Nevada Department of Conservation and Natural Resources ...Bureau of Air Pollution Control 901 South Stewart Street, Suite 4001 • Carson City, NV 89701-5249 ... upon the presentation

Facility ID No. A0003 Permit No. AP1041-2218 MERCURY OPERATING PERMIT TO CONSTRUCT: PHASE 2

Issued to: NEWMONT MINING CORPORATION – TWIN CREEKS MINE (HEREINAFTER REFERRED TO AS THE PERMITTEE)

Mailing Address: P.O. BOX 69, GOLCONDA, NEVADA 89414

Physical Address: 35 MILES NE OF GOLCONDA, NEVADA

General Facility Location: SECTIONS 12, 13, 24, 25 AND 36, T 39N, R 42E SECTIONS 4 – 10, 15 – 22, AND 28 – 33, T 39N, R 43E SECTIONS 4, 5, 9, AND 15, T 38N, R 43E SECTIONS 31 AND 32, T 40N, R 43E MDB&M (HA 66 KELLEY CREEK AREA) (HUMBOLDT COUNTY)

Thermal Unit List: (13 Thermal Units)

Juniper Mill Operations

A. System 01 – Induction Furnaces (Reference System 06 in AQOP AP1041-0723.03)

TU 4.001 Inductotherm Furnace 1 (S2.008)

TU 4.002 Inductotherm Furnace 2 (S2.008.1)

B. System 02 – Carbon Kiln (Reference System 03A in AQOP AP1041-0723.03)

TU 4.003 Carbon Kiln, Drum (S2.002)

C. System 03 – Mercury Retort A (Reference System 05A in AQOP AP1041-0723.03)

TU 4.004 Mercury Retort A (S2.006)

D. System 04 – Mercury Retort B (Reference System 05B in AQOP AP1041-0723.03)

TU 4.005 Mercury Retort B (S2.007)

E. System 05 – Juniper Solution Tanks (Reference System 33 in AQOP AP1041-0723.03)

TU 4.006 Pregnant Solution Tank A (S2.053)

TU 4.007 Pregnant Solution Tank B (S2.054)

TU 4.008 Barren Solution Tank (S2.055)

F. System 06 – Electrowinning Cells (Reference System 34 in AQOP AP1041-0723.03)

TU 4.009 Electrowinning Cells (Six) (S2.056)

Piñon Mill Operations

G. System 07 – Piñon Solution Tanks (Reference System 35 in AQOP AP1041-0723.03)

TU 4.010 Pregnant Tank (S2.057)

TU 4.011 Barren Tank (S2.058)

Nevada Department of Conservation and Natural Resources •••• Division of Environmental Protection

Bureau of Air Pollution Control

901 South Stewart Street, Suite 4001 • Carson City, NV 89701-5249

phone: 775-687-9349 • www.ndep.nv.gov/bapc




Issued to: NEWMONT MINING CORPORATION – TWIN CREEKS MINE

Thermal Unit List (continued)

Sage Mill Operations

H. System 08 – Sage Mill Autoclave 1 (Reference System 08A in AQOP AP1041-0723.03)

TU 4.012 Autoclave 1 (S2.009)

I. System 09 – Sage Mill Autoclave 2 (Reference System 08B in AQOP 1041-0723.03)

TU 4.013 Autoclave 2 (S2.010)




Page I - 3

Section I. General Conditions

The Permittee must comply with, but is not limited to, all conditions of Nevada Administrative Code (NAC) 445B.3611-3689 “Nevada

Mercury Air Emissions Control Program”, inclusive.

A. Records Retention. NAC 445B.3679.2(a)

The Permittee of a Mercury Operating Permit to Construct shall retain records of all required monitoring data and support

information for (5) years after the date of the sample collection, measurement, report or analysis. Supporting information includes,

without limitation, all records regarding calibration and maintenance of the monitoring equipment and all original strip-chart

recordings for continuous monitoring instrumentation.

B. Severability. NAC 445B.3679.2(b)

Each of the conditions and requirements of the Mercury Operating Permit to Construct is severable and, if any are held invalid, the

remaining conditions and requirements continue in effect.

C. Compliance/Noncompliance. NAC 445B.3679.2(c)

The Permittee must comply with all conditions of the Mercury Operating Permit to Construct. Any noncompliance constitutes a

violation and is grounds for:

1. An action for noncompliance;

2. The revoking and reissuing, or the terminating of the Mercury Operating Permit to Construct by the Director; or

3. The reopening or revising of the Mercury Operating Permit to Construct by the holder of the Mercury Operating Permit to

Construct as directed by the Director.

D. Defense to Noncompliance. NAC 445B.3679.2(d)

The need to halt or reduce activity to maintain compliance with the conditions of the Mercury Operating Permit to Construct is not a

defense to noncompliance with any conditions of the Mercury Operating Permit to Construct.

E. Cause. NAC 445B.3679.2(e)

The Director may revise, revoke and reissue, reopen and revise, or terminate the Mercury Operating Permit to Construct for cause.

F. Property Rights/Exclusive Privilege. NAC 445B.3679.2(f)

The Mercury Operating Permit to Construct does not convey any property rights or any exclusive privilege.

G. Information Request from Director. NAC 445B.3679.2(g)

The Permittee shall provide the Director, in writing and within a reasonable time, with any information that the Director requests to

determine whether cause exists for revoking or terminating the Mercury Operating Permit to Construct or to determine compliance

with the conditions of this Mercury Operating Permit to Construct.

H. Right to Entry. NAC 445B.3679.2(h)

The Permittee shall allow the Director or any authorized representative of the Director, upon the presentation of credentials, to:

1. Enter upon the premises of the Permittee where:

a. The thermal unit that emits mercury is located;

b. Activity related to mercury emissions is conducted; or

c. Records are kept pursuant to the conditions of the Mercury Operating Permit to Construct.

2. Have access to and copy, during normal business hours, any records that are kept pursuant to the conditions of the Mercury

Operating Permit to Construct;

3. Inspect, at reasonable times, any facilities, practices, operations, or equipment, including any equipment for monitoring or

controlling air pollution, that are regulated or required pursuant to the Mercury Operating Permit to Construct; and

4. Sample or monitor, at reasonable times, substances or parameters to determine compliance with the conditions of the Mercury

Operating Permit to Construct or applicable requirements.




Page I - 4

Section I. General Conditions (continued)

I. Certify True and Accurate. NAC 445B.3679.2(i)

A responsible official of the stationary source shall certify that, based on information and belief formed after reasonable inquiry, the

statements made in any document required to be submitted by any condition of the Mercury Operating Permit to Construct are true,

accurate and complete.

J. Yearly Reporting. NAC 445B.3679.3(b)(c)(d)

The Permittee will submit yearly reports including, but not limited to, throughput, production, fuel consumption, hours of operation,

emissions and mercury co-product. These reports will be submitted on the form provided by the Bureau of Air Quality Planning for

all emission units/systems specified on the form. The completed form must be submitted to the Bureau of Air Quality Planning no

later than March 1 annually for the preceding calendar year, unless otherwise approved by the Bureau of Air Quality Planning.

K. Facilities Operation. NAC 445B.227

The Permittee may not:

1. Operate a stationary source of air pollution unless the control equipment for air pollution that is required by applicable

requirements or conditions of the Mercury Operating Permit to Construct is installed and operating.

2. Disconnect, alter, modify or remove any of the control equipment for air pollution or modify any procedure required by an

applicable requirement or condition of the Mercury Operating Permit to Construct.

L. Excess Emissions. NAC 445B.232

1. Scheduled maintenance or testing or scheduled repairs which may result in excess emissions of regulated air pollutants

prohibited by NAC 445B.001 to 445B.3689, inclusive, must be approved by the Director and performed during a time designated

by the Director as being favorable for atmospheric ventilation.

2. The Director must be notified in writing of the time and expected duration at least 24 hours in advance of any scheduled

maintenance which may result in excess emissions of regulated air pollutants prohibited by NAC 445B.001 to 445B.3689,

inclusive.

3. The Director must be notified in writing or by telephone of the time and expected duration at least 24 hours in advance of any

scheduled repairs which may result in excess emissions of regulated air pollutants prohibited by NAC 445B.001 to 445B.3689,

inclusive.

4. The Director must be notified of any excess emissions within 24 hours after any malfunction or upset of the process equipment

or equipment for controlling pollution or during startup or shutdown of such equipment. The telephone number for the

notification is (775) 687-9349.

5. The Permittee, as the owner or operator of an affected facility, shall provide the Director, within 15 days after any malfunction,

upset, startup, shutdown, or human error which results in excess emissions, sufficient information to enable the Director to

determine the seriousness of the excess emissions. The information must include at least the following:

a. The identity of the stack or other point of emission, or both, where the excess emissions occurred.

b. The estimated magnitude of the excess emissions expressed in units of the applicable limitation on emission and the

operating data and methods used in estimating the magnitude of the excess emissions.

c. The time and duration of the excess emissions.

d. The identity of the equipment causing the excess emissions.

e. If the excess emissions were the result of a malfunction, the steps taken to remedy the malfunction and the steps taken or

planned to prevent the recurrence of the malfunction.

f. The steps taken to limit the excess emissions.

g. Documentation that the equipment for controlling air pollution, process equipment, or processes were at all times maintained

and operated, to a maximum extent practicable, in a manner consistent with good practice for minimizing emissions.

6. Each owner or operator shall ensure that any notification or related information submitted to the Director pursuant to this section

is provided in a format specified by the Director.




Page I - 5


M. Construction Requirements. NAC 445B.250

1. Early Reduction Credit (ERC), New, or Modified Thermal Units

The Permittee shall provide the Director written notification of:

a. The date that construction or reconstruction of an affected facility is commenced, postmarked no later than 30 days after

such date. This requirement shall not apply to mass-produced facilities which are purchased in completed form.

b. The anticipated date of initial startup of an affected facility, postmarked not more than 60 days and not less than 30 days

prior to such date.

c. The actual date of initial startup of an affected facility, postmarked within 15 days after such date.

N. Testing and Sampling NAC 445B.252

1. To determine compliance with NAC 445B.001 to 445B.3689, inclusive, before the approval or the continuance of an operating

permit or similar class of permits, the director may either conduct or order the owner of any stationary source to conduct or have

conducted such testing and sampling as the director determines necessary. Testing and sampling or either of them must be

conducted and the results submitted to the director within 60 days after achieving the maximum rate of production at which the

affected facility will be operated, but not later than 180 days after initial startup of the facility and at such times as may be

required by the director.

2. Tests of performance must be conducted and data reduced in accordance with the methods and procedures of the test contained

in each applicable subsection of this section unless the director:

a. Specifies or approves, in specific cases, the use of a method of reference with minor changes in methodology;

b. Approves the use of an equivalent method;

c. Approves the use of an alternative method, the results of which he has determined to be adequate for indicating whether a

specific stationary source is in compliance; or

d. Waives the requirement for tests of performance because the owner or operator of a stationary source has demonstrated by

other means to the director’s satisfaction that the affected facility is in compliance with the standard.

3. Tests of performance must be conducted under such conditions as the director specifies to the operator of the plant based on

representative performance of the affected facility. The owner or operator shall make available to the director such records as

may be necessary to determine the conditions of the performance test. Operations during periods of startup, shutdown and

malfunction must not constitute representative conditions of a performance test unless otherwise specified in the applicable

standard.

4. The Permittee shall give notice to the director 30 days before the test of performance to allow the director to have an observer

present. A written testing procedure for the test of performance must be submitted to the director at least 30 days before the test

of performance to allow the director to review the proposed testing procedures.

5. Each test of performance must consist of at least three separate runs using the applicable method for that test. Each run must be

conducted for the time and under the conditions specified in the applicable standard. For the purpose of determining compliance

with an applicable standard, the arithmetic means of results of the runs apply. In the event of forced shutdown, failure of an

irreplaceable portion of the sampling train, extreme meteorological conditions or other circumstances with less than three valid

samples being obtained, compliance may be determined using the arithmetic mean of the results of the other two runs upon the

director's approval.

6 All testing and sampling will be performed in accordance with recognized methods and as specified by the director.

7. The cost of all testing and sampling and the cost of all sampling holes, scaffolding, electric power and other pertinent allied

facilities as may be required and specified in writing by the director must be provided and paid for by the owner of the stationary

source.

8. All information and analytical results of testing and sampling must be certified as to their truth and accuracy and as to their

compliance with all provisions of NAC 445B.001 to 445B.3689, inclusive, and copies of these results must be provided to the

director no later than 60 days after the testing or sampling, or both.

O. SIP Article 2.5.4 Federally Enforceable SIP Requirement

Breakdown or upset, determined by the Director to be unavoidable and not the result of careless or marginal operations, shall not be

considered a violation of these regulations.




Page I - 6


P. Expiration and Extension. NAC 445B.3687

1. If construction will occur in one phase, a mercury operating permit to construct for a new or modified thermal unit that emits

mercury expires if construction is not commenced within 18 months after the date of issuance thereof or construction of the

thermal unit that emits mercury is delayed for 18 months after initiated. The Director may extend the date on which the

construction may be commenced upon a showing that the extension is justified.

2. If construction will occur in more than one phase, the projected date of the commencement of construction of each phase of

construction must be approved by the Director. A mercury operating permit to construct expires if the initial phase of

construction is not commenced within 18 months after the projected date of the commencement of construction approved by the

Director. The Director may extend only the date on which the initial phase of construction may be commenced upon a showing

that the extension is justified.

Q. Construction Requirements NAC 445B.250

1. The NvMACT for TU 4.001 through TU4.013, each, must be implemented not later than 24 months after the issuance of this

mercury operating permit to construct (NAC 445B.3646.3(a)(2)(i)).

a. The issuance date for TU 4.001 through TU 4.003 and TU 4.006 through 4.013 is XX.

b. The issuance date for TU 4.004 and TU 4.005 is October 5, 2009.

2. The Permittee shall provide the Director written notification of:

a. The date of implementation of NvMACT pursuant to NAC 445B.3679(a)(2)(i) postmarked within 15 days after such date

(NAC 445B.3679.2(g)).

R. Annual Reporting.

The Permittee shall:

1. Report mercury co-product on an annual basis (NAC 445B.3679(3)(d)).

2. Report the level of mercury emissions on an annual basis which must be based on mercury emissions test data (NAC

445B.3679(3)(c)).

************ End of General Conditions **************




Page II - 1

Section II. Specific Operating Conditions

A. Thermal Units #TU4.001 and TU4.002 location North 4,570.325 km, East 486.802 km , UTM (Zone 11)

A. System 01 – Induction Furnaces

TU 4.001 Inductotherm Furnace 1, Manufactured by Inductotherm Corp, Serial Number 750-72010-3-87

TU 4.002 Inductotherm Furnace 2, Manufactured by Inductotherm Corp, Serial Number Unknown

1. Air Pollution Equipment

a. Exhaust gases from TU4.001 and TU4.002 shall be ducted to a control system with 100% capture consisting of:

(1) Baghouse (DC-004) (manufactured by W.W. Sly Manufacturing)

(2) Carbon Filter (CF-006) (manufactured by Cameron Great Lakes)

b. Stack parameters

Height: 38 ft.

Diameter: 2.82 ft.

Stack temperature: 100° F

Flow: Volume flow rate of 15,625 dry standard cubic feet per minute (dscfm).

TU4.001 and TU4.002 are ducted to common controls and a common exhaust stack.

2. Operating Requirements (NAC445b.3679.3) a. Limitations of Operation

(1) The maximum allowable batch weight of retorted precious metal laden material for TU4.001 and TU4.002, each,

shall not exceed 2,000 pounds per batch. “Precious metal laden material” shall consist only of the following:

(a) Material loaded with precious metals such as gold and silver, along with various other metals that is produced by

electrowinning, the Merrill-Crowe process, flotation and gravity separation processes, and other gold concentration

or precipitation processes that has been retorted.

(b) Material collected from the wash-down of any equipment or surfaces contacted with precious metals that have been

concentrated through the various concentration methods employed by precious metal mines that has been retorted.

(c) Dust collected from DC-004.

(2) Mercury emissions from TU4.001 and TU4.002, each, shall not exceed 1.0 x 10-5 grains per dry standard cubic foot

(gr/dscf).

(3) TU4.001 and TU4.002 may not operate simultaneously.

(4) Hours

(a) TU4.001 and TU4.002, combined, may operate a total of 8,760 hours per calendar year.




Page II - 2

Section II. Specific Operating Conditions (continued)

A. Thermal Units # TU4.001 and TU4.002 (continued) location North 4,570.325 km, East 486.802 km, UTM (Zone 11)

2. Operating Requirements (NAC445b.3679.3) (continued)

b. Work Practice Standards NAC 445B.3679.3

(1) Inductotherm Furnaces (TU4.001 and TU4.002)

(a) Only precious metal laden material that has been retorted shall be fed into TU4.001 or TU4.002.

(b) DC-004 shall be operated at all times during the operation of TU4.001 or TU4.002 including startup and shutdown.

(2) Baghouse (DC-004)

(a) The pressure differential across DC-004 shall be maintained between 0 – 20 inches of water during operation.

(b) Inspect DC-004 in accordance with the manufacturer’s operation and maintenance maual and record the results, and

any corrective actions taken.

(3) Carbon Filter (CF-006)

(a) CF-006 shall contain 3 filter stages.

(b) CF-006 shall contain a minimum of 100 trays in each of the three stages of the filter module.

(c) CF-006 shall contain filter trays that are filled with approximately 15 pounds of sulfur-impregnated carbon in each

tray.

(d) The differential pressure across CF-006 shall be maintained between 0.5 and 8.0 inches of water during operation.

(e) Replace the sulfur-impregnated carbon in CF-006 according to the following schedule:

Conduct an initial sampling of a randomly chosen carbon filter tray on the first stage of the module 90 days after

the replacement of the trays in the module. A representative sample will be taken from the tray and analyzed. The

exact tray location will be recorded. Based upon sample results, an average carbon loading in percentage of

mercury by weight will be calculated. Quarterly sampling will take place until the average carbon loading reaches

50% mercury loading Monthly sampling will then commence until the carbon reaches 90% loading. The trays will

be replaced no later than 30 days after reaching 90% loading to ensure the saturation limit of the carbon is not

exceeded. The required mercury analysis shall be performed utilization one of the following methods:

1. EPA method 6020-Inductively Coupled Plasma-Mass Spectrometry;

2. EPA method 7471B- Mercury in Solid or Semisolid Waste (Manual Cold-Vapor Technique); or

3. An alternative test method as approved in advance by the Director.

(f) Any sulfur-impregnated carbon replaced in CF-006 shall be replaced with CGL CP48-SU sulfurized bituminous

coal based pelletized activated carbon or with equivalent performing mercury removal media.

(g) The original manufacturer’s design specifications for the sulfur-impregnated carbon used in CF-006 shall be kept

on site.

3. Compliance Testing, Monitoring, Recordkeeping and Reporting (NAC445b.3679.3) a. Compliance Testing

(1) Within 180 days of initial startup of TU4.001 and TU4.002 and annually thereafter, the Permittee shall conduct and

record a performance test for mercury on the exhaust stack of TU4.001 and TU4.002 consisting of three valid runs

utilizing US EPA Method 29 of 40 CFR Part 60 Appendix A. Each of the three test runs must collect a sample volume

of 0.85 dry standard cubic meters (30 dscf).

(2) Simultaneously, during the Method 29 compliance test, conduct and record a material assay from System 01. One

representative sample shall be taken for each test run. Total mercury content shall be determined using EPA Method

7471B (cold vapor atomic adsorption analysis) (or alternative test method approved by the Director).

(3) The Permittee shall comply with the requirements in Section I.N of this operating permit for all compliance testing.




Page II - 3


A. Thermal Units # TU4.001 and TU4.002 (continued) location North 4,570.325 km, East 486.802 km , UTM (Zone 11)

4. Compliance Testing, Monitoring, Recordkeeping and Reporting (NAC445b.3679.3) (continued)

b. Monitoring

The Permittee, upon issuance of this operating permit shall:

(1) Install, operate, calibrate, and maintain instrumentation to measure and record the following.

(a) The pressure differential across DC-004 in inches of water.

(b) The pressure differential across CF-006 in inches of water.

(2) Monitor the daily batch weight of precious metal laden material for TU4.001, in pounds, for each batch.

(3) Monitor the total daily hours of operation per batch for TU4.001, during each day of operation.

(4) Monitor the daily batch weight of precious metal laden material for TU4.002, in pounds, for each batch.

(5) Monitor the total daily hours of operation per batch for TU4.002, during each day of operation.

(6) Monitor the pressure differential for DC-004 in inches of water, once per batch operation vii. Monitor the inspections

of DC-004 quarterly.

(7) Monitor the pressure differential for CF-006 in inches of water, once per batch operation

(8) Monitor the number and movement or relocation of any trays from the second or third stage to the first stage in CF-

006. (9) Monitor the number of trays filled with sulfur-impregnated carbon that are replaced for each stage in CF-006.

(10) Monitor the sulfur-impregnated carbon in CF-006 for percentage of mercury by weight, quarterly until reaching 75%

of the carbon loading capacity and then monthly until reaching 90% of the carbon loading capacity.

(11) Monitor the sample tray location in CF-006 during carbon sampling.

c. Recordkeeping

The required monitoring, established in Section A.3.b. above shall be maintained in a contemporaneous log containing, at a

minimum, the following recordkeeping:

(1) The calendar date of any required monitoring.

(2) The total daily batch weight of precious metal laden material for TU4.001in pounds, for the corresponding date.

(3) The total daily hours of operation per batch for TU4.001for the corresponding date.

(4) The total daily batch weight of precious metal laden material for TU4.002 in pounds, for the corresponding date.

(5) The total daily hours of operation per batch for TU4.002 for the corresponding date.

(6) The pressure differential for DC-004 in inches of water, once per batch operation for the corresponding date.

(7) The inspections of DC-004 quarterly, for the corresponding date.

(8) The pressure differential for CF-006 in inches of water, once per batch operation for the corresponding date.

(9) The number and movement or relocation of any trays from the second or third stage to the first stage in CF-006 for the

corresponding date.

(10) The number and weight of trays filled with sulfur-impregnated carbon that are replaced for each stage in CF-006 for

the corresponding date.

(11) The sulfur-impregnated carbon in CF-006 for percentage of mercury by weight for the corresponding date.

(12) The sample tray location in CF-006 during carbon sampling, for the corresponding date.

d. Reporting

The Permittee shall promptly report to the Director any emissions and or throughput exceedances from System 01. The

report to the Director shall include probable cause and any action taken to correct the exceedance. For this Operating Permit

to Construct, prompt is defined as submittal of a report within 15 days of said deviation. This definition does not alter any

reporting requirements as established for reporting of excess emissions as required under NAC 445B.232 and under

condition I.L of this operating permit.




Page II - 4


B. Thermal Unit # TU4.003 Location North 4,570.312 km, East 486.883 km, UTM (Zone 11)

B. System 02 – Carbon Kiln, Drum

TU 4.003 Carbon Kiln, Drum Manufactured by Lockheed and Haggerty, Serial Number Unknown


a. Exhaust gases from TU4.003 shall be ducted to a control system with 100% capture consisting of:

(1) Wet Scrubber (WS-001) (manufactured by Lockheed and Haggerty)

(2) Hypochlorite Scrubber (HS-001) (manufactured by ADA)

b. Stack parameters

Height: 87 ft.

Diameter: 1.02 ft.

Stack temperature: 100° F

Flow: Volume flow rate of 1,300 dry standard cubic feet per minute (dscfm).

2. Operating Requirements (NAC 445B.3679.3) a. Limitations of Operation

(1) The maximum allowable throughput rate of carbon for TU4.003 shall not exceed 1.0 ton per any one-hour period.

(2) The interim mercury emission limit during the demonstration period for establishment of the final mercury emission

limit as established in Section II.B.3.e for TU4.003 shall not exceed 5.0 x 10-3 grains per dry standard cubic foot

(gr/dscf).

(3) Hours

(a) TU4.003 may operate a total of 8,760 hours per calendar year.

b. Work Practice Standards

(1) Carbon Kiln (TU4.003)

(a) Visually inspect the drum lining of TU4.003 for structural damage and cracks every 6 months.

(2) Wet Scrubber (WS-001)

(a) The water flow rate of WS-001 shall be maintained at or above 120 gallons per minute during operation.

(b) The differential pressure across WS-001 shall be maintained between 1.0 – 10 inches of water during operation.

(c) The nozzles on WS-001 shall be inspected and cleaned annually.

(d) WS-001 shall be operated at all times when TU4.003 is in operation.

(3) Hypochlorite Scrubber (HS-001)

(a) The recirculation flow rate of HS-001 shall be maintained at or above 35 gallons per minute during operation.

(b) The hypochlorite concentration of HS-001 shall be maintained at or above 1000 ppm during operation.

(c) The hypochlorite concentration shall be sampled once per day by iodometric titration.

(d) HS-001 shall be operated at all times when TU4.003 is in operation.




Page II - 5


B. Thermal Unit # TU4.003 (continued) Location North 4,570.312 km, East 486.883 km, UTM (Zone 11)

3. Compliance Testing, Monitoring, Recordkeeping, Reporting and Performance Testing (NAC 445B.3679.3)

a. Compliance Testing

(1) Within 180 days of initial startup of TU4.003, and annually thereafter, the Permittee shall conduct and record a

performance test for mercury on the exhaust stack of TU4.003 consisting of three valid runs utilizing US EPA Method

29 of 40 CFR Part 60 Appendix A. Each of the three test runs must collect a sample volume of 0.85 dry standard cubic

meters (30 dscf).




(3) The Permittee shall comply with the requirements in Section I.N of this operating permit for all compliance testing

b. Monitoring

The Permittee upon the issuance date of this operating permit for TU4.003 shall:


(a) The water flow of WS-001 in gallons per minute.

(b) The differential pressure across WS-001 in inches of water.

(c) The recirculation flow rate of HS-001 in gallons per minute.

(2) Monitor the total daily hours of operation for TU4.003.

(3) Monitor the total daily throughput rate of carbon from TU4.003 in tons.

(4) Monitor the water flow rate of WS-001 in gallons per minute once per day, during each day of operation.

(5) Monitor the differential pressure across WS-001 in inches of water once per day, during each day of operation.

(6) Monitor the recirculation flow rate of HS-001 in gallons per minute once per day, during each day of operation.

(7) Monitor the hypochlorite concentration of HS-001 in PPM, once per day during each day of operation.

c. Recordkeeping

The required monitoring, established in Section B.3.b. above, shall be maintained in a contemporaneous log containing, at a



(2) The total daily throughput rate of carbon from TU4.003 in tons, for the corresponding date.

(3) The total daily hours of operation for TU4.003, for the corresponding date.

(4) The water flow rate of WS-001 in gallons per minute, once per day during operation, for the corresponding date.

(5) The differential pressure of WS-001 in inches of water, once per day during operation, for the corresponding date.

(6) The recirculation flow rate of HS-001 in gallons per minute, once per day during operation, for the corresponding date.

(7) The hypochlorite con0centration of HS-001 in ppm, once per day during operation, for the corresponding date.

(8) The results of the visual inspection of TU 4.003 twice per calendar year, for the corresponding date.

(9) The results of the visual inspection of the nozzles on WS-001, for the corresponding date.

(10) The corresponding average hourly throughput rate in tons per hour. The average hourly throughput rate will be

determined from the total daily throughput rate C.(2) and the total daily hours of operation C.(3) above.




Page II - 6


B. Thermal Unit # TU4.003 (continued) Location North 4,570.312 km, East 486.883 km, UTM (Zone 11)

3. Compliance Testing, Monitoring, Recordkeeping, Reporting and Performance Testing (NAC 112B.3679.3)(continued)

d. Reporting






e. Performance Testing

(1) Upon the date of commencement of operations, the Permittee, shall begin a performance demonstration period for the

establishment of a mercury emissions limit for each thermal unit, which shall consist of (6) consecutive Method 29

source tests at approximate 6-month intervals. The performance demonstration period shall provide emissions data for

the establishment of a final NvMACT mercury emission limit for each thermal unit.

(2) The Permittee shall submit a test protocol and receive NDEP protocol approval for each performance demonstration

test. Performance tests must be performed at conditions that the Director deems representative of normal operations.

Only NDEP-validated tests may be used for the establishment of a final NvMACT mercury emission limit for each

thermal unit.

(3) The Permittee shall provide in each validated performance test report the records of all operating parameters and work

practice standards required in the Phase-2 Mercury Operating Permit to Construct as monitored and recorded during

each corresponding test of performance. Material sampling must be performed pursuant to the NDEP approved

protocol.

(4) Within 30-days of receiving a complete stack test report, the Director shall complete a review of the stack test report

and provide written notification to the Permittee with determination of applicability for the performance demonstration,

pursuant to the NDEP approved test protocol.

(5) The final NvMACT mercury emission limit shall be calculated as the maximum test value from the (6) corresponding

NDEP-validated performance demonstration tests plus one standard deviation in gr/dscf mercury. The standard

deviation value shall be calculated from the (6) corresponding NDEP-validated performance demonstration test values.

(6) The final NvMACT mercury emission limit shall be the applicable mercury emission limit permit requirement for the

Phase-2 Mercury Operating Permit to Construct expressed as gr/dscf mercury.

(7) A validated performance demonstration test may be used for the purpose of annual mercury emissions testing upon prior

approval by the Director.




Page II - 7


C. Thermal Unit #TU4.004 Location North 4,570.311 km, East 486.860 km, UTM (Zone 11))

C. System 03 – Mercury Retort A

TU 4.004 Mercury Retort A, manufactured by Lochhead - Haggerty, model number MR-15E



(1) Mercury Condenser (MC-001), manufactured by Lochhead – Haggerty, (operation in series with MC-002).


(3) Chiller, manufactured by Carrier

(4) Condensation Vessel (CV-001), manufactured by Lochhead – Haggerty.

(5) After Cooler with Mist Eliminator (AC-001), manufactured by Lochhead – Haggerty.

(6) Carbon Filter Column with Sulfur-Impregnated Carbon (CF-001), manufactured by Lochhead – Haggerty,

(operation in parallel with CF-002).



b. Stack Parameters

Height: 32.0 ft

Diameter: 0.33 ft

Stack temperature: 160°F

Flow: Maximum volume flow rate of 40 dry standard cubic feet per minute (dscfm).

TU4.004 is ducted to a single stack.


(1) The maximum allowable throughput rate of precious metal laden material for TU4.004 shall not exceed 0.7 ton per

batch. “Precious metal laden material” shall consist only of the following:

(a) Material loaded with precious metals such as gold and silver, along with various other metals that is produced by

electrowinning, the Merrill-Crowe process, flotation and gravity separation processes, and other gold concentration

or precipitation processes.

(b) Material collected from the wash-down of any equipment or surfaces contacted with precious metals that have been

concentrated through the various concentration methods employed by precious metal mines.

(2) Mercury emissions from TU4.004, shall not exceed 1.0 x 10-4 grains per dry standard cubic foot (gr/dscf).

(3) Precious metal laden material shall be retorted in pans specified by the retort manufacturer and not exceed the volume

capacity specified by the manufacturer, per pan.

(4) Hours

(a) TU4.004 may operate a total of 24 hours per day.

(b) TU4.004 may operate a total of 8,760 hours per calendar year.




Page II - 8


C. Thermal Unit #TU4.004 (continued) Location North 4,570.311 km, East 486.860 km, UTM (Zone 11))

3. Operating Requirements (NAC 445B.3679.3) (continued)

b. Work Practice Standards NAC 445B.3679.3

(1) TU4.004, MC-001, MC-002, CV-001, AC-001, CF-001, and CF-002 shall be operated in accordance with the

manufacturer’s recommendations at all times during operation, including start-up and shut-down periods.

(2) During heating, TU4.004 shall be placed under negative gauge pressure between 1 to 24 inches of mercury.

(3) TU4.004 shall automatically shut off when the negative gauge pressure is below 1 inches of mercury.

(4) The cooling water flow rate entering MC-001, MC-002, and AC-001 shall be maintained at or above 15 gallons per

minute.

(5) TU4.004 shall automatically shut off if the condenser water flow is absent.

(6) The water temperature exiting the chiller shall be maintained at or below 60°F.

(7) Condensed mercury from MC-001 and MC-002 shall be collected weekly.

(8) The exhaust gas temperature leaving AC-001 shall be maintained at or below 110°F.

(9) TU4.004 shall automatically shut off if the exhaust gas temperature reaches 160°F.

(10) CF-001 shall contain no less than 100 pounds of sulfur-impregnated carbon.


(12) Replace the sulfur-impregnated carbon in CF-001 and CF-002, each, according to the following schedule:

(a) The sulfur-impregnated carbon in CF-001 and CF-002 shall be sampled within 90 days after the notification of

implementation of NvMACT of CF-001 and CF-002 as required in Section I.Q. The depth of the sample probe

will be recorded. Using this sample, the percentage of mercury by weight shall be calculated. If more than one

sample is taken, calculate an average loading from the samples. Sampling will continue quarterly, at the same

depth until 50% of carbon loading capacity. Monthly sampling will then commence until the carbon reaches 90%

loading. The carbon will be replaced no later than 30 days after reaching 90% loading to ensure the saturation

limit of carbon is not exceeded. The required mercury analysis shall be performed utilizing one of the following

methods:




(b) The Permittee may request to the Director an alternative sampling and replacement schedule, wherein carbon may

be replaced every 3,060 hours of TU4.004 operation.

(13) Any sulfur impregnated carbon replaced in CF-001 and CF-002 shall be replaced with only the original

manufacturer’s design specification sulfur impregnated carbon, or equivalent performing mercury removal media.




Page II - 9


C. Thermal Unit #TU4.004 (continued) Location North 4,570.311 km, East 486.860 km, UTM (Zone 11)

3. Compliance, Monitoring, Recordkeeping and Reporting (NAC 445B.3679.3)


(1) Within 180 days of initial startup of TU4.004 and annually thereafter, the Permittee shall conduct and record a



meters (30 dscf).

(2) Prior to the Method 29 compliance test, conduct and record a material assay from System 03. One representative

sample shall be taken for each test run. Total mercury content shall be determined using EPA Method 7471B (cold

vapor atomic adsorption analysis) (or alternative test method approved by the Director).

(3) The Permittee shall comply with the requirements in Section I.N of this operating permit for all compliance testing

b. Monitoring

The Permittee, upon issuance date of this operating permit, for shall:

(1) Install, operate, calibrate, and maintain instrumentation to continuously measure and record the following:

(a) The gauge pressure of TU4.004, in inches of mercury.

(b) The cooling water flow rate entering MC-001, MC-002, and AC-001, in gallons per minute.

(c) The exhaust gas temperature exiting AC-001, in degrees Fahrenheit.

(d) The cooling water temperature exiting the chiller, in degrees Fahrenheit.

(2) Install, operate, calibrate, and maintain a vacuum interlock that will shut off the retort heating element if the retort

gauge pressure equals 1 inches of mercury of vacuum or less.

(3) Install operate, calibrate, and maintain a condenser water flow interlock which will shut off the retort heating element

if condenser water flow is not present.

(4) Install operate, calibrate, and maintain an exhaust gas temperature alarm which will notify the operator when the

exhaust gas from AC-001 equals a temperature of 110°F or more.

(5) Install, operate, calibrate, and maintain an exhaust gas temperature interlock which will shut off the retort heating

element if the temperature equals a temperature of 160°F or more.

(6) Monitor the daily batch weight of precious metal laden material, in tons, for each batch.

(7) Monitor the daily hours for each batch, during each day of operation.

(8) Monitor the gauge pressure on TU4.004, continuously per batch during operation.

(9) Monitor the cooling water flow rate entering MC-001, MC-002, and AC-001 continuously per batch during operation.

(10) Monitor the water temperature exiting the chiller, continuously per batch during operation.

(11) Monitor the amount of mercury drained from MC-001 and MC-002 weekly.

(12) Monitor the exhaust gas temperature exiting AC-001, continuously per batch during operation.

(13) Monitor CF-001 and CF-002 for percentage of mercury by weight, quarterly until reaching 14 percent capacity and

then monthly until reaching 15 percent capacity.

c. Recordkeeping

The required monitoring, established in Section C.3.b. above, shall be maintained in a contemporaneous log containing, at a



(2) The total daily weight of precious metal laden material per batch, in tons, for the corresponding date.

(3) The total daily hours of operation per batch, for the corresponding date.

(4) The gauge pressure on TU4.004, based on a one-hour period, for the corresponding date.

(5) The cooling water flow entering MC-001, MC-002, and AC-001, based on a one-hour period, for the corresponding

date.

(6) The water temperature exiting the chiller, based on a one-hour period, for the corresponding date.

(7) The amount of mercury collected from MC-001 and MC-002 weekly for the corresponding date.

(8) The exhaust gas temperature exiting AC-001, based on a one-hour period, for the corresponding date.




Page II - 10


C. Thermal Unit #TU4.004 (continued) Location North 4,570.311 km, East 486.860 km, UTM (Zone 11)

3. Compliance, Monitoring, Recordkeeping and Reporting (NAC 445B.3679.3) (continued)

c. Recordkeeping (continued)

(9) The date, time, and weight of each sulfur-impregnated carbon replacement for CF-001.


(11) The original manufacturer’s design specifications for the sulfur impregnated carbon used in CF-001 and CF-002 shall

be kept on site.

(12) The percentage of mercury by weight in the sulfur-impregnated carbon, for the corresponding date.

(13) The depth of the sample location, for each carbon column, for the corresponding date.

(14) The manufacturer’s specified heating temperature profiles for the TU4.004 shall be kept on site.

(15) The date, time, and corrective action taken for an alarm notification or an interlock shut-down, for the corresponding

date.

d. Reporting









Page II - 11


D. Thermal Unit #TU4.005 Location North 4,570.311 km, East 486.860 km, UTM (Zone 11)

D. System 04 – Mercury Retort B

TU 4.005 Mercury Retort B, manufactured by Lochhead - Haggerty, model number MR-15E





(3) Chiller, manufactured by Carrier.

(4) Condensation Vessel (CV-002), manufactured by Lochhead – Haggerty.

(5) After Cooler with Mist Eliminator (AC-002), manufactured by Lochhead – Haggerty.





b. Stack Parameters

Height: 32.0 ft

Diameter: 0.33 ft


Flow: Maximum volume flow rate of 40 dry standard cubic feet per minute (dscfm).

TU4.005 is ducted to a single stack.


(1) The maximum allowable throughput rate of precious metal laden material for TU4.005 shall not exceed 0.7 ton per

batch. “Precious metal laden material” shall consist only of the following:

(a) Precious metal bearing sludge and precipitate from the electro winning cells and zinc precipitate from the Merrill

Crowe circuit; and

(b) Mercury laden, precious metal bearing sulfonated carbon for recycling of the carbon in the CIL circuit.

(2) Mercury emissions from TU4.005 shall not exceed 1.0 x 10-4 grains per dry standard cubic foot (gr/dscf).

(3) Precious metal laden material shall be retorted in pans specified by the retort manufacturer and not exceed the volume

capacity specified by the manufacturer, per pan.

(4) Hours

(a) TU 4.005 may operate a total of 24 hours per day.

(b) TU 4.005 may operate a total of 8,760 hours per calendar year.




Page II - 12


D. Thermal Unit # TU4.005 (continued) Location North 4,570.311 km, East 486.860 km, UTM (Zone 11))

2. Operating Requirements (continued) (NAC 445B3679.3)


(1) TU4.005, MC-003, MC-004, CV-002, AC-002, CF-003, and CF-004 shall be operated in accordance with the

manufacturer’s recommendations at all times during operation, including start-up and shut-down periods.

(2) During heating, TU4.005 shall be placed under negative gauge pressure between 1 to 24 inches of mercury.

(3) TU4.005 shall automatically shut off when the negative gauge pressure is below 1 inches of mercury.

(4) The cooling water flow rate entering MC-003, MC-004, and AC-002 shall be maintained at or above 15 gallons per

minute.

(5) TU4.005 shall automatically shut off if the condenser water flow is absent.

(6) The water temperature exiting the chiller shall be maintained at or below 60°F.

(7) Condensed mercury from MC-003 and MC-004 shall be collected weekly.

(8) The exhaust gas temperature leaving AC-002 shall be maintained at or below 110°F.

(9) TU4.005 shall automatically shut off if the exhaust gas temperature reaches 160°F.



(12) Replace the sulfur-impregnated carbon in CF-003 and CF-004, each, according to the following schedule:

(a) The sulfur-impregnated carbon in CF-003 and CF-004 shall be sampled within 90 days after the notification of

implementation of NvMACT of CF-003 and CF-004 as required in Section I.Q. The depth of the sample probe

will be recorded. Using this sample, the percentage of mercury by weight shall be calculated. If more than one

sample is taken, calculate an average loading from the samples. Sampling will continue quarterly, at the same

depth until 50% of carbon loading capacity. Monthly sampling will then commence until the carbon reaches 90%

loading. The carbon will be replaced no later than 30 days after reaching 90% loading to ensure the saturation

limit of carbon is not exceeded. The required mercury analysis shall be performed utilizing one of the following

methods:




(b) The Permittee may request to the Director an alternative sampling and replacement schedule, wherein carbon may

be replaced every 3,060 hours of TU4.005 operation.

(13) Any sulfur impregnated carbon replaced in CF-003 and CF-004 shall be replaced with only the original

manufacturer’s design specification sulfur impregnated carbon, or equivalent performing mercury removal media.

3. Compliance, Monitoring, Recordkeeping and Reporting (NAC 445B.3679.3)


(1) Within 180 days of initial startup of TU4.005 and annually thereafter, the Permittee shall conduct and record a



meters (30 dscf).

(2) Prior to the Method 29 compliance test, conduct and record a material assay from System 04. One representative

sample shall be taken for each test run. Total mercury content shall be determined using EPA Method 7471B (cold

vapor atomic adsorption analysis) (or alternative test method approved by the Director).





Page II - 13


D. Thermal Unit # TU4.005 (continued) Location North 4,570.311 km, East 486.860 km, UTM (Zone 11))


b. Monitoring

The Permittee, upon issuance date of this operating permit shall:

(1) Install, operate, calibrate, and maintain instrumentation to continuously measure and record the following:

(a) The gauge pressure of TU4.005, in inches of mercury.

(b) The cooling water flow rate entering MC-003, MC-004, and AC-002 in gallons per minute..

(c) The exhaust gas temperature exiting AC-002, in degrees Fahrenheit.

(d) The cooling water temperature exiting the chiller, in degrees Fahrenheit.

(2) Install operate, calibrate, and maintain a vacuum interlock that will shut off the retort heating element if the retort

gauge pressure equals 1 inches of Hg of vacuum or less.

(3) Install, operate, calibrate, and maintain a condenser water flow interlock which will shut off the retort heating element

if condenser water flow is not present.

(4) Install, operate, calibrate, and maintain an exhaust gas temperature alarm which will notify the operator when the

exhaust gas from AC-002 equals a temperature of 110°F or more

(5) Install, operate, calibrate, and maintain an exhaust gas temperature interlock which will shut off the retort heating

element if the temperature equals a temperature of 160°F or more.

(6) Monitor the daily batch weight of precious metal precipitate, in tons, for each batch.

(7) Monitor the daily hours for each batch, during each day of operation.

(8) Monitor the gauge pressure on TU4.005, continuously per batch during operation.

(9) Monitor the cooling water flow rate entering MC-003, MC-004, and AC-002 continuously per batch during operation.

(10) Monitor the water temperature exiting the chiller, continuously per batch during operation.

(11) Monitor the amount of mercury drained from MC-003 and MC-004 weekly.

(12) Monitor the exhaust gas temperature exiting AC-002, continuously per batch during operation.

(13) Monitor CF-003 and CF-004 for percentage of mercury by weight, quarterly until reaching 14 percent capacity and

then monthly until reaching 15 percent capacity.

c. Recordkeeping

The required monitoring, established in Section D.3.b. above shall be maintained in a contemporaneous log containing, at a



(2) The total batch weight of precious metal laden material per batch, in tons, for the corresponding date.

(3) The total daily hours of operation per batch, for the corresponding date.

(4) The gauge pressure on TU4.005, based on a one-hour period, for the corresponding date.

(5) The cooling water flow entering MC-003, MC-004, and AC-002 based on a one-hour period, for the corresponding

date.

(6) The water temperature exiting the chiller, based on a one-hour period, for the corresponding date.

(7) The amount of mercury collected from MC-003 and MC-004, weekly for the corresponding date.

(8) The exhaust gas temperature exiting AC-002, based on a one-hour period, for the corresponding date.



(11) The original manufacturer’s design specifications for the sulfur impregnated carbon used in CF-003 and CF-004 shall

be kept on site.

(12) The manufacturer’s specified heating temperature profiles for the TU4.005 shall be kept on site.

(13) The percentage of mercury by weight in the sulfur-impregnated carbon, for the corresponding date.

(14) The depth of the sample location, in each carbon column, for the corresponding date.




Page II - 14


D. Thermal Unit # TU4.005 (continued) Location North 4,570.311 km, East 486.860 km, UTM (Zone 11)


d. Reporting









Page II - 15


E. Thermal Units # TU4.006 through TU4.008 location North 4,570.21 km, East 486.86 km, UTM (Zone 11)

E. System 05 – Juniper Solution Tanks

TU 4.006 Pregnant Solution Tank A, Manufacturer not specified, Equipment Number 040-482-061

TU 4.007 Pregnant Solution Tank B, Manufacturer not specified, Equipment Number 040-482-062

TU 4.008 Barren Solution Tank, Manufacturer not specified, Equipment Number 040-482-026


a. Exhaust gases from TU4.006, TU4.007, and TU4.008, shall be ducted to a control system with 100% capture consisting of:

(1) Wet Scrubber (WS-002) (manufactured by Clean Air Systems)

(2) Carbon Filter (CF-007) (manufactured by Camfil)

b. Stack parameters

Height: 82 ft.

Diameter: 1.45 ft.


Flow: 4,000 dry standard cubic feet per minute (dscfm).

TU4.006, TU4.007, and TU4.008 are ducted to WS-002 and CF-007 and a shared exhaust stack.

2. Operating Requirements (NAC445.3679.3) a. Limitations of Operation

(1) The maximum allowable throughput rate of precious metal-bearing solution for TU4.006, TU4.007, and TU4.008,

each, shall not exceed 360 gallons per minute (gpm).


limit as established in Section II.E.3.e for TU4.006, TU4.007, TU4.008, combined, shall not exceed 5.0 x 10-3 grains

per dry standard cubic foot (gr/dscf).

(3) TU4.006, TU4.007, TU4.008, may operate simultaneously.

(4) Hours

(a) TU4.006, TU4.007, TU4.008, each, may operate a total of 8,760 hours per calendar year.




Page II - 16


E. Thermal Units # TU4.006 through TU4.008 (continued) location North 4,570.21 km, East 486.86 km, UTM (Zone 11)

2. Operating Requirements (NAC445.3679.3) (continued)


(1) Wet Scrubber (WS-002)

(a) The water flow rate of WS-002 shall be maintained at or above 10 gallons per minute during operation.

(b) The differential pressure across WS-002 shall be maintained below 10 inches of water.

(c) The nozzles on WS-002 shall be inspected and cleaned annually.

(d) WS-002 shall be operated at all times during operation of TU4.006, TU4.007 and TU4.008.



(b) CF-007 shall contain filter trays that are filled with approximately 9 pounds of sulfur-impregnated carbon in each

tray.

(c) CF-007 shall contain a minimum of 72 trays in each of the two stages of the filter module.

(d) The differential pressure across CF-007 shall be between 2.0 and 12.0 inches of water during operation.


Conduct an initial sampling of a randomly chosen carbon filter tray on the first stage of a module 90 days after the

replacement of the trays in a module. A representative sample will be taken from the tray and analyzed using EPA

Method 7471A. The exact tray location will be recorded. Based upon sample results, an average carbon loading in

percentage of mercury by weight will be calculated. Quarterly sampling will take place until the average carbon

loading reaches 50% mercury loading. Monthly sampling will then commence until the carbon reaches 90%

loading. The trays will be replaced no later than 30 days after reaching 90% loading to ensure the saturation limit

of the carbon is not exceeded. The required mercury analysis shall be performed utilizing one of the following

methods:




(f) Any sulfur-impregnated carbon replaced in CF-007 shall be replaced with equivalent performing mercury removal

media.


on site.

3. Compliance Testing, Monitoring, Recordkeeping, Reporting and Performance Testing (NAC 445B.3679.3)


(1) Within 180 days of initial startup of TU4.006 – TU4.008, and annually thereafter, the Permittee shall conduct and

record a performance test for mercury on the exhaust stack of TU4.006 – TU4.008 consisting of three valid runs










Page II - 17



4. Compliance Testing, Monitoring, Recordkeeping, Reporting and Performance Testing (NAC 445B.3679.3) (continued)

b. Monitoring

The Permittee, upon implementation of the NvMACT for TU4.006, TU4.007, and TU4.008 shall:


(a) The water flow rate of WS-002 in gallons per minute.

(b) The differential pressure across WS-002 in inches of water.

(c) The differential pressure across CF-007 in inches of water.

(2) Monitor the daily hours of operation for TU4.006.

(3) Monitor the daily throughput rate of precious metal-bearing solution for TU4.006 in gallons.





(8) Monitor the water flow rate of WS-002 in gallons per minute, once per day, each day of operation.

(9) Monitor the differential pressure across WS-002 in inches of water, once per day, each day of operation.

(10) Monitor the differential pressure across CF-007 in inches of water, once per day, each day of operation.

(11) Monitor the number and movement or relocation of any trays from the second stage to the first stage in CF-007.

(12) Monitor the number of trays filled with sulfur-impregnated carbon that are replaced for each stage in CF-007.

(11) Monitor the sulfur-impregnated carbon in CF-007 for percentage of mercury by weight.


c. Recordkeeping

The required monitoring, established in Section E.4.b. above, shall be maintained in a contemporaneous log containing, at a



(2) The daily hours of operation for TU4.006, for the corresponding date.

(3) The total daily throughput rate of precious metal-bearing solution for TU4.006 in gallons, for the corresponding

date.

(4) The daily hours of operation for TU4.007.


date.

(6) The daily hours of operation for TU4.008.


date.

(8) The water flow rate of WS-002 in gallons per minute, once per day, each day of operation, for the corresponding date.

(9) The differential pressure across WS-002 in inches of water, once per day, each day of operation, for the corresponding

date. (10) The differential pressure across CF-007 in inches of water, once per day, each day of operation, for the corresponding

date.

(11) The number and movement or relocation of any trays from the second stage to the first stage in CF-007, for the

corresponding date.

(12) The number of trays filled with sulfur-impregnated carbon that are replaced for each stage in CF-007, for the

corresponding date.

(13) The sulfur-impregnated carbon in CF-007 for percentage of mercury by weight, for the corresponding date.

(14) The date, time, and weight of each sulfur-impregnated carbon replacement for CF-007, for the corresponding date.

(15) The sample tray location in CF-007 during carbon sampling, for the corresponding date.




Page II - 18



4. Compliance Testing, Monitoring, Recordkeeping, Reporting and Performance Testing (NAC 445B.3679.3) (continued)

d. Reporting














thermal unit.




protocol.


and provide written notification to the Permittee with determination of applicability for the performance

demonstration, pursuant to the NDEP approved test protocol.






(7) A validated performance demonstration test may be used for the purpose of annual mercury emissions testing upon

prior approval by the Director.




Page II - 19


F. Thermal Unit # TU4.009 location North 4,570.14 km, East 486.93 km, UTM (Zone 11)

F. System 06 – Electrowinning Cells

TU 4.009 Electrowinning Cells (Six), Manufactured by Summit Valley, Serial Number 338EC001 through 338EC006


a. Exhaust gases from TU 4.009 shall be ducted to a control system with 100% capture consisting of:

(1) Carbon Filter (CF-008) (manufactured by Camfil)

b. Stack parameters

Height: 41 ft.

Diameter: 2.5 ft.

Stack temperature: 100 °F

Flow: 9,216 dry standard cubic feet per minute (dscfm).

2. Operating Requirements (NAC445B.3679.3) a. Limitations of Operation

(1) The maximum allowable throughput rate of precious metal-bearing solution entering TU4.009 shall not exceed 360

gallons per minute.


limit as established in Section II.F.4.e for TU4.009 shall not exceed 5.0 x 10-3 grains per dry standard cubic foot

(gr/dscf).

(3) Hours

(a) TU4.009 may operate a total of 8,760 hours per calendar year.


(1) Electrowinning Cells (TU4.009)

(a) TU4.009 shall be covered by hoods during operation.



(b) CF-008 shall contain filter trays that are filled with approximately 15 pounds of sulfur-impregnated carbon in each

tray.

(c) CF-008 shall contain a minimum of 64 trays in each of the three stages of the filter module.

(d) The differential pressure across CF-008 shall be maintained between 0.10 and 1.50 inches of water during

operation.




Page II - 20


F. Thermal Unit # TU4.009 (continued) location North 4,570.14 km, East 486.93 km, UTM (Zone 11)

2. Operating Requirements (NAC445B.3679.3) (continued)

b. Work Practice Standards (continued)


Conduct an initial sampling of a randomly chosen carbon filter tray on the first stage of a module 90 days after the

replacement of the trays in a module. A representative sample will be taken from the tray and analyzed. The exact

tray location will be recorded. Based upon sample results, an average carbon loading in percentage by weight will

be calculated. Quarterly sampling will take place until the average carbon loading reaches 50% mercury loading.

Monthly sampling will then commence until the carbon reaches 90% loading. The trays will be replaced no later

than 30 days after reaching 90% loading to ensure the saturation limit of the carbon is not exceeded. The required

mercury analysis shall be performed utilizing one of the following methods:




(f) Any sulfur-impregnated carbon replaced in CF-008 shall be replaced with only the original manufacturer’s design

specification sulfur-impregnated carbon or with equivalent performing mercury removal media.


on site.

3. Compliance Testing, Monitoring, Recordkeeping, Reporting and Performance Testing (NAC 445B.3379.3) a. Compliance Testing

(1) Within 180 days initial startup of TU4.009, and annually thereafter, the Permittee shall conduct and record a



meters (30 dscf).





b. Monitoring



(a) The differential pressure across CF-008 in inches of water.


(3) Monitor the daily throughput rate of precious metal-bearing solution entering TU4.009 in gallons.

(4) Monitor the differential pressure across CF-008 in inches of water, once per day, each day of operation.

(5) Monitor the number and movement or relocation of any trays from the second or third stage to the first stage in CF-008.

(6) Monitor the number of trays filled with sulfur-impregnated carbon that are replaced for each stage in CF-008.






Page II - 21


F. Thermal Unit # TU 4.009 (continued) location North 4,570.14 km, East 486.93 km, UTM (Zone 11)

3. Compliance Testing, Monitoring, Recordkeeping, Reporting and Performance Testing (NAC445B.3679.3) (continued)

c. Recordkeeping

The required monitoring, established in Section F.3.b. above, shall be maintained in a contemporaneous log containing, at a




(3) The daily throughput rate of precious metal-bearing solution entering TU4.009 in gallons.

(4) The differential pressure across CF-008 in inches of water, once per day, each day of operation, for the corresponding

date.

(5) The number and movement or relocation of any trays from the second or third stage to the first stage in CF-008 for the

corresponding date.

(6) The weight and number of trays filled with sulfur-impregnated carbon that are replaced for each stage in CF-008 for the

corresponding date.


(8) The sample tray location in CF-008 during carbon sampling, for the corresponding date

d. Reporting














thermal unit.




protocol.














Page II - 22


G. Thermal Units # TU4.010 and TU4.011 location North 4,562.99 km, East 486.16 km, UTM (Zone 11)

G. System 07 – Piñon Solution Tanks

TU 4.010 Pregnant Tank, Manufacturer not specified, Serial Number not specified

TU 4.011 Barren Tank, Manufacturer not specified, Serial Number not specified

1. Air Pollution Equipment a. Exhaust gases from TU4.010 and TU4.011 shall be ducted to a control system with 100% capture consisting of:

(1) Carbon Filter (CF-009) (manufactured by Ionex)

b. Stack parameters

Height: 20 ft.

Diameter: 0.452 ft.

Stack temperature: 120 °F

Flow: Volume flow rate of 316 dry standard cubic feet per minute (dscfm).

TU4.010 and TU4.011 are ducted to common controls and a common exhaust stack.


(1) The maximum allowable throughput rate of precious metal-bearing solution for TU4.010 and TU4.011, each, shall

not exceed 360 gallons per minute.


limit as established in Section II.G.4.e for TU4.010 and TU4.011, combined, shall not exceed 5.0 x 10-3 grains per dry

standard cubic foot (gr/dscf).

(3) TU4.010 and TU4.011 may operate simultaneously.

(4) Hours

(a) TU4.010 and TU4.011 each, may operate a total of 8,760 hours per calendar year.


(1) Carbon Filter System (CF-009)

(a) The first stage of CF-009 shall contain no less than 720 pound of zinc chloride impregnated carbon designed for

ammonia removal

(b) The second stage of CF-003 shall contain no less than 720 pounds of sulfur impregnated carbon

(c) The differential pressure across CF-009 shall be maintained between 1.0 and 10.0 inches of water during

operation.




Page II - 23


G. Thermal Units # TU4.010 and TU4.011 (continued) location North 4,562.99 km, East 486.16 km, UTM (Zone 11)



(c) Replace the sulfur-impregnated carbon in CF-009 according to the following schedule:

The sulfur-impregnated carbon in CF-009 shall be sampled within 90 days after the notification of implementation

of NvMACT of CF-009 as required in Section I.Q. The depth of the sample probe will be recorded. Using this

sample, the percentage of mercury by weight shall be calculated. If more than one sample is taken, calculate an

average loading from the samples. Sampling will continue quarterly, at the same depth until 50% of carbon loading

capacity. Monthly sampling will then commence until the carbon reaches 90% loading. The carbon will be

replaced no later than 30 days after reaching 90% loading to ensure the saturation limit of carbon is not exceeded.

The required mercury analysis shall be performed utilizing one of the following methods:




(d) Any sulfur-impregnated carbon replaced in CF-009 shall be replaced with only the original manufacturer’s design

specification sulfur-impregnated carbon or with equivalent performing mercury removal media

(e) The original manufacturer’s design specifications for the sulfur-impregnated carbon used in CF-009 shall be kept

on site.

3. Compliance Testing, Monitoring, Recordkeeping, Reporting and Performance Testing (NAC 445B.3679.3) a. Compliance Testing

(1) Within 180 days of initial startup of TU4.010 – TU4.011, and annually thereafter, the Permittee shall conduct and

record a performance test for mercury on the exhaust stack of TU4.010 – TU4.011 consisting of three valid runs










Page II - 24


G. Thermal Units # TU 4.010 and TU 4.011 (continued) location North 4,562.99 km, East 486.16 km, UTM (Zone 11)


b. Monitoring



(a) The differential pressure of the Carbon Filter System (CF-009) in inches of water.



(4) Monitor the total daily hours of operation for TU4.011.


(6) Monitor the differential pressure of the Carbon Filter System (CF-009) in inches of water, once per day, each day of

operation.


c. Recordkeeping

The required monitoring, established in Section G.3.b. above, shall be maintained in a contemporaneous log containing, at a




(3) The daily throughput rate of precious metal-bearing solution for TU4.010 in gallons, for the corresponding date.


(5) The daily throughput rate of precious metal-bearing solution for TU4.011 in gallons, for the corresponding date.

(6) The differential pressure of the Carbon Filter System (CF-009) in inches of water, once per day, each day of operation,

for the corresponding date.



d. Reporting









Page II - 25


G. Thermal Units # TU4.010 and TU4.011 (continued) location North 4,562.99 km, East 486.16 km, UTM (Zone 11)










thermal unit.




protocol.














Page II - 26


H. Thermal Unit # TU4.012 location North 4,570.471 km, East 487.007 km, UTM (Zone 11)

H. System 08 – Sage Mill Autoclave 1 (Phase 1)

TU 4.012 Autoclave 1, Manufacturer Eaton Metals, Serial Number not specified



(1) Primary Quench Vessel (QV-001) (manufacturer not specified)

(2) Primary Venturi Scrubber (VS-001) (manufacturer not specified)

(3) Secondary Quench Vessel (QV-002) (manufacturer not specified)

(4) Secondary Venturi Scrubber (VS-002) (manufacturer not specified)

At least three of the four listed above shall be in operation during operation of TU4.012

(5) Carbon Filter (CF-011) (manufacturer not specified) – Consisting of two parallel trains of carbon beds. Each train

shall have three carbon beds: a Volatile Organic Compound (VOC) bed, a primary mercury bed, and a secondary

mercury bed.

b. Both TU4.012 and TU4.013 share a backup or standby Carbon Filter (CF-013). CF-011 Consists of two parallel trains of

carbon beds. Each train shall have three carbon beds: a Volatile Organic Compound (VOC) bed, a primary mercury bed, and

a secondary mercury bed.

c. Stack Parameters

Height: 112 ft.

Diameter: 1.83 ft.

Stack temperature: approximately 163°F

Flow: approximately 11,400 dry standard cubic feet per minute (dscfm).


(1) The maximum allowable throughput rate of gold ore for TU4.012 shall not exceed 300.0 tons per hour.


(3) Hours

TU4.012 may operate a total of 8,760 hours per calendar year.


(1) Primary and Secondary Venturi Scrubbers (VS-001 and VS-002) and Primary and Secondary Quench Vessels (QV-001

and QV-002)

(a) The combined water flow rate of QV-001, VS-001, QV-002 and VS-002 shall be maintained at or above 840

gallons per minute.

(b) The exhaust gas temperature exiting VS-002 shall be maintained at or below 180°F.




Page II - 27


H. Thermal Unit # TU4.012 (continued) location North 4,570.471 km, East 487.007 km, UTM (Zone 11)



(3) Carbon Filter (CF-011 or CF-013)

(a) The exhaust pressure relief bypass for System 08 may be operated 100 hours per year. The exhaust pressure relief

bypass shall be ducted through a cyclone and its hours of operation will be based on parametric monitoring of the

exhaust gas through the cyclone.

(b) Except for the 100 hours of operation allocated for the exhaust pressure relief bypass, during operation exhaust gas

shall be sent through a minimum of one Carbon Filter, either CF-011 or CF-013.

(c) Carbon Filters CF-011 and CF-013, each, shall consist of 2 parallel trains of carbon beds. Each carbon bed train

shall contain three carbon beds; a VOC bed, a primary mercury bed, and a secondary mercury bed.

(d) Each VOC bed in carbon filter CF-011 and CF-013 shall contain no less than 3,000 pounds of activated carbon.

(e) Each primary mercury bed in carbon filter CF-011 and CF-013 shall contain no less than 8,000 pounds of activated

carbon.

(f) Each secondary mercury bed in carbon filter CF-011 and CF-013 shall contain no less than 17,000 pounds of

activated carbon.

(g) The differential pressure across the carbon filter in use shall be maintained at or below 83.1 inches of water.

(h) The relative humidity entering the carbon filter in use shall be maintained at or below 70%.

(i) Replace all of the sulfur-impregnated carbon in CF-011and CF-013 according to the following schedule:

The sulfur-impregnated carbon in CF-011and CF-013 shall each be sampled 90 days after the notification of start-

up for TU4.012. CF-011 and CF-013 will each include sampling canisters that will contain the equivalent carbon

depth as the primary mercury bed. The canisters will receive a slip stream of the process gas during operation of the

system. Once every calendar quarter, a sample canister will be analyzed for mercury. The percentage of mercury by

weight shall be calculated. The sampling canister will be analyzed quarterly until 50% of the carbon loading

capacity of 20% by weight, as specified by the manufacturer, is reached. Upon reaching 50% of the carbon loading

capacity of 20% by weight, sampling of the canister will occur monthly until 90% of the carbon loading capacity of

20% is reached. The carbon in the primary mercury bed shall be replaced with an equivalent performing sulfur-

impregnated carbon no later than 30 days after reaching 90% of the carbon loading capacity of 20% by weight. The

required mercury analysis shall be performed utilizing one of the following methods:




(j) Any sulfur-impregnated carbon replaced in CF-011 and CF-013 shall be replaced with only the original

manufacturer’s design specification sulfur-impregnated carbon or with equivalent performing mercury removal

media.

(k) The original manufacturer’s design specifications for the sulfur-impregnated carbon used in CF-011 and CF-013

shall be kept on site.

(l) An alternative adsorbent (e.g., halogenated carbon) may be used in place of the sulfur-impregnated carbon upon

approval by the Director. The alternative adsorbent shall follow the same sampling and change-out schedule

described above using its own proven loading capacity for mercury.




Page II - 28


H. Thermal Units # TU4.012 (continued) location North 4,570.471 km, East 487.007 km, UTM (Zone 11)

3. Compliance Testing, Monitoring, Recordkeeping and Reporting (NAC 445B.3679.3)





meters (30 dscf).





b. Monitoring


(1) Install, operate, calibrate, and maintain instrumentation to continuously measure and record the following.

(a) The combined water flow rate for VS-001, VS-002, QV-001 and QV-002 in gallons per minute.

(b) The temperature of the exhaust gas exiting VS-002, in degrees Fahrenheit.

(c) The differential pressure across CF-011 or CF-013 in inches of water.

(2) The calendar date of any required monitoring and recordkeeping.

(3) Monitor the throughput rate of gold ore for TU4.012 in tons continuously during operation.


(5) Monitor the combined water flow rate for VS-001, VS-002, QV-001 and QV-002 in gallons per minute continuously

during operation.

(6) Monitor the exhaust gas temperature exiting VS002 in degrees Fahrenheit continuously during operation.

(7) Monitor the differential pressure across CF-011 or CF-013 in inches of water continuously during operation.

(8) Monitor the sulfur-impregnated carbon in CF-011 or CF-013 for percentage of mercury by weight.




Page II - 29


H. Thermal Units # TU4.012 (continued) location North 4,570.471 km, East 487.007 km, UTM (Zone 11)

3. Compliance Testing, Monitoring, Recordkeeping and Reporting (NAC 445B.3679.3) (continued)

c. Recordkeeping

The required monitoring, established in Section H.3.b. above, shall be maintained in a contemporaneous log containing, at a




(3) The daily throughput rate of gold ore for TU4.012 in tons, for the corresponding date.

(4) The combined water flow rate for VS-001, VS-002, QV-001 and QV-002 , in gallons per minute, once per 12 hour

shift, for the corresponding date

(5) The exhaust gas temperature exiting VS-002, in degrees Fahrenheit, once per 12 hour shift, for the corresponding date.

(6) The differential pressure across CF-011 or CF-013 in inches of water, once per 12 hour shift, for the corresponding

date.

(7) The sulfur-impregnated carbon in CF-011 or CF-013 for percentage of mercury by weight, for the corresponding date.




d. Reporting









Page II - 30


I. Thermal Unit # TU4.012 location North 4,570.514 km, East 487.031 km, UTM (Zone 11)

I. System 09 – Sage Mill Autoclave 2 (Phase 2)

TU 4.013 Autoclave 2, Manufacturer Eaton Metals, Serial Number not specified



(1) Primary Quench Vessel (QV-003) (manufacturer not specified)

(2) Primary Venturi Scrubber (VS-003) (manufacturer not specified)

(3) Secondary Quench Vessel (QV-004) (manufacturer not specified)

(4) Secondary Venturi Scrubber (VS-004) (manufacturer not specified)

At least three of the four listed above shall be in operation during operation of TU4.012

(5) Carbon Filter (CF-012) (manufacturer not specified) – Consisting of two parallel trains of carbon beds. Each train

shall have three carbon beds: a Volatile Organic Compound (VOC) bed, a primary mercury bed, and a secondary

mercury bed.

b. Both TU4.012 and TU4.013 share a backup or standby Carbon Filter (CF-013). CF-013 Consists of two parallel trains of

carbon beds. Each train shall have three carbon beds: a Volatile Organic Compound (VOC) bed, a primary mercury bed, and

a secondary mercury bed.

c. Stack Parameters

Height: 112 ft.

Diameter: 1.83 ft.

Stack temperature: approximately 163°F

Flow: approximately 11,400 dry standard cubic feet per minute (dscfm).


(1) The maximum allowable throughput rate of gold ore for TU4.013 shall not exceed 300.0 tons per hour.


(3) Hours

TU4.013 may operate a total of 8,760 hours per calendar year.


(1) Primary and Secondary Venturi Scrubbers (VS-002 and VS-003) and Primary and Secondary Quench Vessels (QV-002

and QV-004)

(a) The combined water flow rate of QV-003, VS-003, QV-004 and VS-004 shall be maintained at or above 840

gallons per minute.

(b) The exhaust gas temperature exiting VS-004 shall be maintained at or below 180°F.




Page II - 31


I. Thermal Unit # TU4.013 (continued) location North 4,570.514 km, East 487.031 km, UTM (Zone 11



(2) Carbon Filter (CF-012 or CF-013)

(a) The exhaust pressure relief bypass for System 09 may be operated 100 hours per year. The exhaust pressure relief

bypass shall be ducted through a cyclone and its hours of operation will be based on parametric monitoring of the

exhaust gas through the cyclone.

(a) Except for the 100 hours of operation allocated for the exhaust pressure relief bypass, during operation exhaust gas

shall be sent through a minimum of one Carbon Filter, either CF-012 or CF-013.

(b) Carbon Filters CF-012 and CF-013, each, shall consist of 2 parallel trains of carbon beds. Each carbon bed train

shall contain three carbon beds; a VOC bed, a primary mercury bed, and a secondary mercury bed.

(c) Each VOC bed in carbon filter CF-012 and CF-013 shall contain no less than 3,000 pounds of activated carbon.

(d) Each primary mercury bed in carbon filter CF-012 and CF-013 shall contain no less than 8,000 pounds of activated

carbon.

(e) Each secondary mercury bed in carbon filter CF-012 and CF-013 shall contain no less than 17,000 pounds of

activated carbon.

(f) The differential pressure across the carbon filter shall be maintained at or below 83.1 inches of water.

(g) The relative humidity entering the carbon filter shall be maintained at or below 70%.

(h) Replace all of the sulfur-impregnated carbon in CF-012 and CF-013 according to the following schedule:

The sulfur-impregnated carbon in CF-012 and CF-013 shall each be sampled 90 days after the notification of start-

up for TU4.013. CF-012 and CF-013 will each include sampling canisters that will contain the equivalent carbon

depth as the primary mercury bed. The canisters will receive a slip stream of the process gas during operation of the

system. Once every calendar quarter, a sample canister will be analyzed for mercury. The percentage of mercury by

weight shall be calculated. The sampling canister will be analyzed quarterly until 50% of the carbon loading

capacity of 20% by weight, as specified by the manufacturer, is reached. Upon reaching 50% of the carbon loading

capacity of 20% by weight, sampling of the canister will occur monthly until 90% of the carbon loading capacity of

20% is reached. The carbon in the primary mercury bed shall be replaced with an equivalent performing sulfur-

impregnated carbon no later than 30 days after reaching 90% of the carbon loading capacity of 20% by weight. The

required mercury analysis shall be performed utilizing one of the following methods:




(i) Any sulfur-impregnated carbon replaced in CF-012 and CF-013 shall be replaced with only the original

manufacturer’s design specification sulfur-impregnated carbon or with equivalent performing mercury removal

media.

(j) The original manufacturer’s design specifications for the sulfur-impregnated carbon used in CF-012 and CF-013

shall be kept on site.

(k) An alternative adsorbent (e.g., halogenated carbon) may be used in place of the sulfur-impregnated carbon upon

approval by the Director. The alternative adsorbent shall follow the same sampling and change-out schedule

described above using its own proven loading capacity for mercury.




Page II - 32


I. Thermal Units # TU4.013 (continued) location North 4,570.514 km, East 487.031 km, UTM (Zone 11

3. Compliance Testing, Monitoring, Recordkeeping and Reporting (NAC 445B.3379.3)





meters (30 dscf).





b. Monitoring


(1) Install, operate, calibrate, and maintain instrumentation to continuously measure and record the following.

(a) The combined water flow rate of QV-003, VS-003, QV-004 and VS-004 in gallons per minute.

(b) The temperature of the exhaust gas exiting VS-004, in degrees Fahrenheit.

(c) The differential pressure across CF-012 or CF-013 in inches of water.

(2) The calendar date of any required monitoring and recordkeeping.

(3) Monitor the throughput rate of gold ore for TU4.013 in tons continuously during operation.


(5) Monitor the combined water flow rate for QV-003, VS-003, QV-004 and VS-004 in gallons per minute continuously

during operation.

(6) Monitor the exhaust gas temperature exiting VS-004 in degrees Fahrenheit continuously during operation.

(7) Monitor the differential pressure across CF-012 or CF-013 in inches of water continuously during operation.

(8) Monitor the sulfur-impregnated carbon in CF-012 or CF-013 for percentage of mercury by weight.




Page II - 33


I. Thermal Units # TU4.013 (continued) location North 4,570.514 km, East 487.031 km, UTM (Zone 11

3. Compliance Testing, Monitoring, Recordkeeping and Reporting (NAC 445B.3679.3) (continued)

c. Recordkeeping

The required monitoring, established in Section I.3.b. above, shall be maintained in a contemporaneous log containing, at a




(3) The daily throughput rate of gold ore for TU4.013 in tons, for the corresponding date.

(4) The combined water flow rate for QV-003, VS-003, QV-004 and VS-004 , in gallons per minute, once per 12 hour

shift, for the corresponding date

(5) The water flow rate for WS-006, in gallons per minute, once per 12 hour shift, for the corresponding date

(6) The exhaust gas temperature exiting VS-004, in degrees Fahrenheit, once per 12 hour shift, for the corresponding date.

(7) The differential pressure across CF-012 or CF-013 in inches of water, once per 12 hour shift, for the corresponding

date.





d. Reporting






************ End of Specific Operating Conditions ************




Page III - 1

Section III. Amendments

This permit:

1. Is non-transferable. (NAC 445B.287.3)

2. Will be posted conspicuously at or near the stationary source. (NAC 445B.318.5)

3. Any party aggrieved by the Department’s decision to issue this permit may appeal to the State Environmental Commission

(SEC) within ten days after the date of notice of the Department’s action. (NRS 445B.340)

Signature

Issued by: Ryan Clark

Supervisor, Permitting Branch


Phone: (775) 687-9356 Date: xxxxxxxxxxxxx

nh km

08/09 06/17

Documents

Nevada Department of Conservation and Natural Resources ...Bureau of Air Pollution Control 901 South Stewart Street, Suite 4001 • Carson City, NV 89701-5249 ... upon the presentation