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Date: September 1, 2010

Subject: Minutes of the August 30-31, 2010 Meeting with Representative from the Gold 

Mining Industry

EPA Contract No. EP-D-06-118; EPA Work Assignment No. 4-06

RTI Project No. 0210426.004.006

From: Chuck French

OAQPS/SPPD/MMG (D243-02)

U.S. Environmental Protection Agency

Research Triangle Park, NC 27711

To: Docket ID No. EPA-HQ-OAR-2010-0239

I. Introduction

A meeting with representatives from the Gold Mining Industry was held at the U.S. 

Environmental Protection Agency facility in Research Triangle Park, NC on August 30 and 31, 

2010. The purpose of the meeting was to discuss the industry’s major comments to the proposed 

National Emission Standards for Hazardous Air Pollutants: Gold Mine Ore Processing and 

Production Area Source Category rule. This memorandum summarizes the major topics discussed 

during the meeting.

II. Attendees

Denise Kennedy, Holland and Hart

Joe Beetler, Newmont Mining Corporation

Melissa Barbanell, Barrick Senior Counsel, Regulatory Policy

Greg Schoen, Round Mountain Gold Corporation

Mike Tomko, Parsons Behle & Latimer

Kevin Lewis, Air Sciences Inc.

Chuck French, U.S. EPA, OAQPS

Marvin Branscome, RTI International

Gabrielle Raymond, RTI International

III. Discussion

The major topics discussed during the meeting included title V permitting, the new source 

MACT limit for carbon processes affected source, roaster monitoring, corrective actions for 

exceeding roaster control device operating limits, ore pretreatment affected source, fugitive 

emissions, hydrogen cyanide potential to emit, upper prediction limit calculation, how to measure 
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ore fed to autoclave, timing of compliance, wet scrubber monitoring, and compliance test 

methods. 

Attachment 1 contains the discussion items for the meeting submitted by Denise Kennedy 

prior to the meeting. 
Attachment 1 
From: Denise Kennedy <DKennedy@hollandhart.com> 

 

 To: Chuck French/RTP/USEPA/US@EPA 

 

 Cc: "'joe.beetler@newmont.com'" <joe.beetler@newmont.com>, 'John Mudge' 

<John.Mudge@Newmont.com> 

 

 Date: 07/22/2010 06:28 PM 

 

 Subject: RE: Gold Mines - meeting on 7/27/10 

 

Hi Chuck:

The primary issues we would like to discuss with you at next Tues's meeting are:

1. Roaster compliance monitoring requirements and significant concern with 

requirement to shut down roasters.

2. The new source MACT limit for the carbon group is not achievable by new, wellcontrolled sources

3. Need for 3 years to comply with rule, esp. given complexities of controlling 

autoclave emissions

4. Compliance testing and monitoring: Primary goals here should be to line up Nevada 

and Federal programs so Nevada sources are not subject to overlapping, duplicative 

and inconsistent requirements and to ensure that parameters monitored are directly 

related to mercury emissions

(a) initial compliance test in 6 months is a problem given limited source 

testers and number of sources; already have source testing for Nevada 

sources and will continue to have source testing during implementation of 

the rule

(b) calendar year should be basis for compliance, not 12 months based on 

when source test is done

(c) operational limits and parameter monitoring should be same as required 

by state and reflect what sources are already doing pursuant to their Phase 

1 NMCP permits

(d) parameters monitored need to be focused on those parameters that are 

directly related to mercury emissions

We look forward to discussing these issues with you more at the meeting on Tues. Denise