3ConclusionsBased on standard EPA methods, air quality impacts are far below all EPA National Ambient Air Quality StandardsRisks are below de minimis levels and far below reporting levels based on strict California guidelinesNoise levels are far below County requirementsOdor issues are not significant
4Conclusions (Cont.)Opponents of the gas station are basing opposition on the premise that EPA air quality standards are not sufficiently protectiveRegulatory and land use decisions need to be based on objective facts and standardsAbsent 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
5Conclusions (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 fleetCostco Wheaton gas station is relatively large in terms of sales but not large in terms of emissions relative to trend lines (see attached figures)
612 M Gallons / year Station with Vent Control at 99 12 M Gallons / year Station with Vent Control at 99.7% in 2013 Similar to Smaller Stations in 1980s & 1990s and Will Continue to DropThis 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.
712 M Gallons / year Station with Vent Control at 99 12 M Gallons / year Station with Vent Control at 99.7% in 2013 Similar to Smaller Stations in 1980s & 1990s and Will Continue to DropNot Unprecedented: VOC emissions gasoline marketing Costco in 2013Comparable to 1.5 M gal/year in 1987 and 3 M gal/year in 1998
812 M Gallons / year Station with Vent Control at 99 12 M Gallons / year Station with Vent Control at 99.7% in 2013 Similar to Smaller Stations in 1980s & 1990s and Will Continue to DropNot Unprecedented: VOC emissions gasoline marketing Costco in 2020 Comparable to 1.5 M gal/year in 1997 and 3 M gal/year in 2005
10National Trends in Emissions: Downward Percent Change in Emissions1980 vs 20101990 vs 20102000 vs 2010Carbon Monoxide (CO)-71-60-44Lead (Pb)-97-33Nitrogen Oxides (NOx)-52-48-41Volatile Organic Compounds (VOC)-63-35Direct PM10-83-67-50Direct PM2.5----55Sulfur Dioxide (SO2)-69-65Notes: Trend data not available 2. Direct PM10 emissions for 1980 are based on data since Negative numbers indicate reductions in emissions
11Methods and Results: Environmental Report for Costco Wheaton Gas Station
12Overview 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
13Overview Submitted initial environmental report: July 2012 September 2012 met with Kensington Heights consultant: Dr. Henry ColeDeveloped modified protocol including comments from Dr. ColeFinal report shows modeling results for Costco sources based on consensus approachInterpretations may differ, but basis for concentrations for modeled incremental Costco sources are drawn from a common protocol
14Benefit to Reviewers on Achieving Consensus of Modeling Methods Complex modeling treatments are based on consensus methods to address incremental Costco sourcesCounty staff and hearing examiner can focus on interpretation of results
15Not Implying Consensus on All Issues Differing interpretations of fine particulates can be supported from common modeling resultsDr. 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
17Air 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)
18Summary 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
19Summary of Conservative Assumptions (Cont.) Used very conservative (overstated) background concentrations (maximum ) - - 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 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)
20Parking Garage Sources Summary of Conservative Assumptions: 90 % of All Traffic to Mall Assumed to Park in Costco Lots=((40+185)-48)*0.9=((79+338)-67)*0.9Parking Lot SourcesArea (m²)Morning Peak HourEvening Peak HourMaximum Peak HourParking West25056159315* 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 roadParking Garage SourcesParking East143260260.10* 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=((30+190)-61)*0.9=((312+57)-80)*0.9Assumption 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.
21General Layout of Costco Sources Main Report Figure 1-5: Costco Gasoline and Warehouse Area Sources (in red)
22East Side Parking Area for Costco Main Report Figure 1-6: East Parking Lot Volume Source (in red)
23Layout of Gas Station Operations in Model Main Report Figure 1-4: Costco Gasoline and Warehouse Point Sources (in red)
24Example of Intersection Modeling =Queue=Road SegmentUniversity BlvdMain Report Figure 1-7: Example of 18-Vehicle Traffic Queue Lengths at Nearby Road Intersections
25Assumptions 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 periodCostco 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)ResultsCO 8-hour 28% standard model; 32% if assumption refined per resultsCould increase queue assumptions four-fold or higher and still not approach standardsAveraging TimeModel AssumptionsQueuing Data1-hour40398-hour203224-hour1018Annual Average
27Background TreatmentConservatively used highest measured 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.
28Treatment 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 RoadCostco warehouseMajor nearby roadways (University, Viers Mill, Georgia Ave)Costco parking lot and parking garage
29Actual 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: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)
30Actual Trend in PM2.5 Measured Concentrations (Background) Compared to NAAQS Highest by2012 is 10.8 µg/m3US EPA started regulating PM2.5 in 1997 where NAAQS were 15µg/m³
31Annual 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
32Example Downward Trend: Three Year Running Annual Average PM2 Example Downward Trend: Three Year Running Annual Average PM2.5: Los Angeles
34Importance of Dose: National Ambient Air Quality Standards Based on Defining Acceptable Dose Air pollution does not create adverse health affects at all concentrationsEPA defines acceptable concentrations (dose) with a reasonable margin of safety to protect the most sensitive members of the populationAsthmatics and children are specifically identified in the Clean Air Act sensitive subpopulations to be protectedThe Costco Wheaton gas station, modeled using standard EPA methods, is well below all EPA standards
35Detailed 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
36Summary 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) LocationsCO 1-Hour MaximumCO 8-Hour MaximumNO21-Hour MaximumNO2 Annual AveragePM2.5 Max 24-hrPM2.5 Annual Average(10.8 Background)Pool12,6463,3615460.600.13School13,4803,5556380.710.18Average Background1,4881,145286.8*10.8Total for Pool14,1344,5068212.828.610.9Total for School14,9684,7009114.828.711.0Standard40,00010,0001901003512*28 was changed to 6.8 for supplemental report based on further analysis of background data
37Perspective: 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.
38Perspective: 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
39Perspective: 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
40NoiseUpdated noise modeling to account for relocation of gas station operationsNoise levels far below County acceptable levelsMaximum modeled (LDN = 54.3 dBA) versus CountyOrdinance of 65 dBA and background of 53 dBA.Maximum values below Day / Night noise thresholds
41OdorsSupplemental report: 2.6% time closest homes to SSW and 4.9% SSE are upper bound estimatesBased 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 yearsWhen 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.
42Odors (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.
43Perspective on Odor Analysis Wheaton/Sterling Wheaton, MDSterling, VAVentGas PumpsFillingApproximate Distance from Gas Pumps / Odor ReadingsHedonic Tone#1: 210 ft. \# ft. \# ft. \# ft. \# ft. \# ft. \Approximate Distances from Gas Station Sources to Closest HomePumping Area: 290 ft.Vent- 270 ft.Fill ft.Fill ft.Fill ft.
44Risk Assessment: Pool and school occupancy analysis
45Risk Assessment Most Useful as Relative Risk Comparison - - Not an Indication of Absolute Risk CARB 10 in a million notification level is a risk management toolFor 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 in a million for this area)Based on urban modeling highest relative risks from Costco gas station operations is < 1 in a million
46Conservative Occupancy Calculation Percent in SchoolAverage life expectancyDays per yearhoursyears# of hours over 18 years% Occupancy7018071822,6803.70hrs in 70 years613,200Percent at Pool75810,8001.76hrs in 70 yrs
47VOC ANNUAL INCREMENTAL REALISTIC OCCUPANCY FACTORS Urban VOC Annual Incremental (Emissions per protocol without considering reduction for canister controls on motor vehicles)URBAN MET RUNSVOC ANNUAL INCREMENTAL100 % OCCUPANCYHOMESCHOOLPOOLTotal Modeled12.560.702.52Risks (per million)0.840.090.1970 Year Concentrations12.410.662.4770 Year Risks (per million) for Projected Fleet0.770.070.17REALISTIC OCCUPANCY FACTORS70 Year Risks (per million)0.003
48VOC ANNUAL INCREMENTAL REALISTIC OCCUPANCY FACTORS Urban VOC Annual Incremental (Emissions considering reduction for canister controls on motor vehiclesURBAN MET RUNSVOC ANNUAL INCREMENTALScenario 2100 % OCCUPANCYHOMESCHOOLPOOLTotal VOC Modeled for 2013 Fleet8.940.511.80Risks (per million)0.670.080.1670 Year Concentrations projected Fleet8.780.471.7570 Year Risks (per million) for projected Fleet0.590.060.13REALISTIC OCCUPANCY FACTORS70 Year Risks (per million)0.002
50Opposition Positions are Not Supported By Sound Science Ultrafine particulatesRisks at school and poolLong-term monitoring of air quality / meteorologyBroad modeling of sources in area versus standard EPA background treatmentsAlleged terrain complicationsSchool siting guidance (CARB and EPA)
51Ultrafine Particulates Maximum annual average fine particulates at closest residence is 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 beyondEPA and expert panel (CASAC) reviewed literature and conclusion: new standard protective of most sensitive with adequate margin of safetyEPA 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 doubledThere is no objective or rational basis for concern based on ultrafine particulates contributions from the Costco gas station
52Diesel Emissions From 4 Costco Clean Diesel Delivery Trucks / Day Do Not Present a Significant SourceFour 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”1Diesel emissions from the Costco gas station are not significant1R.O. McClellan et al. / Regulatory Toxicology and Pharmacology 63 (2012) 225–258
53Ultrafines Are Much Higher in Homes due to Inside Sources (during described activities) Glystsos, T. et. al., “Characterization of Particulate Matter Concentrations During Controlled Indoor Activities,” Atmospheric Environment,44 (2010)
54Highest Levels of Ultrafine Particles and Most Toxic are Not Direct Emissions But Photochemically Produced in Atmosphere on a Regional BasisCounts off-peakbut afterPhotochemicalReactions inatmosphereDirect counts duringRush hour periodVarma, V. et. al., “Redox Activity of Urban Qauasi-Ultrafine Particles from Primary and Secondary Sources, Atmospheric Environment, 43 (2009)
55Ultrafine 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 fast-food 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).
56Risks at School and Pool Are Insignificant Important omission when discussing the school and pool: doseNational Ambient Air Quality Standards are developed to protect the most sensitive subpopulations with a reasonable margin of safety, and specifically children and asthmaticsAll standards and guidance are met with wide margins at the school and pool
57Long-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 stationStandard 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 contributionsUnlikely 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 oppositionEPA 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
58Modeling 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 RoadCostco warehouse parking lots and loading dockAll 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)
59What if Include Other Loading Docks Included and Unrealistically Assume Same Parking Rates as Costco Throughout the MallGiantTargetCostcoSears
60Close-Up View of New Loading Docks Added Target Loading DockOther Mall Loading Docks=New Conservative Loading Dock Locations Added
61What if Include Other Loading Docks Included and Unrealistically Assume Same Parking Rates as Costco Throughout the Mall (Cont.)
62Alleged 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 hereThis topic was addressed during the protocol discussion, supplemental modeling analysis was conducted as requested by the opposition, which showed terrain issues to be insignificantThere is no scientific basis to allege that the presence of the hill would result in exceedances of any accepted air quality standardThe 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 consideredSee supplemental PowerPoint.
63Percent 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 openWhen flow is from the southerly directionDuring nighttime conditions (1 hr < sunset through 1 hr > sunrise)Non-overcast conditionsLight wind speeds, such as ≤ 7 mphReview of 5 years of meteorological data shows that all of the above conditions occur ~ 4 percent of the time maximum potentialSee next slide for unlikely gravity flow impacts toward community even when all conditions are aligned (i.e. the 4 percent described above)
64Alleged 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 neighborhoodThe 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 conditionMost 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)
65School 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 availableBased on hypothetical, unrealistic meteorological data (1 m/sec wind speed and nighttime restrictive dispersion all the time)Assumes 100 percent occupancy for a lifetimeDoes not consider prevailing flow relative to offsite locations, control equipment at the station, etc.Does not consider 99.7% vent control at Costco WheatonBoth EPA and CARB indicate that generic guidance is overruled by site-specific analysis (see next slide)
66School Siting Guidance CARB“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.”EPACostco has conducted site-specific analysis that overrides simple screening methodology
67Attempts 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, § 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)
68Changing 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
69Reduction 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 shoppingReduced driving for Costco members that now drive outside of Montgomery County to purchase gasolineGreater controls on Costco gas stations as compared to alternatives:Arid permeator reduces vent emissions 99.7% versus standard gas stationAttendant always on duty to respond to spills and to take corrective action