### Response to Comments, SPI - Loyalton Draft PSD permit #SAC - 87 - 01A August 30, 2010 EPA received six comments on the Sierra Pacific Industries

– Loyalton ( SPI - Loyalton ) Draft PSD permit #SAC - 87 - 01A . The commenter s ’ main concerns were related to particulate matter (PM) / soot and the proposed emissions increases in oxides of nitrogen ( NOx ) and carbon monoxide ( CO ) . Particulate matter and s oot deposits may be attributable to particulate sources affecting Loyalton neighborhood s. The District has informed E PA that there are local efforts underway to help understand the Loyalton

– area PM problem , including the identification of potential sources, and possible PM reduction opportunities. On April 15, 2010, the District, SPI and the community, met to discuss th e Loyalton Particulate Matter Reduction Plan. To control PM emissions at the plant, SPI employs multiclone and electrostatic precipitator control devices for the control of particulates less than or equal to 10 micrometers in diameter. These PM controls are typical pollution controls applied to reduce particulate matter from biomass boilers such as the Riley stoker boiler in operation at SPI - Loyalton. EPA’s draft PSD permit for SPI - Loyalton included PM and VOC emission limits in Permit Condition XII. D and relevant sections of the Ambient Air Quality Impact Report. After EPA announced the public comment period, EPA learned that the SPI - Loyalton permit issued by Northern Sierra AQMD (NSAQMD) already includes enforceable conditions limiting PM and VOC emissions . NSAQMD Permit #88 - 19 - 01, includes p articulate matter and VOC emission limits in Permit Condition 26. PM is limited to 9.96 pounds per hour ( averaged o ver 3 hours); 43.6 tons per year; 0.015 grains per dry standard cubic foot of exhaust gas corre cted to 12% CO 2 . VOCs are limited to 10.5 pounds per hour (averaged over 3 hours); 29.4 tons per year. In addition, NSAQMD recently clarified SPI - Loyalton’s compliance obligations by revising permit terms containing source testing requirements. Permi t Condition 33 now prescribe s the following : p erformance tests for emission of PM - 10 shall be conducted using 40 CFR Part 60, Appendix A, Methods 1 - 4 and Method 5 . F or VOC emissions, the per mit requires testing using EPA Method s 1 - 4, 18 and 25A to assure compliance . Because the permit issued by NSAQMD contains enforceable limits on PM and VOC emissions, and these emissions will not exceed PSD significance levels, EPA is n ot including PM and VOC limits in the final PSD permit. EPA’s f

inal SPI - Loyalton PSD permit addresses increases to NOx and CO levels . T o control NOx and CO emissions, SPI employs a noncatalytic reduction system with ammonia injection, and good combustion practices, to control NOx and CO, respectively. The analysis of proposed NOx and CO emissions increases indicate that expected concentrations fall within acceptable levels. Pleas e refer to the Ambient Air Quality Impact Report i n E Docket, http://www.regulations.gov/search/Regs/home.html#docketDetail?R=EPA - R09 - OAR - 2010 - 0226 . If commenters would like to discuss their issues further, you can contact Manny Aquitania at (415) 972 - 3977, or aquitania.manny@epa.gov . At this time, EPA does not find sufficient justification to conduct a pub lic hearing .