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Notice of Draft Facility-Wide Synthetic Minor Air Quality Permit and Permit to Construct Public Comment Period

Friday, June 20, 2025

PUBLIC NOTICE

Notice Requesting Public Comment on Draft Facility-Wide Synthetic Minor Air Quality Operating Permit and Permit to Construct Facility Expansion for CWC WDC, LLC Gasoline Dispensing Facility at 2431 Market Street NE

Notice is hereby given that, CWC WDC, LLC has applied for an air quality permit pursuant to the requirements of Title 20 of the District of Columbia Municipal Regulations, Chapter 2 (20 DCMR Chapter 2) to expand and operate the existing gasoline dispensing facility located at 2431 Market Street NE, Washington DC 20018. This is the gasoline dispensing facility associated with the nearby Costco warehouse club/retail store. The contact person for the CWC WDC, LLC is Jacqueline Choe, Permitting and Compliance Specialist 1, Barghausen Consulting Engineers, LLC (Authorized Agent), at 425-251-6222 or [email protected].

 

Existing equipment at the facility which would be subject to this permit includes the following:

  • Underground storage tanks as follows:
    • 30,000-gallon regular unleaded Tank #1
    • 30,000-gallon regular unleaded Tank #2
    • 30,000-gallon premium unleaded Tank #3
    • 1,500-gallon additive Tank #4;
  • ARID Permeator back-end vapor processor;
  • Enhanced vapor recovery (EVR) equipment;
  • Eight (8) double-sided multi-product gasoline dispensers; and
  • Associated appurtenances existing at the time of issuance of this permit.

Additionally, CWC WDC, LLC proposes to construct and operate additional equipment as follows:

  • Four (4) additional Gilbarco Encore 700S NG4 double-sided multi-product gasoline dispensers;
  • Single wall transition sump for additive injection and TMS additive injection system;
  • TLS-450PLUS monitoring system;
  • Vent risers; and
  • Associated piping.

The applicant has requested that a limitation on the gasoline throughput for the facility be established in this permit pursuant to 20 DCMR § 200.6 to avoid the applicability of 20 DCMR § 300.1 to the facility. The limit is intended to ensure that emissions of volatile organic compounds (VOCs) remain below the major source threshold of 25 tons per year, facility-wide. The throughput limitation requested is a limitation of 26,000,000 gallons in any 12-consecutive month period.

 

Taking this throughput limitation into account, the following is an estimate of the overall potential emissions from the facility:

 

FACILITY-WIDE EMISSIONS SUMMARY [TONS PER YEAR]

Pollutants

Potential Emissions with 20 DCMR 200.6 Limits

Volatile Organic Compounds (VOCs)

17.07

Total Hazardous Air Pollutants (Total HAPs)

0.47

The primary emission limits included in the permit are as follows:

1.   Visible emissions shall not be emitted into the outdoor atmosphere from the gasoline dispensing equipment or storage tanks. [20 DCMR 201 and 20 DCMR 606.1]

2.   An emission into the atmosphere of odorous or other air pollutants from any source in any quantity and of any characteristic, and duration which is, or is likely to be injurious to the public health or welfare, or which interferes with the reasonable enjoyment of life or property is prohibited. [20 DCMR 903.1]

Violation of standards set forth in this section that occur as a result of unavoidable malfunction, despite the conscientious employment of control practices, shall be an affirmative defense for which the owner or operator shall bear the burden of proof. A malfunction shall not be considered unavoidable if the owner or operator could have taken, but did not take, appropriate steps to eliminate the malfunction within a reasonable time, as determined by the Department. [20 DCMR 903.13(b)]

3.   The Permittee shall, at all times, operate and maintain the equipment covered by this permit, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. [40 CFR 63.11115(a)]

In addition to these emission limits, the throughput limitation is as follows:

  • Total throughput of gasoline shall not exceed 26,000,000 gallons in any 12-consecutive-month period. [20 DCMR 200.6] Total throughput in any 12-consecutive-month period shall be calculated at the end of each calendar month by adding the monthly throughput of each of the last 12 calendar months to obtain a total value.

The Department of Energy and Environment (DOEE) has reviewed the permit application and related documents and has made a preliminary determination that the applicant meets all applicable air quality requirements promulgated by the U.S. Environmental Protection Agency (EPA) and the District. Therefore, draft permit No. 7412-SM has been prepared and, pursuant to 20 DCMR §210, with this notice, the Air Quality Division (AQD) of DOEE provides notice of its proposal to issue this permit to CWC WDC, LLC.

The permit application and supporting documentation, along with the draft permit are available for public inspection at AQD and copies may be made available between the hours of 9:00 A.M. and 5:00 P.M., Monday through Friday. Interested parties wishing to view these documents should provide their names, addresses, telephone numbers and affiliation, if any, to Stephen S. Ours at (202) 498-8143 or [email protected]. Copies of the draft permit and related technical support memorandum are also available in the attachments section below.

A public hearing on this permitting action will not be held unless DOEE has received a request for such a hearing within 30 days of the publication of this notice. Interested parties may also submit written comments on the permitting action. The written comments must include the person’s name, telephone number, affiliation, if any, mailing address and a statement outlining the air quality issues in dispute and any facts underscoring those air quality issues. All relevant comments will be considered in issuing the final permit.
 

Comments on the draft synthetic minor permit and any request for a public hearing should be addressed to:

Stephen S. Ours, P.E. 
Chief, Permitting Branch - Air Quality Division

Department of Energy and Environment
1200 First Street NE, 5th Floor
Washington, DC 20002

[email protected]

No comments or hearing requests submitted after July 21, 2025 will be accepted.

For more information, please contact Stephen S. Ours at (202) 498-8143 or [email protected].