I. Date: January 20, 2010

II. Subject: Meeting with Nevada Division of Environmental Protection (NDEP) and 

EPA

III. Location: Tempe, Arizona

IV. Attendees:

EPA

Chuck French, EPA/OAQPS/SPPD 

 Steve Frey, EPA/Region 9 

 Sona Chilingaryan, EPA/Region 9 

 NDEP

Mike Elges 

 Colleen Cripps 

 Larry Kennedy 

 Rob Bamford 

 RTI International

 Marvin Branscome 

 

V. Discussion Items: 

• A copy of the major discussion items is included in the attached agenda. 

• The NDEP representatives discussed the status of their mercury control program: NDEP 

has conducted inspections focusing on optimizing and improving emission controls, has 

issued some new permits, and expect to issue the remainder in 2010. 

• NDEP discussed their Mercury Emissions Data Management System (MEMS), which is 

an Access database available online and includes stack tests for mercury emissions from 

2006 to the present. 

• NDEP noted the continuing downward trend in mercury emissions with 2008 emissions 

being the lowest to date. 

• The test data that was invalidated by NDEP was discussed, and EPA agreed they would 

not use the data in the MACT analysis. 

• NDEP and EPA discussed the requirements in the NDEP permits for work practices and 

monitoring. NDEP prefers the parametric monitoring requirements as written in the 

permits and expressed reservations about the accuracy and usefulness of monitoring 

using a portable mercury vapor analyzer. 
• The EPA and NDEP reviewed EPA’s draft ranking of facilities based on pounds of 

mercury emissions per ton of ore, ton of loaded carbon, and ton of concentrate, and those 

facilities with controls, and those without controls. There was a general agreement that 

the data analysis and ranking identified the best performers and those who would 

probably have to add controls as a result of the proposed MACT limits. 

• EPA presented options under consideration for monitoring roasters. The EPA explained 

that one of the methods being considered for monitoring mercury emissions from 

roasters is a mercury continuous emissions monitoring system (CEMS), and another 

method being considered is sorbent trap sampling and analysis. The NDEP 

representatives expressed reservations about mercury CEMS, including the fact they had 

not been demonstrated on roasters and the lack of calibration standards for the mercury 

concentration levels found at roasters. 

• For carbon adsorbers, NDEP stated that portable mercury vapor analyzers (such as the 

Jerome and Lumex meters) were problematic because they are easily contaminated and 

give false readings. NDEP described their monitoring requirements: quarterly sampling 

of the mercury content of the carbon, increasing later to monthly sampling when a 

threshold is reached, and replacing the carbon before breakthrough. They also monitor 

pressure drop. 

• The EPA’s suggested grouping of three affected sources was discussed as were other 

ways of grouping or subcategorizing process units. NDEP suggested that concentrate 

would be a better basis for the carbon group, and EPA agreed to examine that suggestion 

in more detail. 

• NDEP recommended that mercury stack testing use Method 29 as they require with some 

minor additions or improvements they made for gold mines. 

• NDEP agreed to supply emissions test data for particulate matter (PM) for the affected 

gold mine emission sources. 

• EPA provided an update on the hydrogen cyanide testing. The flux box testing is 

expected to be completed by the end of January, and the fence line monitoring will be 

completed by mid-February. 
AGENDA 

NvMACT and Federal MACT for Gold Mines Meeting 

EPA/OAQPS, EPA Region 9, and NDEP 

Tempe, Arizona 

January 20, 2010 

Topics: 

1. Introductions 

2. Update on the Nevada Mercury Control Program, including additional information/data 

about the emissions, controls, Mercury Emissions Data Management System (MEMS). 

3. Discussion of regulatory approach and the method of demonstrating compliance under 

such an approach 

a. Data issues, such as invalid test data, potentially incorrect data, etc. 

b. Operational controls – discuss work practices and process operations in the NDEP 

permits to minimize emissions and how these might fit with the MACT. 

c. Parametric monitoring for carbon beds and mercury scrubbers, considerations for 

MACT and how these compare with the NMCP permits. 

d. Alignment of programs, comparison of NDEP data on source-by-source emissions 

and controls with data used in EPA’s draft rankings of the 3 groupings for 

MACT. 

4. Evaluation of Hg emissions 

a. Consideration of potential use of Mercury CEMs for Roasters 

b. Discussion of source test protocols. 

5. Available emissions data for PM-10 from thermal units and relationship to HAP 

metals. 

6. Update/status of cyanide testing, etc. 

7. Other Issues, Discussion, Next Steps