1
OVERVIEW OF ENVIRONMENTAL REPORT
FOR COSTCO WHEATON GAS STATION
2
CONCLUSIONS
3
Conclusions
• Based on standard EPA methods, air quality impacts are far
below all EPA National Ambient Air Quality Standards
• Risks are below de minimis levels and far below reporting
levels based on strict California guidelines
• Noise levels are far below County requirements
• Odor issues are not significant
4
Conclusions (Cont.)
• Opponents of the gas station are basing opposition on the
premise that EPA air quality standards are not sufficiently
protective
• Regulatory and land use decisions need to be based on objective
facts and standards
• Absent alternative, defined air quality standards at the County
level, there is no other objective basis to evaluate air quality
impacts other than consideration of published national standards
and accepted guidelines for risk assessment
5
Conclusions (Cont.)
• The impacts from the Costco gas station are low in 2013 when
the station opens, and will be lower over time as enhanced
motor vehicles evaporative and tailpipe controls are further
incorporated into the fleet
• Costco Wheaton gas station is relatively large in terms of sales
but not large in terms of emissions relative to trend lines (see
attached figures)
6
12 M Gallons / year Station with Vent Control at 99.7% in 2013 Similar to Smaller
Stations in 1980s & 1990s and Will Continue to Drop
VOC Emission Rates for Gasoline Station Marketing and
Operations (grams/second) by Year
VOC Emission Rate (g/s)
1.4
1,500,000
1.2
3,000,000
1.0
12,000,000 Wheaton Costo 2013 w/ Arid Permeator
0.8
0.6
0.4
0.2
0.0
1970
1975
1980
1985
1990
1995
2000
2005
2010
2015
2020
1973 - Uncontrolled (Stage I Promulgated), 1975 - Stage I Controls Submerged Filling Widespread, 1983 - Stage I Balanced Submerged
Filling Widespread, 1994 - Stage II in Non-Attainment Areas Promulgated, 2006 - Stage II Widespread and ORVR Technology
Requirement, 2013 - State II/ORVR Incompatibility and Arid Permeator, 2020 - ORVR Technology Widespread, Spillage Reduced, and
Stage II Phased Out
• This graph was based on the best estimate of when a particular emissions control strategies would be fully
enacted, usually after 10 years of having the control technology first promulgated. We took the average of
the original and controlled emission rate for time periods in between the 10 year block just to keep the graphs
smooth and to show that technologies were being phased in over time, which is consistent with EPA methods.
7
12 M Gallons / year Station with Vent Control at 99.7% in 2013 Similar to Smaller
Stations in 1980s & 1990s and Will Continue to Drop
VOC Emission Rates for Gasoline Station Marketing and
Operations (grams/second) by Year
VOC Emission Rate (g/s)
1.4
1,500,000
1.2
3,000,000
1.0
12,000,000 Wheaton Costo 2013 w/ Arid Permeator
0.8
0.6
0.4
0.2
0.0
1970
1975
1980
1985
1990
1995
2000
2005
2010
2015
2020
1973 - Uncontrolled (Stage I Promulgated), 1975 - Stage I Controls Submerged Filling Widespread, 1983 - Stage I Balanced Submerged
Filling Widespread, 1994 - Stage II in Non-Attainment Areas Promulgated, 2006 - Stage II Widespread and ORVR Technology
Requirement, 2013 - State II/ORVR Incompatibility and Arid Permeator, 2020 - ORVR Technology Widespread, Spillage Reduced, and
Stage II Phased Out
Not Unprecedented: VOC emissions gasoline marketing Costco in 2013
Comparable to 1.5 M gal/year in 1987 and 3 M gal/year in 1998
8
12 M Gallons / year Station with Vent Control at 99.7% in 2013 Similar to Smaller
Stations in 1980s & 1990s and Will Continue to Drop
VOC Emission Rates for Gasoline Station Marketing and
Operations (grams/second) by Year
VOC Emission Rate (g/s)
1.4
1,500,000
1.2
3,000,000
1.0
12,000,000 Wheaton Costo 2013 w/ Arid Permeator
0.8
0.6
0.4
0.2
0.0
1970
1975
1980
1985
1990
1995
2000
2005
2010
2015
2020
1973 - Uncontrolled (Stage I Promulgated), 1975 - Stage I Controls Submerged Filling Widespread, 1983 - Stage I Balanced Submerged
Filling Widespread, 1994 - Stage II in Non-Attainment Areas Promulgated, 2006 - Stage II Widespread and ORVR Technology
Requirement, 2013 - State II/ORVR Incompatibility and Arid Permeator, 2020 - ORVR Technology Widespread, Spillage Reduced, and
Stage II Phased Out
Not Unprecedented: VOC emissions gasoline marketing Costco in 2020
Comparable to 1.5 M gal/year in 1997 and 3 M gal/year in 2005
9
Typical Gas Station vs. Costco
10
National Trends in Emissions: Downward
Percent Change in Emissions
1980 vs 2010
1990 vs 2010
2000 vs 2010
Carbon Monoxide (CO)
-71
-60
-44
Lead (Pb)
-97
-60
-33
Nitrogen Oxides (NOx)
-52
-48
-41
Volatile Organic Compounds (VOC)
-63
-52
-35
Direct PM10
-83
-67
-50
Direct PM2.5
---
-55
-55
Sulfur Dioxide (SO2)
-69
-65
-50
Notes:
1. --- Trend data not available
2. Direct PM10 emissions for 1980 are based on data since 1985
3. Negative numbers indicate reductions in emissions
http://www.epa.gov/airtrends/aqtrends.html
11
METHODS AND RESULTS:
ENVIRONMENTAL REPORT FOR COSTCO
WHEATON GAS STATION
12
Overview of Environmental Report
• All air quality impacts are within applicable national and state
standards and guidelines, evaluated:
• Fine particulates (PM2.5)
• Carbon monoxide (CO)
• Nitrogen Dioxide (NO2)
• Volatile Organic Compounds (VOCs)
• Odor and noise impacts minimal
13
Overview
• Submitted initial environmental report: July 2012
• September 2012 met with Kensington Heights consultant: Dr.
Henry Cole
• Developed modified protocol including comments from Dr. Cole
• Final report shows modeling results for Costco sources based on
consensus approach
• Interpretations may differ, but basis for concentrations for modeled
incremental Costco sources are drawn from a common protocol
14
Benefit to Reviewers on Achieving Consensus of
Modeling Methods
• Complex modeling treatments are based on consensus methods
to address incremental Costco sources
• County staff and hearing examiner can focus on interpretation
of results
15
Not Implying Consensus on All Issues
• Differing interpretations of fine particulates can be supported
from common modeling results
• Dr. Cole requested broader scope of modeling other operations
at the mall and beyond - - (but conservatively addressed through
background) - - alternative background treatments can be
considered based on common modeling results
16
Methods
• Air quality analysis
• Noise
• Odors
17
Air Quality Analysis – Refinements After Initial Report July 2012
• Modeled with updated (minute-resolved) meteorological data using EPA
AERMOD software (Dr. Cole Request)
• Also conducted confirmatory modeling with CALPUFF dispersion model to
more explicitly account for terrain effects (Dr. Cole Request)
• Added “major spills” emission category (Dr. Cole request)
• Increased queuing assumptions and degree of conservatism in source based
on resident concerns (Costco refinement)
• Increased conservatism in modeling based on assuming lower surface
roughness conditions (2x increase in conservatism) (Costco refinement)
• Updated vehicle emissions to account more accurately for emissions controls
(Costco refinement)
18
Summary of Conservative Assumptions
• Maximum peak traffic counts were used for all averaging times
(very conservative) - - overstates (applies to Ring Road and
Mall)
• Assumed 90 percent of cars entering mall park at Costco lots
and used peak traffic into mall for all analysis of parking lot
emissions (applies to traffic going South at #16 and #20)
• Used EPA conservative background method of assuming highest
regional value for each averaging time occurs all the time (and
corresponds with every peak modeled value)
• Double counted some sources when modeling roadways and
using conservative background contribution
19
Summary of Conservative Assumptions (Cont.)
• Used very conservative (overstated) background concentrations
(maximum 2009-2011) - - e.g. used 12.1 µg/m3 for annual fine
particulates - -(rather than annual averages per EPA methods)
• As requested, refined annual average fine particulates to 10.8 µg/m3 to
more accurately represent 2013 and beyond - - overly conservative
considering trend lines established by Washington Council of
Governments (Requested by Parks and Planning Staff)
• Increased emission factors from queuing by 2.5-fold versus previous
report to resolve ambiguity (and increase conservatism) (Costco
Refinement)
• Increased queue lengths, which were subsequently confirmed in January
2013 study at comparable Sterling gas station (Costco refinement)
• Increased roughness of surface in model (acts to increase concentrations)
(Costco refinement)
20
Summary of Conservative Assumptions: 90 % of All
Traffic to Mall Assumed to Park in Costco Lots
=((40+185)-48)*0.9
=((79+338)-67)*0.9
Parking Lot Sources
Area Morning Evening Peak Maximum
(m²) Peak Hour
Hour
Peak Hour
Parking
West
25056
159
315
315
Parking Garage Sources
Morning Evening Maximum
Peak Hour Peak Hour Peak Hour
Parking
East
143
=((30+190)-61)*0.9
260
260.10
* Morning and Evening peak hour was determined by 2012
traffic study by taking intersection 16 incoming traffic minus
Costco gas station traffic, then assumed 10% continued on ring
road
* Morning and Evening peak hour was determined by 2012
traffic study by taking intersection 20 incoming traffic minus
Costco gas station traffic, then assumed 10% continued on ring
road
=((312+57)-80)*0.9
• Assumption of 90 percent of cars entering mall parking intersections at Costco lots and
use of peak traffic into mall for all analysis of parking lot emissions were clearly shown
in Emission.xls spreadsheet provided to opposition - - no basis in fact for stating ignored
other sources at the mall - - see Slide 58.
21
General Layout of Costco Sources
Main Report Figure 1-5: Costco Gasoline and Warehouse Area Sources (in red)
22
East Side Parking Area for Costco
Main Report Figure 1-6: East Parking Lot Volume Source (in red)
23
Layout of Gas Station Operations in Model
Main Report Figure 1-4: Costco Gasoline and Warehouse Point Sources (in red)
24
Example of Intersection Modeling
=Queue
=Road Segment
University Blvd
Main Report Figure 1-7: Example of 18-Vehicle Traffic Queue Lengths at Nearby Road Intersections
25
Assumptions for Cars in Queue at Costco
• Assumed 40 cars maximum 1-hour; 20 cars maximum 8-hours, and 10 cars
for average over typical 15 hour operational period
• Costco conducted study at Sterling (same design) January 11-12, 2013; ±7%
annual sales per 2012, factored 8-hour and annual for sales difference (13.9
mm / 12 mm gallons)
• Results
Averaging Time
1-hour
8-hour
Model Assumptions
40
20
Queuing Data
39
32
24-hour
Annual Average
10
10
18
10
• CO 8-hour 28% standard model; 32% if assumption refined per results
• Could increase queue assumptions four-fold or higher and still not approach
standards
26
BACKGROUND
TREATMENTS
27
Background Treatment
• Conservatively used highest measured 2009-2011 for all
modeled locations.
• Overstates background relative to what would be expected in
2013.
• January 2013, Parks & Planning staff requested that PM2.5
annual background be updated to more accurately reflect current
conditions and to maintain compatibility with Washington
Council of Government’s recommendation of 10.8 µg/m3.
• By ~ 2014 when station is open, trend suggests that background
will be < 10.8 µg/m3.
28
Treatment of Background Concentrations is a Standard
Procedure in Modeling for EPA or MDE
• Defined Term in EPA Guideline on Air Quality Modeling: as including: “(1)
natural, (2) nearby sources other than the one(s) currently under
consideration, and (3) unidentified sources.”
• By way of clarification, EPA specifies that “all sources expected to cause a
significant concentration gradient in the vicinity of the source or sources
under consideration for emission limit(s) should be explicitly modeled”
• Per above, Costco has modeled all sources with potential for causing
significant gradients at the Costco gas station source:
• Costco gas station operations (fueling, spillage, delivery)
• Ring Road
• Costco warehouse
• Major nearby roadways (University, Viers Mill, Georgia Ave)
• Costco parking lot and parking garage
29
Actual Trend in PM2.5 Measured Concentrations
(Background)
This figure was produced from using
the raw annual average daily data
from Rockville, Beltville, and
Arlington accessed from:
http://www.epa.gov/airquality/airdata
/ad_data_daily.html.
This data included all monitoring
locations at each site where annual
averages were computed and then a
3-year running averages was used to
simulate the NAAQS.
For example, the 3-year running
averages for 2010 is the annual
average of 2008, 2009 and 2010.
Supplemental Report Figure 4.2: Trends in PM2.5 Concentrations Based on Rockville, Beltsville, and Arlington Monitoring Sites (three-year running averages
from 2005 through 2012)
30
Actual Trend in PM2.5 Measured Concentrations
(Background) Compared to NAAQS
Highest by
2012 is 10.8 µg/m3
US EPA started regulating PM2.5 in 1997 where NAAQS were 15µg/m³
31
Annual PM2.5 Design Value Background Concentrations from
Washington Council of Governments
Supplemental Report Figure 4.3: Annual PM2.5 Design Value Background Concentration
from Washington Council of Governments
32
Example Downward Trend:
Three Year Running Annual Average PM2.5: Los Angeles
Ambient PM2.5 - Los Angeles - (Avg 6 sites)
3-Year Running Averages
70
Concentration (µg/m3)
60
58
58
54
51
50
50
44
42
39
40
38
33
32
29
30
21
21
21
19
20
18
16
15
15
14
13
12
10
0
1999
2001
ANN AVG
2003
24-HR (98TH)
2005
2007
ANN NAAQS
2009
24-HR NAAQS
2011
11
33
SEE AIR QUALITY TRENDS INTO 2013
RESULTS
34
Importance of Dose: National Ambient Air Quality
Standards Based on Defining Acceptable Dose
• Air pollution does not create adverse health affects at all
concentrations
• EPA defines acceptable concentrations (dose) with a reasonable
margin of safety to protect the most sensitive members of the
population
• Asthmatics and children are specifically identified in the Clean
Air Act sensitive subpopulations to be protected
• The Costco Wheaton gas station, modeled using standard EPA
methods, is well below all EPA standards
35
Detailed Concentration Plots and Other Detailed Tables
Available in Report and on Slides as Needed
• Presentation presents overview for key locations: closest
residence, Kenmont Swim and Tennis facility, and the Stephen
Knolls School; detailed concentration aerial overlay plots are
available in project reports.
• Overall modeled concentrations are shown in presentation, but
contributions from each source is available as needed to support
discussion
36
Summary Table Showing Modeled Rural Concentrations at Pool and
School Compared to Average Background Standards (µg/m3) Based
on Conservative Rural Land Use (overstates close-in locations)
Locations
Pool
School
Average
Background
Total for
Pool
Total for
School
Standard
3,361
3,555
NO2
1-Hour
Maximum
54
63
NO2
Annual
Average
6
8
PM2.5
Max 24hr
0.60
0.71
PM2.5 Annual
Average
(10.8
Background)
0.13
0.18
1,488
1,145
28
6.8*
28
10.8
14,134
4,506
82
12.8
28.6
10.9
14,968
4,700
91
14.8
28.7
11.0
40,000
10,000
190
100
35
12
CO 1-Hour
Maximum
CO 8-Hour
Maximum
12,646
13,480
*28 was changed to 6.8 for supplemental report based on further analysis of background data
37
Perspective: Annual Average
PM2.5 Concentrations (μg/m3)
Urban Concentrations (µg/m³)
Rural Concentrations (µg/m³)
Update to Supplemental Report Figure 3.5 based on Section 4.2 analysis of background values in the
Supplemental Report.
38
Perspective: Maximum Predicted 8-hour CO
Concentrations (μg/m3)
Supplemental Report Figure 3.4: Maximum Predicted 8-hour CO Concentrations (μg/m3) for the Closest
Residence, the Stephen Knolls School, and the Kenmont Swim and Tennis Center Special Receptors
39
Perspective: Predicted Annual Average NO2 Concentrations
(μg/m3)
Existing: contains a small 3-7% incremental vehicle contribution from all roads
[Note: Background for Annual Average NO2 has been updated to 6.8 μg/m3 (see Section 4.0 of
Supplemental Report)]
Supplemental Report Figure 3.6: Predicted Annual Average NO2 Concentrations (μg/m3) for the Closest
Residence, the Stephen Knolls School, and the Kenmont Swim and Tennis Center Special Receptors
40
Noise
• Updated noise modeling to account for relocation of gas station
operations
• Noise levels far below County acceptable levels
• Maximum modeled (LDN = 54.3 dBA) versus County
Ordinance of 65 dBA and background of 53 dBA.
• Maximum values below Day / Night noise thresholds
41
Odors
• Supplemental report: 2.6% time closest homes to SSW and 4.9% SSE are
upper bound estimates
• Based on Sterling (without vent control at 99.7%)- - about half of fueling
emissions expected in total in Wheaton with the planned controls.
• Does not account for near-end of incompatibility period between on-board
canister controls for vehicles and venting from vehicles to underground tank
– Full Transition in MD 2-3 years
• When rely exclusively with on-board canisters (expected by within several
years) there will be 4x reduction from fueling emissions as compared to the
Sterling odor study.
42
Odors (Cont.)
• With vent controls (99.7%) at Wheaton station and reliance on on-
board canisters in the future, odors expected to be within the Ring
Road.
43
Perspective on Odor Analysis Wheaton/Sterling
Wheaton, MD
Vent
Sterling, VA
Gas Pumps
Filling
Approximate Distances
from Gas Station Sources
to Closest Home
Pumping Area: 290 ft.
Vent- 270 ft.
Fill 1- 260 ft.
Fill 2-245 ft.
Fill 3- 230 ft.
Approximate Distance from Gas
Pumps / Odor Readings
#1:
#2#3#4#5#6-
210 ft.
130 ft.
105 ft.
200 ft.
90 ft.
90 ft.
Hedonic Tone
\ -0.8
\ -0.6
\ -1.2
\ -1.2
\ -0.8
\ -0.2
44
RISK ASSESSMENT:
POOL AND SCHOOL OCCUPANCY
ANALYSIS
45
Risk Assessment Most Useful as Relative Risk
Comparison - - Not an Indication of Absolute Risk
• CARB 10 in a million notification level is a risk management
tool
• For relative comparison, EPA modeling applicable for
Montgomery County shows ~ 65 in a million as background
risk for specific set of pollutants modeled (EPA monitoring
shows 70-370 in a million for this area)
• Based on urban modeling highest relative risks from Costco gas
station operations is < 1 in a million
46
Conservative Occupancy Calculation
Percent in School
hrs in 70 years
Percent at Pool
hrs in 70 yrs
Average life
expectancy
70
613,200
Days per
year
180
Average life
expectancy
70
613,200
Days per
year
75
hours
years
7
18
hours
years
8
18
# of hours over 18
years
22,680
# of hours over 18
years
10,800
% Occupancy
3.70
% Occupancy
1.76
47
Urban VOC Annual Incremental (Emissions per protocol
without considering reduction for canister controls on motor
vehicles)
URBAN MET RUNS
VOC ANNUAL INCREMENTAL
100 % OCCUPANCY
HOME
SCHOOL
POOL
Total Modeled
12.56
0.70
2.52
Risks (per million)
0.84
0.09
0.19
70 Year Concentrations
12.41
0.66
2.47
70 Year Risks (per million) for Projected
Fleet
0.77
0.07
0.17
SCHOOL
POOL
0.003
0.003
REALISTIC OCCUPANCY FACTORS
70 Year Risks (per million)
0.77
48
Urban VOC Annual Incremental (Emissions considering
reduction for canister controls on motor vehicles
URBAN MET RUNS
VOC ANNUAL INCREMENTAL
Scenario 2
100 % OCCUPANCY
HOME
SCHOOL
POOL
Total VOC Modeled for 2013 Fleet
8.94
0.51
1.80
Risks (per million)
0.67
0.08
0.16
70 Year Concentrations projected Fleet
8.78
0.47
1.75
70 Year Risks (per million) for projected
Fleet
0.59
0.06
0.13
SCHOOL
POOL
0.002
0.002
REALISTIC OCCUPANCY FACTORS
70 Year Risks (per million)
0.59
49
OVERVIEW OF POSITIONS
EXPRESSED BY OPPOSITION
50
Opposition Positions are Not Supported By Sound
Science
• Ultrafine particulates
• Risks at school and pool
• Long-term monitoring of air quality / meteorology
• Broad modeling of sources in area versus standard EPA
background treatments
• Alleged terrain complications
• School siting guidance (CARB and EPA)
51
Ultrafine Particulates
• Maximum annual average fine particulates at closest residence is 0.005
µg/m3.
• If MOVES was available maximum may increase to ~ 0.01 µg/m3.
• New standard is 12 µg/m3; background is 10.8 in 2013, and less by 2014
and beyond
• EPA and expert panel (CASAC) reviewed literature and conclusion: new
standard protective of most sensitive with adequate margin of safety
• EPA defines insignificant contributions to fine particulates for this region as
0.3 µg/m3 , i.e. Costco’s maximum impact is 30 lower than EPA’s defined
level for insignificant contributions if maximum Costco impacts are doubled
• There is no objective or rational basis for concern based on ultrafine
particulates contributions from the Costco gas station
52
Diesel Emissions From 4 Costco Clean Diesel Delivery Trucks / Day
Do Not Present a Significant Source
• Four clean diesel trucks per day to gas station
• “The emissions of particulate mass in NTDE (clean diesels) are
substantially lower (less than 1%) than those emitted from 1988 engines.”1
• “In fact, the nanoparticle number concentration emissions contained in
NTDE are well below typical urban ambient air concentrations, and amount
to a 10,000-fold reduction when compared against older diesel engines not
equipped with DPFs (Barone et al., 2010).”1
• “Most importantly, NTDE is virtually free of the elemental carbon particles
found in TDE”1
• Diesel emissions from the Costco gas station are not significant
1R.O.
McClellan et al. / Regulatory Toxicology and Pharmacology 63 (2012) 225–258
53
Ultrafines Are Much Higher in Homes due to Inside Sources (during
described activities)
# particles / cm³
350,000
300,000
250,000
200,000
150,000
100,000
50,000
0
Frying Onions
smoking
burning candle
use of hair drier
vacuuming
burning incense 130 m I-110 LA / 130 m I-110 LA /
morning rush
11 am - 2 pm
Glystsos, T. et. al., “Characterization of Particulate Matter Concentrations During Controlled Indoor Activities,” Atmospheric Environment,
44 (2010) 1539-1549.
54
Highest Levels of Ultrafine Particles and Most Toxic are Not Direct Emissions
But Photochemically Produced in Atmosphere on a Regional Basis
18,000
Rush Hour Compared to Photochemically Produced
Particles (# particles / cm³)
16,000
Counts off-peak
but after
Photochemical
Reactions in
atmosphere
14,000
12,000
10,000
8,000
Direct counts
during
Rush hour
period
6,000
4,000
2,000
0
130 m I-110 LA / morning rush
130 m I-110 LA / 11 am - 2 pm
Varma, V. et. al., “Redox Activity of Urban Qauasi-Ultrafine Particles from Primary and Secondary Sources,
Atmospheric Environment, 43 (2009) 6360-6368.
55
Ultrafine Particulates & Fast Food Restaurants:
Common Commercial Source >> Costco Gas Station
• Fast-food restaurants are common commercial facilities
permitted in Montgomery County
“Restaurants, especially fast food and grill outlets that conduct a
lot of frying, are also thought to contribute to UFP
concentrations. For example, measurements from the California
Children’s Health Study reported high UFP levels (similar to
those near major freeways) at a monitoring site next to a fastfood restaurant (38) while a study of UFP concentrations in
Manchester, England suggested high restaurant density as a
predictor of elevated UFP concentrations.”
“A Land Use Regression Model for Ultrafine Particles in Vancouver, Canada » , Rebecca Abernethy, B.Sc., The
University of British Columbia, 2008 a thesis submitted in partial fulfillment of the requirements for the degree of master of
science in the faculty of graduate studies (Occupational and Environmental Hygiene).
56
Risks at School and Pool Are Insignificant
• Important omission when discussing the school and pool: dose
• National Ambient Air Quality Standards are developed to
protect the most sensitive subpopulations with a reasonable
margin of safety, and specifically children and asthmatics
• All standards and guidance are met with wide margins at the
school and pool
57
Long-Term Monitoring of Air Quality and Meteorology
• Even large industrial sources are not required to conduct the extensive
air quality and meteorological monitoring proposed by opponents to
the gas station
• Standard practice would be to use existing meteorological data for a
setting such as this and to conservatively use regionally available air
quality data to address background contributions
• Unlikely to be one gas station in the U.S. that has conducted
extensive pre or post construction air quality and meteorological
monitoring as requested by the opposition
• EPA recommends three years of air quality data to ensure a stable data
set, which obviously is inconsistent with the permitting process for
facilities of this nature - - reason for EPA use of regional data
58
Modeling of All Parking Lots and Other Loading Docks
(90 % cars peak hours to Costco lots: very conservative)
• Costco has most likely conducted the most extensive air quality
modeling analysis of any gas station in the U.S.:
• All gas station operations including (filling of underground tanks, filling of
motor vehicles, spills, queuing, ingress / egress)
• Ring Road
• Costco warehouse parking lots and loading dock
• All major nearby roadways and intersections (University, Viers Mill, and
Georgia Avenue)
• The results would be substantially lower if it were feasible to model
all sources of air pollution within and beyond the mall and not use the
highly conservative background approach recommended by EPA (and
followed here)
What if Include Other Loading Docks Included and Unrealistically Assume
Same Parking Rates as Costco Throughout the Mall
Target
Costco
Sears
Close-Up View of New Loading Docks Added
Target Loading Dock
Other Mall Loading Docks
=New Conservative Loading Dock Locations Added
What if Include Other Loading Docks Included and Unrealistically
Assume Same Parking Rates as Costco Throughout the Mall (Cont.)
62
Alleged Terrain Complications - - No Basis in Fact to
Suggest This is a Significant Issue
• No regulatory agency in the country would require specialized
micrometeorological study or specialized modeling because of the presence
of a small drop in terrain as occurs here
• This topic was addressed during the protocol discussion, supplemental
modeling analysis was conducted as requested by the opposition, which
showed terrain issues to be insignificant
• There is no scientific basis to allege that the presence of the hill would result
in exceedances of any accepted air quality standard
• The allegation in fact is inconsistent with the terrain slope, the vegetation
cover, the surface material at the mall, the hours of operation of the school,
and all other factors considered
• See supplemental PowerPoint.
63
Percent of Possible Hours That Could Even Potentially
Have the Gravity Flow Conditions is Very Small
• Gravity flow (redirection towards residential area to the south) of
emissions from Costco gas station can only occur when all of the
following conditions occur:
•
•
•
•
•
When the gas station is open
When flow is from the southerly direction
During nighttime conditions (1 hr < sunset through 1 hr > sunrise)
Non-overcast conditions
Light wind speeds, such as ≤ 7 mph
• Review of 5 years of meteorological data shows that all of the above
conditions occur ~ 4 percent of the time - - - maximum potential
• See next slide for unlikely gravity flow impacts toward community
even when all conditions are aligned (i.e. the 4 percent described
above)
64
Alleged Gravity Flow Concern is Inconsistent with Facts
• Terrain slopes up towards Ring Road (not down)
• Flow if deflected from screening wall would flow to the East,
which slopes towards the North and away from the
neighborhood
• The alleged impacts at the school are incorrect since the school
is open 8:55 AM to 3:10 PM - - inconsistent with the nocturnal
nature of this potential condition
• Most of the year there is vegetation cover along the downslope
towards the community which would inhibit the formation of
gravity flow conditions (actual potential less than 2 percent)
65
School Siting Guidance (CARB and EPA)
• Developed by California (CARB) and EPA to guide siting of new
schools when site-specific air quality studies are not available
• Based on hypothetical, unrealistic meteorological data (1 m/sec wind
speed and nighttime restrictive dispersion all the time)
• Assumes 100 percent occupancy for a lifetime
• Does not consider prevailing flow relative to offsite locations, control
equipment at the station, etc.
• Does not consider 99.7% vent control at Costco Wheaton
• Both EPA and CARB indicate that generic guidance is overruled by
site-specific analysis (see next slide)
66
School Siting Guidance
CARB
EPA
http://www.epa.gov/schools/siting/downloads/School_Siting_Guidelines.pdf
“If an LEA is considering locations that are in proximity to air pollution sources
that may pose potential risks, an understanding of those potential exposures and
risks is essential. Due to the many variables involved (such as those included in
Exhibit 5: Factors Influencing Exposures and Potential Risks from Nearby
Hazards), assessing risks from air pollution is inherently complex and should be
performed by a trained environmental professional with monitoring, modeling
and risk assessment expertise.”
• Costco has conducted site-specific analysis that overrides simple screening
methodology
67
Attempts to Link Gas Station to Major Federal Environmental
Requirements (that are obviously not applicable to a gas station)
• EPA’s Conformity Rule: applies to Federal actions and of much larger size
than building a gas station (“Conformity determinations are not required
under this subpart for individual projects which are not FHWA/FTA projects.
However, §93.121 applies to such projects if they are regionally significant”
- - neither of which applies to building a gas station)
• National Environmental Policy Act (NEPA) does not apply to building a gas
station: (Not a Federal action and not of sufficient size)
• Prevention of Significant Deterioration (PSD) does not apply to a gas station
(not a major source per PSD definition: not applicable)
68
Changing the Definition of a Gas Station
• Costco is proposing to build a gas station to sell gasoline (only)
to the public
• “The emissions from the gas depot resemble emissions from a
small factory . . “
Larry Silverman 4/4/13
• “Do the Clean Air Act (CAA) National Ambient Air Quality
Standards (NAAQS) guarantee that the regional gasoline
distribution center proposed by Costco is safe?” Larry Silverman 4/4/13
69
Reduction in Energy Consumption and Greener
Environment for County
• Business model of Costco results in more combined trips (combined
shopping and gasoline purchase)
• Reduced driving emissions through centralization of shopping
• Reduced driving for Costco members that now drive outside of
Montgomery County to purchase gasoline
• Greater controls on Costco gas stations as compared to alternatives:
• Arid permeator reduces vent emissions 99.7% versus standard gas station
• Attendant always on duty to respond to spills and to take corrective action
70
END