OVERVIEW OF ENVIRONMENTAL REPORT FOR COSTCO WHEATON GAS STATION 1.

OVERVIEW OF ENVIRONMENTAL REPORT FOR COSTCO WHEATON GAS STATION

1

CONCLUSIONS

2

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

3

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

4

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)

5

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

6

• 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.

1970 1975 1980 1985 1990 1995 2000 2005 2010 2015 2020

0.0

0.2

0.4

0.6

0.8

1.0

1.2

1.4

VOC Emission Rates for Gasoline Station Marketing and Opera-tions (grams/second) by Year

1,500,000

3,000,000

12,000,000 Wheaton Costo 2013 w/ Arid Permeator

VO

C E

mis

sion

Rat

e (g

/s)

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 Require -ment, 2013 - State II/ORVR Incompatibility and Arid Permeator, 2020 - ORVR Technology Widespread, Spillage Reduced, and Stage II

Phased Out

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

7

1970 1975 1980 1985 1990 1995 2000 2005 2010 2015 2020

0.0

0.2

0.4

0.6

0.8

1.0

1.2

1.4

VOC Emission Rates for Gasoline Station Marketing and Opera-tions (grams/second) by Year

1,500,000

3,000,000

12,000,000 Wheaton Costo 2013 w/ Arid Permeator

VO

C E

mis

sion

Rat

e (g

/s)

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 Require -ment, 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 2013Comparable to 1.5 M gal/year in 1987 and 3 M gal/year in 1998

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

8

1970 1975 1980 1985 1990 1995 2000 2005 2010 2015 2020

0.0

0.2

0.4

0.6

0.8

1.0

1.2

1.4

VOC Emission Rates for Gasoline Station Marketing and Opera-tions (grams/second) by Year

1,500,000

3,000,000

12,000,000 Wheaton Costo 2013 w/ Arid Permeator

VO

C E

mis

sion

Rat

e (g

/s)

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 Require -ment, 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

Typical Gas Station vs. Costco

9

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 available2. Direct PM10 emissions for 1980 are based on data since 1985

3. Negative numbers indicate reductions in emissions

10

http://www.epa.gov/airtrends/aqtrends.html

METHODS AND RESULTS: ENVIRONMENTAL REPORT FOR COSTCO WHEATON GAS STATION

11

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

12

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

13

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

14

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

15

Methods

• Air quality analysis

• Noise

• Odors

16

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)

17

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

18

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)

19

Summary of Conservative Assumptions: 90 % of All Traffic to Mall Assumed to Park in Costco Lots

20

Parking Lot Sources              

  Area (m²)

Morning Peak Hour

Evening Peak Hour

Maximum Peak Hour

Parking West 25056 159 315 315 * 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 

Parking Garage Sources

  Morning Peak Hour

Evening Peak Hour

Maximum Peak Hour

Parking East 143 260 260.10 * 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 

• 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.

=((79+338)-67)*0.9=((40+185)-48)*0.9

=((312+57)-80)*0.9=((30+190)-61)*0.9

General Layout of Costco Sources

21

Main Report Figure 1-5: Costco Gasoline and Warehouse Area Sources (in red)

East Side Parking Area for Costco

22

Main Report Figure 1-6: East Parking Lot Volume Source (in red)

Layout of Gas Station Operations in Model

23

Main Report Figure 1-4: Costco Gasoline and Warehouse Point Sources (in red)

Example of Intersection Modeling

24

University Blvd

Main Report Figure 1-7: Example of 18-Vehicle Traffic Queue Lengths at Nearby Road Intersections

=Queue =Road Segment

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

• 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

25

Averaging Time Model Assumptions Queuing Data

1-hour 40 39

8-hour 20 32

24-hour 10 18

Annual Average 10 10

BACKGROUND TREATMENTS

26

Background Treatment

27

• 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.

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

28

Actual Trend in PM2.5 Measured Concentrations (Background)

29

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)

Actual Trend in PM2.5 Measured Concentrations (Background) Compared to NAAQS

30

US EPA started regulating PM2.5 in 1997 where NAAQS were 15µg/m³

Highest by2012 is 10.8 µg/m3

Annual PM2.5 Design Value Background Concentrations from Washington Council of Governments

31

Supplemental Report Figure 4.3: Annual PM2.5 Design Value Background Concentration from Washington Council of Governments

Example Downward Trend:Three Year Running Annual Average PM2.5: Los Angeles

32

1999 2001 2003 2005 2007 2009 20110

10

20

30

40

50

60

70

58 5854

51 50

4442

39 38

33 3229

21 21 21 19 18 16 15 15 14 13 12 11

Ambient PM2.5 - Los Angeles - (Avg 6 sites) 3-Year Running Averages

ANN AVG 24-HR (98TH) ANN NAAQS 24-HR NAAQS

Con

cent

rati

on (µ

g/m

3)

RESULTS

33

SEE AIR QUALITY TRENDS INTO 2013

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

34

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

35

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)

36

 Locations

 CO 1-Hour Maximum

 CO 8-Hour Maximum

 NO2

1-Hour Maximum

 NO2

Annual Average

 PM2.5

Max 24-hr

PM2.5 Annual

Average(10.8

Background)Pool 12,646 3,361 54 6 0.60 0.13

School 13,480 3,555 63 8 0.71 0.18Average

Background1,488 1,145 28 6.8* 28 10.8

Total for Pool

14,134 4,506 82 12.8 28.6 10.9

Total for School

14,968 4,700 91 14.8 28.7 11.0

Standard 40,000 10,000 190 100 35 12

*28 was changed to 6.8 for supplemental report based on further analysis of background data

Perspective: Annual Average PM2.5 Concentrations (μg/m3)

37

Rural Concentrations (µg/m³)Urban Concentrations (µg/m³)

Update to Supplemental Report Figure 3.5 based on Section 4.2 analysis of background values in the Supplemental Report.

Perspective: Maximum Predicted 8-hour CO Concentrations (μg/m3)

38

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

Perspective: Predicted Annual Average NO2 Concentrations (μg/m3)

39

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

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)]

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

40

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.

41

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.

42

Perspective on Odor Analysis Wheaton/Sterling

43

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.

Filling

Vent Gas Pumps

Approximate Distance from Gas Pumps / Odor Readings

Hedonic Tone #1: 210 ft. \ -0.8#2- 130 ft. \ -0.6#3- 105 ft. \ -1.2 #4- 200 ft. \ -1.2#5- 90 ft. \ -0.8#6- 90 ft. \ -0.2

Wheaton, MD Sterling, VA

RISK ASSESSMENT:

POOL AND SCHOOL OCCUPANCY ANALYSIS

44

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

45

Conservative Occupancy Calculation

46

Percent in School Average life expectancy

Days per year hours years # of hours over 18

years % Occupancy

70 180 7 18 22,680 3.70hrs in 70 years 613,200  

Percent at Pool Average life expectancy

Days per year hours years # of hours over 18

years % Occupancy

70 75 8 18 10,800 1.76hrs in 70 yrs 613,200

Urban VOC Annual Incremental (Emissions per protocol without considering reduction for canister controls on motor vehicles)

47

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

REALISTIC OCCUPANCY FACTORS   SCHOOL POOL

70 Year Risks (per million) 0.77 0.003 0.003

48

Urban VOC Annual Incremental (Emissions considering reduction for canister controls on motor vehicles

URBAN MET RUNSVOC 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

REALISTIC OCCUPANCY FACTORS   SCHOOL POOL

70 Year Risks (per million) 0.59 0.002 0.002

OVERVIEW OF POSITIONS EXPRESSED BY OPPOSITION

49

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)

50

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

51

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

52

Ultrafines Are Much Higher in Homes due to Inside Sources (during described activities)

53

Frying Onions smoking burning candle use of hair drier vacuuming burning incense 130 m I-110 LA / morning rush

130 m I-110 LA / 11 am - 2 pm

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

# particles / cm³

Glystsos, T. et. al., “Characterization of Particulate Matter Concentrations During Controlled Indoor Activities,” Atmospheric Environment, 44 (2010) 1539-1549.

Highest Levels of Ultrafine Particles and Most Toxic are Not Direct Emissions But Photochemically Produced in Atmosphere on a Regional Basis

54

130 m I-110 LA / morning rush 130 m I-110 LA / 11 am - 2 pm0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

16,000

18,000 Rush Hour Compared to Photochemically Produced Par-ticles (# particles / cm³)

Direct counts during

Rush hour period

Counts off-peakbut after

PhotochemicalReactions inatmosphere

Varma, V. et. al., “Redox Activity of Urban Qauasi-Ultrafine Particles from Primary and Secondary Sources, Atmospheric Environment, 43 (2009) 6360-6368.

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 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).

55

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

56

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

57

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)

58

What if Include Other Loading Docks Included and Unrealistically Assume Same Parking Rates as Costco Throughout the Mall

Giant

Sears

Target

Costco

Close-Up View of New Loading Docks Added

=New Conservative Loading Dock Locations Added

Target Loading Dock

Other Mall Loading Docks

What if Include Other Loading Docks Included and Unrealistically Assume Same Parking Rates as Costco Throughout the Mall (Cont.)

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.

62

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)

63

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)

64

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)

65

School Siting Guidance

• Costco has conducted site-specific analysis that overrides simple screening methodology

66

CARB

EPAhttp://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.”

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

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

69

END

70