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By Venugopal Bonani, Kumaran M., Thomas John

Liquid storage tanks are usually located in nearshore or coastal regions with soil profiles containing thick layers of compressible soils. These storage tanks are usually of large diameter up to 90m and carry high loads, and the tanks are supported by heavy deep foundations such as piles. These structures are subjected to huge lateral loads due to wind and earthquake, and any damage to storage tanks with highly inflammable liquids leads to disastrous condition. So, it is important that the top layer of soil (up to the fixity depth) should be strong enough to provide the required lateral load capacity to the pile. In a project for constructing LNG terminal in Odisha containing 2nos of 89m diameter LNG storage tanks supported with pile foundation located near to coastal region, for improving the lateral capacity of existing soil, the top 3m was replaced with compacted engineered fill (GSB). The site was a filled-up area with dredged soil from seabed, the top 5m-10m were soft to medium stiff clay with SPT N less than 10. The lateral design load on pile was 534kN under free head condition. Actual lateral capacity for the strata was around 200kN under free head condition which was less than required capacity as per structural requirements. Therefore, for improving the lateral capacity of pile the top 3m soil is replaced with well compacted engineered fill (GSB) in layers of 150mm and the capacity is proved by conducting initial and routine lateral load tests. This paper describes the properties of the engineered fill used and how the lateral load capacity of pile was improved to meet the design requirement.

Sep 1, 2022

By M. A. Bronston

A drill system configuration capable of working in the arctic offshore environment was developed to evaluate the placer gold resources contained in the glacio-fluvial sediments offshore Nome, Alaska. This system is capable of working on the shore fast ice during the winter months and is deployed on a drill ship during the summer. Transfer of the drill between its summer and winter configurations is accomplished with a minimum of modification to the design. The system is designed around the Becker drill. This percussive, reverse circulation drill is capable of penetrating the indurated glacial sediments present in the offshore Nome environment. This drill has operated effectively to depths in excess of 50 m (164 ft) below sea level. Since early 1987, in excess of 2000 holes have been drilled using the system. The drill system often operates in extreme weather conditions. It has averaged approximately 10 holes a day of drill production. The ore reserves defined during these drilling programs have resulted in the recovery of more than 70,000 oz (2.18 t) of gold to date, by the mining vessel Bima.

Jan 1, 1990

By John S. Berber

Bureau of Mines research on the production of phthalic anhydride by vapor phase oxidation of hydrocarbons began at Morgantown, W. Va., in October 1960. For these preliminary studies, a known solution containing naphthalene and 1-methylnaphthalene was used. In another series of tests, pure naphthalene was dissolved in different solvents. A series of investigations was conducted with the neutral oil fraction (210° to 270° C) of a low-temperature tar obtained from the Texas Power and Light Company's low-temperature carbonization unit. The neutral oil fraction was first dealkylated, and then the product was distilled into 210° to 250° C and 250° to 270° C fractions. These two fractions were then subjected to catalytic vapor phase oxidation. Although a number of catalysts was tested, most of the experiments were made using 9 percent vanadium pentoxide on inert alumina. The activity of this catalyst did not decrease after 162 hours at 1,030° F. Studies were conducted over a temperature range from 610° to 1,180° F. An operating temperature of 1,030° F yielded 47.50 percent of phthalic anhydride from a synthetic mixture of naphthalene and 1-methylnaphthalene. The highest yield (84.40 percent phthalic anhydride) was obtained with naphthalene dissolved in toluene and also with naphthalene dissolved in methyl ethyl ketone. With a 210° to 250° C fraction the highest yield of phthalic anhydride obtained was 12.32 percent at a temperature of 900° F, and, with a 250° to 270° C fraction, it was 15.80 percent at a temperature of 875° F.

Jan 1, 1963

By R. D. Miller

Application of shallow seismic reflection to problems associated with mineral exploration, mine planning, abandoned-mine detection, and environmental evaluation has been successful in a variety of geologic settings. Increased dynamic range of recording equipment and decreased cost of processing hardware and software have made shallow seismic reflection a cost-effective means of imaging geologic targets significant to mining operations. Seismic data possess sufficient resolution in many areas to detect faulting with displacement of less than 3 m in coal seams as thin as 2 m at depths of 200 m. Subsurface voids associated with abandoned mines at depths of less than 20 m can be detected and mapped. Seismic reflection has been successful mapping disturbed subsurface associated with dissolution mining of salt Complex geologic features associated with deposition of various hydrothermal minerals have been effectively mapped with high resolution seismic reflection at depths from 80 to over 300 m. Faults in sulfur-bearing cap rock over salt domes have been accurately located, allowing improved efficiency of the dissolution mining process. Shallow high-resolution seismic reflection has the potential to significantly enhance the economics and safety of mine operations.

Jan 1, 1993

By D. H. Lynch

Prompted by the need to conserve energy and reduce operating costs, Agrico Mining Company has made two significant improvements in the transportation of phosphate ore from the mine to the beneficiation plant. One improvement involves a change in a slurry pipeline system which substantially reduced pumping energy, and the other improvement is a major innovation for the phosphate mining industry which involves the transportation of the ore by railroad. This paper briefly describes these two projects.

Jan 1, 1981

By Wilbur I. Duvall

Nineteen quarry blasts were instrumented with particle-velocity gages mounted in a uniform soil overburden, back of one face in a quarry in Iowa. Three components of particle velocity, radial, vertical, and transverse, were recorded at each of eight stations back of each blast. Distances from blast area to gage stations ranged from 150 to 3,000 feet. Eleven of the quarry blasts employed millisecond delays, and eight were instantaneous blasts. Charge weight per hole was 200 pounds, and the charge weight per delay interval, including the instantaneous blasts, ranged from 100 to 3,000 pounds. Analysis of the data from these tests shows that the particle velocity, V, produced at distance, D, by a quarry blast of charge per delay interval, W, can be represented by an equation of the form, V=KWb D-n, where b and n are exponents, and K is the intercept constant which is a measure of the level of vibration. The value of K for a millisecond-delayed blast employing one hole per delay interval is about 42 percent larger than the value of K for a single-hole blast. The value of K for a multiple-hole milli-second-delayed blast is about the same as that for an instantaneous blast when the charge per delay for the millisecond blast is equal to the total charge for the instanteneous blast. The vibration level from millisecond-delayed blasts employing one hole per delay is shown to be independent of the length of the delay interval and the number of delay intervals over the range of the variables tested: 9, 17, and 34 milliseconds and 3, 7, and 15 delays per blast.

Jan 1, 1963

By Glenn Allen

SAN FRANCISCO Mines of Mexico, Ltd. owns and operates an extensive group of claims in the San Francisco del Oro-Santa Barbara district, about 15 miles southwest of Parral, Chihuahua. The property comprises the mines, aerial tramways, flotation mill, power plant, shops, offices, assay and testing laboratories, modern hospital, water and sanitary system, quarters for miners, mechanics and operators, a well housed colony for Mexican staff employees and residences for foreigners. Each colony has a club house and mess and tennis courts. The employees have constructed a nine-hole golf course. In other words, the property is self-contained and completely integrated for production of lead and zinc concentrates from complex sulfide ores.

Jan 1, 1930

The response was good-one of the best the SAIMM has had to its various questionnaires. 231 replies were received from 2768 members representing a response of 8,35%. For fellows and Members together, the response was 13,7%. The spread of responses based on respondents' work situation appeared to be well balanced with some bias from those in consulting organizations. Members' perceptions of their employers' positions withrespect to environmental management looked somewhat optimistic, but it is encouraging to note that they reported that more than half were developing environmental management systems. Training of varying degree was taking place at al levels in their organizations. Members saw their Institute as an important agent inlifting environmental awareness, literacy and responsibility not only through the journal and symposia, but also by liaison with government departments and educational institutions. Most respondents saw environmental legislation both from local and overseas sources as affecting their organizations, their products and services with the emphasis on corporate image, core business and sales.

Jan 1, 1995

By H. R. Pierce

Bureau of Mines engineers end others have endeavored to deter-nine a fundamental method for gauging the capacity of gas wells to deliver gas under different pressure conditions. Their studies show that for accurate gauging two factors must be determined: (1) The actual pressures at the face of the sand in the well (usually referred to as "at the sand"), acid (2) the relation between such pressures and the rates. of flow of c as through the sand. This paper, the first of a series, describes a method of attacking the problem of determining the actual pressures at the sand by means of observations of pressures and volumes at the well head.

Jan 1, 1929

By H. I-Lieh Huang, O. D. Sherby, J. E. Dorn

RECENT investigations1-4 have suggested that the total plastic strain, C, for high temperature creep under a given stress can be correlated by means of a temperature-compensated time, te- where t is the duration of test, e is the base of natural logarithms, aH is the activation energy for creep, R is the gas constant, and T is the absolute temperature. A typical set of data on which this deduction was based is given in Fig. la. Inasmuch as the e-in t curves for the various temperatures are identical except for their displacement along the In t axis where f and are appropriate functions. If the increase in creep rate with an increase in temperature is exclusively ascribable to a single process involv- ing thermal activation, (T) should equal RT and therefore it = constant [2] where ?= te Assuming the validity of this relationship, ? = ?2 at the same strain, or where the subscripts refer to two alternate test conditions.

Jan 1, 1957

A recent study estimates that a 10% improvement in the performance of wire rope used on draglines could save the US coal industry $2 million annually in rope costs. In addition, such an improvement could boost annual coal production by allowing the industry's draglines to remove an extra 1.5 million m3 (2 million cu yd) of solid overburden each year. These findings, although admittedly preliminary, suggest the magnitude of benefits that can be derived from a well-planned wire rope maintenance program.

Jan 3, 1978

By W. O. Vanderburg

This paper describing the methods of concentrating tungsten pros at the mills of the Atolia Mining Co. is one of a series of similar papers being prepared by the United States Bureau of Mines. The writer acknowledges the assistance and cooperation of A. V. Udell, president, Louis Warnken, bookkeeper, and C. K. Dennis, superintendent, of the Atolia Mining Co. in the preparation of this paper.

Jan 1, 1931

By R. W. Raymond

ALEXANDER BRINTON COXE was born in Philadelphia, Pa., Jan. 19, 1838, the second of five sons of lion. Charles Sidney Core and Ann Maria Brinton. A more extended history of his family and its important relations to the development of the United States will be found in my Biographical Notice of his younger brother, Eckley B. Coxe, published in 1895. It is therefore sufficient to say here that Dr. Daniel Coxe, a distinguished physician and surgeon of London, and a medical attendant of Charles II and Queen Anne, purchased, in 1684 and 1686, lands in East and West Jersey from grantees of the Duke of York, and became Governor of West Jersey, in which capacity he did much to develop the provincial fisheries, the manufacture of marine salt and pottery, the exportation of tim¬ber and the West India trade. In 1698, having acquired the royal patent of the Province of " Carolana," covering (with some reservations) the territory extending from the Atlantic to the Pacific, between the 31st and 36th parallels of N. latitude, Gov. Cole sent an expedition from Charleston, S. C., to the Mississippi. In 1769, seventy years later, his grandchildren surrendered to the Crown their title under this vast and vague patent, receiving in return a grant of 100,000 acres in the Colony of New York. The line of his descendants, so far as they concern this sketch, is as follows 1. Col. Daniel Core, his son, b. 1673, who came to New Jersey in 1700; resided there until his death (1730); held many high offices; and issued in London (1722) A Description of the Provinces of Carolana, containing probably the earliest published plan of political union for the British Colonies in North America.

Sep 1, 1906

By M. R. J. Wyllie, F. Morgan, P. F. Fulton

The importance of formation factor, F, not only in electric logging but as a fundamental rock parameter has recently been stressed.',: The desirability of investigating the range of variation of the resistivity index exponent, n, in the relationship I = S ;", where I is the resistivity index and Sw the water saturation as a fraction of the void volume of a porous medium, has also been urged.3 The magnitude and variation of n with saturation and rock texture is a subject not only of theoretical interest but also one of prime importance in the interpretation of electric logs. A simple technique has recently been developed which enables both F and u to he measured with high accuracy and which may also find acceptance as a convenient method for the determination of irreducible saturation attainment in the restored state method of core analysis. Experience has taught that reproducible measurements of F are possible only if the resistance measuring electrodes are so arranged with respect to a plane face on a porous medium that they are able to make electrical contact with substantially all entry pores in that plane. In practice this may be achieved by using a platinized-platinum gauze electrode backed by some absorbent material (such as felt) which has been saturated with a fluid identical with that used to saturate the porous medium. Applicatiorl of pressure to the electrode and absorbent material then forces the gauze against the plane face of the porous medium and simultaneously squeezes saline solution through the meshes of the gauze. By this means the electrode is in continuous aqueous contact with all pores and satisfactory and reproducible low resistance contact with the porous medium is achieved. Clearly this method, although satisfactory for measurements of F, cannot be applied to the making of continuous resistance measurements on a porous medium while capillary pressure desaturation is being carried out. However, accepting the principle that for satisfactory results electrical contact must be made between a measuring electrode and all pores adja- cent to that electrude, methods of bringing electrodes into intimate contact with the surfaces of porous media were investigated. Two methods were ultimately found to be satisfactory: in the one, the metal electrode is formed on the required portion of the porous medium by the use of a metal spray gun, while in the second the electrode is painted on with an ordinary camel's hair brush. The first method has the advantage of permitting the use of any metal which can be sprayed, but has the disadvantage of requiring rather elaborate and expensive equipment. The second method is presently limited to silver electrodes although in principle other metals, e.g. platinum or gold, could be used. Moreover, the method is so simple and cheap, and has been found to be so satisfactory that it will be described in some detail. The core being investigated is cut into a right circular cylinder and is extracted and dried in the usual manner. The ends are then lightly painted with silver conducting paint* of the type used in printed electrical circuits. The quantity of paint used is not critical but the recommended, minimum compatible with entirely coating the core ends is recommended, particularly on the end that contacts the barrier. The core is then dried at atmospheric temperature for one hour or for shorter periods at any suitable elevated temperature up to about 110°C. It will be found that silver coatings so prepared are not only strongly adherent but also permeable and the core may be the core may be desaturated by the ordinary capillary pressure technique through one of the coated faces. The same permeability is characteristic also of thin metal coatings formed using the spray-gun technique. An ordinary Lucite capillary pressure desaturation cell has been adapted to a form suitable for measuring the resistivity of the saturated silver faced cores both at 100 per cent saturation (i.e., F) and at intermediate saturations down to the irreducible minimum. This has been achieved as follows: A Coors porcelain barrier, having a displacement pressure of c 30 psi was grooved across a diameter. Dimensions of this groove were c 1 mm deep and 1 mm wide at the top. The groove was then painted thickly with silver conducting paint, the paint in the groove being extended lightly over the edges of the groove for a distance of c 1 mm on each side. A 30 gauge silver wire was then arranged in the groove in a form of a spring bow, each end of the silver being held at diamet~ically opposite ends of the groove by means of plastic cement. The arc of the bow at its highest point was arranged to be a millimeter or so above the face of the barrier, while one end of the bow wire was led by means of a pressure-tight connection through the wall of the capillary pressure cell. The groove in the barrier was then Surrounded by suitably cut portions of Kleenex in the conventional manner so as to ensure capillary continuity from core to barrier, and the core placed on the barrier. The weight of the core distorted the silver spring bow and good electrical contact was thereby made between the outside of the cell and the lower painted silver electrode. Electrical connection to tile top painted silver

Jan 1, 1951

By M. R. J. Wyllie, F. Morgan, P. F. Fulton

The importance of formation factor, F, not only in electric logging but as a fundamental rock parameter has recently been stressed.',: The desirability of investigating the range of variation of the resistivity index exponent, n, in the relationship I = S ;", where I is the resistivity index and Sw the water saturation as a fraction of the void volume of a porous medium, has also been urged.3 The magnitude and variation of n with saturation and rock texture is a subject not only of theoretical interest but also one of prime importance in the interpretation of electric logs. A simple technique has recently been developed which enables both F and u to he measured with high accuracy and which may also find acceptance as a convenient method for the determination of irreducible saturation attainment in the restored state method of core analysis. Experience has taught that reproducible measurements of F are possible only if the resistance measuring electrodes are so arranged with respect to a plane face on a porous medium that they are able to make electrical contact with substantially all entry pores in that plane. In practice this may be achieved by using a platinized-platinum gauze electrode backed by some absorbent material (such as felt) which has been saturated with a fluid identical with that used to saturate the porous medium. Applicatiorl of pressure to the electrode and absorbent material then forces the gauze against the plane face of the porous medium and simultaneously squeezes saline solution through the meshes of the gauze. By this means the electrode is in continuous aqueous contact with all pores and satisfactory and reproducible low resistance contact with the porous medium is achieved. Clearly this method, although satisfactory for measurements of F, cannot be applied to the making of continuous resistance measurements on a porous medium while capillary pressure desaturation is being carried out. However, accepting the principle that for satisfactory results electrical contact must be made between a measuring electrode and all pores adja- cent to that electrude, methods of bringing electrodes into intimate contact with the surfaces of porous media were investigated. Two methods were ultimately found to be satisfactory: in the one, the metal electrode is formed on the required portion of the porous medium by the use of a metal spray gun, while in the second the electrode is painted on with an ordinary camel's hair brush. The first method has the advantage of permitting the use of any metal which can be sprayed, but has the disadvantage of requiring rather elaborate and expensive equipment. The second method is presently limited to silver electrodes although in principle other metals, e.g. platinum or gold, could be used. Moreover, the method is so simple and cheap, and has been found to be so satisfactory that it will be described in some detail. The core being investigated is cut into a right circular cylinder and is extracted and dried in the usual manner. The ends are then lightly painted with silver conducting paint* of the type used in printed electrical circuits. The quantity of paint used is not critical but the recommended, minimum compatible with entirely coating the core ends is recommended, particularly on the end that contacts the barrier. The core is then dried at atmospheric temperature for one hour or for shorter periods at any suitable elevated temperature up to about 110°C. It will be found that silver coatings so prepared are not only strongly adherent but also permeable and the core may be the core may be desaturated by the ordinary capillary pressure technique through one of the coated faces. The same permeability is characteristic also of thin metal coatings formed using the spray-gun technique. An ordinary Lucite capillary pressure desaturation cell has been adapted to a form suitable for measuring the resistivity of the saturated silver faced cores both at 100 per cent saturation (i.e., F) and at intermediate saturations down to the irreducible minimum. This has been achieved as follows: A Coors porcelain barrier, having a displacement pressure of c 30 psi was grooved across a diameter. Dimensions of this groove were c 1 mm deep and 1 mm wide at the top. The groove was then painted thickly with silver conducting paint, the paint in the groove being extended lightly over the edges of the groove for a distance of c 1 mm on each side. A 30 gauge silver wire was then arranged in the groove in a form of a spring bow, each end of the silver being held at diamet~ically opposite ends of the groove by means of plastic cement. The arc of the bow at its highest point was arranged to be a millimeter or so above the face of the barrier, while one end of the bow wire was led by means of a pressure-tight connection through the wall of the capillary pressure cell. The groove in the barrier was then Surrounded by suitably cut portions of Kleenex in the conventional manner so as to ensure capillary continuity from core to barrier, and the core placed on the barrier. The weight of the core distorted the silver spring bow and good electrical contact was thereby made between the outside of the cell and the lower painted silver electrode. Electrical connection to tile top painted silver

Jan 1, 1951

By F. Chavan

1. Introduction The new Cleuson-Dixence development project in the Valais region of the Swiss Alps, involves the construction of a new link between the Grande-Dixence dam (still world recordholder with a height of 300 m) and a power house on the banks of the Rhone consisting of approximately 20 km tunnels and shafts, and involving a fall of about 1900 m. This 1200 MW project will replace an existing 900 MW structure built in the 1960s, no longer considered efficient. The new project comprises a head race drift about 15.8 km long, a surge tank, an inclined cascade shaft 4,2 km long, and an underground power station. The work for lots C and D (head race drift from Tortin to Tracouet, surge tank, six adits ans the complete inclined shaft) was awarded to our group (Prader, Locher, SELL, Losinger, Evéquoz, Dénériaz, Imboden and Bouygues). The geological conditions are: Lower part of the shaft (300 m) : sedimentary - sandstone and soft tertiary sandstone. Middle and upper part (2600 m) : metamorphic - upper and lower carboniferous, interrupted by triasic chipping. The horizontal section (7 km) consists of mica

Jan 1, 1995

By Shuchen Sun, Ganfeng Tu, Chuan Liu, Xiaoping Zhu

The hydrometallurgical residue generated during the hydrometallurgical processing of waste automotive catalysts is valuable as a secondary resource. In this study, a process of platinum recovery from the hydrometallurgical residue by high-temperature smelting process was proposed. Results of lab- and pilot-scale experiments show a high recovery of more than 98% of platinum and glass slag was successfully obtained by controlling the Fe3O4 addition, C/Fe3O4 mass ratio, CaO/SiO2 mass ratio, smelting temperature, and holding time at 15 wt%, 0.4, 0.6, 1500 °C, and 120 or 60 min, respectively. Results from the pilot-scale show that the platinum contents in the glass slag and alloys were less than 4 g/t and more than 0.6 wt%, respectively. Therefore, the process proposed in this study is a prospective and effective approach for reutilization of hydrometallurgical residue containing platinum.

Oct 12, 2020

By C. F. Cockrell, K. K. Humphreys, H. E. Shajer

It is quite conceivable that the question of using coal or an alternate fuel in the future by large industrial consumers may be decided on the basis of possible profitable utilization of flyash. Accordingly, the Coal Research Bureau at West Virginia University has been attempting to develop new uses for this waste material. This effort has resulted in the development of a process for producing flyash-based face brick and other structural materials which generally exceed published specifications for competitive clay-based materials. These structural materials, containing up to 97% waste coal ash, can be produced from flyash derived from most coals without regard to the physical or chemical properties of the coal ash. Preliminary production cost estimates indicate that face brick can be manufactured at a rate of 9000 brick per hr or more with a resultant gross profit of over $24.00 per thousand brick. Plant payout time for a plant of this size would be only about 1.2 years assuming a market price of approximately $55.00 per thousand, a well established figure for comparable clay brick. With flyash production expected to more than double in the next 15 years, there is an increasing need for a practical and Profitable method for the utilization of large tonnages of this material (see Table I listing total flyash production of utilities in each state of the U.S.). Present industrial and governmental physical and chemical restrictions, particularly for use as a lightweight filler or pozzolanic material, have limited the use of flyash considerably. For those ashes which have met the required standards, utilization is not always assured because of lack of promotion and poor public acceptance. Less than 6% of the total flyash production in the U.S. was sold in 1962. The remainder was dumped in disposal areas at costs as high as $2.42 per ton.' It is quite conceivable that in the near future the question of using coal or an alternate fuel by large industrial consumers may be decided on the basis of the possible utilization of flyash. To help insure future coal demands, the Coal Research Bureau at

Jan 1, 1968

By Ray Jambakhsh, Gabrielle Bourget

In the summer of 1998, Ontario Hydro awarded a contract to demolish an obsolete and inefficient chimney by blasting. The Ontario Hydro Thunder Bay Thermal Generating Station (T.G.S.), is a fully operational hydro thermal generating station located in Thunder Bay, Ontario, Canada. The Chimney was a 356 ft (108 m) high freestanding structure constructed of reinforced concrete with a brick liner. Falling the chimney required careful planning due to the highly sensitive structures and equipment which surrounded it. Damage either sustained to the existing systems through ground vibrations or direct contact would have resulted in expensive power outage and/or lost production. The role of Explotech Engineering Ltd. on this project was to provide and evaluation of the proposed demolition procedure, defme the predicted and maximum seismic vibrations at sensitive structures including underground services, conduct pre-blast / post-blast inspections and recommend various safety precautions. The general contractor for the project, LeBrun Northern Contracting Ltd., of Thunder Bay, Ontario was responsible for all site preparations and post-blast clean up. All demolition blasting calculations and operations were conducted by Dykon demolition experts from Tulsa, Oklahoma. On September 13, 1999, the chimney was successfully demolished. Extensive analysis of the vibration records and visual post-blast inspections of the surrounding structures concluded that the demolition event induced no damage to any of the Ontario Hydro facilities.

Jan 1, 2000

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