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[..] outside of Icecrown until boss 4, 17 and 31 (yes, IC is that big). [..]
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Given the way this is said, it indeed strongly points towards 31 (or more) unique encounters. It seems off that Blizzard would actually count Runemaster, Steelbreaker and Stormcaller as being bosses nr. 6+7+8 in the Ulduar instance (numbers obviously can vary as your killing order may be different). It also would have to imply that encounters 4, 17 and 31 would be single boss encounters, else it would have said "on boss 3+4+5+6" f.e. (should atleast one of those bosses be a multi-boss encounter).
On top of that, I also had the feeling Blizzard wasn't just referring to normal mode (15 encounters) and heroic mode (16 encounters). The quoted line hints more towards the direction that the dk tank would have to wait outside the instance for a long time, only to be taken for very specific fights. I have the feeling Blizzard doesn't quite expect us to clear the heroic mode instance quickly after the release of 3.3, especially (given the way the quote was said) to do these 31 encounters back to back.
Blizzard has made a seperate instance for all-hardmode encounters due to the fact that it removes the limitation on the hardmode of 'having to activate it' (think thorim speed-gauntlet, xt heart killing and others). This gives them alot more space to work with hardmode encounters, and they're now able to completely change an encounter. (Note, we haven't seen a single hardmode of the new kind yet, hence we can only speculate what these will actually add now). I guess it'll come down to the fact whether or not Blizzard actually sees hardmode encounters as a completely new and seperate encounter, rather than a difficulty setting, but still the same encounter.
Edit: Just realised another thing to somewhat counter the 15-normal and 16-hardmode theory. If you want to switch out your dk tank on the fourth encounter (which would be normal), why would you want to keep him in on heroic (which would be the 19th encounter)?