Feature Opinion
The Regulatory Encouragement of
Metals Recycling—Vete a Otro Perro
Con Ese Hueso
Larry M. Southwick
Editor’s Note: It bears noting that the opinions and state-
ments published in JOM are attributable to the authors alone
and do not necessarily reflect the opinion of TMS, JOM, or the
editorial staff. Letters to the editor regarding the tone and/
or substance of this paper will be welcome.
Author’s Note: Loosely translated, “vete a otro perro con ese
hueso” means “go tell it to the marines.” In today’s age, this
is unintelligible, but 200 years ago that was not the case. At
that time, marines were landlubbers assigned temporarily to
duty aboard a ship, and sailors found them gullible to any
story the tars cooked up. A literal translation, as with most
Spanish idioms, is far more expressive: “tempt another dog
with that bone.”
INTRODUCTION
Every citizen of the United States ac-
counts for more than 12.5 tons per year
of metals and minerals consumption.
While the larger portion represents sand,
gravel, coal, and fertilizer, more than
1,300 pounds per capita are consumed of
aluminum, copper, iron (steel), lead, and
zinc. Of these latter metals, much has
been generated by recycling: more than
60% of the lead (the secondary lead in-
dustry has exceeded the primary indus-
try since the early 1950s), 65% of steel,
25% of copper, and so on. But these are
largely post-consumer scrap recycling,
meaning they are relatively easy to deal
with and not extensively regulated (yet).
However, in processing recycled ma-
terials (which are usually alloyed or
mixed with other compounds) or raw
ores (which contain impurities), a vari-
ety of residues and by-products are gen-
erated. Since these materials contain
things like lead, cadmium, chromium,
arsenic, and antimony (the PGCs—para-
noia-generating compounds), they at-
tract regulatory attention, and the focus
of this article is to examine and comment
on how these regulations affect the recy-
cling chain. The more difficult the pro-
cessing part of recycling becomes, the
more difficult the whole recycling activ-
ity itself becomes.
As metals are produced by the extrac-
tive metallurgy industry, it has a sub-
stantial role to play in meeting environ-
mental standards. Meeting environmen-
tal goals and maintaining supplies of
metals requires a healthy, financially
sound industry working conscientiously
under reasonable and scientifically de-
fensible regulations. Unfortunately, the
latter often is not obtained, with envi-
ronmental activism within and without
the regulatory community leading to
1998 July • JOM
rules that are more prohibitory rather
than allowing industry to function. Fur-
ther, common perceptions, even if gen-
erally favorable, abound in myths and
misconceptions of both the necessity of
healthy industry as well as its environ-
mental impacts when measured against
normal everyday activities. Compound-
ing these misconceptions are the gener-
ally overwrought and inflammatory lan-
guage in much of the regulations. The
media’s handling of these paranoia-gen-
erating regulations (PGRs) hardly helps.
Little wonder that when PGCs are com-
bined with PGRs and stirred by para-
noia-generating media (PGMs), the re-
sulting brew is not conducive to rational
debate and reasoned appraisal of rela-
tive risks. Even applying the concept of
relative risk to environmental issues be-
comes difficult.
A facility generates various solid and
hazardous wastes by the nature of its
activity. The disposal of these are regu-
lated under the Resource Conservation
and Recovery Act (RCRA). The original
purpose of this statute was envisioned
to encourage conservation of resources
(i.e., waste prevention) and their recov-
ery (i.e., recycling). The evolution of the
regulations has been more toward pro-
hibiting activities (e.g., land bans) and
mandating treatment processes—in
other words, command and control, not
goal setting. In fact, much of RCRA seems
adversarial toward metals recycling.
One RCRA provision affecting recy-
cling is a mechanism called delisting,
which allows certain types of wastes to
be removed from the hazardous waste
criteria and supposedly become less of a
burden and expense to manage. But this
has tended to be an inaccessible mecha-
nism. Also under RCRA, there has been
increasing attention paid to minimizing
the generation of wastes. But these have
been more directed at quotas, which
favor bulk over actual hazardous con-
tent. Finally, contamination of operat-
ing and shut down sites becomes the
responsibility of current and past opera-
tors to clean up. These problems are
regulated both under RCRA (operating
sites) and the Comprehensive Environ-
mental Response and Compensation
Liability Act (CERCLA) (Superfund or
shutdown sites). But these have become
more legal exercises in pursuit of deep
pockets and punishment rather than ac-
tual clean-up.
DEALING WITH WASTES AS
GENERATED
Wastes are classified as hazardous
according to two measures: characteris-
tics or listing (pertaining to the indus-
trial operation that generated them).
Treatment and disposal of hazardous
wastes is governed by the land-ban regu-
lations (LBR), which were set up under
RCRA to prohibit direct disposal of un-
treated wastes into landfills.
The characteristic classification in-
cludes ignitability, corrosivity, reactiv-
ity, and toxicity. Of most impact in the
metals industry is corrosivity (i.e., pH)
and toxicity. The latter is determined by
a special test called the toxicity charac-
teristic leaching procedure (TCLP),
which uses a somewhat acidic solution
(5.0 pH) and establishes toxicity by
whether the concentration of a list of 40
compounds (eight are metals) in the re-
sulting leach solution exceeds certain
values. Decontamination of these wastes
requires reduction of the characteristic
to within specified limits.
A BDAT is Born
More germane to most metals opera-
tions are the listed wastes. Treatment
and disposal under LBR usually requires
treatment and disposal by specified
methods (called the best developed avail-
able technology [BDAT]), with the re-
sulting residues meeting specified trace
metals concentration limits (as measured
by the TCLP).
An instructive example of a typical
experience with BDAT is that of steel
mill EAF dust, listed as K061 waste. It
was included on the RCRA list because
of concerns with heavy metals, espe-
cially lead and cadmium. It is of interest
for metals recovery not for these two
components but because it also contains
zinc, often in moderately attractive con-
centrations. Prior to regulatory action,
perhaps 15% of this dust (more than
about 25% zinc) was already being pro-
cessed in rotary (Waelz) kilns for the
recovery and reuse of the zinc. Zinc was
21
fumed off as the oxide (along with the
other heavy metals) and the iron, lime,
and silica also in the dust were produced
as a slag. Here, economics were such
that the mills were paid for their dusts;
regulations soon put a stop to such uto-
pian nonsense.
Satisfied with the levels of heavy met-
als in the residual slag, the U.S. Environ-
mental Protection Agency (EPA) sought
to broaden the application of this tech-
nology (called high-temperature metals
recovery [HTMR]) by designating it as
BDAT and urging all K061 dusts be pro-
cessed in a similar manner. While it was
not absolutely required, using HTMR
technologies greatly streamlined the
permitting process. Recognizing that
many dusts had relatively low levels of
zinc that would be especially uneconomi-
cal to process, an exemption was origi-
nally granted allowing dusts below 15%
zinc to be landfilled after stabilization.
Also, a specific exemption from regula-
tory oversight was granted to EAF dust
destined for fertilizer use.
An analysis conducted by the EPA
while developing the proposed regula-
tions identified eight HTMR plants ei-
ther in operation, construction, or de-
sign that satisfied the criteria they had
established for metals concentrations in
the residual slags. Unfortunately, while
the regulations stipulated that proven,
commercially available technologies had
to be used, five of the eight plants iden-
tified by the EPA used technologies that
had never been operated commercially.
As might be expected, such disregard of
commercial status led to much trouble.
A further complication was that upon
promulgation of the BDAT in August
1988, it was determined that insufficient
capacity existed to process all of the then
currently generated wastes. Thus, a two-
year delay was granted, to which a third
year was added, before all facilities had
to be in compliance.
Even by the time set for final compli-
ance (August 1991) it was already be-
coming apparent that the new technolo-
gies were not working. Within three
years, all of the new technology plants
had either shut down or been exten-
sively modified. One was never built
(Waste Management, which was to use
Table I. Electric Arc Furnace Dust Disposal Routes
Disposal Route 1985 1992
Landfill 337 63
Fetilizer 25 13
Micronutrients 16 17
HTMR
Horsehead Resource
Development 55 424
Zinc Nacional 17 50
Miscellaneous (ZTT, IR, 0 10
LaClede, IMS, MRT,
HRD-NSS)
Total 462 560
22
the Elkem electric furnace technology),
two shut down (the two IMS-Tetronics
plasma furnace plants), and two were
extensively modified (Zia’s inclined ro-
tary reactor system and Elkem’s plant at
Laclede Steel, which Elkem gave up on
and turned over to the steel company).
The only facilities that operated as
planned were the three rotary kiln plants
owned by Horsehead Resource Devel-
opment. Recently, even the modified
plants have shut down. So now all the
original righteously selected and highly
touted (by the EPA) new HTMR pro-
cesses have bit the dust. And found it
indigestible.
BDAT Becomes UACT
This failure of many of the second-
generation processes led to considerable
turmoil in the industry. A mill was re-
quired to manage its wastes in a strictly
proscribed manner, but the prescription
was not working. Needless to say, the
agency came under considerable pres-
sure to be more open in the selection of
alternatives. So what happens when Best
Developed Available Technology be-
comes Un-Available Control Technol-
ogy? Answer: U ACT on your own. Sev-
eral generations of processing technolo-
gies followed (we are now in the fifth)
with many other new schemes, but with
limited success. The coverage here is
only of processes actually built or being
built, with an emphasis on how regula-
tions impacted the choices and results.
Process and mechanical issues that bet-
ter design or due diligence would catch
are treated elsewhere.
One of the problems raised by the
regulations was what to do with resi-
dues from processing dust. Based on the
specious “derived-from” rule (which a
court threw out, but which was rein-
stated anyway), any waste derived from
a hazardous waste was still considered
hazardous. So while all processes to date
have met the treatment standard, any
process residue for which a beneficial
use is not available is still considered
hazardous. The logic behind calling
treated materials hazardous, even when
designated technologies that had been
selected in the first place because they
produced benign residues are used,
Throughput (1,000 t/y)
1993 1995 1996 1997
82 143 220 365
25 25 12 12
17 16 16 16
384 351 290 310
82 82 110 125
14 33 52 61
604 650 700 889
somehow escapes the rational mind.
An even more stringent treatment
standard allows a generic exclusion from
hazardous waste regulations. But com-
pliance with solid-waste regulations (i.e.,
placement in a managed solid-waste
landfill) is still required, which can still
be onerous in the extreme. A salable
residue product allows an exemption,
but is scrutinized to determine if such
use constitutes disposal, which is a no-
no. Regulations cast an all pervasive net.
One way around this was to turn all
(or most all) of the dust into the primary
product. Four processes have found a
way to do this. Two technologies vitrify
the whole dust into glass and two fume
off zinc and heavy metals, making sal-
able products of the irony residues (brick,
in one case; in the other, iron magnetite).
The vitrification process developed by
Glassification International was too ex-
pensive to build, too expensive and dif-
ficult to operate, and the markets for the
products were too limited and undevel-
oped. And if that was not enough, they
ran afoul of the Occupational Safety and
Health Act (OSHA) and were hit with a
fine exceeding $1 million. Enough coffin
nails to terminate any new idea.
The other glassification process, by
Inorganic Recycling, has had difficulties
with process and mechanical design and
was shut down for a spell, but now ap-
pears rejuvenated and has recently ex-
panded. They also have what appears to
be stable, if not yet overly lucrative,
markets for their product. The brick
plant (Richland Moulded Brick) has re-
cently started up, and the magnetite
plant (Phoenix Environmental Ltd.) is in
design.
Another new process attempted was
an innovative hydrometallurgical route.
This was developed by Metals Recy-
cling Technologies for leaching dust with
ammonium chloride, producing a high-
purity zinc oxide. Two versions have
been built, both failures. In the first plant,
the insoluble iron and zinc ferrite resi-
dues were recycled to the melt shop.
While this has all the attractiveness of
throwing dirt (albeit an irony one) into
the EAF unit, it does avoid the issue of
residue disposal. The second version
used a rotary hearth furnace to recover
zinc from ferrite and produce an irony
slag, which would be more palatable to
the melt shop. But this only replaced one
set of problems with another, among
which was the tendency of the slag to
adhere to the hearth. A third trans-
mogrification is now being developed.
The HTMR route came in for its share
of attention as well. First, while the EPA’s
vision did not extend beyond the Rio
Grande River, a certain zinc company’s
vision in Mexico did. Zinc Nacional in
Monterrey, Mexico, had noted the rising
tide of money to be earned by taking U.S.
wastes. So the operators switched their
JOM • July 1998
Waelz kiln to EAF dust feed (for which
they were paid) rather than ore (for which
they had to pay) and operated from the
early years of regulated K061 manage-
ment. They even survived an EPA audit
instigated by “green-dreams” that waste
was being exported to avoid regulations.
The Zinc Nacional plant is one of the
cleanest around.
The other old-time zinc processor in
the market, HRD, not only expanded
their plants, but added a new HTMR
technology (the flame reactor) as well.
They have also been working on making
the iron residues more palatable to EAF
melt shops, though one mill taking
another’s wastes can be a difficult sale.
Also, returning impurities fumed out of
the melt shop into the EAF dust back to
the melt shop via iron residues can also
be a difficult sale. A variation on the
Tetronics process as modified by IMS
has been modified again by AllMet and
is in start-up.
And the Winner Is . . .
Ironically, the biggest gainers in all of
this have been landfills. If that seems
surprising, it is but an example of the
Law of Unintended Consequences
(LUC). Ergo, RCRA begat LBR; LBR
begat BDAT; BDAT begat UACT;
UACT begat frustration and monopoly;
monopoly begat high prices; high prices
begat more frustration, but also oppor-
tunity; and opportunity opened the door
to the stabilization and landfill compa-
nies. Interestingly, these late arrivals ar-
rived at this window of opportunity by
a different, yet strangely similar set of
consequences (LUC again at work).
Anyway, with hazardous wastes and
landfills both bad words, what better to
do than separate them? And what better
way to separate them than to make some
new regulations? Thus, RCRA (different
part of the family) begat increased regu-
lations of hazardous-waste landfills in
the form of more stringent design crite-
ria; this begat more landfill construction
expense and, thus, higher prices; this,
coupled with more RCRA begatting,
begat less hazardous waste; less waste
begat less need for landfill space, which
begat less capital utilization and less
cash flow to the landfills, which begat
the search for more opportunities, which
brings us back to EAF dust. Since stabi-
lization and landfilling of EAF dust, by
strict adherence to the law, was allowed,
it was now a legitimate option for mills
to consider.
Hence, what could be done, was done.
And given monopolies and high prices
in the HTMR options, what was done
was done cheaper. That begat market
share to the stabilization and landfill
operators, which has made life less re-
warding financially for all of the players
(except the steel mills). It has also wiped
out the last holdouts from the original
1998 July • JOM
five new HTMR processes, bringing
down the curtain on technology forcing.
Further, it introduced a whole new level
of economic criteria. Table I reviews the
results of all this begatting about. As can
be seen, while the LBRs of 1991 knocked
the bottom out of the landfill market,
now, six years later, it is larger than ever.
Note too that the HTMR group (the EPA
Five plus others) have only recently be-
come significant players, though even
then at far below the level predicted.
Of course, if we had started out this
exercise with the realization that non-
engineers or non-metallurgists, even
those two years out of college, have no
business selecting “best developed”
metals-processing technologies, then we
might not have made such a mess of
things. The “Greyhound Option” would
have been a better choice—take the bus
and leave the driving to us (i.e., get your-
self a ticket and let someone who knows
the way get you there). The original Clean
Air Act of 1970 took that route, setting
standards but allowing industry to plan
and execute the specifics. But then, just
as we seemed to be arriving at our desti-
nation, the regulations were shifted to a
more command-and-control approach.
It is as though everyone had to get off the
bus. It has never been seen since.
DELISTING
Another proffered way out of the regu-
latory morass is to delist the waste. This
takes two forms, either to redesignate
the waste in its as-generated condition
or redesignate it as a result of treatment.
While both can be an exercise in self-
flagellation, only the second form will be
addressed here.
The original regulations seemed
straightforward enough. One tests the
residues from the process, and if they
fall beneath hazardous waste designa-
tion criteria (primarily using the TCLP),
then they can be delisted. Three fallacies
were shown to exist in this whole sce-
nario: not only was the path not short, it
was also not easy and not certain.
Delisting petitions frequently took two
years or more to be reviewed, with many
recycling requests for information and
retesting (the number of cycles some-
what dependent upon how often the
reviewers were reassigned to other work
and replaced by individuals unfamiliar
with what had already been done and
discussed). Favorable rulings were prob-
lematic at best and have a batting aver-
age for delisting treated wastes that
would discredit a minor league pitcher.
One of the few successes, that for
delisting stabilized EAF dust, plays a
part in our story shortly.
To this already ponderous mix, we
now have the added confusion created
by the recent dispersal of the review
process to the EPA’s ten regions indi-
vidually. For further variety, state regu-
latory agencies have primacy over
delisting in a number of cases.
A primary interest for hazardous
waste technology holders in delisting is
to lessen costs and promote wider utili-
zation of their processes. An added ben-
efit would be if a delisting could be
applied generally across the country,
rather than restricted to one specific site.
It had been hoped that the new changes
would promote such so-called multiple
site delistings. Not! We will now turn to
a discussion of two examples of how
delisting has or has not worked: those
for EAF dust stabilization and for EAF
dust processing slag.
Conversion System and
EnviroSource
Bethlehem Steel developed a process
for stabilizing EAF dust in the 1980s and
licensed it to Conversion System, Inc.,
which was later purchased by En-
viroSource. Bethlehem Steel built a large
(50,000 t/y) plant to treat a dust with less
that 10% zinc content. It was, thus, a
poor candidate for HTMR treatment and
recovery of zinc. In 1992, Conversion
System petitioned the EPA for a generic,
multisite delisting. The timing was such
that many of the blessed HTMR tech-
nologies had failed, and the mills were
clamoring for more options, in general,
and specifically for relief from regula-
tory support of the monopoly enjoyed
by the major processor. After extensive
review, and following the takeover of
the company by EnviroSource, the
delisting was granted and made final in
1995, allowing placement of the treated
waste in a solid-waste landfill as op-
posed to a hazardous waste one.
This granting is what opened the EAF
dust door to the stabilization and land-
fill contractors (others cannot use the
delisting, but stabilization per se became
more widely accepted, even if the treated
waste now went to a hazardous-waste
landfill). It was a logical denouement to
the command-and-control approaches
of trying to force technology selections.
In essence, stabilization was a technol-
ogy whose time had come. Process fail-
ures, economics, regulatory pressures,
and appeals for more options all reached
a head at the same time and combined to
more fully open up stabilization options.
Other stabilization contractors benefited
from this conjunction; they did not need
the delisting, though it enhanced their
image.
However, the delisting is not an unal-
loyed boon. While 13 sites were identi-
fied in the original petition, EnviroSource
was, in fact, granted a generic delisting.
This meant it could be applied anywhere.
Since all of this was occurring during the
switchover of delisting review proce-
dures and since some regions differ con-
siderably on their attitudes not only to-
ward delisting in general, but also to-
23
ward the competence of other regions to
even conduct the procedure, it is not at
all clear just what rights were actually
conferred.
The result is that even with a delisting,
EnviroSource’s use of their technology
can still be stymied. First, a solid-waste
landfill nearer the sites of potential users
may not be freely accessible (at least not
without further review by the local
delisting agency and public hearings).
Second, pricing and a competitive posi-
tion for a new site is unknown without
considerable paper processing, delay-
ing a response to generators’ needs and
putting the technology at a disadvan-
Innovative Technologies
In 1995, the EPA analyzed the reasons for selecting
or rejecting innovative technologies during CERCLA
feasibility studies conducted during fiscal years 1991
and 1992. This analysis focused on 20 generic innova-
tive technology areas, ranging from ultraviolet radiation,
in-situ heating, and soil vapor extraction to chemical,
electrokinetic, and metallurgical processes. Overall,
more than 200 different technologies were included in
the sum of all the studies. There were 205 sites involved
in the study.
Here, the EPA study results are reviewed for only
those technology areas that might be applicable to
recovering and recycling metals. These include metal-
lurgical processes, in-situ and ex-situ chemical pro-
cesses, other thermal processes (ex-situ), soil washing,
and solvent extraction. While only the metallurgical
processes were strictly applicable to the type of sites of
interest, results of the other processes are reflective of
the difficulties encountered in trying new technologies.
Table I summarizes how these technology areas fared.
The one metallurgical success was for stockpiled EAF
dust (K061); it could be sent to a standard dust treat-
ment plant. The most important factors in rejecting
technologies were the nature of the media, difficulties in
implementation, and available information.
There were eight metallurgical processes for which
treatability studies were conducted, of which three
showed promise; none were selected. In addition, there
were three smelting processes tested (samples sent to
commercial smelters), of which only one was success-
ful. However, it was not the remedy selected.
All of the innovative technologies suffered because
of their complexity, the lack of information on applica-
tions to specific sites, an unwillingness to conduct
extensive treatability tests, and the frequent need to
further process residues. While the EPA’s Superfund
Innovative Technology Evaluation (SITE) program has
often been mentioned as a means around many of
these concerns, it rarely results in the commercializa-
tion of a new resource recovery technology. There are
simply too many high-risk factors to consider, and since
the SITE program does not expedite or eliminate any
regulatory hurdles (EPA Research, which runs the SITE
program, and EPA’s regions, which run remediation, do
not work off the same page), it does not provide assis-
tance where it might help most. Two sites will now be
examined further.
Anaconda Copper Company
The Washoe smelter was built in 1900–1902 by
Marcus Daly’s Anaconda Copper Company to process
copper ores produced by mines in the Butte, Montana,
region. Operations ceased in 1980, and in 1983, the
complete 6,000 acre facility was subsequently declared
a Superfund site.
A large amount of flue dusts (316,500 cubic yards)
24
tage by adding a layer of uncertainty.
Third, licensing technology to others is
restricted. The first hinderance can be
by-passed by using a hazardous-waste
landfill, but this adds three further in-
sults: transportation costs are higher,
disposal costs (tipping fees) are higher,
and taxes on the use of hazardous waste
landfills add to the cost. What one hand
giveth, the other taketh away.
Slag
Slag residues from HTMR processing
have been regulated in a widely varying
manner. In the 1991 LBRs, they had a
generic exclusion from hazardous waste
CASE STUDIES
with primary contaminants of copper, lead, zinc, ar-
senic, bismuth, and several other metals were stock-
piled at nine locations. While the dusts had up to 8%
arsenic, they also contained up to 25% copper, 5% zinc,
3% lead, and 10 oz/ton silver. A Record of Decision
(ROD) set how those dusts were to be treated. Although
several years had gone into the study and development
of a number of processing technologies for the recovery
of metals (worth in excess of $100 million), all were
rejected, and it was decided to excavate and stabilize
the dusts, placing them in a secure landfill located on-
site.
The remedial investigation and feasibility study (RI/
FS) identified three hydrometallurgical routes for test-
ing. Those were a pressurized hydrochloric acid leach,
the Cashman Process (under license to a company
called Artech); a standard atmospheric sulfuric acid
leach/electrowinning circuit; and flotation to separate
metals. The first two processes were then evaluated in
more detail. In addition, two pyrometallurgical routes
were selected for testing. One was to fume arsenic off
in a rotary kiln, the other processed the dusts in the
combined hydrometallurgical/pyrometallurgical facilities
at Falconbridge’s smelter at Kidd Creek, Ontario,
Canada. Neither of these warranted further investiga-
tion. Finally, stabilization and landfilling of the various
dusts with cement or lime-based additives was exten-
sively studied. After detailed economic evaluations of
the three remaining alternatives, the overall project cost
comparisons (after by-product credits) came out as
shown in Table 2.
While technically a success in trials, the Cashman
process was considered too costly, was not yet com-
mercialized, and would have required a long time to
bring it on-line (four years) and process the dust (ten
years). The sulfuric acid leach, while well proven, only
recovered copper and would have produced a toxic
residue requiring treatment prior to disposal. Stabiliza-
tion and landfilling was considered the least costly, the
most proven (but see below), and allowed the poten-
tially responsible parties (PRPs) to come to closure
relatively quickly on the project.
A review of the documents was compared to several
reviews conducted during the Anaconda project. In
addition, Artech also critiqued the results. A critique by
Table 1. A Comparison of Technologies Studied
by the EPA during 1991–1992
Number of Sites
Technology Considered Selected
Metallurgical 21 1 Three Hydrometallurgical Processes
In-Situ Chemical 47 0 Costs (millions)
Ex-Situ Chemical 42 1 Process
Other Thermal (Ex-Situ) 138 0
Soil Washing 118 5 Cashman
Solvent Extraction 103 5*
* One was later deselected.
considerations and could be disposed of
in a solid-waste landfill. Further, if the
slag had a beneficial use (i.e., someone
would pay to use it), then it did not have
to be landfilled. Examples included non-
encapsulated use (e.g., road deicer/
antiskid or road-surfacing material) or
encapsulated use (e.g., cement aggre-
gate or road base). In the first, slag is
exposed directly to the elements, whereas
in the second it is covered or otherwise
protected from the leaching.
However, a number of court cases
arose, and in 1994 these rules were
changed. While landfilling and encap-
sulated uses were still allowable, non-
an EPA contractorfocused on bureaucratic minutia, so
it is virtually worthless regarding scientific, technical,
economic, design, conceptual, and logistical issues.
Project critiques fell into two general areas: a review
of the overall RI/FS procedures and the treatability
testing program and a discussion of items specific to the
Cashman process. In the first instance, conclusions
were that the evaluations went on far too long, were
conducted by staff that were unqualified for the work,
involved many aspects that really did not need further
investigation, and were based on poor site character-
ization data. For example, it was stated in one of the
outside reviews that the competence of “experts” was
not adequate, that the project was purposely slowed so
that little was ever actually done, and that the costs
were excessive and of little benefit to anyone but the
consultants.
Inadequate dust characterization, or even knowl-
edge of metallurgical processes that generated the
dusts, resulted in some technologies (e.g., flotation)
being tested that should never have been considered.
Flotation is usually applied to sulfides; flue dusts by their
nature are oxides. Flotation is an extremely complicated
issue for oxides and has rarely been applied. In the
environmental field, most studies have been on oil
separation from solids.
Costs for the Cashman process were not optimized,
which would have considerably improved the econom-
ics. However, in the final analysis, it was really too
complex, with too many questions on scale-up, design,
and operability. These are issues that commercial pro-
duction facilities face constantly, but a Superfund project
can not deal with such uncertain legal and environmen-
tal liabilities or open-ended timetables.
Interestingly, but not unexpectedly, residues from
the Cashman process were very stable, having a leach
life of millions of years as compared to tens of years for
the cement-stabilized product. Even the untreated
wastes were more stable than the stabilized product.
Cement is well known to not be a good stabilization
agent for arsenic. Thus, both untreated and Cashman
residues in unlined sites would represent less contami-
nation than the selected remedy.
Bunker Hill
The Kellogg mining area of northern Idaho is named
for Noah Kellogg, an early prospector who in 1885
discovered a large galena (lead sulfide) deposit that he
Table 2. Overall Project Cost Comparisons for
Best Case Worst Case
$18.7 $78.4
Sulfuric Acid $6.7 $34.7
Stabilization/Landfill $19.1 $24.9
JOM • July 1998
encapsulated uses were not. Specifically,
the road deicer use was disallowed. In
another reversal in late 1994, this was
changed again. In a later-proposed rule
affecting encapsulated uses of slag, both
non-encapsulated uses were allowed.
The proposed change was based on a
more thorough review of the potential
hazards and a subsequent finding of
minimal risk. Finally, to top things off,
that proposal was shelved in 1996, and
no resolution is in sight.
As for the delisting of EAF dust slag,
HRD tried that for their flame-reactor
process. This would have allowed more
free and varied uses of the slag and was
named the Bunker Hill. Initially, lead ores were pro-
cessed at a lead smelter in Tacoma, Washington, but in
1917, Bunker Hill built its own lead smelter. An electro-
lytic zinc plant was later built, which produced some of
the highest quality special high-grade zinc produced in
the United States. An effort was made to keep the
smelter in compliance with projected SO2 regulations
with the erection of a new, taller exhaust stack in 1976.
It was not enough, and tighter regulations and worsen-
ing metals prices closed the smelter in 1981. It was
declared a Superfund site with 18 PRPs identified and
an ROD finalized in 1992. Demolition started in 1994
and was completed by mid-1996.
One waste product remaining on-site was a material
called copper dross flue dust (CDFD). Copper dross
was generated during the initial steps of refining lead
bullion, where bullion is cooled and impurities are floated
off as a dross, which contained primarily copper. This
dross was treated in a reverberatory furnace wherein it
was separated into lead bullion, copper matte, speiss,
and slag phases, and arsenic and antimony fumed off
and collected as a dust. This dust was designated
CDFD. It contained perhaps 12% arsenic, 1.5–4%
antimony, 35–45% lead, about 9% zinc, and 2–5 oz/ton
silver. Of most interest was indium, with a content of
about 3,500 ppm. There was about 20,000 tons of this
dust stored at the smelter.
During the operating life of the smelter, several
attempts were made to either develop specific pro-
cesses for the dust or to find outside contractors inter-
ested in it. Finally, in 1981, a contract was let for
processing off-site, but this contract was terminated
after only three months due to closure of the smelter.
However, some indium was actually produced at that
plant, proving the viability of their process (pressure
leaching). Unfortunately, this operation led to later legal
action by the EPA, which was partly driven by concerns
that by-products were being held for speculative accu-
mulation [see 40 CFR, 261.1 (c)]. This is a millstone that
metals-recycling activities must put up with, but it is not
the dirty word often implied. Stockpiling is a legitimate
business exercise done in the hope that markets will
improve for a material that currently has, at best, mini-
mal or no value.
Pintlar, the primary PRP, embarked on an extensive
study of how to process this dust. A committee was
organized with two experts from the plant plus represen-
tatives from other primary and secondary lead smelters,
Table 3. Estimated Processing Costs for
Processes Studied at Bunker Hill
Operating Cost
Process (per ton)
Bunker Hill Atmospheric Leach $150–200
Sunshine Pressurized Leach $200–300
ICA/CSM Molten Sodium $350–400
Ausmelt Lance Smelting $150
1998 July • JOM
not a request for solid-waste landfilling.
While the technology has since been suc-
cessfully commercialized, it achieved less
success on the delisting front. The re-
view process dragged on, with an un-
ending stream of requests for more data.
In March 1994, after more than six years
of trying, the petition was withdrawn.
This was costly beyond just the legal and
petition filing time or in the lost poten-
tial business. It had originally been hoped
to use the delisting. Such was not to be,
and after two years the budget ran out
and the slag was sent off-site for treat-
ment. Thus, not only were the storage
funds used up, but costs were incurred
zinc companies, and consultants to consider alterna-
tives. This was not a typical RI/FS exercise, staffed with
90 day metallurgical wonders, but was rather made up
of practicing extractive metallurgists. Finalists were two
hydrometallurgical routes and two pyrometallurgical
routes.
The hydromet processes were Bunker Hill’s earlier-
developed atmospheric pressure leach and Sunshine
Mining’s pressurized leach. The atmospheric process
was similar to that used in the zinc plant during normal
operation, wherein zinc is extracted and lead and silver
remain behind. In the Sunshine process, certain impu-
rities, such as antimony, are liberated in a pretreatment
step using sodium sulfide. A pressurized leach using
nitrous and sulfuric acids follows, extracting zinc, ar-
senic, cadmium, silver, and indium, leaving lead behind
in the residue.
The two pyrometallurgical processes investigated in
more detail were the Indium Corporation of America-
Colorado School of Mines (ICA-CSM) molten sodium
processand the Ausmelt submerged lance smelting
process. In the ICA-CSM process, sodium removes
indium as a dross, producing a lead bullion. A water
leach will then remove sodium from the dross, leaving
behind an indium concentrate that can be sold for
further processing. The Ausmelt process smelts the
CDFD in a slag bath, fuming impurities (e.g., arsenic,
cadmium, zinc, and indium) away from the slag and
lead. Estimated processing costs are shown in Table 3.
Further analyses indicated that the old Bunker Hill
process needed additional development work to be
optimized, and the Sunshine process did not have as
high an indium recovery (70%) as desired. The ICA/
CSM process had some safety concerns. The Ausmelt
process depended on a sophisticated two-step fuming
operation, where arsenic and cadmium were evolved
first, then zinc and indium, but overall seemed to have
the most promise.
During testing, an interesting problem arose. Slag
chemistry was unstable, which was caused by varia-
tions in the lime-to-silica ratio that had not appeared in
site data. This problem resulted from excavation of the
dust also picking up tramp quartz (silica) underlying the
storage area. Unstable slag chemistry meant operating
Table 4. The Economics of CDFD Processing for
Various Metals
Price (millions)
Metal October 5, 1994 January 1, 1994
Lead $0.28/lb = $4.78 $0.18/lb = 3.07
Zinc $0.46/lb = 1.84 $0.42/lb = 1.68
Antimony $2.30/lb = 4.60 $0.70/lb = 1.40
Cadmium $2.50/lb = 1.50 —
Indium $5.50/oz = 8.80 $4.50/oz = 7.20
Arsenic $1.40/lb = 6.44 —
Total $27.96 $13.35
to ship and treat what was actually a
benign slag.
Thus, using delisting to open up by-
product use is seen as problematic. The
problem is no one can foretell the full
scope of potential uses, so too many
gaps are left in the evaluation. Since it is
the nature of regulations to abhor a
vacuum, it is filled here with suspicion
that the petition is a disguised attempt at
land disposal; that what is being pro-
posed really falls under use constituting
disposal. Even though the fact that an-
other material would have to be used is
considered irrelevant, these options are
viewed as evading the regulations.
temperatures fluctuated. Consequently, the two selec-
tive fuming steps could not be kept separate, resulting
in contamination of the indium product. However, sub-
sequent testing identified solutions to these problems.
The EPA’s review of the Pintlar study concluded that
all of these process studies were not necessary, as any
smelter could have processed this dust similarly to their
own waste streams. This was nonsense and did not
reflect a clear understanding of how complicated pro-
cessing CDFD was. Compatibility in existing smelters
depends on impurity balances, such as arsenic, cad-
mium, and antimony. Since these are PGCs, they
provide limited commercial interest. The effort was
further criticized for not having developed the final
hydrometallurgical zinc-indium separation step. One of
the process partners had developed that section sepa-
rately, but the combination was disallowed. That partner
then proposed the earlier contracted process as a
stand-alone option, even bringing some indium along to
the meetings. The EPA said that it was unproven
technology!
In evaluating the economics of CDFD processing, it
became apparent that prices changed dramatically in
ten months (Table 4). Net by-product value varied over
100%. This demonstrates the need in reprocessing to
be able to time sales to maximize (or even result in)
profits.
After the site owner was driven into bankruptcy in
1991, various parties such as the EPA, the state of
Idaho, the Bunker Hill pensioners, the Couer d’Alene
Indian Tribe, bondholders, and their various law firms
began vying for any visible asset. Thus, when it became
known that processing this dust would generate in
excess of $25 million in revenues, a feeding frenzy of
interested parties went after the hapless potential project.
Since it then became extremely uncertain that a proces-
sor would be able to retain any net earnings (and
perhaps even some of the gross earnings), the project
died.
The EPA has stated that the dust has subsequently
been buried on-site in a form (i.e., unstabilized) in which
it can be recovered for later processing. That is patently
misleading. As with much of the twisted logic applied to
this site, what actually happened reflects a perverse
version of the EPA’s goal of encouraging recycling.
After moving the waste to permanent storage, in went
the railroad ties that had formed retaining walls on the
temporary storage, the plastic and tires that covered it,
and road dirt over which the trucks traveled to move the
waste, all capped with mercury-contaminated soil from
the zinc plant. There is no way that anyone will want to
process this dust.
Thus, this formerly recoverable resource sits in an
unprocessable jumble compounded be a morass of
legal and financial claims and regulatory restrictions.
Further, the tall smelter stacks were demolished in
May of 1996, making a pyrometallurgical process even
less feasible.
25

POLLUTION PREVENTION
Another way to decrease pollution
and the generation of wastes is through
programs referred to in general as pollu-
tion prevention. While the regulatory
mindset restricts this to source reduc-
tion, common sense recognizes that the
goal can also be reached by collection,
treatment, and recycle—alone or in com-
bination.
The turmoil this mindset creates can
be seen in media and activist reviews of
the annual Sara Title III reports, the so-
called toxic release inventories (TRIs).
These were promulgated in 1986 and
basically require industry to report all
releases and off-site transfers of materi-
als as listed in the regulations. These
materials do not even have to be regu-
lated wastes, just something that falls on
the list. The list is long and all-encom-
passing and in the vast percentage of
cases should not even be called toxic. But
that is the way of most regulations.
In the metals industries, it is these off-
site transfers of recyclable by-products
that is often all that allows them to stay
in business and be profitable. Other-
wise, these materials would become solid
(or hazardous) wastes and, thus, incur
disposal costs. With recycling, they are
valuable raw materials that other com-
panies can process. But the TRIs paint a
picture of industry running rampant,
spewing out toxic compounds to poison
everyone’s everyday existence. That is,
of course, nonsense, as any rational sci-
entific inquiry has shown.
In the copper industry, various dusts
and sludges are generated that may con-
tain precious metals, zinc, lead, etc., de-
pending on the source of ore and scrap.
These can be recycled to other metals
plants that can handle the impurities
and recover metals. Easy transport of
these materials then encourages their
reprocessing, recovery of their values,
and, thus, less pollution. A special prob-
lem arises when no processor exists in
the country of origin. Thus, out-of-coun-
try movement needs to be encouraged.
While the North American Free Trade
Agreement might encourage such ac-
tivities, the Besel accord, Rio Agreement,
and various proposed environmental
riders do not.
For zinc and lead, residues may con-
tain silver and other materials that make
further processing on- or off-site vi-able.
This industry produces a multitude of
residues that contain zinc in varying
amounts. Given zinc’s well-noted health
and nutrition benefits, many tie-ins to
the fertilizer and micronutrient indus-
tries exist and need to be encouraged.
Copper and iron residues are also im-
portant to micronutrient manufacture.
Unfortunately, micronutrient and fertil-
izer use of industrial wastes has come in
for a great deal of bad publicity of late,
26
most of which is unfounded, but all of
which weakened its ties to the nonfer-
rous industry.
Other residues abound, such as re-
fractory bricks, residues from crucibles,
and acid-mine drainage treatment slud-
ges. These have substantial contained
metals, plus the base materials can be
used as fluxes. The point here is that
these operations are a carefully balanced
blend of economics, processing options,
available markets, and product specifi-
cations that require off-site transfers to
remain viable. Concerns caused by ex-
aggerated reporting of their appearance
on TRI reports overstate any actual haz-
ards; raise fears where none should ex-
ist; and, in general, lead to uneconomic
choices and in the long run, to more
actual environmental impact than is
warranted.
SITE CLEAN-UPS
There has been a continuing effort to
implement new and innovative tech-
nologies in the clean-up of hazardous-
waste sites. Much of this has focused on
stabilizing or immobilizing metallic
wastes in innovative ways. This is be-
cause it has been virtually impossible to
commercialize the few technologies ca-
pable of recovering metals from a nasty
matrix of PGCs, yet satisfying the regu-
lations regarding residues. The discus-
sions in the Case Studies sidebar first
cover an overall review of efforts to com-
mercialize recycling technologies. Then
two specific examples are discussed.
U.S. BUREAU OF MINES
The U.S. Bureau of Mines was disbanded about
two years ago. It came at a time of considerable
potential change in the industry and in areas such
as mining law and at a time of regulatory and other
governmental attacks on the viability of mining and
increasing needs to address ever more strident
environmental activists. There was a general over-
all need for at least some combination of an advo-
cate for mining and an information and statistical
resource to keep federal and state legislators in-
formed who were in the process of remaking the
government’s agenda.
While government had certainly gotten bloated,
there were better choices for places to cut—agen-
cies that generated reams of paper to little benefit
or, even worse, that required business to generate
reams of paper to little benefit. At least the Bureau
of Mines helped solve environmental problems,
rather than creating an endless bureaucracy whose
major achievement has been the expenditure of
billions of dollars with little tangible progress. They
were a sounder way to advise government on
current issues, such as new technologies for waste
treatment and resource recovery or the impacts of
mining royalties, and they helped small business by
conducting (and publishing the results on) research.
Opinions among the industry may differ, but it
seems inescapable that dealing with government
pressures will be more difficult without them. With
improvements to operating methods, research di-
rection, and oversight, many of the bureau’s per-
ceived shortcomings would have been addressed,
and their efficiency and relevancy enhanced.
CONCLUSIONS
We have seen how the development
and implementation of metals recycling
projects can be substantially impacted
by regulatory requirements and activi-
ties. These range from classifying poten-
tial feed materials and, thus, the regula-
tions that apply; specifying technolo-
gies; restricting the disposition of resi-
dues and by-products; requiring time-
tables and performances that are not
realistic in the process industries (even
when they are well engineered; often
they are not); and creating liabilities for
non-performance or mistakes that not
only take the fun out of it, but can make
it hazardous to economic, professional,
and business life.
This would be manageable if the regu-
lators at least recognized that industrial
activity has an important economic ben-
efit, their decisions were based on good
science and engineering practice, and
they were realistic for an operating facil-
ity. Unfortunately, such is rarely the case.
So, not only must the proper decisions
be found, decided upon, and made, but
the regulators must be convinced that
their approach is not always feasible,
logical, or even sensible—and to do so in
a timely manner so that the economics of
the endeavor are not lost or unduly con-
stricted and that legal and environmen-
tal liabilities are not incurred.
Good technologies, economics, oper-
ating plans, and by-products are neces-
sities, but are not sufficient conditions
for metals recycling to occur. It is suffi-
cient (and necessary) to only satisfy the
regulators, but then they are not respon-
sible for the economic results. The eco-
nomic performance is industry’s respon-
sibility, and that is why it is so hard to
make a paying prospect out of recover-
ing and recycling metals from a regu-
lated waste.
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JOM • July 1998