Resources Policy 68 (2020) 101706

Contents lists available at ScienceDirect

Resources Policy
journal homepage: http://www.elsevier.com/locate/resourpol

Waste management costs (WMC) of mining companies in Turkey: Can

waste recovery help meeting these costs?
Taşkın Deniz Yıldız
Adana Alparslan Türkeş Science and Technology University, Department of Mining Engineering, Adana, Turkey

A R T I C L E I N F O A B S T R A C T

Keywords: Humankind is in need of mines throughout its entire life. As a result of mine production obtained for this need,
Environment mining wastes emerge. Mining waste management is reflected in mining enterprises as a cost item. It would be
Mineral useful to determine how much share these costs have in mining operating costs (OC). At the same time,
Mining
considering that the ratio of land use costs to mining investment amounts (MIA) in Turkey is very high, mining
Operating cost
Operation
investment risks should be reduced. In order to bring forward solutions for the WMC and its regulation, in May,
Waste June and July of 2018, a survey was conducted to mining corporations via the survey software called “Survey
Monkey”. The cost of wastes of each mining enterprise is proportionate to the yearly average OC of these mining
companies. The results that come out when the ratio of the costs of mining waste management to the estimated
investment costs as well, changing based on the different mineral groups, show that the mining WMC take a
noticeably high place among the mining investments and OC in Turkey. Despite the environmental expenses
made by mining companies in Turkey, the recovery of waste still lacks. In this regard, necessary arrangements
should be made in the legislation, and the recovery of waste should be promoted despite the expenditure of the
miner, and the return of the cost of the mining investor should be provided.

1. Introduction
Past mining experiences in the world highlight the interrelation be­
tween the financial and economic benefits and the legal change in the
environmental impact. When deciding where to put the right balance,
the negative consequences for the environment should be taken into
consideration by creating an optimum balance to ensure the sustainable
management of natural resources (Elvan, 2013). Sustainable develop­
ment is needed for the creation of this balance. Particularly in the late
1990s, under the increasing pressure from civil society, the mining
sector started a process of change to embrace sustainable development
(Boscio, 2016). Therefore, the mining industry plays a role in the
responsible development of the natural resources of the earth, given the
significant and direct social, environmental and economic impacts that
its operations can make (Ghorbani and Kuan, 2017). The value of metal
and mine production at the mining stage is described as the percentage
of GDP. This number gives an idea about the scale of value of production
based on the size of the economy (Ericsson and Lo €f, 2019). According to
the data of 2016, mining takes a share of 1.2% in the total global GDP. In
the same year, Turkey took a share of 0.82% (MAPEG, 2019).
It should not be ignored that meeting the demand for mineral
products is vital for sustainable development and social welfare (Nie�c
et al., 2014). Mineral resources are the “food” of industry (Ziran, 1999).
Before everything, a person needs mine throughout his/her whole life.
To maintain the status quo of daily life in the United States, each indi­
vidual requires 18.43 kg of new minerals, apart from non-fuel minerals
(MEC, 2019). (Fig. 1).
What are shown in this figure are the total 1445 tons of minerals,
metals, and fuels that an American will need in his/her lifetime on
average.1 Extracting the minerals that human beings will need
throughout their lives from the underground, and making them subject
to mineral processing process and subsequently making them suitable
for the use of industry and thus for human after smelting processes are
required.
There are several important matters on the evaluating of resources
for their transformation. One is the fact that the mining industry is long-
term in both respects, and the necessary time for a mine to be opened
and put into production, and that mine sites have been active for tens of

E-mail addresses: tdyildiz@atu.edu.tr, yildizta@itu.edu.tr.

1
Calculations are based on a life expectancy of 78.6 years and mineral use data from the National Mining Association, the U.S. Geological Survey and the U.S.
Energy Information Administration (MEC, 2019).

https://doi.org/10.1016/j.resourpol.2020.101706
Received 28 January 2020; Received in revised form 22 April 2020; Accepted 22 April 2020
Available online 1 June 2020
0301-4207/© 2020 Elsevier Ltd. All rights reserved.
T.D. Yıldız
Fig. 1. Amount of mineral that a person needs to use for his/her life in the USA
(MEC, 2019).
years (Bastida, 2014). The economic benefits in mining decrease
through the advancing stages of mining life, and all mines eventually
will usually finish in less than about 20–40 years (Boerchers et al.,
2018). According to (Clark and Clark, 1999), all around the world, the
mining industry generally has a historical reputation that is grossly
negative, and that causes almost all mining activities to be perceived
with concern by most stakeholders. With a footprint of only 0.3% of the
world’s ice-free soil, mining can still cause severe environmental
degradation at the local level (Boscio, 2016). While the natural re­
sources are rapidly depleted, wastes from production and consumption
are disposed to the environment without taking precautions; and, these
situations can cause environmental pollution. In fact, mining wastes are
one of the most critical environmental problems resulting from mining
operations. The most important environmental impacts of these wastes
could cause water pollution and insensitivity problems (Yıldız et al.,
2017). Other significant effects of mining wastes on the environment
other than water pollution and insensitivity are visual pollution,
degradation of land, deterioration of ecosystems, powdering, and
erosion (Cetiner et al., 2006). Depending on the types of mining activ­
ities, various wastes such as a cover layer, spoil, process wastes, heap
leach wastes, and wastewater are formed (Erdemoglu, 2016).
Cost-effective mechanisms can be used to provide the types of in­
dications related to the environmental damage that is necessary for the
scarcity of resources and that provides efficient resource utilization and
minimization of waste for making sustainable development possible
(Panayotou, 1995). In this context, companies need to incorporate the
sustainable development function into their core activities in order to
reconcile their internal risk orientations with the country’s development
priorities (De Sa, 2019). Environmental conformity seems costly at first
sight, but it gives a mining company a competitive advantage (Zvar­
ivadza, 2018). Nonetheless, there is no doubt that increasing social and
environmental demands associated with the sustainable development
will make entry into the mining industry a progressively costly and
complex process (Humphreys, 2001). So, mining comes at the price of
environmental and social impacts (Falck, 2016).
Environmental performance is significant in terms of competition
among mining companies. This is because mining firms are mainly
competing in the matter of cost (Bomsel et al., 1996). The cost structure
of the firm is an important internal condition that needs to be considered
in this competition (Flor� en et al., 2019). The cost risk in a project
2
Resources Policy 68 (2020) 101706
corresponds to exceeding the projected cost value. Uncertainties in the
economic conditions are one of the important cost risks (Aydin, 2006).
One of the factors posing an investment risk is the changes in the
regulation. With the effect of legislative changes in recent years, the
ratio of the prices of land use, such as forest fees,2 pasture fees,3 private
land permits and expropriation costs,4 for mining activities overlapping
with these areas, to MIA is quite high5 compared to other countries in
the world.
This situation causes Turkey to be more dependent on the outside
sources for mining, and only the rich parts of the mines to be evaluated
to cover the costs, and the remaining part to be left idle (Ko
€se and Unver,
2019). In this case, the share of WMC which can be evaluated out of the
category of land use costs within the OC and whether this share changes
according to different mineral groups are matter of concern. Addition­
ally, all over the world, there is no study conducted nor made sugges­
tions on the waste costs and their changes according to mineral groups
or on the waste cost factors arising from waste regulation. Taking these
deficiencies in literature, in this paper;
� Calculating how much of a share the mining companies that operate
according to the different mineral groups in Turkey have on average
within OC of WMC,
� Determining which factors play a role in changes of this share ac­
cording to the different mineral groups,
� Learning how the waste classification in the Mining Regulations
should be from the perspective of mining companies in Turkey, and,
bringing forward legislative proposals in line with the importance of
the recovery of mining waste for the purpose of avoiding a mining
investment risk, has been aimed.
2. Methods
In this study, first of all, surveys were conducted by using the “Survey
Monkey” in May, June, and July of 2018. The survey questions were
answered by the relevant departments of the mining companies. ‘‘Survey
Monkey’’ is a survey software in which the answers are transmitted
collectively, without revealing which companies have completed the
surveys and what kind of answers have been given to the questions.
Some of the 97 mining enterprises that participated chose not to answer
some questions in the Survey. It is tried to determine how the “waste
classification’’ should be in order to avoid the negative impact of WMC
on mining investments. Next, in “Section 3”, it was asked about the
waste costs paid to mining enterprises by using the survey program.
Each mining enterprise announced the costs they pay for their mineral
groups. The mineral groups stipulated by the legislation in Turkey are
presented in (Table 1).
According to the different mineral groups, the data of 58 mining
2
In Turkey, in order to carry out mining activities in forest areas, ‘‘forest land
permit cost’‘, ‘‘reforestation cost’‘, and ‘‘other costs (such as security deposit,
service, report, etc.)’’, security deposit of conformity to environment þ reha­
bilitation cost are required to be obtained from the mining enterprise. Ac­
cording to the survey conducted in 2018, in Turkey (the vast majority of
respondents in this study), the sum of all forest fees the mining enterprises will
be giving throughout the mine life constitutes an average of 38.32% of the total
MIA (Yıldız, 2020).
3
According to the research, due to the overlapping of pasture areas with
mining operating area, the ratio of all the prices paid by the enterprises to the
total of MIA is average 0.44% for all mineral groups (Yıldız, 2019).
4
According to the survey conducted in 2018, the ratio of private land permit
and expropriation costs to total MIA is 2.97% on average for all mineral groups
(Yıldız, 2020).
5
In many countries that the mining and natural stone sector are developing,
all property permits, including forest permits received for the mining activities
paid during the project, do not exceed 2% of the total MIA (Aydin, 2018; TMA,
2018).
T.D. Yıldız
companies that answered the “mining production amount” (MPA),
“WMC”, “OC”, “MIA”, questions at the same time were evaluated.
Therefore, the costs of the mining wastes of each mining enterprise are
proportioned to the annual average OC of these mining companies. The
necessity of considering the waste costs and waste recovery is estab­
lished for the production amount by emphasizing the fact that waste
costs increase as mining products increase. These costs were analyzed in
terms of different mineral groups. Also calculating the total share of
waste costs in mining investment and operational expenses, the total
waste costs spent per ton of mine production during investment and
operation periods in mining life are calculated approximately based on
the different mineral groups. When the results are evaluated separately
and collectively according to the mineral groups, it is seen that the
problems and the projections in the legislation are reflected in the costs.
It is detected that there is a need for legislation that is particularly
sensitive in waste classification and ensures waste recovery.6
3. Waste amounts based on the different types of waste & the
share of mining and environmental costs within GDP
Large amounts of waste occur depending on the waste/product ratio
in mining activities (Cetiner et al., 2006). According to the research
done by TurkStat, a total of 812 million tons of waste occurred from
mining enterprises in 2018.99.9% of it resulted from mineral wastes.
Also, it was detected that 97.9% of mineral wastes were composed of
stripping materials/spoil. 71.2% of the total waste was disposed in spoil
areas, tailing dam or at regular storage facilities, 26.2% of it were
back-filled into the mine, and 2.6% of it was either recycled (recovered)
with other methods or disposed. Thus, 17 million tons of waste was
generated in the mining enterprises except for stripping materials/spoil
(TurkStat, 2019). The change of the amount of mining waste according
to the years of 2010–2018 based on their types and waste dis­
posal/recovery in Turkey is shown below in detail (Table 2).
In this table, the data can be analyzed separately, and also with other
parameters. The ratio (%) of mining waste/tailing recovered by the
mining enterprises in Turkey to the total mining waste has decreased
over the years (Fig. 2).
As it is observed, this decline has parallels with the decline in mining
to a certain extent, especially in GDP. On the other hand, although there
is no increase in the number of mining enterprises, it is seen that the
number of regular mining waste storage facilities has increased due to
the changes in the mining waste regulation. As a matter of fact, a
considerable majority of mining wastes are being stored. It is significant
that these wastes are recovered as much as possible. Furthermore, all of
these wastes should be evaluated separately, considering whether they
are tailings generated in mineral processing plants or not.
6
In this study, only the mining sector views on the Mining Waste Regulation,
which is the legislation that affects WMC the most, was evaluated. Undoubt­
edly, there are a few other regulations in Turkey that affect WMC and waste
recovery. It was preferred not to mention them in this study (See about the
legislation envisaged in Turkey on mining wastes (Yıldız et al., 2017; Cetiner
et al., 2006)). For instance, one of them related to waste management is
“Regulation on Recovering Lands Degraded by Mining Activities” (Effective:
23rd January 2010). This Regulation is related to field rehabilitation during
and after the mining activities and is important environmental protection
legislation in terms of waste management. The addition of these rehabilitation
costs to WMC, which is the main theme of this article, can be considered in the
first place. However, although it may be thought that some of these costs fall
within the scope of WMC, it is more accurate to evaluate the costs covered by
this regulation within the scope of “rehabilitation costs.” Therefore, it was
preferred that rehabilitation costs should not be evaluated within the scope of
the article. For different information about this Regulation, EIA process and
rehabilitation practices, see: (Aforementioned Regulation Annex-1 (3); Yıldız,
2020; Yıldız, 2020, Yıldız et al., 2019, Yıldız et al., 2020, TUMMER, 2013;
MFWM, 2014).
3
Resources Policy 68 (2020) 101706
‘‘Spoil’’ is the stripping material released after excavation in mining
enterprises or the worthless, excavated barren material that emerges
during mine production. ‘‘Tailings’’, on the other hand, is the fine-
grained material with no economic value that residual after the
extraction of valuable minerals in the mineral processing plants in the
mining enterprises, and that is sent to tailing dam through getting mixed
with water (Ulusoy et al., 2011). Both of them are defined as ’’mining
waste’’ as a whole. Of these wastes, particularly tailings, are the mate­
rials that can be recovered more economically in the future.
According to the data of 2008, about 26, 500, 00 tons of plant wastes
generated in 91 mineral processing plants in Turkey (Aka, 2011). 79% of
these wastes emerged as a result of the enrichment of metallic mines,
16% of energy raw materials, and 5% of industrial raw materials
(Ercikdi et al., 2012) (Fig. 3).
The ores produced from the mine are generally low-grade. Coals are
not clean as they are extracted with the stones and schists that increase
the ash rate. For this reason, it is not economical as well as it is not
possible to sell the mines in their extraction form. Moreover, some mines
have no economic value with their extraction forms. Hence, almost all
mines are subject to mineral processing after they are extracted (Biro
€n and
Atak, 1986). Therefore, the enrichment of the mines that have no eco­
nomic values with their extraction forms is a necessity due to the tech­
nical, economic, and social reasons (Topaloglu, 2012).
The main aim of each company is to get the maximum profit. The
profit or the damage of company depends on two factors. The first factor
is the cost that the company will endure for the amount of product it will
produce and sell. And the second is the earnings it gains from the
products sold (Unay, 2000). The value of 1-ton ore depends on various
factors (Saltoglu, 2008). Today, the growing demands and prices for
minerals have created an opportunity to operate the low-grade ores and
even the old spoils economically. For instance, while the operability of
8gr/tons gold was considered to be economical in the 1950s, today, the
grades below 0.5–1 gr/ton can be operated economically. It is the same
for other metals. The copper mines with a grade of 0.5% and zinc mines
with a grade of 2% have become economically operable over the years
(Journal of Mining Turkey, 2012). In a study carried out for hundreds of
mineral deposits and projects, the decrease in the cut off grades that can
be used minimum over the decades of aforementioned minerals is seen
below-with the differences in terms of mineral deposits, projects, and
mines (Fig. 4).
Although the decline in the minimum operable cut-off grades around
the world indicates that new mining enterprises with low cut-off grades
can become open, it increases the competition in existing mining en­
terprises even more. In the face of this competition, the financial
strength of the enterprises has become more important. For this, in the
face of increasing mining WMC in the face of environmental expecta­
tions, mining enterprises should pay more attention to the recovery of
their wastes emerging as a result of their operations.
Waste storage (waste discharge, tailing dam, waste distribution
system, dry waste storage area, etc.), and waste management are some of
the most important mining investment components mentioned in the
feasibility reports with international validity (Promer Engineering,
2018). In addition to this investment, a mining enterprise is obliged to
allocate a share from the operational expense each year for all of the
above activities. Thus, all of these activities emerge as capital costs and
operational costs.
After the characterization and classification of wastes, the all
framework of the storage, management, and recovery of the waste have
been determined by the Regulation on Mining Wastes in Turkey (Yıldız
et al., 2017). All these issues are reflected in the mining operations as
cost items. The first step in the process of including environmental
protection in mining projects is to determine what environmental risks
are and what the protection costs are (Smith and Naito., 1998). The ratio
of total private and public expenditures for environmental protection in
the gross domestic product in EU countries was 1.11% on average as of
2013 (Eurostat, 2014). In Turkey, on the other hand, the ratio of
T.D. Yıldız Resources Policy 68 (2020) 101706

Table 1
Mineral groups in Turkish mining legislation (summary).a
Ist Group Minerals I (a) Sand and Gravel

I (b) Clays and rocks used in cement and ceramics industries

IInd Group Minerals
IIIrd Group Minerals
IVth Group Minerals
Vth Group Minerals
a
For a detailed version of this summary table, see (Yıldız, 2019; Topaloglu, 2016).
II (a) Aggregate rocks and rocks for ready-mix concrete and asphalt
II (b) Dimension stones, Marble, Travertine, Granite, Andesite, Basalt etc.
II (c) Ground/milled rocks for industrial use (Calcite, etc.)
Salts (incl. sea, lake, and spring water), CO2 gas (except geothermal, natural gas and petroleum areas, Hydrogen Sulfide
IV (a) Industrial minerals
IV (b) Peat, Lignite, Hard Coal, Anthracite, Asphaltite, Bituminous Schist/Shale Shale, Coccolith/Sapropel
IV (c) Metallic ores, rare earth elements/minerals
IV (ç) Radioactive minerals
Precious and semi-precious stones

Table 2
According to the years of 2010–2018, the amounts of mining waste by their types and waste disposal/recovery methods (TurkStat, 2019).
Category/year 2010 2012 2014 2016 2018

Number of mining establishments (Ores in operation) 1,482 3,945 4,846 3,810 3,865
Waste types (thousand tonnes) Total amount of waste generated (Thousand tonnes) 729,750 951,782 755,218 811,056 812,098
Total amount of hazardous waste 2,314 3,181 2,355 Confidential 11,177
data
Amount of hazardous mineral waste 2,307 3,168 2,350 Confidential 11,164
data
Total amount of non-hazardous waste 727,436 948,601 752,863 Confidential 800,922
data
Amount of non-hazardous mineral waste 726,561 947,175 750,973 805,845 800,374
Amount of overburden/tallow/spoil – 945,998 750,734 801,864 794,711
Waste disposal/recovery methods and amount of Recovered within establishment 5,327 182 4.1 0.1 0.04
waste (thousand tonnes) Recovered out of establishment (Sold/sent to licensed 1,161 9,336 8,303 5,677 5,973
waste treatment facilities)
Used for reclamation purposes in mining sites 13,687 54,021 51,134 105,709 14,462
Incinerated/co-incinerated 1.0 1.0 0.3 0.5 1.3
Backfilling 169,174 240,406 137,650 129,060 212,388
Disposed of in heaps for overburden/controlled landfill 531,485 648,024 558,155 617,197 578,186
sites
Disposed of in tailing dam 3,184 1,830 1,997
Dumping onto land 5,144 6,225 1,105 995 381
Disposed of by other methodsa 588 159 38 184 706
a
Includes deposit into dumping site indicated by municipality, temporary storage within the establishment, deposit into municipal dumping site, etc. (TurkStat,
2019).

Fig. 2. Relationship between mining waste amount & waste recovery & change of GDP share of mining.

4
T.D. Yıldız
Fig. 3. Distribution of the produced metal ore plant waste in Turkey (Aka, 2011).
expenditures for environmental protection in the gross domestic product
was 1.06% in 2016, while it was 1.11% in 2017.49% of these expendi­
tures were spent on waste management services (TurkStat, 2018)
(Fig. 5).
Allocating such a high share of waste management in GDP makes one
think how much expenditure on average the operation allocated in total
for mining waste, and whether this allocated expenditure creates an
investment risk or not when considering the mining sector.
4. Evaluation of WMC of mining enterprises in terms of MPA &
investment cost (IC) þ OC
Taking into consideration the possible demand for mineral, the
annual production, the life of the mineral deposit, and the amount of
investment required for the operation are determined (Sarac, 2008). The
limited availability of resources in a country requires that these should
be used in an efficient and maximum way without wastefulness. Because
investment projects (such as raw materials, capital, labor, etc.) are plans
which are made for the optimum utilization of limited economic re­
sources in a way to maximize their benefits. Investment is a strategic
decision that is of utmost importance for the companies (Ko €se and
Kahraman, 2009).
After the investment period comes to the production period. In order
to calculate costs in a fast, easy and healthy way, to provide effective
control opportunity, and most importantly to meet the requirements of
business management in the budgeting and decision-making phases, the
costs that constitute the expenditures have to be evaluated and analyzed
in terms of their qualities, characteristics, locations and types of costs
(So
€zbilir, 1986). At the same time, these cost data are also beneficial in
terms of the ability of the business executives to take measures against
the various risks they may encounter and develop various strategies to
minimize the risks (Uygun, 2014). How much of a share the different
types of costs for the different mining groups take on average in the
operating and investment costs are also extremely important for the
mining administrations and legislation making governments that carry
out the mining policies and management in the countries. WMC should
be examined within this scope.
5
Resources Policy 68 (2020) 101706
4.1. The share of WMC paid by mining enterprises in OC
4.1.1. The change relationship between mineral groups
After the investment has been made, and the operation has started
production, the expenditures to be made for carrying out the production
are called operating period expenses (Sarac, 2008). “Expense”: It can be
defined as the monetary value of the goods and services used and
consumed in a certain accounting period in order for the entity to
maintain its usual activities and assets and to generate income (Yukcu,
1992). All expenses incurred by a mining company during its production
activities constitute total OC (Ko €se and Kahraman, 2009). WMC consist
of the storage costs of tailings emerged as a result of mineral processing
activities, the permission/license costs required for this storage, and the
establishment and maintenance costs of the tailing dams as well as the
spoils emerged as a result of mining operation activities.
It is useful to determine the share of WMC in all costs in mining
operations. In this direction, mining companies were asked to reply to
the survey question that “How much is the yearly cost for waste? (Do not
include “Security Deposit of Compliance to Environment” in the calculation.
Include the costs in all the procedures, including the tailing dams in your
calculation)". Fifty-eight mining companies responded to the survey
question. The distribution of these responses by mineral groups is shown
below (Fig. 6).
In the figure, it is possible to calculate the share these WMC,7 which
are paid by the mining enterprises, take in each enterprise’s average
yearly OC.8 Accordingly, there are 58 mining companies that also
explained the “OC” from the mining companies which answer the
“WMC” question above. The ratio of the yearly average WMC to the
yearly average OC was calculated by distinguishing the mineral groups
of each mining enterprise (Table 3).
As shown in the table, the OC of the mining enterprises, according to
the mineral groups, are also different. On average, the WMC of these
mining enterprises are observed to be lower than the 4th group minerals
7
“Security Deposit of Conformity to Environment” taken from mining oper­
ations every year and “rehabilitation costs” paid during and after the operation
activity were not included in these “waste costs”.
8
In this calculation, the average WMC of each mining enterprise and the
average value of the cost range they stated in survey responses as OC are taken.
T.D. Yıldız
Fig. 4. Relative ore grades of gold, copper and zinc deposits, mines, and pro­
jects (Priester et al., 2019). (For interpretation of the references to colour in this
figure legend, the reader is referred to the Web version of this article.)
in Group 2nd group minerals (Fig. 7).
On the figure, it can be said that there is a very good exponential
relationship (R2 ¼ 0.95) between the yearly average WMC and the
mineral groups. The ratio of yearly average WMC to yearly average OC
varies according to the mineral groups, but on average, the shares are
between 0.82 and 7.50% (Fig. 8).
As can be seen in the figure, with the ratio of average waste to yearly
average OC, there is a very strong polynomial correlation (R2 ¼ 0.995)
between the mineral groups. Besides this strong correlation, it is note­
worthy that WMC have a share of 6–7% on average in OC in 4 (b) and 4
(c) mineral groups. Many factors can be listed as the reasons for the
higher WMC in these mineral groups. The wastes generated after the
production of these mines in this group are of thin dimensions and
require large tailing dams. Therefore, initial investment and OC are
high.
6
Resources Policy 68 (2020) 101706
2 (a) mineral group consists of minerals that are used for aggregate,
ready-mixed concrete and asphalt, such as Calcite, dolomite, lime­
stone, granite, andesite, basalt rocks. But, 2 (b) mineral group con­
sists of natural stones such as marble, travertine, granite, andesite
and basalt stones that are produced as blocks and used for decorative
purposes. There are no wastes that may harm the environment from
the mining activities in these mineral groups.
4 (a) mineral group is mostly composed of clay minerals and minerals
that contain salt. Borax, rock salt, sodium sulfate, potash (alunite),
soda, etc., as salt-type minerals can easily dissolve in water. For the
enrichment of this type of ores, saturated water is used in a closed
circuit. There is no direct discharge to the receiving environment.
However, when lead (PbS), zinc (ZnS), copper (CuFeS2), chromium
(Cr2O3FeO), iron (Fe2O3) mines in the process of mining activities in
which bauxite (Al2O3), feldspar, graphite, quartz, manganese,
magnesite, mica and coal are produced, the physical or physico­
chemical process methods are applied by crushing the structures to a
certain size without deteriorating. This type of minerals, generally
with low chemical solubility in water, generates chemical pollution
that is negligible in water compared to the salt-type minerals.
However, in the enrichment of precious metals such as gold and
silver, chemical methods are used. In such mineral enrichment
techniques, solvent chemicals are toxic. Both the mineral enrichment
facilities and the wastes/residues must be kept under control (Vardar
and Guney, 2008).
In the scope of the legislation in Turkey, wastes generated by the
production of 4 (c) group minerals require higher levels of control than
other mineral groups, as seen in Fig. 7. As a result, this group brought
about the separation of higher WMC of mining enterprises.
Thus, for all mineral groups, the yearly average WMC of mining
enterprises take an average of 3.16% of the yearly average OC. While
this share increased above the average of 6–7% for 4 (b) and 4 (c)
mineral groups, the biggest reason for the average value of all mineral
groups to be reduced to 3% was the fact that ~ 2/3 of the mining en­
terprises consist of 2 (a) and 2 (b) mineral groups. Assuming that an
equal number of mining enterprises from each mineral group responded
to the survey, the average WMC would have a share of 4.4% in the
mine’s OC.
4.1.2. The change relationship of MPA and WMC
It was stated in the second section that wastes consisted of the wastes
that emerged in mine production with stripping and of the mineral
processing tailings. The amount of this material is important in terms of
detecting the WMC. In order to determine the MPA for each mineral
group, the question, “What is the average ton/year of your mine production
output?” was asked to the mining enterprises. The distribution of the
answers, based on the mineral groups, given by 58 mining enterprises to
this question, is shown below (Fig. 9).
In the figure, MPA varies based on the mineral groups. It is beneficial
to analyze the change relationship between the MPA that vary according
to the aforementioned mineral groups and the WMC (Fig. 10).
As it will be examined in the figure, when the MPA in different
mineral groups increases, the WMC increase in a polynomial change. In
this analysis, the evaluation was made excluding 2 (a) group mines. The
correlation coefficient is R2 ¼ 0.97. Based on this data, there is a very
good degree of significance between MPA and WMC. The fact that there
is a relationship of significance moving a little bit away from the linear
change (R2 ¼ 0.83) indicates that actually larger waste storage facilities
and more efficient mineral processing plants can be established as the
MPA increases, thus reducing costs. In this cost fixation, the amount of
wastes coming out of mineral processing plants is determined primarily
by taking into account the raw ore/waste ratio. Especially in the scope of
the subject of the article, MPA is a significant parameter to determine
the waste storage facility costs and the storage costs of spoils that emerge
as a result of mine production and stripping. For the 4 (b) (coal) mineral
T.D. Yıldız Resources Policy 68 (2020) 101706

Fig. 5. Environmental protection expenditures according to the topics (2013–2017). (MEU, 2018; TurkStat, 2018).

Fig. 6. WMCa according to mineral groups (TLb).

a
"> 5 million”: 5–10 million TL, ie, the average of TL 7.5 million was accepted.
b
1 USD ¼ 4.84 Turkish Lira (TL) (16th July 2018) (Central Bank of the Republic of Turkey, 2019).

7
T.D. Yıldız Resources Policy 68 (2020) 101706

Table 3
Ratio of yearly average WMC to OC.
Mineral groups Number of mining MPA (tons/ Average yearly WMC of pperating period per 1-ton Yearly average OC The ratio of average WMC to
enterprises year) WMC (TL) mine production (TL) average OC (%)

2 (a) Group 15 1,221,933 52,333 0.94 10,675,000 0.82

2 (b) Group 25 67,020 241,000 10.59 13,160,000 2.52
4 (a) Group 4 1,196,250 1,408,750 2.87 28,125,000 4.81
4 (b) Group 12 823,588 1,635,714 19.39 21,178,571 6.35
4 (c) Group 2 1,175,000 1,875,000 4.47 25,000,000 7.50
For all mineral 58 638,320 609,397 9.17 15,484,914 3.16
groups

Fig. 7. Change in WMC based on the mineral groups.

group, the fact that WMC is high per 1 ton of mine production is
remarkable.
4.2. WMC of operating period per 1-ton mine production during the
lifetime of mining enterprise
In order to find the total of WMC per 1-ton mine production for the
entire lifetime of mining, these costs are required to be calculated
separately as IC and OC. In the section above, annual WMC was calcu­
lated on average for different mineral groups. In order to find the total
operating period of these costs, it is necessary to calculate approximately
the mining lifetime of these mining operations. The mining enterprises
participated in the survey were asked “the activity periods since the
beginning of mining operation” and “the remaining periods until the end
of mining operation activities”. The distribution of responses given by
the 58 mining enterprises is shown below (Fig. 11 (a) ve 11 (b)).
Among the questions that were asked to the mining enterprises
through the survey program, ’’the ratio of total waste IC to the invest­
ment costs’’ was not requested. However, the waste IC per 1-ton mine
production for the mining enterprises evaluated in the survey can be
found by taking9 this value at an average of 5%. In order to determine to
what extent the aforementioned waste IC of the mining enterprises take
9
The mining enterprises allocates approximately 5% of the total MIA as
“waste IC” (Promer Engineering, 2018).
a share in the MIA of each enterprise, the mining enterprises were asked,
‘‘What is the MIA of your mining enterprise (until the end of 2017)?” The
distribution of 58 answers given to this question by different mineral
groups is shown below (Fig. 12).
This distribution of MIA shows that the mining enterprises in Turkey
are mostly in small and medium-sized enterprises. This indicates that the
operational WMC paid by the mining enterprises will have a greater
impact on mining enterprises as a cost item. These mining enterprises
are planning to make new investments in 2018 and beyond. “How much
is the new MIA targeted for your mining operation in 2018 and beyond?” The
answers given by 58 mining enterprises to this question are given below
according to different mineral groups (Fig. 13).
The ‘‘total of current and future MIA’’ is found by adding the new
MIA that each mining enterprise aims for the year 2018 and later on
together with the existing MIA prior to 2018. The total of IC of the
mining enterprises spent for the waste –calculated in the above section-
and the annual waste OC for the life of mining are calculated to the total
MIA. Thus, the average WMC per 1 ton mine production through the
entire lifetime of the mining enterprise is calculated on average for
different mineral groups (Table 4).
In the table, throughout the entire lifetime of mining enterprises, the
WMC of operating period per 1-ton mine production is 372 TL/tons.
When the IC spent on the waste during the investment period is taken
into consideration, this number is 445 TL/tons. This number ranges
between 48 and 611 TL/tons based on different mineral groups. In order
to carry out the mining operation activities without damaging the

8
T.D. Yıldız Resources Policy 68 (2020) 101706

Fig. 8. Percentage of WMC to yearly average OC.

Fig. 9. MPA of the mining enterprises.a

a
In the figure, "> 1 million tons”: 1 million-3 million tons, i.e., the average of 2 million tons has been accepted.

environment where the mining takes place, mining enterprises make
these environmental expenses in accordance with the mining waste
regulation.
5. Evaluation of legislation in subjects of cost and recovery of
mining wastes
When the ore is produced in its natural state, it contains some
precious metals and some non-precious stones or other minerals. In this
way, the ore in a natural state is called “run-of-mine” or “raw ore’’, and
the non-precious part of the raw ore is called ’’gangue”. The process for
the separation of mineral/minerals from the gangue, which constitutes
the valuable part in the ore, is called “mineral processing”. As a result of
the mineral processing activity, a mine-rich ore is obtained, which
contains a small amount of gangue, which is called “concentrate”. The
part of more often gangue-containing that is separated from the mine is
called “tailing”. Concentrated ore, which is the raw material of metal­
lurgical plants, is turned into an almost pure mineral in metallurgical
plants. The gangue separated from the concentrated ore during this
smelting activity is called “slag” (Alpan, 1969).

9
T.D. Yıldız
Fig. 10. The Change relationship between the MPA based on the mineral groups and the WMC.
Mining activities generate crude ore and residues. Barren rock is
composed of excess ore, in the case of open-pit mining, it is 1–3 times
more than the ore produced. In underground mining, increasing costs
make it necessary to focus on the ore, and the amount of barren rock is
less than 10% of the volume of ore produced. Barren rock can be
completely metal-free, but generally includes some metal content, yet is
always below the degree of a cut-off grade of the mine (Priester et al.,
2019). When the material from the mine begins to be removed, the mine
is contemplated operational, and the development stripping becomes
waste stripping, an operational cost. Most orebodies are not homoge­
neous and accommodate large amounts of both waste rock and ore of
such low mineral content as to make concentrating unprofitable (Cross,
1965). So, after the mining activities during the excavations and receipt
of the ore, and after ore beneficiation process, the resulting millions of
tons of spoil and tail stored in the mining operating license field (Zan­
bak, 2015). According to mining activities, mineral processing methods
are also changeable. Therefore, after the enrichment process, waste
characteristics also vary. Besides, today, substances that are raised after
mining activities and are defined as “mining wastes” can be turned into
products with another technology that will be applied tomorrow. The
issue that should be taken into account at this point is whether the
substance from every enrichment process is “waste” or not (TMA Envi­
ronment Unit, 2011).
One of the most important issues concerning waste in the practices in
EU countries is the reduction of waste amount by means of reusing and
recovering, thus ensuring the optimum use of natural resources and by-
product identification. EU Mining Waste Directive encourages the
reduction of waste by means of reusing and recovering (Karapınar,
2012).
According to ‘‘By-product’’ definition in Article 19 (1) of Wastes
Management Regulation dated on April 02, 2015, in Turkey, Ore tal­
lows, which cannot be considered as a mining product due to the market
situation or minerals that cannot be considered as a mining product due
to variable prices in the world ore market and the ore spoil that stored in
the license area is called “mineral waste’‘.With the Ministry’s
conformable opinion, these can be considered as “by-products.
In the mining sector, waste and residues should be recovered within
the scope of “mining by-product,” and the number of companies that
manage the waste and residues appropriately should be increased. In the
marble and natural stone sector, for example, the most important
10
Resources Policy 68 (2020) 101706
residues that occur during the processing of the raw product are marble
pieces and marble powders. Although these residues are primarily
envisaged to be environmental pollutants, they are, in fact, commer­
cially valuable by-products. These mining by-products can be used as an
input in sectors such as paper industry, paint sector, plastic and cable
sector, plastering, paste, joint filling production, adhesive production,
food industry, ceramics industry, carpet base, flooring industry, filtra­
tion of harmful gases, etc. Thus, wastes of the marble sector should not
be evaluated in the same category as chemical wastes (TUMMER, 2013).
The block yield of marble from the open-pit ranges from 5 to 30%,
and this is generally less than 10%. While the blocks with high
machinability are sent from the quarries to the factories, the residual
parts are mixed together with the stripping materials at the closest
distance to the pit. Marble parts that are obtained in some mines and
which cannot be evaluated as block-rubble are sent mainly to the lime
industry, to the cement, gravel, construction, and fertilizer industry.
Primarily, wastes should be reduced in their resources; if this situation is
not possible, options such as recovery and use as an alternative raw
material are important. In this context, a legislative arrangement should
be prioritized to make the use of tailings mandatory. In this way, it can
be ensured that the parts and dust occurring in the marble and natural
stone production will not harm the environment. Furthermore, coop­
eration between related sectors may be provided to evaluate these
mining by-products; new areas of use can be supported (TUMMER,
2013).
For decades, on the matter of the recovering of tailings, some
omissions are made in Turkey. For example, by way of one of the pro­
jects carried out for the recovery of chromite ore tailings was made for
the recovery of Orhaneli chromite (Cr2O3) tailing; chromite concentrate
was increased to about 48.5%, and it was started to be made suitable for
the use of industry (Guney et al., 2016). After the studies, a project with
an MIA of USD 50 million was planned for the recovery of chromite
tailings/wastes in Mugla Gocek and its vicinity, which can provide for
51.5% of chromium concentrate (Turhan, 2012) for an average 14%
Cr203 ore grade ranging between 12 and 18% (Turhan, 2017). However,
these and other similar projects haven’t been put into practice; and so
recovery policies of the tailings have been ignored throughout the whole
of Turkey.
The Regulation on Mining Waste stipulates that the Ministry may
apply exemptions (promotion) to the facilities that process their own
T.D. Yıldız Resources Policy 68 (2020) 101706

Fig. 11. (a) Activity durations of mining enterprises since the start of the operationa.(b) The duration of the end of the operational activity of the mining enterprises.
a
In the figure "> 30 years”: 30 years–40 years, so the average was considered to be 35 years.

tailings/wastes. The recovery of these by transferring them to the same
facility or later to another facility will contribute to the economy and
employment (Demirkan, 2017). In this respect, if possible, recovery of
tailings/wastes should be a top priority in waste management (Fig. 14).
As can be seen from the figure, by the Ministry of Environment and
Urbanization, 2020 waste management is identified as -in order to
minimize the “disposal” and “sanitary landfill-only “prevention”
and“recovery, if possible. To achieve this goal, it has been revealed that
mining wastes should be defined and evaluated differently from other
wastes. According to the Regulations, materials that are not chemically
treated or heat-treated during the mining activities, processed only by
physical methods, not economical according to the conditions of the
day; nevertheless, materials which can be evaluated later according to
their economic conditions, should not be considered as “mining wastes”
(Yıldız et al., 2017).
However, in the Regulation on Mining Wastes, the difference be­
tween “waste” and “tailing”, which may be economical in the following
years depending on the technology or market conditions, is not taken
into consideration, and so all tailings are classified as waste. Moreover,
residues of the minerals that were gold, lead, zinc, and copper, which
can be produced as secondary mines, they are directly evaluated as
“hazardous wastes”. Whereas, for example, in the processes, they are
produced, tailings in the lead-zinc plant, which have no economic value,
may be economical as they allow the production of zinc oxide in the

11
T.D. Yıldız
Fig. 12. MIA of mining enterprises until the end of 2017.a
a
> 500 million TL”: 500 million - 1 billion TL, i.e., the average was accepted as 750 million TL.
Fig. 13. New MIA of mining enterprises in 2018 and the future.
future together with the developments in zinc technology. So that mil­
lions of tons of tailings will be able to gain economic value, and the base
of this economic asset will be laid with this application of the Regulation
(Demirkan, 2017).
Instead of the definitions such as ‘‘hazardous, non-hazardous, neither
hazardous nor non-hazardous wastes’’ for mineral wastes in the Regu­
lation on Mining Wastes that may cause misunderstandings among the
public or even representative offices in various government institutions,
it will be more beneficial to make nomenclature and determine appro­
priate content according to the mineralogy of minerals, the compounds
contained in the ore preparation/enrichment methods. For example; It
will be appropriate for sulfur-containing minerals to be defined as
mineral wastes with acid potential (such as chalcopyrite, pyrite, sphal­
erite, and galena), or as mineral wastes enriched with cyanide or acid
12
Resources Policy 68 (2020) 101706
–with their content-, or as “Class 1", “Class 2" and “Class 3". The rec­
ommended technical content of this classification may be the same as EU
legislation. The use of these definitions for mining wastes in this Regu­
lation is problematic in practice in terms of social perception/psychol­
ogy (Yıldız et al., 2017; Journal of Mining Turkey, 2014; Zanbak, 2015).
As observed, especially the definition of “hazardous,” “non-hazard­
ous” and “inert” waste in the Regulation on Mining Wastes have the
criteria of evaluating almost all mining wastes/tailings to the category of
“hazardous waste”. In order to learn the thoughts of the mining com­
panies on mining wastes, the question that “Do you think it is appropriate
for them to be defined as “non-hazardous,” “hazardous” or “inert” wastes in
Regulation on Mining Wastes?” was asked to 86 mining companies. The
distribution of their responses is shown in the diagram (Fig. 15).
As it can be seen from the figure, 52.3% of the respondents think
T.D. Yıldız Resources Policy 68 (2020) 101706

WMC per 1 ton mine production

for the entire lifetime of mining
Total operational þ investment

enterprise (TL/Ton)

611

425

611

385

445
48
WMC per 1 ton mine
to be produced for
investment period
(TL/ton)

308
28

63

69

82

72 Fig. 14. Aim of ministry waste management (MEU, 2011).

during the lifetime of mining
per 1-ton mine production
WMC of operating period

that: “Minerals can be defined according to the mineralogy of minerals,

mineral processing with the compounds they contain/enrichment methods, or
enterprise (TL/ton)

they may be defined as “Class 1", “Class 2" and “Class 3.” 47.7% of them
express that “the definition should remain in its current state”. It is also
beneficial to examine the changes of these answers that are given by the
aforementioned enterprises among the mineral groups (Table 5).
549

117

542

303

372
21

Since the number of respondents in the 1 (a) and 1 (b) mineral groups
in the table is one for each, it can be ignored in the evaluation. The
The lifetime of

majority of the 2 (b) mineral group (59%) is in favor of the current

definition of the mining waste. However, the majority of 4th group
enterprise

minerals (61%), especially those whose WMC is higher than other group
mining

(year)

39.7

41.6

49.4

40.6

42.5

41.5

minerals, are in favor of changing the definition of mining waste. Some

of the different evaluations of mining companies on the “Survey Mon­
key” are as follows:
The remaining end

enterprise activity
time of mining

� In this Regulation, it is beneficial to avoid generalizations. Each

mining operation project (with its wastes/tailings) should be sepa­
(year)

rately evaluated. In feasibility studies, this issue is already discussed

in detail or needs to be evaluated. What is essential is that each
21.9

21.6

26.6

21.4

22.8

22.0

project should be evaluated according to its own studies.

enterprise
operating
period of

� This issue should be based on detailed feasibility studies and

mining

(year)

geochemical studies. Cost is not a priority. In fact, what is important

Total of investment and operational expenses of for waste per 1-ton mine production.

17.8

20.0

22.8

19.2

19.8

19.4
The

should be the functional assessment of the environmental impact,

and the optimal prevention and waste disposal methods against it. So
this should be an engineering work. Whatever the cost is, the investor
WMC of the

period (TL/

has to bear it, of course.

operating

� Hazardous wastes should be examined in many ways. When the

1,408,750

1,635,714

1,875,000
year)

241,000

609,397
52,333

classification of the wastes from the mines are being classified as

“hazardous waste”, it should be carefully done, and be cautious that
the practice does not damage the mine operations.
waste IC (TL)

33,878,125

23,421,875

30,875,000

� According to mineral groups, that is, for example, there should be

1,312,500

1,935,000

9,420,474
Estimated

separate waste management of limestone, gold, and coal. Instead of

putting almost all mines into hazardous waste classification, such a
classification should be made. For example, if the tailings of coal
have economic value, these must be evaluated as “by-product” in the
67,756,2500

468,437,500

617,500,000

188,409,483
26,250,000

38,700,000
Total MIA

Regulation.
� In summary, the tailings should be classified according to the types of
(TL)

mines. Mines should not be classified as “hazardous and “non-

hazardous".
enterprises
Number of

The efficient recovering of waste and expired products at each stage

mining

of production significantly reduces the demand for primary raw mate­

15

25

12

58

rials, thereby alleviating the risk of procurement of critical raw materials

4

(TMA, 2011). Therefore, in order to maximize the recovery of mine

mineral

waste, determining a waste class within the scope mentioned should be

groups
Group

Group

Group

Group

Group
Mineral
Groups
Table 4

For all

not only the expectation of the mining sector but also other sectors.
2 (b)

4 (b)
2 (a)

4 (a)

4 (c)

The mining companies were asked a question on the topic of the

13
T.D. Yıldız Resources Policy 68 (2020) 101706

Fig. 15. Description of mining wastes in the Regulation on Mining Wastes.

applicability of the Regulation on Mining Wastes to provide economic

Table 5
operability of mine. The question that “Do you think the Regulation on
Description of mining wastes based on the mineral groups.
Mining Wastes is applicable in Turkey?” was asked. The distribution of
Mineral The definition should Minerals can be The total responses of 88 mining companies to this question is shown below
Groups remain in its current defined according to number of
(Fig. 16).
state the mineralogy of enterprises
minerals, mineral answered the As can be seen, only 13.6% of the surveyed mining companies think
processing with the survey based on that this Regulation is applicable. The other 29.6% finds that the
compounds they the mineral Regulation to be applicable, but it is of the opinion that the imple­
contain/enrichment groups
mentation of the Regulation will be postponed for a few more years. The
methods, or they may
be defined as “Class 100 , majority (56.8%) finds that the Regulation is not applicable in Turkey
“Class 200 and “Class 3." due to a significant increase in the costs of the application carried out,
The number % The number %
and thinks that -taking into account the different conditions in the
of enterprises of enterprises mines-more proper applications should be projected. It is useful to
answered the answered the examine the distribution of these answers given by the mining enter­
survey survey prises among the mineral groups (Table 6).
1 (a) 1 100.0 0 0.0 1 Similar to Table 5, in Table 6, when evaluated only within the 4th
Group group of minerals, 69% of the 4th group of minerals think that Mining
1 (b) 1 100.0 0 0.0 1 Waste Legislation significantly increases the costs and that more
Group
2 (a) 9 45.0 11 55.0 20
reasonable practices should be envisaged by considering the different
Group conditions in Mines. 28% believe that the mining waste legislation is
2 (b) 16 59.3 11 40.7 27 applicable, but that a few more years should be given for the start of the
Group application. Among the 4th group of minerals, only 3% think that what
4 (a) 3 30.0 7 70.0 10
is envisaged by the waste legislation is applicable. Among the 2 (a) and 2
Group
4 (b) 7 43.8 9 56.3 16 (b) group minerals, it is also remarkable that nearly half of them stated
Group that the “Mining Waste Legislation has significantly increased costs”.
4 (c) 4 40.0 6 60.0 10 Some of the different evaluations of the mining companies in the “Sur­
Group vey Monkey” survey software are as follows:

14
T.D. Yıldız Resources Policy 68 (2020) 101706

Fig. 16. Applicability of regulation on mining waste.

Table 6
Applicability of mining waste legislation based on the mineral groups.
Mineral What is envisaged by the legislation However, the start of the application It is not applicable. The costs have The total number of enterprises answered
Groups in Turkey is applicable. needs a few more years to be given. increased significantly. More the survey based on the mineral groups
reasonable applications should be
envisaged by considering the
different conditions in mines.

The number of enterprises % The number of enterprises % The number of enterprises %

answered the survey answered the survey answered the survey
1 (a) Group 0 0.0 1 100.0 0 0.0 1
1 (b) Group 1 100.0 0 0.0 0 0.0 1
2 (a) Group 7 36.8 3 15.8 9 47.4 19
2 (b) Group 2 7.7 10 38.5 14 53.8 26
4 (a) Group 0 0.0 4 40.0 6 60.0 10
4 (b) Group 0 0.0 1 6.3 15 93.8 16
4 (c) Group 1 10.0 5 50.0 4 40.0 10

� In applications of Regulations, there may be some biased attitudes
towards mining. In this case, small-scale companies can put in a very
difficult situation.
� From the lowest operating level, i.e., the applicability in terms of its
effect on small-scale companies should be considered. Many mining
sites have meager earnings. It is, therefore, not right to apply the
same sanctions and procedures for all mineral groups in the same
way.
6. Conclusion and suggestions
In Turkey (surveyed), the average yearly costs of mining wastes are
an average of 3.16% of all shares in the mineral group average yearly
OC. In fact, the fact that the share of this group exceeds 7%, according to
the mineral groups, shows that these costs are cost items that will not be
underestimated in all OC. Along with the increase in foreign exchange, it
is expected that the mining wastes expenditures will increase further,
and thus, the share of these shares will be increased within the OC.
In addition to the expenses of waste operating period, the waste IC
made prior to starting the enterprise constitutes a good part of the
mining WMC. The fact that forest fees, pasture fees, and private land
fees, and expropriation prices granted for mining operations overlap the
forest land, pasture area, private land in Turkey, and that they are high
in the MIA as being costs resulting from land use, this high share of WMC
in the investment and OC will economically force the mining companies
further. These costs need to be taken into account, especially in a newly
established mining operation, in the construction of a new ore prepa­
ration facility, a tailing dam, and a waste storage facility, before an

15
T.D. Yıldız
investment in a mining operation is made.
As there is a situation in which almost all tailings are to be classified
as ’’hazardous waste’’, the mining companies participated in the survey
ask for separate waste management to be established based on the
mineral groups, and for economically valuable wastes to be coded as a
by-product in the regulation. Instead of making generalizations in the
legislation, it is suggested that each mining project (with a waste proj­
ect) should be evaluated separately within itself.
Compared to the world average, the ratio of mining in Turkey to GDP
in recent years is low. Similarly, waste recovery is also-despite the leg­
islative arrangements for mining waste - at a low level. Minerals being
classified as “hazardous” and “non-hazardous” is an obstacle to the
recovering of mining tailing. However, it is the expectation of the
mining sector to have an identification for a waste class within the scope
mentioned in the study in order to maximize the recovery of mining
waste.
The majority of the 4th group of minerals, whose WMC are higher
compared to the other mineral groups, are in favor of changing the
definition of mining waste. At the same time, 97% of the 4th group of
minerals suggested that the Mining Waste Legislation has significantly
increased costs, or, although this Legislation may be applicable, it
should be given a few more years for the start of the application. Also,
within the 2nd group of minerals, even though the ones who think the
definition of mining waste should be changed are not the majority, the
share of those who believe the Mining Waste Legislation has signifi­
cantly increased costs is close to half.
Taking into the account the share of WMC in the mining IC,
considering the enterprise per 1-ton mine production for the entire
lifetime of mining enterprise, and the total WMC of investment period is
445 TL/tons on average, the mining enterprises bearing the costs makes
the importance of the possible earnings especially coming from the
waste recovery bigger.
Undoubtedly, for sustainable and environmentally friendly mining,
the requirements laid down in the legislation must be met. However,
although the companies make these environmental expenditures, in the
recovery of tailing, -compared to EU countries-Turkey is inadequate. In
this respect, necessary arrangements should be made in the legislation,
and, despite these expenditures for waste, the return of WMC to the
mining investor should be ensured with the encouragement of recovery
from tailing. Thus, it not only will be provided a more sensitive mining
environment but also increased the profitability rate in mining, hence
reducing the investment risks of the mining sector.
References
Aka, M., 2011. Management of Mining Waste in Turkey. Ministry of Environment and
Forestry & Waste Management Symposium. Antalya, 17-21 April, 65 pp. Available
via: https://docplayer.biz.tr/8111071-Turkiye-de-maden-atiklarinin-yonetimi.html.
Alpan, S., 1969. Mineral Processing. In: Mineral Research and Exploration Institute
(Turkey). Education Series Publications No: 4, Ankara, p. 15.
Aydin, H., 2006. Project cost risk analysis: an application in mining. In: Proceedings of
the 15th Coal Congress of Turkey (07-09 January). Zonguldak, pp. 209–216.
Aydin, O., 2018. Investor is in trouble .. (Foreword by journal editor). J. Min. Turk. 70, 4.
Available via: http://madencilikturkiye.com/madencilik-turkiye-dergisinin-70-sayi
si-cikti/.
Bastida, A.E., 2014. From extractive to transformative industries: paths for linkages and
diversification for resource-driven development. Miner. Econ. 27 (2–3), 73–87.
https://doi.org/10.1007/s13563-014-0062-8.
Bir€
on, C., Atak, S., 1986. Introduction to Mining Engineering. Istanbul, p. 219.
Boerchers, M., Sinclair, A.J., Gibson, R.B., Halden, N.M., 2018. “Sustainability is finding
the next mine”: the complicated relationships among legacies, sustainability, and EA.
Environ. Impact Assess. Rev. 71, 84–93. https://doi.org/10.1016/j.
eiar.2018.01.002.
Bomsel, O., B€ orkey, P., Glachant, M., Leveque, F., 1996. Is there room for environmental
self-regulation in the mining sector? Resour. Pol. 22 (1–2), 79–86. https://doi.org/
10.1016/S0301-4207(96)00030-X.
Boscio, N.D., 2016. Daniel Franks’ B Mountain movers—mining, sustainability and the
agents of change. Miner. Econ. 29 (1), 41–43. https://doi.org/10.1007/s13563-016-
0079-2.
Central Bank of the Republic of Turkey, 2019. Indicative exchange rates & Central Bank
rates by date. Available via: https://www.tcmb.gov.tr/kurlar/kurlar_tr.html, 05th
December, 2019.
16
Resources Policy 68 (2020) 101706
Cetiner, E.G., Unver, B., Hindistan, M.A., 2006. Regulations related with mining wastes:
European community and Turkey. J. Min. 45 (1), 23–34. Available via: https://www
.madencilik.org.tr/article/04416eacf9fd75b_ek.pdf.
Clark, A.L., Clark, J.C., 1999. The new reality of mineral development: social and
cultural issues in Asia and pacific nations. Resour. Pol. 25, 189–196. https://doi.org/
10.1016/S0301-4207(99)00026-4.
Cross, B.K., 1965. A Systems Analysis of the Open Pit Mine Design Problem. The
University of Arizona, p. 85. Available via: http://hdl.handle.net/10150/554010.
De Sa, P., 2019. Mining and sustainable development: territorializing the mining
industry. Miner. Econ. 32 (2), 131–143. https://doi.org/10.1007/s13563-018-0149-
8.
Demirkan, H., 2017. Mining Regulatory Changes and Restructuring in Turkey. Our Life Is
Mine. Meeting Booklet, Antalya, p. 31.
Elvan, O.D., 2013. The legal environmental risk analysis (LERA) sample of mining and
the environment in Turkish legislation. Resour. Pol. 38, 252–257. https://doi.org/
10.1016/j.resourpol.2013.03.008.
Promer Engineering, 2018. Costing studies in mining plants. J. Min. Turk. 74, 44–46.
Available via: http://madencilikturkiye.com/madencilik-turkiye-dergisinin-74-sayi
si-cikti/.
Ercikdi, B., Cihangir, F., Kesimal, A., Deveci, H., 2012. Putty pack technology in plant
waste management. J. Min. Turk. 24, 71–76. Available via: https://www.mtmagaza.
com/wp-content/uploads/2018/05/Madencilik-Turkiye-Dergisi-Sayi-24-52aefgg.
pdf.
Erdemoglu, M., 2016. Environmental Planning in Mining and Mining Wastes Assessment
Course Notes, p. 242.
Ericsson, M., L€ of, O., 2019. Mining’s contribution to national economies between 1996
and 2016. Miner. Econ. 32, 223–250. https://doi.org/10.1007/s13563-019-00191-
6.
Eurostat, 2014. Environmental protection expenditure of private and public specialized
producers. Available via. https://ec.europa.eu/eurostat/tgm/table.do?tab¼table
&init¼1&plugin¼1&pcode¼ten00061&language¼en.
Falck, W.E., 2016. Social licencing in mining—between ethical dilemmas and economic
risk management. Miner. Econ. 29 (2–3), 97–104. https://doi.org/10.1007/s13563-
016-0089-0.
Flor�en, H., Frishammar, J., L€of, A., Ericsson, M., 2019. Raw materials management in
iron and steelmaking firms. Miner. Econ. 32, 39–47. https://doi.org/10.1007/
s13563-018-0158-7.
Ghorbani, Y., Kuan, S.H., 2017. A review of sustainable development in the Chilean
mining sector: past, present and future. Int. J. Min. Reclamat. Environ. 31 (2),
137–165. https://doi.org/10.1080/17480930.2015.1128799.
Guney, A., Kangal, M.O., Ozer,
€ M., Yenial, U., 2016. Concentration possibilities of
Orhaneli chromite mineral processing plant tailings. In: 15th International Mineral
Processing Symposium. Istanbul, pp. 322–334. October 19-21.
Humphreys, D., 2001. Sustainable development: can the mining industry afford it?
Resour. Pol. 27, 1–7. https://doi.org/10.1016/S0301-4207(01)00003-4.
Journal of Mining Turkey, 2012. The solution of current account deficit is a strong
mining industry. (Interview with muhterem k€ ose). J. Min. Turk. 24, 46–53. Available
via: https://www.mtmagaza.com/wp-content/uploads/2018/05/Madencilik-Turkiy
e-Dergisi-Sayi-24-52aefgg.pdf.
Journal of Mining Turkey, 2014. Opened to the Regulation on Mining Wastes Draft
Opinion Miners, vol. 41, pp. 70–71. Available via: https://www.mtmagaza.com/wp-
content/uploads/2018/05/Madencilik-Turkiye-Dergisi-Sayi-41-45677sbrb.pdf.
Karapınar, N., 2012. Impressions on the visit to Italy within the scope of the mineral
waste management project. J. Min. Turk. 26, 74–81. Available via: https://www.
mtmagaza.com/wp-content/uploads/2018/05/Madencilik-Turkiye-Dergisi-Sayi-
26-weds84f.pdf.
K€
ose, H., Kahraman, B., 2009. Mining Operation Economics, third ed., vol. 223. Dokuz
Eylül University Faculty of Engineering Publications, Izmir, p. 339.
K€
ose, M., Unver, B., 2019. Why should the forest permit fees Be revised? J. Min. Turk. 77,
134–138. Available via: http://madencilikturkiye.com/madencilik-turkiye-dergi
sinin-77-sayisi-cikti/.
MAPEG, 2019. Mining statistics. Ministry of energy and natural resources of Turkey,
general directorate of mining and petroleum affairs (MAPEG). Available via: http://
www.mapeg.gov.tr/maden_istatistik.aspx.
MEC, 2019. Minerals Education Coalition (MEC), Society for Mining. Metallurgy &
Exploration Foundation. Available via: https://mineralseducationcoalition.
org/mining-mineral-statistics/.
MEU, 2011. Waste Management Applications in Mining Sector (23rd December 2011
Presentation). Ministry of Environment and Urbanization (MEU), Turkish Republic
Tekirda� g Provincial Directorate of Environment and Urbanization.
MEU, 2018. Environmental protection expenditures. Available via: https://cevreselgost
ergeler.csb.gov.tr/cevre-koruma-harcamalari-i-85708.
MFWM, 2014. Mine Site Rehabilitation Action Plan. Ministry of Forestry and Water
Management (MFWM), Ankara, p. 124.
Nie�c, M., Galos, K., Szamałek, K., 2014. Main challenges of mineral resources policy of
Poland. Resour. Pol. 42, 93–103. https://doi.org/10.1016/j.resourpol.2014.10.010.
Panayotou, T., 1995. Economic Instruments for Environmental Management and
Sustainable Development. United Nations Environment Programme, Environment
and Economics Unit, Nairobi, p. 73. Available via: https://www.cbd.int/doc/nbs
ap/finance/Panayotou1994EconInstEnvMgSusDev_199EcInsEnvMgSusDev.pdf.
Priester, M., Ericsson, M., Dolega, P., L€ of, O., 2019. Mineral grades: an important
indicator for environmental impact of mineral exploitation. Miner. Econ. 32 (1),
49–73. https://doi.org/10.1007/s13563-018-00168-x.
Saltoglu, S., 2008. Explorations and investigations in mineral deposits. Min. Eng, Open.
Pit Oper. Handb. 2, 57–88.
T.D. Yıldız
Sarac, S., 2008. General Mining, vol. 80. Süleyman Demirel University Faculty of
Engineering and Architecture, p. 244.
Smith, D., Naito, K., 1998. Asian mining legislation: policy issues and recent
developments. Resour. Pol. 24 (2), 125–132. https://doi.org/10.1016/S0301-4207
(98)00021-X.
S€
ozbilir, H., 1986. Use of Cost Information as a Tool for Management to Increase
Effectiveness at Hospitals and a Case Study in Afyon. Anadolu University
Publications. No:35, Eskisehir. Quoted from (Uygun, 2014).
TMA, 2011. Mining, Environment, and Critical Raw Materials in the European Union.
Istanbul, p. 170. Available via: http://www.turkiyemadencilerdernegi.org.tr/conte
nt/docs/ab-madencilik-rpt.pdf.
TMA, 2018. Mining problems and solution suggestions report. TMA Sect. News Bull. 72,
23–36. Available via: https://www.tmder.org.tr/modules/faq/datafiles/FILE
_023031-DD93F5-842115-C5DE84-237B24-EBFD75.pdf.
TMA Environment Unit, 2011. Management of mining wastes regulatory management.
TMA Sect. News Bull. 40, 14–16. Available via: https://www.tmder.org.tr/modules/
faq/datafiles/FILE_FFB9E8-C4FEA5-98AE47-94D941-D2499D-D8F8E8.pdf.
Topaloglu, M., 2012. Scope of mining operation activities and processing facilities. TMA
Sect. News Bull. 44, 56–59. Available via: https://www.tmder.org.tr/modules/faq/d
atafiles/FILE_94D0C9-FDDCDE-17CCAE-1C353C-780136-D9FDD7.pdf.
Topaloglu, M., 2016. Mining Law No. 3213 and Related Regulations (Translation).
IMMIB, p. 617p.
TUMMER, IMMIB, EIP, 2013. Marble and Natural Stone Strategic Action Plan 2011-
2023, p. 29.
Turhan, M., 2012. Memories of Gocek. TMA Sect. News Bull. 42, 70–72. Available via:
https://www.tmder.org.tr/modules/faq/datafiles/FILE_6D52FD-B8ADFC-DE
9415-301C04-D9EF50-27B6FE.pdf.
Turhan, M., 2017. A ferrochrome adventure. TMA Sect. News Bull. 66, 102–112.
Available via: https://www.tmder.org.tr/modules/faq/datafiles/66.pdf.
TurkStat, 2018. Environmental protection expenditure statistics (2017). Available via.
http://www.tuik.gov.tr/PreHaberBultenleri.do?id¼27673.
TurkStat, 2019. Mining Establishments Water, Wastewater, and Waste Statistics, 2018.
Available via: http://www.tuik.gov.tr/PreHaberBultenleri.do?id¼30670.
Ulusoy, R., Ekmekci, M., Gercek, H., Cetin, K.O.,
€ Aktar, M., 2011. Earth Sciences
Glossary of Engineering Terms. Chamber of Mining Engineers, Ankara, p. 262.
Unay, C., 2000. General Economics, second ed. Ekin Publishing, Bursa, p. 510.
Uygun, R., 2014. Formation of Production Costs in Underground Mining Operations
According to the Cost Locations. Cost System in Mining Operations & Accounting
and Tax Practices – Chosen Articles, pp. 11–26.
Vardar, M., Guney, A., 2008. Mining and environment: scientific mining. TEMA. Journal
of Yeşiliz, p. 7.
17
Resources Policy 68 (2020) 101706
Yukcu, S., 1992. Cost Accounting (In Terms of Management). Izmir, p. 557.
Yıldız, T.D., 2019. The share of required costs in investment amounts for mining
operating activities in pasture lands in Turkey. J. Eng. Sci. Adiyamman Univ. 6 (10),
23–31. Available via: https://dergipark.org.tr/tr/download/article-file/736499.
Yıldız, T.D., 2020. The impacts of EIA procedure on the mining sector in the permit
process of mining operating activities & Turkey analysis. Resour. Pol. 67 https://doi.
org/10.1016/j.resourpol.2020.101681.
Yıldız, T.D., 2020. Evaluation of forestland use in mining operation activities in Turkey
in terms of sustainable natural resources. Land Use Pol. 96 https://doi.org/10.1016/
j.landusepol.2020.104638.
Yıldız, T.D., 2020. The Effects of Expropriation Process and Costs on Mining Enterprises
before Mining Operation Activities in Turkey & Evaluation of Legislation. Land Use
Policy (Unpublished yet, minor revision).
Yıldız, T.D., 2020. Forest Fees Paid to Permit Mining Extractive Operations on Turkey’s
Forestlands & Ratio to Investments. Gospodarka Surowcami Mineralnymi: Mineral
Resources Management (Accepted).
Yıldız, T.D., Guner, O., Kural, O., 2017. Effects of regulation on mining wastes on mining
sector, 25th international mining congress and exhibition. April 11-14, 457-472,
Antalya. Available via: https://www.researchgate.net/publication/329962843_Turk
iye%27de_Maden_Atiklari_Yonetmeligi%27nin_Madencilik_Sektorune_Etkileri.
Yıldız, T.D., Kural, O., Aslan, Z., 2019. Problems and solutions in relation to permits
required to Be perform mining operation activities in forest lands in Turkey. 1st
international sişli science congress. October 24-25, 159-160, Istanbul. Available via:
https://www.sisli.edu.tr/uisbk/2019/tr/wp-content/uploads/2019/09/issc-abst
ractsbook.pdf.
Yıldız, T.D., Kural, O., Aslan, Z., 2020. Problems and Solutions in Relation to Permits
Required to Be Perform Mining Operation Activities in Forest Lands in Turkey.
Academic Studies in the Field of Science and Mathematics. Gece Bookstore
Publishing, pp. 23–46. Available via: https://www.gecekitapligi.com/Webkontrol/
uploads/Fck/FenBilimleriveMatematik.pdf.
Zanbak, C., 2015. Regulation on mining wastes (15th july 2015) developments from 2001
to present and regulation review. TMA Sect. News Bull. 58, 70–74. Available via:
https://www.tmder.org.tr/modules/faq/datafiles/FILE_B4029A-DE2F6C-E03F99-0
98D77-936166-4D0FF9.pdf.
Ziran, Z., 1999. Natural resources planning, management, and sustainable use in China.
Resour. Pol. 25, 211–220. https://doi.org/10.1016/S0301-4207(99)00028-8.
Zvarivadza, T., 2018. Sustainability in the mining industry: an evaluation of the National
Planning Commission’s diagnostic overview. Resour. Pol. 56, 70–77. https://doi.
org/10.1016/j.resourpol.2018.01.008.