CASE STUDY
Evaluating the EPA NESHAP-OLD Rule at the Valdez Marine Terminal
To help inform the community, a citizens’ advisory council commissioned an independent technical review of emission controls at the Valdez Marine Terminal to assess compliance with new EPA hazardous air pollutant standards.
BACKGROUND
In 2020, the U.S. Environmental Protection Agency updated the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Organic Liquids Distribution (OLD), targeting emissions from crude oil storage tanks. Alyeska Pipeline Service Company, operator of the Valdez Marine Terminal (VMT) in Alaska, challenged the rule, arguing that its existing vapor recovery system already exceeded the EPA’s updated requirements. Specifically, Alyeska claimed its system captured 99.94% of tank vapors—surpassing the EPA’s 95% reduction target.
To assess the validity of Alyeska’s appeal, the Prince William Sound Regional Citizens’ Advisory Council (PWSRCAC) commissioned JBE to conduct an independent technical review. The resulting report supported Alyeska’s position, concluding that the existing controls at VMT were more effective than the alternatives mandated by the revised NESHAP-OLD rule. The Council’s Terminal Operations and Environmental Monitoring Committee sponsored the project, emphasizing the importance of accurate, science-based assessments of hazardous air pollutants (HAPs) like benzene, which pose serious health risks.
OUTCOME AND ADVOCACY
Based on the findings, PWSRCAC voted to support Alyeska’s appeal and submitted a letter to the EPA advocating for reconsideration of the rule’s applicability to VMT. The Council’s stance was grounded in its mission to promote environmentally safe crude oil transportation through Prince William Sound, ensuring that regulatory efforts are both effective and justified by empirical data.
To view Prince William Sound Regional Advisory Council Presentation by JBE - please click here.