From: Chuck French/RTP/USEPA/US 

 

To: "King, Heidi R." <Heidi_R._King@omb.eop.gov> 

 

Cc: Branning.Amy@epamail.epa.gov; "Raymond, Gabrielle" 

<graymond@rti.org>; VanLare.Paula@epamail.epa.gov; "Marinshaw, Richard" 

<rjmarinshaw@rti.org>; Fruh.Steve@epamail.epa.gov; Blake.Wendy@epamail.epa.gov

 

 

Date: 12/15/2010 12:06 AM

 

Subject: RE: EO 12866 Interagency Review comments on Gold Mine Draft Final

Hi Heidi,

 With regard to the question on what comments we received on costs of 

controls. Attached is a summary of those. Let me know if you have questions.

Thanks.

Chuck

(See attached file: Specific Comments Regarding Cost of Controls.doc)
12/13/10

Specific Comments Regarding Cost of Controls

Newmont (EPA-HQ-OAR-2010-0239-0342)

Barrick (EPA-HQ-OAR-2010-0239-0274)

-Newmont supports EPA’s determination that beyond the floor controls would be prohibitively 

costly for the carbon process group. While EPA’s own numbers support this conclusion, 

Newmont believes the actual costs of adding a second carbon adsorber would exceed EPA’s cost 

estimate of $3.2 million capital costs and $1.2 million in annualized costs, likely depending upon 

the type of system designed, exhaust gas flow rate, and site-specific constraints on geometry and 

size.

Beyond-the-floor estimates for carbon processes affected source

-The Proposed Rule estimates capital costs of $890,000 with a total annualized cost of $720,000 

for autoclave controls. 

Beyond-the-floor estimates for autoclaves in ore pretreatment affected source

-While EPA’s cost estimate was based on information provided in Newmont’s Twin Creeks 

Phase 2 operating permit application for autoclaves submitted in February 2008, as Newmont has 

continued to investigate control options for the autoclaves, it has developed a better 

understanding of the actual costs for such control systems. Based on this new information, 

Newmont estimates that capital costs for autoclave controls will range from $18 million to $30 

million, and even higher, and annual operating costs could range from $2 million to $60 million, 

depending on which controls, if any, are determined to be technically feasible. 

-Barrick has evaluated what would be required to implement additional controls on its

autoclaves. For three autoclaves (having a total throughput rate of up to 500 tph) the capital cost 

associated with this equipment is estimated to between $30 million and $35 million. 

Additionally, EPA has significantly underestimated the energy requirements necessary to

accomplish the required cooling. Barrick estimates that energy requirements for this type of

control would be approximately 11,400 megawatt-hours per year, with an annual energy cost of

around $900,000. Finally, EPA has also underestimated the operating cost. Barrick estimates

the annual operating costs for this type of system will be greater than $2 million per year.

-The Final Rule estimates capital costs of $29,300,000 with a total annualized cost of $4,904,200 

and 11,400 MW hr/yr for controls on Newmont’s autoclaves to meet the MACT standard.
Costs to implement rule

-In proposed rule, EPA estimates capital cost of emission control at $5 million with a total 

annualized cost of $2.3 million per year, and capital costs for monitoring, reporting, and 

recordkeeping at $1 million to $1.3 million with total annualized cost of $0.8 million to $1.5 

million per year, depending on the monitoring option chosen. Yet, in Newmont’s experience and 

as it researches controls options pursuant to the Nevada mercury program, and has discussions 

with vendors, these numbers are severely underestimated and will likely be many times higher, 

as discussed earlier in these comments. Moreover, the estimate of energy requirements (2100 

MW hours) is low and will likely be higher, further adding to the costs and negative 

environmental impact of this unnecessary federal regulation.

-In final rule, EPA estimates capital cost of emission control at $35.7 million with a total 

annualized cost of $8 million per year, and capital costs for monitoring, reporting, and 

recordkeeping at $0.5 million to $1million with total annualized cost of $0.7 million to $1.5 

million per year, depending on the monitoring option chosen. The estimate of energy 

requirements is now 12,600 MW hr/yr.