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By Tim O’Neil

Big and getting bigger. Barrick Gold Corp., the third-largest gold producer in the world, began production in September — ahead of schedule — at its Meikle Mine. At a scheduled full production rate of 12.4 t/a (400,000oz/year), it will be the largest producing underground gold mine in the United States. The $180-million Meikle Mine is located on Barrick’s Goldstrike property in Nevada and has 205 t(6.6 million oz) of gold reserves. The compact Meikle deposit has an average ore grade of 23 g/t (0.68 oz/st), making it one of the highest-grade mines in the country.

Jan 1, 1996

By Earl M. Frizzell, Ronald W. Utley

Introduction For the past several years the Bureau of Mines has undertaken research to develop alternative mine material haulage systems that will improve mine productivity, reduce haulage costs, increase mineral availability, and conserve energy. One basic concept being pursued is a means for crushing primary blasted rock to a size that can be reliably and economically moved on conveyors. During 1980, mine requirements for this equipment and the capability of existing technology to satisfy these requirements were assessed. The study continued into 1981 on the basis that satisfactory equipment for this purpose needed to be developed. The objective of the 1981 program was to perform an engineering design of such a system. A mine survey and equipment development study was conducted in cooperation with the open-pit mining industry by GATX through its subsidiaries, Fuller Co. (a crusher manufacturer) and GARD Inc. (GATX's research and development center), under contract to the USBM. Results of a mine survey in the copper, iron, and molybdenum industries indicated that a universal crusher system could be developed even though details might vary from mine to mine. The crushing characteristics, including tonnages desired, were similar in all surveyed mines. Most mines had similar views about the desirability and frequency of crusher movement. The perceived need for in-nit crushing varied between copper and iron mining. The copper mines felt a greater sense of urgency for introduction of such a system, probably because typically greater vertical haulage is found in copper mines than in the iron mines. All mine personnel surveyed were interested in portable crushers and almost universally preferred gyratory-type primary crushers. They preferred large crushers, citing inherent reliability and durability, and the machine's relative freedom from clogging. Large size minimizes the number of crushers and conveyors needed. Analysis of desired crusher system characteristics (Table 1) fixed the crusher size at 1.5 x 2.3 m (60 x 89 in.). The 1.5-m (60-in.) feed-opening dimension could accept the largest material normally fed to the crusher, and the 2.3-m (894n.) head diameter could fulfill the 3.63 kt/h (4,000 stph) capacity requirement. Selected System Description The comments and analyses discussed in the contract report led to the design and refinement of a movable crusher system. This system represents the consensus of more than 100 mine workers and almost 50 construction and engineering company personnel. It is supported by more than 50 years of experience in crusher manufacturing. Although many alternatives are available for any given system, and selections are likely to be dictated by varying site conditions, the selected system is believed to be appropriate for most projected requirements. Final design would be dictated by mine operators during evaluation for approved projects. Detail design of the feed and discharge systems were not included in the study because they are mine specific. The basic system (Fig. 1) consists of a 1.5 x 2.3-m (60 x 89-in.) gyratory crusher on a structural steel frame. The frame is used as an operating platform for the crusher and as a carriage to move the crusher. The control tower includes a crusher lubrication room, a hydraulic equipment room, a switch gear room, a room for the motor control center, and a control room for operating the crusher and maintaining the equipment. The auxiliary system consists of a hydraulic rock hammer and pedestal crane with 74-t (80-st) and 14-t (15-st) hooks. Figure 1 also shows stairs, railings, and a work platform. Feed and discharge arrangements are shown on Fig. 2. The system shown is for mildclimate applications. Additional enclosure and heating would be needed for extremely cold weather conditions. Crusher A 1.5 x 2.3-m (60 x 89-in.) gyra¬tory crusher was selected for this application. This size can handle the typical throughput of 3-3.63 kt/h (3,500-4,000 stph) desired by the mines and the 1.3-m (50-in.) material to be crushed without difficulty. The crusher is the heaviest

Jan 4, 1983

By G. Van Weert

Separation of minerals by shape has received little attention, since minerals normally do not break into different shapes during crushing and grinding. However, comminution of consumer wastes generates opportunities for novel separations based on particle shape. For instance, ductile plastics are broken into longer curved shapes, whereas brittle plastics yield angular particles. Using spouting beds for particle separation in water requires controlling the spout's instability. The preferred geometry for such redesigned spouting beds is reported. Plastic cylinders, discs and spheres were separated as a function of rising water velocity and amount of particles in the system. By using 5 mm particles, differences in settling behavior could be video recorded.

Jan 1, 1999

By Edward Marszalek, Boleslaw Firganek

The paper deals with a computer method and algorithm of optimization of the rescue routes for the endangered staff in the case of fire in a given place of the mine. The adapted method is based on the objective function and realizes the algorithm of the shorest path with weighers assigned to it. The objective function is so defined that it reflects possibly all the hazards and difficulties arising during a fire in the mine. The algorithm is enhanced by an empirical formula for calculation of the smoke zone as result of a mine fire. The presented results of computations of optimal routes for several simple examples using the canonical scheme of the mine network and simulated fires are satisfying and prove the method, the algorithm and the coded program to be correct. The program will be a part of the software library of the mine ventilation engineer. The data for the program will be updated on-line from the fire detection systems.

Jan 1, 1989

By C. H. Sampaio

The effectiveness of modem spirals in the processing of fines from Brazilian coals is assessed and discussed. Coals representing the four major coalfields in Brazil have been cleaned in Reichert LD 9 spirals in pilot and industrial plants and performance results are here presented. Normalized distribution curves for all equipment and splitters are presented and were modeled using an empirical model. These data have been compared with those for shaking tables and water-only cyclones (WOC), and it has been observed that, in the size interval investigated, spirals have indeed superior accuracy than WOC and comparative performance to tables. By analyzing experimental as well as simulation results it could be observed that although limited by the poor liberation characteristics of most Brazilian coals, significant ash and sulfur removal could be achieved using spirals.

Jan 1, 1995

By Keith S. Liddell

he selection of mill design parameters to suit the applica­tion requirements can result in quite different operating parame­ters for each generic type of application, even though the basic mechanical layout of the mills may remain similar. The selection of the type and size of grinding media is very important to efficient and cost-effective operation, and to ensuring that the milled product achieves the required properties. Accordingly, the grinding media selection is seen as an integral part of the mill design. Consideration of the requirement for classification is important in order to achieve the optimum mill and circuit performance. This can lead to the circuit feed not being classified for a steady feed with minimal slimes and a low size reduction ratio. Feed containing on-size particles would be deslimed by open circuit classification. Closed circuit classification is performed where the feed fluctuates. The rheological characteris­tics of the circuit feed slurry can have an influence on mill performance, and needs to be allowed for. A common misconception frequently encountered is the belief that "a mill is just a mill". This is not the case with stirred types of mills, since the operating parameters selected for the mill can have a large effect on the product characteristics. For example, horizontal shaft high speed stirred mills have a com­pletely different grinding action to vertical shaft low to medium speed stirred mills, which results in large differences between the surface area produced at a given product size (Liddell, 1986). Hence, it can be misleading to apply test results or design procedures obtained from one type of mill to other types for scale-up. The Metprotech stirred mill, as applied in the mining and minerals industries, is a low to medium speed vertical shaft mill. The basic design has been discussed previously (Liddell, 1989). Currently, the largest mills that have been manufactured have an installed power of 400 kW. The largest chamber volume at this power is 6000 litres, containing IO t of grinding media. It is intended that the installed power will increase up to lMW as applications requiring larger sizes arise.

Jan 1, 1995

By Tommy B. Thompson

The Cripple Creek diatreme-intrusive complex is known primarily for its vein telluride-gold ores. It is also known for the great vertical range of its major veins - >990 m (>3250 ft). Not as well-documented, however, are the ores dispersed into the wallrocks adjacent to veins, the ores associated with hydrothermal and tectonic breccias, or mineralized zones within fluvial, lacustrine and volcaniclastic rocks de- posited within the diatreme complex. The ore-gangue minerals were precipitated from oxidized, alkaline fluids that yielded an abundance of carbonate, sulfate and oxide minerals along with minor base metal sulfides and precious metal tellurides. Wallrock alteration is limited adjacent to veins and is more extensive within hydrothermal and tectonic breccias. Cripple Creek background The Cripple Creek district has a spectacular production history. More than 653 t (21 million oz) of gold were recovered between 1891 and 1959. Early published accounts documented the principal production from narrow- sheeted vein systems (Cross and Penrose, 1895; Lindgren and Ransome, 1906; Loughlin, 1927; Loughlin and Koschmann, 1935). Production also came from spectacular open-space fillings within the Cresson diatreme, also known as the Cresson “blow-out” (Patton, 1917; Patton and Wolf, 1915). Beginning in the mid- l96Os, more modern studies were initiated by the US Geological Survey (USGS) (Gott et al. , 1967, 1969; Kleinkopf et al., 1970) and by universities (Lane, 1976: Dwelley, 1984; Trippel, 1985; Thompson et al., 1985; Saunders, 1986; Birmingham, 1987; Eriksson, 1987; Nelson, 1989; Wood, 1990; Seibel, 1991).

Jan 1, 1992

By J. Navoyski, B. Macdonald, W. J. Helfrich, J. L. Bellanca, B. Demich

DISCLAIMER The findings and conclusions in this paper are those of the authors and do not necessarily represent the official position of the National Institute for Occupational Safety and Health, Centers for Disease Control and Prevention. Mention of company names or products does not constitute endorsement by NIOSH. ABSTRACT The pervasiveness of high-fidelity video games raises expectations of quality, detail, and lighting in virtual reality (VR) applications. However, high-quality models of mining equipment and environments are often not readily available, and developers may not be familiar with the latest techniques, such as physically based rendering (PBR). Because a consistent aesthetic is critical for maintaining immersion and controlling visual stimuli in research as well as in training, researchers at the National Institute for Occupational Safety and Health (NIOSH) created an asset development workflow. This paper details this workflow, including precision modeling and PBR techniques as well as a rigorous review process. It also describes lessons learned in the creation of photorealistic VR assets. BACKGROUND Virtual reality (VR) describes the simulated experience generated by an assemblage of hardware and software that are used to immerse the user. Over many years VR developers targeted the development of virtual environments (VE) toward various purposes: entertainment, the treatment of phobias [1], rehabilitation [2], and training [3]. A large part of the VE development includes digital assets, where digital assets refer to the non-programmed elements including 3D models, audio, and user interface. Because vision provides nearly 10Mbps of data [4] and accounts for the majority of all sensory input combined [5], a focused effort on asset appearance in VEs is warranted. Furthermore, research has shown that higher-resolution imagery increases search performance and training transfer, necessitating high-fidelity assets [6, 7]. In addition to being visually appealing, it is important that the assets and environment are also dimensionally accurate and consistent in order to elicit appropriate responses from the end users as they interact with and among these items [8, 9]. Researchers at the National Institute for Occupational Safety and Health (NIOSH) have developed VEs and digital assets under several research projects over the course of the last two decades [10, 11, 12, 13]. This work has provided researchers with a strong knowledge base for digital asset development. However, the assets themselves have had limited reuse value. Due to the extended timeframes and limited scope of these projects, the previously developed assets are not consistent in visual quality and dimensional accuracy. Moving forward, researchers wanted to minimize future development time and use of resources as well as adopt new asset development tools and game engine technology. Therefore, the aim of this paper is to document a new asset development workflow including geometry, materials, UV layout, and shader implementation combined with review steps in order to produce high-fidelity simulation assets that are accurate with consistent characteristics, using repeatable methodologies that are well documented.

Jan 1, 2019

By J. Noll, E. Cauda, T. Barone, S. Vanderslice

Measuring diesel particulate matter (DPM) for underground metal/nonmetal mine compliance samples is done by collecting DPM onto quartz fiber filters and analyzing the samples via NIOSH method 5040 for elemental carbon (EC) and total carbon (TC). As part of the sampling train, two quartz fiber filters in tandem are housed inside an SKC DPM cassette that includes an impactor. The impactor segregates DPM and mine dust, and the second filter is used to correct for adsorption of vapor phase organic carbon (OC). Since the value of the second filter is subtracted from the first, the pre-existing carbon on the filter media for both filters needs to be comparable. In addition, the pre-existing carbon on the media should be low for accurate and sensitive results. However, there have been some reports of elevated OC on the filter media of the SKC DPM cassettes, which would cause the limit of detection (LOD) to be higher than reported at times. In this study, blank SKC DPM cassettes from different batches and with different expiration dates were analyzed to quantify the amount of carbon on the filter media and to determine the LOD and limit of quantification (LOQ) associated with these samplers. It was found that the organic carbon and total carbon on the media was about five times higher than quartz media used in samplers from other studies. The average TC on the blanks was 2.57 μg/cm2 with a standard deviation of 0.70, resulting in a LOD of 21 μg/m3 TC, 8-hr Time Weighted Average (TWA), and LOQ of 69 μg/m3 TC, 8-hr TWA, when using these samplers for collecting DPM. The LOD and LOQ may be improved through some sample preparation techniques. INTRODUCTION Exposure to diesel exhaust (DE) is associated with an increased risk for lung cancer and other adverse health effects (Attfield et al. 2012, Silverman et al. 2012, Ping and Guang 2017, IARC 2012). Pronk et al. 2009 reported that the highest exposed groups to elemental carbon (EC) from DE worked in underground sites in mining and construction and they were exposed to concentrations between 27–658 μg/m3. At concentrations (1–25 μg/m3 EC) well below those observed in mining, diesel particulate matter (DPM) exposures were estimated to increase the risk of cancer by levels exceeding those typically acceptable for occupational risk in the United States and Europe (Vermeulen et al. 2014). This suggests that underground miners are especially at risk because of their more substantial exposures in confined working spaces. As a protective measure, in 2001, the Mine Safety and Health Administration (MSHA) promulgated a rule to limit exposures of metal/nonmetal underground miners to DPM to an 8-hr time-weighted average (TWA) of 160 μg/m3 total carbon (TC) (MSHA 2001, 2006).

Jan 1, 2019

By Edward H. Peplow

Mr. Chairman; honored guests; ladies and gentlemen: The subject assigned me today by your committee, according to the program, is "the mineral industry and the public land law I have preferred to title the talk, "you can't mine here", for that is the essence of the message we, as an industry, have been getting from so many agencies of the federal government for so long. And, unfortunately, we can expect to hear the same message even louder and clearer -- with increasing frequency in future, unless. Every segment of the industry devotes the necessary time, energy and creative thought to combat successfully the forces that are writing and broadcasting that message. I said that agencies of the federal government are sending the message --- and this, of course, is true, the forest service, for example, and some bureaus of the department of the interior as well as others have appeared in recent years to be abiding by a policy designed to block mineral entry to as much of the public lands as possible and to wipe out existing mining claims.

Jan 1, 1967

By H. Soto, J. Jara, F. Nava, J. B. Hiskey, B. J. Scheiner

Laboratory tests showed that ozone can destroy free cyanide and weakly complexed cyanide (copper and zinc cyanides). The iron cyanide complexes were resilient to ozonation but they were effectively eliminated by precipitation with Fe (II) ions under controlled pH conditions. Tests carried out with effluents from a number of gold mills confirmed the results obtained previously in the laboratory. The industrial samples contained cyanide in the form of free cyanide and also complex copper, zinc and iron cyanides. Solutions that contained up to 184 mg/L total cyanide, after the ozone treatment analyzed only 2-3 mg/L dissociable cyanide and 50-90 mg/L CN(t) (accounted for by iron complexes). After precipitation with ferrous ions total cyanide was reduced below 1.5 mg/L. For most solutions ozone consumption ranges from 3 to 6 g per g of cyanide destroyed. However, certain impurities (such as SCN and S203 ), present in some effluents, increase ozone consumption and make it more difficult to reduce copper concentration to satisfactory levels.

Jan 1, 1993

By Steve Kral

The Prospectors and Developers Association of Canada (PDAC) was established in 1932 in response to proposed regulations that would have threatened prospectors in Ontario. From there, the association grew to represent the interests of Canada?s mineral exploration and development industry. The PDAC?s mission statement reads: ?The PDAC exists to protect and promote the interests of the Canadian mineral exploration sector and to ensure a robust mining industry in Canada. The PDAC will encourage the highest standards of technical, environment, safety and social practices in Canada and internationally. ?Today, the PDAC?s 6,000 individual members include prospectors, developers, geoscientists, consultants, mining executives and students. In addition, the association?s membership includes 950 corporate members, representing senior, mid-sized and junior mining companies in addition to organizations that provide services and equipment to the mining industry. In 2010, the PDAC adopted its e3 Plus principles, a framework to guide its membership in responsible exploration.

Jan 1, 2011

By Peter Zhang, Daniel Su, Bo Hyun Kim

Shale gas wells drilled in longwall chain pillars are influenced by longwall mining. Longwall mining on each side of the chain pillars can create overburden movements and induce deformations in gas well casings. If the deformations result in a casing breach, intrusive shale gas could leak into the longwall mine with serious safety consequences. This study concerns five shale gas wells in the chain pillars between two adjacent longwall panels in the Pittsburgh coal seam under a cover depth of 670 ft and a mining height of 7 ft. The gas wells were constructed with typical casing design, but a casing cementing alternative with uncemented production casings was practiced. Four production casings were uncemented, and one production casing was unintentionally cemented with good quality cement to a 535-ft depth and low-quality cement stringers from a 444- to 535-ft depth. The longwall faces passed by the shale gas wells as each adjacent longwall panel retreated. Production casings were surveyed by a multi-finger caliper after each panel was mined. No deformation was detected in the four uncemented production casings, but small deformations were detected in the partially cemented production casing. The maximum measured deformation in the cemented production casing was 0.05 in. after first panel mining and 0.06 in. after second panel mining. The casing deformations were also predicted by the FLAC3D model set up on site-specific overburden geology. The predicted deformations were in good agreement with the measurements in terms of deformation locations and magnitudes. All five shale gas wells resumed normal production after being temporarily plugged during the period of mine-by. This study provides a successful demonstration of the effectiveness of a casing cementing alternative for decoupling production and intermediate casing, and thus minimizing the influence of longwall mining in the shale gas wells drilled through longwall chain pillars.

Jul 1, 2023

By Mostafa Benzaazoua, Mariam El Adnani, My Ahmed Boumehdi, Rachid Hakkou, Salah Ouhamdouch, Abdelmalek Goumih

This study focuses on the environmental characterization and assessment of long-term neutral mine drainage (CND) potential from waste rock piles at the abandoned Erdouz mine in Morocco. The study involved metallographic analysis, static tests, and column tests. Results indicate that the waste rock is not an acid mine drainage generator but produces CND, mainly with sulfates exceeding Moroccan standards. The waste rock is relatively stable and could be reused after pretreatment.

Jan 25, 2022

By I. O. Otunniyi

The natural hydrophobic response flotation method for beneficiation of printed circuit board comminution fines (PCB CF) still requires many studies to further basic understanding of the process and the flotation traits that the PCB CF presents. Varying particle size distribution (PSD) and water recovery under the scheme show that higher mass pull, obtained at the finer PSD, gave lower water recovery but higher value loss. The reverse also holds: the least mass pull at the coarsest PSD used, -106 + 75 µm, gave the highest water recovery per unit mass pull with the highest reverse recovery. This is unlike what obtains in primary resources processing, where higher water recovery is often with increased fines entrainment. The reverse recovery loss here is, therefore, more due to entrapment with the heavy mass pull characteristic of the method than to the entrainment of value with water. Other peculiarities of the system observed are discussed, with the goal of improving the performance of the process, and broadening the general knowledge of flotation systems.

By Norman F. Schulz

The technical excellence of separation achieved in a mineral concentration process, or any other process where two constituents of any kind are physically separated from each other, is expressed uniquely and quantitatively by the Separation Efficiency: ES = (R ? Rg) where R is the percentage of the valuable constituent and Rg the percentage of the waste appearing in the concentrate. The Separation Efficiency meets all the usual requirements of a true efficiency and is independent of the nature of the process used. It can be visualized as the percentage of the feed material that, in effect, actually undergoes complete separation while the rest of the feed is distributed randomly and unchanged into the two separation products.

Jan 1, 1969

By Ronald L. Wiegel

The United States produces approximately 40 mil- lion tons of phosphate rock per year. Most of this rock is converted to diammonium phosphate and used as a fertilizer component for the domestic and international agricultural market. Much of this phosphate rock production is concentrated in the southeastern United States, with about half coming from washing and screening operations and half from flotation separation from sand and clay. This paper summarizes current operating practice in the industry and touches on some of the emerging technologies required to solve the problems associated with a diminishing high- grade reserve and the need to implement dolomite/francolite separations on a commercial scale.

Jan 1, 1999

By Arash Habibi, Anna Cable, David Loring, Aleksandar D. Bugarski, Logan Ingalls, Calvin Rutter

The results of diesel particulate matter (DPM) monitoring were used by the underground mining industry to mitigate adverse effects of exposure to DPM. NIOSH Method 5040, currently used for ambient and personal exposure monitoring, does not provide needed real-time information. The objective of this study is to develop a methodology for continuous monitoring of DPM concentrations in an underground environment, founded on the application of the Dekati electrical particle sensor (DePS). The DePS, which measures concentrations of submicron aerosol in real time using a diffusion-charging sensor, was evaluated by comparing the results of the concurrent measurements with reference methods at several locations downstream of the diesel-powered equipment. The DePS results were found to correlate well to those obtained by reference methods. However, it was found that dependence of the response on the physical and chemical properties of aerosols necessitates sitespecific correlation factors for the targeted matrices. The site-specific factors for number and mass of diesel aerosols were derived using the results of concurrent measurements with TSI NanoScan, FLIR Airtec, and carbon analyses performed on the concurrently collected filter samples. The results showed that methodology based on compensated DePS measurements would be suitable for continuous monitoring of DPM in underground mining operations.

Dec 1, 2022

By J. M. Link

A technique is presented for the economic selection of a slurry pipeline with the aid of a computer. Mathematical models for the flows of homogeneous slurries are utilized. Only the pipeline and its prime movers are considered. Slurry flow properties are first obtained from rheology and/or pipeline data measurements. A rheological model is then selected for the slurry. It must be emphasized that the accuracy of the method is greatly affected by the accuracy of the slurry flow-property data. Approximate cost parameters may be selected from data for plain and lined pipes, centrifugal and positive displacement pumps, motors and engines. Cost data for the purchase, operation and maintenance of slurry pipelines are also described. A total cost equation for the ownership and operation of a slurry pipeline system is then established. The complexity of the equation is a function of the rheological model selected to describe the slurry. The equation is solved with the aid of a computer for several combinations of pipeline diameters and throughputs to yield minimum total annual cost for the system. A mean velocity is then computed to give the required throughput. The velocity is constrained by an upper and lower bound. A high velocity is undesirable from an energy consumption viewpoint and if pipeline wear is possible. On the other hand, the velocity must exceed the deposition velocity for a heterogeneous suspension or the critical velocity for a homogeneous suspension. There is no guarantee that the velocity developed by this method will lie within the constraints applied, nor that the constraints are even known. This is particularly true for heterogeneous slurries. An important feature of the method is the ease with which the variables can be adjusted to measure the sensitivity of the total cost to the variables. The purpose of the sensitivity analysis is to identify those critical variables that. if changed, can considerably affect the total cost. Mathematically, individual variables are changed and the effect of such a change on the annual total cost is computed. But from a designer's point of view, individual components in the system are changed to study their effect on the annual total cost. A change in one component of the system may involve a change in one or more variables. For example, the replacement of a steel pipe by a smooth-lined pipe will change the pipewall roughness and wall thickness as well as purchase, operating, and maintenance costs.

Jan 1, 1974

By Gail L. Achterman

Most mining companies today perform site assessments and operational or compliance audits regularly. The purpose of these audits is to review company facilities and operations to determine whether they comply with applicable federal, state and local environmental laws and regulations. Why Audit? Companies adopt assessment and audit programs for legal and business reasons. The business reasons include: (1) ensuring efficient and cost-effective compliance through early problem identification and resolution; (2) planning and implementing business transactions such as real estate conveyances, loans, mergers and acquisitions, and waste disposal service contracts; and (3) employee training and relations. Legal reasons for audits include: (1) avoiding enforcement actions and penalties; (2) meeting environmental permit certification requirements; (3) avoiding corporate officer liability; and (4) meeting Security and Exchange Commission disclosure requirements. The Environmental Protection Agency ("EPA") encourages environmental auditing by regulated entities. The EPA Environmental Auditing Policy Statement was published in the Federal Register on July 9, 1986 (51 Fed Reg 25,004). Although the existence of an auditing program does not create a defense to or otherwise limit a company's regulatory responsibilities, EPA considers compliance programs in setting inspection and enforcement priorities. If a company makes an honest effort to identify and correct its own problems, EPA's enforcement approach is influenced, especially if violations are promptly reported. Perhaps more significant to many executives, the U.S. Department of Justice issued guidelines last year on when it will pursue criminal prosecution for environmental violations. See Department of Justice, "Factors and Decisions on Criminal Prosecutions for Environmental Violations in the Context of Significant Voluntary Compliance or Disclosure Efforts by the Violator," (July 1, 1991). It is now commonplace to read about major companies pleading guilty to criminal violations and paying millions of dollars in penalties. For example ALCOA recently agreed to pay criminal fines and civil penalties totaling $7.5 million for unauthorized excavation of PCB-contaminated soil and improper dumping of spent caustic solution. No executive wants to explain to the Board of Directors or shareholders why the company was criminally indicted. The Department of Justice considers factors such as voluntary disclosure, preventive measures and compliance programs, such as a regular compliance auditing program, the effectiveness of the disciplinary system for employees who violate the company's environmental policies, and subsequent compliance efforts by companies to remedy ongoing noncompliance. The Department of Justice looks closely at whether audit recommendations were implemented in a timely way and whether environmental compliance was a standard by which employees were judged. The Lawyer's Role. The role of the lawyer in an audit team deserves special attention. When enforcement action or litigation has begun or is contemplated or a government agency has asked for information, attorneys always should be directly involved in environmental audits. In most situations, however, environmental audits are management tools, and the attorney's role should be to advise the team. The attorney can help make sure the team understands the laws and regulations the facility must

Jan 1, 1992