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By I. J. Wu

China’s land area, comparable in size to United States or Canada, contains diverse geological environments and mineral resource potential. The diversity in geological environments is such that the potential for developing many world-class mineral deposits in China is good. However, China’s mining sector was not open to foreign investment until the1990s. The long-term prospect for Chinese resource development is attractive because of China’s enormous population and cumulative demand for minerals. Approximately 33 foreign mineral companies, including 11 major internationals, are to various degrees active in China. Chinese mining laws and regulations pertaining to joint ventures with foreign companies are, from the international investment prospective, evolving slowly, but positively. This positive trend is continuing under the current government reform process, which is moving China towards a freer market economy. Although improving the enforcement of relevant laws and regulations is an ongoing process, the environment for mineral investment and joint ventures is increasingly more accommodating to foreign companies.

Jan 1, 2000

By John H. Bassarear

The never ending search for lower unit costs led Pima Mining Company's management to study various alternatives shortly after Expansion III was completed. It soon became apparent that a considerable amount of ore assaying 0.35% copper had to be moved in order to maintain mill feed at the desired 0.54% copper content, which is the overall grade of the ore reserves. Detailed investigations revealed that for a period of 8 - 10 years, about 14,000 tons per day of 0.30 - 0.40% copper ore would pass by the crusher en-route to the low grade stockpile. This ore is very hard, very clean and has to be mined at a relatively uniform rate. A six month pilot plant run testing autogenous and semi-autogenous grinding gave very encouraging results. Since no mining costs need to be charged to the extra tonnage (it had to be mined anyway) the only major costs would be against milling. The decision to proceed was made in August 1970 and Fluor-Utah was retained as the prime design construction contractor. Ore was first put through the new mill on December 29, 1971. By March of 1972 design tonnage of 14,000 TPD had been attained. The first three expansions at Pima Mining Company, 20 miles south of Tucson, increased mill capacity from 3,000 TPD to 36,000 TPD. These expansions included a separate, conventional, three stage crushing plant plus additions to the existing concentrator that primarily duplicated the then current flowsheet. Expansion IV, however, consisted of an entirely new and separate primary crusher and a completely new mill building located about 2,000 feet southeast of the 01 d concentrator. The new mill, using semi-autogenous grinding, produces scavenger and rougher flotation concentrates that are pumped to the old mill for regrinding, cleaning, thickening and filtration.

Jan 1, 1973

By H. Huang, R. N. Gow

"EH-pH diagrams are useful tools in understanding how mineral surfaces react in solution and particularly how aqueous conditions can be changed to enhance mineral leaching processes. Successful application of these diagrams, however, requires that several considerations be kept in mind to prevent what had been termed as “gross errors” in their calculation and use. In this paper, the aqueous Cu-S system is used as the basis for explaining the mass-balanced method of calculating EH-pH diagrams with the STABCAL thermodynamic equilibrium software. A breakdown of the Gibbs’ Phase Rule and how it is used in STABCAL to modify the diagrams is included. The methodology was applied to the aqueous Cu-As-S system, and resulting diagrams were compared against examples of those generated using the predominant-ion method. The complexity of such diagrams increases with every additional component, and competition between species becomes more apparent, as can be seen by curvature in the resulting mass-balanced diagrams. The complete diagram for enargite (Cu3AsS4) is shown. It compares well with spectroelectrochemical measurements from Raman spectroscopy and cyclic voltammetry studies.IntroductionInnovation in the field of processing arsenicbearing copper ores has been of particular interest. Copper arsenic sulfosalt minerals such as enargite (Cu3AsS4) and tennanite (Cu12As4S13) are now frequently prevalent in ore bodies as the oxide and easily leachable sulfides become harder to find. These minerals, unless pretreated somehow, concentrate in copper sulfide flotation processes, in turn concentrating the arsenic levels. Increasing environmental restrictions on arsenic content for smelters makes the hydrometallurgical processing of these concentrates more favorable. While enargite is considered one of the more refractory copper sulfides, more so than chalcopyrite (CuFeS2), there are still several methods, both industrially proven and in development, that are capable of processing these ore types. Alkaline sulfide leaching can be used as a pretreatment method to solubilize arsenic selectively (Delfini et al., 2003; Anderson and Twidwell, 2008; Tongamp, Takasaki and Shibayama, 2010a, 2010b), or the entire metal content can be leached using acid-type leaches such as acidified ferric sulfate (Dutrizac, 1981; Hackl et al., 1995; Klauber, 2008), or the chloride assisted, CESL (McDonald and Muir, 2007) or nitrogen species catalyzed (Anderson, 2003) processes can be used.As development of these leaching technologies proceed, it is also important to develop an understanding of the mineral thermodynamics. To date, there are numerous studies on the Cu-Fe-S-H2O system, particularly as it relates to chalcopyrite leaching, yet few studies have done on the Cu-As-S-H2O system. Computer-generated EH-pH diagrams have been employed to illustrate the importance of thermodynamic calculations in providing insight into such a system."

Jan 1, 2016

By Y. Okahara

The chlorination behaviors of pure iron and manganese oxides were investigated by combining a thermogravimetric analysis (TGA) technique with batch-boat roasting followed by leaching. Ferrous and manganeus oxides could be chlorinated readily, but, in the absence of a reductant, the higher oxides of both iron and manganese were difficult to chlorinate. Thermogravimetric analysis curves were drawn to illustrate the complexitites of the reactions, and the possible mechanisms were discussed. Then three manganiferous materials from the Cuyuna Range of Minnesota were treated by a process involving the selective chlorination of manganese followed by leaching. The results were interpreted in the light of the chlorination mechanisms observed on the pure iron and manganese oxides.

Jan 1, 1969

By C. J. Burkhalter, H. Andrade, T. C. A. Gardner, J. P. Campbell

During the 1990’s several copper heap leach facilities treating crushed and agglomerated oxide and sulfide ore were constructed in South America. The majority of these facilities have been in operation for at least three years, during which time the operators have been able to monitor the performance of the heaps. The basis for the paper is a compilation of these operators’ experiences, leading to a discussion of the lessons learned over the past decade. Several key geotechnical issues are examined, focusing upon the integrity of the ore, drainage material and pipe network, along with the success of any inter-lift liners.

Jan 1, 2002

By R. Frim, S. D. Ukeles

The present U.S. production of bromine is from inland brines located in Arkansas and Michigan. The most concentrated domestic brines (up to 5,000 ppm bromide) are situated in Arkansas. Less concentrated brines (about 2,500 ppm bromide) are located in Michigan. The amount of bromine sold or used in the United States came from three companies operating in Arkansas and Michigan. Arkansas, with its six plants, was the leading U.S. state in bromine production. Bromine being the leading mineral commodity valuewise produced in the state. The Michigan bromine production was a byproduct of magnesium compounds production.

Jan 1, 2006

By MOHAMMED AMINE BELMI, ANAS DRIOUCH, ABDELAZIZ LAHMILI, LATIFA OUADIF

For many years, underground workings in the Bou Azzer mine have been challenged by geotechnical problems related to the serpentinite instability. The stage of evaluation of the compression potential is crucial to develop an appropriate drilling method and the choice of non-standard support. This research work presents a retro-analysis of serpentinite behavior in underground excavations at different depths, using a multi-approach method, based on several empirical and semi-empirical and theoretical-analytical methods, calibrated by the observational method. The analysis performed in this work reveals that underground excavations in Bouazzer East and Ait Hmane area would encounter compression problems that were recognized as the most serious from a depth of 300 m because of the effects of lithology and tectonics. Therefore, the Aghbar region has a slightly negligible compression potential. The compressive failure mechanism in this mine, depending on the mechanical strength, is started at induced stress of 9 MPa.

Nov 27, 2021

By D. J. Pandelis, W. J. Schlittler

Auxiliary Equipment pumping systems to support primary, secondary and regrind grinding circuits will be the primary focus of this paper. Every grinding system is unique and requires special design considerations for proper application of pumps to transport mill discharge. To satisfy the majority of applications, a new series of pumps has been developed by Svedala, known as World Class Pumps. Selection of these newly developed pumps for each type of grinding circuit will be presented. Specific components of selection are materials of construction, piping system, classification method, material characteristics and slurry characteristics. Both horizontal and vertical pump applications will be reviewed with emphasis on rules of pump piping and sump design.

Jan 1, 1999

By A. J. Dudzik

In 2006 Arch Materials initiated the development of an underground limestone mining complex. The decision to proceed with the project was the end result of several years of market research and geological reconnaissance. The scope of the project included the construction of two declines to the mining horizons located approximately 900 feet below the surface, the means and methods of this phase will be the primary focus of this discussion. The design, fabrication and erection of a state of the art crushing and screening processing plant which when completed will have the primary crushing located on the mine level allowing uniformly sized material to be brought to the surface by means of a highly efficient conveyor system and a surface portion of the plant where material would be additionally processed, screened and stockpiled into specific product types. Also included in the scope of the project is the construction of offices, warehouse and shop facilities necessary to support the operations, commercial sales and distribution of the finished products.

Jan 1, 2010

By M. A. Stoakes, H. D. S. Miller

Surface subsidence is becoming an increasingly important factor in the economics of mining Louisiana salt domes due to, amongst others, excessive shaft deformations and land loss to encroaching sea water. The vast majority of subsidence studies have been undertaken on bedded, tabular deposits. It is important to understand the causes of subsidence due to mining domal salt and how it can be minimized. The paper will review the major differences between subsidence caused by domal and tabular evaporite mines, the problems encountered in predicting subsidence, the factors that influence subsidence and, finally, possible alternative mining methods.

Jan 1, 1986

By Anna Kate Miller, James J. Brady, Hamza Jaffal, Ritika Sangroya, Chadi El Mohtar, Wing Shun Kwan

"The design of an appropriate pre-grouting program can be the difference between a successful tunnel construction and an expensive on-the-go repair. However, current grout design relies heavily on rulesof- thumb and outdated charts. The geotechnical investigation is rarely targeted towards grouting design and the final grouting decisions are made based on fines content or soil classification. The current paper presents an experimental study performed to determine the optimal grout for a tunnel in soft ground below the ground water table (GWT). The testing program consisted of sieve analysis and undrained static triaxial tests on reconstituted sonic samples. Rheological tests were used to compare the different grout mixes and identify best candidates before performing one-dimensional permeation tests. Pressure and volume measurements during the permeation tests, along with the unconfined compression strength results on the permeated soils, helped evaluate the filtration potential for the different grouts and select the optimal grout.INTRODUCTIONConstruction of the Millwoods Double Barrel Replacement Project commenced in 2009 and was expected to be completed by 2015. To facilitate ongoing city development in south Edmonton, the City implemented construction of a major sanitary trunk network along 91st Street and 30th Avenue. The project involved the design and construction of approximately 1.2 miles (2 km) of 7.8-ft (2,400 mm) sanitary tunnel and 2.1 miles (3.4 km) of 11.5-ft. (3,500 mm) and 9.5-ft. (2,900 mm) storm tunnel. Part of the project also involved the conversion of the existing double barrel storm and sanitary trunk to full sanitary service, and reconnecting the local storm sewers from the double barrel pipe to the new storm tunnel. The tunnels range in depth from 26-ft. (8 m) to 115-ft. (35 m) and are being installed using a one pass system with precast concrete segmental liners."

Jan 1, 2016

By R. Merkl

Since the 1940s, decanter centrifuges have become more important for increasingly complex solid-liquid or solid-liquid-liquid separation processes. Sometimes processed industrial or metalliferous minerals are abrasive or are treated with corrosive chemical agents. Traditional mining applications include the processing of coal, gravel and other products, where low-speed decanters, as well as screen bowl decanters and filters, dominate. These have been increasingly replaced by high-speed decanters during the last decade. Decanter centrifuges also started to play a key role in applications such as drilling muds, processing carbonates and separating SX crud in copper platinum ore concentrations of nickel and gold. Communication between machine producers and mineral processing engineers is vital for the right choice of materials and the design of the right decanter centrifuge for the individual process.

Feb 1, 2012

By E. A. Schmidt

In 1962, while investigating the tungsten potential in the Thompson Creek area for Union Carbide Corp., Henry T. Eyrich obtained anomalous concentrations of molybdenum (up to 19 ppm Mo) from stream sediment samples collected along Pat Hughes Creek, a tributary to Thompson Creek. Follow-up investigations by Eyrich during the same year disclosed the presence of a hydrothermally altered and molybdenite-bearing granitic exposure in the headwaters of Pat Hughes Creek about 2.4 km (1.5 miles) upstream from the sample point. The altered outcrop measured about 549 by 305 m (1800 by 1000 ft), contained abundant northwest-trending quartz veins locally with molybdenite, and was overlain and surrounded by the Challis volcanic extrusive sequence of mid-Tertiary age. Eyrich's subsequent soil and rock chip geochemical sampling program over the altered outcrop area showed a general increase in the molybdenum content to the northwest toward the postmineral Challis volcanic cover. Over a distance of about 305 m (1000 ft), values in the altered intrusive rock increased from less than 5 ppm Mo to over 600 ppm Mo, with aconcomitant intensity of the hydrothermal alteration pattern. Based on these geochemical results and on preliminar; megascopic hydrothermal alteration studies, Eyrich correctly concluded that the altered outcrop is an erosional window and that molybdenum mineralization of sufficient grade could exist beneath the Challis volcanic cover some distance further to the northwest. His recommendation to test the area of potential molybdenum mineralization with several drill holes was, however, declined by Union Carbide in 1962. The property remained unclaimed until 1967, when Eyrich joined Cyprus Mines Corp. Acting on Eyrich's recommendation, Cyprus immediately staked 26 lode mining claims to cover not only the altered intrusive outcrop, but also the northwest trend of mineralization where it projected beneath Challis volcanic rocks. Eleven of these claims are now patented.

Jan 1, 1991

By Bob Munz, Ry Stone

To facilitate the installation of the longwall equipment for each extraction panel, West Elk mine develops set-up room roadways that are between 26.5 and 30.5 feet wide. Historically at the mine, the set-up room roadways have been driven in a single 20-foot-wide pass, then incrementally widened to the required width during installation of the longwall shields. The first pass roof is supported with a generic roof support plan consisting of partially encapsulated roof bolts and point-anchored cables. This ground support plan was utilized regardless of the geotechnical conditions encountered in the roadways or consideration of the required stand-up time of the roadway before the longwall shields were installed. This "blanket" approach tends to result in over-conservative or inappropriate roof support designs, particularly in changing geotechnical environments. Guided by the desire to optimize the ground support plans and increase mining efficiency for future set-up rooms, the West Elk mine and Agapito Associates, Inc. have developed and implemented a strata management program. Strata management, as a formal and structured process, allows ground support and mining methods to be tailored to the anticipated and encountered geotechnical environment in a con- trolled manner (Thomas 2007). To arrive at adequate site-specific ground support plans for the set-up rooms at the mine, several struc- tured processes were utilized. Firstly, the geotechnical environment was characterized by examining the roof lithology and geomechanical properties from nearby rock core obtained from exploration boreholes. To increase both mining efficiency and continuity, and to achieve longer stand-up times before the longwall shields are installed, a multi-pass approach was implemented into the design. During mining, the geotechnical conditions of the roadway are mapped, and the roof is strategically surveyed with a borescope. This process was used to ensure that the encountered ground behavior was in alignment with the design standards used for the roof support design. To support this process with measured data, roof extensometers were strategically installed throughout the roadway. This data was used to monitor the magnitude of roof displacement at various horizons and record displacement rates up until the longwall shields were installed. Lastly, a Trigger Action Response Plan (TARP) was used during mining to cater for any unforeseen changes in ground conditions that would warrant additional con- trols such as increased monitoring or the installation of additional ground support. This paper presents two case histories at the mine where the above strata management approach was implemented to arrive at a site-specific ground support plan. The main changes to the mine's ground control plan included a multi-pass mining approach, the utilization of fully encapsulated roof bolts, and the transition to a stiffer roof support system. The geotechnical mapping, the roof borescope results, and the roof extensometer data will be presented to demonstrate the effectiveness of the ground support system up until the longwall shields were installed in both presented cases.

Jun 25, 2024

By MANZOOR ALI BROHI, IZHAR MITHAL JISKANI, Atta Ur Rehman, SHUAI HAN, MUHAMMAD TARIQ, NIAZ MUHAMMAD SHAHANI

A thorough improvement in mine safety is contingent on many factors that require scientific decision-making for selection and prioritizing of important factors for safety improvement. Their analysis using an established scientific method can improve mines’ safety conditions and assist the administration for informed decision-making. This research establishes a mine safety evaluation index and proposes an integrative model based on the entropy weight and grey clustering methods. In the evaluation index, 27 significant factors of safety are identified and categorized into 7 criteria. The proposed evaluation system analyzes all indicators according to Pakistan’s current mine safety situation and their significance for potential safety improvement in the future. Results reveal that current safety practices are outdated due to a lack of mechanization in the mining industry and minimal capability of the management to achieve the desired safety targets. Appropriate safety policies and safety education are missing in the daily working environment. The lack of overseeing the execution of safety operations and the lack of ambition and strong work ethic workers contribute to the paucity of mines’ safety conditions. The prevention and control systems to manage risks and hazard are not in place, and the working environment in mines remain difficult. Therefore, to have enhanced mine safety, important factors can be addressed in chronological order, as presented in this paper. The proposed methodological approach can be applied to other prioritization applications to analyze the indicators and determine the appropriate management strategies.

Jun 14, 2021

By V. T. McLemore

"Production of industrial minerals remains important to the rural economy of New Mexico. In 2014, some 240 mines were registered in New Mexico, including 25 industrial mineral operations and 189 aggregate operations. New Mexico leads domestic production of potash, perlite, zeolite, and travertine. Other production includes aggregate, humate, pumice, gypsum, salt, common and fire clay, scoria, limestone, fly ash, cement, magnetite, silica, and decorative stone. New Mexico has potential for additional production of industrial minerals. One company is exploring for garnet. Cretaceous black sandstones in the San Juan Basin have drawn interest for titanium, rare earth elements (REE), and zircon. Other REE deposits are being explored. REE-Th-U veins are found in the Gallinas, Capitan, and Cornudas Mountains and Laughlin Peak-Chico Hills. Recent exploration has occurred for beryllium in the San Mateo Mountains, Iron Mountain, and Victorio districts. Companies also are examining High-Ca limestone and High-Mg dolomite for potential development. Aggregate continues to be important in urban areas and along highways. INTRODUCTION Industrial minerals and rocks are literally the building blocks of our way of life and they are an exceptionally diverse and vital group of raw materials that underpin almost all aspects of human activity, infrastructure, and standard of living. Industrial minerals and rocks are used in the manufacture of many products, from ceramics to plastics and refractories to paper. Although industrial minerals permeate every aspect of daily life, their presence and their role are typically invisible. A widely used definition of industrial minerals and rocks is “any rock, mineral, or other naturally occurring substance of economic value, exclusive of metal ores, mineral fuels, and gemstones: one of the non-metallics” (Bates, 1975). This definition includes the important construction materials sector as well as specialized industrial minerals, but complex interactions between consumer industries produce a number of apparent anomalies to this definition. Some metals are included as industrial minerals because their use is industrial rather than as a metal. Sulfur is now predominantly extracted as a by-product of cleaning natural gas, one of the world's major energy fuels. Production of industrial minerals has been and remains important to the rural economy of New Mexico. Industrial minerals constitute nearly 40% of the more than $2.8 billion generated by mineral production in New Mexico in 2013 (Table 1, see APPENDIX). In 2015, some 240 mines were registered in New Mexico. This total includes 25 industrial mineral operations and 189 aggregate operations. New Mexico leads domestic production in potash, perlite, zeolite, and travertine. Other industrial minerals production from New Mexico includes aggregate, humate, pumice, gypsum, salt, common and fire clay, scoria, limestone, fly ash, cement, magnetite, silica, and decorative stone. Additional production statistics are in Harben et al. (2008). Major industrial mineral districts are shown in Figure 1."

Jan 1, 2016

By Shaoyang Yan, Xinming Chen, Huazhe Jiao, Huaibao Chu, Chang Wang

In terms of the technical problems of rib spalling in large mining height coal face, a long-distance advanced pre-grouting layer flexible reinforcement technology is proposed in this paper. Based on the mechanism and failure mode of rib spalling in the coal face, the mechanical properties of the aluminum plastic composite pipe were analyzed by using the tensile and compression experiment. The deformation and strength characteristics of “flexible pipe + grouting” specimens were studied by uniaxial compression test, splitting test, and shear test. The UDEC numerical simulation software was used to simulate the reinforcement effect of “flexible pipe + grouting” at different positions. Combined with the field application, the feasibility of long-distance advanced pre-grouting layer flexible reinforcement technology was verified. The test results show the following: The coal face has the characteristics of brittle and large deformation. The aluminum plastic composite pipe has the characteristics of good elongation and tensile strength, which can endure the large deformation of the coal face. The “flexible pipe + grouting” can improve the tensile and shear strength of coal. The UDEC numerical simulation analysis indicated that the grouting hole layout of “flexible pipe + grouting” has a significant difference in the reinforcement effect of the coal face. Compared with single row grouting reinforcement, the reinforcement effect of double row grouting holes 1.5 m and 3.0 m away from the roof is better. According to the field application, it is feasible to use aluminum plastic composite pipe as a flexible grouting pipe to reinforce coal seam with 80–100 m long-distance pre-grouting. Long-distance advanced pre-grouting layer flexible reinforcement technology can improve the daily production of coal and reduce the support cost of the coal face. As a new method of reinforcement, long-distance layered flexible reinforcement has a significant effect on the prevention and treatment of rib spalling in large mining height coal face.

Sep 27, 2022

By Ken Deter

I have some general comments on optimizing profitability based on working in heap leach operations in tropical environments. Many of my planned comments this morning have been stated earlier in the Conference. I get the opportunity to say only a few words, and follow up on some specific comments and concerns. In normal operations, stack the ore higher, where possible. The surface area of the stacked ore controls the total solution volume that can be sprayed on the pad at a specific time period. With higher lifts, solution will contact more ore particles as it percolate through the lift, and therefore the solution grade flowing through the base will be increased, whether it is freshly stacked or almost completely leached ore. This also allows more tonnage to be stacked per lift on the pad, decreasing conveyor movement and downtime. Increasing from 6 to 8 meter (20 to 26 feet) lifts have worked successfully, and some mines are using 10 meter (33 feet) lifts in 10,000-15,000 dmtpd plants. The same concept will work with smaller plants, but initial 6 meter lifts should be used until the start-up period has shown the leaching is working as planned. As the stacked ore lifts get higher, the solution flowing through the highest lift is diluted by solution retained in the lower ones. Eventually no real increase is noted from putting fresh ore in service, and gold production rate suffers. To address the dilution problem, an HDPE liner should be installed between each 2 to 4 lifts, depending on each site specific lift height, recovery, % slump in the lift, recovery rates, and grade treated, among others. The surface of the previous lift should be leveled and sloped to control the effluent draining from the planned lift, then the liner is placed, including berms and discharge pipes. The intermediate HDPE liner does not need to be completely sealed as would be the case with the base liner, and can accept some solution penetrating into the lower lifts. A one-mm (40-mil) thickness liner can be used. This intermediate liner allows the upper lift(s) higher-grade effluent to report to the pad discharge point. This will maintain higher gold solution grades going to the ponds. The slopes of the previous lifts should not be covered with HDPE in this concept, and precipitation falling on the lower lift slopes and benches can be directed to barren or surge ponds.

Jan 1, 1999

By Susana Bolhão Muiños, José Hipólito Monteiro, Martin Frank, James R. Hein, Henrique Garcia Pereira, Fátima Abrantes, Tracey Conrad, Luís Gaspar

In spite of all the work that has already been done on ferromanganese deposits, studies on the Atlantic Ocean occurrences are still in their infancy and there is a clear need for investigations concerning the origin, distribution, and resource potential assessment of these deposits. Nevertheless, studies already carried out on northeast Atlantic seamounts indicate the general presence of ferromanganese deposits of hydrogenetic origin, i.e. deposits formed by direct precipitation of colloidal, hydrated metal oxides that are scavenged from the water column on hard-rock substrates. The hydrogenetic precipitation promotes the enrichment of ferromanganese crusts in many trace metals, most of which are of economic interest, such as Co, Ni, Te, rare earth elements, and platinum-group elements and thus ferromanganese crusts are considered an important metal resource.

Sep 1, 2014

By S. R. Dismukes

Mining is likely to be targeted by The United States Environmental Protection Agency (“EPA”) as one of its key enforcement targets for fiscal year 2002-2003. Identifying the mining industry as an enforcement target, coupled with an increase in enforcement activity in recent years, places each mining operation at increased risk of receiving enforcement attention. A properly developed and implemented Environmental Management System (“EMS”) tailored for your operation is invaluable in reducing the risk of incurring liability for non-compliance. At the heart of an effective EMS is an audit program that checks the company’s compliance with environmental requirements. In addition, audit privilege (in select states), voluntary self-disclosure, and the attorney-client privilege serve as very effective tools for managing those liabilities that may arise during auditing a well-developed program. Of course, these latter tools are effective only if the auditing program is properly structured and properly managed. EPA and some states also provide varying degrees of immunity for environmental violations that are voluntarily disclosed in writing by the company. However, self-disclosure laws and policies typically prescribe stringent requirements for parties seeking to take advantage of them. For example: U.S. EPA has recently extended the time period in which to provide full written self-disclosure to 21 days. However, U.S. EPA’s revised Self-Disclosure guidance also addresses when a company obtains knowledge of a violation for purposes of triggering the 21-day clock and specifically extends the knowledge requirement to include the company’s agents and consultants. This expansion increases the difficulty companies may have in clearly defining and managing when they obtained knowledge. This difficulty increases the importance of managing factual development and the strategic use of other

Jan 1, 2001