wastewater Discharge
~ Page 200. We believe this section should discuss the existing Alyeska
effluent discharge, addressing how it differs from the proposed ALPETCO
C23d1scharge' anc' Potent"'a^ f°r additional environmental impact caused by
A
-------
C30
A
~
C31
A
C$2
C$3
C34
A
C$5
We suggest this addition for the following reasons: Recognition of
sublethal effects of effluent based only on changes in health is only
correlative evidence, dependent on coincidence of health changes with
increases in toxic substances in the tissues of organisms. Correlation
does not necessarily prove that the toxic substances are responsible for
a change in health. A hypothetical example of this problem would be a
decline in growth rate of Macoma and an increase in toxic substances in
the tissues, when the decline in growth was the result of reduction of
the food supply available to the organisms, i.e., toxic substances
reduced the bacterial or plankton populations the clam utilizes for food
without directly affecting the clam.
It is therefore important to monitor the abundance and distribution of
the population (not only the health of individuals). For example, the
clams may surface due to the presence of a toxic substance and disappear
as a result of predation. The only useful evidence in such a case would
be data which show a decrease in abundance coinciding with an increase
of refinery-derived substances in the environment.
Annual and seasonal population estimates at the NOAA/NMFS site from
1970-79 show a remarkably stable population of large Macoma at the
higher tidal elevations. With this backlog of data, any later change in
the abundance or distribution of the clam population would be measur-
able, and studies to determine the cause could be implemented. (See
Attachment B; p, B-55 in Section 2, a. (2) under mortality.)
Sufficient leeway should be incorporated in the permit to initiate addi-
tional studies on particular aspects of the biology of the mudflat
community to evaluate changes in population abundance or health of
individuals within reasonable limits in terms of time and cost.
Page B-56. Reference - Stekoll, Clement and Shaw.
Page B-56. Add: "Macoma shall be . . . from the Old Valdez dock to an
mtertidal location near the diffuser."
Page B-57. (2). We suggest specifying Mytilus edulis or Limanda aspera
(yellowfin sole) as additional species. NMFS has previous data from
Port Valdez on hydrocarbon levels in these species.
Page B-57. Footnote 2, paragraph 1. (Lees, et al.) is missing.
154
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RESPONSE TO COMMENTS BY U. S. DEPARTMENT OF COMMERCE
NATIONAL MARINE FISHERIES SERVICE
C30 Concerning adding quantitative estimates of the abundance and distribution
of populations of Macoma and associated organismas to the biological
studies conditions.
R30 Abundance and zonation studies in the muddy intertidal regions are required
in permit Part E.l.a.(l), which specifies that these studies shall be con-
ducted at a minimum of three stations along three separate sampling tran-
sects, including the Dayville Flats area. Quantitative estimates of Macoma
abundance and distribution will be documented in this study. NMFS infor-
mation will be integral to the determination of any chronic effects of low
levels of wastewater constituents on water quality and biota. The data
collected shall be submitted in semi-annual reports throughout the life of
the permit, and shall be synthesized and discussed in a final summary
report to be submitted November 25, 1984 (see NPDES permit Part E.2. in
Section IV, p. 177). The final data report shall include intrepretations
of major findings, and the principal investigator's recommendations for
future studies, should any be necessary.
C31 Sufficient leeway should be incorporated into the permit to initiate addi-
tional studies of the biology of the mudflat community to evaluate changes
in population abundance or health.
R31 No such open-ended condition would be acceptable in a permit. EPA does
have procedures by which to propose a modification to the permit if just-
ifiable reason comes to light (see permit Part C.2.). However, it is ex-
pected that the final data summary report required in permit Part E.2.
would identify any information indicating need for such studies, as well as
recommend the studies.
C32 Regarding the reference to Stekoll, Clement and Shaw on p. B-56.
R32 The typographical error in Stekoll's name has been corrected in the final
permit.
155
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C33 Regarding the insertion of two words into the first sentence of the first
full paragraph on p. B-56.
R33 The suggested insertion would change the intent of the sentence. The sen-
tence, which has been modified in the final permit, refers to an intertidal
location nearest the diffuser, in the area of the old Valdez dock.
C34 On p. B-57, (2) We suggest specifying Mytilus edulis or Limanda aspera as
additional species.
R34 It is likely that one of the two suggested species will be the third
species identified for hydrocarbon analysis, if found in suitable abun-
dance. While the suggestion that a filter-feeder such as Mytilus be used
in the study is appreciated, it seems appropriate to leave final selection
of the third species until after relative abundance has been documented by
the applicant's monitoring consultant. This initial reconnaissance may
show that Mytilus is an appropriate species for intensive monitoring.
Mytilus is the subject of extensive monitoring in Port Valdez as a part of
the Alyeska Pipeline Service Company NPDES permit.
C35 Page B-57, footnote 2, paragraph 1, is missing.
R35 The reference is to Lees, et al, "Intertidal and Shallow Subtidal Habitats
of Port Valdez," prepared by Dames and Moore for The Alpetco Company in
September 1979.
156
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INTRODUCTION TO NPDES PERMIT
The draft NPDES permit, which appears in Attachment B, has been modified
slightly as a result of comments received by the agency. Limitations have been
established for un-ionized ammonia (see p. 3 and 4 of the final permit). An ex-
planation of the rationale for these changes appears in Section IV, p. 150-151,
items C3 and R3. In addition, the State of Alaska Department of Environmental
Conservation has made several changes to the monitoring program. A listing of
these changes and their rationale is presented below, with references keyed to
the page numbers of the final permit. A copy of the final permit follows this
explanation.
Changes to E.2 - Receiving Water Monitoring - As Requested by ADEC
Page 19
Condition (1) Abundance and Zonation Studies: A sentence was added to provide
the consultant the flexibility of choosing specific sites within the general
areas listed.
%
Condition (2) Biological Studies of Intertidal Species: Axinopsida serricata
was substituted for Mya areneria because it is a common subtidal bivalve, more
abundant and widespread than M. areneria. Also, Axinopsida will allow examina-
tion of a subtidal dweller for comparison with Macoma balthica, a common inter-
tidal species.
The Airport Creek transect is added to the section on the study of individual
species so that parameters are examined at three locations consistent with those
listed in the abundance and zonation study section.
A. serricata is added to the condition index study to provide a measure of the
physiological response of both a common subtidal bivalve (Axinopsida) and a
common intertidal bivalve ( Macoma) to waste discharges. This is considered
important in order to evaluate effects under both stratified and nonstratified
plume conditions.
157
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Page 20
Axinopsida sampling location is specified here to make the paragraph consistent
with the previous paragraph.
Condition b Subtital Benthos Monitoring Program: The new wording adds a
single station at a location very near the diffuser at the approximate trap
depth as estimated in diffuser studies. It is considered important to evaluate
the extent of community response very near the diffuser at depths where the
effluent plume is likely to "layer out" under stratified hydrographic conditions
because it is at these locations that effects, if any, are likely to be found.
Such an approach may also provide valuable information on the threshold re-
sponses of specific species to wastes and allow for identification of the most
sensitive indicator species that would be useful in monitoring at more distant
locations. Also importantly, gradients in the response of the benthos as a
function of distance from the discharge point will be better defined by the
proposed station selection.
Page 21
Condition c Hydrocarbon Analysis: Indicated changes were made in (1) to pro-
vide for a measure of gradients in buildup of hydrocarbons in sediments as a
function of distance from the diffuser outfall. This change has also been made
in the Alyeska Pipeline Service Company discharge permit which requires similar
types of studies.
The compounds phenanthrene, fluorene and anthracene have been highlighted in
historic and recently published accounts as accumulating in sediments and have a
long residence time around chronic petroleum inputs, and, as such they serve as
an excellent indicator of buildup through time.
The species A. serricata was substituted for Echicerus echicerus because it is
more abundant in the subtidal area and the change here makes the section con-
sistent with earlier sections on monitoring of individual species, one of which
is A. serricata.
158
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Condition (d) Substitutions of Axinopsida for Echicerus for reasons above.
Addition of Nephtys to include a polyehaete species of differing feeding
behavior than Macoma or Axinopsida to evaluate whether any metal accumulations
differ as a function of feeding type, i.e. trophic level.
159
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Permit No.: AK-002763-4
Application No.: AK-002763-4
AUTHORIZATION TO DISCHARGE UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of the Federal Water Pollution
Control Act, as amended, (33 U.S.C. S1251 et seq; the "Act"),
is authorized to discharge from a facility located near Valdez,
Alaska,
to receiving waters named Port Valdez,
in accordance with effluent limitations, monitoring requirements and
other conditions set forth hereof.
This permit shall become effective on May 25, 1980.
This permit and the authorization to discharge shall expire at
midnight May 25, 1985.
Signed this 25th day of April, 1980.
Alaska Petrochemical Company, an Alaskan
Corporation (hereinafter called "Alpetco")
Direc 'ision
160
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Page 2 of 24
Permit No.: AK-002763-4
A. EFFLUENT LIMITATIONS, MATER QUALITY CONDITIONS, AND MONITORING REQUIREMENTS
1. During the period beginning at plant start-up and lasting through the expiration date, the
permittee is authorized to discharge treated process water, treated ballast water, treated storm
water, and untreated clean storm water from the treatment plant through the outfall diffuser system.
a. Such discharges shall be limited and monitored by the permittee as specified below:
1. WASTEWATER TREATMENT PLANT DISCHARGE LIMITATIONS
EFFLUENT CHARACTERISTIC DISCHARGE LIMITATION
Daily Average!/ Daily Maximum]./
Biochemical Oxygen Demand 467 + Ballast Water + Storm Water 878 + Ballast Water + Storm Water
(5-day) (BOD5) kg(lb)/day (1041) Allocation!/ Allocation!/ (1956) Allocation Allocation
Total Suspended Solids (TSS) 383 + Ballast Water + Storm Water 600 + Ballast Water + Storm Water
kg(lb)/day (838) Allocation Allocation (1321) Allocation Allocation
Chemical Oxygen Demand (COD) 2780 + Ballast Water + Storm Water 5360 + Ballast Water + Storm Water
kg(lb)/day (6096) Allocation Allocation (11,940) Allocation Allocation
Oil & Grease 141 + Ballast Water + Storm Water 266 + Ballast Water + Storm Water
kg(lb)/day (330) Allocation Allocation (610) + Allocation Allocation
1/ The Daily Average and Daily Maximum discharge limitations for BOD5, TSS, COD, and Oil and
Grease shall be the summation of the specified numerical limitation plus the Ballast Water and
Storm Water Allocations.
2/ Ballast Water Allocations are defined in Part A.l.a.3.
3/ Storm Water Allocations are defined in Part A.l.a.4.
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Page 3 of 24
Permit No.: AK-002763-4
1. WASTEWATER TREATMENT PLANT DISCHARGE LIMITATIONS (Continued)
EFFLUENT CHARACTERISTIC
Phenolic Compounds kg(lb)/day
Un-Ionized Anmonia mg/1
Sulfide Kg (lb)/day
Total Chromium kg (lb)/day
Hexavalent Chromium kg (lb)/day
Aromatic Hydrocarbons (BTX) mg/1
Cyanide mg/1
DISCHARGE LIMITATION
Daily Average
3.1 (6.9)
N. A.
2.5 (5.6)
7.7 (17.3)
0.48 (1.1)
N. A.
N. A.
Daily Maximum
6.37 (14.2^
2.31/
5.64 (12.7)
12.9 (29.5)
1.01 (2.4)
1.00
0.38
V Permittee may obtain a relaxation of this value, up to a maximum of 7.0 mg/1, upon the
showing to EPA and ADEC that the mixing zone boundary condition for NH3 of 0.030 mg/1 will
be continuously maintained.
-------
2. WASTEWATER TREATMENT
EFFLUENT CHARACTERISTIC
Flow
B0D5
TSS
COO
Oil and Grease
Phenolic Compounds
Ammonia as NH3 (un-ionized)
Sulfide
Total Chromium
Hexavalent Chromium
Cyanide
Density
Temperature
Nickel
Aromatic Hydrocarbons (BTX)
Aromatic Hydrocarbons (by GS-MS)
Selenium, Cadmium, Copper, Zinc, Lead
Methylene Chloride
T ri ch1oroethy1ene
Phenanthrene/Anthracene
1, 1, 2, 2-tetrachloroethane
parachlorometa cresol
1, 2-trans-dichloroethylene
dichlorobromomethane
N-nitrosodi-n-propy1 ami ne
bis (2-ethylhexyl) phthalate
Diethyl phthalate
tetrachloroethylene
Page 4 of 24
Permit No.: AK-002763-4
DISCHARGE MONITORING REQUIREMENTS
MONITORING REQUIREMENTS
Measurement Frequency
Sample Type
Continuous
Recording
Daily
24 hour composite
Daily
24 hour composite
Daily
24 hour composite
Daily
24 hour composite
Daily
24 hour composite
Daily
24 hour composite
Daily
24 hour composite
Daily
24 hour composite
Daily
24 hour composite
Daily
24 hour composite
Daily
Not Applicable
Daily
Not Applicable
2/weekly
24 hour composite
2/weekly
Grab
Monthly
Grab
Monthly
24 hour composite
Quarterly
Grab
Ouarterly
Grab
Quarterly
Grab
Quarterly
Grab
Quarterly
Grab
Quarterly
Grab
Ouarterly
Grab
Quarterly
Grab
Quarterly
Grab
Quarterly
Grab
Quarterly
Grab
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Page 5 of 24
Permit No.: AK-0002763-4
3. TREATED BALLAST WATER ALLOCATION
EFFLUENT CHARACTERISTIC
Flow
bod5
TSS
COD
Oil and Grease
DISCHARGE LIMITATION
Daily Average Daily Maximum
11,345 m3/Day
(2,995,000 gpd)
0.026 kg/m3
14,800 m3/Day
( 3,900,000 gpd)
0.048 kg/m3
MONITORING REQUIREMENTS
Measurement Frequency Sample Type
Continuous Recording
(0.21 lb/1000 gal) (0.40 lb/1000 gal)
0.021 kg/m3
0.033 kg/m3
(0.17 lb/1000 gal) (0.27 lb/1000 gal)
0.24 kg/n)3
(2.0 lb/1000 gal)
0.008 kg/m3
0.47 kq/m3
(3.9 lb/1000 gal)
0.010 kg/m3
(0.067 lb/1000 gal) (0.084 lb/1000 gal)
N/A
N/A
N/A
N/A
The total daily Ballast Water Allocation in kg/Day or lb/Day for BOD5, TSS, COD, and Oil and Grease
shall be determined by multiplying the appropriate daily average and daily maximum values by the
actual daily flow.
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Page 6 of 24
Permit No.: AK-0002763-4
TREATED STORM WATER ALLOCATION
EFFLUENT CHARACTERISTIC
Flow
B0D5
TSS
COD
Oil and Grease
DISCHARGE LIMITATION
Daily Average Daily Maximum
6,000 m3/Day 14,800 m3/Day
(1,584,000 gpd) (3,900,000 gpd)
0.026 kg/m3 0.048 kg/m3 N/A
(0.21 lb/1000 gal) (0.40 lb/1000 gal)
0.021 kg/m3 0.033 kg/m3 N/A
(0.17 lb/1000 gal) (0.27 lb/1000 gal)
0.19 kg/m3 0.37 kg/m3 N/A
(1.6 lb/1000 gal) (3.1 lb/1000 gal)
0.008 kg/m3 0.015 kg/m3 N/A
(0.067 lb/1000 gal) (0.126 lb/1000 gal)
MONITORING REQUIREMENTS
Measurement Frequency Sample Type
Continuous Recording
The total daily treated Storm Water Allocation in kg/Day or lb/Day for BOD5, TSS, COD, and Oil and
Grease shall be determined by multiplying the appropriate daily average and daily maximum values by
the actual daily flow.
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Page 7 of 24
Permit No.: AK-0002763-4
b. The pH shall not be less than 6.0 standard units nor
greater than 9.0 standard units and shall be recorded and monitored
continuously.
c. There shall be no discharge of floating solids or
visible foam in other than trace amounts or oily wastes which produce
a sheen on the surface of the receiving water.
d. Samples taken in compliance with the monitoring
requirements specified above shall be taken prior to the addition of
untreated "clean storm water" and prior to entering the outfall
system.
e. "Clean storm water" shall have a total organic carbon
(TOC) level less than 35 mg/1 and an Oil and Grease level less than
15 mg/1 prior to entering the final holding pond and firewater pond.
Any segragated "clean storm water" exceeding these limits shall
receive complete treatment (air flotation, biological oxidation, and
sand filtration).
f. An outfall diffuser system shall be utilized to provide
for the dispersal of the treated wastewaters to Port Valdez. A
mixing zone is provided in Port Valdez for the purpose of receiving
the discharge from the diffuser system. The boundaries of the mixing
zone are:
(1) The top of the mixing zone shall be at all times
five (5) meters below the receiving water surface.
(2) The bottom of the mixing zone shall be at all
times one half (0.5) meters above the bottom of Port Valdez.
(3) The sides of the mixing zone shall not be more
than 150 meters from the diffuser centerline.
(4) The ends of the mixing zone shall not be more than
150 meters from each end of the diffuser system.
g. The outfall diffuser shall be designed and located to
continually achieve a minimum dilution of 75 to 1 at all points along
the boundary of the mixing zone. A report containing all data
relative to the determination of dilutions (including worst case) and
the design and location of the diffuser system (including impacts
from seismic activities) shall be submitted six (6) months prior to
diffuser construction start-up to the Director, Enforcement Division
and the Alaska Department of Environmental Conservation (ADEC).
Before diffuser construction start up may begin the diffuser system
design and location must receive joint approval by the Director,
Enforcement Division and ADEC.
166
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Page 8 of 24
Permit No.: AK-0002763-4
If it is determined that worst case conditions cannot continually
achieve a 75 to 1 dilution, the permittee may request from EPA and
ADEC a reduction in the dilution rate upon the showing that the
boundary conditions as specified in Part A.l.h. are continually
maintained.
h. At all boundaries of the mixing zone, conditions of the
Alaska Water Quality Standards (18AAC 70.020) for marine waters shall
be maintained. In particular the following shall be achieved:
(1) The pH shall not be less than 6.5 standard units
or greater than 8.5 standard units, and shall not vary more than 0.1
pH unit from natural conditions.
(2) No measurable increase in sediment concentrations
above natural conditions.
(3) Total aromatic hydrocarbons in the water column
shall not exceed 10 ug/1 (micrograms per liter), or 0.01 of the
lowest measured continuous flow 96 hour LC50 for life stages of
species identified by the Alaska Department of Environmental Conser-
vation as the most sensitive, biologically important species in a
particular location, whichever concentration is less. There shall be
no concentration of hydrocarbons, animal fats, or vegetable oils in
the sediment which cause deleterious effects to aquatic life. Surface
waters and adjoining shorelines shall be virtually free from floating
oil, film, sheen or discoloration.
(4) Cyanide in the water column shall not exceed 5
ug/1.
(5) Un-Ionized ammonia (NH3) in the water column
shall not exceed 0.030 mg/1.
B. MONITORING AND REPORTING REQUIREMENTS
1. Representative Sampling
Samples and measurements taken as required shall be repre-
sentative of the volume and nature of the monitored discharge.
2. Reporting
Monitoring results shall be summarized each month on a
Discharge Monitoring Report fom (DMR; EPA No. 3320-1). These
reports shall be submitted monthly and are to be postmarked by the
14th day of the following month. Reporting shall begin at the
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commencement of discharge. Duplicate signed copies of these, and all
other reports herein, shall be submitted to the Director, Enforcement
Division, the Alaska Operations Office and ADEC at the following
addresses:
United States Environmental Protection Agency
Region 10
1200 Sixth Avenue
Seattle, Washington 98101
Attn: Water Compliance Section M/S 513
United States Environmental Protection Agency
Alaska Operations Office
701 'C1 Street - Box 19
Anchorage, Alaska 99513
State of Alaska
Department of Environmental Conservation
Region II
MacKay Building - Room 1206
Denali Street
Anchorage, Alaska 99501
3. Additional Monitoring by Permittee
If the permittee monitors any pollutant at the location(s)
designated herein more frequently than required by this permit, using
approved analytical methods as specified below, the results of such
monitoring shall be included in the calculation and reporting of the
values required in the Discharge Monitoring Report form (EPA No.
3320-1). Such increased frequency shall also be indicated.
4. Definitions
a. The "daily average concentration" shall be the
arithmetic average (weighed proportionally by flow volume) of all the
daily maximum concentrations made during a calendar month.
b. The "daily maximum concentration" shall be the
concentration for a sample determined for any calendar day when taken
as required in A.l.a.
c. A "composite sample" is a simple weighted propor-
tionally by flow volume. Either the volume of each individual sample
comprising the composite will be directly proportional to discharge
flow rate or the sampling interval (for constant-volume samples) will
be inversely proportional to the flow rates over the time period used
to produce the composite.
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d. The "daily average flow" is the total discharge volume
occurring during a calendar month divided by the number of days
within the calendar month for which a discharge occurred.
e. The "daily maximum flow" is the total volume of
discharge for any calendar day.
f. BOD5 means five (5) day biochemical oxygen demand.
g. MGD means millions of gallons per day.
h. mg/1 means milligrams per liter.
i. nvfyday means cubic meters per day.
j. gpd means gallons per day.
k. kg/m3 means kilograms per cubic meter.
1. lb/1000 gal means pounds per 1000 gallons.
m. kg means kilograms.
n. lbs means pounds.
0. "Bypass" means the intentional diversion of wastes from
any portion of a treatment facility.
p. "Severe property damage" means substantial physical
damage to property, damage to the treatment facilities which would
cause them to become inoperable, or substantial and permanent loss of
natural resources which can reasonably be expected to occur in the
absence of a bypass. Severe property damage does not mean economic
loss caused by delays in production.
q. "Upset" means an exceptional incident in which there is
unintentional and temporary noncompliance with technology-based
permit effluent limitations because of factors beyond the reasonable
control of the permittee. An upset does not include noncompliance to
the extent caused by operational error, improperly designed treatment
facilities, lack of preventive maintenance, or careless or improper
operation.
5. Test Procedures
Test procedures for the analysis of pollutants shall conform
to 40 C.F.R. Part 136, which contains a list of approved methods.
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Permit No.: AK-0002763-4
Procedures for Aromatic Hydrocarbons (BTX) under Part A.l.a.
will be indentical or equivalent to those used by the EPA contractor
Rockwell International titled "Aromatics in Oily Wastewaters: Deter-
mination of Benzene, Toluene, and Xylenes", during 1978 and 1979.
Test of permittee's effluent will measure Benzene, Toluene, Xylene,
and ethyl benzene content of the effluent.
Test procedures for Aromatic Hydrocarbon (GC-MS) under Part
A.l.a. will be identical to or equivalent to those used by the Envi-
ronmental Protection Agency titled "Sampling and Analysis Procedures
for Screening of Industrial Effluents for Priority Pollutants" dated
March 1977 and revised April 1977. Parameters to be reported include
Benzene, Toluene, o-Xylene, m-Xylene, p-Xylene, 1,2,3-Trimethylben-
zene, 1,2,4-Tri-methylbenzene, 1,3,5-Trimethylbenzene, Napthalene,
2,6-dimethylnaphtha- lene, 1-Methylnapthalene, 2-Methylnapthalene,
Pyrene, Benzo-a-pyrene, Chrysene, Fluoranthene, Acenaphthene, Fluo-
rene, 2,4-dimethylphenol, 1,2-dichloroethane, ethylbenzene, 4-nitro-
phenol, benzo-a-anthracene, anthracene, benzo-ghi-perylene and
phenanthrene. Trimethylbenzene and dimethylnaphthalene concentrations
can be reported as the sum of all isomers for each of these groups
(i.e. total trimethylbenzenes and total dimethylnaphthalenes).
Xylene isomers are to be reported individually, except that meta and
para isomers may be reported together.
Alternative techniques, jointly approved by the Director,
Enforcement Division, EPA, the Alaska Department of Environmental
Conservation (ADEC) may be substituted for the Aromatic Hydrocarbons
methods given above. Also after joint agreement between EPA, ADEC,
and the permittee, one or more of the Aromatic Hydrocarbon analyses
or surrogate methods under Part A.l.a. may be eliminated from
monitoring requirements.
6. Recording of Results
For each measurement or sample taken pursuant to the
requirements of this permit, the permittee shall record the following
information:
a. The exact place, date, and time of sampling;
b. The dates the analysis were performed;
c. The person(s) who performed the analyses;
d. The analytical techniques or methods used; and
e. The results of all required analysis.
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7. Records Retention
All records and information resulting from the monitoring
activities required by this permit including all records of analyses
performed, calibration and maintenance of instrumentation, and
recordings from continuous monitoring instrumentation shall be
retained for a minimum of three (3) years, or longer if requested by
the Director, Enforcement Division or ADEC.
8. Noncompliance Reporting
a. Noncompliance notification will be made when any of the
following situations occur:
below).
(1) Bypassing of any treatment facilities (Part C.5.,
(2) Facility upset (Part C.6., below).
(3) Failure of facility (Part C.7., below).
(4) Other instances not covered by above.
b. Noncompliance notification shall consist of at least
the following:
(1) A description of the discharge and cause of
noncompliance;
(2) the period of noncompliance to include exact dates
and times and/or the anticipated time when the discharge will again
be in compliance; and
(3) steps being taken to reduce, eliminate and prevent
recurrence of the noncomplying discharge.
c. Timing of report shall be consistent with the following:
(1) Permittee shall report telephonically within
24-hours from the time of becoming aware of any violation of a daily
maximum. A written submission shall be provided within five (5) days
of becoming aware of the noncompliance.
(2) Permittee shall provide a written report of any
violations of the monthly average. This report shall conform to a.
and b. above and be submitted concurrently with the Discharge
Monitoring Report as a separate report.
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C. GENERAL REQUIREMENTS
1. Reopener Clause
This permit shall be modified, or alternatively, revoked and
reissued, to comply with any applicable standard or limitation
promulgated or approved under Section 301(b)(2)(c) and (d), 303(c),
304(b)(2) and 307(a)(2) of the Act if the standard or limitation so
issued or approved:
(1) Contains additional or more stringent permit conditions which
are not technology based (e.g. conditions based on water quality
standards, or effluent standards or prohibitions under Section
307(a)); or
(2) Contains additional permit conditions controlling pollutants
listed as toxic under Section 307(a) of the Act or as hazardous
substances under Section 311 of the act and which are not contolled
by new source performance standards.
2. Modification
The permit may be modified, terminated, or revoked during
its term for cause as described in 40 C.F.R 122.31.
Any permittee who knows or has reason to believe that any
activity has occurred or will occur which would constitute cause for
modification or revocation and reissuance under 40 C.F.R. 122.31 must
report its plans, or such information to the Director, Enforcement
Division.
3. Right of Entry
The permittee shall allow the head of the Alaska Department
of Environmental Conservation, Director, Enforcement Division and/or
their authorized representative, upon the presentation of credentials
and such other documents as may be required by law,
a. to enter upon the permittee's premises where a point
source is located or where any records must be kept under the terms
and conditions of the permit;
b. to have access to and copy at reasonable times any
records that must be kept under the terms and conditions of the
permit;
c. to inspect at reasonable times any monitoring equipment
or method required in the permit;
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Permit No.: AK-002763-4
d. to inspect at reasonable times any collection,
treatment, pollution management, or discharge facilities required
under the permit; and
e. to sample at reasonable times any pollutants in the
ballast or process wastewater treatment streams.
4. Operation and Maintenance
The permittee shall at all times maintain in good working
order and operate as efficiently as possible all facilities and sys-
tems (and related appurtenances) for collection and treatment which
are installed or used by the permittee/for water pollution control
and abatement to achieve compliance with the terms and conditions of
the permit. Proper operation and maintenance includes but is not
limited to effective performance based on designed facility removals,
adequate funding, effective management, adequate operator staffing
and training, and adequate laboratory and process controls including
appropriate quality assurance procedures.
5. Bypass
a. Bypass is prohibited unless all of the following four
(4) conditions are met:
(1) Bypass is unavoidable to prevent loss of life,
personal injury or severe property damage;
(2) there are no feasible alternatives to bypass, such
as the use of auxiliary treatment facilities, retention of untreated
wastes, or maintenance during normal periods of equipment down-time:
(3) permittee makes notification in accordance with
Part B.8.b. and c.; and
(4) where the permittee knows in advance of the need
for a bypass, prior notification shall be submitted for approval to
the Director, Enforcement Division if possible at least 10 days in
advance. The bypass may be allowed under conditions determined to be
necessary by the Director, Enforcement Division to minimize any
adverse effects. The public shall be notified and given an
opportunity to comment on bypass incidents of significant duration,
to the extent feasible.
b. Prohibition of Bypass
The Director, Enforcement Division may prohibit bypass
in consideration of the adverse effect of the proposed bypass or
where the proposed bypass does not meet the conditions set forth in
Part C.5.a., above.
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6. Upsets
a. Effect of an Upset
An upset shall constitute an affirmative defense to an
action brought for noncompliance with such technology-based permit
effluent limitations if the requirements of paragraph b. below are
met.
b. Conditions Necessary for a Demonstration of Upset
The permittee who wishes to establish the affirmative
defense of upset shall demonstrate, through properly signed,
contemporaneous operating logs, or other relevant evidence that:
(1) An upset occurred and that the permittee can
identify the specific cause(s) of the upset;
(2) the permitted facility was at the time being
operated in a prudent and workman-like manner and in compliance with
proper operation and maintenance procedures;
(3) the permittee submitted information required in
Part B.8.b. and c.
c. Burden of Proof
In any enforcement proceeding the permittee seeking to
establish the occurrence of an upset shall have the burden of proof.
7. Failure of the Facility
The permittee, in order to maintain compliance with its
permit, shall control production and all discharges upon reduction,
loss, or failure of the treatment facility until the facility is
restored or an alternative method of treatment is provided. This
requirement applies in the situation where, among other things, the
primary source of power of the treatment facility is reduced, lost,
or fails.
The permittee shall report such instances in accordance with
Part B.8.b. and c. above.
8. Adverse Impact
The permittee shall take all reasonable steps to minimize
any adverse impact to waters of the United States resulting from
noncompliance with the permit.
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9. Removed Substances
Collected screenings, grit, sludges, and other solids
removed in the course of treatment or control of wastewaters shall be
disposed of in a manner such as to prevent entry of those wastes or
runoff from such materials into navigable waters unless otherwise
authorized in this permit.
10. Transferability of Permits
This permit may be transferred to another person by the
permittee if:
a. The permittee notifies the Director, Enforcement
Division of the proposed transfer;
b. a written agreement containing a specific date for
transfer of permit responsibility and coverage between the current
and new permittees (including acknowledgement that the existing
permittee is liable for violations up to that date, and that the new
permittee is liable for violations from that date on) is submitted to
the Director; and
c. the Director, Enforcement Division within 30 days does
not notify the current permittee and the new permittee of his or her
intent to modify, revoke and reissue, or terminate the permit and to
require that a new application be filed rather than agreeing to the
transfer of the permit.
D. RESPONSIBILITIES
1. Availability of Reports
Except for data determined to be confidential under section
308 of the Act, all reports prepared in accordance with the terms of
this permit shall be available for public inspection at the offices
of ADEC and the Director, Enforcement Division. As required by the
Act, effluent data shall not be considered confidential. Knowingly
making a false statement on any such report may result in the
imposition of criminal penalties as provided for in section 309 of
the Act.
2. Civil and Criminal Liability
Except as provided in permit conditions on "Bypass" (Part
C.5.) and "Upset" (Part C.6.) and "Failure of Facility" (Part C. 7."),
nothing 1n this permit shall be construed to relieve the permittee
from civil or criminal penalties for noncompliance.
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3. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the
institution of any legal action or relieve the permittee from any
responsibilities, liabilities, or penalties to which the permittee is
or may be subject under section 311 of the Act.
4. State Laws
Nothing in this permit shall be construed to preclude the
institution of any legal action or relieve the permittee from any
responsibilities, liabilities, or penalties established pursuant to
any applicable State law or regulation under authority preserved by
section 510 of the Act.
5. Property Rights
The issuance of this permit does not convey any property
rights in either real or personal property, or any exclusive
privileges, nor does it authorize any injury to private property or
any invasion of personal rights, nor any infringement of Federal,
State or local laws or regulations.
6. Severability
The provisions of this permit are severable, and if any
provision of this permit, or the application of any provision of this
permit to any circumstance, is held invalid, the application of such
provision to other circumstances, and the remainder of this permit
shall not be affected thereby.
E. OTHER REQUIREMENTS
1. Outfall Study
Permittee shall develop and implement a study which will
measure the actual diffusion and dispersion characteristics achieved
by the outfall diffuser system. The study shall extend for a one
year period with dispersion studies occurring at sufficiently close
intervals to evaluate the effects of the varied climate and seasonal
conditions, complete tidal cycles, and extremes in plume
stratification. The plan shall as a minimum describe the following:
a. Frequency and duration of testing;
b. Method of measuring dispersion and mixing;
c. Extent of testing in the vicinity around the outfall
system, and
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Permit No.: AK-002763-4
d. Type of dye, tracer material, or other material or
parameter to be used.
e. Hydrographic characterization at the sampling points.
The study plan shall be submitted to the Alaska Department
of Environmental Conservation, the Alaska Operations Office of EPA,
and the Director, Enforcement Division, EPA three (3) months prior to
commencement of facility operation. The outfall study shall commence
no later than three (3) months after start-up of the refinery
facility. Summary reports shall be submitted quarterly, with a final
report submitted no later than sixty (60) days following completion
of the study. Each report shall include all relevant data including
actual receiving water and effluent characteristics (affecting
dispersion and mixing) as well as times, locations, and duration of
test.
2. Receiving Water Monitoring
The permittee shall implement the following receiving water
and biological monitoring program for the waters of eastern Port
Valdez. The emphasis of the program is on monitoring for subtle
changes in water quality and sediment, sublethal responses of
resident biota to waste water discharges, and to sample intensively
at selected representative stations to provide an improved
statistical basis for analysis of the data. The following program
encompasses studies that are considered necessary to objectively
evaluate existing conditions and any chronic effects of low levels of
refinery/petrochemical effluent process water and ballast water
discharges on water quality and biota.
This program shall be implemented no later than two (2}
months following the effective date of this permit and will be
reviewed semi-annually.
The permittee shall submit semi-annual and yearly progress
reports on the studies to the Alaska Department of Environmental Con-
servation, Pouch 0, Juneau, Alaska, the Environmental Protection
Agency, Anchorage Office and Director Enforcement Division. Semi-
annual and annual reports shall be made available to other agencies
upon request. The first semi-annual report shall be due
on October 1, 1980, and semi-annually thereafter
through May 25, 1985. A final summary report, including all
data and conclusions contained by that time, shall be submitted
on November 25, 1984. This report shall include a synthesis of
data and a discussion and interpretation of major findings and also
principal investigator recommendations for future studies should any
such studies be necessary.
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The receiving water and biological monitoring program are to
include at least the following elements:
a. Intertidal Monitoring Program
(1) Abundance and Zonation Studies
Three (3) muddy, sandy intertidal transects are to
be maintained over the life of the permit. Sites: North Lowe River
(Dayville Flats), Old Valdez dock area and the Airport Creek area.
Specific sites within these areas shall be selected by the permittee's
contractor. Sampling intervals along the transects are to be
permanently marked. Three sampling periods: April or May, June or
July, and September of each year. Vertical intertidal coverage shall
be consistent with the range established by Myren and Pella for
studying the various Macoma complexes. A minimum of three (3)
sampling stations per transect shall be required.
Stratified random sampling methods and data analysis as
described by Myren and Pella (1977) shall be generally followed.
Temperature, salinity and suspended sediment shall be monitored
concurrent with each sampling period.
(2) Biological Studies of Individual Species
Macoma balthica (intertidal) and Axinopsida
serricata (subtidal) shall be individually monitored for purposes of
detailing important biological events, including, but not limited to:
a) seasonal and annual growth, b) reproductive biology (histological
examination of reproductive staging schemes, i.e. gametogenesis,
fecundity, spawning period), and c) mortality. Mya arenaria may be
selected as an alternate species should population densities be
sufficient for monitoring purposes. Sampling data reduction and
reporting methodologies shall be consistent with those specified in
sections 8.6 and 8.7 of the 1979 Final Report to Alyeska, Continuing
Environmental Studies of Port Valdez, Alaska, and those of Lees et
a]_. Sites: Old Valdez dock transect, North Lowe River (Dayville
Flats) and Airport Creek transect. Three sampling periods: April or
May, June or July and September of each year.
In addition to the study of selected biological
events of individual species as decribed above, the permittee shall
provide a measure of the overall biological condition of Macoma
balthica and Axinopsida serricata using methodologies consistent with
published accounts on this index of health. These accounts generally
specify the following ratios for calculating the index, either of
which are acceptable in reporting results:
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Permit No.: AK-002763-4
(Reference: Stekoll,
Clement and Shaw.
1978. Sublethal effects
of chronic oil exposure
on the interidal clam
Macoma balthica.
University of Alaska.
IMS)
(Reference: Anderson,
J. W. 1978. Condition
index and free amino
acid level of Protothaca
staminea exposed to oil
contaminanted sediment.
Battelle Northwest
Laboratories, Sequim,
Washington.)
Macoma and Axinopsida shall be collected (in stratified groups over
their vertical ranges) from the Old Valdez dock area intertidal
location nearest the diffuser. Establishment of suitable control
site(s) away from these areas to assess gradients in condition index
is a critical requirement of this study. Sampling frequency at all
sites shall be at least semi-annually in conjunction with the
elements in a.(l). and a.(2). above. Temperature, salinity and
suspended load shall each be monitored coincident with sampling.
b. Subtidal Benthos Monitoring Program
The deep subtidal benthos program shall consist of
annual grab sampling at each of the following stations: Stations 1,
2, 4, 5 and 8 of Feder's Valdez grid and a single station located
along the northern side of the mixing zone at the approximate plume
trap depth (i.e. between 40 to 60 meters depth). September is
suggested for the sampling period. Eight replicate grabs per
station shall be taken with a 0.1m2 Van Veen sampler. Analyses
shall be performed on the data consistent with methods outlined in
Section 9.4.3 of the Final Report, Continuing Environmental Studies
of Port Valdez, Alaska 1979, including statistical differences in
station mean wet weight biomass.
Temperature and salinity of the bottom water, suspended
sediment load and percent organic composition of sediments shall be
monitored concurrently with this program.
A shallow subtidal shelf sampling program (to approxi-
mately 6 meters below MLLW or the depth of shelf break) shall
Tissue dry weight (g) x ioo
(shell length in mm)
or
ash-free dry weight (q) v iqoo
(cm shell length)-*
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Permit No.: AK-002763-4
consist of at least semiannual transecting at adjacent extensions of
the three (3) intertidal sites in a. above, emphasizing the following
indicator species: Nepht.ys punctata, Axinopsida serricata and
Polydora quadrilobata. Sampling design shall follow methods
established by Lees et Temperature, salinity and suspended
solids shall be determined concurrent with each sampling period.
c. Hydrocarbon Analysis
(1) Sediment concentrations of aromatic, non-biogenic
petroleum hydrocarbons shall be monitored annually at intertidal and
subtidal stations identified in both a. and b. above; and from a
minimum of four (4) total sites located outside but within 0.05
kilometer of both the north and south sides of the mixing zone. A
fifth sample shall be taken from the bottom near the diffuser and
inside the sides of the defined mixing zone. At least two (2) of the
above five (5) samples shall be collected at the approximate trap
depth. Naphthalene, phenanthrene, fluorene, anthracene and total
alkylnapthalene concentrations should be individually highlighted in
the analysis of the suite of petrogenic hydrocarbons.
(2). Hydrocarbon levels shall be monitored at least
annually in the soft tissues of Macoma balthica, Axinopsida serricata
and a single additional species to be selected. Sample sites: each
of the intertidal and shallow subtidal transects discussed above.
d. Trace Metals
(1) Chromium, zinc, cyanide and cadmium levels shall
be determined at least annually in sediment samples from all subtidal
benthos stations and at sediments around the diffuser outfall at
sites identified in c.(l) above.
(2) Chromium, zinc, cyanide and cadmium concentrations
are to be determined in bottom water samples collected at stations
listed in c.(l) above concurrent with the taking of sediment samples.
(3) Chromuim, zinc, cyanide and cadmium concentrations
in Macoma balthica, Nephtys and Axinopsida serricata soft tissues are
to be determined for individuals sampled at each of the established
intertidal and shallow subtidal transect sites. Sampling interval to
be identical to that described for sediments and water.
3. Bioassa.y Monitoring
If appropriate methodology is developed which is mutually
acceptable to EPA and ADEC in which to perform bioassay monitoring to
determine acute toxicity levels of toxic pollutants from the expected
effluent discharge, EPA may initiate a permit modification for review
to establish a bioassay monitoring program to determine these levels.
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Permit No.: AK-002763-4
4. Mitiqative Measures
The permittee shall meet the following mitigative measures:
a. Design Criteria
(1) The final structural design of refinery components
shall incorporate a ground motion analysis which assesses the dynamic
behavior of the coupled site/refinery components.
(2) Culverts, bridges, and other drainage structures on
fish streams shall be designed to assure that water velocities will
not impede fish passage, and culverts shall be installed in concert
with the natural streambed to prevent "perched" conditions which
impede fish passage.
(3) Noise abatement components on refinery equipment shall
be used.
(4) Implement a sediment and erosion control program for
all disturbed soil surfaces to minimize erosion and subsequent
si 1 tation into the streams.
(5) The crude supply and product pipelines shall be
aligned to minimize the number of stream crossings, and shall be
buried to reduce the risk of hydrocarbon spills from accidential
pipeline damage and vandalism. However, the crude supply and
products pipelines from the plant site to the Richardson Highway
shall be elevated to avoid in-water crossing of the Robe Lake System
anadromous fish streams.
b. Groundwat er Suppli es
(1) The point of groundwater withdrawal shall be located
near the north edge of the site so that drawdown in the vicinity of
the Brownie and Corbin (Robe) Creeks is minimized. The groundwater
drawdown shall be monitored during plant operations.
(2) Additional water to Corbin (Robe) and Brownie Creeks
shall be provided to maintain winter flow if the water table is
1owered.
(3) Pollution of the groundwater source shall be mitigated
by the provision of impervious diking and surfacing of areas where
hazardous materials are stored.
c. Construction Related Activities
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Permit No.: AK-002763-4
(1) Construction work at the products dock shall be
scheduled between June 1 and July 15 to avoid the intertidal
spawning period for salmon in Solomon Gulch Creek.
(2) Trenching activities for burial of the effluent
pipeline in the intertidal zone shall be scheduled to avoid the pink
salmon run in nearby Sewage Lagoon Creek.
(3) Buried pipeline stream crossings shall be installed
during the least biologically sensitive time of the year employing
the construction method that is least damaging for that type of
stream. A stream bypass flume shall be utilized to carry stream
flows during pipe burial at Dayville Flats Creek. Construction at
most streams in the area shall be conducted between June 1 and July
15. Construction at the Lowe River shall take place between March 1
and June 15.
(4) Construction activities which could affect the streams
during no-flow or very low-flow periods shall be scheduled to
minimize the problems associated with increases in erosion and
turbidity.
(5) Dredging activities for the construction barge dock
shall be conducted outside the period of April 7 to June 7 to avoid
disturbance of juvenile salmonids present during that time span.
Operations shall be conducted with a clamshell to avoid fish entrap-
ment problems, and material shall be deposited inland.
(6) Construction and fill material shall be disposed of
only in approved landfill sites.
(7) Any damage to the Richardson Highway and Dayville Road
in the vicinity of the Alpetco operations shall be repaired to its
preconstruction condititon at the close of construction.
d. Spill Prevention, Control and Countermeasure
(1) The permittee shall develop and implement a spill
prevention, control and countermeasure plan, and an oil and
hazardous substances spill contingency plan for offshore and onshore
operations to reduce the chances of spillage of petroleum
hydrocarbons and to maximize the effectiveness of control and
cleanup measures in the event of a spill.
(2) Positive-seal liners shall be used in all ponds
containing hazardous materials.
182
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Page 24 of 24
Permit No.: AK-002763-4
(3) The permittee shall containerize any hazardous
materials temporarily stored on-site, using sealed 50-gallon drums
or similar sealable and transportable containers.
(4) Leak detection systems capable of detecting small
volumes and slow rates of leakage, and the proper use of valves in
in the pipelines shall be used to minimize potential spills.
e. The permittee shall assist in establishing an
interdisciplinary team of engineers, fishery biologists, and
hydrologists to provide early review of construction plans and
schedules.
f. The permittee shall establish training programs to meet the
staffing requirements of the proposed facility during its
construction and operations phases.
g. Collect rain runoff and snowmelt along the eastern
periphery of the site and direct it to a point on Corbln Creek
(Glacier) minimizing the potential for contamination of a portion of
the surface runoff.
h. Fences shall be installed around the construction camp and
all permanent facilities and garbage disposal areas to help minimize
human/bear interaction.
1. The permittee shall leave a buffer zone of undisturbed
natural vegetation with minimum radius of 91 m (300 ft) around all
bald eagle nest sites to reduce disturbance and prevent "blowdown"
of nest trees. Pipeline construction activities shall not be
conducted in the vicinity of active bald eagle nest during the
nesting period if the nests are active.
j. The permittee shall to the extent possible, locate project
facilities away from nesting areas or resting areas for migrating
bi rds.
k. If any historical or archaeological site is discovered, the
permittee shall stop construction work at the location and contact
the appropriate authorities.
183
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STATE OF ALASKA
DEPARTMENT OF ENVIRONMENTAL CONSERVATION
CERTIFICATE OF REASONABLE ASSURANCE
A Certificate of Reasonable Assurance, as required by Section 401 of the
Clean Water Act, has been requested by the Alaska Petrochemical Company,
an Alaskan Corporation, 601 W 5th Avenue, Suite 320, Anchorage, Alaska
99501, for authorization to discharge treated wastewater, treated ballast
water, and storm water from an outfall into waters of the State of Alaska.
The proposed activity is located in the subtidal zone, Section 3, T9S, R6W
in eastern Port Valdez, approximately 3 miles SE of the City of Valdez.
Public notice of the application for this certification has been made in
accordance with 18 AAC 15.180.
Water Quality Certification under Section 401 of the CWA is required for
the proposed discharge because the discharge will be permitted by an
Environmental Protection Agency, National Pollutant Discharge Elimination
System permit, identified as AK-002763-4.
Having reviewed the application, comments received in response to the
public notice, and the final conditions of the NPDES permit, the Alaska
Department of Environmental Conservation certifies that there is reasonable
assurance that the proposed discharge is in compliance with the requirements
of Section 401 of the Clean Water Act which includes the Alaska Water Quality
Standards, 18 AAC 70, and the Standards of the Alaska Coastal Management Program,
6 AAC 80.
C. Deming Cowles
Deputy Commissioner
184
-------
IF M
OFFICE OF THE GOVERNOR
DIVISION OF POLICY DEVELOPMENT AND PLANNING
April 3, 1980
JAY S. HAMMOND, Governor
Phone 465-3512
Pouch AD - Juneau 99811
Mr. W. James Sweeney, Director
Environmental Protection Agency
605 West Fourth Avenue
Anchorage, Alaska 99501
Mr. Dan Steinborn
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
St/bject: Alpetco NPDES EPA Water Quality Permit
State I.D. No. FP060-80040301
Dear Sirs:
The Division of Policy Development and Planning, in accordance with
Public Law 92-583 and 94-370 and Alaska Statutes 46.40.010, has completed
review of the consistency of the subject proposal with the Alaska Coastal
Management Program (ACMP).
As currently planned, we concur that the proposal 1s consistent with
ACMP.
However, if the project is substantially amended during Its Implementation
such that it affects the coastal zone differently than as represented in
the proposal we reviewed, we ask that you contact the State Clearinghouse
to determine if an ACMP review of the revision required.
cc:
Trances A. Ulme
'Director
Tom Barnes, Office of Coastal Management
Alpetco
R1kk1 Fowler, DEC
Commissioner McAnerney, CRA
Commissioner Webber, CED
Commissioner Ward, D0T/PF
Bob Baldwin, DNR
Bruce Barrett, ADF&G
J1m Caruth, C0E
01-A3LH
-------
PSD
-------
INTRODUCTION TO PSD CONSIDERATIONS
No comments were received on the PSD Preliminary Determination. One letter of
no comment was received from the U.S. Department of the Interior, Fish and Wild-
life Service, and it is printed on the following page.
This section also contains EPA's PSD Preliminary Determination, PSD Technical
Analysis, PSD Final Determination, the PSD permit and relevant state certifi-
cations. Notice of the Final Determination appeared in the Federal Register on
1 April 1980.
186
-------
DEPARTMENT OF THE INTERIOR
FISH AND WILDLIFE SERVICE
UNITED STATES
IN REPLY REFER TO:
1011 E. TUDOR RD.
ANCHORAGE, ALASKA 99503
(907) 276-3800
27
Mr. Michael M. Johnston, Chief
New Source Permit Section (M/S 521)
U.S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Johnston:
We have no official comments concerning the Prevention of Significant
Deterioration (PSD) permit application submitted by the Alaska Petro-
chemical company for a facility at Valdez, Alaska. We have taken an
interest however, in the possible impacts initiated by air emissions of
sulfur dioxide and nitrogen oxides on the freshwater environment in the
Valdez basin. Of particular concern is the potential increased acidi-
fication accumulations in the snowpack and discharge with spring snow
melt. Our office has prepared a proposal for research of such a potential
problem but as of yet it has not been funded. We do hope to see adequate
monitoring of the air quality in the Valdez area, by a regulatory agency,
to insure protection of the areafs fish and wildlife resources as well
as to maintain the present healthy and scenic environment. Thank you
for the opportunity to comment.
Sincerely
Area Director
cc: Bill Lamoreaux, EPA Anchorage
COMMENT
NOTED
187
R7-1
-------
PRELIMINARY DETERMINATION DOCUMENT
PREVENTION OF SIGNIFICANT AIR QUALITY DETERIORATION
PROPOSED CONSTRUCTION OF ALASKA
PETROCHEMICAL COMPANY'S OIL REFINERY AND
LOADING TERMINAL AT VALDEZ, ALASKA
SCOPE
This document, with the technical analysis, presents EPA's
preliminary determination of approvability of the Alaska
Petrochemical Company's (ALPETCO) proposal to construct a
refinery and loading terminal, pursuant to Title I, Part C
of the Federal Clean Air Act "Prevention of Significant
Deterioration of Air Quality" (PSD).
GENERAL INFORMATION
The Federal Clean Air Act requires review and approval of
the construction or modification of major sources of air
pollution to assure that the air quality in areas
attaining National Ambient Air Quality Standards (NAAQS)
is not deteriorated beyond allowable limits for all
pollutants regulated by EPA as a result of increased
emissions from such new or modified facilities. Before an
application to construct a major stationary source can be
approved, it must be demonstrated that the expected
emissions of all applicable pollutants above the minimum
level established by Section 169 of the Act will not
exceed the following:
1. Emission limits achievable by the application of
best available control technology (BACT)
2. National Ambient Air Quality Standards (NAAQS).
3. In the case of particulate matter and sulfur
dioxide, allowable air quality increments.
FINDINGS
A detailed technical analysis of the proposed refinery and
loading terminal has been conducted and it has been
determined that the Company proposes to install best
available control technology (BACT) in all process units
except the fluid catalytic cracker regenerator. In this
case EPA has determined that BACT will require additional
control to clean the flue gas from that unit and has set
the emission limits for that source and* the others in the
refinery as listed on .the attached table.
188
-------
- 2 -
A detailed discussion of this determination as well as
proposed record keeping and compliance testing are
contained in the technical analysis document.
Emissions of SO2, TSP, N0X» CO, and HC as limited
above, are not expected to cause or contribute to a
violation of any NAAQS or PSD increment.
RECOMMENDATION
Based upon a review of the application, EPA finds the
proposed construction, with additional control as required
to meet BACT on the FCC unit, will not cause violations of
the NAAQS or PSD increment*. Furthermore, the emission
limits required above for S02* TSP, CO, N0X, and HC
represent the BACT. Therefore, EPA proposes to approve
the ALPETCO request to construct an oil refinery and
ioading terminal at Valdez, Alaska. Comments are
requested from interested parties and will be carefully
considered when making the final determination.
189
-------
PRELIMINARY DETERMINATION DOCUMENT
TABLE
Emission Limitations
Source SO?
i / W'r
conc/efJ/ (Ib/hr)
NOx
kg/hr
conc/ef (ib/hr
PM
kg/hr opacity
conc/ef (Ib/hr) (*)
ro
kg/hr
conc/ef (ib/hr)
HC !
kg/hr Equipment
(lb/hr) or cperati
specif icat
Cements
ng
ions
Refinery Fuel
Gas
1 80mg/dscm H?S
J (0.035gr/
dscf)
The avpratjp SO?
emission factor for the
combined refinery
qas/fle*Icoker qas is
?4.3 nq/J (5fi.6
lb/109BTUl
Flexicoker Fuel
Gas
155mg/dscm
total sulfur
(0.067gr/dscf)
Combustion Devices
(Total!
85
(187)
70ppm 90
at 3t (198)
0?
34.4ng/J
(BOlb/
lO^BTO)
5
Low M0X burners anil
oxygen monttorings will
he used.
FluM Catalytic
Cracker (FCC)
12ppnt 5
(11)
0.75kg/ 20 20
1000kg (44)
coke
burnoff
SOOppm 96
(212)
Based on a 15X effi-
cient FGtl system.
Particulate concen-
tration is ahout
70tng/dscm or
0.03gr/dscf
Sulfur Recovery
0.015% 7.1
by volume (15.6)
OX 02
dry basis
Flexicoker Sulfur
recovery vent
0.8
(1.8)
Gas Turbines
3.2ng/J 3.2
(7 431b/ (7.1)
109BTU)
(0.0075E) 94
~F X (207)
by volume
at 15X 02
5
yT Based on the use of
refinery gas as fupl
// E *14.4kq/wa tt. hr
actual ISO hpat rate
F Fuel Bound Nitrngen*N
0 II < 0.015
O.Oi(N) 0.015 0.0067(H-0.n 0.1 < N <0.75
0.005 N > 0.?5
1/ conc/ef wans a concentration or an emission factor limitation
-------
PRELIMINARY DETERMINATION DOCUMENT
Source SO?
kg/hr
conc/ef (lb/hr)
N0X
kg/hr
conc/ef (lb/hr)
PM
kg/hr opacity
conc/ef (lb/hr) IX)
CO.
kg/hr
conc/ef (lb/hr)
tin
kg/hr Equipment
flb/lir) or operation
speci f icat ions
Solid HaUe
Incinerator
l.?S
(2.8)
70tng/ 0.04 10
dscm (.09)
0.03gr/dscf
Storage Tanks
58 Presswe tanks for liquids w,tb
U?B) 1VP 76.f>kPa. Internal floating
roofs with double seals or
equivalent for liquids with 10.3
TVP 76.fi kPa
Product loading
Terminal
A vapor recovery system to collect
and incinerate the HC emissions.
The design effie'ency of the
incinerator must exceed 99t.
Process fugitive
1—•
t—•
Specifications for valves, pumps,
and compressors must Include the
optimum sealing techniques
available from the
manufacturers. Process drains
must be trapped. Oil/water
separators must be covered. A lit
monitoring and maintenance plan
must be submitted to EPA for
approval 1 year prior to
projected refinery startup.
Page two
-------
Technical Analysis
for Prevention of Significant Deterioration
ALPETCO—Valdez, Alaska
December 31, 1979
I. Introduction
Alaska Petrochemical Company (Alpetco) proposes to construct a new
oil refinery near Valdez, Alaska to refine approximately 150,000
bbl/day of North Slope crude oil. The proposed new facilities will
include a refinery complex and a product loading terminal. The
location of the proposed facilities is shown in Figure 1.
Both the potential and allowable air emissions of sulfur dioxide
(SO2)» nitrogen oxides (N0X), particulate matter (PM), carbon
monoxide (CO), and hydrocarbons (HC) from the proposed facility
exceed the limits for PSD applicability for refineries (100
tons/year). Therefore, a BACT determination and an air quality
analysis are required for all sources which emit the above mentioned
pollutants. A summary of the air emissions from the refinery is
shown in Table 1.
II. Determination of Best Available Control Technology (BACT)
Definition of BACT
One of the criteria for approval of an application under the PSD
section of the Clean Air Act is that the control equipment proposed
for the source must be representative of the best available control
technology (BACT). BACT means an emission limitation based on the
maximum reduction of each pollutant achievable through-the use of
process modifications and emission control systems as determined by
the permitting authority. This determination is made on a
case-by-case basis, taking into account energy, environmental, and
economic impacts. The BACT emission limitation must be at least as
stringent as that established under Section 111 or 112 of the Clean
Air Act.
BACT for Petroleum Refineries
Several new source performance standards (NSPS) promulgated under
Section 111 of the Clean Air Act are applicable to the facilities
proposed for this refinery. Included are NSPS for the hydrogen
sulfide (H2S) content of refinery fuel gas (which indirectly
192
-------
aJL-2£L_S——^
scale in miles
PROPOSED
^ALPETCO
f SITE
~W, ^
CR
VALDEZ
AIRPORT
ISLAND
y latst
)tu*
rVALDE2
PORT
VALOEZ
CONSTRUCTION
BARGE DOCK
MOBILIZATION
AREA
, /
V '
WASTEWATER
OUTFALL
TIDELAMD
JACKSON
POINT
Its*
ALYESKA
TERMINAL *?J
Lf£?F \ .PRODUCTS
AREA \ /DOCK
, U Fig p.3»3
^o®£ R 'j££9
OAYm*.* *UST$
CRUDE
SUPPLY
\ LINE
ABERCROMBIE
CR
ROBE LAKE
PRODUCT
PIPELINES
Fig 3. 3-5
0>"»VER
-------
TABLE 1
Alpetco Refinery
Projected Annual Emissions to the Atmosphere 1/
{Tons per year)
Emission Source SO2 N0X PM CO HC
Process Combustion
Devices
842
2,148
108
182
32
Fluid Catalytic
Cracker
964
378
245
930
6
Sulfur Recovery Units
107
—
—
—
—
Gas Turbines
31
900
42
71
13
Solid Waste
Incinerator
12
4
<1
<1
—
Storage Tanks
—
—
—
—
560
Product Loading
Terminal
C 1
2
—
—
21/
Process Fugitive
—
—
—
—
7301/
Total 1,956 3,432 395 1,183 1,344
1/ Based on the company's proposed control levels at maximum production of 150,000
lb/day.
2/ EPA estimate based on revised control technique—thermal incineration.
3/ EPA estimte based on Radian study.
-------
Page 4
limits SO2 emissions from process heaters and boilers), CO and
particulate limitations on the fluid catalytic cracking (FCC)
regenerator, equipment specifications for hydrocarbon storage tanks,
an SO2 limitation on the tail gas from the sulfur recovery unit,
and N0X and SO2 limitations on the gas turbines. The specific
values of these NSPS are shown in Table 2.
SO? Sources
The five sources of SO2 emissions which must be addressed in the
BACT determination are fuel combustion devices, the sulfur recovery
unit, the gas turbines, the solid waste incinerator, and the FCC
regenerator. The heating requirements within a petroleum refinery
are met by first burning the fuel gas generated by the process
units. Since there is usually not enough fuel gas generated to meet
all the heating demand, the remaining heat is typically supplied by
burning oil or purchased natural gas. In this case Alpetco has
proposed a processing scheme which will eliminate the need to burn
oil during normal operation. This is primarily due to the inclusion
of a flexicoker which produces a significant quantity of low BTU gas
that can be burned to replace much of the heating requirement
typically supplied by burning oil. The remaining heat requirement
will be supplied by burning propane. The net effect is that SO2
emissions will be significantly lower for the proposed Alpetco
refinery because of the use of low sulfur refinery gas, flexicoker
gas and propane rather than oil. This is an example of a process
modification which reduces emissions.
Each of the gas systems (refinery fuel gas and flexicoker gas) will
be treated to remove hydrogen sulfide (H2S) prior to combustion in
the process heaters. Alpetco proposes to use amine treating to
reduce H2S in the refinery fuel gas to 50 ppm (about 0.033
gr/dscf) which 1s about one third the level of the applicable NSPS.
A Stretford sulfur removal system is proposed for the flexicoker
gas. H2S will be reduced to 10 ppm, but the total sulfur content
will be 100 ppm (about 0.066 gr/dscf) which 1s about two thirds the
level of the applicable NSPS. Because the flexicoker gas has a low
BTU content (about 110 BTU/scf), the SO2 emission factor in units
of pounds per billion BTU is considerably greater than for the
refinery fuel gas (171 vs 7,43 lb/10^BTU)t but it is still much
lower than for low sulfur fuel oil (300 lb/10'BTU for 0.3% sulfur
oil). Based on the factors discussed above the Alpetco proposal for
SO2 control from process combustion devices 1s representative of
BACT.
The H2S removed from the various gas streams and from the sour
water stripper 1s sent to a sulfur recovery unit and converted to
195
-------
Page 5
TABLE 2
Summary of NSPS for Petroleum Refineries
Facility
FCC
FCC
Any Combustion
Device
Petroleum
Storage Tanks
Pollutant
Particulate
CO
SO2
Hydrocarbons
Claus Sulfur
Recover Unit
SO2
Gas Turbines
NOv
SO?
Emission Limitation
1.0 kg/1000 kg of coke
burnoff
0.050 percent by volume
230 mg/dscm H2S in
the refinery fuel gas
Equipment specification
of floating roof with
double seals or vapor
recovery system
Remarks
0.025 percent by
volume at zero percent
O2, dry basis
75 ppm at 15 percent
oxygen and ISO ambient
atmosphere conditions
150 ppm
This is equivalent
to 0.1 gr/dscf.
This NSPS was pro-
posed May 18, 1978
and applies to
tanks greater than
151,416 liters
storing liquids
with a true vapor
pressure between
10.3 and 76.6 kPa.
This NSPS is not
applicable to
Claus plants
smaller than 20
long tons of
sulfur per day
which are
associated with a
small refinery.
The NSPS allows
for an adjustment
factor for turbine
efficiency and for
fuel bound
nitrogen.
A sulfur limit in
the fuel of 0.8
percent can be
used as an
alternate sulfur
limitation.
196
-------
Page 6
elemental sulfur. Alpetco proposes to install two Claus sulfur
plants in parallel, each capable of processing 100'percent of the
refinery H2S production. Since Claus sulfur plants typically
convert about 94-96% of the sulfur in the feed to elemental sulfur,
a significant amount of SO2 would remain in the tail gas and be
emitted if additional treatment was not employed.. Alpetco proposes
to construct a tail gas treatment unit which will reduce SO2 to
150 ppm compared to the NSPS emission limitation of 250 ppm. The
Alpetco proposal is considered to be representative of BACT.
The gas turbines will be fueled with refinery fuel gas. The
applicable NSPS for gas turbines is 150 ppm SO2 or 0.8% sulfur
fuel. As pointed out in the discussion on refinery fuel gas, the
SO2 emissions from burning refinery gas in the gas turbines are
about 100 times lower than for 0.8% sulfur oil. Therefore, the
Alpetco proposal for SO2 control from the gas turbines is
representative of BACT.
The emissions from solid waste Incinerator will be controlled with a
scrubber using mild caustic as the scrubbing liquid. This system
will remove at least 90 percent of the sulfur which is considered to
be representative of BACT.
The SO2 emissions contained in the exhaust gas from the FCC
regenerator result from oxidation of sulfur in the coke which is
formed on the FCC catalyst 1n the reactor portion of the FCC
process. SO2 emissions from the FCC regenerator can be reduced by
hydrotreating the feed to the FCC, by treating the regenerator flue
gas or by a combination of the two. Since hydrotreating of the FCC
feed has certain process benefits such as improved catalyst life,
higher gasoline yields, and elimination or reduction of the need for
hydrotreating the FCC product streams, FCC feed hydrotreating is now
typically selected for use in modern refineries. Alpetco states
that they view FCC feed hydrotreating as primarily an air pollution
control technique for reduction of SO2 emissions. Since both ends
are achieved through the use of FCC feed hydrotreating, It 1s
difficult to exactly allocate the costs of this unit to the process
and to air pollution control. If FCC feed hydrotreating is used to
reduce the FCC feed sulfur content by 95% as proposed by Alpetco,
the SO2 concentration in the regenerator flue gas will be about
225 ppm* and the SO? emission rate will be about 220 lb/hr. This
Is the largest single source for which there 1s any reasonable
potential for further SO2 reduction. Alpetco briefly discusses a
few of the possibilities for flue gas desulfurizatlon (FGD); but
after pointing out a few problem areas with the Exxon FGD process,
the company decided not to propose a FGD system for the FCC.
197
-------
Page 7
Several FGD processes are feasible for control of the FCC
regenerator flue gas. These include a number of wet systems such as
the Exxon process mentioned in Alpetco's application, sodium based
scrubbers with or without sodium regeneration, and the newer dry
absorber system. The Exxon scrubber system was specifically
designed for FCC units to control PM, SO2, and to a lesser extent
condensible HC. It is installed at several Exxon refineries and is
achieving about 95% SO2 removal. The small water purge stream (20
gpm) which Alpetco cited as a potential water discharge problem
could be treated to remove the dissolved solids or to eliminate the
waste water stream without significant difficulty or cost.
Several companies supply double alkali SO2 scrubbing systems which
are capable of removing 90 to 95% of the SO2 emissions. If sodium
regeneration is employed, no waste water is generated and the filter
cake is 50-70% solid calcium sulfite/calcium sulfate.
The available dry absorption systems are based on the use of a spray
dryer and a particulate collection device such as a baghouse or
electrostatic precipitator. Although this is a relatively new
application for this technology, the major equipment (spray dryers
and baghouses or electrostatic precipitators) have been used in
other similar industrial applications for many years. SO2 removal
up to 90 percent is possible with the dry scrubbers; however, the
incremental cost rises steeply after 70-75 percent removal. The
recent NSPS for coal fired power plants took into account the
desirability of the dry scrubber approach and its applicability to
SO2 control when low sulfur coal is burned, by allowing low sulfur
coal users to meet a 70 percent SO2 removal efficiency
requirement. The dry scrubber system obviously does not present a
water discharge problem or a wet sludge disposal problem and would
require fewer safeguards for freeze protection.
An SO2 control situation similar to this case arose in a recent
PSD application for an aluminum smelter modification. A PSD permit
was issued to Martin Marietta Aluminum in 1978 which required FGD
for two streams which are larger (165,000 and 185,000 acfm) and have
a lower SO2 inlet concentration (about 150 ppm SO2). Originally
the company did not think that SO2 control was feasible for this
source. However, after further engineering analysis a highly
efficient and successful SO2 control system was designed and
installed. The Flakt sodium based scrubber system was selected and
has exceeded the 70 percent SO2 removal efficiency requirement by
a significant margin and has been operating satisfactorily. Each of
the Flakt scrubbing systems cost less than $2 million.
198
-------
Page 8
Alpetco raised a few other problems associated with FGD for the FCC
including possible acid mist from the wet plume, equipment damage
from freezing, and the cost of control. Although these questions
should be addressed in the design of any FGD system, they do not
appear to be insurmountable. For example, the use of properly
designed demisters and reheat of the stack gases would overcome the
potential acid mist problem as would the choice of the dry scrubber
system. Certain design features such as insulation, steam tracing,
enclosed buildings and proper pump and piping design would protect
the equipment from freeze damage. The capital cost of $5-6 million
presented by Alpetco for FGD appears to be a high estimate.
However, even $6 million is less than 0.5 percent of the total
capital investment of the refinery, and the estimated annualized
cost of $2 million per year is about $0.04 per barrel of refinery
throughput. Alpetco did not indicate the economic impact of such
costs, but without further information to the contrary it does not
appear that these costs have a significant impact on the financial
feasibility of the project.
Based on the information contained above, FGD is required to satisfy
the BACT requirement. Ninety-five percent SO2 removal appears
technically and economically feasible for the FCC and the emission
limitations of 12 ppm SO2 and 11 Ib/hr are based on that removal
efficiency.
NOv Sources
The primary sources of N0X emissions are the gas turbines, the
process heaters, and the FCC regenerator. Only the gas turbines are
covered by a NSPS for N0X at this time. Alpetco proposes to meet
the NSPS emission limitation of 75 ppm at 15£ oxygen, dry basis.
Since the NSPS for gas turbines is relatively recent (promulgated
September 10, 1979) and there have not been any significant advances
in control technology for gas turbines since that date, BACT for
N0X from gas turbines is determined to be equivalent to the NSPS
value of 75 ppm.
N0X emissions will be minimized from the process heaters by a
combination of burning gas rather than oil and using burners
especially designed to reduce N0X (termed low-N0x burners). The
use of low-NOx burners reduces N0X emissions at least 30 percent
to less than 0.08 lb/106BTU which is determined to be BACT for the
process heaters.
At the present time there is no available control technology for
N0X from the FCC regenerator. Therefore, the emission limitation
representative of BACT 1s simply the value of the estimated
uncontrolled emissions (90 lb/hr).
199
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Page 9
Particulate Sources
The primary particulate sources are the process heaters, the FCC
regenerator, the gas turbines and the solid waste incinerator. The
company proposes to burn gas and monitor oxygen in the flue gas of
the process heaters to maintain optimum combustion conditions.
These measures will minimize particulate emissions to about 10
lb/109BTU which is representative of BACT.
Alpetco proposes to control particulate matter (PM) from the FCC
with an electrostatic precipitator (ESP) to a level of 1 lb/1000 lb
coke burnoff which is the NSPS emission limitation for this source.
In order to meet the NSPS, the ESP will remove 90 percent of the PM
to a concentration of about 0.04 gr/dscf. Considering PM control
alone an ESP or other control device such as a baghouse or venturl
scrubber are capable of achieving lower PM concentrations.
Depending on the source category, levels of 0.02 or as low as 0.01
gr/dscf have been achieved. Since the company did not present a
BACT analysis evaluating alternative control levels for this source,
there is no evidence that this source could not achieve better PM
control by sample increasing the collection plate area in the ESP.
Since SO2 must also be controlled for this source, the BACT
determination for PM must be considered in combination with SO2
removal.At this time the specific SO2 control system has not been
selected. Therefore, it is difficult to precisely evaluate the
impact of various levels of PM control. For example, if a dry SO2
scrubber system is used with a baghouse, a PM level of 0.02 gr/dscf
would be representative of BACT. However, if a wet scrubber system
using a venturi scrubber for PM control is selected, 0.03 gr/dscf is
representative of BACT.
In order to allow reasonable flexibility in designing an optimum PM
and SO2 control system for the FCC, a PM emission limitation of
0.75 lb/1000 lb coke burnoff (about 0.03 gr/dscf) is determined to
be representative of BACT.
Particulate matter from gas turbines results from ash introduced in
the fuel or injection water and from incomplete combustion of the
fuel. The only feasible control techniques are to limit the ash
content of the fuel and the solids content of the injection water
and to operate the turbine in a manner which results in good
combustion. Alpetco proposes to burn refinery gas which has
essentially no ash and to operate the turbines to achieve efficient
combustion. Therefore, BACT for PM is determined to be 9.6 Ib/hr
maximum for the gas turbines which is based on the company's
proposal to burn gas and use efficient operating procedures.
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The solid waste incinerator will be controlled by a wet scrubber of
90 + percent efficiency. The resulting PM emissions of 0.03 gr/dscf
(0.09 lb/hr) are representative of BACT.
CO Sources
The FCC regenerator, the process heaters, and the gas. turbines are
the major sources of CO. The company proposes to limit CO emissions
from the FCC regenerator to the level of the NSPS (500 ppm) by
controlling the operating conditions within the regenerator to
oxidize most of the CO to CO2. The only other available control
technique requires the installation of an external CO boiler which
is considerably more expensive and not significantly more
efficient. Therefore, the Alpetco proposal to meet the NSPS CO
emission limitation of 500 ppm is representative of BACT.
CO emissions from the process heaters are minimized by burning gas
rather than oil and monitoring the combustion parameters especially
oxygen to insure good combustion. Since Alpetco proposes to employ
both of these measures to limit CO emissions to 17 lb/109BTU,
their proposal is representative of BACT.
CO emissions from the gas turbines will be minimized by the same
techniques as for the process heaters which are representative of
BACT.
HC Sources
Hydrocarbons are emitted from process stacks (primarily the process
heaters), storage tanks, the product loading terminal and fugitive
sources such as valve stems, pump and compressor seals, drains and
oil/water separators. The only feasible measures to minimize
hydrocarbons from the process combustion sources is to use fuel gas
rather than oil and to maintain good combustion conditions. The
Alpetco proposal which will employ both measures is considered to be
representative of BACT.
Alpetco proposes to control hydrocarbon emissions from storage tanks
by: (1) using pressure vessels for hydrocarbons with a true vapor
pressure (TVP) greater than 76.5 kPa. The pressure vessels will be
equipped with a pressure relief valve discharging to the flare
system; (2) using internal floating roofs with double seals for
hydrocarbons with a TVP greater than 10.3 kPa but less than 76.6
kPa. These control techniques are in compliance with the applicable
NSPS and are considered to be representative of BACT. Further
hydrocarbon control could potentially be achieved by using floating
roofs on nine large storage tanks in heavy oil service (TVP<10,3
kPa). Alpetco submitted an analysis of this option which showed the
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incremental capital cost to be about $12 million. The hydrocarbon
emission reduction associated with this expenditure was less than 20
percent of the total refinery hydrocarbon emissions (after control)
and was not considered sufficient to justify the added investment.
Therefore, in this case BACT for heavy oil storage tanks is
considered to be cone roof tanks.
In their original PSD application Alpetco proposed to employ certain
operational procedures such as submerged filling to reduce
hydrocarbon losses at the product loading terminal. Upon EPA's
request Alpetco re-examined the available control alternatives for
this source and now proposes to collect and incinerate the
hydrocarbon emissions. Collection and incineration which will
eliminate essentially all hydrocarbon emissions (about 200 tons per
year) from product loading is considered to be representative of
BACT.
Hydrocarbons will be emitted from a multitude of small source within
the process units such as valve stem packing, pump and compressor
seals, drains, flanges, and oil/water separators. These are termed
process fugitive emissions. Alpetco proposes to build into their
design certain features to minimize process fugitive emissions and
to conduct a monitoring and maintenance program after startup to
keep the process fugitive emissions at a minimum. The proposed
design features include reducing the number of flanges by welding as
many joints as possible; using double mechanical seals, tandem
mechanical seals or equivalent on pumps; ordering the optimum
sealing arrangment offered by the compressor vendors; trapping all
process drains and covering the oil/water separators.
The other part of the process fugitive control plan 1s a monitoring
and maintenance program. Recent research has shown that a few
sources with high leak rates make up the bulk of the total process
fugitive losses. The objective of the monitoring and maintenance
program is to screen all the sources to identify the high leakers
and have them repaired. Alpetco proposes to institute such a
program although the details are not completely finalized at this
time. EPA agrees that the proposed two pronged approach is
representative of BACT for process fugitive hydrocarbon sources.
Rather than itemize in detail all the requirements of a monitoring
and maintenance program, the permit conditions will require the
company to submit a detailed plan a year prior to startup for EPA
approval. This approach will allow the company to incorporate the
latest developments of EPA sponsored research 1n this subject area.
Ill Ambient Air Quality Analysis
Based on the potential and allowable emissions discussed in Section
II, the proposed refinery project 1s subject to ambient air quality
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review for SO2, TSP, CO, and NO2. For each of these pollutants
the air quality analysis must demonstrate that the emissions from
the source will not cause or contribute to a violation of either a
national ambient air quality standard (NAAQS) or a PSD increment.
The proposed refinery is also subject to ambient air quality review
for hydrocarbons. This pollutant will be discussed separately in
Subsection F.
A. Existing Conditions
Topographically the area surrounding Valdez, Alaska is extremely
complex. Port Valdez itself is essentially a fjord encompassed on
all sides by mountains which rise abruptly to four to five thousand
feet above sea level. Interspersed among the mountains are glacial
and river valleys which feed into the "bowl-like" Port from all
directions. The irregular topography with its resulting
mountain-valley wind circulation, plus the added complexity of the
land-water interface, make an attempt to model pollutant transport
and dispersion in such terrain extremely difficult.
The entire area within the region of air quality impact of the
proposed refinery is designated at Class II for purposes of PSD. In
addition, all currently existing sources in the Valdez area
contribute only to the baseline concentration, i.e., none of the PSD
increments have been consumed.
Meteorology and ambient air quality have been monitored in Port
Valdez at the locations indicated in Figure 2. Table 3 lists each
of the locations along with the pollutants and/or meteorological
parameters being monitored, and the approximate period of record
which was available for consideration for this PSD review.
A summary of the available air quality data is contained in Table
4. Air quality data from both the Alpetco and Alyeska monitoring
networks form the basis of this summary. The highest measured value
from both networks for the available period of record is listed for
comparison with the appropriate NAAQS. Existing ambient levels of
CO and NO2 are low. The indicated TSP levels are also low,
however, 1t should be noted that the period of record does not
include the summer months when higher TSP levels would be expected.
Moderate levels of O3 and SO2 have been measured rather
infrequently in Valdez. Based on all of these data 1t appears that
NAAQS are not threatened by existing sources of air pollution in
Valdez.
203
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LOCATION OF METEOROLOGICAL DATA SOURCE
USED IN MCRSVAL MODELING ANALYSES,
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Table 3
AIR QUALITY/METEOROLOGY MONITORING IN VALDEZ
LOCATION*
Alpetco Site 1
Alpetco Site 2
National Weather
Service (WSO)
Valdez Airport
Coast Guard and
Robe River
East Gate and
Quarry
PARAMETERS
MONITORED
S02, TSP, CO, O3, NO2
Wind speed, wind direction,
temperature.
SO2, TSP, CO, O3, NO2
Wind speed, wind direction,
mixing height, temperature.
Wind speed, wind direction,
temperature, cloud cover,
ceiling height, (24 obser-
vations per day).
Wind speed, wind direction,
cloud cover, ceiling height
(daytime only, 8 observations
per day).
S02» NO2, O3, total
hydrocarbons.
SO2, wind speed, wind
direction.
AVAILABLE
PERIOD OF
RECORDfapprox.)
12/78 - 6/79
2/79 - 6/79
7/75 - 6/79
7/78 - 6/79
9/78 - 6/79
9/78 - 6/79
*See Figure 2.
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Table 4
SUMMARY OF AIR QUALITY DATA
in micrograms per cubic meter
POLLUTANT
SO2 3 hour
24 hour
TSP 24 hour
CO 1 hour
8 hour
O3 1 hour
NO2 arithmetic mean
Total
Hydrocarbons 3 hour
HIGHEST
MEASURED VALUE
265**
105
48
5,725
2,290
145
8
62
NAAQS*
1,300
365
150
40,000
10,000
235
100
160
* National Ambient Air Quality Standard
** Value may have been higher—instrument pegged for 4 hours.
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Figure 3 is a graphic display of the joint frequency distribution of
wind speed and wind direction (a wind rose) measured by the National
Weather Service at the Coast Guard Building in Valdez. This station
has the longest period of record in Valdez, although it is a very
short period of record relative to other locations in the U.S. Most
important to note is the relatively high percentage of reported
calm surface winds (33.2%). This is mainly a result of the
"bowl-like" topography which minimizes the effects of synoptic scale
winds at the surface. Some average mixing heights which were
determined from a very limited set of data are listed in Table 5.
The mixing height can be thought of as the upper limit of vertical
dispersion of air pollutants. Relative to other locations in the
U.S. (Holzworth, 1972), the average mixing heights are very low.
Due to the high frequency of calm conditions and low average mixing
heights, dispersion conditions in Valdez can be characterized as
generally poor.
B. Regulatory Framework
To establish the regulatory framework for this very difficult air
quality modeling problem, a few important quotes from EPA's
"Guidelines on Air Quality Models" (EPA, 1978) are pertinent. (This
guideline is incorporated by reference into PSD regulations.)
p. 19 "Gaussian models are considered to be state-of-the-art
techniques for estimating concentrations of sulfur dioxide
and particulate matter. They are the best choice for most
point source evaluations. For all point sources two levels
of sophistication in the use of models are suggested. The
first level is composed of models which can provide a
preliminary estimate of concentrations. If it is estimated
by the screening technique that a source may cause a
concentration that is an unacceptable portion of an
allowable air quality increment, then that source should be
subjected to a more refined analysis."
In a paragraph mentioning screening techniques the Guideline says
that the "Valley Model is applicable to some complex terrain
situations". However, about refined techniques, the Guideline says
(p. 20) "No refined, widely available models applicable to complex
situations are identified. It is recommended that each complex
situation be treated on a case-by-case basis with the assistance of
expert advice." And if "...refined models applicable to a complex
situation do not exist, then 1t may be necessary to base estimates
of source impact...on only the estimates provided by the screening
techniques."
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HOURLY AVERAGE SURFACE WINDS PRECENTAGE FREQUENCY
OF OCCURANCE VALDEZ WSO WIND ROSE (7/75-12/78) Figure 3
208
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Table 5
VALDEZ SEASONAL MIXING DEPTHS*
(Meters)
Valdez
Lowe
Shoup
Valdez
Alyeska
Alpetco
Season
Airport
River
Spit
Narrows
Terminal
Site 2
Summer
221
—
194
186
166
—
Fall
—
221
—
111
—
—
Winter
--
184
—
105
—
—
Spring
310
*A11 values except Alpetco Site 2 determined from limited set of aircraft temperature
soundings taken in 1971 and 1972 (Alyeska, 1974). Alpetco Site 2 values determined from
limited set of acoustic sounder measurements during 1979.
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Page 19
C. Model Methodology
Faced with the difficult task of modeling air quality in Valdez and
in light of regulatory guidance, Alpetco used three models to
estimate air quality impacts: '
1) The Valley Model (Burt, 1977), an EPA Gaussian screening model.
2) MCRSVAL (for Multi-CRSTER/Valley), a Gaussian hybrid model
developed by Dames & Moore, consultants to Alpetco.
3) RADM (for Random-Walk Atmospheric Dispersion Model), a refined
numerical model also developed by Dames & Moore.
1. The Valley Model is basically a Gaussian model which was
developed by EPA to estimate the air quality impact of stabilized
plumes on hillsides in complex terrain. Valley is considered by EPA
to be a screening technique, and as such it provides an upper limit
estimate of the second highest 24-hour concentration that would
occur during a year. Valley is appropriate if the worst-case
meteorological conditions for a particular area might be those which
would cause an elevated stablized plume to impact terrain. Valley
is therefore considered appropriate for application to Valdez to
identify potential threats to 24-hour NAAQS. Due to the arbitrary
assumptions in the model it is not appropriate to estimate a 3-hour
impact. The model does, however, have an option to calculate an
annual impact.
2. MCRSVAL was developed by Dames & Moore from two EPA models:
CRSTER and Valley. CRSTER is a single source, flat-terrain model
whose most important feature is the ability to calculate hourly
concentrations from the input of hour-by-hour meteorological
conditions for one or more years of data. CRSTER was modified by
Dames & Moore to accept spatially separated sources and this became
Multi-CRSTER. This model has been previously accepted by EPA Region
10 for a PSD application in flat terrain. Multi-CRSTER was then
modified to include the terrain impact algorithm which is in the
Valley Model, and the result is MCRSVAL. It is essentially the
Valley Model modified to calculate hour-by-hour concentrations.
MCRSVAL treats the input wind speed differently than the Valley
Model. Valley simply assumes that the input wind speed applies
throughout the mixing layer. MCRSVAL, on the other hand, assumes
that the input wind speed applies at 10 meters above the surface and
that the wind speed increases with increasing height above the
surface as is normally the case in the real atmosphere. For a given-
set of input meteorological conditions the MCRSVAL estimate would be
less than the Valley estimate since concentration is inversely
proportional to wind speed in the model calculations.
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Page 20
Even though MCRSVAL is designed to accept the more refined,
hour-by-hour meteorological input, it can not be considered a
refined model in the sense indicated by EPA's "Guideline on Air
Quality Models". To take the arbitrary assumptions in the Valley
model and assume they apply on an hour-by-hour basis to the actual
physical conditions in Valdez as MCRSVAL does, is stretching the
application of the model well beyond where it was intended and where
there is a technical basis to do so. MCRSVAL is therefore not
considered appropriate for calculating a 3-hour estimate. However,
it can be considered a screening technique for the 24-hour estimate,
in the same way as the Valley Model, to identify potential threats
to ambient standards or increments. MCRSVAL can also provide an
estimate of the annual average impact.
3. RADM is a sophisticated mathematical representation of transport
and diffusion which can be applied in complex terrain situations.
Its application to Valdez suffers from two major problems: a lack
of necessary detailed input data and a possible tendency to
underestimate concentrations. Much detailed meteorological
information is needed to properly specify the initial conditions and
the boundary conditions in the model. This is particularly true for
vertical wind profiles, for example. Vertical wind data from
several locations around the area would be essential input to a
three-dimensional model of Port Valdez. The "Guideline on Air
Quality Models" recognizes this problem inherent in sophisticated
numerical models when it states on p. 15 that "A model which
requires detailed, precise input data should not be applied when
such data are unavailable." In addition to the lack of data
problem, RADM may tend to underestimate concentrations due to its
treatment of calm winds, plume impingement on elevated terrain, and
diffusion close in to a source. Although RADM has the potential to
better represent the actual physical conditions in complex terrain,
the technical basis to accept the model results is inadequate.
D. Model Input
To estimate maximum concentrations for comparison with the NAAQS,
the emissions from all existing sources in the Port Valdez area and
the proposed Alpetco sources were included in the model analysis.
Emissions from the proposed Alpetco sources only were used as input
to determine compliance with the PSD increments. To ensure that
maximum values were modeled, emission rates from all stationary
sources were based on maximum allowable limits, or they were based
on maximum design capacity if limits are not specified. Maximum
3-hour and 24-hour average emission rates were determined for ships
based on worst-case operating scenarios and assuming the ships were
burning fuel containing 2% sulfur.
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Page 21
Initially, MCRSVAL and Valley were run using generalized receptor
grid systems to identify potential problem areas. Figure 4 shows
the general receptor grid used in MCRSVAL; the general grid used in
Valley is similar. The high concentration areas identified by the
general grid were then modeled with a very refined (closely spaced)
receptor grid in order to determine the maximum concentration
values. Figure 4 also identifies the refined grid areas.
Meteorological input to the Valley Model for the 24-hour estimate
includes a low wind speed (2.5 meters per second) and moderately
stable atmospheric conditions. Furthermore, the wind is assumed to
be in a given direction for 6 hours out of the 24-hour period. All
wind directions were modeled to determine maximum impacts. For the
annual impact estimate the Valley Model requires a joint frequency
distribution of wind speed, wind direction, and stability, i.e., a
stability wind rose. A stability wind rose was developed from the
one-year meteorological input files used in MCRSVAL discussed below.
MCRSVAL requires a meteorological file which contains values for
wind speed, wind direction, stability, surface temperature, and
mixing height for each hour of a year. Due to expected differences
in winds which affect the two major groups of sources, Alpetco and
Alyeska, two separate meteorological input files were developed—one
for existing sources and one for proposed sources. Since a complete
year of data is not available from Alpetco Site #1, which would be
most representative of the meteorology affecting the proposed
Alpetco sources the Site #1 data had to be supplemented with data
collected at the Valdez Airport and at the Coast Guard Building by
the National Weather Service. Figure 5 is a wind rose from the
input for proposed sources. The meteorological input file for
existing sources was made up mainly from data collected at Jackson
Point, supplemented by data collected at the Coast Guard Building..
MCRSVAL uses the input files of hourly data to calculate a
concentration at each receptor for each hour of the year. The model
then calculates average concentrations for each 3- and 24-hour
period of the year and identifies the maximum values.
E. Model Results
CO—To determine whether or not the CO emissions from the proposed
Alpetco sources would cause a significant impact, MCRSVAL was used
with Alpetco sources only. The maximum concentrations occurred on
the hillside east of the refinery. The results are presented in
Table 6. The maximum values are below the Level of Significance
indicating no further air quality analysis is required for CO
emissions.
212
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FIGURE 4
MCRSVAL RECEPTOR GRID
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Page 23
N
NNW NNE
WIND SPEED SCALE IN KTS
1.0 3-0 6.0 10.0 16.0
TO TO TO TO TO OVER
3.0 6.0 10.0 16.0 21.0 21.0
FIGURE 5
HOURLY AVERAGE SURFACE WINDS
PERCENTAGE FREQUENCY OF OCCURRENCE
PROPOSED SOURCES WIND ROSE (6/1/78 - 5/31/79)
214
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Table 8
CO AND NO2 RESULTS
in micrograms per cubic meter
POLLUTANT
CO
AVERAGING
PERIOD
1 hour
8 hour
MAXIMUM
MODEL
ESTIMATE
225
73
NAAQS
40,000
10,000
LEVEL OF
SIGNIFICANCE
2,000
500
NO2
Annual
28
100
Table 7
SO2 RESULTS
in micrograms per cubic meter
All Existing and Proposed Sources Considered
AVERAGING
PERIOD
3 hour
24 hour
Annual
MCRSVAL
MAXIMUM
ESTIMATE
2,808
360
36
MCRSVAL
2ND HIGH
ESTIMATE
2,665
301
NAAQS
1,300
365
80
215
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Page 25
NOg—To determine the maximum annual impact, the Valley Model was
used in the annual mode. NO2 emissions from all existing and
proposed sources were considered. The maximum impact occurred on
the hillside east of the refinery and was mainly a result of
refinery emissions. The maximum estimate listed in Table 6
indicates there will be no apparent threat to the NO2 standard.
SO2--Emissions from all existing and proposed sources were input
to MCRSVAL to determine compliance with NAAQS for SO2. Maximum
impacts were shown to occur near the Alyeska Terminal about 2
kilometers southwest of Jackson Point during low wind speed, stable
conditions. The results are listed in Table 7.
The value indicated as "2nd High Estimate" is the highest of the
second-highest concentrations estimated during the year by MCRSVAL.
This value is appropriate for comparison with short-term NAAQS and
PSD increments since one exceedance per year is allowed.
The MCRSVAL results indicate there may be a potential violation of
the 3-hour (secondary) NAAQS in a small area on the hillside near
the Alyeska tanker terminal. (It should be remembered that, as
discussed in Subsection C, MCRSVAL is not considered appropriate for
the 3-hour estimate; however, EPA has no recommended technique to
estimate a 3-hour impact in complex terrain. For this reason these
model results are presented here).
These 3-hour estimates were calculated assuming the worst-case
emissions from both the Alpetco and Alyeska tankers occurred during
each and every 3-hour period of the year. Dames & Moore estimated
from actual tanker traffic data that four or more tankers arrive in
Valdez within a 24-hour period 7.55% of the time. This should be a
conservative estimate of the probability of these worst-case
emissions occuring during a year. The probability of occurrence of
the meteorological conditions which caused the high concentrations
is determined by the model using worst-case emissions; this is
simply the number of 3-hour periods over the standard, which in this
case was about 20. The joint probability of these two events
(emissions and meteorology) is the product of the two individual
probabilities. This assumes independence of emissions and
meteorology and that all of the high concentration is caused only by
the Alyeska tankers. Other sources contribute very little to the
high values. The joint probability is then 7.55% of 20 periods per
year or about 1.5 periods per year. This is less than two periods
per year so that on a probabilistic basis there should be no
violation. It is recognized that there are large uncertainties in
this approach, but it is believed to be conservative, mainly due to
the overestimate of the frequency of occurrence of the worst-case
emissions.
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Page 26
Emissions from the proposed Alpetco sources only were input to
Valley Model and MCRSVAL to determine compliance with the Class II
PSD increments. Maximum impacts occurred on the hillside east of
the refinery and on the hillside south of the Alpetco tanker dock.
The results are listed in Table 8. Again, the appropriate MCRSVAL
value to compare with the short-term increments is the "2nd High
Estimate".
The Valley Model indicates potential violations of the 24-hour and
annual increment. In fact, the Valley Model estimate is in excess
of the 24-hour NAAQS for SO2 of 365 micrograms per cubic meter.
In limited comparisons of Valley Model estimates with measured
concentrations at other complex terrain locations, the Valley Model
has been shown to slightly underpredict at some locations and
greatly overpredict at others (see Burt, 1977).
In the two regions of maximum impact at Valdez, the areas actually
exceeding the short-term increments were very small, less than a few
hundred meters in diameter. The meteorological conditions which led
to the high concentrations were, as before, low wind speed and
stable conditions. Often it was found in the MCRSVAL analysis that
one particular hour during the high 3- or 24-hour periods
contributed significantly to the increment exceedance as the wind
direction for that hour was directly toward the critical impact
area. Considering the area where the exceedances were caused by the
Alpetco tanker, the probability of occurrence can again be taken
into account. The refinery capacity requires only one tanker every
third day. The worst-case emissions only occur for at most 12 hours
of that day so that the probability of occurrence is then 12 out of
72 hours, or about 17% of the time. MCRSVAL indicated no
exceedances of the 24-hour increment caused by the Alpetco tanker
and four periods during the year when exceedances of the 3-hour
increment occurred. The joint probability of occurrence is then 17%
of four priods or less than one period per year. On a probabilistic
basis then no violation of Class II increments should occur on the"
hillside immediately south of the Alpetco dock.
Since the refinery emissions are essentially constant throughout the
year, the number of periods exceeding the short-term increments
caused by the refinery can not be reduced through a probablistic
argument. MCRSVAL indicates there may be violations of the
short-term SO2 increments on the hillside east of the refinery.
The number of periods exceeding the increment are in parenthesis in
Table 8.
217
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Table 8
SO2 RESULTS
in micrograms per cubic meter
Alpetco Sources Only Considered
ADDITIONAL
CONTROL ON FCCU
AVERAGING
PERIOD
VALLEY
MAXIMUM
ESTIMATE
MCRSVAL
MAXIMUM
ESTIMATE
MCRSVAL
2ND HIGH
ESTIMATE
CLASS
II PSD
INCREMENT
95% EFF.
2ND HIGH
ESTIMATE
70% EFF
2ND HIGH
ESTIMATE
3 hour
—
876 (9)
837
512
507 (0)
591 (3)
24 hour
370
174 (4)
131
91
83 (1)
98 (2)
Annual
24
10
_ _
20
() Number of averaging periods during the modeled year exceeding the increment.
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Page 28
The SO2 results presented so far are based on Alpetco's original
proposal which assumes the Fluid Catalytic Cracking Unit (FCCU) has
no additional SO2 control beyond hydrotreating the feed to the
unit. The FCCU contributes a major portion fo the maximum
concentrations on the hillside. Since BACT is proposed to require
additional control, two additional scenarios were modeled to
determine the air quality improvement by installation of an SO2
scrubber on the FCCU. The two scrubber efficiencies which were
modeled were 95% and 70%. The results are presented in Table 8. It
can be seen that according to MCRSVAL, with a 95% efficient
scrubber on the FCCU, violations of the short-term SO2' increments
will not occur. It should be recognized that large uncertainties
exist in these screening model estimates.
TSP---Emissions from all existing and proposed sources were input to
the Valley Model to determine compliance with NAAQS for TSP.
Maximum impacts were shown to occur on the hillside east of the
refinery. The results are listed in Table 9. Since there was no
apparent threat to NAAQS based on these results using the
generalized grid, no concentrations were estimated using the refined
grid areas.
To determine compliance with the PSD increments, Alpetco sources
only were input to the Valley Model and MCRSVAL. Maximum values
again occurred on the hillside east of the refinery. The results
are listed in Table 10. The Valley Model was used with a refined
grid area to determine the maximum impact. The results indicated a
possible violation of the 24-hour Class II increment. The MCRSVAL
"2nd High" 24-hour estimate shows compliance and is about 70% of the
TSP increment. Since MCRSVAL 1s acceptable as a screening technique
for the 24-hour estimate, violations of the short-term TSP increment
would not be expected as a result of the refinery emissions. There
appears to be no problem meeting the annual increment. The TSP
results discussed so far are based on Alpetco's original proposal
which assumes the emission limit for the FCCU is .04 gr/dscf.
According to Section II, the BACT limit recommended is .03 gr/dscf.
The additional model runs with the FCCU at this BACT emission rate
are also presented in Table 10.
F. Hydrocarbons
Because of the complexities involved 1n the photochemical reactions
which take place in the atmosphere to form ozone, it 1s very
difficult to estimate the effects that the hydrocarbon emissions
from the proposed Alpetco sources might have on ambient ozone levels
downwind. The data needed to perform adequate photochemical
modeling are not currently available, and furthermore, substantial
219
-------
Table 9
TSP RESULTS
in micrograms per cubic meter
All Existing and Proposed Sources Considered
AVERAGING
PERIOD
24 hour
Annual
*Not modeled using refined grid area.
VALLEY
MAXIMUM
ESTIMATE
40*
4*
SECONDARY
NAAQS
150
60
Table 10
TSP RESULTS
in micrograms per cubic meter
Alpetco Sources Only Considered
AVERAGING
PERIOD
VALLEY
MAXIMUM
ESTIMATE
MCRSVAL
MAXIMUM
ESTIMATE
BACT LIMIT OF 0.03 gr/dscf
MCRSVAL CLASS MCRSVAL VALLEY
2ND HIGH II PSD 2ND HIGH MAXIMUM
ESTIMATE INCREMENT ESTIMATE ESTIMATE
24 hour
Annual
72
5
32
2
26
37
19
20
1
60
4
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Page 30
time and financial commitments would be required to obtain the data
and perform the model estimates. The following points can be made
concerning potential impacts from Alpetco's hydrocarbon emissions:
1. Alpetco's proposed hydrocarbon emissions total 1350 tons per
year, while annual emissions from the existing Alyeska tankers
alone are approximately 7500 tons. The amount of Alpetco's
hydrocarbon emissions can be considered small relative to
existing sources in the Valdez area and also relative to the
amount of hydrocarbon emissions from large urban areas which are
known to cause ozone problems. Furthermore, it is estimated
(EPA, 1979) that only about 1% of the hydrocarbon emissions from
a new refinery are the highly reactive type which lead to ozone
formation.
2. Valdez is located at high latitude which implies a low sun angle
the year around. The result is a lower maximum intensity of the
sunlight which is required to initiate photochemical reactions.
In addition, there is a high frequency of occurrence of cloud
cover in Valdez which also would tend to reduce the amount of
sunlight available for photochemical reactions.
3. An EPA Staff Report (EPA, 1979) summarizes the results of a
photochemical modeling analysis the purpose of which was to
determine ozone impacts downwind of rural sources of
hydrocarbons. One of the sources modeled was a typical large
new refinery with hydrocarbon emissions of 4380 tons per year.
Worst-case meteorological conditions were assumed to maximize
the amount of increase of ambient ozone levels. The model
results caused an increase of only about 4 micrograms per cubic
meter, or 0.002 parts per million.
Although existing levels of ozone in Valdez are moderate, it does
not appear for the reasons stated above that the proposed Alpetco
hydrocarbon emissions will pose a threat to the NAAQS for ozone.
G. Other Impacts
The nearest Class I area is about 300 kilometers northwest of
Valdez. No significant air quality Impacts from the proposed
refinery are expected at this very large distance.
To assess possible impacts on soils, Dames & Moore performed an
analysis with the following assumptions: All SO2 emissions are
transformed to sulfates; all NOx emissions are transformed to
nitrates; on an annual basis, all TSP emissions along with sulfates
and nitrates are deposited uniformly on the soil surface within a
50-kilometer radius of the proposed refinery site. This results 1n
a total deposition of about one gram per .square meter.
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Emissions from the proposed Alpetco sources will increase ambient
levels of TSP, NO2, and SO2, all of which may affect
vegetation. It is expected, however, that concentrations will be
below NAAQS, and that effects on vegetation will not be significant.
The proposed facilities will increase particle concentration in the
atmosphere which may reduce visibility slightly in the area at
times. Particulate levels will increase as a result of TSP
emissions and possible gas-to-particle conversion of emissions of
S02» N0X, and hydrocarbons. Most of the sources at the refinery
will not emit visible plumes; however, two of the sources may have
visible water vapor plumes extending some distance downwind at
times. The tankers which will berth at the Alpetco dock will emit a
slightly visible plume. Visible tanker emissions from the existing
Alyeska terminal have been observed to accumulate in an elevated
stable layer of the atmosphere causing significant visibility
reduction within the layer.
IV Findings & Recommendations
Lacking adequate detailed data to perform the air quality analysis
using a refined model, screening models had to be relied upon to
determine compliance with standards and increments. Based on the
results of the screening model analysis, it appears that the
proposed Alpetco sources will not cause or contribute to a violation
of the NAAQS or the PSD increments.
Emission Limitations
The emission limitations based on the BACT evaluation are listed in
Table 11.
Compliance Determination
Compliance with the emission limitations shall be demonstrated by
the Company conducting source tests and a program of emission
monitoring as described below.
1. Compliance testing—compliance testing shall be conducted within
60 days after achieving the maximum production rate at which the
refinery will be operated, but not later than 180 days after initial
startup of the refinery. The test methods and procedures described
in 40 CFR 60.106 shall be followed for determining compliance with
the emission limitations for the refinery fuel gas system, the Claus
sulfur recovery unit, and the FCC regenerator. In addition, EPA
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TABLE 11
Emission Limitations
Source SO2
kg/hr
conc/efl/ (lb/hr)
N0X
kg/hr
conc/ef (lb/hr)
PM
kg/hr opacity
conc/ef (lb/hr) (X)
CO
kg/hr
conc/ef (lb/hr)
HC I
kg/hr Equipment 1
(lb/hr) or operati
specificat
Comments
ig
ions
Refinery Fuel
Gas
80mg/dscm H2S
(0.035gr/
dscf)
The average SO?
emission factor for the
combined refinery
qas/flexicoker qas is
24.3 ng/J (56.6
lb/lO^BTUl
Flexicoker Fuel
Gas
155mg/dscm
total sulfur
(0.067gr/dscf)
Combustion Devices
(Total)
85
(187)
70ppm 90
at 3X (198)
O2
34.4ng/J
(801b/
109BTU)
5
Low N0X burners and
oxygen monitorings will
be used.
Fluid Catalytic
Cracker (FCC)
12ppm 5
(11)
0.75kg/ 20 20
1000kg (44)
coke
burnoff
500ppm 96
(212)
Based on a 95X effi-
cient FGD system.
Particulate concen-
tration is about
70mg/dscm or
0.03gr/dscf
Sulfur Recovery
0,015% 7.1
by volume (15.6)
ox 02
dry basis
Flexicoker Sulfur
recovery vent
0.8
(1.8)
Gas Turbines
3.2ng/J 3.2
(7.431b/ (7.1)
lO^BTU)
(0.0075E) 94
+F % (207)
by volume
at 15X O2
5
Based on the use of
yS refinery gas as fuel
/ E=14.4kq/watt.hr
actual ISO heat rate
F Fuel Bound Nitroqen=N
0 N< 0.015
0.04(N) 0.015 0.25
1/ conc/ef means a concentration or an emission factor limitation
Page 32
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Source SO2
kg/hr
conc/ef (lb/hr)
N0X
kg/hr
conc/ef (lb/hr)
PM
kg/hr opacity
conc/ef (lb/hr) (%)
ro
kg/hr
conc/ef (lb/hr)
HC
kg/hr Equipment
(lb/hr) or operating
specifications
Solid Waste
Incinerator
1.25
(2.8)
70mg/ 0.04 10
dscm (.09)
0.03gr/dscf
Storage Tanks
58 Pressure tanks for liquids with
(128) TVP 76.6kPa. Internal floating
roofs with double seals or
equivalent for liquids with 10.3
TVP 76.6 kPa
Product Loading
Terminal
A vapor recovery system to collect
and incinerate the HC emissions.
The design efficiency of the
incinerator must exceed 995!.
Process Fugitive
ro
ro
-E*
Specifications for valves, pumps,
and compressors must include the
optimum sealing techniques
available from the
manufacturers. Process drains
must be trapped. Oil/water
separators must be covered. A HC
monitoring and maintenance plan
must be submitted to EPA for
approval 1 year prior to
projected refinery startup.
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Method 6 (40 CFR 60; Appendix A) shall be used to determine
compliance with the FCC regenerator SO2 limitation. EPA Method 15
shall be used to determine compliance with the total sulfur emission
limitation for the flexicoker gas system. EPA Method 7 shall be
used to determine compliance with the N0X emission limitation for
the combustion devices. Only one combustion device of each type
needs to be tested. The company shall submit a plan for EPA
approval proposing which combustion devices to test. - The test
methods and procedures described in 40 CFR 60.335 shall be followed
for determining compliance of the gas turbines with the N0X
emission limitation.
2. Compliance Monitoring—The emission monitoring requirements of
40 CFR 60.105 and 60.334 shall be followed. In addition, continuous
oxygen monitoring instruments shall be installed to record the
excess oxygen in the combustion devices. A continuous SO2 monitor
shall be installed on the FCC regenerator stack unless the company
can demonstrate that sufficient process monitoring data will be
recorded to determine the SO2 emissions. All continuous
monitoring instruments must meet the requirements contained in 40
CFR 60.13. Process monitors shall be installed to record pressure
drop across the scrubber, liquid flow rate and any other process
variable necessary to insure proper operation of the scrubber on the
solid waste incinerator. The thermal incinerator for the product
loading terminal shall be equipped with instruments to continuously
monitor the incinerator temperature and to determine the residence
time within the combustion zone.
V. References
Alyeska Pipeline Service Company, 1974, "Summary Report, Air Quality
for the Trans Alaska Pipeline System: Terminal".
Burt, E. W., 1977, "Valley Model User's Guide", U.S. E.P.A.,
EPA-450/2-77-018.
EPA, 1978, "Guideline on Air Quality Models", OAQPS No. 1.2-080,
EPA-450/2-78-027.
EPA, 1979, "The Ozone Impact of Rural Sources", Staff Report, Source
Receptor Analysis Branch, OAQPS, Research Triangle Park, NC.
Holzworth, G. C., 1972, "Mixing Heights Wind Speeds, and Potential
for Urban Air Pollution Throughout the Contiguous United
States", U.S. E.P.A., OAP No. AP-101.
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FINAL DETERMINATION DOCUMENT
PREVENTION OF SIGNIFICANT DETERIORATION
APPROVAL OF CONSTRUCTION OF THE ALASKA PETROCHEMICAL
COMPANY OIL REFINERY AND MARINE LOADING TERMINAL
AT VALDEZ, ALASKA
SCOPE
This document presents the final determination by the
Environmental Protection Agency (EPA) to approve the
Alaska Petrochemical Company's (ALPETCO) proposal to
construct an oil refinery and marine loading terminal at
Valdez, Alaska. This determination is made under the
federal requirement of Part C, Title 1 of the Clean Air
Act, "Prevention of Significant Deterioration of Air
Quality (PSD)".
BACKGROUND
On December 11, 1979, EPA received a complete PSD permit
application from ALPETCO requesting approval to construct
an oil refinery and marine terminal at Valdez, Alaska.
EPA reviewed this material and presented its findings in a
preliminary determination document which was released for
public comment on January 14, 1980. A preliminary
determination to approve the refinery construction was
issued on the basis that the National Ambient Air Quality
Standards and PSD increments would not be violated, and
that the proposed emission standards represented best
available control technology (BACT). Affected government
agencies were notified of their opportunity to submit
written comments and public hearings were held on January
29, 30 and 31, 1980. The record closed on February 16,
1980.
PUBLIC COMMENT
No adverse public comments were made at the public
hearings and no comments regarding air quality were
received during the comment period.
FINDINGS
Based on our review of the application, EPA finds that the
"Class II" air quality increments and the NAAQS will not
be violated as a result of this project and that the
emission limits listed in the PSD permit constitute BACT.
In light of these findings, EPA grants approval to ALPETCO
to construct an oil refinery and marine loading terminal
at Valdez, Alaska. This approval is subject to the terms
and conditions set forth in the MAR 21 r 1980 letter of
approval to the ALPETCO company.
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U.S. ENVRIONMENTAL PROTECTION AGENCY
REGION 10
1200 SIXTH AVENUE
SEATTLE, WASHINGTON 98101
APPLICATION OF:
Alaska Petrochemical Company
601 West 5th Avenue
Anchorage, Alaska 99501
No. PSD-X80-08
APPROVAL OF APPLICATION
TO CONSTRUCT
Pursuant to the Agency regulations for the Prevention of
Significant Deterioration of Air Quality (PSD) set forth at
Title 40 Code of Federal Regulations, Part 52 and based upon
information submitted on October 8, 1979, November 23, 1979,
December 4, 1979, and December 11, 1979 the Regional
Administrator now finds as follows:
FINDINGS
1. The Alaska Petrochemical Company (ALPETCO) proposes to
construct an oil refinery and marine loading terminal at
Valdez, Alaska.
2. An analysis of the projected emissions indicates that
the proposed new construction has the potential to emit more
than 100 tons per year of sulfur dioxide (S02), particu-
late matter (PM), carbon monoxide (CO), nitrogen oxides
(NOx) and hydrocarbons (HC), and therefore is subject to
PSD review for these pollutants.
APPROVAL TO CONSTRUCT PAGE 1 Of 8
0A7
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3. Since the proposed source emissions will exceed the
limits set forth in §52.21(j)(2) and §52.21(k)(l) (ii) for
S02» PM, CO, N0X and HC, these emissions must be
controlled by the best available control technology and an
ambient impact analysis must be conducted for those
pollutants.
4. Modeling analyses of SC^, PM, CO, NOx and HC have
been conducted and demonstrate that while emissions of these
pollutants will increase, the construction will not cause
violations of any National Ambient Air Quality Standard or a
PSD air quality increment, so long as the plant is operated
in accordance with the conditions specified below. With the
application of best available control technology, as requied
by Section 165(a)(4) of the Clean Air Act, operation of the
proposed oil refinery and marine loading terminal will meet
the applicable PSD requirements.
5. The proposed construction will be located in an area
designated as "Class II" under Section 162(b) of the Clean
Air Act (42 use 7472).
ACCORDINGLY, it is hereby determined that subject to the
conditions set forth below, ALPETCO will be permitted to
construct an oil refinery and marine loading terminal, as
described in its PSD application received on October 8, 1979
and supplemented on of November 23, 1979, December 4, 1979
and December 11, 1979.
APPROVAL CONDITIONS
1. Emission of SO2, PM, NOx, CO and HC shall not exceed
the following limits.
Emission Limitations
Concentration
kg/hour or Emission Factor
Facility Pollutant lib/hour) Limitation
Combustion SO2 85 NOTE 1
Devices (187)
(Total)
APPROVAL TO CONSTRUCT PAGE 2 of 8
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Emission Limitations
Facility
Refinery
Fuel Gas
(NOTE 2)
Flexicoker
Fuel Gas
Fluid
Catalytic
Cracker
(FCCU)
Sulfur
Recovery
(SRU)
Flexicoker
SRU Vent
Gas Turbines
Solid Waste
Incinerator
Storage Tank
(Total)
Pollutant
NOx
PM
S02
so2
so2
PM
CO
S02
so2
so2
N0X
so2
PM
HC
kg/hour
lb/hour
90
(198)
5
(11)
20
(44)
96
(212)
7.1
(15.6)
0.8
(1.8)
3.2
(7.1)
94
(207)
1.25
(2.8)
0.04
(0.09)
58
(128)
Concentration
or Emission Facto
Limitation
70 ppm at 3% 02
34.4 ng/J
(80 lbs/10^ BTU)
5% opacity
80 mg/dscm H2S
(0.035 gr/dscf
155 mg/dscm Total
Sulfur
(0.067 gr/dscf)
12 ppm
0.75 kg/1000 kg
Coke burnoff.
20% opacity.
NOTE 3
500 ppm
0.015% by volume
at 0% 02 dry
basis
(0.0075E)+F%
by volume at 15%
°2
NOTE 4
70 mg/dscm
(0.03 gr/dscf)
10% opacity
Based on the
equipment standard
and operation
practices below:
Pressure tanks
shall be used for
liquids with a
TVP greater than
APPROVAL TO CONSTRUCT PAGE 3 of 8
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Emission Limitations (cont.)
Concentration
kg/hour or Emission Factor
Facility Pollutant lb/hour Limitation
76.6kPa. Internal
floating roofs with
double seals or
equivalent shall be
used for liquids with
TVP greater than 10.3
but less than 76.6 kPa.
Product Loading HC
Terminal
The following equip-
ment standard and
operating practice
shall be substitutes
for an emission
standard:
Process Fugitives HC
A vapor recovery
system shall be ins-
talled and operated to
collect and incinerate
the HC emissions
treater during vessel
loading. The design
efficiency of the in-
cinerator must exceed
99%.
The following equip-
ment standard and
operating practice
shall be substituted
for an emission
standard:
Specifications for
valves, pumps and
compressors must
include the optimum
sealing techniques
available from the
manufacturers. Pro-
cess drains must be
trapped. Oil/water
separators must be
covered. A HC
monitoring and
maintenance plan must
be submitted to EPA
for approval one year
prior to projected
refinery startup.
NOTE 1
NOTE 2
The average SO2 emission factor for the combined
refinery gas/flexicoker gas is 24.3 ng/J (56.6
lbs/109 BTU)
Includes fuel gas to combustion devices and gas
turbines
NOTE 3 Particulate concentration is about 79 mg/dscm or
0.03 gr/dscf
APPROVAL TO CONSTRUCT PAGE 4 of 8
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NOTE 4 Based on the use of refinery gas as fuel
w- 14.4kg/watt.hr
actual ISO heat rate
F
Fuel Bound Nitrogen = N
0
0.04(N)
0.004+0.0067(N-O.l)
0.005
N <0.015
0.015 < N £ 0.1
0.1 < N < 0.25
N > 0.25~
2. Only the above listed sources shall be permitted for
emissions of air pollutants to the atmosphere. Additional
sources or design changes which result in an increase in
emissions will require formal permit modification in
accordance with §52.21.
3. The solid waste incinerator final design shall include a
control device capable of 90% removal efficency for SO2.
4. Compliance testing shall be conducted within 60 days
after achieving the maximum production rate at which the
refinery will be operated, but not later than 180 days after
initial startup of the refinery. The test methods and
procedures described in 40 CFR 60.106 shall be followed for
determining compliance with the emission limitations for the
refinery fuel gas system, the Claus sulfur recovery unit, and
the FCC regenerator. In addition, EPA Method 6 (40 CFR 60;
Appendix A) shall be used to determine compliance with the
FCC regenerator S02 limitations. EPA Method 15 shall be
used to determine compliance with the total sulfur emission
limitation for the flexicoker gas system. EPA Method 7 shall
be used to determine compliance with the NOx emission
limitation for the combustion devices. Only one combustion
device of each type needs to be tested. The company shall
submit a plan for EPA approval proposing which combustion
devices to test. The test methods and procedures described
in 40 CFR 60.335 shall be followed for determining compliance
of the gas turbines with the NOx emission limitations.
APPROVAL TO CONSTRUCT PAGE 5 of 8
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5. Compliance Monitoring — The emission monitoring require-
ments of 40 CFR 60.105 and 60.334 shall be followed. In
addition, continuous oxygen or carbon monoxide monitoring
instruments shall be installed to record the excess oxygen or
carbon monoxide in the combustion devices. A continuous
SO2 monitor shall be installed on the FCC regenerator stack
unless the company can demonstrate that sufficient process
monitoring data will be recorded to determine the SC>2
emissions. All continuous monitoring instruments must meet
the requirements contained in 40 CFR 60.13. Process monitors
shall be installed to record pressure drop across the
scrubber, liquid flow rate and any other process variable
necessary to insure proper operation of the scrubber on the
solid waste incinerator. The thermal incinerator for the
product loading terminal shall be equipped with instruments
to continuously monitor the incinerator temperature and to
determine the residence time within the combustion zone.
6. All reasonable measures shall be taken to prevent and
reduce emissions of air pollutants to the atmosphere during
the period of construction. This shall include but not be
limited to activities to prevent particulate matter from
becoming air borne from roadways or arising from traffic
activities in and about the construction site.
7. The refinery throughput shall not exceed 150,000 barrels
per day feed stock.
8. ALPETCO shall notify the Alaska Department of Environ-
mental Conservation (ADEC), in writing of any occurrence of
emissions in excess of limits specified above; notification
shall be forwarded to ADEC in writing in a timely fashion and
in each instance, no later than ten (10) days from the date
of such occurrence. The notification shall include an
APPROVAL TO CONSTRUCT PAGE 6 of 8
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estimate of the resultant emissions and narrative report of
the cause, duration and steps taken to correct the problem
and avoid a recurrence. ALPETCO shall contemporaneously send
a copy of all such reports to EPA.
9. This approval shall become void if on-site construction
is not commenced within eighteen (18) months after receipt of
the approval or if on-site construction once initially
commenced is discontinued for a period of eighteen (18)
months.
10. As approved and conditioned by this permit, any
construction, modification or operation of the proposed
facility shall be in accordance with the application which
resulted in this permit. Moreover, any such activity which
is undertaken in a manner inconsistent with this permit shall
be subject to EPA enforcement action under the Clean Air Act.
11. This permit in no way constitutes a waiver which relieves
ALPETCO from its obligations to meet requirements under other
parts of the Clean Air Act, including Section ill, New Source
Performance Standards, or from other obligations as a result
of permits required by other Federal or State laws.
12. EPA and ADEC shall be notified of the commencement of
construction date and the start up date not later than within
thirty (30) days before the date these events begin.
13. The United States Court of Appeals for the D.C. Circuit
has issued a ruling in the case of Alabama Power Co. v.
Douglas M. Costle (78-1006 and consolidated cases) which will
have significant impact on the EPA PSD program. The
applicant is hereby advised that this permit may be subject
to reevaluation and/or modification as a result of the final
court decision and its ultimate effect.
APPROVAL TO CONSTRUCT PAGE 7 Of 8
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14. Access to the source by EPA or state regulatory
personnel shall be permitted upon request for the purpose of
compliance assurance inspections. Failure to allow such
access is grounds for revocation of this permit.
APPROVAL TO CONSTRUCT PAGE 8 of 8
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ctp r\ ctp
4
F
JAYS. NAMMOMO, 60¥BUMR
DEPT. OF ENVIRONMENTAL CONSERVATION
POUCH 0 - JUHEAU Mil
March 17, 1980
CERTIFIED MAIL
RETURN RECEIPT
REQUESTED
Mr. Ronald R. Dagon, Manager
Environmental Programs § Permitting
The Alpetco Company
3700 Buffalo Speedway
Houston, Texas 77098
Dear Mr. Dagon:
The Department has evaluated the Prevention of Significant Deterioration
Permit Application submitted by Alaska Petrocfiemical company for the
Contruction of a Refinery and Petrochemical Complex in Valdez, Alaska
transmitted By your letter of October 8, 1979. We have also reviewed
the four-volume supplement submitted November 23, 1979, additional
information accompanying your letters of December 4, 11, and 19, 1979
and February 20, 1980 and the Draft Environmental Impact Statement for
the refinery dated December 7, 1979. Based on this evaluation, the
Department has determined that:
a) The increased emissions of particulate matter, sulfur dioxide,
nitrogen oxides and carbon monoxide will not cause violations
of the Alaska Ambient Air Quality Standards specified in
18 AAC 50.020.
b) Particulate matter and sulfur dioxide emissions from the
turbines, process heaters, boilers and flares will not exceed
the standards specified in 18 AAC 50.050 so long as desulfurized
process gas is the only fuel burned.
c) Sulfur dioxide emissions from the sulfur recovery plants will
not exceed the standards specified in 18 AAC 50.050 so long as
the plants are designed, operated and maintained to reduce
potential gaseous sulfur emissions by more than 97%.
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Mr. Ronald R. Dagon
Page 2 of 3
d) The electrostatic precipitator design specifications are
lacking in detail, but at control efficiencies greater than
98%, particulate matter emissions from the fluidized catalyst
cracking unit regenerator will comply with standards specified
in 18 AAC 50.050.
e) A hydrotreater will remove more than 90% of the sulfur in the
feedstock to the fluidized catalyst cracking unit, resulting
in sulfur dioxide emissions from the regenerator which will
comply with standards specified in 18 AAC 50.050.
f) The process waste incinerator design specifications and operating
parameters are lacking in detail and do not affirmatively
demonstrate compliance with requirements specified in 18 AAC 50.040.
g) Reasonable precautions have been taken to minimize excessive
hydrocarbon emissions from storage tanks, piping, valves and
other equipment.
Therefore, Permit AQC-525 is granted for the construction and operation
of the Valdez Refinery and Petrochemical Complex, with the condition
that final design specifications for all air contaminant emission control
systems be submitted to the Department for review and approval. On site
fabrication, installation or construction of any process unit which
requires emission control systems or units to achieve compliance is
prohibited until the Department grants final approval of design specifications.
Please note the permit has thirteen (13) conditions and expires January 30,
1984. Conditions 5 and 6 require that an evaluation of the impacts on
air quality due to any process design changes which might be made be
submitted by The Alpetco Company to the Department by December 30, 1980
and the final design specifications for each emission control system by
December 30, 1981. Based on review of these submittals, the Department
may modify or amend this permit in part or in its entirety, as appropriate.
Conditions 7 and 8 require that a monitoring network be established and
operated to measure any changes in ambient air quality due to operation
of the refinery.
Conditions 9 and 10 require that source tests be conducted, and continuous
stack monitors be installed, to measure pollutant concentrations in
major effluent stacks.
Many of the unit processes must comply with federal regulations promulgated
in 40 CFR 60 Subparts J and/or GG. Please contact Mr. Robert Chiwis of
the U.S. EPA Alaska Operations Office in Anchorage, 271-5083, for specific
requirements. Your facility must also be reviewed for compliance with
the Prevention of Significant Deterioration Provisions of the Clean Air
Act Amendments of 1977. Mr. Michael M. Johnston of the U.S. EPA Region X
Office in Seattle is responsible for this review.
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Mr. Ronald R. Dagon
Page 3 of 3
You have a right to an adjudicatory hearing to contest the Department's
action. A request for an adjudicatory hearing must be made within 30
days of receipt of this letter by mailing or delivering a statement of
issues to the Alaska Department of Environmental Conservation, Pouch 0,
Juneau, Alaska, 99811. The statement of issues must state the basis for
the hearing request and otherwise conform with AS 44.62.370. A failure
to request a hearing within 30 days of receipt of this letter constitutes
a waiver of your right to administrative or judicial review of this
action.
Ci -\ r
C. Deming Cowldfer
Deputy Commissioner
Enclosure: AQC-525
237
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ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION
AIR QUALITY CONTROL
PERMIT TO OPERATE
Permit No. AQC-525 Date of Issue:
The Department of Environmental Conservation, under authority of AS 46.03
and 18 AAC 50.120, issues an Air Quality Control Permit to Operate to
THE ALPETCO COMPANY
3700 BUFFALO SPEEDWAY
HOUSTON, TEXAS 77098
for the operation of the Valdez Refinery, associated fuel burning equipment,
sulfur recovery plants, fluid catalyst cracking unit, process waste
incinerator, safety flare and storage tanks as described in the Alaska
Petrochemical Company "Prevention of Significant Deterioration Permit
Application" dated October 8, 1979, "Supplement to Prevention of Signifi-
cant Deterioration Application" (Vol. I-IV) dated 23 November 1979,
letters dated December 4, 11, and 19, 1979 and supplemental information
transmitted by The Alpetco Company letter dated February 20, 1980.
Located about six miles east of Valdez, Alaska in Sections 31 and 32,
T8S, R5W, Section 6, T9S, R5W and Section 1, T9S, R6W (CRM).
Under the conditions:
1. Permittee shall comply with the State Ambient Air Quality Standards
established in Section 020 and the applicable emission limitations
specified in Sections 040 and 050 of the State Air Quality Control
Regulations 18 AAC 50.
2. Any unit process design changes which may alter either the quality
or quantity of air contaminant emissions from the proposed refinery
shall be reported by December 30, 1980 to the Department together with
an evaluation of any change in the original estimates of impacts on
Ambient Air Quality Standards and Prevention of Significant Deterioration
increments.
3. Final engineering designs and specifications such as a set of "Engineer-
ing for Cost Estimate" drawings and performance specifications for each
air contaminant emission control unit/system are to be submitted to the
Department by December 30, 1981 for final approval.
4. Permittee shall not commence on site fabrication, installation or
construction of any process unit requiring an emission control unit/
system until the final design of the control unit/system has been
approved by the Department.
5. Permittee shall maintain and operate all fuel burning equipment, processes,
emission control devices and monitoring systems so as to provide optimum
air quality control during all operating periods.
6. Permittee shall establish, maintain and operate a continuous meteorological
and air quality monitoring network as described in Exhibit B. Instruments,
siting, operation, calibration and data reduction shall be in accordance
with applicable state guidelines. The monitoring network shall be
operational at least 90 days prior to startup of the first process unit,
and the Department shall be notified in writing ten (10) days prior to
placing the monitoring network into operation.
Page 1 of 2
238
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Air Quality Control Permit to Operate AQC-525 (cont)
7. Permittee shall maintain and operate the meteorological and air
quality monitoring equipment to maximize data collection and accuracy
at all times, assuring that at least ninety percent of possible
data is recovered and the data is of high quality. If any continuous
instrument is malfunctioning or non-operable for two or more consecutive
days, permittee shal] notify the Department during the third day of
inoperability, indicating the cause of failure and the anticipated
time required to repair the instrument.
8. Source tests as described in Exhibit D shall be performed within
six (6) months of startup and the results reported to the Department.
Prior notification to and approval by the Department of the date
and conditions of each test is required. The Department may require
additional tests if deemed necessary to ascertain compliance with
applicable standards.
9. Continuous monitors as described in Exhibit C shall be installed,
maintained, and operated to measure fuel quality and consumption,
air contaminant emissions concentrations and opacity. If any
continuous sulfur dioxide monitor is malfunctioning or non-operable
for 24 hours or more, and any other monitor is malfunctioning or
non-operable for seven or more consecutive days, permittee shall
notify the Department on the second or eighth day, as appropriate,
indicating the cause of failure and anticipated time required to *
repair the instrument.
10. Air Contaminant Emission Reports as described in Exhibit A and
Meteorological and Air Monitoring Network Data Reports as described
in Exhibit B shall be submitted to the Department for each calendar
quarter by January 30, April 30, July 30, and October 30 each year.
11. Permittee shall maintain test results, monitoring instrument recorder
charts and other applicable data in an active file for not less
than one (1) year, and have them accessible on request to the
Department for not less than three (3) years.
12. The Department, with permittee's approval, is allowed access to
permittee's facilities to conduct scheduled or unscheduled inspections
or tests to determine compliance with this permit and state environ-
mental laws and regulations.
13. A copy of this permit shall be clearly displayed, and the State Air
Quality Control Regulations 18 AAC 50 kept on file, at the permitted
facility location.
This permit expires 30 January 1984 and may be revoked or suspended in
accordance with 18 AAC 50.130.
I
DEPARTMENT OF ENVIRONMENTAL CONSERVATION
239
Page 2 of 2
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EXHIBIT A
PERMIT TO OPERATE AQC-525
AIR CONTAMINANT EMISSION REPORT
An Air Contaminant Emission Report shall be submitted to the Department
quarterly by January 30, April 30, July 30, and October 30 each year. This
report is to be submitted for any period during which the equipment is
tested or operated. The report shall include, but not be limited to, the
following information:
NAME OF FIRM
LOCATION OF FACILITY
PERIOD OF REPORT
1st
Month
2nd
Month
3rd
Month
1. DAYS OPERATED
2. PROEiCTION
3. FUEL CONSUMPTION*
number of hours or days
barrels crude oil throughput
a.
Note:
11 heaters/boilers totaling
949.38 mm Btu/hr associated
with the following process
units:
hydrogen production
naphtha hydrotreater
sulfolane extraction
vacuum gas oil hydrotreater
HF alkylation
catalytic polymerization
indicate type of fuel and quantity
in mmcf, or other appropriate unit
of measure; report the sulfur content,
as H2S, based on at least five analyses
during each month of the first quarter
of operation
b.
4 gas turbines totaling
955 mm Btu/hr.
c.
12 heaters/boilers totaling
1501 mm Btu/hr associated with
the following process units:
crude distillation
vacuum distillation
distillate hydrocracker
catalytic reformer
indicate type of fuel and quantity in
mmcf, barrels or other appropriate unit
of measure; report sulfur content of
any liquid fuel burned based on repre-
sentative or daily sampling
indicate type of fuel and quantity in
mmcf, or other appropriate unit of
measure; report the sulfur content, as
H2S, based on at least ten analyses
during each month of the first quarter
of operation
For purposes of this report, the total quantity of refinery gas
and low-Btu flexicoker gas produced daily may be reported, rather
than the quantity of refinery gas and blended fuel gas burned in
each unit or set of units.
Page 1 of 3
240
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Permit to Operate AQC-525 Exhibit A (cont)
1st
Month
2nd
Month
3rd
Month
SULFUR RECOVERY PLANTS
operating days
production
tail gas incinerator
PROCESS WASTE INCINERATOR
operating days
wastes burned
auxiliary fuel
6. FLARE
operating days
flaring
7. STORAGE TANK TURNOVER
8. CONTINUOUS MONITORING
9. SOURCE TESTING
number of hours or days for each plant
total sulfur, tons
hours and dates operated
number of hours or days
mmcf waste gas burned
gallons/barrels liquid wastes burned
pounds/tons solid wastes burned
gallons fuel oil burned
number of days
number of hours flared
mmcf gas flared
indicate type of fluid and throughput
for each tank in barrels or other
appropriate unit of measure --or report
an estimate of the total hydrocarbons
emitted per month from product storage
tanks
tabulate the appropriate average air
contaminant emission concentrations for
each instrument installed pursuant to the
monitoring requirements described in
Exhibit C; attach a copy of any "excess
emission" report as described in Exhibit C
summarize the results of each analysis and
source test conducted pursuant to the
testing requirements described in Exhibit D.
Include: date of test, testing procedure,
processing or firing rate of tested unit,
% isokinetic if applicable, concentration
or rate in appropriate units, flow rate in
ACFM and SCFM, temperature and water vapor
content.
Page 2 of 3
241
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Permit to Operate AQC-525 Exhibit A (cont)
10. Attach a detailed description of equipment failures or operating
conditions which may have adversely affected air contaminant emissions.
A preliminary report of the incident shall be submitted to the Department
within twenty four hours of the incident. A separate report is required
for each incident.
Include such information as: date of incident, duration, nature of the
occurrence, equipment failures, steps taken to minimize emissions, measures
taken to avoid recurrence, available emissions and ambient air data, and
a general description of the weather.
11. Attach a brief discussion of any change in operations, stack monitoring
equipment, testing procedures, air quality or meteorological equipment
or locations which may affect reported results, or failures which may
have affected the results or resulted in incomplete or a lack of data
for any given day.
12. Signature of authorized agent preceded by the statement: "I
, being first duly sworn, hereby certify that I am familiar
with the information contained in this report and that to the best of my
knowledge and belief such information is true, complete and accurate."
13. Notarization: "Subscribed and sworn to before me this (day)
of (month) (year) (city and state) ."
Notary Public's Signature,
commission, date of expiration and
seal.
Page 3 of 3
242
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EXHIBIT B
AIR QUALITY CONTROL
PERMIT TO OPERATE AQC-525
METEOROLOGICAL AND AIR QUALITY MONITORING NETWORK DATA REPORT
A notarized monitoring report shall be submitted to the Department by
January 30, April 30, July 30, and October 30 each year. The report shall
include, but not be limited to, the following information:
1. MONITORING SITES
1st 2nd 3rd
Month Month Month
Old Valdez (site 2) (Continuous SO2, NO, NO2, O3, wind
speed, and wind direction)
Valdez Airport (Continuous SO2)
Hillside east of refinery (Continuous SO2)
(6777E, 545.5N at about
the 1000 foot level)
2. Data from the meteorological and air quality network shall be reported
as hourly averages in SARQAD format and may be submitted on punched cards
or magnetic tapes.
3. Attach a detailed description of monitoring network equipment failures
or malfunctions which may have resulted in incomplete or erroneous data.
Include such information as: date of occurrence, duration, nature of the
occurrence, steps taken to maximize data recovery and measures taken to
avoid recurrence.
4. Signature of authorized agent preceded by the statement: "I
, being first duly sworn hereby certify that I am familiar
with the information contained in this report and that to the best of ray
knowledge and belief such information is true, complete and accurate."
5. Notarization: "Subscribed and sworn to before me this (day) of
(month) (year) (city and state),"
Notary Public's signature,
commission, date of expiration and
seal.
243
Page 1 of 1
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EXHIBIT C
AIR QUALITY CONTROL
PERMIT TO OPERATE AQC-525
CONTINUOUS EMISSIONS MONITORING REQUIREMENTS
Continuous air contaminant emissions monitoring equipment is to be
installed on the sources described below. Instrument siting, operating
and maintenance procedures must be approved by the Department.
1.
MONITORED SOURCE AND PARAMETER
CRUDE DISTILLATION COLUMN HEATER
Particulate matter (opacity)
Sulfur dioxide
Nitrogen oxides
Oxygen
2. GAS TURBINE
Nitrogen oxides
INSTALLATION AND REPORTING
REQUIREMENT
Install monitor on one of two stacks
Report weekly average opacity or
transmissivity to the nearest 5%
if >15%; indicate <151 if average
is less than 15%
Report weekly average concentration
to the nearest 5 ppm
Report the date, time, duration and
average sulfur dioxide concentration
for any period during which the average
concentration exceeds 40 ppm for
three hours or more
Report monthly average concentration
to the nearest 10 ppm
Report weekly average concentration
to the nearest 0.51
If monitor is installed as an
alternative to requirements in
40 CFR 60.334
Report monthly average nitrogen oxides
concentration to the nearest 10 ppm
Report the duration and average
nitrogen oxides concentration for any
period during which the average
concentration exceeds 75 ppm for more
than seven days
Page 1 of 2
244
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Permit to Operate AQC-525 Exhibit C (cont)
3. FLUID CATALYST CRACKING UNIT
CATALYST REGENERATOR Install monitors on each of two stacks
Particulate matter (opacity) Report weekly average opacity or
transmissivity to the nearest 5$
Report the date, time, duration and
average opacity or transmissivity for
any period during which the average
opacity or transmissivity exceeds 201
for thirty minutes or more
Sulfur dioxide Report weekly average concentration
to the nearest 20 ppm
Report date, time, duration and average
sulfur dioxide concentration for any
period during which the average
concentration exceeds 400 ppm for
three hours or more
Carbon monoxide If monitor is installed pursuant to
40 CFR 60.105(a)(2)
Report monthly average concentration
to the nearest 50 ppm
Report the duration and average carbon
monoxide concentration for any period
during which the average concentration
exceeds 500 ppm for more thai: seven days
4. SULFUR RECOVERY PLANTS Install monitor on each stack
Sulfur dioxide Report weekly average sulfur dioxide
concentration to the nearest 10 ppm
Report the date, time, duration and
average sulfur dioxide concentration
for any period during which the average
concentration exceeds 200 ppm for three
hours or more
245
Page 2 of 2
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EXHIBIT D
AIR QUALITY CONTROL
PERMIT TO OPERATE AQC-525
TESTING AND REPORTING REQUIREMENTS
Permittee shall conduct source tests or analyses as described in this exhibit.
Initial compliance tests shall be performed and reported to the Department
within six months following startup of the applicable unit(s). The results of
routine periodic tests are to be reported quarterly as an attachment to the
required air contaminant emissions report. Permittee may submit additional
source test data at his discretion or to substantiate certification of
compliance with applicable regulations.
PROCESS STREAM OR EXHAUST
Refinery gas
Flexicoker gas
(or blended fuel gas)
Liquid fuel oil
Crude distillation unit
process heater exhaust
Gas turbines exhaust
Fluid catalytic cracking
unit catalyst regenerator
exhaust
PARAMETER
AMD UNIT OF
MEASURE
H2S ppm
Heating value
Btu/ft^
H2S ppm
Heating value
Btu/ft^
NUMBER OF TESTS AND FREQUENCY
Five per month during each month
of the first quarter of operation
Ten per month during each month
of the first quarter of operation
ratio of Weekly average for twelve
refinery gas consecutive weeks following
to flexicoker startup
gas in blended
fuel gas
S weight %
NQx ppm
PM gr/scf
NQx ppm
CO ppm
PM gr/scf
and
lb/1000 lb
coke burnoff
246
Representative sampling during
any period that fuel oil is
burned in turbines or process units,
Three during first quarter of
operation
Three during first quarter of
operation
Three (of one turbine) during
first quarter of operation
Three during first quarter of
operation
Three during first quarter of
operation; one each quarter if
the average of the first three
tests is over 0.04 gr/scf, or one
per year if the average is less
than 0.04 gr/scf;
one test during each month the
average opacity exceeds 151 for
two weeks or more
Page 1 of 2
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Permit to Operate AQC-525 Exhibit D (cont)
PARAMETER
PROCESS STREAM OR EXHAUST
Sulfur recovery plants
Tail gas from Claus unit
to final process unit
Stretford solution
tank vent(s)
Tail gas incinerator
Process waste incinerator
Fugitive hydrocarbon
emissions from valves,
pumps, flanges, drains etc.
AND UNIT OF
MEASURE
Total sulfur
as H2S ppm
Total sulfur
as SO2 ppm
SO2 ppm
SO2 ppm
PM gr/scf
Non-methane
HC ppm
NUMBER OF TESTS AND FREQUENCY
Three per week during first month
of operations
Three during first month of
operation, twice a month thereafter
if over 400 ppm
Daily when incinerator is in
operation if continuous SO2
monitor is not installed.
Three during first quarter of
operation (before and after
exhaust gas scrubber); quarterly
thereafter if exhaust concentration
exceeds 400 ppm
Three during first quarter of
operation; quarterly thereafter
if exhaust concentration exceeds
0.04 gr/scf
Report any incident in excess of
100,000 ppm found during routine
inspection by "sniffing" pursuant
to the hydrocarbon emission
monitoring program established by
The Alpetco Company. Include:
date, location, identification of
equipment causing emissions and
ambient HC level
Page 2 of 2
247
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,ctp n crp
k
OFFICE OF THE GOVERNOR
DIVISION OF POLICY DEVELOPMENT AND PLANNING
April 3, 1980
JAY S. HAMMOND, Governor
Phone 465-3512
Pouch AD • Juneau 99811
Mr. W. James Sweeney
Environmental Protection Agency
605 West Fourth Avenue
Anchorage, Alaska 99501
Mr. Dan Steinborn
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Subject: Alpetco PSD EPA Facilities Permit
State I.D. No. FP060-80040302
Dear Sirs:
The Division of Policy Development and Planning, in accordance with
Public Law 92-583 and 94-370 and Alaska Statutes 46.40.010, has completed
review of the consistency of the subject proposal with the Alaska Coastal
Management Program (ACMP).
As currently planned, we concur that the proposal 1s consistent with
ACMP.
However, 1f the project is substantially amended during its implementation
such that it affects the coastal zone differently than as represented in
the proposal we reviewed, we ask that you contact the State Clearinghouse
to determine 1f an ACMP review of the revision/is required.
cc:
¦ranees A. Ulme
Director
Tom Barnes, Office of Coastal Management
Alpetco
Rlkkf Fowler DEC
Commissioner McAnerney, CRA
Commissioner Webber CED
Commissioner Ward, D0T/PF
Bob Baldwin, DNR
Bruce Barrett, ADF&G
Jim Caruth, C0E
01-A3UM
248
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Sections 10 and 404
-------
SECTIONS 10/404
Issues related to the Corps of Engineers Section 10 and 404 permits are con-
sidered on the following pages. Included is an attachment from the EIS
comment letter received from the U.S. Department of the Interior, Office of the
Secretary, which requests further information on the project in order for the
office to complete its review of the Sections 10/404 actions. The requested
information was supplied in a March 6 letter to that office, which is printed
here following the attachment. Comments from the Fish and Wildlife Service,
and responses to them follow. The section concludes with pertinent state
certifications.
250
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U.8. DEPARTMENT OF MMERCE
National Ocaanie and Atmoapharie Adminiatration
National Marine Fisheries Service
701 C St. Box 43
Anchorage, Alaska 99513
D«« : JAN 2 5 1980
Reply to Attn, of:
District Engineer
Alaska District-^ Corps of Engineers
Prom ; Harry L. Rietze
* . J
Director, Alaska Region
Subject: NPACO RF Port Valdez 85
NPACO No. 071-OYD-2-790373
Reference is made to your public notice dated October 19, 1979, from
Alaska Petrochemical Company to construct a refinery and petrochemical
supporting facilities at Valdez, Alaska.
We have reviewed the above referenced public notice, and the Draft
Environmental Impact Statement (DEIS) prepared for the ALPETCO refinery
proposal. The public notice attempts to describe several activities
associated with the construction/operation of the proposed refinery. Be-
cause of its scope, the notice often lacks the detail needed to properly
assess potential impact. Nevertheless, we are aware that support documents,
including the DEIS, exist and have attempted to review each of the various
activities whenever possible. We have also identified several matters in
which discrepancies appear or additional information is required. Our
specific comments are as follows.
Construction Dock
T It is unclear whether this dock will indeed be temporary or, after
ownership reverts to the City of Valdez, will remain indefinitely. Addi-
„ tionally, we can find no mention of where the dredged material will be
*,1 disposed of. We recommend that it be placed as fill material behind the
bulkhead, if the material is suitable. Otherwise, upland disposal should
be stipulated. Work should be scheduled to avoid the period April 7 to
A June 7 to avoid interference with juvenile salmon.
Control Levee
No comments.
Slater Creek Diversion
No conments.
251
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Roadway Crossings
a) Valdez Glacier Stream - No comments.
b) Corbin & Corbin Glacier Creeks and Robe River Crossings:
~ The public notice allows that these crossings may be by concrete
bridges or gravel covered culverts. We recommend that bridges be
used in the crossing of the Robe River, and for any crossing of Corbin
C2 Creek (Robe). We do not feel the bridge designs shown on the public
notice are sufficient for our review purposes, and would appreciate
the opportunity to study specific plans before approving this design
~ feature.
Product Line Crossing
~ The importance of the Corbin Creek/Robe River system to the salmon production
within Port Valdez has been recognized in the DEIS, which states that the
most sensitive area (to a petroleum product spill) would be near Corbin
Creek (Robe) since spilled substances would pass through the whole Robe
C3 Lake system. The Alaska Dept. of Fish and Game has recommended that an
alternative alignment to the west of Corbin Creek (Robe) be utilized, and
that the products line across the Robe River be aerial rather than buried.
We support these requests and believe their adoption would significantly
A reduce potential impacts.
~ All in-water construction should occur from June 1 to July 15 of each year
C4 with the exception of the Lowe River within which work should occur only
A from March 1 to June 15.
Outfall Line
~ The buried portion of this line may be extended to - 5.0'(MLLW) to avoid
Q,5 exposure at any tidal level. Construction of the line below MHHW should
A be done from April 7 to June 7.
We appreciate this opportunity to comment on this public notice.
252
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RESPONSE TO COMMENTS BY U.S. DEPARTMENT OF COMMERCE
NATIONAL MARINE FISHERIES SERVICE
CI It is unclear whether the construction dock will indeed be temporary or,
after ownership reverts to the City of Valdez, will remain indefinitely.
Additionally, we can find no mention where the dredged material will be
disposed of. We recommend that it be placed as fill material behind the
bulkhead, if the inaterial is suitable. Otherwise, upland disposal should
be stipulated. Work should be scheduled to avoid the period April 7 to
June 7 to avoid interference with juvenile salmon.
Rl The information on DEIS p. 39 represents the current plan for eventual
ownership of the construction barge dock. Upon completion of the project
and expiration of the tidelands lease, ownership of the barge dock would
revert to the City of Valdez. It is presumed that the dock would remain in
place; however, this would be the option of the City of Valdez. It is the
intention to dispose of any dredged material on land. Work on the con-
struction barge dock would be scheduled to avoid the period April 7 to June
7, as suggested.
C2 Regarding the creek crossings on the secondary access road, the Public
Notice allows these crossings to be made by concrete bridges or gravel
covered culverts. We recommend that bridges be used in the crossing of the
Robe River, and for crossing of Corbin Creek (Robe) we do not feel the
bridge designs shown on the Public Notice are sufficient for our review
purposes, and we would appreciate the opportunity to study specific plans
before approving this design feature.
R2 The bridge design configurations shown in the Public Notice are only for
the Valdez Glacier Stream crossing on the primary access road. The sec-
ondary access road would have three bridge crossings on Robe River, Corbin
Creek (Robe) and Corbin Creek (Glacier). Any other drainage ways would be
crossed with appropriately sized culverts. Regarding design configuration
of these bridges, it is currently planned that the bridges be prestressed,
concrete bridges with "H" pile foundations and two 12-foot lanes. The
253
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bridges would be designed at least to the 50-year flood level indicated on
the recent City of Valdez flood insurance study.
C3 The importance of the Corbin Creek/Robe River system to the salmon produc-
tion within Port of Valdez has been recognized in the DEIS, which states
that the most sensitive area (to a petroleum product spill) would be Corbin
Creek (Robe) since spill substances would pass through the whole Robe Lake
system. The Alaska Department of Fish and Game has recommended that an
alternate alignment to the west of Corbin Creek (Robe) be utilized, and
that the products line across the Robe River be aerial rather than buried.
We support these requests and believe their adoption would significantly
reduce potential impacts.
R3 The pipelines over Robe River have been changed to an elevated mode in
response to comments on the DEIS. The Alaska Department of Fish and Game
concurs with this preferred route provided that the state attaches certain
design and construction related stipulations to the State of Alaska right-
of-way lease in which these pipelines would be constructed. For more
detailed information, please see Section II, p. 13-16.
C4 All in-water product pipeline construction should occur from June 1 to
July 15 of each year, with the exception of the Lowe River within which
work should occur from March 1 to June 15.
R4 Comment so noted. Please see Section II, p. 47, mitigation measure C(3).
C5 The buried portion of the wastewater outfall line may be extended to -5.0'
(MLLW) to avoid exposure at any tidal level. Construction of the line
below MHHW should be done from April 7 to June 7.
R5 This will be done.
254
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Attachment I
The following outline identifies the key points for which additional
information is required in order for us to complete our review of
the Corps of Engineers' Public Notices. The need for this information is
also reflected in our comments on the draft Environmental Impact Statement.
1. Roadway Access Route -
a. Description of primary and alternative routes,
b. Methods of stream crossing (bridge, culvert) for each
route at each stream crossing.
c. Expected environmental impacts for each alternative
route to include siltation and wetland filling.
d. Projected cost for each route.
e. Bridge description over Valdez Glacier Stream to
include method of anchoring support structures - need
specific plans.
Construction Barge Dock -
a. Status of dock after construction is completed.
b. Location where dredge spoil will be deposited.
c. Type of dredge to be used.
d. Time schedule for dredging.
Pipeline Crossing -
a. What sections are to be buried.
b. Time schedule for construction across streams.
c. Full description of alternative routes.
d. Threats to fish and wildlife resources should be more
fully discussed for each alternate route.
4. Wastewater Outfall Pipe -
a. Full description of route.
b. Method for crossing Valdez Glacier Stream.
c. Sections to be buried or supported above ground.
This is Attachment 1
to the DEIS comment
letter from the U.S.
Department of the
Interior (see Sec-
tion HI, p. 118,)
requesting informa-
tion for the Depart-
ment's Fish and
Wildlife Service.
The response letter
follows.
V.
255
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d. Feasibility of winter dye plume tests (or similar
test for measuring dispersion).
5. Diversion Ditch -
a. Full description of route.
b. Timing stipulations for construction.
c. Full disclosure of anticipated resource impacts.
256
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U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION X
1 200 SIXTH AVENUE
SEATTLE, WASHINGTON 98101
ATTN OF:
REPLY TO M/S 529
March 6, 1980
Mr. Paul D. Gates
U.S. Dept. of the Interior
Office of the Secretary
P.O. Box 120
Anchorage, AK 99510
Re: Alaska Petrochemical Company Project -
COE Section 10/404 Permit Applications
Dear Mr. Gates:
As requested in your February 8, 1980 comment letter on the
Alpetco Draft EIS, we are responding to your request for
additional information on the Corps of Engineers permit
actions. This letter will provide the information requested
in the outline contained in Attachment I to your letter.
For convenience in responding, the replies will be identified
in the same numerical order as in your letter.
1. Roadway Access Route
The alternative roadways into the site are still those shown
on Figure 3.3-1 in the DEIS. The main access route would be
via the existing Glacier Stream haul road and would enter
the site at the northeasterly corner in the vicinity of the
administrative headquarters of the plant. The secondary
access would enter the site from the Richardson Highway on
the south. The Alpetco site would be one tract in a larger
City of Valdez industrial use zone, and the Glacier Stream
haul road will be a central access corridor to the general
industrial area. This would be a logical main access route
to the refinery. Valdez Glacier Stream would be crossed
257
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2
with a bridge and a low profile approach roadway. The
bridge likely would be a pile supported three span pre-
stressed concrete structure. The configuration remains as
shown in the DEIS (Attachment B, COE permit applications).
The secondary access roadway would cross three streams, Robe
River, Corbin Creek (Robe) and Corbin Creek (Glacier), with
single span bridge structures. Any other drainage courses
would be crossed with culverts. Wetland filling would be
minimal, involving mainly any freshwater marsh areas that
might adjoin streams the roadbed would have to cross. With
an elevated pipeline structure and roadway bridge structures
over the streams, siltation concerns should not be signifi-
cant. It is premature to know what the construction costs
might be for the access routes. The bridge over Valdez
Glacier Stream is described in some detail with regard to
span, foundation and dimension in the COE permit application
(see DEIS Attachment B). It is permature to have more
detailed engineering plans at this time.
2. Construction Barge Dock
The construction barge dock would not be removed following
construction. Upon expiration of the tidelands lease and
completion of construction of the plant, ownership of the
dock would revert to the City of Valdez. It is planned that
the dredge spoil would be deposited upland, somewhere in the
vicinity of the Old Valdez townsite that is proposed for the
Alpetco mobilization area. Dredge spoil would not be deposited
in the waters of Port Valdez. Also, the dredge spoil is not
expected to be suitable for backfilling behind the bulkhead.
A clamshell dredge would be used for this work. Construc-
tion of the barge dock would be scheduled to avoid the
period April 7 to June 7.
3. Pipeline Crossing
Some modifications have been made to the mode of construc-
tion of the pipeline bundle in response to various comments
received. The revised plan is that the pipelines from the
plant site to the Richardson Highway would be constructed in
an above-ground configuration. The pipelines would then be
buried from the Richardson Highway west to the point at
which the pipeline route departs from the highway. The
crude supply line from the point of connection on the Alyeska
line to Dayville Road would also be buried. The remaining
westerly portion of the pipeline from the departure point on
Dayville Road to the products dock (with the exception of
258
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3
the final crossing on Dayville Road) would be constructed
above ground. For the streams for which there is no in-
water construction, there would be no restricted construc-
tion periods. In-water construction in Lowe River would be
conducted between^March 1 and June 15, per your recommenda-
tion. The alternate pipeline route along the Richardson
Highway and around Knife Ridge proposed by the Alaska Depart-
ment of Fish and Game is not feasible due primarily to the
fact that it crosses an area that had severe responses to
the 1964 seismic event. During the 1964 earthquake, the
largest individual longitudinal fissure segments observed
were located in the general area where this alternate route
would be located.
The Alaska Department of Fish and Game is in the process of
officially approving the preferred pipeline route as described
in the DEIS with certain design-related stipulations. One
is that the pipeline be changed from a buried to an elevated.,
configuration, and this has already been done. The other
stipulations will be identified and made conditions of the
State of Alaska right-of-way permit in which these pipelines
would be constructed. The pipeline system should have no
significant long-term effects on the wildlife in this area.
The pipeline does not cross any unique habitat areas or
known migratory routes. Potential threats to the fish
resources in this area have been alleviated greatly by
changing to an elevated pipeline configuration and the
subsequent design stipulation which will be attached to
construction of this facility. With proper crossing of this
stream during construction, the only remaining threat to the
fish resources is that which would be associated with a
major catastrophic event such as the 1964 earthquake. Were
that to occur, it is highly likely there would be other
overriding natural damage to the entire Robe Lake drainage
system, such as cutting off water flow to Robe Lake by
areawide ground subsidence. We feel that elevating the
pipeline and attaching a stipulation package to the pipeline
construction will reasonably mitigate potential threats to
the fish and wildlife resources in this area.
4. Wastewater Outfall
The proposed route of the wastewater outfall pipe is as
shown in DEIS Attachment B, page B-105 in the Corps of
Engineers (Port Valdez 85) permit application, sheet 1 of
11. There have not been any changes to this route as shown.
John Paulson at CCC/HOK-DOWL indicated that he had recently
259
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4
sent Dave Dall a larger scale right-of-way map showing this
route. It is proposed that the Alpetco pipe be buried
across Valdez Glacier Stream, as would all other segments of
the pipe from the wastewater treatment facility to the shore
of Port Valdez. The draft NPDES permit, DEIS Attachment B,
page B-43, item g, does require Alpetco to prepare and
submit a report containing all data relative to the deter-
mination of dilutions and the design and location of the
wastewater outfall diffuser system six months prior to
diffuser construction. One of the ways this could be achieved
is with a dye plume test. We assume that it would probably
be done during the worst case summer months, however, rather
than during the winter. The stratified, low flow conditions
during summer would be the worst case dilution conditions.
5. Diversion Ditch
There is no diversion ditch per se planned for this project.
This was an alternative to rechanneling Slater Creek on the
north side of the site. The current plan is to rechannel
Slater Creek as shown on the map on page B-114 of DEIS
Attachment B. The drawing on Sheet 10 of 11 of the permit
application indicates how Slater Creek would be rechanneled
to flow directly into Valdez Glacier Stream, rather than
through Corbin Creek (Glacier) and then into Valdez Glacier
Stream, as it now does. As neither Valdez Glacier Stream
nor Slater Creek are anadromous fish streams, no timing
stipulations are anticipated for performing this work. We
would expect a logical time to do this would be in the
spring just after breakup and before the flows increase.
There are no known significant resource impacts from rechan-
neling Slater Creek. As mentioned, the creeks involved do
not currently support a fish population. It is also not
expected to have an impact on groundwater recharge. During
the summertime when there is flow in Slater Creek, there is
ample groundwater recharge in this basin from numerous
surrounding sources. In the wintertime when groundwater
recharge would become most critical, Slater Creek normally
is dry and is not believed to contribute anyway.
I hope this will provide you the information you need in
sufficient detail to prepare your response to the Corps of
Engineers permit application. You will be receiving a
review copy of the Final EIS on March 17. Dave Dall indicated
that with the above response, the DEIS and the review draft
of the Final EIS, he could prepare and send his official
260
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5
comments to the Corps of Engineers on the 404/Sec. 10
actions by March 28, 1980. It is important to have the
comments by this date because EPA is trying to make the EIS
a consolidated permitting effort. If there are any further
questions, please do not hesitate to contact me.
Sincerely yours,
Deborah K. Kirk
EIS Project Officer
DKK:adh
cc: Dave Dall (U.S. Fish & wildlife)
John Paulson (CCC/HOK-DOWL)
Ron Dagon (The Alpetco Co.)
261
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UNITED STATES
IN REPLY REFER TO:
o 1 APR 1980
Colonel Lee R. Nunn
District Engineer
Alaska District
Corps of Engineers
P.O. Box 7002
Anchorage, Alaska 99510
Dear Colonel Nunn:
The interested agencies of the Department of the Interior have reviewed
the subject Public Notice, dated 19 October 1979. The applicant, Alaska
Petrochemical Company (ALPETCO), has requested a Department of the Army
permit under Section 10 of the River and Harbor Act of 1899 and Section
404 of the Clean Water Act of 1977 for the following activities:
(1) Construct a temporary construction dock on the north shore of
Port Valdez;
(2) construct a control levee on the east bank of Valdez Glacier
(3) divert Slater Creek from Corbin Creek (Glacier) to Valdez
Glacier Stream;
(4) construct a bridge across Valdez Glacier Stream;
(5) construct a paved roadway across the Robe River, Corbin Creek
(Robe), Corbin Creek (Glacier), and related tributaries;
(6) lay a pipeline system (crude, product, and ballast water)
across the Lowe River, Robe River, Corbin Creek (Robe), Corbin
Creek (Glacier) and related tributaries, and Ambercrombie
Creek; and
(7) lay a wastewater outfall pipe from the ALPETCO site, across
the Valdez Glacier Stream, to discharge from the north shore
of Port Valdez.
A discussion of the proposed activities follows:
Re: Port Valdez 85
071-OYD-2-790373
Stream
R7-1
262
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Colonel Lee R. Nunn
Page 2
(1) Temporary Construction Dock - A construction barge dock would
be built at the far end of Port Valdez at the former Old
Valdez dock site obtained in a twelve-acre state tidelands
lease. The site would allow direct access to an adjacent city
of Valdez tract of land that ALPETCO would lease for a mobiliza-
tion yard to offload heavy materials, equipment and prefab-
ricated modules during refinery construction. Sheet piling
would be driven along one side of an existing projection of
land and fill would be placed behind it. Construction of the
dock would require approximately 1,000 cubic yards of dredging
and 4,000 cubic yards of fill. The dock would accommodate 100
x 400-foot barges. Upon completion of the project and expira-
tion of the tidelands lease, all facilities, with the exception
of the concrete ramp, would be removed. During the two years
of construction, equipment and construction materials totaling
approximately 750,000 tons would be transported to Valdez by
cargo vessels and barges and offloaded across this dock.
General cargo would arrive at the Valdez City Dock.
The intertidal flats adjacent to the construction dock site
are used by juvenile salmonids (mostly pink and chum salmon)
as a nearshore rearing area. Siwash Creek, the Loop Road
Creek system, and Sewage Lagoon Creek produce tens of thousands
of fry annually which feed in this area. Siwash Creek is the
most important pink salmon producing stream in Port Valdez
(escapement of 46,550 in 1977). The major usage of this
intertidal area is early April through mid-June.
The blue mussel (Mytilus edulis) and pink clams (Macoma balthica)
are important components of the faunal assemblage. Pink clams
are heavily utilized by diving ducks feeding in this area.
The greatest concentration of waterfowl is in the late fall
and early winter months.
The installation of pilings and riprap along with the filling
to form the barge dock will cause increased sedimentation to
the existing faunal assemblages in the immediate dock area.
However, the area is already influenced by sedimentation from
the Lowe River system, and additional deposition will not
present an insurmountable problem.
We have no objection to the construction dock providing the
following stipulations are satisfied:
(a) The dock will revert to city ownership as described in
the Review Draft Final Environmental Impact Statement
(EIS), page 109 and the Draft EIS, page 39.
(b) Dredge work shall not occur between 7 April and 7 June and
shall be limited to a clam shell operation as described
in the Review Draft Final EIS, pages 45 and 143.
263
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Colonel Lee R. Nunn
Page 3
(c) A.11 dredged material not suitable for fill will be
placed in the appropriate upland location (Alyeska
mobilization yard) as described in the Review Draft Final
EIS, pages 45 and 143.
(2) Control Levee - A flood control levee is to be constructed
along the west side of the plant site. This levee will
reduce the possibility of flood waters from Valdez Glacier
Stream entering the refinery complex. The levee will consist
of a 200,000 cubic yard earth embankment stabilized with
40,000 cubic yards of riprap. Material for the fill will come
from the refinery site and commercial sources. The embankment
will be nine feet high, a minimum of 15 feet wide at the top
(of which three to four feet will be class III riprap), and
will have a west facing slope of 1%:1.
We have no objection to construction of the control levee as
described.
(3) Stream Diversion - A modification to the hydrologic system is
proposed which would divert Slater Creek, which now meanders
through the proposed site and drains into Corbin Creek (Glacier),
into Valdez Glacier Stream through an abandoned and vegetated
braided channel. This diversion would result in a loss of
100-250 cubic feet per second (cfs) of flow in Corbin Creek
(Glacier) during the period of June through September. This
would reduce the flood flow of Corbin Creek (Glacier) by 35
percent during the high flow season.
No significant fish and wildlife resources are associated with
either Slater or Corbin Creek (Glacier), therefore, we have no
objection to the proposed Slater Creek diversion.
(4) Bridge and Access Road - The proposed primary access route
will use the existing city-owned Glacier Stream Haul Road. A
2,000-foot connecting road would be needed from the Haul Road
to the site, including a bridge across the main channels of
Valdez Glacier Stream. The bridge will be a pile-supported
steel and concrete structure consisting of three spans. Each
span will be approximately 60 feet in length with the overall
length at a minimum of 180 feet.
We have no objection to the bridge and access road across
Valdez Glacier Stream.
(5) Secondary Access Roadway - A paved roadway will be constructed
across the Robe River, Corbin Creek (Robe), Corbin Creek
(Glacier), and related tributaries. Stream crossings will be
concrete bridges with surfaced gravel approaches or gravel
covered culverts. The access road will be 24 £eet wide within
a 100-foot wide corridor.
264
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Colonel Lee R. Nunn
Page 4
Localized increases in suspended sediment concentration and
turbidity could occur at all stream crossings. The crossing
of Corbin Creek (Robe) would be the most sensitive crossing.
Coho salmon spawning and egg incubation is most sensitive
during the period of late August through mid-May.
~ We are proposing a realignment of the pipeline bundle and
associated access road (see item (6)). If ALPETCO determines
that this route is not feasible for the secondary access route,
and can provide documented evidence to support their position,
C1 we will not object to a secondary access road along the
designated route providing that pertinent mitigation measures
are implemented as described in the Review Draft Final EIS,
pages 42-45, or elsewhere in the document. The following
A stipulations must be satisfied:
(a) Crossing of anadromous fish streams will be by single
C2 span concrete bridges (as described in the Review Draft
A Final EIS, page 149(R-2).
V (b) Bridge construction shall be limited to the period June 1
C3 t° July 15 (as described in the Review Draft Final EIS,
A page 150 (c-4)).
(c) Once the refinery construction is completed, the access
road will be used only as an emergency route.
(6) Pipeline Route - Crude, product, and ballast water pipeline
crossings will be made across the Lowe River, Robe Rivar,
Corbin Creek (Robe), Corbin Creek (Glacier) and related
tributaries, and Ambercrombie Creek. There would be ten
products pipelines and one crude supply line which would be
constructed above ground from the refinery site to the Dayville
Road/Richardson Highway connection, then buried along the
Dayville Road right-of-way to within 1 1/3 miles of the pro-
ducts dock. From this point, the pipeline would again be
above ground. Above ground portions would be constructed on a
two-level structure. The pipeline rights-of-way, to be acquired
by lease from the State of Alaska, would be 300 feet wide
except for all/3 mile stretch immediately west of the Lowe
River Bridge which would use the southern 70 feet of the
Dayville Road right-of-way. The pipeline corridor immediately
adjacent to the Robe River residential subdivision would be
950 feet wide and 400 feet wide from there to the site. Total
length of the proposed route is approximately 5 1/3 miles.
The Robe Lake system, which includes Corbin Creek (Robe),
Brownie Creek, and the Robe River provides critical spawning
and rearing habitat for salmon, particularly coho and sockeye
salmon, that contribute to the sport and commercial marine
fishery. Corbin Creek (Robe), which passes directly through
265
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Colonel Lee R. Nunn
Page 5
~ ALPETCO's preferred pipeline corridor, supports the greatest
number of coho salmon spawners (4840 coho salmon in 1978) of
any Port Valdez drainage. Brownie Creek, with its headwaters
:s immediately adjacent to the pipeline route, supports up to
9,200 spawning sockeye salmon per year, and serves as a
rearing area for sockeye and coho salmon. The Robe River
ik serves as a migratory corridor for coho and sockeye salmon
enroute to Robe Lake and its tributaries, provides spawning
habitat for pink (15,000 pink salmon in 1973) and chum salmon,
and provides rearing habitat for coho and sockeye salmon. The
three major streams within this system also sustain populations
of Dolly Varden which currently provide a sport fishery. The
four Pacific salmon species that occur within the proposed
development area are all of special concern because of their
value to the sport fishery and commercial fishery of Prince
William Sound, and ecological importance to brown bear in the
area. Coho salmon, the most important sport fish species, are
the most vulnerable because of the limited spawning and rearing
habitat.
The Alaska Department of Fish and Game has identified the
Corbin Creek (Robe) and Brownie Creek system as "an excep-
tionally important salmon spawning drainage" (Draft EIS
Appendix I, page 1-184). Eighty percent of the coho salmon
spawning within the Robe Lake system occurs in Corbin Creek
(Robe). Table I, page 1-271 of the Draft EIS Appendix I shows
actual counts covering the last few years.
Nesting habitat for waterfowl is scarce in Port Valdez. The
largest area is the freshwater marsh at Robe Lake. The
northwest boundary of Robe Lake has been designated as a
"sensitive habitat area" (Dames and Moore, in The Birds of
Port Valdez, Sept. 1979), This marsh area provides valuable
nesting habitat for dabbling ducks and shorebirds. The
"Annotated List of Birds," page 1-245 of the Draft EIS Appendix
I lists those species utilizing this area.
The entire lengths of Corbin Creek (Robe) and Brownie Creek
are designated as "critical habitat" for black and brown bear
(Dames and Moore, in The Mammals of Port Valdez, Sept. 1979).
The area north of Robe Lake, to the refinery site, and west to
the subdivision is considered important habitat for black bear
and other mammals. The ALPETCO proposed pipeline route would
pass through both of these designated types of habitat. In
fact, the area considered important to these species extends
into the southern and eastern portion of the site.
266
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Lee R. Nunn
Page 6
Severe loss of aquatic life would be unavoidable in the event
of a pipeline rupture that introduced substantial quantities
of petroleum products into surface waters and/or the ground-
water system feeding Robe Lake and its tributaries (Corbin
Creek (Robe) and Brownie Creek). The high permeability of the
surface materials makes it imperative that spills of product
fuels or toxic substances be prevented. Some of the refined
products are highly toxic to aquatic organisms, especially
salmonid fishes. The most sensitive spill area would be near
Corbin Creek (Robe) since spilled substances would pass through
the entire Robe Lake system.
Contamination of surface waters and the groundwater system
would not only impact the salmon fishery and waterfowl usage
of Robe Lake but would seriously degrade the water quality of
the Robe River residential subdivision. The porous nature of
the surface materials found over the majority of the site area
causes the unconfined aquifer to be vulnerable to contamination
by spills of petrochemical products. This unconfined aquifer
is the main source of groundwater used by the subdivision as
well as feeding the headwaters of Corbin Creek (Robe) and
Brownie Creek. The degree of hazard from this contamination
source would be highest for products such as gasoline, naptha,
toluene, xylene, etc., which would dissipate from the ground.
The light fuel oils, in an underground situation, would
persist almost indefinitely and are of a sufficiently light
viscosity to soak into the permeable gravels to great depths
before cleanup could be effected.
If final design studies confirm a potential for liquefaction
in the southern and eastern portions of the site, the products
pipelines probably would present the greatest risk to the
environment. The northern section of ALPETCO's proposed pipe-
line route now passes through an area potentially prone to
liquefaction. Field data indicates that the subsurface forma-
tion may be loose and that the water table is quite shallow
(less than five feet). This suggests that strong seismic
activity may cause liquefaction and subsidence within this
area. Ground stretching also appears to be a potential hazard
to the pipeline corridor.
Due to the aforementioned concerns, we are suggesting an
alternative alignment which we consider to be less environ-
mentally damaging (see attached map). With our proposed
alignment, the pipeline would leave the Dayville Road right-
of-way approximately 2,000 feet south of the Richardson Highway
and would run parallel to the Richardson Highway for approxi-
mately 3,500 feet. The pipeline would then turn north at an
267
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colotiel Lee R. Nunn
Page 7
angle of about 45° (for a perpendicular crossing of the Robe
River) for a distance of approximately 2,000 feet to the
Richardson Highway. The pipeline would again turn north at an
angle of about 45°, cross under the Richardson Highway, and
continue to the base of Knife Ridge. A 25° turn to the east
would enable the pipeline to cross Knife Ridge at an angle
perpendicular to the ridge. This area appears to offer the
most gradual assent and descent of the ridge. The pipeline
would then cross Corbin Creek (Glacier) and run somewhat
parallel to the west side of Corbin Creek (Glacier) into the
proposed site. An access road would parallel the route. This
road would be used for maintenance and surveillance of the
pipeline.
We believe this route to be more environmentally acceptable
for the following reasons:
Our proposed route would avoid the major critical spawning
and rearing habitats associated with Robe Lake and its
tributaries (Draft EIS Appendix I, page 1-282). This
route would bypass the entire Robe Lake system except for
the crossing of Robe River near its mouth.
There would be one less anadrotaous fish stream crossing.
The only crossings after the Dayville Road cutoff would
be the Robe River and Corbin Creek (Glacier). Both
crossings would be at locations offering less potential
impact to fish and wildlife habitat and the groundwater
system. With this route, Corbin Creek (Robe) would not
be crossed.
The pipeline route would avoid the sensitive mammal and
waterfowl habitat associated with the Robe Lake system
(Draft EIS Appendix I, pages 1-242 and 1-388).
Our proposed route would cross less wetlands areas. The
only wetlands affected would be those associated with the
Robe River and Corbin Creek (Glacier) crossings (Draft
EIS, page 151 and Appendix I, page 1-404).
Our proposed pipeline route would cross less area possibly
prone to liquefaction (as indicated by areas of possible
loose sands)(Draft EIS, page 109 and Appendix I, page I-
89).
Our alternative would avoid crossing any areas with known
potential for ground stretching with the occurrence of a
major seismic event (Draft EIS Appendix I, page 1-60).
(a)
C9
(b)
(c)
~ (d)
C10
A.
V (e)
C11
A
(O
C12
A
268
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Colonel Lee R. Nunn Page 8
The Draft EIS also indicates that no gross tectonic
deformation occurred in the site area as a result of the
1964 earthquake and that no active or inactive faults are
known to exist within a ten-mile radius of the site
(Draft EIS, page 112). No major landslides or rockfalls
have been associated with seismic activity in the Valdez
region. The natural rock slopes within the site should
remain stable during expected ground shaking in this
area. This should pose no problem for the pipeline over
Knife Ridge. The 1964 seismic event was unique in that
it was extremely violent and of unusually long duration.
These two factors may have resulted in the reported
ground failures (Draft EIS Appendix I, page 1-59). There
was some ground stretching southwest of Knife Ridge along
the existing levee (ALPETCO's alternate route). Our
proposed route would be approximately 3,000 feet east of
this area.
C}3
(g) The route would be approximately the same length as the
ALPETCO preferred route.
~ (h) Our suggested route would offer increased protection of
C14 the groundwater system for the existing and proposed
A residential subdivision.
C15
(i) The existing land use is currently designated as "open
space" (Draft EIS, pages 168 and 171). North of the
Richardson Highway the pipeline would cross existing or
proposed city-owned lands. South of the highway the
pipeline would cross city-owned and possibly state-owned
lands.
~ (j) South of the Richardson Highway the pipeline route would
C16 be entirely within the area currently zoned for "industrial
A use" (Draft EIS Appendix II, page 11-108).
~ (k) Our proposed route north of the Richardson Highway will
C17 only cross and area projected for industrial use (Draft
A EIS, page 245).
~ (1) The route will avoid using corridors of the Department of
C18 Transportation and Copper Valley Electric Association
A rights-of-way along the Richardson Highway.
C19
(m) The pipeline would be removed from the Robe River residential
subdivision and the proposed extension of this subdivision
to the north (Draft EIS, page 139 and 168). This would
reduce construction noise adjacent to the residential
area and reduces the possibility of exposure to residential
activity.
269
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Colonel Lee R. Nunn Page 9
~ (n) The pipeline could be either above ground or buried,
C20 except for the crossing of the Robe River which would
± have to be elevated.
(7) Wastewater Outfall Pipe - A wastewater outfall pipe will
extend from the ALPETCO site across Valdez Glacier Stream to
discharge from the north shore of Port Valdez. The pipe line
will be 24 inches in diameter and will be buried along its
entire length. The pipeline will extend 1,200 feet out from
mean lower low water (MLLW) to a depth of 180 feet.
We have no objection to the location of the wastewater outfall
pipe. However, we do suggest that the buried portion of this
-------
/faoPOStr'O /Zo
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RESPONSE TO COMMENTS BY THE
U.S. DEPARTMENT OF THE INTERIOR, FISH & WILDLIFE SERVICE
The preceeding letter by the U.S. Fish & Wildlife Service is in reply to the
Corps of Engineers Section 404 Permit public notice. There are several facets
to the 404 permit on which FWS has provided a reply of "no objection." These
items will not be repeated; the responses that follow address only those items
that raise specific questions or warrant further discussion. The only items
receiving substantive comment in the FWS letter concern the location of the
pipeline route from the Richardson Highway into the site, and its adjoining
secondary access road. Consequently, the comments which are paraphrased below,
and their responses, address mainly these two issues.
CI We are proposing a realignment of the pipeline bundle and associated access
road. It Alpetco determines that this route is not feasible for the sec-
ondary access route, and can provide documentation to support their posi-
tion, we will not object to a secondary access road along the designated
route, providing that pertinent mitigation measures are implemented.
R1 Physical alterations to Knife Ridge that would be necessary to construct a
useable access road along the suggested route preclude this route from
being a feasible alternative to the preferred secondary access road route.
In addition, the City of Valdez has stated that a roadway or pipeline
crossing of city-owned land west of Robe River Subdivision would not be
compatible with the city's intended use of this area, and would not be
allowed. The city also voiced objections to a major surface alteration of
Knife Ridge for aesthetic and noise control reasons (See City of Valdez
letter, p. 281).
The natural ground surface of Knife Ridge at the lowest point in elevation
rises from 50 ft at the base of the hill to 228 ft at the top, a rise of
about 35 percent or about 2.9 ft horizontal to 1 ft vertical. At the
highest point of the hill, the rise is about 47 percent, or 2.1 ft hori-
zontal to 1 ft vertical. Two factors governing the design of a roadway are
to maintain a grade which allows for physical access during slippery winter
272
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to maintain a grade which, allows for physical access during slippery winter
conditions, limited to about 10 percent maximum, and to maintain a grade
which allows safe site distance, which would be expected to be less than 10
percent. Therefore, to cross the ridge at its lowest point and maintain a
maximum grade of 10 percent, the peak roadway elevation would be limited to
102 ft, compared to the natural elevation of 228 ft. ,This would require a
cut approximately 126 ft deep. To allow for roadway at the bottom, and
properly cut slopes, the cut would have to be 450 ft wide at the top of
Knife Ridge. To include the pipeline bundle, or cross at any but the
lowest point, the depth and width of the cut would increase. Creation of
such an eyesore at the entry to the city is among the objections of the
City of Valdez. Additionally, an access road in a less obtrusive area
would be more easily restricted from use.
C2 Regarding the route of the preferred secondary access road, crossing of
anadromous fish streams would be by single span concrete bridges.
R2 This stipulation has been made. See Section IV, p. 253, item R2.
C3 Regarding the preferred route of the secondary access road, bridge con-
struction shall be limited to the period June 1 to July 15 (as described in
a review draft of the FEIS which was made available to the agencies for
comment prior to publication of the FEIS).
R3 The statement, which appears in FEIS Section II, p. 47, item C3, states
that all in-water product pipeline construction shall occur from June 1 to
July 15 of each year, with the exception of the Lowe River within which
work will occur from March 1 to June 15. This restriction applies to con-
struction activities that will take place in the streams. A single-span
bridge deck, for example, could be placed outside this time span, provided
there is no in-stream work. This restriction doeB not apply to any part of
bridge construction that is not performed in the stream or that does not
directly affect the natural stream flow.
C4 Regarding the preferred route for the secondary access road, once the
273
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R4 The secondary access road would be restricted from general public access
and would serve only as an emergency route and for pipeline surveillance
access by company officials (see Section II, p. 15).
C5 Alpetco's preferred pipeline corridor supports the greatest number of coho
salmon spawners (4,840 coho salmon in 1978) of any Port Valdez drainage.
Brownie Creek, with its headwaters immediately adjacent to the pipeline
route, supports up to 9,200 spawning sockeye salmon per year and serves as
a rearing area for sockeye and coho salmon.
C5 For clarification, Corbin Creek (Robe) which crosses the preferred pipeline
corridor currently (1978-1979) supports the greatest number of coho salmon
spawners of any Port Valdez drainage. Per Alaska Department of Fish & Game
information, during the years 1975 through 1977 the Lowe River system and
Robe Lake system produced nearly equivalent numbers of coho salmon.
Brownie Creek is located adjacent to the preferred pipeline route at a
distance of approximately 900 ft from the proposed pipeline alignment.
C6 First two paragraphs on p. 6 of the comment letter regarding possible
occurrence of pipeline spills of substantial quantities and the conse-
quences .
R6 Refer to FEIS Section II, p. 14, for the discussion on probability of
spills, and specific spill avoidance precautions. This comment discusses
the severe losses that would be experienced in the event substantial
quantities of petroleum products spilled into the surface waters and/or the
groundwater systems feeding Robe Lake and its tributaries. Although the
term substantial quantities is a relative term which has not been quant-
ified, the available information indicates that the probability of a large
spill has been reduced to an acceptable level. In addition, various miti-
gation items are directed toward early detection and minimization of any
spill that could occur from the remaining risk. The prediction of the con-
sequences of a spill should focus on the expected spill magnitude as well
as the catastrophic scenario. As a final mitigation measure, Alpetco has
agreed to assist the Alaska Department of Fish and Game and/or Valdez
Fisheries Development Association in establishing an alternate coho fishery
in the eastern Port Valdez area.
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sequences of a spill should focus on the expected spill magnitude as well
as the catastrophic scenario. As a final mitigation measure, Alpetco has
agreed to assist the Alaska Department of Fish and Game and/or Valdez
Fisheries Development Association in establishing an alternate coho fishery
in the eastern Port Valdez area.
C7 If final design studies confirm a potential for liquefaction in the eastern
and southern portions of the site, the products pipeline probably would
present the greatest risk to the environment.
R7 For further information, see FEIS Section III, p. 129, items C17 and R17.
The referenced statement concludes that if the area is determined to be
sufficiently susceptible to liquefaction, safe construction is not pre-
cluded but rather subjected to more restrictive design standards.
C8 Ground stretching also appears to be a potential hazard to the preferred
pipeline corridor.
R8 This is not correct. There is no known information documenting any ground
stretching (cracks in the earth due to strong seismic events) in the area
of the preferred pipeline corridor.
Note: At this point in the comment letter, the Fish and Wildlife Service sug-
gests a third alternate route for the pipeline system and presents an outline of
comments and discussions concerning the route. The comments and responses that
follow concern the FWS discussions on the third alternate pipeline route. The
location of this route is described in the comment letter on the bottom of p. 6
and top of p. 7, and is shown in a diagram at the conclusion of the letter.
This alternate suggested pipeline route was first proposed by Fish & Wildlife
Service in a conference on March 21, 1980 and appeared as a formal proposal in
the April 1, 1980 comment letter to the Corps of Engineers on the Section 404
Permit Public Notice. During consideration of alternate pipeline routes> the
general FWS suggested route was eliminated from consideration for reasons con-
tained in the following responses. In reviewing preliminary text material being
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prepared for the Final EIS, FWS stated that Alpetco has determined that the
alternate pipeline route which was described in the DEIS is not acceptable;
therefore, no viable alternative was presented for public and agency review.
Therefore, FWS presented the suggested route described in their comments. This
has been misunderstood and is not the case. Alpetco has not made any determina-
tions or decisions regarding the alternate pipeline route since the DEIS was
released. The DEIS alternate pipeline route does remain an alternative in this
project; however, it is not considered the preferred route for the reasons
described in Final EIS, Section II, p. 13-16. Although a description of this
third alternative route was received late, the responses below are intended to
be sufficiently detailed to describe why, with consideration to all factors
involved, a route in this location was not considered an alternative previously
and is inferior to the preferred pipeline corridor.
C9 Paragraphs (a), (b), & (c) on p. 7 of the comment letter.
R9 The FWS-proposed pipeline route would avoid the entire Robe Lake system as
indicated in the comments. However, this applies only to the pipeline sys-
tem but not necessarily to the secondary access road. All indications are
that the secondary access road could still be located in the proposed cor-
ridor from the Richardson Highway to the plant site. The net increase of
habitat lost with the route suggested by the FWS would be greater than with
the preferred corridor. The suggested pipeline route would still require
an adjoining access road for pipeline surveillance purposes. This would
preclude the preferred secondary access road serving a dual purpose (emer-
gency access and pipeline surveillance) and would result in a net increase
of disturbed land for these facilities.
CIO The FWS-proposed route would cross less wetland areas. The only wetlands
affected would be those associated with the Robe River and Corbin Creek
(Glacier) crossings.
RIO This route would cross less wetland areas.
Cll The FWS-suggested route would cross less area possibly prone to liquefac-
tion (as indicated by areas of possible loose sands).
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Rll As discussed in R7 above, this is not really an issue. Any subsequent
determination that the preferred route is prone to liquefaction would only
define safe design and construction techniques, and would not necessarily
imply any greater environmental risks.
C12 The FWS-suggested route would avoid crossing any areas with known potential
ground stretching with the occurrence of a major seismic event.
R12 This is not correct. The FWS-suggested route would pass within 900 feet of
the location of the largest individual longitudinal fissures produced in
the Valdez area during the 1964 earthquake. This is about the same dis-
tance as the alternate pipeline route #2 identified in the EIS was from the
fissure segments, and this was of considerable concern to the viability of
that route. See also item R8 above and Section II, p. 16.
C13 The FWS-suggested route would be approximately the same length as the pre-
ferred route.
R13 This is true, the routes would be roughly equivalent in length.
C14 The FWS-suggested route would offer increased protection of the groundwater
system for the existing and proposed residential subdivision.
R14 Both routes have pipelines within 1,000 feet of the subdivision; therefore,
on the basis of proximity, the subdivision groundwater system would be
equally vulnerable to each route. The FWS route has a greater length of
pipe located a greater distance from the subdivision than the preferred
route and on this basis part of the system would present less risk to the
groundwater system.
C15 Existing land use in the area of the FWS-suggested route is currently
designated as "open space." North of the Richardson Highway, the pipeline
would cross existing or proposed city-owned lands. South of the highway,
the pipeline would cross city-owned, and possibly state-owned lands.
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R15 The proposed Valdez zoning ordinance, recently published, will update
existing land use designations. The area south of the Richardson Highway
would be zoned P (Public Interest Lands District) which is intended to be
lands containing major open space areas, watershed areas and major public
and quasi-public recreation, education and institution uses, including pri-
vate lands and uses that are essentially public in character and of spec-
ific value to the entire community. There is a 500 ft wide buffer strip
around the northwest and northeast sides of Robe River Subdivision that
would also be zoned P. The other parcel applicable to this discussion is
the city-owned property west and north of Robe River Subdivision which
would be zoned HI (Heavy Industrial District).
C16 South of the Richardson Highway, the FWS-suggested pipeline route would be
entirely within the area currently zoned for "industrial use."
R16 As mentioned in R15 above, this area is now proposed for P zoning.
C17 The FWS-proposed route north of the Richardson Highway will only cross an
area projected for industrial use.
R17 The City of Valdez has stated that a pipeline system or access road would
not be compatible with their intended use of this HI zoned parcel west of
Robe River Subdivision. In addition, the city is concerned that the pipe-
line construction over Knife Ridge would create an unacceptable eyesore.
For this reason, the City of Valdez has stated that this land shall not be
considered available for a pipeline route and should be excluded from
further consideration. See City of Valdez letter, p. 281.
C18 The FWS-suggested route would avoid using corridors in the Department of
Transportation and Copper Valley Electric Association rights-of-way along
the Richardson Highway.
R18 True, this route would avoid these corridors.
C19 The FWS-suggested route would be removed from the Robe River residential
subdivision and the proposed extension of this subdivision to the north.
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This would reduce construction noise adjacent to the residential area and
would reduce the possibility of exposure to residential activity.
R19 The preferred route and the FWS-suggested route are nearly equidistant from
the existing subdivision boundaries; however, the presently developed por-
tions of the subdivision are closest to the preferred route. Over the long
term, it would have to be assumed that the subdivision would become fully
developed and that the possibility of exposure to residential activity
would be equal between the two routes. The construction activities would
be of short duration and all of the developed subdivision areas are located
closer to the preferred route. The short-term impacts from construction
are not expected to be significant. From a noise standpoint, operating
heavy equipment on an elevated location such as Knife Ridge could have the
most significant short-term effects. The new proposed Valdez zoning ordin-
ance classifies the land north of Robe River Subdivision as either P
(Public Interest Lands) or HI (Heavy Industrial District) which would pre-
clude extension of the subdivision to the north.
C20 Along the FWS-suggested route, the pipeline could be above ground or
buried, except for the crossing of the Robe River which would have to be
elevated.
R20 Comment so noted.
C21 Regarding the wastewater outfall pipe, we have no objection to the loca-
tion; however, we do suggest that the buried portion of this line be
extended to -5.0 ft. MLLW to avoid exposure at lower tide levels. This
suggestion is in support of the National Marine Fisheries Service recom-
mendation to you on January 25, 1980.
R21 This will be done. See Section III, p. 254.
C22 Reference the last paragraph in the Fish and Wildlife Service comment
letter.
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R22 It should be clarified that Fish & Wildlife Service discussed their pipe-
line alignment with CCC/HOK-DOWL, which is acting as EPA's consultant for
preparation of the Environmental Impact Statement. CCC/HOK-DOWL was not
acting as a consultant to Alpetco as stated in the comment letter. With
reference to the suggested FWS pipeline alignment alternative, CCC/HOK-DOWL
was looking into this proposal on behalf of EPA.
280
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OFFICE OF ADMINISTRATION
April 7, 1980
Mr. John E. Paulson, Project Manager
CCC/HOK-DOWL
4040 "B" Street
Anchorage, Alaska 99503
Dear Mr. Paulson:
The City of Valdez Planning Department has reviewed the pipeline
route discussed in your March 14, 1980 letter and we offer the
following comments.
The City does own the tract west of Robe River Subdivision from
the Richardson Highway north across Knife Ridge into and includ-
ing the proposed Alpetco plant site. We would not agree with
use of any portion of the property east of Robe River Subdivision
for a pipeline crossing. This is approximately two hundred
acres of developable highway frontage land that the City considers
important to the industrial park currently being formulated in
this general area. We would not want to encumber any part of
this property with a pipeline system. The City views either
of the other two alternatives far more viable from a land-use
standpoint.
In addition, the City would strongly oppose any large-scale
alteration of Knife Ridge which appears would be required by
construction activities over the ridge. Aesthetically, the City
views Knife Ridge as one of the natural features that will
visually screen the Alpetco plant from Richardson Highway view-
points and we don't want the ridge to become an eyesore by destruc-
tion of the natural features. Also, we consider Knife Ridge as a
valuable sound barrier between Robe River Subdivision and the
plant site and any alteration of it will render it less effective
for this purpose. Particularly from a visual standpoint we would
not agree with crossing Knife Ridge with the pipeline system or
access road.
The City of Valdez does not consider this pipeline route a viable
alternative and we recommend it be excluded from further considera-
tion in the development of this project.
Sincerely/ 1 /
CITY OF/VAXiD^Z, ALASKA
i I'>'(
Mark Lewis
City Manager ^
c'c:BCDXeborah Kirk -A'ePAZ' ALASKA 99686 • • • TELEPHONE (907) 835-4313
Ron Flfloon "hp A I npfnn Pnmnanw
J^Pigeline ^
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U.S. ENVIRONMENTAL PROTECTION AGENCY
ALASKA OPERATIONS OFFICE
Room E535, Federal Building
701 C Street
Anchorage, Alaska 99501
March 26, 1980
REPLY TO
ATTN OF:
David L. Robbins, Chief
Construction/Operations Division
Alaska District, C/E
P. 0. Box 7002
Anchorage, Alaska 99510
Re: 071-0YD-2-790373 Port Valdez 85
Dear Mr. Robbins:
The Alaska Operations Office has received the above referenced permit
application to construct a refinery and petrochemical supporting facil-
ities at Valdez.
We have no objection to the issuance of this permit provided the appli-
cant complies with Alaska Department of Fish and Game conditions that
may be needed to protect the aquatic resources.
Sincerely,
William Lawrence
Dredge and Fill Permit Coordinator
cc: USFWS, Anchorage
NMFS, Anchorage
ADFG, Anchorage
ADEC, Anchorage
Applicant
282
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U.S. ENVikONMENTAL protection «gency
ALASKA OPERATIONS OFFICE
Room E535, Federal Building
701 C Street
Anchorage, Alaska 99501
1$ FEB 1880
REPLY TO
ATTN OF:
David L. Robbins, Chief
Construction/Operations Division
Alaska District, C/E
P. 0. Box 7002
Anchorage, Alaska 99510
Re: 071-0YD-2-790372 Port Valdez 84
Dear Mr. Robbins:
We have reviewed the above referenced permit application to construct
a tanker terminal in an area adjacent to the Dayville Road in Port
Valdez near the City of Valdez.
Our Agency will have no objection to the issuance of this permit pro-
vided the applicant complies with all State and Federal resource agency
conditions that may be needed to protect the aquatic resources.
Sincerely,
William Lawrence
Dredge and Fill Permit Coordinator
cc: USFWS, Anchorage
NMFS, Anchorage
ADFG, Anchorage
ADEC, Anchorage
Applicant
283
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STATE OF ALASKA
DEPARTMENT OF ENVIRONMENTAL CONSERVATION
CERTIFICATE OF REASONABLE ASSURANCE
A Certificate of Reasonable Assurance, as required by Section 401 of the
Clean Water Act, has been requested by the Alaska Petrochemical Company,
an Alaskan Corporation, 601 W 5th Avenue, Suite 320, Anchorage, Alaska
99501, for the construction of a temporary construction dock, a control
levee, diversion ditches, bridge crossings, pipeline crossings and installation
of a wastewater outfall pipe from the facility.
The proposed activity is located in numerous Sections of T9S R6W R5W;
and T8S R6W, R5W, Valdez quads, A-6, A-7, at the eastern end of Port Valdez.
Public notice of the application for this certification has been made in
accordance with 18 AAC 15.180.
Water Quality Certification under Section 401 of the CWA is required for
the proposed activity because the activity will be permitted by a Department
of the Army permit identified as NPACO 071-OYD-2-790373, Port Valdez 85, and a
discharge may result from the proposed activity.
Having reviewed the application and comments received in response to the
public notice, the Alaska Department of Environmental Conservation
certifies that there is reasonable assurance that the proposed activity,
as well as any discharge which may result, is in compliance with the
requirements of Section 401 of the Clean Water Act which includes the
Alaska Water Quality Standards, 18 AAC 70, and the Standards of the
Alaska Coastal Management Program, 6 AAC 80, provided that the following
conditions are included:
1. The pipeline shall be above ground throughout the Corbin Creek
(Robe) drainage with shut off valves at the Corbin Creek and Robe River
crossings.
2. The pipelines shall be elevated across Corbin Creek (Robe) and Robe
3. Once the facility is constructed, the Corbin Creek (Robe) access
road shall be used only for pipeline maintenance and inspection purpose;
4. Dredge work in the area of the temporary dock shall not occur
between 7 April and 7 June. Dredging shall be limited to a clam
shell operation.
5. Inwater work in Abercrombie Creek shall occur only between 1 June
and 15 July. For the Lowe River, inwater work shall occur between
1 March and 15 June.
River.
fj f * fa
Date
284 C. Deming Cowles
Deputy Commissioner
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p tTP
'4
I
OFFICE OF THE GOVERNOR
DIVISION OF POLICY DEVELOPMENT AND PLANNING
JAY S. HAMMOND, Governor
POUCH AD
JUNEAU. ALASKA 99811
PHONE: 465-3512
April 3, 1980
Mr. James Caruth
U.S. Army Corps of Engineers
Regulatory Functions Branch
P.O. Box 7002
Anchorage, Alaska 99510
Subject: Valdez Oil & Gas Refinery & Facilities Permit
State I.D. No. FD230-79102303FP, COE #071-0YD-2-790373
Dear Mr. Caruth:
It is our understanding that the following 6 stipulations have been
agreed to by the applicant, Alpetco, concerning the subject project's
Alaska Coastal Management Program (ACMP) consistency review:
1. The pipeline shall be above the ground throughout the Corbin Creek
(Robe) drainage with shut off valves at the Corbin Creek and Robe
River crossing. 6 AAC 80.130(c)(7).
2. The pipelines shall be elevated across Corbin Creek (Robe) and Robe
River. 6 AAC 80.130(c)(7).
3. Once the facility is constructed, the Corbin Creek (Robe) access
road shall be used only for pipeline maintenance and inspection
purposes. 6 AAC 80.130(c)(7).
4. Alpetco shall establish within the Port Valdez area, an alternate
coho salmon run of value not less than the Corbin Creek (Robe) run.
This establishment will be in conjunction with activities of the
Alaska Department of Fish and Game and/or Valdez Fisheries Development
Association. This run should be established within thirty-six (36)
months after commencement of plant operation. 6 AAC 80.130(c)(7).
5. Dredge work in the area of the temporary dock shall not occur
between April 7 and June 7 with all dredge work limited to a clam
shell operation.
6. Inwater work in Abercrombie Creek is limited to the period between
June 1 and July 15, while inwater work in the Lowe River is to be
limited to the period between March 1 and June 15.
Since these stipulations have been accepted by the applicant, the Division
of Policy Development and Planning, in accordance with Public Law 92-583
01-A3LH
285
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Mr. James Caruth
-2-
April 3, 1980
and 94-370 and Alaska Statutes 46.40.010, has completed review of the
consistency of the subject proposal with the Alaska Coastal Management
Program.
As currently modified by these stipulations, we concur that the proposal
is consistent with ACMP.
However, if the project is substantially amended during its implementation
such that it affects the coastal zone differently than as represented in
the proposal we reviewed, we ask that you contact the State Clearinghouse
to determine if an ACMP review of the revision is required.
cc: Alpetco
Tom Barnes, Office of Coastal Management
Department of Fish and Game
Department of Natural Resources
Department of Community & Regional Affairs
Department of Environmental Conservation
Department of Transportation & Public Facilities
Department of Commerce and Economic Development
Environmental Protection Agency
286
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STATE OF ALASKA
DEPARTMENT OF ENVIRONMENTAL CONSERVATION
CERTIFICATE OF REASONABLE ASSURANCE
A Certificate of Reasonable Assurance, as required by Section 401 of the
Clean Water Act, has been requested by the Alaska Petrochemical Company,
an Alaskan Corporation, 601 W 5th Avenue, Suite 320, Anchorage, Alaska
99501, for the construction of a tanker terminal, including loading platforms,
a product and ballast pipeline network, mooring dolphins and a trestle.
The proposed activity is located near Allison Creek on the southeastern portion
of Port Valdez.
Public notice of the application for this certification has been made in
accordance with 18 AAC 15.180.
Water Quality Certification under Section 401 of the CWA is required for
the proposed activity because the activity will be permitted by a Department
of the Army permit identified as NPACO 071-OYD-2-790372, Port Valdez 84, and a
discharge may result from the proposed activity.
Having reviewed the application, and comments received in response to the
public notice, the Alaska Department of Environmental Conservation
certifies that there is reasonable assurance that the proposed activity,
as well as any discharge which may result, is in compliance with the requirements
of Section 401 of the Clean Water Act which includes the Alaska Water Quality
Standards, 18 AAC 70, and the Standards of the Alaska Coastal Management Program,
6 AAC 80.
Date
C. Deming Cowles
Deputy Commissioner
28 7
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,qp r\ CTP
k
&
fn\
v(
urn
/
OFFICE OF THE GOVERNOR /
DIVISION OF POLICY DEVELOPMENT AND PLANNING /
April 3, 1980
JAY S. HAMMOND, Governor
Phone 465-3512
Pouch AD - Juneau 99811
Mr. Jim Caruth
U.S. Amy Corps of Engineers
Regulatory Functions Branch
P.O. Box 7002
Anchorage, Alaska 99510
Subject: Valdez Oil & Gas Terminal COE Permit
State I.D. No. FD230-79110703FP, COE #071-0YD-2-790372
Dear Mr. Caruth:
The Division of Policy Development and Planning, in accordance with
Public Law 92-583 and 94-370 and Alaska Statutes 46.40.010, has completed
review of the consistency of the subject proposal with the Alaska Coastal
Management Program (ACMP).
As currently planned, we concur that the proposal 1s consistent with
ACMP.
However, if the project is substantially amended during its Implementation
such that It affects the coastal zone differently than as represented 1n
the proposal we reviewed, we ask that you contact the State Clearinghouse
to determine if an ACMP review of the revision is required.
rrances A. Ulme
'Director
cc: Tom Barnes, Office of Coastal Management
Alpetco
Glen Akins, DEC'
Rikki Fowler, DEC
Commissioner McAnerney, CRA
Commissioner Webber, CED
Commissioner Ward, D0T/PF
Bob Baldwin, DNR
Bruce Barrett, ADF&G
James Sweeney, EPA
01-A3LH
288
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U.8. DEPARTMENT OF ( 1MERCE
National Oeaanie and Atntwspharie Administration
National Marine Fisheries Service
701 C St. Box 43
Anchorage, Alaska 99513
Reply to Attn, of:
NPACO'No. 071-0YD-2-790372
Reference is made to your public notice dated October 19, 1979, to
construct a tanker terminal in an area adjacent to the Dayville Road
in Port Valdez, near the city of Valdez, Alaska.
We have reviewed the above-referenced application and believe the described
construction activities could have an adverse impact on the living marine
resources located in the vicinity of the proposed construction. We be-
lieve the resources will be adequately protected provided the permittee
adheres to the standard conditions of the £orps of Engineers' permit and
the following stipulation:
1. No in-water construction shall occur between July 15 and August 15,
to avoid interference with salmon migrations.
Thank you for the opportunity to comment on this application at this time.
COMMENT
NOTED
289
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DEPART MENT OF FISH AND GA ME
333RASPBERRY ROAD
ANCHORAGE §95t2
JA Y S. HAMMOND. GOVERNOR
January 14, 1980
NPA 2-790372/Port Valdez 84
Department of the Army
Alaska District, Corps of Engineers
Regulatory Functions Branch
P. 0. Box 7002
Anchorage, Alaska 99510
Attention: David L. Robbins
Gentlemen:
The Alaska Department of Fish and Game has reviewed the subject proposal
by Alpetco to construct a tanker terminal in the Port Valdez area.
We do not foresee any major fisheries or wildlife conflict with the
proposal. There will be, however, some indirect problems but not to the
extent that warrants discussion in this letter. These points will be
covered in our response on the Draft Environmental Impact Statement.
Thank you for the opportunity to comment.
Sincerely,
BY: Bruce M. Barrett
Projects Review Coordinator
Habitat Protection Section
cc: R. Morris, NMFS
R. Bowker, USFWS
B. Flint, ADEC
B. Lawrence, EPA
A1petco
Rona" ' ~ ~ * •
290
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PUBLIC HEARINGS
Public hearings on the draft EIS and associated federal permit actions were con-
ducted in Anchorage on January 29, 1980, in Valdez on January 30, 1980 and in
Juneau on January 31, 1980. The hearings were widely publicized. The following
testimonies by federal agencies were presented at the hearings in Anchorage and
Valdez. Due to the very limited attendance at Juneau, the testimonies were
incorporated into the record by reference and were made available to the
attendees. Attendance numbered 28 in Anchorage, 31 in Valdez and 2 in Juneau.
Because agency testimonies were the same at all three hearings and the only
public testimony was that of Valdez Mayor Walker, the transcript of the Valdez
hearing only is repeated here. There were no statements or questions by the
public in Anchorage. Mayor Walker, City of Valdez, presented a statement at the
Valdez hearing. At Juneau, Bob Martin entered into the record the fact that he
represented the Alaska Conservation Society and that they had been represented
at the hearing.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
FEDERAL PUBLIC HEARING
ON THE
DRAFT ENVIRONMENTAL IMPACT STATEMENT (DEIS)
FOR THE ALASKA PETROCHEMICAL COMPANY (ALPETCO)
REFINING AND PETROCHEMICAL FACILITY
TO BE SITED AT VALDEZ, ALASKA
The above-entitled matter came on for hearing, pursuant
to notice, at approximately 7:40 p.m. on Wednesday, January 30,
1980 in the City Council Chambers, Valdez, Alaska.
PANEL MEMBERS
RICHARD DU BEY
LLOYD REED
DEBORAH KIRK
MIKE JOHNSTON
BILL LAMOREAUX
Hearing Officer
Assistant Regional Counsel
U.S. Environmental Protection Agency
Region 10
1200 Sixth Avenue
Seattle, Washington 98101
Director of Enforcement Division
EPA Project Officer for the DEIS
Chief, EPA1s New Source Permits
Section
EPA'S Alaska Operations Office
701 C Street
Anchorage, Alaska
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ALASKA-WIDE COURT REPORTERS 292
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ANCHORAGE. ALASKA 9S501
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SPEAKERS
NAME PAGES
Statement - William Du Bey 4-10
Statement - Deborah Kirk 10 - 15
Statement - Bill Lamoreaux 15 - 21
Statement - Joyce Bealman 21 - 25
Statement - Michael Johnston 25 - 30
Statement - Mike Mahoney 30 - 34
Statement - Mayor Bill Walker 35 - 36
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certificat ion
THIS IS TO CERTIFY:
That the proceedings in the matter of:
PUBLIC HEARING ON THE
DRAFT ENVIRONMENTAL IMPACT STATEMENT (DEIS)
FOR THE ALASKA PETROCHEMICAL COMPANY (ALPETCO)
REFINING AND PETROCHEMICAL FACILITY
TO BE SITED AT VALDEZ, ALASKA
were had as herein appears and this is the
original verbatim transcript thereof for
the files of the Agency.
ALASKA-WIDE COURT REPORTERS
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ALASKA-WIDE COURT REPORTERS 294
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PROCEEDINGS
HEARING OFFICER RICHARD DU BEY, presiding: Good evening.
My name is Richard Du Bey, Assistant Regional Counsel of the
U.S. Environmental Protection Agency in our Seattle Office and
I've been designated by our Regional Administrator as Hearing
Officer for the purpose of this hearing.
I'd like to welcome you all here this evening. I realize
the subject of the hearing, the ALPETCO refinery and the permits
for the ALPETCO refinery, are of interest to you and we hope to
share our information with you and receive any information that
you may have about the project.
The people who are seated up at the panel, and we don't
quite outnumber you although we tried to, are going to be making
presentations as a part of this hearing to provide you with
information as to what we have done to date regarding the NEPA
process and the various permits that are involved in this
project. I'd like to just take a moment to introduce everybody.
From your left to right, Miss Deborah Kirk, and she's with EPA,
she was the Project Officer for the EIS, Environmental Impact
Statement, for this project; next is Bill Lamoreaux of the EPA's
Alaska Operations Office in Anchorage and he is the person who
is responsible for the NPDES water discharge permit for the
project; next is Lloyd Reed, he's the special representative of
the Regional Administrator, and he's the Director of our Enforce-
ment Division; next is Joyce Bealman with the Alaska Department
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of Environmental Quality, she's going to be talking to us a bit
about the water quality standards and the State Certification of
EPA's water discharge permit; next is Mike Johnston, he's Chief
of EPA's Permit Branch in Seattle and he's going to tell you
about the PSD, or the Prevention of Significant Deterioration of
the air permit which is a part of this project. Next is
Captain Mike Mahoney of the Corps of Engineers. The Corps is
a cooperating agency with EPA in developing the Environmental
Impact Statement and he's going to talk about the Corps' 404
permit and Section 10 permit, which they will be issuing for the
project.
For the record, I'd like to note that this combined hear-
ing was convened at 7:40 p.m., January 30, 1980 at the Valdez
City Hall, Council Chambers, Valdez, Alaska. The subject of
this hearing is going to be the following:
The EPA's Draft Environmental Impact Statement for the
project, the Draft, National Pollutant Discharge Elmination
System permit, I'll call it the water discharge permit; State
Certification regarding water quality standards under Section 401
of the Clean Water Act; the Corps of Engineers dredge and fill
permit under Section 404 of the Clean Water Act; and finally
EPA's preliminary determination regarding the Prevention of
Significant Deterioration air permit under the Clean Air Act.
For the purpose of this combined hearing, what we are
going to be doing is reviewing the project as a whole and pro-
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viding you with an update of all the information that we have
available at this time.
I'd like to make it clear from the beginning that even
though there will be a number of people talking, the hearing is
being conducted by EPA and I'll be conducting it on behalf of
EPA.
As Hearing Officer, I'd like to establish some ground
rules as to how we're going to be conducting this evening's
hearing and also establish an agenda to let you know how I
would like to have the hearing progress this evening.
The public hearing is for the purpose of allowing the
citizens to comment on EPA's proposed Draft Environmental Impact
Statement and the other permits I have mentioned. All of these
permits and the DEIS regard the proposed ALPETCO Refinery and
Petrochemical Facility to be sited in Valdez. The Draft
Environmental Impact Statement was prepared under the authority
of the National Environmental Policy Act which requires federal
agencies to prepare the Environmental Impact Statement when
they are going to be involved in major actions that signficantly
affects the quality of the human environment.
The federal action in this case is the issuance of an
NPDES, or water discharge permit to ALPETCO under the Clean
Water Act. ALPETCO submitted an application on September 12,
1978 to EPA for a water discharge permit for the proposed
refinery and based on a review of information submitted with the
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application, EPA determined the facility would be a new source
of discharge and would likely have significant impact on the
environment and, therefore, prepared an Environmental Impact
Statement. At the request of EPA, the Corps of Engineers be-
came a cooperating agency for the purposes of developing the
EIS and in the NEPA process.
EPA's alternatives in this case are limited to issuing the
NPDES permit, the denying it, or to issuing it with certain
conditions. The Draft NPDES permit for this facility contains
several conditions which directly are related to the waste water
discharge, including a long term monitoring program. Neverthe-
less, EPA will consider the complete range of environmental
impacts in acting on this application and will not make a final
decision until the NEPA process, or the National Environmental
Policy Act process has been completed. The process involves
three stages from this point forward. First, a review by EPA
of the comments received on the Draft Environmental Impact
Statement, both at this public hearing and the other public
hearings we've held, and any write-ins, which you or others wish
to sbumit after this hearing tonight. Then we're going to be
preparing a final Environmental Impact Statement, which will
respond to those comments and finally, a thirty-day comment
period following publication of the final Environmental Impact
Statement.
For those who wish to testify at this hearing, we've
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encouraged participation by providing the Draft Environmental
Impact Statement and the Draft NPDES permit, on file in Anchorage
Juneau and Valdez since December 7th, 1979. Copies of EPA's
Statement can also be obtained, for those of you who would like
to receive one, by writing to our Environmental Evaluation
Branch or by asking to have a copy to review at this hearing,
several copies are available, is that correct?
MS DEBORAH KIRK: Yes, they might be in Mike's office but
they're in town.
MR. DU BEY: The PSD permit application, or the Prevention
of Significant Deterioration permit, that's the air permit that's
required for this project, has been available in Anchorage,
Juneau, Valdez and Fairbanks since December 18th, 1979, and the
preliminary determination has been available at the same
locations since January 14th, 1980.
Persons who are unable to testify at the hearing this
evening, or wish to furnish comments after the hearing, may do
so by writing to Miss Deborah Kirk at the Environmental
Evaluation Branch at EPA's Regional Headquarters in Seattle.
Anyone interested in the address, I'll be glad to furnish it to
you either during a break or at the conclusion of the hearing.
The deadline for comments on both documents is February 16, 1980.
I'd like to mention at this time that we're going to have a
question and answer period at the third stage of this hearing
and anyone who has a question I'd like them to direct it at me
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and I will then assign the proper person to answer the question
for you.
Next, I'd like to give you an agenda of how I would like
to conduct the hearing. First, we will provide you with some
background information from the members of the panel who have
been involved since the beginning of the Statement, in developing
the EIS from the various comments. Secondly, soliciting comments
by those of you here who wish to make them and thirdly, having
a question and answer period where it will be rather free-form,
if anyone has a question they would like to ask, we'll try to
answer it for them.
The various participants I've already introduced to you.
If anyone has to leave early, if they can either let me or
Deborah Kirk know, we will arrange to have you speak early so
you will be able to participate here.
The other thing I'd like to mention is the people who
are available to respond to your questions, Mr. John Paulson,
who is the consultant to EPA on the Environmental Impact State-
ment and Mr. Ron Dagon representing ALPETCO are also here this
evening, so if you have any questions you would like them to
respond to, they are likewise available.
As Hearing Officer, I reserve the right to limit the
questioning, call recesses and adjourn and reconvene the hearing.
Since this is an informal hearing, there will be no cross-
examination . I would ask that presentations be limited to ten
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or fifteen minutes. If anyone wants to continue beyond ten or
fifteen minutes, you may do so at the end of the hearing so
others will have a chance to speak also. If anyone has any
written material, and you are under no obligation to prepare
any, we'd be glad to receive it and enter it into the record.
Written comments will be received after this hearing, as I
mentioned before, by February 16th, 1980.
We also anticipate that the final Environmental Impact
Statement, which will follow a review of the comments which you
provide to us, is going to be released about May of 1980.
The record of this hearing is being made by a court
reporter, Ms Nancy Glassman and, therefore, I'd ask you to
state your name and address and affiliation, if any, when you
come and make your statement so we will be able to have a
record reflect your remarks.
We also intend to make the transcript of this hearing
this evening available for your review at EPA's Alaska
Operations Office in Anchorage and at the Public Libraries in
Fairbanks, Juneau and here in Valdez.
Any questions or comments about the procedures? (No
response) Okay, well why don't we go right into the background
information and I'll ask Deborah Kirk to talk about the
Environmental Impact Statement.
MS DEBORAH KIRK: I work for the Environmental Protection
Agency in their Seattle Regional office. I am going to present
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a brief overview of some of the findings of the EIS that's been
prepared during the past year. Since there can be many
potential impacts from a proposal of this type, during the
process of preparing the EIS, many state, federal and local
agencies, as well as the public, helped us to identify and
evaluate the potential impacts. The major environmental con-
siderations that I'm going to summarize, they are by no means
all of the ones that we studied, are as follows: site alterna-
tives, geological hazards, solid wastes, biological impacts,
spill prevention and control, marine transportation and socio-
economic considerations.
^LPETCO carefully studied other potential Alaska sites
during the State mandated site selection process before selecting
Valdez. Valdez was chosen primarily due to community support,
proximity to crude oil supplies and presence of a deep water
port. Further, there was no evidence of insurmountable environ-
mental problems and the existing local public services and
facilities were thought to be adequate to accommodate the
anticipated growth.
In an area which is seismically active, as this area is,
extensive soils and seismic studies were a necessity. It has
been determined that the affected soils should generally present
no construction problems. There is no permafrost in the area
and the site has low potential for frost heave. It is going to
be necessary to perform a ground motion analysis in designing
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the individual components of the facility to allow for seismicall?
induced out of phase motion. Based on the studies undertaken
during this past year, there is no evidence that it would be
inadvisable or unsafe to build a refinery at this location using
known engineering and construction techniques.
Considerable volumes of both hazardous and nonhazardous
solid wastes would be generated by this facility. There are no
designated treatment or storage sites for hazardous wastes in
Alaska. Therefore, all wastes classified as hazardous would be
shipped to approved disposal sites in the lower forty-eight.
There are existing Federal regulations, primarily Transportation
regulations, which govern the safe transport of such materials.
In addition, the on-site, short-term storage area can be
designed to prevent contamination of land or water resources
in the event of a spill. Nonhazardous wastes, such as solid
refuese and some of the sludges, would be incinerated on-site
with ash disposal in the city landfill. Valdez is currently in
the process of upgrading their landfill facilities, with this
project in mind, and anticipates no problem accommodating
wastes from the proposed facility.
Maintenance of fish spawning areas is the major fresh-
water concern in this area. There are many spawning streams at
the east end of Port Valdez, however, most of these streams
would not be directly affected by this project due to their
distance from the site. The only spawning system in the area
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directly affected by the project is the Robe Lake system. As a
result of concern expressed over this resource, design changes
in plant layout have already occurred, such as eliminating the
tank farm from this system's drainage area. Currently, the
only surface disturbance to the Robe Lake drainage would be the
buried product pipeline bundle and accompanying access road
which transports the refinery products to the product dock. Con-
struction practices exist which could minimize impacts on the
resource. Construction can also be carried out during times of
the year when the impact on the resource would be minimal. There
is also a salmon spawning creek within a thousand feet of the
proposed product dock. The design of the product dock was
undertaken to produce minimal impacts during both construction
and operation. Construction can occur during those seasons when
potential impacts on the fishery resources are few. Operation
of the dock, including implementation of appropriate spill pre-
vention measures, would not present a significant disturbance
to the locality.
Spill prevention and control is one of the basic
Objectives of the design and operation of the proposed facility.
Among specific design parameters are: containment dikes around
all feedstock and product tankage; ability to treat contaminated
storm water in the wastewater treatment facility; containment of
storm water from the process areas; leak detection for the pipe-
line system and appropriate use of valves to minimize potential
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spill volumes. Such measures will protect both the surface and
ground water from contamination and hence would minimize the
risk of indirect impacts on other elements of the ecosystem.
Prior to operation, ALPETCO would be required by the State of
Alaska, to prepare a spill prevention and control plan and an
oil spill contingency plan. Such plans would be consistent with
those in force at the Alyeska pipeline terminal facility and
would be based in part on experiences acquired at that facility.
As a result of the proposal, there would be an increase
in tanker traffic through Prince William Sound and Port Valdez.
One additional vessel, ranging in size from ten to eighty
thousand dead weight tons, would enter Port Valdez approxi-
mately every other day. The Coast Guard operates a vessel
tracking system in Port Valdez, and indicates their existing
system can ea.-ily handle the increase in traffic projected by
the project. The risk of tanker accidents transiting the area
is considered low because of the Coast Guard system.
At the present time, the City of Valdez is uniquely
suited to handle the impacts caused by a large construction
force and a smaller permanent work force. The city has grown
and changed a great deal during the pipeline days. Many of the
existing services, such as fire and police, are already
sufficient to accommodate the expected short and long term
growth. Some facilities, such as schools, sewage and solid
waste facilities, are already being upgraded by the city, with
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this project in mind. The city is currently developing a
comprehensive plan, to be completed this year, which should
provide adequate guides and safeguards for the growth antici-
pated by this proposal. The city, having gained experience with
the Trans Alaska pipeline project, has a good idea of the types
of problems to expect and is currently building on that
experience. It's working very hard to anticipate the needs and
impacts of this proposal and it is capable of handling the
financial loads of the planning studies and of facility up-
grading. The City of Valdez has stated that it will not require
additional State or Federal governmental financial support.
Many, there were many other studies and other types of
impacts evaluated during the past year that are discussed in
detail in either the EIS or the Technical Analysis. I haven't
even tried to give you a list of all the things that we've looked
at. All I've tried to do here tonight is give you a brief
summary of the major elements of the environment affected by
this proposal. Further details on some of these other impacts
can be found in the EIS. There's a table at the entrance to
the room and we have cards on it that you can sign in on so that
we can keep track of who attended this hearing.
At this time, I'd like to let Mr. Bill Lamoreaux speak
on the NPDES permit.
MR. BILL LAMOREAUX; Good evening. My name is Bill
Lamoreaux and I'm employed as an Environmental Engineer in the
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Alaska Operations Office of the Environmental Protection Agency.
Our office is located in Anchorage in the new Federal Building.
It is my intention to explain the rational used in developing
the draft permit called the National Pollutant Discharge
Elimination System permit, and I'll refer to it as the NPDES
permit. Helping me will be personnel from the State of Alaska
Department of Environmental Conservation who jointly share an
active role in the permitting process.
The draft NPDES permit is based on requirements of the
Clean Water Act as amended in 1977. This Act stipulates certain
levels of treatment technology to be applied as a minimum to all
point source discharges of waste water. As written, the Act
requires that new discharges, such as ALPETCO, that New Source
Performance Standards, as promulgated by EPA, be imposed. It is
important to remember that these standards are really tech-
nology related standards and do not necessarily relate to
potential water quality impacts. Also, however, the Clean Water
Act requires that discharges be controlled sufficient to protect
the receiving water from adverse impacts and further, that the
State of Alaska have the opportunity to review and certify all
EPA issued permits to the extent that the discharge will not
violate existing State statutes, including the State of Alaska
Water Quality Standards.
To accomplish this end, we have deliberately coordinated
all aspects of the permit preparation process with the Alaska
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Department of Environmental Conservation personnel and now
believe we have a draft permit that meets both of the major
criteria, the achievement of current New Source Performance
Standards, and compliance with the State of Alaska Water Quality
Standards.
I would like to briefly outline the structure of the
proposed discharge permit, as well as explain the critical
elements which relate to EPA's New Source Performance Standards.
Following this, Joyce Bealman of the Alaska Department of
Environmental Conservation, will outline permit conditions which
relate to limits for protection of water standards and elements
of a long term biological monitoring study designed to measure
any possible, effects of the discharge upon the marine environ-
ment.
To begin with, the permit addresses several different
major areas. These are:
Discharge effluent limitations.
Effluent monitoring and reporting requirements.
Outfall discharge requirements.
Outfall diffusion study requirements.
Receiving water monitoring study, and
Other general conditions common to all NPDES permits.
Rather than go into a lengthy discussion of the general
permit conditions, I would rather just refer to the draft permit
and mention that these conditions cover such factors as non-
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compliance reporting, right of entery, bypass, upsets, civil and
criminal liability, oil and hazardous substance liability, to
name just a few.
The majority of the effluent limits contained on pages
2, 3, 5 and 6 of the permit are based on promulgated New Source
Performance Standards. These standards establish allowable
effluent limits for certain pollutants based on production
levels and process configuration. For example, the allowable
effluent limit for oil and grease from the process waste stream
is three hundred and thirty pounds average and six hundred and
ten pounds maximum per day. The product level assumed in
these calculations are a hundred and sixty-one thousand, four
hundred and forty barrels per day throughout. Additional dis-
charge allowances are allowed for the separate sources of
ballast water and storm water runoff from process areas. These
extra allowances are also a reflection of the same New Source
Performance Standards with the exception of the oil and grease
limits for ballast water, which is stipulated at the tighter
effluent limits currently being achieved for ballast water by
Alyeska Pipeline Service Company located here in Valdez.
Two parameters in the effluent waste stream are limited
because of possible impacts on the receiving water, Port Valdez
in this case, outside of a defined mixing zone. The effluent
parameters of aromatic hydrocarbons and cyanide are limited to
levels which after achieving a seventy-five to one dilution,
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should be capable of meeting State Water Quality Standards. For
a more detailed explanation of the effluent limits and their
determination, I would like to reference you to the draft permit
and fact sheet, which are contained in the draft EIS document.
ALPETCO will be allowed a mixing zone which is defined
on pages 7 and 8 of the draft permit. This is a relatively small
area, roughly allowing a hundred and fifty meters from the end
and sides of the diffuser pipe. This mixing area will be, will
allow the discharge plume to achieve its optimum dilution prior
to stratifying. Outside of the mixing zone, water quality
standards must be met and maintained. Doug Redburn will discuss
the more significant water quality standards following my
discussion.
It is a requirement that the diffuser system achieve a
minimum dilution ratio of seventy-five to one at all points
outside the mixing zone. ALPETCO will be required to submit a
design report on the diffuser at least six months prior to
diffuser construction to EPA and ADEC for approval before con-
struction can commence. If the seventy-five to one dilution
rate cannot be met, ALPETCO can request a reduction to the
dilution rate upon a showing that certain sensitive effluent
parameters, for example, aromatic hydrocarbons and cyanide, are
correspondingly reduced in the effluents such that the concen-
tration of the parameters at the edge of the mixing zone does
not exceed those levels necessary to meet Alaska water standards.
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A significant aspect of the permit is the extensive
effluent monitoring. The permittee is required to monitor all
effluent limit parameters except nickel and aromatic hydro-
carbons, daily. Nickel and aromatic hydrocarbons are to be
monitored twice weekly. Besides these parameters, however,
the permittee will be required to monitor an additional
seventeen parameters on a monthly or quarterly basis. Mostly,
these parameters are those listed on EPA's toxic list and have
been found in the effluents of similar refineries around the
country, but have not as yet been listed or limited in the
EPA's New Source Performance Standards for refinery complexes.
I have provided just a very brief overview of certain
elements of the draft NPDES permit. Joyce Bealman from the
Alaska Department of Environmental Conservation is here tonight
and will provide some explanation of effluent limited receiving
water parameters contained in the permit necessary to protect
Alaska Water Standards, as well as a comprehensive biological
monitoring study in Port Valdez to evaluate subtle impacts
caused by the discharge of waste waters to Port Valdez. This
work, biological work, was primarily a product of Doug Redburn
of the Department of Environmental Conservation. I worked with
him extensively throughout the drafting process. He is located
in their Juneau office and is unable to be here tonight. Once
aqain, I encouraqe you to read the draft permit, and especially
the fact sheet, for a better understanding of the rational used
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in preparinq this permit. Thank you.
HEARING OFFICER: Joyce?
MS JOYCE BEALMAN: Thank you. As you've heard, I'm Joyce
Bealman with the Department of Environmental Conservation here
in Valdez and I'm going to be using the testimony that was given
in Anchorage by Doug Redburn who works along with EPA in drafting,
in the department's drafting of conditions for the receiving
water monitoring program outlined in Section E.2 of the draft
NPDES permit for the ALPETCO facility. So the following is his
testimony.
Our department is responsible for establishing and en-
forcing water quality standards for all State waters. Standards
of particular importance in this permit are aromatic hydrocarbons,
cyanide, several potentially toxic heavy metals, pH and
suspended sediments. Aromatic hydrocarbons shall not exceed
ten micrograms per liter in the water or cause deleterious
effects to biota in sediments; toxic substances shall not
exceed zero point zero one LC^q of the most sensitive life
stage identified by DEC in the area. Suspended sediments shall
not exceed ambient levels at the boundary of the mixing zone.
The purpose of the receiving water monitoring program is to
insure that our standards are maintained outside of the mixing
zone and that the components of the effluent, individually or
collectively, do not cause significant alterations in the
chemical and biological environment.
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The development of the proposed monitoring program was
based on five principles:
First, a desire to detect any subtle changes in water
quality and evaluate the type and magnitude of any sublethal
responses of key indicator species chronically exposed to low
levels of aromatic hydrocarbons and heavy metals.
Second, to develop the capability to detect and to
evaluate gradients in responses of organisms at varying
distances for the diffuser.
Third, to utilize the information from previous marine
reconnaissance studies in Port Valdez as an aid in selecting
representative stations, and subsequently, in developing a
more cost effective monitoring program.
Fourth, to provide for adequate chemical characteriza-
tion of the sedimentary environment in conjunction with bio-
logical sampling, emphasizing compounds with long residence
times such as substituted naphthalenes and polynuclear aromatic
hydrocarbons.
Fifth, to provide an improved statistical basis for
detecting change by adopting a program of rigorous sampling at
a few representative stations rather than broad reconnaissance
at numerous stations throughout the Port.
In developing the specific tasks of the monitoring
program, which I shall discuss shortly, the department has bene
fited greatly from previous marine studies in Port Valdez, most
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notably the preliminary biological investigations of Dames
and Moore for the ALPETCO project and those of the Institute
of Marine Science conducted to fulfill the monitoring require-
ments of the ALYESKA ballast water discharge permit. These
sampling efforts have isolated certain biological assemblages
or station groupings that share several common affinities and
have guided us in selecting a few representative stations
within these groupings for comprehensive followup.
The IMS studies, in pointing to the apparent basence of
any detectable changes, on a gross, short term level, in com-
munity structure and biomass, suggested that gross community
changes should be deemphasized in lieu of detecting subtle
changes on the individual species level. For this reason,
sampling stations in this permit are located as near the
diffuser outfall as practicable and address subtidal and inter-
tidal indicator species, keying on major life history events,
gametogenesis, spawning periods, growth, while retaining basic
abundance and zonation studies.
With these concepts in mind, the department has en-
deavored to establish a statistically supportable monitoring
program providing the maximum amount of information for the
money. The program is designed primarily to provide evidence of
any subtle variations in normal species life history functions,
be it changes in fecundity, growth, or spawning periodicity of
major invertebrates, as a function of distance from the
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proposed diffuser. The community studies should provide ample
basis for detecting any major changes in community structure.
The sampling stations are located on the assumption that the
outfall location as proposed in the DEIS will be the ultimate
location.
The monitoring program consists of six main elements:
One, abundance and zonation studies conducted three
times per year at three permanently established muddy inter-
tidal transects, both adjacent and distant from the outfall;
Two, shallow subtidal extensions of these stations, to
be occupied at the same frequency;
Three, benthic studies at five stations in the far
eastern Port with eight replicate grabs per station;
Fourth, studies of key biological events in the life
histories of selected intertidal and subtidal indicator species,
including reproductive phenology and seasonal and annual
growth;
Fifth, hydrocarbon and heavy metal characterization of
sediments, water and biota at all biological sampling stations
plus a suite of stations very near the diffuser;
Sixth, assessing the condition index or condition factor
of two common bivalve species, one found intertidally and
another subtidally.
This later concept in pollution monitoring is a measure
of an organism's overall physiological fitness and is defined
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as the ratio of the organism's dry weight divided by its shell
volume. The index has been used successflly by several re-
searchers in controlled, long term experiments to evaluate
organism response to hydrocarbon stress. We have chosen to
apply this relatively inexpensive approach as part of our over-
all monitoring strategy.
And that's the testimony of Doug Redburn last night in
Anchorage.
MR. MICHAEL JOHNSTON; Good evening. My name is Michael
Johnston and I am Chief of the New Source Permit section with
Region 10 of the Environmental Protection Agency. I am here
tonight to discuss the Prevention of Significant Deterioration
requirements for the ALPETCO project.
Before I discuss the project itself, some background re-
garding the Prevention of Significant Deterioration program might
be helpful. Because the term Prevention of Significant
Deterioration is so cumbersome, I will refer to that term by
use of its initials, PSD.
The first PSD program was established by EPA in 1974 as
a result of court action and addressed only nineteen specific
source categories. In the Clean Air Act amendments of 1977,
Congress expanded on EPA's effort outlining detailed programs
that address all major construction or modification projects
that are potential air pollutant emitters.
In order to understand the PSD program, one must first
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understand the concept of the PSD increment. Under existing
regulations, the baseline, or reference date for calculating
increment consumption, is August 7, 1977. The baseline air
quality is the existing air quality in the proposed construction
area as of that date. The PSD increment is simply the amount of
air quality degradation allowed beyond the baseline air quality.
The increment is expressed in terms of micrograms of pollutants
per cubic meter of ambient air.
I've got a diagram up here that might be of some help in
understanding what the basic program is all about. This axis
is air quality, and as I said, it's measured in micrograms per
cubic meter of ambient air. The baseline air quality is the air
quality as of the baseline date, or August 7. The PSD increment
describes the amount of degradation allowed by the Clean Air
Act. This baseline air quality may change, or may be different
in different areas, depending on the amount of development that
occurs in any given area. In no case is this allowed degradation
to go above the National Ambient Air Quality Standards, this is
the top level. The whole purpose of the PSD program is
basically keep clean areas clean without totally restricting
growth.
Before a major new source construction or modification
can take place, a PSD permit must be obtained. In order to
obtain this permit, an applicant must make three demonstrations:
One, the source will incorporate state-of-the-art air
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pollution control technology taking into account energy,
economics and the environment. This level of technology is
termed Best Available Control Technology, or BACT.
Two, the source will not cause a violation of the PSD
increment.
Three, the source will not cause or contribute to a
violation of a National Ambient Air Quality Standard. These
are the approval criteria. In addition, the PSD regulations
require a public disclosure of the effect of the project on soils
vegetation and visibility.
Let me expand a bit on the primary criteria for approval.
The procedure for determining Best Available Control
Technology is relatively straightforward. Control equipment and
j operating experience from similar facilities recently built in
other parts of the country were analyzed to determine the
control systems which result in the lowest reasonable emissions
from the various emission points.
In order to determine the impact of the proposed source
on the National Ambient Air Quality Standards and the PSD in-
crements, atmospheric diffusion modeling must be conducted.
Existing monitoring for both the meteorological conditions and
existing pollutant levels. Then, projected pollution emission
rates from the proposed source's emission points, as controlled
by Best Available Control Technology, are input into a computer
simulation model that predicts the impact of the source on air
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quality in the area under various meteorological conditions
defined by the monitoring effort, and various plant operating
conditions. If the project impacts do not exceed the PSD in-
crements, if these impacts, when added to the existing pollutant
levels, do not cause violations of any National Ambient Air
Quality Standard, and if the source will install the Best
Available Control Technology, a PSD construction and operating
permit can be issued.
In order to minimize the amount of time and money needed
to fulfill the air quality impact analysis requirements, an
escalation process has been developed. Screening techniques
are used first to predict project impacts. These techniques
are quite simple and assume worst case conditions resulting in
very conservative results. If these techniques show a threat
to the PSD increments or national standards, more refined
techniques are utilized in making impact predictions. The only
standard EPA approved technique available for predicting air
quality impacts of a source locating in complex terrain is the
Valley model. In the case of ALPETCO, this conservative tech-
nique showed violations of PSD increments. Because the Valley
model is a conservative screening technique, a more refined
hybrid model was developed using two models designated in EPA's
document, Guideline on Air Quality Models. This hybrid model
and its application to the Valdez situation was reviewed by EPA
regional and national experts in the field of air quality
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modeling and determined to be appropriate for this application.
In addition to such review, the Clean Air Act requires that any
alteration of a guideline model be made available for public
comment. A detailed description of the hybrid model is avail-
able in the Technical Analysis document, part of the Preliminary
Determination available at the Public Inspection locations. I
have a few copies of the Technical Analysis document here
tonight as well.
On October 8, 1979, EPA received a PSD application for
the ALPETCO project. This initial application was supplemented
on November 2 3rd, December 4th, and December 11th, 1979, with
additional information requested by EPA. The ALPETCO refinery
is subject to PSD review for emissions of sulfur dioxide,
nitrogen oxides, particulate matter, carbon monoxide and hydro-
carbons. After a detailed review of ALPETCO's application, EPA
determined that the company proposed to install BACT for all
emission points except for fluid catalytic cracking unit. We
have determined that a lower sulfur dioxide emission rate than
that proposed by ALPETCO is reasonably achievable and have
imposed this as a condition of our tentative approval of the
ALPETCO project. A detailed ambient air quality impact
analysis was also conducted. Air quality and meteorological
monitoring was conducted at two locations near the plant site
specifically for this project. In addition, data was obtained
from four existing sites in the Valdez area. Refinery emissions
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data and area wide meteorological data were used with a
mathematical model to predict the ambient air quality impacts
of the ALPETCO project. These projections were then super-
imposed on existing air quality to determine the expected air
quality during refinery operations. With the installation of
Best Available Control Technology, no violations of the PSD in-
crements or National Ambient Air Quality Standards are expected.
It should be noted, however, that for the case of sulfur dioxide,
nearly the entire available PSD increment in the east end of the
Port will be consumed. This will be a consideration for future
growth near the ALPETCO site for sources emitting S02-
The impact of the project on soils and vegetation is not
expected to be significant. There will be a minor impact on
visibility as a result of the project. Two plumes from the
source may be visible due to entrained water vapor. Additionally,
a slight visible plume can be expected from the tankers calling
at the refinery terminal.
As a result of our detailed review,of ALPETCO1s project,
EPA has preliminarily determined that the PSD requirements have
been fulfilled and unless substantive information is offered to
the effect that the refinery should not be built, or that it
should be built differently, EPA intends to issue a PSD permit
for this facility.
Thank you.
CAPTAIN MICHAEL MAHONEY: Hello, my name is Mike Mahoney,
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I work for the Alaska District Corps of Engineers in the
Regulatory Functions Branch. Our offices are located on
Elmendorf Air Force Base, which is just adjacent to Anchorage,
so you can stop in if you have any problems if you get a
chance.
I'm here tonight because the Corps of Engineers is a
cooperating agency with the EPA for the finalization of this
EIS and also because the Corps of Engineers has permit juris-
diction over several portions of the ALPETCO project. My
presentation tonight will touch on three topics.
First, I want to give you a brief overview of the Corps
of Engineers administered Section 10 and Section 404 permit
program. Secondly, I want to explain what our jurisdiction is
in the ALPETCO refinery project, and finally, I'd like to
briefly update where those permit applications are today.
Now first of all, the DA permit program which involves
this project is divided into two areas. We've got Section 10,
which I refer to, Section 10 of the Rivers and Harbors Act of
1899. It charges the Secretary of the Army with insuring that
all structures or work in or affecting navigable waterways of
the United States are in compliance with that law. Now for the
project we're talking about tonight, that includes all of the
work at the tanker facility and all of the work at the temporary
construction dock.
The second portion of our permit program, Section 404 of
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the Federal Water Pollution Control Act of 1972, otherwise known
as the Clean Water Act, now it stipulates that the Secretary of
the Army, through the Corps of Engineers, will regulate the
discharge of dredge or fill materials into waters of the United
States. Now here we have jurisdiction for this project over
the fill activities, over the temporary construction dock, over
the fills that are going to be required for pipes, roadway
crossings at the refinery site, and over use of grout to anchor
piles at the terminal facility, or the tanker facility.
The Corps of Engineers issues permits as specified in
Section 33, Code of Federal Regulations, Part 325. The applicant,
in this case ALPETCO, must first submit an application with a
plan that adequately describes the project, then the Corps of
Engineers issues a public notice to solicit comments from the
general public and from all of the interested agencies. The
Corps of Engineers, you see, is required to conduct what we call
a general public interest review. Nov/ that review involves a
study by the Corps of Engineers, it involves an analysis of all
the comments received from the interested agencies and from
the general republic — excuse me, the general public, and it
involves an analysis of the rebuttal or explanatory comments
authored by the applicant if someone objects to his project.
Now at the end of that public interest review, if the Corps of
Engineers decides to issue a permit, that permit will be subject
to the general permit conditions and we may also make it subject
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to any special provisions which we deem necessary to protect the
environment or any other special interest group.
Now in that regard, public notices were issued on 19
October 1979 to solicit comments for the proposed ALPETCO
refinery facility, they were titled Port Valdez 84 and Port
Valdez 85. The first public notice dealt with the tanker
facility. Now that work includes the loading platforms, the
dolphins, the connecting walkways, pipeways, roadways. We have
Section 10 jurisdiction over all of that work because Port
Valdez is a navigable waterway. We also have Section 404 juris-
diction over the use of grout to anchor any piles of bedrock
where that is needed, now that's because grout is considered
fill material.
The second public notice described the refinery and its
supporting facilities. At the temporary construction dock, we
have Section 10 authority over the fill activity, the dredging,
sheet pile curtain and the concrete ramp. At the same location,
we have Section 404 jurisdiction over the fill activities and
over the placement of wet concrete to form that ramp because
wet concrete, again, is considered fill material.
Now at the refinery site itself, we have Section 404
jurisdiction over all of the fills which are used to take the
road or a pipeline across a stream or wet land in that area.
Now we usually have a thirty-day comment period on
public notices. That thirty-day period for each of these public
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notices has been extended to allow for completion of the EIS. We
have received several comments from folks just like you who are
interested in the project and a couple of the agencies have
finalized their comments. Most of the agencies have opted to
wait until the EIS procedure is finalized before commenting.
Now when the final EIS is published and all the required comments
received, the Corps of Engineers will make its final determina-
tion in this case. If any and all objections we have received
have been adequately resolved at that time, the permit should be
issued within fifteen days. If there are still outstanding,
unresolved objections, the permit will not be issued until the
District Engineer is certain that this project is in the
general public interest.
Now that, admittedly, is a very brief explanation of what
the Corps of Engineers'involvement in this project has been. I
brought some pamphlets with me which further explain the Corps
of Engineers permit program if any of you are interested.
I'd like to thank the EPA for the opportunity to speak
before you folks tonight and I'd like /to thank you for your
attentivness during my presentation.
MR. DU BEY: Thank you, Mike. We have received one
request to make a presentation at the completion of our presen-
tation to provide you with background information. Is there
anyone else who would like to make a presentation? (No response)
Okay, let me call upon, then, Mayor Walker to come forward,
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please, and make his presentation.
MAYOR BILL WALKER: Good evening. My name is Bill Walker,
Mayor of Valdez. On behalf of the City, I would like to welcome
you to Valdez and thank you for giving us the opportunity to
partake of the information you've given us this evening.
A little background, I have no written formal statement,
but a little history on the support of the City of Valdez on
this project.
We became interested in the project when the Royalty Oil
Board began having hearings throughout the State. We invited
them to come to Valdez, they had one of their meetings here and
following that, we kept track of each hearing and tried to be
present at those hearings. Now when they selected, in Juneau,
one of the seven companies who received the royalty oils, we
began to seek their admittance of Valdez as the site selection.
Just prior to our becoming extremely aggressive in this path, we
took a public opinion poll, and that was conducted over a period
of several weekends in one of our local grocery stores who
volunteered any help with the ballots, asking them if they were
for such progress or not. The results of that poll were over-
whelming, five to one, in support of this project. Based on
that support, the City of Valdez became very aggressive in
bringing ALPETCO to Valdez. There was a lot of competition and
it was through the efforts of the entire City of Valdez behind
this project to do it. I don't think you could find a
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community more aggressively supporting this project or any
project such as this.
That pretty well summs up my comments. I just wanted to
be sure that it was in the record that the City of Valdez is
very much in support of this project.
Thank you.
MR. DU BEY: Is there anyone else who would like to make
a statement at this time? (No responde) Okay, I see no hands,
so if that's the case, I suggest we take a five minute break
and then have a question and answer period. We'll go on break
for five minutes.
(The hearing recessed at 8:30 p.m. and reconvened
at 8:40 p.m.)
MR. DU BEY: Okay, we are back on the record. The third
phase of our hearing will be the question and answer period and
the panel is eager if you have questions or if you would like
anything clarified that wasn't made clear, or any other questions
you might have. Who's going to ask the first question?
MR. RON DAGON: Mr. Du Bey, I've been negligent. We have
two people from ALPETCO here tonight that some people don't
know and I'd like to introduce them.
MR. DU BEY: Okay, let me ask the question. Is there
anyone else here from ALPETCO?
(Laughter)
MR. DICK BARNES: My name is Dick Barnes, I'm Vice
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©
President for Alaska Operations and I'm based in Anchorage. Jack
Sedwick is Special Counsel for the project and he's with Burr,
Pease and Kurtz.
MR. RON DAGON: Thank you.
MR. DU BEY; You're welcome. Anybody have any other
questions? (No response) Any statements? (No respone) Okay,
I see no hands. If that's the case then our hearing is
adjounred.
(The hearing adjourned at 8:43 p.m.)
-37- 328
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This Environmental Impact Statement has been prepared by CCC/HOK-DOWL performing
as a third-party consultant to EPA. CCC/HOK-DOWL is an association of two
Anchorage, Alaska, consulting firms, DOWL Engineers and CCC/HOK Architects and
Planners. Under the management of CCC/HOK-DOWL, a multidisciplinary team of
specialists was assembled to perform the work. Following is a list of the firms
and persons of primary responsibility engaged in preparation of the EIS. Brief
biographies of Corps of Engineers personnel follow this list. Biographical
sketches of other preparers appear in Attachment A, which was released with the
Draft EIS.
EPA REGION 10 - LEAD AGENCY
1200 Sixth Avenue
Seattle, WA 98101
Deborah K. Kirk, Project Officer
Daniel I. Steinborn, Energy Coordinator
Alexandra Smith, Acting Division Director, Air
& Hazardous Materials Division
Lloyd Reed, Division Director, Enforcement
Mike Johnston, Chief, New Source Permits Section
Sylvia Kawabata, NPDES Coordinator
Lee Marshall, PSD Coordinator
Robert G. Courson, Chief, Technical Support Branch
Robert B. Wilson, Regional Meteorologist
Paul Boys, Chemical Engineer, Air Surveillance Section
John R. Yearsley, Environmental Engineer
William H. Lamoreaux, Industrial NPDES permit
coordinator, Alaska Operations Office
William B. Lawrence, Corps of Engineers coordination,
Alaska Operations Office
Deborah Yamamoto, Noise Program
329
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CORPS OF ENGINEERS, ALASKA DISTRICT - COOPERATING AGENCY
P. 0. Box 7002
Anchorage, AK 99510
Benjamin B. Kutscheid, Ecologist
Philip J. Brna, Forester
Evelyn J. Elder, Fisheries Biologist
Richard J. Gutleber, Biologist
CCC/HOK-DOWL - MANAGEMENT STAFF
4040 B Street
Anchorage, AK 99503
Lewis E. Dickinson, Partner, DOWL
Edwin B. Crittenden, Senior Officer, CCC/H0K
John E. Paulson, Project Manager
Kenneth E. Stroh, Project Coordinator
Priscilla Post Wohl, Assistant Coordinator
Vicky N. Sterling, Technical Writer/Editor
Roberta E. Goldman, Resource Assistant, Graphic Artist
Alma D. Hartman, Word Processor
William E. Palmer, Draftsman
DOWL ENGINEERS
4040 B Street
Anchorage, AK 99503
Responsibilities: Hydrology, geology, seismology, soils
Harry R. Lee, Geotechnical Engineer
David A. Cole, Jr., Geotechnical Engineer
Toraman Sahin, Hydrologist
Robert W. Kranich, Jr., Hydrologist
Jordan Jacobsen, Geophysical Engineer
Terry L. Barber, Geologist
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CCC/HOK ARCHITECTS & PLANNERS
801 West Fireweed Lane
Anchorage, AK 99503
Responsibilities: Socioeconomics, transportation
Gordon S. Harrison, Economist
Richard K. Morehouse, Environmental Planner
Steven M. Reiner, Planner
Alan M. Voorhees and Associates, Inc., Special Consultant, Berkeley, CA
Northrim Associates, Special Consultant, Anchorage, AK
ALASKARCTIC
P. 0. Box 397
Fairbanks, AK 99707
Responsibility: Archaeology
Glenn H. Bacon, Archaeologist
ATKINSON, CONWAY, YOUNG, BELL AND GAGNON, INC.
420 L Street, Suite 500
Anchorage, AK 99501
Responsibility: Permits and regulations
John Treptow, Attorney at Law
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DAMES & MOORE
800 Cordova Street
Anchorage, AK 99501
Responsibilities: Ecosystems, air quality
James B. Hemming, Arctic Biologist
Charles B. Fahl, Meteorologist
METCALF & EDDY, INC.
50 Staniford Street
Boston, MA 02114
Responsibility: Oceanography
Jekabs P. Vittands, Vice President
David R. Bingham, Hydrodynamic Engineer
Joseph Colonell, Special Consultant, Institute of Marine Science, University
of Alaska
Donald R. F. Harleman, Special Consultant, Massachusetts Institute of Technology
E. Eric Adams, Special Consultant, Massachusetts Institute of Technology
Miles 0. Hayes, Special Consultant, Research Planning Institute, Inc., South
Carolina
THE PACE COMPANY CONSULTANTS AND ENGINEERS, INC.
5251 Westheimer
Houston, TX 77052
Responsibilities: Plant processes, wastewater treatment, marine transportation
Douglas L. Burton, Vice President, Engineering Services
F. Paul Pizzi, Project Manager, Environmental Management Services
Peter E. Kelly, Manager, Process Design Services
Richard F. Smullen, Senior Consultant, Environmental Management Services
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TOWNE, RICHARDS AND CHAUDIERE, INC.
105 NE 56th Street
Seattle, WA 98105
Responsibility: Acoustics
Robin M. Towne, President
Jan Hauge, Acoustical Engineer
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CORP OF ENGINEERS PERSONNEL
Benjamin B. Kutscheid - Ecologist
Expertise: Wetland ecology, environmental assessment
Experience: Nine years as biologist/ecologist for the Corps of Engineers in
Alaska, North Carolina, Virginia, West Virginia, Ohio and Kentucky. Involvement
in EIS preparation, vegetation mapping, wetland evaluation, environmental plan-
ning. One year as Planning Associate with the Board of Engineers for Rivers and
Harbors; two years on the Illinois Natural History Survey.
Philip J. Brna - Forester
Expertise: General biological and ecological analysis
Experience: Two and one-half years in Alaska. Involvement in EIS preparation,
vegetation mapping, wetland evaluation and environmental planning. Environ-
mental Coordinator for the Alaska District.
Evelyn J. Elder - Fisheries Biologist
Expertise: Chemistry, general biology
Experience: Three years with the Alaska District Corps of Engineers, one year
in the Regulatory Functions branch and two years in environmental studies.
Involvement in permit processing, EIS preparation and review, and wetland deter-
minations and evaluations.
Richard J. Gutleber - Biologist
Expertise: Biological applicability under the COE Regulatory Program
Experience: Nine years as biologist with the Corps of Engineers; background
supervisor of field operations for limnological studies of the Great Lakes,
Detroit District; involvement in preparation of environmental statements dealing
with civil works and regulatory projects; team leader of an underwater biologi-
cal investigation team; and preparation of environmental evaluations for the
Section 404 concerns of the Corps' regulatory program.
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y w
q
««r
VII EIS Distribution List
'* --
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EIS DISTRIBUTION LIST
The following list of recipients of the EIS is arranged with federal agencies
first, followed by state agencies, local agencies, and interested groups. A
copy of the Draft EIS was mailed to each of the agencies or groups listed below;
in addition, a copy of the Final EIS automatically will be mailed to each recip-
ient on this list marked with an asterisk.
FEDERAL AGENCIES
U.S. Environmental Protection Agency
Office of Environmental Review EIS Filing Section (A-104) - Washington D.C.*
Oil and Special Materials Division Water Progress Operations (WH-548)*
Office of Public Affairs (A-107)*
Office of Legislation (A-102)
Alaska Operations Office*
Office of Legislation (A-102) Congressional Affairs Division*
Office of Water Programs Operations Water Quality and Nonpoint Source
Division
Office of Enforcement
Region I Regional Administrator, Boston, Massachusetts*
Region II Regional Administrator, New York, New York*
Region III Regional Administrator, Philadelphia, Pennsylvania*
Region IV Regional Administrator, Atlanta, Georgia*
Region V Regional Administrator, Chicago, Illinois*
Region VI Regional Administrator, Dallas, Texas*
Region VII Regional Administrator, Kansas City, Missouri*
Region IX Regional Administrator, San Francisco, California*
U.S. Department of Interior
Office of Environmental Project Review*
Office of Assistant to the Secretary of Interior*
Bureau of Land Management, Alaska Outer Continental Shelf Office, Anchorage
U.S. Fish and Wildlife Service, Anchorage*
Western Alaska Ecological Systems, Anchorage*
Office of Biological Services, Anchorage
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National Park Service, Alaska Area Office
Bureau of Indian Affairs, Juneau, Alaska
Heritage Conservation and Recreation Service, Anchorage
U.S. Geological Survey, Water Resources District, Alaska District
Alaska Resources Library*
U.S. Department of Commerce
National Marine Fisheries Service, Portland, Oregon*
National Oceanic and Atmospheric Administration/National Marine Fisheries
Service, Juneau, Alaska*
National Oceanic and Atmospheric Administration, Anchorage*
National Marine Fisheries Service, Anchorage*
U.S. Department of Housing and Urban Development
Environmental Officer for Community Plan and Management, Seattle, Washington*
Anchorage Area Office, Anchorage
Region X, Office of Community Planning, Seattle, Washington
U.S. Department of Agriculture
Coordinator of Environmental Quality Activities*
Area Conservationist, Bellevue, Washington*
U.S. Forest Service, Director, Juneau, Alaska*
U.S. Department of Transportation
Region X, Seattle, Washington*
Marine Safety Office, Anchorage
Federal Highway Administration, Juneau, Alaska
Federal Aviation Administration, Anchorage
U.S. Coast Guard, 17th Coast Guard District, Juneau, Alaska*
U.S. Department of Defense
Department of the Army, District Corps of Engineers, Anchorage*
Department of the Army, District Corps of Engineers, Seattle, Washington*
Department of the Army, District Corps of Engineers, Bloomington,
North Carolina
Department of the Navy, 13th Naval District, Seattle, Washington
336
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U.S. Department of Energy
U.S. Department of Energy, Washington, D. C.
U.S. Department of Energy, Alaska Regional Office
U.S. Department of Energy, Region X, Regional Representative*
U.S. Department of Health, Education and Welfare
Public Health Service, Davisville, Rhode Island*
Regional Environmental Officer, Seattle, Washington*
Advisory Council on Historic Preservation, Office of Archaeological and
Environmental Preservation, Washington, D.C.*
Council on Environmental Quality, Washington, D.C.*
National Resources Defense Council, Project on Clean Water, Washington, D.C.*
Economic Development Administration, Anchorage
Federal Energy Office, Enviornmental Impact Division*
Federal Maritime Commission, Washington, D.C.
U.S. Legislature
Honorable Ted Stevens, U.S. Senator*
Honorable Donald Young, U.S. Representative*
Honorable Mike Gravel, U.S. Senator*
STATE AGENCIES
Office of the Governor
Honorable Jay S. Hammond, Governor*
State Planning and Research, Juneau*
State Clearinghouse, A-95 Coordinator*
Division of Policy Development and Planning
Alaska Growth Policy Council*
Alaska Oil and Gas Conservation Commission, Anchorage
Department of Commerce and Economic Development, Juneau
Divison of Economic Enterprise, Juneau
Alaska Industrial Development Authority, Juneau
Alaska Pipeline Commission, Anchorage
Division of Energy and Power Development, Anchorage
337
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Department of Community and Regional Affairs
Department of Education, Juneau
Department of Environmental Conservation
Planning and Program Coordinator, Juneau*
South Central Regional Office, Anchorage'*
Prince William Sound Regional Office, Valdez
Department of Fish and Game
South Central Region, Anchorage*
Habitat Protection, Fairbanks*
Glennallen Office*
Department of Health and Social Services, Juneau
Department of Labor, Juneau
Department of Natural Resources
Division of Geological and Geophysical Survey, Anchorage
State Historic Preservation Officer, Anchorage
Department of Revenue
Petroleum Revenue Division
Department of Transportation and Public Facilities
Division of Highways, Juneau
Alaska Energy Allocation Assistance Officer, Anchorage*
Land Use Planning Commission for Alaska, Anchorage
Alaska Fisheries Council, Juneau
338
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LOCAL AGENCIES
Honorable Bill Walker, Mayor of Valdez*
Mark Lewis, Valdez City Manager*
City of Valdez*
Valdez Chamber of Commerce*
City of Cordova
Cordova Chamber of Commerce*
Resource Development Council*
Municipality of Anchorage - Water Department*
INTERESTED GROUPS
AEIDC, University of Alaska, Anchorage*
Alaska Center for the Enviornment, Anchorage*
Alaska Conservation Society, Fairbanks, Alaska*
Alaska Conservation Society, Taku Chapter, Juneau, Alaska*
Alaska League of Women Voters
Alaska Public Interest Research Group, Anchorage*
Alaska Wildlife Federation and Sportsman's Council, Inc., Fairbanks, Alaska
Aleut Corporation, Anchorage*
Anchorage Historical and Fine Arts Museum*
Bradyo Associates Insurance*
Brooks, Woody, Davis California
Calista Corporation, Anchorage*
Center for Urban Affairs, Northwestern University*
Center for Urban Affairs, Evanston, Illinois*
Chevron, U.S.A., San Francisco, California*
CH2M-Hill, Anchorage*
Cole, Hartig, Rhodes, Norman and Mahoney, Anchorage
Colorado State University, Fort Collins, Colorado*
Consolidated Marketing, Inc., Denver, Colorado*
Copper River School District, Glennallan, Alaska
Dames & Moore, Los Angeles, California
Doherty, Mike, Port Angeles,Washington
339
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Doyon Limited, Fairbanks, Alaska*
Energy Impact Associates, Pittsburgh, Pennsylvania
Fairbanks Environmental Center
Farmers Home Administration, Palmer, Alaska
Gorton, Sharl, Sacramento, California
Institute of Marine Science, University of Alaska
Institute of Social and Economic Research, University of Alaska, Fairbanks*
Japanese Government, House of Councillors*
Kinnetics Labs*
KTVS News, Fairbanks
Le Beau, Joseph P., Knik, Alaska*
Lockheed Environmental Services, Anchorage*
Matanuska Electric Association, Inc.*
Mittelhauser Corporation, El Toro, California
National Wildlife Federation*
Oceanographic Institute of Washington*
ORI, Inc., Silver Springs, Maryland*
Ott Water Engineers, Inc., Anchorage
PMEL, Seattle, Washington
Prince William Sound Aquaculture Corporation, Cordova, Alaska*
Resource Development Council, Anchorage*
Rockwell International, Newbury Park, California*
RSKERL, Ada, Oklahoma*
Sierra Club, Alaska Chapter, Anchorage*
Sinnott, Richard*
S. Masuda, Inc.*
Sohio/BP, Anchorage*
Ted Forsi and Associates, Anchorage
Tenneco, Inc., Tennessee Gas Pipeline, Houston, Texas*
Trout Unlimited, Anchorage*
Trustees for Alaska, Anchorage*
University of Alaska, Division of Life Sciences, Fairbanks*
University of California, University Library, Davis
Valdez Fisheries Development Association*
Valdez Vanguard
Washpirg, University of Washington, Seattle, Washington
340
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Washington Archeological Research Center, Washington State University*
William P. Lorentz and Company, Boston, Massachusetts
Wirtz, Jack, Los Angeles, California
Woodward, Hall & Primm*
341
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