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 regar d 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 Propose d 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 submitte d 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 au toclave 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 w hat 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.

Addition ally, 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 ener gy 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 wi th 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 ex perience 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 e stimate 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 optio n chosen. The estimate of energy requirements is now 12,600 MW hr/yr.