From:   Chuck French/RTP/USEPA/US  

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

Cc:   Amy Branning/DC/USEPA/US@EPA, cortney_higgins@omb.eop.gov,

hking@omb.gov, Paula VanLare/DC/USEPA/US@EPA  

Date:   04/06/2010 03:23 PM  

Subject: Re: Gold Mines ‐ follow‐up to teleconference

Hi Heidi,

During our phone conversation the other day, I recall that you

asked for more information about costs. Attached is a draft document

that describes the costs of controls and costs for monitoring. Please let me know

if you have comments or questions.

Thank You.

Chuck

(See attached file: Cost draft Apr 6 2010.doc)
ESTIMATES OF COSTS FOR THE PROPOSED MERCURY EMISSION STANDARDS 

FOR GOLD MINE ORE PROCESSING AND PRODUCTION 

DRAFT (4/6/2010) – Do Not Cite or Quote 

Metals and Minerals Group 

Sector Policies and Programs Division 

Office of Air Quality Planning and Standards 

U.S. Environmental Protection Agency 

Research Triangle Park, NC 

April 6, 2010 
Estimates of Costs for the Proposed Mercury Emission Standards for Gold Mine Ore 

Processing and Production 

1.0 Cost Estimates 

This section provides a summary of the estimated costs of the proposed rule and 

background details on how these costs were developed. The cost components include both the 

cost of mercury emission controls and the costs associated with monitoring, reporting, and 

recordkeeping (MRR). The costs of mercury emission controls for each affected facility are 

summarized in Table 1. There were cases where facilities had installed new or additional 

controls on thermal process units in 2008 – 2010 as a result of the Nevada Mercury Control 

Program (NMCP). The costs of these newly-installed controls are not included in the estimates 

presented here because the controls were installed prior to the proposed national standard. For 

example, mercury controls were installed at Round Mountain in 2008, at Cortez in 2008 and 

2009, and at Jerritt Canyon (roasters) in 2009. Details on the cost estimates for mercury 

emission controls are provided in Section 1.1. 

Table 1. Estimates of Mercury Emission Control Costs 

No. Facility Name Location

Hg 

reduction 

(lb/yr)

Estimates of mercury emission control costs 

Total capital 

cost ($2008) 

Total 

O&M cost 

($/yr) 

Total 

annual 

cost ($/yr) 

Cost 

effectiveness 

($/lb)

1 Goldstrike Elko, NV 109 658,512 135,968 198,131 1,800 

2 Denton-Rawhide Fallon, NV 31 135,100 103,900 116,653 3,800 

3 Florida Canyon Pershing Co., NV 98 367,868 165,382 200,109 2,100 

4 Gold Quarry Carlin, NV 141 199,400 44,222 63,045 450 

5 Bald Mountain Elko, NV 215 432,260 65,522 106,328 500 

6 Jerritt Canyon Elko, NV 131 141,933 31,966 45,365 350 

7 Lone Tree Valmy, NV 194 453,500 157,858 200,669 1,000 

8 Midas Midas, NV 15 430,000 150,421 191,013 13,000 

9 Ruby Hill Eureka, NV 30 305,224 88,629 117,442 4,200 

10 Twin Creeks Golconda, NV 686 1,654,551 916,105 1,055,067 1,500 

Totals 1,650 4,800,000 1,900,000 2,300,000 1,400 

Table 2 presents the costs of MRR and includes all of the gold mine ore processing and 

production facilities identified as having the thermal processes that would be subject to the 

proposed rule. All of these facilities will incur additional MRR costs; however, several are 

already controlled at levels that would be required by the rule and would incur no additional cost 

for mercury emission controls. The proposed rule provides options for MRR; consequently, 

costs are presented for a range of these MRR options that includes the higher and lower costs 

options. Details for the MRR cost estimates are provided in Section 1.2. 

2 
Table 2. Estimates of Costs for Monitoring, Reporting, and Recordkeeping 

No. Facility Name Location

Number of stacksa Higher estimates of MRR costs L

Roaster Other Not in 

NVb 

Monitoring 

capital 

Monitoring 

O&M 

Monitoring 

total annual 

Monito

capit

1 Goldstrike Elko, NV 2 15 120,000 212,696 229,784 2402 Coeur Rochester Lovelock, NV 3 40,000 31,634 37,330 403 Cortez Crescent Valley, NV 6 40,000 62,336 68,032 404 Cripple Creek Victor, CO 3 3 40,000 59,894 65,590 405 Denton-Rawhide Fallon, NV 4 40,000 41,868 47,564 406 Echo Bay/Kettle River Republic, WA 3 3 40,000 59,894 65,590 407 Florida Canyon Pershing County, NV 7 40,000 72,570 78,266 408 Fort Knox Fairbanks, AK 2 2 40,000 40,239 45,935 409 Gold Quarry Carlin, NV 1 10 80,000 132,399 143,791 140

10 Golden Sunlight Whitehall, MT 3 3 40,000 31,634 37,330 4011 Greens Creek Mine Greens Creek, AK 1 1 40,000 20,585 26,281 4012 Bald Mountain Elko, NV 5 40,000 52,102 57,798 4013 Jerritt Canyon Elko, NV 2 3 120,000 89,886 106,974 24014 Lone Tree Valmy, NV 5 40,000 52,102 57,798 4015 Marigold Valmy, NV 4 40,000 41,868 47,564 4016 Midas Midas, NV 3 40,000 31,634 37,330 4017 Ruby Hill Eureka, NV 4 40,000 41,868 47,564 4018 Round Mountain Round Mountain, NV 4 40,000 41,868 47,564 4019 Twin Creeks Golconda, NV 13 40,000 133,976 139,672 4020 Western Mesquite Brawley, CA 3 3 40,000 59,894 65,590 4021 Wharf Resources Lawrence Co., SD 2 2 40,000 40,239 45,935 40

Totals 5 103 17 1,040,000 1,351,184 1,499,280 1,341

a Number of stacks that must be monitored b Stacks at facilities outside of Nevada will incur additional costs for Method 29 testing (Method 29 testing is already required in Nevada).

3 
1.1 Cost of Mercury Emission Controls 

The primary sources of the cost estimates are the estimates developed by the gold mine 

ore processing and production facilities in their Phase 2 applications for the NMCP.a

 In these 

applications, individual facilities identified their process units that emit mercury and proposed 

additional controls for units that were not currently controlled. The cost estimates were based on 

applying carbon adsorbers to capture mercury emissions and were developed from the actual 

costs that had been incurred when installing them on other process units. Most of the facilities 

provided estimates of capital costs for the proposed emission control systems. For the few 

facilities that did not provide a capital cost estimate, a cost algorithm presented in the Phase 2 

application for the Twins Creek facility was used.1

 This algorithm uses the total installed cost 

($184,000) for a carbon adsorption system with a volumetric flow rate of 2,500 cubic feet per 

minute (cfm). The cost for applying carbon adsorbers to other process units was based on the 

process unit’s cfm scaled with an exponent of 0.6 to account for economy of size: 

Total installed capital cost = $184,000 * (cfm/2,500)0.6 

Many facilities did not provide an estimate of the annual operating and maintenance 

(O&M) costs. However, when a facility estimated annual O&M costs in their Phase 2 

application, those estimates were used in this analysis. For facilities without their own sitespecific estimates, O&M cost estimates were developed based on the reported costs for other 

units that had already been equipped with carbon adsorbers. The Goldstrike facility estimated 

the annual labor costs for carbon adsorbers as $4,968/yr for operating labor, $4,752/yr for 

maintenance labor, and $106/yr for carbon replacement labor for a total of $9,826/yr.2 The 

annual material and utility costs include the cost of replacement carbon and electricity for 

additional fan capacity to move the vent stream through the carbon adsorber. The Goldstrike 

facility estimated carbon replacement cost as $54,000/yr for a system designed for 4,400 cfm, or 

$12.27/cfm.2 The Florida Canyon facility estimated carbon replacement costs as $23,541 for a 

2,000 cfm system, or about $11.77/cfm.3 Carbon replacement costs presented here are based on 

the average of these two values ($12/cfm of design capacity). For the fan, Florida Canyon 

estimated annual energy costs as $3,291/yr for a 2,000 cfm system or $1.65/cfm.3

 The combined 

O&M costs were then estimated based on each process units flow rate and the following 

equation: 

O&M costs ($/yr) = $9,826 + $13.65 * cfm. 

The total installed capital cost was estimated based on a 20-year lifetime, an interest rate 

of 7 percent, and a capital recovery factor of 0.094. The total annualized cost is estimated from 

the O&M costs plus the annualized cost of capital. Table 4 presents the estimated mercury 

emission control costs for each of the process units and provides references for the estimates. 

 

a

 Copies of the Phase 2 applications are available at http://ndep.nv.gov/baqp/hg/clearinghouse.html. 

4 
5 

Table 4. Estimated Cost of Mercury Emission Controls for Affected Process Units 

No. Facility Unit Controla 

Mercury 

reduction 

(lb/yr) 

Flow 

(cfm)b 

Total 

capital costc 

Annual 

O&M 

coste 

Total 

annualized 

cost 

Cost 

effectiveness 

($/lb) 

1 Twin Creeks Juniper preg tanks CA 80.0 3,085 209,0004 51,936 71,666 896 

2 Twin Creeks Electrowinning CA 47.2 7,311 434,0005 109,621 150,591 3,189 

3 Goldstrike Carbon kilns WC, CA 109.2 4,406 658,512d 135,968 198,131 1,814 

4 Gold Quarry AARL carbon kiln CA 124.8 900 99,7006 22,111 31,523 253 

5 Florida Canyon Carbon kilns CA 91.5 2,000 183,9342 82,6917 100,054 1,094 

6 Florida Canyon 

Electrowinning, preg 

tanks, melt furnace CA 6.0 1,000 183,9347 82,6917 100,054 16,718 

7 Denton Rawhide Melt furnace CA 31.1 6,500 135,1008 103,9008 116,653 3,755 

8 Lone Tree Electrowinning CA 51.6 10,000 423,0009 146,326 186,257 3,604 

9 Lone Tree Preg tanks CA 142 125 30,50010 11,532 14,411 101 

10 Bald Mountain Electrowinning CA 208 496 183,36011 16,596 33,906 163 

11 Bald Mountain Melt furnace CA 6.3 4,220 248,90012 48,926 72,422 11,378 

12 Ruby Hill 

Electrowinning, preg 

tanks, melt furnace CA 25.3 2,250 230,00013 71,11813 92,830 3,674 

13 Ruby Hill Melt furnace CA 4.2 563 75,22414 17,511 24,612 5,888 

14 Gold Quarry Carbon kiln CA 16.0 900 99,7006 22,111 31,523 1,975 

15 Twin Creeks Melt furnace new CA 13.8 3,000 60,77614 50,776 56,513 4,103 

16 Twin Creeks Melt furnace old CA 16.9 3,000 60,77614 50,776 56,513 3,342 

17 Jerritt Canyon Melt furnace CA 131.1 1,622 141,933d 31,966 45,365 346 

18 Midas Furnace CA 14.6 10,300 430,00015 150,421 191,013 13,056 

19 Twin Creeks Autoclave WC, CA 527.8 7,778 890,00016 652,99616 719,784 1,364 

Subtotal Carbon Group (No. 1 through No. 17)f 1,104 3,458,349 1,056,557 1,383,025 1,250 

Subtotal Non-carbon Concentrate Group (No. 18) 15 430,000 150,421 191,013 13,100 

Subtotal Ore Pretreatment Group (No. 19) 528 890,000 652,996 719,784 1,400 

Total 1,647 4,778,349 1,859,974 2,293,822 1,400 a

 CA = carbon adsorber, WC = water chiller (e.g., refrigeration unit or condenser) 

b cfm = cubic feet per minute 

c Capital costs estimates come primarily from the referenced NDEP Phase 2 applications (exceptions have footnotes). d Estimated from : $184,000 * (cfm/2,500)0.6 (see text). e Unless a reference is given, estimated from : $9,826 + $13.65 * cfm (see text). 

f

 Costs and emission reductions are not included for Cortez because the facility installed carbon adsorbers in 2009 prior to 

MACT. 
1.2 MRR Costs 

 Two monitoring options are proposed for roasters: a mercury continuous emission 

monitoring system (CEMS) and periodic sorbent trap sampling. (Costs are not included for 

parametric monitoring of control devices because the facilities are already performing that 

monitoring as a result of State permit requirements.) The cost estimates for the mercury CEMS 

were developed from the EPA/OAQPS spreadsheet for estimating CEMS costs and are 

summarized in Table 5. 

Table 5. Cost Estimate for a Mercury CEMS 

Capital cost 

CEMS equipment (analyzer, sampling line data acquisition software, etc.) $90,000

Taxes and shipping $5,400

Install and check CEMS $4,320

Initial calibration $614

Total installed capital cost $100,334

Total annualized cost 

Daily operation of CEMS $4,608

Weekly checks of CEMS $2,938

Monthly checks of CEMS $2,765

Consumables $1,000

Annual QA $288

Recordkeeping and reporting $1.253

Subtotal $12,852

Capital recovery (10 years at 7%, CRF = 0.1424) $14,288

Total annualized cost $27,140

Costs for the sorbent trap monitoring for roasters were obtained from EPA testing 

personnel and from vendor quotes for the cost of sorbent tubes and mercury analyses. The 

capital cost is estimated as $40,000 for the sampling probe, pump, moisture conditioner, 

metering console, and data logger. The paired traps cost $150 each with an analysis cost of $200 

each. The estimated labor to install the traps, leak check, and set flow rates is 4 hours or 

$206/sample (at $51.51/hr). Weekly sampling would be required, which results in an annual 

sampling cost of $28,893/yr per stack. 

For process units other than roasters, the common mercury control device is a carbon 

adsorber. The proposed rule provides options for sampling carbon adsorbers: monthly sorbent 

trap sample (except going to weekly when the adsorber reaches 50 percent of the operating limit) 

or quarterly sampling of the carbon for mercury loading (going to monthly when 50 percent of 

capacity is reached). The capital cost for the sorbent trap sampling is the same as estimated 

above ($40,000). The annual cost is also estimated in a similar manner except the lower 

frequency of sampling results in lower sampling costs. The annual costs for sorbent trap 

sampling and analysis of carbon adsorbers based on monthly sampling for 10 months and weekly 

sampling for 2 months is $10,000/yr per stack that is sampled. The carbon bed sampling is much 

less expensive because there is no capital cost, the analytical cost is less ($110/sample instead of 

6
$200/sample), and the sampling frequency is less. The carbon bed sampling is estimated as 

$3,170/yr per stack that is sampled. 

Reporting and recordkeeping costs are based on an estimate of 16 hours per plant plus 4 

hours per stack that is monitored. The reporting costs for a facility were developed as shown in 

Table 6 ($931+ $233 * number of stacks). 

Table 6. Estimate of Reporting and Recordkeeping Costs 

 General Description 

 Mean 

Hourly 

Ratea

 

Rate with 

overheadb hr/plant $/plant hr/stack $/stack 

Environmental Engineer $32.13 $51.41 16 $823 4 $206 

Managementc $50.15 $80.24 0.8 $64 0.20 $16 

Office/Admin. Supportd $17.24 $27.58 1.6 $44 0.40 $11 

Total 18.4 $931 4.6 $233 a Labor rates are for private industry workers in the mining industry (NAICS 212200) and were taken from the 

United States Department of Labor, Bureau of Labor Statistics, May 2008, available at: 

http://www.bls.gov/oes/2008/may/naics4_212200.htm. b

 Overhead at 60%. 

c

Estimated as 5% of technical hours 

d Estimated as 10% of technical hours 

 The proposed rule would also require annual stack sampling for mercury emissions (e.g., 

using EPA Method 29). However, most of the gold mine facilities are located in Nevada, and the 

Nevada Division of Environmental Protection already requires annual sampling using Method 

29. Consequently, only facilities outside of Nevada would incur additional costs for stack 

sampling. The cost of Method 29 testing is estimated as $9,420 per stack test: 

Table 7. Estimate of Costs for Method 29 Testing 

Cost Description Cost

Equipment rental $1,850

Travel and lodging $1,625

Testing cost $2,611

Laboratory analysis $2,650

Test report $680

TOTAL $9,420

The MRR costs were estimated for each facility and are presented in Table 2. The costs 

are estimated from the cost functions described in this section and the number of roaster stacks, 

number of other (not roaster) stacks, and stacks not located in Nevada (for Method 29 testing) 

that must be monitored and tested. 

7
1.3 Beyond-the-Floor Costs 

The affected sources with carbon processes use carbon to recover the gold and have one 

or more of the following process units: carbon kilns, electrowinning, preg tanks, retorts, and 

melt furnaces. Approximately 9 of the 11 facilities for which data are available will need to 

improve control to meet the floor limits because these 9 plants have an average emission control 

performance that is above the Maximum Achievable Control Technology (MACT) floor average 

performance. We expect that the carbon process units not currently controlled will have carbon 

adsorbers installed to effectively control mercury emissions at the MACT floor level. 

Considering the very low mercury concentrations when the carbon processes are performing at 

the MACT level of control, it is difficult to identify a technology that can obtain efficient 

additional percent reductions from low concentration streams. The proposed rule requires close 

monitoring of the carbon adsorber so that the carbon can be replaced before breakthrough occurs 

and mercury is emitted. With careful monitoring, emission reductions on the order of 99 percent 

could be achieved by the carbon adsorbers installed to achieve the MACT floor level of control. 

For a beyond-the-floor analysis, we assumed that theoretically a second carbon adsorption 

system could be installed in series with the first one and would get an additional 90 percent 

reduction (a lower reduction because of the very low mercury concentrations that result from the 

MACT floor level of control). We acknowledge that there is uncertainty as to the additional 

percent reduction the second control system might achieve. The cost estimates for a second 

carbon adsorption system in series with the first one are presented in Table 8. The capital cost 

was estimated as $3.4 million with a total annualized cost of about $1.2 million/yr and a cost 

effectiveness of about $110,000/lb. 

The facilities with ore pretreatment processes have installed mercury scrubbers and 

venturi scrubbers on their roasters and autoclaves, respectively, to achieve the MACT floor for 

ore pretreatment processes. To achieve further reductions in mercury beyond what can be 

achieved using mercury scrubbers and venturi scrubbers, one beyond-the-floor option that was 

identified was the installation of both a refrigeration unit (or condenser) and a carbon adsorber 

on autoclaves. The Twin Creeks Mine evaluated this option as a potential way to reduce 

mercury emissions from their autoclaves.17 This additional control system would follow the 

existing venturi scrubbers to further reduce mercury emission from autoclaves. Because the 

exhaust is saturated with water, a refrigeration unit or condenser would be needed to remove 

water that would otherwise adversely affect the adsorptive capacity of the carbon adsorber. The 

capital costs were estimated as $525,000 for the refrigeration unit and $365,000 for the carbon 

adsorber.17 The operating cost was estimated as $537,000/yr for the refrigeration unit17 and 

$116,000/yr for the carbon adsorber (using the cost algorithm presented earlier for operating 

costs). The total annualized cost is estimated as $720,000/yr. Mercury emissions would be 

reduced by 528 lb/yr, assuming the system would achieve a conservative 70 percent reduction in 

mercury emissions from a level of 754 lb/yr, with a resulting cost effectiveness of $1,400/lb. 

Energy consumption would increase by about 730 megawatt-hours per year, primarily due to the 

refrigeration unit. Solid waste generation and disposal (spent carbon loaded with mercury) 

would increase by about 3 tons per year. 

8
Table 8. Estimate of Costs for a Second Carbon Adsorber for Carbon Processes 

No. Facility Unit 

Flow 

(cfm) 

Total 

capital 

costa 

Annual 

O&M 

costb 

Total 

annualized 

cost 

Mercury 

reduction 

(lb/yr) 

1 Twin Creeks Juniper P/B tanks 3,085 208,741 51,936 71,641 0.76 

2 Twin Creeks Electrowinning 7,311 350,300 109,621 142,689 0.45 

3 Goldstrike Carbon kilns 4,406 258,512 69,968 94,371 1.03 

4 Gold Quarry AARL carbon kiln 900 99,678 22,111 31,521 1.18 

5 Florida Canyon Carbon kilns 2,000 160,943 37,126 52,319 0.87 

6 Florida Canyon 

Electrowinning, P/B 

tanks, melt furnace 1,000 106,183 23,476 33,500 0.06 

7 Denton Rawhide Melt furnace 6,500 326,439 98,551 129,367 0.29 

8 Lone Tree Electrowinning 10,000 422,721 146,326 186,231 0.49 

9 Lone Tree P/B tanks 125 30,493 11,532 14,411 1.35 

10 Bald Mountain Electrowinning 496 69,718 16,596 23,178 1.97 

11 Bald Mountain Melt furnace 4,220 251,908 67,429 91,209 0.06 

12 Cortez P/B tanks 200 40,427 12,556 16,372 0.02 

13 Cortez Induction furnace 1,400 129,936 28,936 41,202 0.63 

14 Ruby Hill 

Electrowinning, P/B 

tanks, melt furnace 2,250 172,728 40,539 56,844 0.24 

15 Ruby Hill Melt furnace 563 75,224 17,511 24,612 0.04 

16 Gold Quarry Carbon kiln S0056,57 900 99,678 22,111 31,521 0.15 

17 Twin Creeks Melt furnace new 3,000 205,271 50,776 70,154 0.13 

18 Twin Creeks Melt furnace old 3,000 205,271 50,776 70,154 0.16 

19 Jerritt Canyon Melt furnace 1,622 141,933 31,966 45,365 1.24 

Totals 3,356,102 909,844 1,226,660 11 

 a Estimated from : $184,000 * (cfm/2,500)0.6 (see text). b Estimated from : $9,826 + $13.65 * cfm (see text). 

For the two facilities with non-carbon concentrate processes, we expect that Midas would 

need to add a carbon adsorber to its melt furnace to achieve the MACT floor level of control. 

For beyond the floor, we again assumed that the existing carbon adsorbers would be 

supplemented by adding a second control system of carbon adsorbers in series for all of the melt 

furnaces at both facilities. Using the cost algorithms presented earlier as a function of system 

flow rate, we estimated the capital cost for the second set of carbon adsorber control systems as 

$730,000, an annual operating cost of $237,000/yr, and a total annualized cost of $306,000/year. 

Emissions would be reduced by 7 lb/year, which results in a cost effectiveness of $45,000/lb. 

9
2.0 References 

1. Application for Phase 2 Operating Permit for Twin Creeks. Nevada Division of 

Environmental Protection. Page 3-21. 2008. 

2. Application for Phase 2 Operating Permit for Barrick Goldstrike. Nevada Division of 

Environmental Protection. Appendix 3, Table 3.4, Page 22. 2008. 

3. Application for Phase 2 Operating Permit for Florida Canyon. Nevada Division of 

Environmental Protection. Table 3.4, Page 19. 2008. 

4. Application for Phase 2 Operating Permit for Twin Creeks. Nevada Division of 

Environmental Protection. Table 14, Page 3-21. 2008. 

5. Application for Phase 2 Operating Permit for Twin Creeks. Nevada Division of 

Environmental Protection. Table 17, Page 3-24. 2008. 

6. Application for Phase 2 Operating Permit for Gold Quarry. Nevada Division of 

Environmental Protection. Table 20, Page 3-26. 2008. 

7. Application for Phase 2 Operating Permit for Florida Canyon. Nevada Division of 

Environmental Protection. Table 3.4, Page 18. 2008. 

8. Application for Phase 2 Operating Permit for Denton-Rawhide. Nevada Division of 

Environmental Protection. Table 3.4, Page 21. 2008. 

9. Application for Phase 2 Operating Permit for Lone Tree. Nevada Division of 

Environmental Protection. Page 3-10. 2008. 

10. Application for Phase 2 Operating Permit for Lone Tree. Nevada Division of 

Environmental Protection. Page 3-12. 2008. 

11. Application for Phase 2 Operating Permit for Bald Mountain. Nevada Division of 

Environmental Protection. Appendix 3, Page 21. 2008. 

12. Application for Phase 2 Operating Permit for Bald Mountain. Nevada Division of 

Environmental Protection. Appendix 3, Page 16. 2008. 

13. Application for Phase 2 Operating Permit for Ruby Hill. Nevada Division of 

Environmental Protection. Appendix 3, Table 3.8, Page 31. 2008. 

14. Application for Phase 2 Operating Permit for Twin Creeks. Nevada Division of 

Environmental Protection. Page 3-21. 2008. 

10
11

15. Application for Phase 2 Operating Permit for Midas. Nevada Division of Environmental 

Protection. Page 3-33. 2008. 

16. Application for Phase 2 Operating Permit for Twin Creeks. Nevada Division of 

Environmental Protection. Page 3-11. 2008. 

17. Application for Phase 2 Operating Permit for Twin Creeks. Nevada Division of 

Environmental Protection. Pages 3-11 and 3-12. 2008.