Source Emissions Test Report Round Mountain Gold Corporation: Smoky Valley Common Operation

Mercury Testing – EPA Method 29
MOPTC No. AP1041-2250

for System 24 - Refinery
and System 25 – Carbon Stripping and Regeneration

Report prepared for: Round Mountain Gold Corporation Smoky Valley Common Operation 1 Smoky Valley Mine Road Round Mountain, Nevada 89045

Report prepared by: Air Pollution Testing, Inc.
5530 Marshall Street Arvada, Colorado 80002

APT Project: RMG9183

## Certification

Team Leader Certification:

I certify that all of the sampling and analytical p rocedures and data presented in this report are authentic and accurate.

Justin Nylen Field Team Leader / Project Manager

Reviewer Certification:

I certify that all of the testing details and concl usions are accurate and valid.

Matt McGregor
Reviewer / Technical Writer

## Deviation Report

There were no significant deviations to the EPA Tes t Methods or abnormalities in the unit operating procedures.

## Table of Contents

1. Introduction....................................

................................................... ........ 1

2. Summary of Results..............................

................................................... . 2

3. Test Data and Sampling Methods..................

.......................................... 5

4. Summary of Operating / Process Data.............

........................................ 9

Tables & Figures

Table 1.1 : Emission Unit Identification...........

........................................ 1

Table 1.2 : Contact Personnel........................

........................................ 2

Table 2.1 : Test Results Summary, System 24........

............................ 3

Table 2.2 : Test Results Summary, System 25........................

......... 4

Figure 3.1 : Systems 24 and 25 Process Flow Diagram

....................... 6

Table 3.1 : Sampling Techniques............................................

......... 7

Table 3.2 : Sampling and Analytical Methods Summary

....................... 8

Appendices

Facility Process Information.......................................................... Appendix 1

Description of EPA Reference Methods.......................................

... Appendix 2

Method 29 Results and Sample Calculations..........................

......... Appendix 3

Field Data................................................................................. Appendix 4

Electronic Data CD..................................................................... Appendix 5

Sampling and Analysis Procedures/Schematics........................

....... Appendix 6

Laboratory Data......................................................................... Appendix 7

Calibration Information and Project Participants.......

........................ Appendix 8

Test Protocol and NMCP Comments.............................................. Appendix 9

Cyclonic Flow Checks...

.............................................................. Appendix 10

NMCP Source Test Summary Sheets........................................

.... Appendix 11APT Project RMG9183 RMG-SVCO – Hg Emissions Test Report

page 1 1. Introduction

Air Pollution Testing, Inc. (APT) was contracted by Round Mountain Gold Corporation (RMG) to conduct a series of source emission testin g services at the Smoky Valley Common Operation site near Round Mountain, Nye Coun ty, Nevada.

The purpose of the emissions testing program was to quantify the emission levels of total suspended particulate matter (PM) and mercury (Hg), from deep bed carbon
scrubber exhausts from the sources identified in Ta ble 1.1.

RMG-SVCO – PM and Hg Emissions Testing:
Emission Unit Identification

Permit No. System Thermal
Unit ID Source Description

TU 4.001* Carbon Reactivation Kiln

TU 4.002* Pregnant Solution Tank

TU 4.003* Barren Solution Tank 1 25

TU 4.004* Barren Solution Tank 2 AP1041-2250

24 TU 4.005 Electric Induction Furnace

* TU4.001 - TU4.004 controlled through a common dee p carbon bed scrubber

Table 1.1: Emission Unit Identification

Concurrently collected stack gas velocity and volum etric flow, oxygen (O 2 ), carbon dioxide (CO 2 ) and moisture (H 2 O) measurements were used to determine mass emission rates. All sampling was conducted with th e involved processes operating at normal capacity. Testing began on Monday, August 3 1, 2009 and concluded on Wednesday, September 2, 2009.

The stack testing was conducted pursuant to the Nev ada Mercury Control Program (NMCP) requirement for annual (2009) testing pursua nt to NAC 445B.3675.2(c).

Key contact personnel involved in the test program are provided in Table 1.2 on the following page.APT Project RMG9183 RMG-SVCO – Hg Emissions Test Report

page 2 RMG-SVCO – PM and Hg Emissions Testing: Emissions Testing Program Contact Personnel

Name, Title Company, Address Phone, FAX

Mr. Larry Kennedy, Acting, Compliance Supervisor NDEP - BAPC 901 S. Stewart Street, Suite 4001 Carson City, Nevada 89701 775-687-9495,
775-687-6396

Mr. Greg Schoen, Environmental Superintendent Round Mountain Gold Corporation Smoky Valley Mine No. 1 Smoky Valley Mine Road Round Mountain, Nevada 89045 775-377-3336,
775-377-3224

Mr. Chris Keefe, Director of Operations Air Pollution Testing, Inc.
5530 Marshall Street Arvada, Colorado 80002 303-420-5949 ext. 24,
303-420-5920

Table 1.2 : Emissions Testing Program Contact Pers onnel

2. Summary of Results

The results of the testing program are summarized i n Tables 2.1 and 2.2 for Systems 24 and 25, respectively. Any emission parameters not found in the tables can be found in Appendix 3 – Method 29 Results and Sample Calculati ons . The following abbreviations
are used in the tables:

°F – temperature, measured in degrees Fahrenheit (° F)

dscfm – dry standard (68°F, 1 atmosphere) cubic fee t per minute

O 2 (%vd) – oxygen concentration (dry volume percent)

CO 2 (%vd) – carbon dioxide concentration (dry volume p ercent)

H 2 O (%vw) – duct gas water vapor content (wet volume percent)

F 1⁄2 PM – the front half of the particulate train, i ncluding the acetone rinse and
filter

Hg – mercury

gr/dscf – grains per dry standard (68°F, 1 atmosphe re) cubic feet

lb/hr – pounds per hour

gpm – gallons per minuteAPT Project RMG9183 RMG-SVCO – Hg Emissions Test Report

page 3 ∆ P (“H 2 O) – pressure drop, in inches of water

RMG-SVCO – PM and Hg Emissions Testing: Test Results Summary, System 24 - Refinery Test Date(s): August 31 – September 1, 2009

Run #1 Run #2 Run #3 Average Limit (1)

Date 8/31 9/1 9/1

Start Time 13:00 8:37 11:04

Stop Time 15:04 10:17 12:48

Sampling Time (minutes) 120.0 96.0 96.0

Stack Temp. (°F) 92 92 94 93

Stack Flow (dscfm) 1,748 1,797 1,708 1,751

Hg Mass (g) 8.69E-04 1.91E-04 3.70E-04 4.77E-04

O 2 (%vd) 20.9 20.9 20.9 20.9

CO 2 (%vd) 0.0 0.0 0.0 0.0

H 2 O (%vw) 4.2 4.1 4.4 4.2

% isokinetic 102.2 102.2 102.4 102.3

Operational Data

Total Batch Weight (lbs) 430.9 382.5 327.4 380.3 720 (A), 136.3 (B)

Batch Time (min) 60 120 114 98

Process Material Hg Conc. (ppm) 140 200 160 167

Dynamic Scrubber Flow (gpm) 17 16 16 16 ≥ 12.0

Dynamic Scrubber ∆ P (“H 2 O) 4.4 5.0 4.4 4.6 ≥ 1.0

Carbon Bed Scrubber ∆ P (“H 2 O) 9.0 9.6 9.2 9.3 < 10.0

Emissions Data

F 1⁄2 PM (lb/hr) 0.05 1.02 0.09 0.39

F 1⁄2 PM (gr/dscf) 0.003 0.066 0.006 0.025

Total Hg (gr/dscf) 1.75E-04 4.68E-05 9.51E-05 1.06E-04

Total Hg (lb/hr) 2.62E-03 7.21E-04 1.39E-03 1.58E-03

(1) A – Permit Limit B – Protocol-Approved Limit

Table 2.1: Test Results Summary, System 24 – Refin eryAPT Project RMG9183 RMG-SVCO – Hg Emissions Test Report

page 4 RMG-SVCO – PM and Hg Emissions Testing: Test Results Summary, System 25 - Carbon Stripping and Regeneration Test Date(s): September 1 – 2, 2009

Run #1 Run #2 Run #3 Average Limit (1)

Date 9/1 9/2 9/2

Start Time 15:10 8:10 10:58

Stop Time 17:13 10:13 13:02

Sampling Time (minutes) 120.0 120.0 120.0

Stack Temp. (°F) 113 103 107 108

Stack Flow (dscfm) 125 124 126 125

Hg Mass (g) 2.79E-04 1.95E-04 3.01E-04 2.58E-04

O 2 (%vd) 20.4 19.8 19.9 20.0

CO 2 (%vd) 0.6 0.8 0.8 0.7

H 2 O (%vw) 9.4 8.6 9.4 9.1

% isokinetic 108.7 102.3 101.9 104.3

Operational Data

Carbon Throughput (tons/hr) 0.4 0.4 0.4 0.4 0.5 (A), 0.38 (B)

Propane Throughput (gal/hr) 14.95 14.91 14.91 14.92

Process Material Hg Conc. (ppm) 2.50 2.66 0.46 1.87

Dynamic Scrubber Flow (gpm) 18 18 18 18 ≥ 12.0

Dynamic Scrubber ∆ P (“H 2 O) 4 4 4 4 ≥ 1.0

Carbon Bed Scrubber ∆ P (“H 2 O) 7 8 8 8 < 10.0

Emissions Data

F 1⁄2 PM (lb/hr) 0.002 0.002 0.001 0.002

F 1⁄2 PM (gr/dscf) 0.002 0.001 0.001 0.002

Total Hg (gr/dscf) 7.20E-05 4.89E-05 7.44E-05 6.51E-05

Total Hg (lb/hr) 7.73E-05 5.18E-05 8.05E-05 6.99E-05

(1) A – Permit Limit B – Protocol-Approved Limit

Table 2.2: Test Results Summary, System 25 – Carbo n Stripping and RegenerationAPT Project RMG9183 RMG-SVCO – Hg Emissions Test Report

page 5 3. Test Data and Sampling Methods

3.1. Process Description

The pregnant solution from leach pads is pumped to the adsorption plant, where gold is
adsorbed from the solution onto activated carbon. The activated carbon containing the adsorbed gold is sent to carbon strip vessels, wher e it is stripped of the gold with a heated stripping solution. The pregnant strip solu tion exits the strip vessels to pregnant solution tank (TU-4.002) via a heat exchanger, whic h cools the pregnant strip solution and preheats the barren strip solution from barren solution tanks (TU-4.003 and TU4.004) on its way to the strip vessels. The stripp ed carbon is sent to the carbon reactivation kiln (TU-4.001), where it is thermally reactivated and returned to the adsorption tanks.

Exhausts from the kiln and the pregnant and barren solution tanks (System 25) are routed through a common stack and controlled by a d ynamic wet scrubber followed by a deep bed carbon scrubber, added as part of Nevada’s mercury early reduction credit

program.

The pregnant strip solution is pumped to the electr owinning cells for gold recovery. When the pregnant strip solution flows through the cells, an electric current plates the gold onto the steel wool cathodes. Cathode baskets , removed from the cells, are dismantled and subjected to a high-pressure spray t o remove the gold sludge from the steel wool. The gold sludge is dried and then smel ted in an electric-powered bar (doré) induction furnace (System 24 – Refinery – TU-4.005) and poured into gold bars. The gold bars are then shipped to an off-site refinery for further processing.

Particulate and mercury emissions from the furnace are controlled by a dynamic wet scrubber and a deep bed carbon scrubber as part of Nevada’s mercury early reduction credit program.

Process flow diagram for Systems 24 and 25 is prese nted in Figure 3.1. Stack Diagrams with stack gas sampling points can be foun d in Appendix 6 – Sampling and Analysis Procedures / Schematics

.APT Project RMG9183 RMG-SVCO – Hg Emissions Test Report

page 6 CARBON

ADSORPTION

TU-4.002

PREGNANT

SOLUTION

TANK TU-4.003

TU-4.004

BARREN

SOLUTION

TANKS EW CELLS TU-4.005

ELECTRIC

INDUCTION

FURNACE FROM LEACH

PADS

Pregnant

solution

Loaded

activated

carbon Hot

stripping

solution

HEAT

EXCHANGERSTRIP VESSELS

Pregnant strip

solution Barren solution

Pregnant strip

solution Gold

sludge

Dore'

OFF-SITE

REFINERY TU-4.001

CARBON

REACTIVATION

KILN Stripped

carbon

Reactivated

carbon DYNAMIC WET

SCRUBBER &

DEEP CARBON

BED SCRUBBER Air exhaust Air exhaust

Air exhaust

Air exhaust DYNAMIC WET

SCRUBBER &

DEEP CARBON

BED SCRUBBER

RMG-SVCO

SYSTEMS 24 & 25

PROCESS AND CONTROL DIAGRAM

Figure 3.1: RMG-SVCO Systems 24 and 25 Process Flo w Diagram

3.2. Absence of Cyclonic Flow

Cyclonic flow check datasheets can be found in Appendix 10 – Cyclonic Flow Checks

.

3.3. Operation Anomalies

There were no operation anomalies during this testi ng program.

3.4. EPA Test Methods

All testing was conducted in accordance with the fo llowing U.S. EPA source emission
test methods referenced in 40 CFR Part 60, Appendix A

.

Method 1 – Sample and Velocity Traverses for Statio nary Sources

Method 2 – Determination of Stack Gas Velocity and Volumetric Flow Rate

Method 3 – Gas Analysis for the Determination of Dr y Molecular WeightAPT Project RMG9183 RMG-SVCO – Hg Emissions Test Report

page 7 Method 4 – Determination of Moisture Content in Sta ck Gases

Method 5 – Determination of Particulate Matter Emis sions from Stationary Sources

Method 29 – Determination of Metals Emissions from Stationary Sources

The complete Method 29 sample calculations are prov ided in Appendix 3 – Method 29 Results and Sample Calculations

.

3.5. Process Material Sampling Procedures

In accordance with the NMCP, RMG collected material samples for Hg analysis. Table 3.1 provides the material sampling methods used for this analysis.

RMG-SVCO – PM and Hg Emissions Testing: Sampling Techniques
Source Thermal Unit ID Sampling Technique

Carbon
Reactivation Kiln TU 4.001 Sample of carbon was collected from each lot fed to kiln during each test run. At least one sample was taken per test

run. Pregnant Solution
Tank TU 4.002 One liquid sample was collected during each run for a total of three samples.
Barren Solution
Tank 1 TU 4.003 One liquid sample was collected during each run for a total of three samples.
Barren Solution
Tank 2 TU 4.004 One liquid sample was collected during each run for a total of three samples.

Electric Induction
Furnace TU 4.005 Sample of furnace feed material was collected prior to each furnace test run. Furnace melt /pour cycle duration were timed with the two hour test runs. A total of three samples
were collected. Table 3.1: Sampling Techniques

3.6. Test Program Summary

The testing program provided all necessary equipmen t and labor for the determination of all emission parameters detailed in Table 3.2 on the following page. Integrated samples were recovered on-site for shipment to the analytical facilities as indicated below. Stack gas volumetric flow data were collect ed concurrently to calculate mass emission rates in units of pounds per hour (lb/hr). Any applicable production data and control equipment operating parameters were monitor ed and provided to APT by Round Mountain Gold personnel.

At each source, triplicate test runs were conducted in which every effort was made to collect a minimum sample volume of 60 dry-standard cubic feet (dscf), up to a maximumAPT Project RMG9183 RMG-SVCO – Hg Emissions Test Report

page 8 sampling duration of 2 hours. Integrated samples w ere recovered by APT personnel and delivered via overnight shipment under chain-of -custody for subsequent analysis at the Test America laboratory in West Sacramento, Cal ifornia. All on-site recovery of samples were conducted in an analytical trailer dev oted specifically to sample recovery to minimize sample contamination risk. Once per sa mpling run, an integrated sample of stack gas was collected in a clean, leak-free Tedla r bag for subsequent wet-chemical analysis, for the determination of stack gas O 2 and CO 2 content.

In accordance with NDEP preference, a cyclonic flow check was performed at each stack prior to emissions testing. All QA/QC requir ements detailed in the appropriate reference test methods were strictly followed. All field data were recorded on appropriate data sheets. All pre-test / post-test equipment calibration / preparation were conducted as required in the applicable reference t est methods.

RMG-SVCO – PM and Hg Emissions Testing: Sampling and Analytical Methods

Parameter Sampling Method Analytical Method Laborat ory

gas flow Methods 1, 29 draft gauge, thermocouple, p itot tube

O 2 , CO 2 Method 3 wet chemical (Orsat instrument)

H 2 O Method 29 gravimetric APT, on-site

PM Method 29 gravimetric

Hg Method 29 CVAAS (Hg) Test America, West Sacramento, CA

Table 3.2: Sampling and Analytical Methods Summary

Mercury emissions were determined in accordance wit h EPA Method 29.

Each mercury sampling period consisted of extractin g a gas sample from the applicable sampling location at an isokinetic flow rate for a period sufficient to collect a minimum sample volume of 60 dscf or for a maximum duration of 120-minutes. The gas passed through a glass nozzle, a heated Teflon probe liner , across a heated, tared quartz fiber filter, through a series of 6 chilled glass impinge rs, and through a calibrated dry gas

meter.

At the start of mercury sampling, the first two imp ingers were filled with 100 ml of 10% hydrogen peroxide/5% nitric acid. The third and fo urth impingers each contained 100 ml of 4% potassium permanganate/10% sulfuric acid. The fifth impinger was empty. The sixth impinger contained 250 grams of dried sil ica gel.

Following each sampling period, the filter, a serie s of acetone and dilute nitric acid rinses (separate amber bottles) of the probe and no zzle, and the contents of theAPT Project RMG9183 RMG-SVCO – Hg Emissions Test Report

page 9 impingers were recovered for subsequent gravimetric , for front half particulate, and cold vapor atomic absorption spectroscopy (CVAAS) analys is. CVAAS was used for mercury (Hg) analysis.

An integrated sample of stack gas was collected eac h run and analyzed using an Orsat instrument. The laboratory data were combined with concurrently collected gas flow data to calculate the mercury emissions in units of pounds per hour (lb/hr).

As a QA/QC measure, a field blank of the impinger s olutions was analyzed concurrent with the emissions samples. A field blank train wa s also collected once during the test program and held for possible analysis.

4. Summary of Operating / Process Data

RMG provided all pertinent operational data. All r equired operating and control equipment parameters during the testing program for each source are shown in Appendix 1 – Facility Process Information

.

Appendices

This report contains the following appendices.

Appendix 1: Facility Process Information This appendix contains process throughput data and operating parameters collected during the testing program for each source. Certif ication by a facility representative and sampling and laboratory results for any material pr ocess analysis are also included in this appendix.

Appendix 2: Description of EPA Reference Methods This appendix provides description of reference tes t method procedures used in this testing program.

Appendix 3: Method 29 Results and Sample Calculati ons This appendix presents complete Method 29 results w ith sample calculations.

Appendix 4: Field Data This appendix provides all original raw field data sheets.

Appendix 5: Electronic Data CD This appendix includes a data CD with electronic sp readsheet in Microsoft Excel format containing the data collected during each PM test s ource run. A .pdf copy of this report complete with appendices is also included on the CD

.APT Project RMG9183 RMG-SVCO – Hg Emissions Test Report

page 10 Appendix 6: Sampling and Analysis Procedures/Schem atics Stack Diagrams with stack PM/Hg sampling points and the sampling train description and diagrams are provided in the appendix.

Appendix 7: Laboratory Data This appendix includes all laboratory certification s, analyses, results, QA/QC, and chain of custody(s).

Appendix 8: Calibration Information and Project Pa rticipants Meter box pre and post calibrations and project par ticipants are included in this appendix.

Appendix 9: Test Protocol and NMCP Comments A copy of the Test Protocol submitted to NMCP and t heir response letter and any correspondence are attached in this appendix.

Appendix 10: Cyclonic Flow Checks This appendix presents raw data showing verificatio n of the absence of cyclonic flow.

Appendix 11: NMCP Source Test Summary Sheets This appendix contains the NMCP Source Test Summary sheet for each test source.880 Riverside Parkway West Sacramento, CA 95605 tel 916.373.5600 fax 916.372.1059 www.testamericainc.com October 12, 2009

TestAmerica Project Number: G9I080219
PO/Contract: RMG 9183

Brad Ganong Air Pollution Testing
5530 Marshall Street Arvada, CO 80002

Dear Mr. Ganong,

This report contains the analytical result s for the samples received under chain of custody by TestAmerica on September 3, 2009. These samples are associated with your RMG 9183 project.

The test results in this report meet a ll NELAC requirements for parameters that accreditation is required or available. Any exceptions to NELAC requirements are
noted in the case narrative. The case narra tive is an integral part of this report.

If you have any questions, please feel free to call me at (916) 374-4333.

Sincerely,

Robert Weidenfeld Project Manager

G9i080219 TestAmerica West Sacramento (916) 373 - 5600 1 of 28 G9i080219 Mercury

### Table of Contents



## TestAmerica West Sacramento Project Number G9I080219

Case Narrative

Quality Assurance Program

Sample Description Information

Chain of Custody Documentation

Metals – M29 Mercury by CVAA Samples: 1, 2, 3, 4, 5, 6, 7, 8, 9 Sample Data Sheet Method Blank Report Laboratory QC Reports

G9i080219 TestAmerica West Sacramento (916) 373 - 5600 2 of 28 G9i080219 Mercury

## Case Narrative

TestAmerica West Sacramento Project Number G9I080219

AIR, Mercury by 7471A Sample: 1 The matrix spike and matrix spike duplicat e performed on the run 1 nitric/peroxide
fraction have recoveries below stated limit s. This is most likely due to the high concentration in the parent sample (great er than 4X the spike value). Acceptable laboratory control sample (LCS) data demons trate that the analytical system is in
control.

There were no other anomalies associated with this project.

G9i080219 TestAmerica West Sacramento (916) 373 - 5600 3 of 28 G9i080219 MercuryTestAmerica Laboratories West Sacramento Certifications/Accreditations

Certifying State Certificate # Certifying State Certificate #

Alaska UST-055 New York* 11666

Arizona AZ0708 Oregon* CA 200005 Arkansas 88-0691 Pennsylvania 68-1272

California* 01119CA South Carolina 87014

Colorado NA Texas T104704399-08-TX

Connecticut PH-0691 Utah* QUAN1

Florida* E87570 Virginia 00178 Georgia 960 Washington C1281 Hawaii NA West Virginia 9930C, 334

Illinois 200060 Wisconsin 998204680

Kansas* E-10375 NFESC NA

Louisiana* 30612 USACE NA Michigan 9947 USDA Foreign Plant 37-82605

Nevada CA44 USDA Foreign Soil P330-09-00055 New Jersey* CA005 US Fish & Wildlife LE148388-0

New Mexico NA Guam 09-014r
*NELAP accredited. A more detailed parameter list is available upon request. Updated 3/25/2009

QC Parameter Definitions

QC Batch : The QC batch consists of a set of up to 20 field samples that behave similarly (i.e., same matrix) and are processed using the same procedures, reagents, and standards at the same time.

Method Blank : An analytical control consisting of all reagents, which may include internal standards and surrogates, and is carried through the entire analytical procedure. The method blank is used to define the level of laboratory background contamination.

Laboratory Control Sample and Laboratory Control Sample Duplicate (LCS/LCSD): An aliquot of blank matrix spiked with known amounts of representative target analytes. The LCS (and LCSD as required) is carried through the entire an alytical process and is used to m onitor the accuracy of the analytical process independent of potential matrix effects. If an LCSD is performed, it may also be used to evaluate the precision of the process.

Duplicate Sample (DU): Different aliquots of the same sample are analyzed to evaluate the precision of an analysis.

Surrogates: Organic compounds not expected to be detected in field samples, which behave similarly to target analytes. These are added to every sample within a batch at a known concentration to determine the efficiency of the sample prep aration and analytical process.

Matrix Spike and Matrix Spike Duplicate (MS/MSD): An MS is an aliquot of a matrix fortified with known quantities of specific compounds and subjected to an entire analytical procedure in order to indicate the appropriateness of the method for a particular matrix. The percent recovery for the respective compound(s) is then calculated. The MSD is a second aliquot of the same matrix as the matrix spike, also spiked, in order to determine the precision of the method.

Isotope Dilution : For isotope dilution methods, isotopically labeled analogs (internal standards) of the native target analytes are spiked into the sample at time of extraction. These internal standards are used for quantitation, and monitor and correct for matrix effect s. Since matrix effects on method performance can be judged by the recovery of these analogs, there is little added benefit of performing MS/MSD for these methods. MS/MSD are only performed for client or QAPP requirements.

Control Limits: The reported control limits are either based on laboratory historical data, method requirements, or project data quality objectives. The control limits represent the estimated uncertainty of the

test results.

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