7. Annex II: SASA Mine LLC Makedonska Kamenica (further down
SASA Mine)
A. General data
SASA Mine is located on the Northeast part of Republic of Macedonia, in the central part of Osogovo
range. Makedonska Kamenica is the nearest town to the mine, located in a distance of 12 km. The
nearest bigger city to SASA LLC is Delchevo, located around 35 km Southeast of the mine.
SASA Mine halted its activities in April 2003, and in September 2005 they were reactivated.
The pit and supporting facilities remediation was completed in few months and flotation and reagents
departments were completely equipped, so that in July 2006 there was a stable production of 700.000
tonnes of dry ore.
The most important infrastructural and environmental issues, including the regional road construction,
construction of the new dump site as well as the remediation of the diversion tunnel for Kamenica
River, located beneath the dump site, were solved during the first year and a half of preparations for
restarting the organization’s production activities.
According with the information given by the BC, SASA Mine is an installation for production of lead and
zinc concentrate. That is, this facility produces an intermediate product (non-ferrous concentrate)
which needs considerable further processing, carried it out by KCM Smelter in Bulgary (as the nontechnical review included in the application explains), where the non-ferrous metal is produced from
the concentrate.
SASA Mine specifications concentrate are:
No
Content of element
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
Pb
%
Sb
%
Bi
%
Zn
%
Cu
%
Cd
%
Mn %
Fe %
S
%
As %
P
%
MgO %
CaO %
Al2O3 %
Na %
K
%
SiO2 %
Se %
Te %
Ni
%
Co %
Cr
%
In
%
Specifications
of Pb Concentrate
76,21
0,02
0,07
2,99
0,12
0,04
0,07
1,51
14,93
0,01
0,04
0,15
0,49
0,28
< 0,01
0,02
1,23
<0,01
<0,01
<0,01
<0,01
<0,01
<0,01
Page 1 of 13
Specifications
of Zn Concentrate
1,16
<0,01
<0,01
49,64
0,94
0,44
0,66
10,20
31,44
<0,01
0,06
0,20
1,08
0,38
0,01
0,02
2,00
<0,01
<0,01
<0,01
0,02
<0,01
<0,01
24.
25.
26.
27.
28.
29.
30.
31.
Sn %
Ba %
C
%
Ag Gms/1000 Kilos
Au Gms/1000 Kilos
Hg Gms/1000 Kilos
Cl Gms/1000 Kilos
F Gms/1000 Kilos
0,02
<0,01
0,78
476
1,0
<1
53
123
<0,01
<0,01
0,65
45
0,1
<10
<50
185
B. Assessment of the installation according to Directive 2010/75/UE
The scope of section 2.5.a) of Directive 2010/75/UE is the production of non-ferrous crude metals
from ore, concentrates or secondary raw materials by metallurgical, chemical or electrolytic processes.
A metal concentrate is a product which has been treated: flotation, leakage, gravimeter,… to separate
most part of the gangue and to obtain a concentrate formed by the principal metal (lead or zinc in this
case) with other residual materials, so it is not crude metal (crude metals usually have a metal
content upper than 99%).
In accordance with that and regarding all the information provided by the BC, SASA mine activity is
not under the scope of Directive 2010/75/UE (IED).
Nevertheless, since the BC has shown its intention of include SASA Mine activity in the IED national
transposition, a site-visit checklist has been incorporated into this document. Also, a great deal of
effort was put into the manual in relation with the management of the SASA Mine tailings, keeping in
mind that this question is not subject to the IED.
C. Processing description
As we couldn´t visit SASA Mine installation and with the aim to elaborate this manual as well as
possible, a general mineral processing is described below (SASA Mine would carry out a similar one):
In broader terms, mineral processing consists of two functions. Firstly, it involves the preparation
and liberation of the valuable minerals from waste minerals and secondly, the separation these values
into two or more products, called concentrates. The term separation in this case is synonymous
with concentration.
Page 2 of 13
Possible selective mineral processing
This flowsheet shows diagrammatically the typical sequence of operations in the process plant. The
various unit operations used for liberation and separation will be discussed in the following sections.
Liberation and Comminution

Liberation
In order to separate the minerals from gangue (the waste minerals), it is necessary to crush and grind
the rock to unlock, or liberate, valuable minerals so that they are partially or fully exposed. This
process of size reduction is called comminution. The crushing and grinding process will produce a
range of particles with varying degrees of liberation. Any particles that exceed a target size required
for physical separation or chemical extraction are returned to the crushing or the grinding circuit.
Breaking of larger material to smaller pieces result in particles with varying degrees of liberation. The darker regions
represent the valuable mineral

Comminution
The comminution process actually begins during the mining stage through the use explosives,
excavators or scrapers for softer material. This is necessary in order to generate a material that is
transportable by haul trucks or conveyors. Comminution in the mineral processing plant is carried out
in a sequential manner using crushers and screens followed by grinding mills and classifiers.
Page 3 of 13
Separation and Concentration Technique: froth flotation
The separation and concentration of the valuable mineral can take place after the ore is crushed,
ground, and classified into the required particle size distribution. There a number of different
techniques are employed in concentrating the valuable minerals. These techniques exploit differences
in physical or chemical properties of the valuable and gangue minerals, but in the case of SASA Mine
froth flotation was selected.
In terms of daily tonnages of ore that are treated globally, froth flotation is the single most important
mineral recovery process. This is driven by its ability to selectively separate minerals. Flotation is
considered to be a physico-chemical process. Equipment in the form of mechanically or pneumatically
agitated tanks or cells generate air bubbles, which provides the physical aspect. The chemical aspect is
provided by reagents, which vary the surface properties of minerals and of the slurry medium for
separation of valuable minerals, especially those of copper, lead and zinc sulfides from gangue
materials.
The flotation process begins with a modification of the surface properties of the desired mineral. The
addition of surfactants renders the mineral surface hydrophobic (water-hating), so that the mineral
may preferentially adhere to air bubbles and float to the surface. The unwanted minerals remain
hydrophilic (water-loving) and do not attach to air bubbles. The surface of the slurry is modified by
other reagents that lower surface tension forces. This allows the air bubbles to form a semi-stable
froth. The hydrophobic minerals are recovered by skimming the froth off of the surface, while the
hydrophilic minerals remain in the slurry.
The establishment of a hydrophobic surface on a mineral is similar in principle to waxing an
automobile or shining shoes to prevent wetting. A hydrocarbon layer is established on the surface
because the hydrocarbon surface is not water-wetted. In flotation systems, chemical, rather than
mechanical, means are used to establish the hydrocarbon layer selectively on one or more of minerals,
and the layer is not complete. There are three main types of surfactants used in flotation: collectors,
frothers, and modifiers.

Collectors are also known as promoters. They are polar reagents with a metal ion on one end
joined by an organic ion at the other end. The metal ion adsorbs onto a metal ion in the
mineral surface. The organic ion at the other end forms a new surface that is hydrophobic. A
common example, potassium amyl xanthate, C5H11OCS2K that dissolves or ionizes in water.

Frothers are surface-active chemicals that concentrate at the air-water interface. They prevent
air bubbles from coalescing or bursting by lowering the surface tension of the slurry. Frothing
properties can be persistent or non-persistent depending on the desired stability of the froth.
Examples of frothers are pine oil and high molecular weight alcohols such as MIBC. There are
other proprietary frothers developed by various chemical companies

Modifiers are sometimes known as regulators, and are used to vary slurry and mineral
conditions to assist in the selective flotation of minerals. Modifiers may activate poorly floating
minerals such as sphalerite, or may depress certain minerals, so that a differential flotation can
be performed on a complex ore. Chemicals that change the pH of the slurry are also used as
Page 4 of 13
modifiers. pH modifiers include lime, soda ash, sulfuric acid; can act as activators and/or
depressants by controlling the alkalinity and acidity of the slurry. Modifiers can also counteract
interfering effects from the detrimental slimes, colloids, and soluble salts that can absorb and
thereby reduce the effectiveness of flotation reagents.
Elements of a conventional flotation cell
Flotation tailings
According to the application, flotation tailings are transferred through a pulp pipeline to hydrocyclones
of the active hydro dump site No. 3 – phase 2. In the hydrocyclones there is a separation of flotation
tailing in sand and overflow. With the disposal of sand a downstream dam of dump site is formed. In
this dam there are water sprinkles installed for suppression of dust. The overflow (which is actually
sludge material) is released inside the dump site where its mechanic and chemical treatment is
perfomed (treated with flocculants), so the majority of the clarified water is released in Kamenica
River.
D. SASA Mine site-visit checklist
i. General data
Date of visit
Installation
Name of company
SASA Mine
SASA Mine LLC Makedonska Kamenica
Location of the plant (coordinates)
Legal address
(Address, Postal Code, City, Country)
Address of installation
(address, postal code, city, country)
Contact person
Page 5 of 13
Telephone and e-mail
+389 (0) 33 27 92 00
[email protected]
Company representative during the visit
Operation starting data
September 2005
Working schedule (hours/day; days/week;
weeks/year)
Employees
693
Main IED activit
Production (tonnes/year)
Other IED activities
Lead concentrate: 52.337 (in 2008)
Zinc concentrate: 63.862 (in 2008)
-
Description of other IED activities
-
Auxiliary facilities (description)
Environmental management system
(standardise/ certified)
Special environmental characteristics (e.g.
water bodies, nature protection areas,
neighbourhood situation)
Kamenica River, Sviwa River, Kozja River, Crvena River, Petrova
River
Makedonska Kamenica town and other neighbourhood
Possible groundwater, water bodies and soil polluted with heavy
metals because of old mining activity
BAT Reference Document (principal)
Non-ferrous Metals Industries (final draft – October -2014)
Emissions from Storage (July 2006)
Other BAT Reference Documents
BAT Conclusions Decision
Management of Tailings and Waste-Rock in Mining Activities
(MTWR BREF) - January 2009 - (is not subject to the Directive on
industrial emissions IED, 2010/75/EU).
Decision 2016/1032 (13 June 2016) Official Journal of European
Union (30.6.2016)
-
ii. Environmental and process flow chart
The application should allow the permit writer to depict a process flow chart, more or less detailed,
depending on the quality of the application. It should reflect the input materials and all controlled
emissions to air, water and soil. Relevant diffuse emissions (e.g. occurring from storage, handling and
transport of raw material, grinding, crushing …) might be included, too.
iii. General BAT conclusions assessment
Page 6 of 13
See Section C of Annex I and choose those techniques that could be applied in SASA Mine.
iv. Specific BAT conclusions assessment
See Section D of Annex I: considering that SASA Mine doesn´t produce any non-ferrous metal, it is
unnecessary to do this assessment.
v. Emissions from storage: BAT conclusions assessment
See Section E of Annex I and choose those techniques that could be applied in SASA Mine.
8. Management of tailings and waste-rock in mining activities
A. Introduction
The Directive on the management of waste from extractive industries (the so-called "Mining Waste
Directive”, 2006/21/EC) requires that mining and quarry operators take all measures necessary to
prevent or reduce any adverse environmental or human health effects related to the management of
extractive waste. The content of this Directive is vital to authorise the construction of new dump
sites in SASA Mine, or even to impose new requirements to the existing ones.
The first MTWR BREF was published in January 2009
http://eippcb.jrc.ec.europa.eu/reference/BREF/mmr_adopted_0109.pdf
with most of the work performed in the time period 2001-2004. Since then, new technological
developments have seen the light and new challenges have arisen in an enlarged EU. Therefore, the
European Commission has now launched the process of reviewing and adapting the MTWR BREF.
Contrary to other BREF documents, managed by the European IPPC Bureau , the MTWR BREF is not
subject to the Directive on industrial emissions (IED, 2010/75/EU).
The MTWR BREF covers activities related to tailings and waste-rock management of ores that have the
potential for a significant environmental impact. In particular the work sought out activities that can
be considered as examples of “good practice”. Mining techniques and mineral processing are only
covered as relevant to tailings and waste-rock management. The intention is to raise awareness of
such practices and promote their use across all activities in this sector.
Important: considering that the BC wants to include the management of the
flotation tailings in SASA Mine dump sites, even though is not subject to the IED,
I´ve tried to summarize the most important questions that should be keeping in
mind in the scope of mining permit and during the environmental assessment
procedure.
Page 7 of 13
B. Key environmental issues
i. Material characterization including prediction of long-term behaviour
Tailings and waste-rock management sites go through certain phases from design to after care. It is
essential to manage these facilities in a way that makes most sense in all phases of that life cycle.
Proper material characterisation is the basis for successful tailings and waste-rock management.
The only way of determining the long-term behaviour of tailings and waste-rock is to characterize
them properly. This may sound trivial, but it has often been neglected. Too often the focus has been
on the saleable concentrate, which generates revenue and not on the remaining residue. However,
operators should not forget the negative economic effect that improper tailings and waste-rock
management can incur.
From an environmental point of view, the main difference between the mineral in the original deposit
and the same mineral, less as much as possible of the desired mineral, in the tailings and waste-rock is
the increased availability for physical, chemical and biological processes to affect the mineral. This
means that through the treatment of the ore (mainly comminution) the constituents of the tailings and
waste-rock are more accessible.
The following example may further explain this phenomenon:
Sulphide ore, in its natural location (i.e. underground and bound in rock mass), is not exposed to an
oxidising environment. The finely ground tailings of this ore, once discarded in a pond, are much more
accessible to water and oxygen. The surface area of accessible sulphides is increased by orders of
magnitude through the size reduction. This implies that, if not managed properly, the rate of
weathering, and thereby the mobilisation of weathering products, may be significantly increased.
Also, the mineral processing of the ore may change the chemical characteristics of the processed
mineral and hence the tailings.
Overall, the characteristics that have to be investigated are, e.g.:







chemical composition, including the change of chemistry through mineral processing and
weathering
leaching behaviour
physical stability
behaviour under pressure
erosion stability
settling behaviour
hard pan behaviour (e.g., crust formation on top of the tailings).
Proper material characterization is the basis for any planning of the management of tailings and wasterock. Only if this background work is done properly can the most appropriate management measures
be applied.
ii. Environmentally relevant parameters
The environmentally relevant parameters of tailings and waste-rock management facilities can be
subdivided into two categories: (1) operational, and (2) accidental. Both have to be taken into
consideration.
Page 8 of 13
Two very important environmental issues which need to be highlighted are:


the generation of acid rock drainage (ARD) and
the occurrence of accidental bursts or collapses.

Typical emissions and management of water and reagent:
Emissions to air can be dust, odour and noise. Usually the latter two are of less concern unless the
tailings or waste-rock are transported with trucks and there is residential housing nearby. Dust can
consist of materials such as quartz or any other components found in rocks and minerals, including
metals.

Emissions to water can include reagents from mineral processing, such as:








cyanide
xanthates
acids or bases resulting in low or high pH
solid or dissolved metals or metalliferous compounds (e.g. iron, zinc, aluminum)
dissolved salts e.g. NaCl, Ca(HCO3)2, etc,
radioactivity (in coal tailings/waste-rock heaps)
chloride (coal mines)
suspended solids.
Emissions to land can occur via settled dust or via the seepage of liquids from tailings and/or wasterock management facilities into the ground. The building and removal of temporary storage piles is
one often occurring source of land contamination. This is also true for the construction of industrial
areas, railway banks, tailings dams, etc., using waste rock containing, e.g. ARD producing material.
Overall management of water and reagents, such as:


Consumption and treatment and/or recycling of reagents (e.g. flotation reagents, cyanide,
flocculants) and water prior to discharge into tailings facility or surface water
management of precipitation and surface water (e.g. gathering in ditches).

The environmental impact of emissions
Effluents and dust emitted from tailings and waste-rock management facilities, controlled or
uncontrolled, may be toxic in varying degrees to humans, animals and plants. The effluents can be
acidic or alkaline, may contain dissolved metals and/or soluble and entrained insoluble complex
organic constituents from mineral processing, as well as possibly natural occurring organic substances
such as humic and long-chain carboxylic acids from the mining operations. The substances in the
emissions, together with their pH, dissolved oxygen, temperature and hardness, may all be important
aspects in the toxicity to the receiving environment.
Certain reagents, such as cyanides, frothers and xanthates require long retention time, oxidation (air,
bacteria, sunlight) and, for xanthates, temperatures above 30 ºC to decompose. Therefore the
planning of the mineral processing circuit and the TMF (Tailings Management Facilities) must consider
the environmental impacts of these substances and the potential need for extra ponding or treatment
to provide for certain reagents’ decomposition.
Page 9 of 13
The actual environmental impact of emissions to watercourses always depends on many factors such
as concentration, pH, temperature, water hardness etc. Many sources provide tables listing, e.g.:





maximum and minimum pH levels for various aquatic life form
ammonia toxicity data
acute toxicity data for various flotation agents
toxicity of specific chemicals
toxicity data for flocculant and coagulants.

Acid Rock Drainage
In oxygen-free environments, such as in deep groundwater, the sulphide minerals are
thermodynamically stable and have low chemical solubility. Deep groundwater in mineralised areas,
therefore, often has a low metal content. However, when excavated and brought to the surface, the
exposure to atmospheric oxygen starts a series of bio-geo-chemical processes that can lead to
production of acid rock drainage. Hence, it is not the content of metal sulphides in itself that is the
main concern, but the combined effects of the metal sulphide content and the exposure to
atmospheric oxygen. The effect of exposure increases with decreasing grain size and, therefore,
increased surface area. Hence the sulphides in the finely ground tailings are more prone to oxidation.
ARD may be produced where sulphide minerals are exposed to the atmosphere (oxygen and water)
and there are not enough readily-available buffering minerals present. In mining this could be in, e.g.,
waste-rock deposits, marginal ore deposits, temporary storage piles for the ore, tailings deposits, pit
walls, underground workings or in heap leach piles. Historically sulphide containing material has also
been used for construction purposes at mine sites, e.g. in the construction of roads, dams and
industrial yards. However, regardless of where ARD production occurs, the fundamental processes
behind the generation of ARD are the same.
The release of ARD to surface- and groundwater deteriorates the water quality and may cause a
number of impacts, such as depletion of alkalinity, acidification, bioaccumulation of metals,
accumulation of metals in sediments, effects on habitats, elimination of sensitive species and unstable
ecosystems.
In summary, the key issues which are the root of this environmental problem are:




tailings and/or waste-rock often contain metal sulphides
sulphides oxidise when exposed to oxygen and water
sulphide oxidation creates an acidic metal-laden leachate
leachate generation over long periods of time.

Accidental bursts or collapses
An investigation of 221 tailings dam incidents has identified the main causes for the reported cases of
dam failures. The main causes were found to be lack of control of the water balance, lack of control of
construction and a general lack of understanding of the features that control safe operations. It was
found that only in very few cases did unpredictable events, such as unexpected climatic conditions or
earthquakes, cause the bursts.

Site rehabilitation and after-care
Page 10 of 13
It is impossible to restore a site to its original condition. However, the operator, the authorities and the
stakeholders involved have to agree on the successive use. It will usually be the operators
responsibility to prepare the site for this. In order to receive a permit for the closure, the
characteristics of the impounded material should be well determined (e.g. amounts, quality/
consistency, possible impacts). To avoid future ARD is a main concern for the closure design for tailings
with a net ARD potential.
Generally, the major issues to be considered for the reclamation and closure of tailings and waste-rock
management facilities include the long-term:



physical stability of constructions
chemical stability of tailings and waste-rock and
successive land use.
The TMF areas of a mine site should be stable under extreme events such as floods, earthquakes and
perpetual disruptive forces, including wind and water erosion, such that they do not impose a hazard
to public health and safety or to the environment.
If tailings and/or waste-rock contain sulphide minerals, they may create an acid discharge. Even
though ARD is a phenomenon that may occur during operation, it is the time after the closure of the
facility when ARD becomes a problem. While in operation tailings impoundments are usually saturated
and the voids are filled with water. Therefore, chemical oxidation is limited during operation. It is at
the closure phase of an operation, when usually the water level within the tailings drops and air enters
the voids, that pyrite oxidation can occur and create a problem.
The rehabilitation of a site usually aims to turn the area into something that the local society needs
and can make use of. This, of course, has to be compatible with the long-term stability of the site.
iii. Techniques to consider in the determination of BAT
Chapter 4 of MTWR BREF contains the detailed information used to determine BAT for the
management of tailings and waste-rock in mining activities. The information in this chapter is essential
to the determination of BAT.
Those techniques which are judged to be BAT, are also cross-referenced from chapter 5. Users of the
document are thus directed to the discussion of the relevant techniques associated with the BAT
conclusions, which can assist them when they are determining the BAT-based conditions of permits.
Some of the techniques in Chapter 4 are of a technical nature whilst others are good operating
practices, including management techniques. The techniques are grouped in the following order:
• General principles: Good management principles, management strategies and risk assessment, all
aimed at providing the general background for successfully managing tailings and waste-rock.
The good management of tailings and waste-rock includes evaluating alternative options for:


minimising the volume of tailings and waste-rock generated in the first place, by e.g. proper
choice of mining method (open pit/underground, different underground mining methods)
maximising opportunities for the alternative use of tailings and waste-rock, such as:
a) use as aggregate
b) use in the restoration of other mine sites
Page 11 of 13


c) use in backfilling
conditioning the tailings and waste-rock within the process to minimise any environmental
or safety hazard, such as
a) de-pyritisation
b) addition of buffering material.
Any tailings and waste-rock that cannot be avoided (due to accessibility to the orebody, safety
reasons, etc.) and that are not suitable for alternative use (e.g. due to physical on chemical properties,
transport costs, lack of market) require a suitable management strategy, which aims to assure the:



safe, stable and effective management of tailings and waste-rock, with a minimised risk for
accidental discharges into the environment in the short, medium and long term
minimisation of quantity and toxicity of any contaminated release/seepage from the
management facility
progressive reduction of risk over time.
If more than one type of tailings and waste-rock are generated, segregating them according to type
would facilitate any future recovery for alternative use or re-processing; however, blending the
different types of tailings and/or waste-rock might become a good environmental management option
if, for example, ARD minimisation could be achieved as a result.
• Life-cycle management: a reduction of the risk of any failures can be assisted by a commitment of
the operator to the adequate and rigorous application of appropriate available engineering techniques
for the design, operation and closure of tailings and wasterock management facilities over the entire
period of their operating life. Some tools elemental to good engineering are the establishment of an
environmental baseline, the characterisation of tailings and waste-rock, the use of dam safety manuals
and audits, as well as applying planning for closure from the outset.
 Emission prevention and control:












ARD management
techniques to reduce reagent consumption
prevention of water erosion
dust prevention
techniques to reduce noise emission
progressive restoration/revegetation:
water balances
drainage of ponds
free water management
seepage management
techniques to reduce emissions to water
groundwater monitoring
 Accident prevention:






tailings or waste-rock management in a pit
diversion of natural run-off:
preparation of the natural ground below the dam
dam construction material
tailings deposition
techniques to construct and raise dams
Page 12 of 13








free water management, freeboard, emergency discharge and design flood
determination
drainage of dams
monitoring of seepage
dam and heap stability
techniques to monitor stability of dams and heaps
cyanide management
dewatering of tailings
 Reduction of footprint: An efficient way to reduce the footprint of tailings and waste-rock
management facilities is to backfill all or part of these materials. Other options include the
underwater management of tailings, or finding other uses of the tailings and waste-rock.
 Mitigation of accidents: two tools for the mitigation of accidents are emergency planning and the
evaluation and follow-up of incidents.
 Environmental management tools: environmental management systems are a useful tool to aid the
prevention of pollution from industrial activities in general.
iv. BAT for the management of tailings and waste-rock in mining activities
The BAT chapter (Chapter 5) identifies those techniques that are considered to be BAT. It is divided
into a generic part, applicable to all sites managing tailings and waste-rock, and a specific part for
specific minerals.
Tailings and waste-rock management decisions are based on environmental performance, risk and
economic viability, with risk being a site specific factor.
It is intended that the general BAT are a reference point against which to judge the current
performance of an existing installation or to judge a proposal for a new installation. In this way they
will assist in the determination of appropriate "BAT-based" conditions for the installation. It is
foreseen that new installations can be designed to perform at or even better than the general BAT
performances presented in Chapter 5. It is also considered that existing installations could move
towards the general BAT levels or do better, subject to the technical and economic applicability of
the techniques in each case.
Page 13 of 13