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Date: August 13, 2010

Subject: Minutes of the July 27, 2010 Meeting with Representative from Newmont Mining 

Corporation

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 (D243-02)

U.S. Environmental Protection Agency

Research Triangle Park, NC 27711

To: Docket ID No. EPA-HQ-OAR-2010-0239

I. Introduction

A meeting with representatives from Newmont was held at the U.S. Environmental 

Protection Agency facility in Research Triangle Park, NC on July 27, 2010. The purpose of the 

meeting was to discuss Newmont’s major comments to the proposed National Emission Standards 

for Hazardous Air Pollutants: Gold Mine Ore Processing and Production Area Source Category 

rule. This memorandum summarizes the major topics discussed during the meeting.

II. Attendees

Newmont Mining Corporation Representatives:

Denise Kennedy

Joe Beetler

John Mudge

Chuck French, U.S. EPA, OAQPS

Marvin Branscome, RTI International

Gabrielle Raymond, RTI International
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III. Discussion

The major topics discussed during the meeting included the potential Donlin Creek Mine 

in Alaska, the new source MACT standards for the carbon processes affected source, the notion 

of subcategorizing plants or facilities that do not require mercury retorts to meet the rule/ have 

low mercury concentration in their ore, the requirement to shut down the roaster when exceeding

of operating limits, the methodology for establishing operating limits during compliance testing, 

current parameters being monitored at Newmont’s facility with a roaster, and other ways to 

establish the operating limit ranges. 

Attachment 1 contains primary issues to discuss during the meeting submitted by Denise 

Kennedy prior to the meeting. 
Attachment 1 
From: 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@Newmont.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, wellcontrolled 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, duplicative 

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 Nevada 

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 required 

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