1 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 (D 243

- 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 representative s from the Gold Mining Industry w as held at the U.S. Environmental Protection Agency facili ty in Research Triangle Park, NC on August 30 and 31

, 20 10 . The purpose of the meeting was to discuss the i ndustry’s major comments to the proposed National Emission Standards for Hazardous Air Pollutants: Gold Mine Ore Processing and

Production Area Sou rce 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 , Rou nd 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 meet ing 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 cy anide potential to emit, upper prediction limit calculation, how to measure2 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 K ennedy prior to the meeting.Attachment 1From: 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@Ne wmont.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, well

controlled 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, duplic ative 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 N evada 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 req uired 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