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 exp ect to issue the remainder in 2010.

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

an Access database available online and includ es 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 m onitoring 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 load ed carbon, and ton of concentrate, and those

facilities with controls, and t hose 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 fo r 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 tr ap sampling and analysis. The NDEP representatives expressed rese rvations about mercury CEMS, including the fact they had

not been demonstrated on roas ters and the lack of calibra tion standards for the mercury

concentration levels found at roasters.

• For carbon adsorbers, NDEP stated that porta ble 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 car bon before breakthrough. They also monitor pressure drop.

• The EPA’s suggested grouping of three affect ed 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 fo r particulate matter (PM) for the affected gold mine emission sources.

• EPA provided an update on the hydrogen cyan ide testing. The flux box testing is expected to be completed by the end of Ja nuary, 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 Progra m, including additional information/data about the emissions, controls, Mercury Emi ssions Data Management System (MEMS).

3. Discussion of regulatory approach and th e method of demonstrating compliance under such an approach

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

b. Operational controls – discuss work pract ices 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 compar e 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 cy anide testing, etc.

7. Other Issues, Discussion, Next Steps