1. Beyond Federal Standards Nevada Mercury Emissions Control Program Colleen Cripps Nevada Division of Environmental Protection September 22, 2005

2. Nevada Mercury Emissions Program Overview  Situation in 2000  Voluntary Mercury Reduction Program  Program review in 2005  Enhanced Nevada Mercury Emissions Program

3. Situation Analysis  1998: Metal mining industry required to submit mercury emissions with Toxic Release Inventory (TRI)  2000: TRI numbers for 1998 released Four largest mines report 98% of the 21,098 pounds of mercury emissions  2001: EPA site tours to analyze sources and controls  2002: EPA and NDEP develop Voluntary Mercury Reduction Program with four largest metal mines

4. Objectives of Nevada Mercury Reduction Program  Through the Voluntary Mercury Reduction Program (VMRP): Achieve significant, permanent and rapid reductions in mercury air emissions from gold mining operations Achieve reductions through approaches that are most suitable for each individual mining facility Voluntary partnership encourages flexibility in technology innovation and greater reductions per transaction cost

5. Measurable goals set  33% reduction in mercury air emissions by the end of 2003  50% reduction by the end of 2005  Reduction measured using baseline emissions of 21,098 pounds of mercury air emissions reported in 2001

6. Nevada approach versus MACT  Had a regulatory approach been pursued in the case of the gold mines, it would have taken at least four years for the rules to be developed and another two years to allow companies to install MACT air emission controls.

7. Nevada program realized rapid mercury emissions reductions

8. Targeted and process specific approach  Examples of MACT equivalent VMRP emissions controls include: Wet Venturi Scrubber/Carbon Filtration installed at Barrick Goldstrike Mine in March 2002 Gas Quench Scrubber installed at Queenstake Jerritt Canyon West Roaster in 2002 Baghouses and SO2 Scrubber installed at the Newmont Gold Quarry Operations Area Ore Preheaters before 2001

9. 2005 Program review  A scheduled summer 2005 review of the VMRP program was accelerated: Greater involvement from other mining operations Improved reporting, record keeping and testing ICL notice of intent to sue Ability to formalize the original VMRP commitments Evaluate the need for additional controls

10. A brave new world  Need for broader coordination Increased national focus on Hg Three states, three EPA regional offices and three media (water, waste and air) are involved in Nevada mercury program  Research is needed, but NDEP does not have a research arm Impacts from data collection and research

11. NDEP focused on controls  NDEP determined that the most critical function of the agency is to focus on controlling mercury emissions NDEP Deputy Administrator Colleen Cripps said, “regardless of where the impact occurs, whether globally, regionally or locally, we’re doing everything that we can to control mercury air emissions in Nevada.”

12. Conclusion  Original program exceeded our expectations Significant reductions were achieved Reductions were realized better, faster and cheaper with the VMRP program Now moving into a new phase with the Nevada Mercury Control Program

13. Enhanced Nevada Mercury Control Program  NDEP is committed to: Increased involvement in the Nevada Mercury Control Program Improved consistency of monitoring, record keeping and reporting Evaluation of the need for additional mercury emissions controls Continued work with industry to develop innovative controls Development of a program that will formalize the commitments made by the industry