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By E. V. Redin

"The Bakal (South Ural, Russia) deposit of iron ore bearing iron carbonate (siderite) with the capacity of more than 1 billion tones belongs to the MMK. This ore cannot be fully processed via blast furnace technology because of high content of MgO. According to the investigations carried out in the USA and Japan in 1999-2004 the ITmk3 (Ironmaking Technology mark three) RHF technology is a breakthrough in Ironmaking. Four iron ore types (hematite, magnetite, high and low Al2O3/SiO2) were tested. Reduction, melting and slag removal can be achieved in just 10 min. The main objective of the investigation is to establish optimum operation conditions for the production of iron nuggets from iron carbonate bearing ore via the ITmk3 by means of the lab scale testing. Green pellets were processed via a lab tube (chamber) furnace to simulate RHF conditions. This preliminary test work provides valuable information which may be used for large-scale testing in a commercially sized RHF.IntroductionThe ITmk3 process upon which this paper focuses was developed by Kobe Steel in its research facilities in 1996 [1]. After pilot testing at Kobe Steel’s Kakogava Works in 1999-2004 the pilot demonstration plant was built and operations were successfully carried out by Mesabi Nugget joint venture in 2002-2004. Steel Dynamics has committed to building the commercial plant at the Mesabi Nugget site in Hoyt Lakes (Minnesota). Only 4 iron ore types (hematite, magnetite, high Al2O3/SiO2 and low Al2O3/SiO2), as well as 4 coal types with range of volatility, ash and fixed carbon were tested. Results were consistent with nugget characteristics confirming ITmk3’s flexibility with respect to raw material inputs. At the same time, no research in the field of nugget from iron carbonate bearing ore with high content of MgO has been done. Such kind of iron ore is restricted for charging into the blast furnace due to contamination of MgO. The reason for restriction is the limitation of load of MgO in the blast furnace. If a lot of MgO enters the blast furnace, slag becomes viscous. The viscous slag is obstacle for stable operation of the blast furnace."

Jan 1, 2012

By J. K. Ross, K. O. Hoal, S. K. Appleby

Understanding ore variability is a key factor in the geometallurgical analysis of a deposit and is beneficial to process development and mine planning. Ore variability is a function of the mineralogy of a deposit, in terms of both ore and gangue minerals and their textural relationships. This study integrates optical microscopy and quantitative mineral analysis to characterize the mineralogy and texture from 13 samples from different lithologic units at the Bingham Canyon Mine. The analysis identified several parameters, such as modal mineralogy, alteration assemblages, distribution of mineral phases and alteration assemblages and microfracture and void space distribution. These parameters can have an impact on the materials’ behavior during processing. This study demonstrates that quantitative mineralogical analysis can provide detailed information for improved understanding of ore variability.

Jan 1, 2010

By Michael J. Mankosa

Carpco has recently evaluated the use of various mineral processing techniques for secondary materials recovery. These applications include recycled foundry sands, plastics and secondary metals. This paper describes different recycling applications and the associated separation solutions. Results from extensive laboratory-and pilot-scale test work in each area are discussed. Industrial installations resulting from this test work will be presented. A detailed description of an industrial installation patented by Carpco for the recovery of plastic and metallics from current waste by-products is presented.

Jan 1, 1997

By H. R. G. Steeghs

Recently developed organic binder systems have the advantage of eliminating bentonite contamination. This results in better chemically reactive taconite pellets. Both acid and fluxed pellets show increased R40 reducibilities, whereas mechanical and physical properties of the taconite pellets are not adversely affected. Blast furnace performance of these pellets is excellent, and substantial economic benefits are achieved.

Jan 1, 1989

By L. Adler

In spite of distractions from glam-our areas (ground control, computers, etc.), excavating and bulk handling in mining remains paramount but is now undergoing dramatic advances. The massive intervention of mining and civil engineers as "engineer-users" into the tight, exclusive, and specialized bond between the equipment operator ("operator-users") and the manufacturer (mechanical engineers "and sales "reps") has now occurred. Three developments have accelerated this: 1) larger, more costly, complex, specialized, and innovative equipment; 2) a more profound understanding of the equipment, operations, and working conditions (encumbered space); and 3) a concurrent thrust into "high-tech," (automatic and remote controls, sensors, automation, artificial intelligence, and even robotics) and human factors (workload intensity, work-station design). This has produced a well-defined professional discipline, including construction and even military engineering. The mine plant, and to a lesser extent, the mine face, is now being monitored. Equipment conferences, journals, and centers at universities and agencies have multi-plied. The discipline's impact on future mining now becomes more apparent.

Jan 1, 1988

By S. H. Lorain, Norman L. Wimmler, S. Ricker, P. E. Oscarson, H. G. Iverson

This paper has been prepared with the principal objective of recording the results of the Bureau of Mines exploration of five major clay deposits in the Western Region. It is based mainly on data contained in unpublished Bureau of Mines reports. Acknowledgment is made to the Federal Geological Survey for its cooperative work with the Bureau of Mines, to the various State geological and mining departments, and other State and local agencies. Clay Exploration by the Bureau of Mines Much has been written and published on clays and clay deposits relating to their refractory, ceramic, and other qualities but such literature is lacking in analyses of the available alumina content of the clays and provides little indication of their possibilities as a source of alumina. With this new objective in view, a great many of the known clay deposits were reexamined and new ones discovered. The Bureau of Mines made preliminary examination of numerous areas in the western United States. Five of those most favorably indicated were systematically drilled, and in each a large amount of high-alumina clay has been found. These five major projects are Molalla and Hobart Butte, in western Oregon; Cowlitz-Castle Rock, in southwestern Washington; Ione, in California; and the Olson-Troy area in Idaho (Fig. I). Preliminary scout drilling was done in the Stockton deposit at Coeur d'Alene, Idaho; the White ware deposit near Lewis-town, Mont.; and 13 areas in the Spokane or eastern Washington region, where the most favorably indicated area, known as the Excelsior, is now being drilled more systematically. Preliminary drilling was undertaken in numerous areas adjacent to the major deposits and others more remote. As a result, large additional clay possibilities were found. The Clay Deposits The clay deposits under consideration are of the sedimentary or transported types, parts of which have been altered further by the agencies of weathering, ground water, or hydrothermal action. There are extensive deposits of residual clays in northern Idaho and in eastern Washington, but they have been found to be low in the available alumina and to contain much free quartz, mica, and unaltered feldspar. To be of value, they must first be subjected to beneficiation to remove these gangue minerals. The sedimentary clays have been derived largely from the decomposition, erosion, and transportation of granites, gneisses, schists, and basalts. At Molalla, some

Jan 1, 1948

By Norman L. Wimmler, H. G. Iverson, S. Ricker, P. E. Oscarson, S. H. Lorain

This paper has been prepared with the principal objective of recording the results of the Bureau of Mines exploration of five major clay deposits in the Western Region. It is based mainly on data contained in unpublished Bureau of Mines reports. Acknowledgment is made to the Federal Geological Survey for its cooperative work with the Bureau of Mines, to the various State geological and mining departments, and other State and local agencies. Clay Exploration by the Bureau of Mines Much has been written and published on clays and clay deposits relating to their refractory, ceramic, and other qualities but such literature is lacking in analyses of the available alumina content of the clays and provides little indication of their possibilities as a source of alumina. With this new objective in view, a great many of the known clay deposits were reexamined and new ones discovered. The Bureau of Mines made preliminary examination of numerous areas in the western United States. Five of those most favorably indicated were systematically drilled, and in each a large amount of high-alumina clay has been found. These five major projects are Molalla and Hobart Butte, in western Oregon; Cowlitz-Castle Rock, in southwestern Washington; Ione, in California; and the Olson-Troy area in Idaho (Fig. I). Preliminary scout drilling was done in the Stockton deposit at Coeur d'Alene, Idaho; the White ware deposit near Lewis-town, Mont.; and 13 areas in the Spokane or eastern Washington region, where the most favorably indicated area, known as the Excelsior, is now being drilled more systematically. Preliminary drilling was undertaken in numerous areas adjacent to the major deposits and others more remote. As a result, large additional clay possibilities were found. The Clay Deposits The clay deposits under consideration are of the sedimentary or transported types, parts of which have been altered further by the agencies of weathering, ground water, or hydrothermal action. There are extensive deposits of residual clays in northern Idaho and in eastern Washington, but they have been found to be low in the available alumina and to contain much free quartz, mica, and unaltered feldspar. To be of value, they must first be subjected to beneficiation to remove these gangue minerals. The sedimentary clays have been derived largely from the decomposition, erosion, and transportation of granites, gneisses, schists, and basalts. At Molalla, some

Jan 1, 1948

By Steve Trussell, William H. Langer

"Arizona aggregate (sand, gravel and crushed stone) producers enjoyed more than a half a century of nearly constant growth in demand for aggregates. Approximately 80 percent of the aggregate produced in Arizona is sand and gravel, and 20 percent is crushed stone (U.S. Geological Survey, 2015). Figure 1 shows the generalized distribution of potential sources of sand and gravel (yellow) and potential sources of crushed stone (other colors described below). Black dots show locations of aggregate operations.Sand and gravel commonly is produced from modern river channels and terraces although some alluvial fans and high-level paleo-river terraces also serve as aggregate resources. The gravel clasts are a mix of rock types that reflect the types of rock in the source area of the rivers. Generally processed river gravels meet stringent specifications for highend uses.Crushed stone, which makes up about 20 percent of production, primarily comes from a variety of metamorphic rocks and light-colored intrusive igneous rocks such as granite (brown areas), dark colored extrusive igneous rocks such as basalt and scoria (rust colored areas), and carbonate rocks such as limestone or dolostone (green areas). Carbonate rocks are also used in the manufacture of cement and lime.Construction and aggregate production in ArizonaBecause aggregate producers have limited facilities for storing product, stockpile changes are insignificant compared to production. Therefore, demand or consumption of aggregate in Arizona is considered to be equal to production. Production figures used in this paper reflect shipments, sales or marketable production, including aggregate used by producers to make readymix concrete and asphalt. Production figures were reported by the U.S. Bureau of Mines from 1950 until 1995 and by the U.S. Geological Survey (USGS) since then. Production figures are reported voluntarily, and major operators are the primary source for these figures. Because many smaller operators do not report their production, the figures are conservative values that provide an approximation of aggregates production activity."

Jan 1, 2015

By D. W. Rierson

Svedala has a ported kiln process, designed specifically for the direct reduction of pelletized or natural lump iron ores. The process is called ACCAR. This ported kiln technology has been coupled with Svedala's GRATE-KILN System, for iron ore pelletizing, into the GRATE-CAR System for the reduction of fine grained ore concentrates through the steps of agglomeration, induration and reduction in a single production line. Additional applications of the GRATE-CAR System include: the recovery, agglomeration and reduction of steelmill waste oxide fines and the use of minus 6mm size natural lump ores to produce a highly metallized pellet agglomerate. Svedala conducts tests to confirm certain operating parameters through process simulations of the GRATE-CAR process. These tests are conducted at Svedala's Process Research and Test Center, Oak Creek, Wisconsin. Svedala also assesses issues of process variables, heat transfer, equipment sizing, retention time and endothermic demand associated with iron ore reduction using natural gas or coal as the reductant. The purpose of this paper is to present the GRATE-CAR processing concepts, the commercial production line and the testing procedures associated with investigating potential raw materials.

Jan 1, 1997

By J. E. Crawshaw

"The few previous observations of the effect of turbulence on limits of inflammability have been made on a small scale in turbulence produced either by a fan or by movement of the mixture.By a suitable amount of turbulence from a fan the lower limit of methane was 5 per cent as compared with 5 per cent observed for quiescent mixtures in the same vessel.3 With a streaming movement of the gas mixture within the range of speed from 35 to 65 centimeters per second (69 to 128 feet a minute) the lower limit was approximately 5 percent,4 For a quiescent mixture of ethane the lower limit was 3.10 per cent ethane, but with fan running at a moderate speed a 3 per cent mixture exploded.5The object of the tests herein reported was (1) to determine the lower limit of natural gas in a mixture of natural gas and air Which would be ignited and propagate violently when the turbulence was produced by explosives fired from a cannon into the mixture; (2) to observe the behavior when the mixture contained less than this low limit; and (3) to determine how turbulence produced by a fan affects thin limit.Four series of tests were run, three of which were to determine the effect of different sources of ignition: Tests with (1) an electric igniter; (2) 3F black blasting powder stemmed with 2 pounds of dry fire clay stemming used to ignite the mixture, and (3) 40 per cent straight nitroglycerin dynamite unstemmed. The fourth was made to study the effect of turbulence produced by a two-speed electric fan, using an electric igniter as the source of ignition.In both series of tests with explosives, charges of 50 and 200 were used to determine the effect of increased quantity of explosives on the lower limit of natural gas."

Jul 1, 1930

By S Hapugoda, M Peterson, A Haileslassie, A Poliakov, E Donskoi, L Lu

Most metallic iron in the world is produced in blast furnaces from different feed stocks – sinter, lump ore and pellets. Sinter is the main iron-containing feed to the blast furnace and can constitute up to 70–85 per cent of the total ferrous burden. As sinter quality is a key element for stable blast furnace operation, the textural, chemical and physical characteristics of the sinter are very important. Two major factors that affect sinter strength are mineralogy and porosity. This study utilised optical image analysis (OIA) to characterise sinter mineralogy, and the results were compared to those obtained by manual point counting under the optical microscope.Two major mineral characteristics of iron ore sinter are the presence of primary (unreacted) and secondary (derived from melt) hematite. Standard OIA, which is based on RGB thresholding, is not able to distinguish them as they have the same reflectivity; however, primary and secondary hematite in iron ore sinter have a different morphology. The CSIRO-developed OIA software Mineral4/Recognition4 has a unique feature to identify various textures/morphologies of the same mineral. Together with other capabilities of the Mineral4/Recognition4 software, this feature was used to identify different types of hematite and silico-ferrite of calcium and aluminium and other common sinter phases, such as magnetite, larnite, glass and remnant aluminosilicates.A visual comparison of the sinter mineralogy present in optical photomicrographs and that present in the mineral maps created automatically by the Mineral4 module of the CSIRO software confirmed the accuracy of the automated mineral identification.CITATION:Donskoi, E, Hapugoda, S, Lu, L, Poliakov, A, Peterson, M and Haileslassie, A, 2015. Advances in optical image analysis of iron ore sinter, in Proceedings Iron Ore 2015, pp 543–548 (The Australasian Institute of Mining and Metallurgy: Melbourne).

Jul 13, 2015

By Benjamin W. Haynes

The Federal government has a lengthy history in supporting and conducting research in the ocean mining and minerals field. The Federal effort has been and is currently focused primarily in four agencies: the National Oceanic and Atmospheric Administration (NOAA) within the Department of Commerce, and the Geological Survey (USGS), the Bureau of Mines (BuMines), and more recently the Minerals Management Service (MMS) within the Department of the Interior. While NOAA and the USGS have played dominant roles in mapping and geologic studies, and the MMS has recently provided funding for several task force studies within the Exclusive Economic Zone (EEZ) , the Bureau of Mines has conducted research in mining technology, minerals processing, resource definition, and economic evaluation of minerals from the seabed for over 20 years. These studies have yielded considerable minerals information regarding manganese nodules and crusts, placers, mineral sands, phosphorites, and sulfides. This paper reviews the past achievements in ocean mining and minerals programs starting in the late 1960's, describes current research and information efforts, and presents an outlook for Bureau of Mines research and information gathering efforts. Specific topics

Jan 1, 1989

By Arthur D. Silber

The economic success and growth of any metropolitan region depends on mobility. Today, mobility between New Jersey and New York is threatened by a transportation system that cannot meet 21st century travel demands. The transportation bottleneck created by the Hudson River threatens the viability of one of the world?s great centers of commerce and culture. Fortunately, there is a solution: The Access to the Region?s Core Mass Transit Tunnel. The US$8.7-billion Mass Tran-sit Tunnel?s (MTT) new two-track line will double commuter rail capacity under the Hudson and create a new, state-of-the-art cavern station in Midtown Manhattan, with wide platforms, high-speed escalators and other features to improve riders? travel experience. The capacity and other benefits of the MTT project will launch a new era of prosperity for the region, just as the Pennsylvania Railroad did almost 100 years ago when it built the existing two, single-track rail tunnels that now form the sole commuter rail link between New Jersey and New York. The existing tunnels run from North Bergen, NJ, under the Hudson River to Pennsylvania Station at 33rd Street in Manhattan. Construction on the MTT, the largest public works project in the United States, is scheduled to start this year and continue through 2017. The MTT is ready to go to construction thanks to a major commitment of financial, engineering, project management and other resources from NJ TRAN-SIT, New Jersey?s statewide mass transit agency, and the Port Authority of New York and New Jersey, a bistate agency that operates the Holland and Lincoln tunnels, the George Washington Bridge and other major transportation facilities in New York and New Jersey. The project is also strongly supported by the state governments of New York and New Jersey, as well as that of New York City. The MTT is New Jersey Governor Jon Corzine?s number one transportation priority.

Jan 1, 2009

By Norman L. Wimmler, H. G. Iverson, S. Ricker, P. E. Oscarson, S. H. Lorain

THIS paper has been prepared with the principal objective of recording the results of the Bureau of Mines exploration of five major clay deposits in the Western Region. It is based mainly on data contained in unpublished Bureau of Mines reports. Acknowledgment is made to the Federal Geological Survey for its cooperative work with the Bureau of Mines, to the various State geological and mining departments, and other State and local agencies. CLAY EXPLORATION BY THE BUREAU OF MINES Much has been written and published on clays and clay deposits relating to their refractory, ceramic, and other qualities but such literature is lacking in analyses of the available alumina content of the clays and provides little indication of their possibilities as a source of alumina. With this new objective in view, a great many of the known clay deposits were reexamined and new ones discovered. The Bureau of Mines made preliminary examination of numerous areas in the western United States. Five of those most favorably indicated were systematically drilled, and in each a large amount of high-alumina clay has been found. These five major projects are Molalla and Hobart Butte, in western Oregon; Cowlitz-Castle Rock, in southwestern Washington; Lone, in California; and the Olson-Troy area in Idaho (Fig. I). Preliminary scout drilling was done in the Stockton deposit at Coeur d'Alene, Idaho; the Whiteware deposit near Lewistown, Mont.; and 13 areas in the Spokane or eastern Washington region, where the most favorably indicated area, known as the Excelsior, is now being drilled more systematically. Preliminary drilling was undertaken in numerous areas adjacent to the major deposits and others more remote. As a result, large additional clay possibilities were found. THE CLAY DEPOSITS The clay deposits under consideration are of the sedimentary or transported types, parts of which have been altered further by the agencies of weathering, ground water, or hydrothermal action. There are extensive deposits of residual clays in northern Idaho and in eastern Washington, but they have been found to be low in the available alumina and to contain much free quartz, mica, and unaltered feldspar. To be of value, they must first be subjected to beneficiation to remove these gangue minerals. The sedimentary clays have been derived largely from the decomposition, erosion, and transportation of granites, gneisses, schists, and basalts. At Molalla, some

Jan 1, 1944

By John C. Robbins

A new technique for the determination of trace levels of uranium in solution has been developed. A compact laser emits short, but intense, ultraviolet pulses to excite the green fluorescence of a uranyl-complex formed by the addition of a proprietary reagent to the sample. Organic species present in most natural waters also fluoresce quite intensely, but their emission does not last appreciably longer than the excitation pulse, in contrast to the relatively long persistence of the uranyl fluorescence . Electronic 'gating' is employed to separate the long-lived contribution, rejecting substantially the organic emission. Results using the laser fluorescence method on many sets of natural waters of various origins have been compared against corresponding values generated by independent laboratories. Correlation has been generally good over a range from less than 0.1 to more than 100 ppb U. Solid samples have also been analyzed after extraction of the uranium into solution. Accuracies adequate for most exploration purposes have been achieved, but further work is required to determine effects of interferences in samples with complex matrices. The transport and deposition of uranium in natural waters is controlled by the organic and inorganic chemistry of the waters involved. It is suggested that interpretation of very low uranium levels will be aided by additional measurements of conductivity and organic content, with subsequent statistical treatment.

Jan 1, 1978

By Rick T. Richins

Despite what may be overwhelming evidence that natural degradation of cyanide and cyanide attenuation in hydrogeochemical processes are capable of reducing or eliminating potential water quality problems associated with heap leach facilities, the recent sharp increase in the price of gold and wide interest in the cyanidation process has focused all regulatory eyes on cyanide leaching. Regulations continue to increase, design criteria are more strict, and detoxification requirements approach or exceed the level of detectability. Current governmental regulation of mining and milling operations using cyanide varies considerably from state to state. The lack of regulatory consistency at this level is largely attributable to the current Bevill Amendment exclusion of mine wastes as potentially hazardous wastes, the undefined status of the Environmental Protection Agency's ongoing mine wast study effort, and the mining industry's reluctance to develop a consistent policy regarding state versus federal mine waste regulation.

Jan 1, 1998

By M. L. Requa

This paper is abstracted from the report of the Appraisement Committee of the Independent Oil Producers' Agency, of which the writer was Chairman. The other members of the committee were M. V. McQuigg and R. S. Haseltine. To Thomas Cox, engineer in charge of the investigation, and to his efficient staff of assistants, is due the credit for the detail work necessary in carrying out the plan of the Committee. It treats only of the valuation of the lands, wells, and piping, without going into details of equipment and other features. It was recognized, early in the operation, that the value of oil lands was the value of oil ,to be extracted and marketed, less the costs attendant thereon. Referring this back to the costs in cents per barrel, it became obvious that surface improvements, absolutely necessary in the production of oil, from wells then drilled, had no separate and independent value aside from the value of the land, but that any excess equipment, not necessary for the production of oil from present wells, such as drilling tools, well casing, etc., should be given a present condition value. In valuing the properties of the Independent Oil Producers' Agency, the Committee has considered the following facts: 1. That from each property there will ultimately be produced a certain total quantity of oil. 2. That in the production of that oil a certain total quantity of money will be expended. 3. That a certain total amount of money will be received from the oil. 4. That the total net receipts will be the total gross receipts less the cost of development and production. 5. That the present value of the net receipts must be such an amount that when invested by a purchaser it will be returned with 8 per cent, interest additional during the life of the property. The initial procedure consisted in making a general reconnaissance of the entire district in which the property was located and determining the lithological and structural conditions underlying the area. The data obtained from each individual tract comprised the logs of all the wells

Jan 1, 1918

By F. J. Tavera, J. A. Finch

A probe suitable for on-line measurements of gas hold-up in industrial flotation systems has been developed. It is based on an open cell for measurement of slurry-gas conductivity and a novel syphon cell for measurement of slurry-only conductivity. The desired behaviour of the two cells was demonstrated and estimates of gas hold-up were shown to be in good agreement with independent measurements. The gas hold-up probe was used as a diagnostic tool to assess the operation of flotation columns. Differences in gas hold-up between baffled sections in two industrial columns were detected

Jun 18, 1905

By J. Robert Moore

Introductory remarks will be made by the speaker, chiefly on recent and current developments in the industrial, agency and academic sectors that relate to the status of marine mining and mineral exploration programs and to recommendations for strengthening and continuing these programs. Subsequent to these brief comments, a selected panel with representation from industry, academe and government will address the following related topics: 1) development and objectives of new centers for marine mining technology, 2) cooperative R. and D. programs between academe and the user groups, 3) arrangements for specialized training and student instruction that will provide for educational components, and 4) funding and other support for implementing new centers and new programs. The panel discussion will be open to all UMI participants and whose contributions will be both solicited and encouraged.

Jan 1, 1986

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