processing wastes, rather than beneficiation wastes.
The September 1, 1989 final rulemaking also points out differences between extraction/ beneficiation wastes and mineral processing wastes (emphasis added):
In considering the functional distinctions between beneficiation and processing using both heat and acid, EPA has examined both the range of actual practices employed, and the types of waste streams that are generated by these operations in various mineral commodity sectors. In a general sense, the lines that the Agency has drawn between beneficiation and processing parallel the common sense differences that can be observed between beneficiation and processing wastes generated using other types of mineral exploitation techniques. Most beneficiation processes, at least those immediately upstream from the initial processing operation in a production sequence, generate high volume solid waste streams that are essentially earthen in character. Despite the fact that valuable constituents have been removed, the remaining material is often physically and chemically similar to the material (ore or mineral) that entered the operation, except that particle size reduction has often occurred. Processing operations, in contrast, generate waste streams that generally bear little or no resemblance to the materials that entered the operation (with the arguable exception of smelting slags). These operations most often destroy the physical structure of the mineral, producing product and waste streams that are not earthen in character.
This common sense distinction is reflected in EPA's definitions of beneficiation and processing operations using heat and acid. The beneficiation operations (e.g., calcining, dissolution, roasting in preparation for leaching) produce wastes, where applicable, that are essentially earthen and of relatively high volume. The processing operations (e.g., smelting, acid or alkaline digestion), on the other hand, produce wastes that are not earthen, bear little resemblance to the materials that entered the operation, and are of relatively lower volume.
The Agency recently (April 1998) issued two finalized collections of damage cases involving extraction/beneficiation and mineral processing wastes: Human Health and Environmental Damages from Mining and Mineral Processing Wastes and Damage Cases and Environmental Releases from Mines and Mineral Processing Sites.
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What are the Lines Between Beneficiation and Mineral Processing?
EPA uses the terms "extraction," "beneficiation," and "mineral processing" to describe the sequence of events needed to produce a saleable mineral.
- - The concentration of the mineral commodity increases because impurities are removed as the operations progress from extraction through beneficiation to mineral processing.
What is a Primary Ore or Mineral?
It is important to establish whether primary mineral production takes place at the facility. The exclusion does not apply to secondary production of mineral commodities. Wastes from scrap recycling, metals recovery from flue dust, and similar activities have always been subject to Subtitle C regulation if these wastes exhibit hazardous characteristics or are listed hazardous wastes.
---Primary mineral production operations are defined as those using at least 50 percent ores, minerals, or beneficiated ores or minerals on an annual basis as the feedstock providing the mineral value.
---The exclusion does not extend to downstream chemical manufacturing, fabrication, or other activities that use a saleable commodity as the primary raw material, even it these activities occur at the same facility. (see 54 FR 36616, September 1, 1989)
The initial stages of mining (i.e., extraction and beneficiation) produce relatively earthen-like large volume and low hazard wastes.
Beneficiation operations typically serve to separate and concentrate the mineral values from waste material, remove impurities, or prepare the ore for further refinement.
Processing operations, in contrast, generally follow beneficiation and serve to change the concentrated mineral into a more useful chemical form. This is often done by using heat or chemical reactions to change the physical/chemical composition of the mineral and produce relatively low volume, high hazard wastes.
It is critical to determine at what point mineral processing first occurs because all operations following that initial processing operation will be considered processing. Any waste generated downstream from the initial mineral processing step loses the exemption unless it is on the list of the special 20 mineral processing wastes eligible for the Bevill exclusion. 4
Wastes falling on the beneficiation side of the line retain the exemption, while wastes on the mineral processing side, except for 20 "special wastes", fall within Subtitle C jurisdiction.