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By R Tooher, S J. Oliver

The operation of copper flotation circuit is a challenging task for the site metallurgists and plant operators. To optimise the performance requires meeting both grade and recovery objectives. These plants have numerous pieces of equipment that are monitored by hundreds of sensors. The challenge is to review these sensors and adjust the numerous control inputs to maintain peak operational efficiency for extended periods. There is also a need to respond to equipment failure. These challenges lead to in operational inefficiencies and can result in a reduction in revenue.This paper details an overview of an operational assistance tool implemented at Newcrest's Telfer plant’s copper flotation circuit. This tool is based on a digital twin of the plant. A digital twin is a model of the plant that is simulated in parallel to the normal plant operation. It is fed with the plant data in real time to provide a prediction of plant operation. The model outputs directly generate the metrics that are used to assess the plant performance, and these are compared with the metrics calculated from the actual plant’s operation. Deviations between the model estimate and the plant’s actual performance are used to gather insight into plant health and alert the operator to poor performance. The operators gather more information regarding the root cause by reviewing the model’s inputs that have deviated outside their normal operating range. An evaluation of the plant performance, following the commissioning of the digital twin, showed an overall reduction of acid soluble copper in the tails.This paper discusses the implementation of a digital twin of the plant to monitor plant performance during live operation. It will include details on data collection and cleansing, data reduction techniques, model development, and real-time implementation. The results of the case study of an implementation of a digital twin at Newcrest's Telfer copper flotation plant will be used throughout the paper.CITATION:Oliver, S J and Tooher, R, 2018. Optimising flotation plant operation by using a digital twin in the control room, in Proceedings 14th AusIMM Mill Operators' Conference 2018, pp 93–100 (The Australasian Institute of Mining and Metallurgy: Melbourne).

Aug 29, 2018

By R A. Pakhomov, L V. Krupnov, P V. Malakhov, I M. Dymov

The article presents results of thermodynamic calculations and laboratory studies, focusing on the cobalt behaviour during oxidative smelting of copper-nickel mattes. The compositions of the studied solutions are related to the products formed during the second stage of the converting process of copper-nickel matte at the Nadezhdinsky Metallurgical Plant (NMP) of MMC Norilsk Nickel company. These sulfide products typically contain from 1.5 to 12 wt per cent of iron. The obtained experimental results and thermodynamic calculations indicate that adjusting the CaO ratio to increase the proportion of CaO or complete replacement of SiO2 with fluxes containing CaO leads to a significant increase in cobalt recovery rates in the matte phase (with an iron concentration of 2.5 wt per cent) raising them from 30 per cent to 45 per cent. Meanwhile, the recovery rates of copper and nickel remain constant.

Aug 21, 2024

By S N. Donaldson, B L. Hollis, K Wynn, L Potts, M Evans

A real-time load-haul-dump (LHD) dispatch optimisation tool has been deployed at Panel Cave 1 and Panel Cave 2 at Newcrest’s Cadia Valley Operations. The tool, known as ORB, is the first known successful implementation of an optimisation-based, autonomous, real-time dispatch tool, custombuilt for underground mining operations. ORB can co-ordinate the optimal dispatch of LHD’s in a block cave to achieve a range of objectives while adhering to draw compliance and geotechnical constraints. It is an example of highly automated short-term interval control. This paper starts by outlining the pre-existing business planning process, detailing the simple logic that produced the daily draw order. Next, the motivations for a real-time dispatch tool are presented, drawing comparison to the limitations in existing planning processes and how these can be overcome through an optimisation-based, autonomous, real-time dispatch tool. Subsequently, the paper details the Ratio Bogging Draw Strategy, through which tonnes targets are expressed continuously on draw bells or draw points as a ratio of total cumulative cave draw. This signifies artificial planning boundaries are removed and that draw targets are linked within a cave; such that tonnes are unlocked by bogging other parts of the cave, instead of as a function of time. This creates incentive within the target mechanism for fixing and bogging struggling draw areas whilst allowing uncapped progress if all draw targets are progressing within compliance. Furthermore, the optimisation tool developed is outlined, including the data it uses and the objectives it optimises. Finally, detail on the improvements to operations the implementation of this tool has brought, and the business process change it has facilitated are presented using Newcrest’s Cadia Valley Operations as a case study.

Mar 15, 2021

By R van Wyk

In today’s mining environment the use of heavy mechanical devices and other high-tech electronic devices like two-way radios, cellular phones and even automated mining systems, form a vital part of the daily operations of a mining site. These human-made devices and some of the naturally occurring events, like lightning and gamma radiation, can have negative effects on electronic detonators and the associated control equipment.On larger mining operations the necessity to move the point of safety for blasting further away from the blast area, introduced remote firing via radio frequencies for electronic detonator systems. Other influences on electronic detonators can be abuse or ignorance. To ensure the safety of the end-user, an electronic detonator must be resistant to some common mistakes that users can make. One of main concerns here is resistance to static discharge or incorrect wiring. Despite the daily use of electronic detonator solutions, scepticism and concern still exists amongst those who believe the system raises the risk of a premature initiation of the blast through some form of interference trigger.This paper will help users understand how electronic detonators and the associated control equipment protects itself from external influences. Focus will be on protection schemes to counter static and over-voltage discharge and methods to ensure protection of secure wireless radio links and detonator communications. With well engineered communication systems and solid static and over-voltage protection, an electronic detonator system can be more reliable and safer than other detonator systems. The following main points will be discussed:what makes a detonator an electronic detonator,static electricity and over-voltage protection,the general influence of electromagnetic energy on the detonator,the influence of lightning on detonators,the protection of radio communication’s links as used by remote firing equipment, andthe safety protection features built into remote firing equipment.

Nov 8, 2011

By J Johansson, J Lööw

Attractive mining workplaces are good, safe and healthy environments. They are also workplaces that the workforce of the future wants to work in. As skilled miners and engineers are already scarce, this is important both for today and for the future. However, the future of mining will also be subject to increased international competition. In attempting to become more competitive, many mining companies turn to rationalisation, looking to both rationalise their production and organisation as well as optimise their processes. Work organisation is important in both rationalisation and providing attractive mining work. As a result, this paper investigates a ‘lean production’ (LP) philosophy for the organisation of future mines. The aim of the paper is to investigate to what extent LP can be used to organise for attractive mining. It first defines what attractive mining work is and to what degree it can be influenced by work organisation. A short insight into the LP concept will be given as well as a review of how it is discussed and utilised in mining today. In conclusion, a summary of LP’s potential to realise future attractive mining is given.CITATION:Lööw, J and Johansson, J, 2015. Work organisation for attractive mining – lean mining and the working environment, in Proceedings Third International Future Mining Conference, pp 197–204 (The Australasian Institute of Mining and Metallurgy: Melbourne).

Nov 4, 2015

By Grossi M, Baiden G

This paper describes a new mine backfill method based on a newly invented binder with several years of test results from laboratory and on- site applications. The new binder has several advantages over traditional Portland and slag cement binders. One tonne of the new binder can replace two to three tonne of Portland cement when used to consolidate backfill and can result in the same compressive strength within seven days. When comparing backfill slurries of the same pulp density, the new binder attains more volume of in-place backfill mass than Portland cement because of the high crystallisation of water, resulting in tightly filled stopes. The crystallisation of the water provides for less or no de- watering in the backfill stope and easier transportation of the backfill slurry. Pastefill performance can be achieved by using pulp densities typical of a hydraulic backfill and the new binder, all the while transporting with the same ease of hydraulic fill.

Jan 1, 1998

By W Potma, C Brauhart, S Halley, S Urbisinov, A Scogings

Truly integrated, quantitative, 3D GEOmetallurgical (or mineral system) characterisation, classification and 3D modelling should provide a cradle to grave unifying link across the exploration and mining value chain. All too often, spatially representative (quantitative) characterisation and modelling of a mineral system is delayed until feasibility stage, incurring a significant opportunity cost. The application of robust GEOmet characterisation methods early in the project lifecycle (at exploration stage) improves ground selection, exploration, and Mineral Resource estimation outcomes, long before there is a need for metallurgical test work. The value of this early provision of quantitative 3D mineralogy models is compounded at project feasibility stage, and continues to accrue over the entire project lifecycle, delivering cost savings, improved decision making and early warning of issues and opportunities.CITATION: Potma, W, Halley, S, Scogings, A, Urbisinov, S and Brauhart, C, 2018. Putting the ‘GEO’ back in front of GEOmetallurgy: importance of early implementation of quantitative mineral system characterisation, classification and modelling, in Proceedings Complex Orebodies Conference 2018, pp 55–57 (The Australasian Institute of Mining and Metallurgy: Melbourne).

Nov 21, 2018

I've talked a number of times in the past year or so to audiences like today's about culture -about thinking of it, understanding it, respecting it. So, rather than talk just yet about your laws for mining on Aboriginal land and the successes some of us and some of you have been able to achieve, I'd like to first of all talk about cul- ture as I understand it. Anyone who proposes any kind of development on Aborigi- nal land needs to have some basic understanding of what we, the traditional owners of that land, are about. Without that under- standing, you will find difficulty in coming to terms with us. Many people have experienced this difficulty and, unless we can do something about it together, many more will continue to find it.

Jan 1, 1988

By C Ausa, Nyunt Htay, A, L Deiparine

The main tectonic elements in Myanmar are a late Mesozoic and Cenozoic magmatic arc system in the west, repeated in northern Myanmar by more than 300 km of dextral movement on the Sagaing Fault, and the back-arc continental region affected by early and late Mesozoic orogenies, in the east. Historically most lode gold production has been from latest Cretaceous high-grade mesothermal veins and derived placers in the Wuntho and Tagaung-Myitkyina segments of the magmatic arc. Placer deposits in the Ayerwaddy River north of Myitkyina are currently worked by more than 100-bucket dredges. South of Wuntho, the magmatic arc and Pegu Yoma fold belt host epithermal gold with associated As, Sb and Zn in mid-Tertiary marine sediments. MyanmarÆs most productive lode gold deposit, the Kyaukpahto mine, lies within a north-trending district east of the magmatic arc and north of Mandalay. Here mineralisation and associated jasperoidal silica occur in Eocene sandstones and Permian and Triassic carbonates. Possibly this district continues southeastwards, across the Sagaing Fault, as sediment-hosted Sb Au and locally skarn Au mineralisation within a 1100 km long fold-thrust belt. Also present in the back-arc region are sandstone-hosted Au Cu in a Palaeozoic slate belt, and gold and stratabound gold-base metal mineralisation in the medial metamorphic belt. While untested targets remain in the magmatic arc, particularly for high sulphidation Au, the best potential is clearly within the back-arc slate and fold-thrust belts in the western part of the Shan Plateau and in northeastern-most Myanmar.

Jan 1, 1999

By J Gotte, C Morley, J Froud

Newcrest Mining LimitedÆs Telfer Mine is a world-class gold and copper producer, situated in the Great Sandy Desert, in the north west of Western Australia. The mine has a number of distinctive characteristics such as being one of AustraliaÆs most remote mine sites, being within 270 km of the hottest town in the southern hemisphere (Marble Bar) and having been shut down and reopened after a two-year feasibility study. The construction of a new plant and reopening of the mine gave Newcrest the opportunity to review their mining practices and systems including the opportunity to incorporate reconciliation as a core process. Telfer is now well on the way to being one of the largest gold and copper concentrate producers in Australia. When the mine reopened in June 2003, Telfer implemented SnowdenÆs Reconcilor software system to facilitate reconciliation of geological models, production data and plant measurements. The system was implemented on site in June 2004, as a web-based information management system, integrating other existing mining and plant software packages. It continues to provide an auditable process and consistency of data, providing ease of analysis with standard and customised reporting. This paper provides a case study of the reconciliation system implementation at Telfer. It outlines the consolidation of a number of management systems into one centralised system that can be used to compare and reconcile the tonnes and grades from the mine through to the mill. The authors outline the key estimates and measures that are used for reconciliation at Telfer, detailing the characteristics of the system used to capture the information and the benefits that have been gained through the use of a rigorous reconciliation process on a complex orebody.

Jan 1, 2007

By B Broad

"Establishing ventilation in the early stages of a new mine is an essential step to achieve scheduled outcomes that ultimately drive the financial success of an operation. If the primary ventilation is not in place in time to support a contractorÆs work output, then the ore delivery is likely to be severely impacted. Options to increase ventilation in order to address shortfalls are limited. This in turn can lead to reduced revenue generation at a time when a mine is at its highest capital outlay. This can have implications for any company, but even more for an explorer moving to producer. The ventilation put in place to cover the start-up period is also unlikely to cover any extended or increased load required to meet schedule delays.The following paper examines two issues in relation to ventilation with a focus on small to medium projects where the company is establishing a mine using a mining contractor. The issues being: potential impacts on the contract and tender process when using a mining contractor key mine design considerations, such as æcrunch timeÆ, as they interact with ventilation achieving a successful ramp up.A recommendation is made for higher levels of detail around secondary ventilation leading up to the primary fan installation. The information should be included as part of the tendering process and preliminary project execution planning. Understanding the æcrunch timeÆ concept can lead to strategies, as well as back up plans, to minimise any negative impact.By understanding key risks around primary ventilation establishment for a new mine, detailed design work can be completed where it is needed most. Value is added by reducing uncertainty and a payback with better contract terms and a more robust ramp up plan. This will improve the economic return for the company and reduce the risk.CITATION:Broad, B, 2013. Contract considerations and other critical ventilation aspects in achieving a new mine ramp up, in Proceedings The Australian Mine Ventilation Conference, pp 207-214 (The Australasian Institute of Mining and Metallurgy: Melbourne)."

Jul 1, 2013

By P Willems, J B. Crow, R Dale

Open pit mining commenced at Lihir Island in 1997 and is undertaken using a conventional drill, blast, load, haul methodology. Unique challenges at the operation include an active geothermal system, a well-developed advanced argillic blanket in the upper portions of the orebody and high rainfall. Grade control is effective utilising routine blast cone sampling. While this provides ‘just in time’ grade information for mill blending, there are opportunities to improve scheduling of mill feed, based on material classification of clay types and sulfur grades. The nature of the clay can impact on the handling properties while the sulfur grade is an important guide for autoclave blending, required for refractory gold. Drilling below the pit floor introduces hazards from the identified geothermal field. A trial Reverse Circulation (RC) program was implemented with the aim of defining four benches below the active mining bench. A comprehensive risk analysis, including the geothermal environment, was undertaken to design a drill collaring procedure with pressure diversion equipment. Operator exposure was minimised through ‘nil on foot’ principles with the driller located in an onboard cab, utilising remote rod handling. Sampling personnel operate in an elevated platform with access to protective covering. Samples from blastholes and the RC holes are processed at two site laboratories. One provides conventional Au fire assays with additional Infrared Combustion (Leco style) S analysis. The second laboratory collects material classification details from portable XRF (pXRF), near infra-red spectrometry (ASD) and Hardness Indicator Testing (HIT). An existing workflow was updated by the site to deal with the additional samples and ensure production ‘turn around times’ were retained for short-term planning. This required some changes to drying temperatures, compositing and screen sizing for the material classification. All results from the two laboratories are loaded into a centralised acQuire database for estimation into a single block model that informs the 13 week medium term planning (MTP) schedule. This paper describes some of the logistical issues faced when drilling in a geothermal area. It also discusses the selection and commissioning Quality Assurance of the sampling equipment and drill rig. Integration of the resulting assay data with existing resource models is also explained.

Mar 22, 2022

By E M. Gama, L Resende

The tailings are waste from mineral processing operations. The type of tailings of iron ore processing are classified into sandy tailings and mud. Already the overburden are showing significant levels of useful mineral. Both iron ore`s waste have in your composition phyllosilicates/clay that indicates the potential for use in niche markets as paving and cement. According to several studies, there are various technologies in bench and pilot levels that could be used on a large scale but there is not an economic environment, tax, regulatory and tax set. Many of these technologies are associated with the reuse of tailings and overburden in construction. All these factors influence for that so many initiatives remain in search formats and cannot advance to the new business format. There is no way to set goals of reuse of this waste, as already occurs in China, if there is not a fiscal, tax and economic structure to support such measures. The way to foster and ensure that reuse of tailings and overburden is an incentive for promoting a culture of circular economy that would allow the emergence of an ecosystem between the private, public and Government sectors with the objective of accelerating and subsidize the entire network of reuse of this waste. The closure of the mine could be the tool used to ensure and boost this ecosystem of reutilization to align it with the vocation of the area of the mining law. Following this model, the end of the mining activity could provide a financial return to the local population, a more effective environmental compensation and a reduction in costs related to the closure of the mine. In this study are shown how the Vale is working in the reuse of tailings and overburden.CITATION:Resende, L and Gama, E M, 2018. The challenges of the reuse of tailings and overburden, in Proceedings Mine Waste and Tailings Stewardship Conference 2018, pp 117–125 (The Australasian Institute of Mining and Metallurgy: Melbourne).

Jul 23, 2018

By Robins R. G

The dissolution of metallic copper powder in aqueous solutions of cupric sulphate under the influence of ethylene gas was investigated. The dissolution reaction stoichiometry obtained was: Cue+(aq) + Cu(s) + 2C2H4(g) = 2(CuC2H4)+(aq) The rate of formation of the copper (I)-ethylene complex in the above reaction was studied in a laboratory autoclave and the effect pH, temperature, ethylene partial pressure and initial concentration on the dissolution rate was measured experimentally and expressed theoretically in terms of several simple conceptual kinetic models. The results led to the selection of optimum conditions for the reaction and the suggestion of an "ion-molecule reaction" mechanism to explain the very low activation energies for the reaction system. The area of application of this reaction lies in the direction of refining impure copper such as cement copper. Several experiments were performed in which an acidified solution of cupric sulphate under ethylene pressure was used to dissolve copper from the cement copper powder in the form of the copper (I)-ethylene complex, followed by the release of gas pressure to disproportionate the complex and precipitate a purer metallic copper.

Jan 1, 1987

By L McCallum, G Dale, B Silverwood, T Roscoe, A Costin

The introduction of Progressive Closure and Rehabilitation Plans (PCRPs) in Queensland from 2019 places greater importance on planning and implementation of mine rehabilitation activities. The progress and outcomes of progressive rehabilitation activities is monitored and reported upon to demonstrate success in achieving progress towards the approved post-mining landform, and to inform corrective action where required. The requirements of PCRPs place additional emphasis on mine sites to quantify the risks of successfully achieving planned outcomes. This is particularly challenging given mined-land rehabilitation is a complex process involving decisions on multiple inter-acting management interventions, climatic conditions and spatially variable site characteristics.

Aug 2, 2023

By J Webb

The mining industry is relatively niche and complex compared to other global industries in its safety and operating environment. Whilst some of the technology required to decarbonise the mining industry will emerge from the mass market (eg batteries, energy storage solutions and renewable power generation) where exogeneous external investment and innovation will drive supply, bespoke applications such as material movement will be constrained by industry limitations. Underground load and haul equipment burns the majority portion of underground mine diesel, and typically 25 per cent of scope one and two emissions. Transitioning away from incumbent diesel engines offers a considerable health benefit to all mine workers, as well as decarbonisation achievements, and through trials there is emerging evidence of more productive equipment and realistic expectations of lower operating costs of fleet. However, new equipment and material movement systems that support these industry goals are currently approached with caution due to the pivotal role they play in delivering productivity goals, and the lack of experiential data and certainty to mitigate the supplier development risk during this technology transition period, where all resources are required to meet a booming industry. A group of mining companies and suppliers have the aligned aim to accelerate the understanding and availability of heavy haulage mobile equipment through collaboratively piloting equipment and working with suppliers and each other to aggregate market demand, encourage investment and resolve the mine design and technology choices through their involvement in the Electric Mine Consortium (EMC). This paper will outline the major challenges the industry must overcome in sourcing and adopting a zero-diesel particulate and zero-emission mine, drawn from cases and insights across ten EMC mining company members.

Mar 29, 2023

By A Keogh, P Allen, P Stoker

"An EXTENDED ABSTRACT is available for download. A full-length paper was not prepared for this presentation. Private equity (PE) firms are comparatively free of mandatory requirements for the level and scope of due diligence applied prior to making investment decisions in minerals projects when compared to listed entities, sovereign funds or financial institutions adopting the Equator Principles (Equator Principles Association, 2013). While this freedom allows for flexibility, agility and innovation in making investment decisions, it can also expose PE firms to material risks that may impact their ability to successfully list the projects or attract later financing.Financial institutions and investors with mandatory due diligence and disclosure standards may refrain from investment in or acquisition of a project if it fails to meet various performance requirements. There are many high-profile projects that have suffered significant write-downs on book value after acquisition because specific non-mining issues were not adequately assessed. Thus, a PE firm may be left with an asset that is difficult to divest and incapable of securing development finance.PE firms can manage this risk by being aware of the growth trend in the adoption of ‘international standards’ in addition to host nation standards and legislative requirements. This paper outlines key issues for PE firms to address to maximise the chances of obtaining funding or successfully taking an exploration or mining project through to listing or divestment. Two steps are required: identification of gaps in performance and priority matters of interest to financial institutions and development of action plans to ensure that the priority requirements are met or capable of being met.A PE firm can set its project for success by understanding the social and environmental performance requirements of international standard financiers and by setting the project on the right path to meeting these requirements, and thus making it an attractive investment.CITATION:Allen, P, Stoker, P and Keogh, A, 2015. Setting for success – private equity exploration and mining project buy-in to listing and divestment , in Proceedings PACRIM 2015 Congress, pp 93–100 (The Australasian Institute of Mining and Metallurgy: Melbourne)."

Mar 18, 2015

By T Mizuta, D Ishiyama

The Vienna Wood hydrothermal is hosted by mid-oceanic ridge type basalt in graben morphology and is located in the Central Manus Basin. The hydrothermal field is about 300 metres in diameter and consist of a sulphide mounds and tall huge death and active chimneys. From the three distinct ore types collected from the Vienna Wood site, the dominant ore minerals recognised are pyrite, wurtzite, sphalerite, chalcopyrite, Fe-oxide and gangue minerals of anhydrite, gypsum, barite and silica. The consistencies in the paragenetic sequence and in the spatial distribution of the sulfides across the three ore types suggest that similar hydrothermal process exist across active and death chimneys. Fluid inclusion studies reveal a homogenisation temperature of 190-260¦C and an average salinity of 5.1-5.4 wt per cent NaCl equiv. The pH of the hydrothermal fluid ranges from 4.2 to 6.1. Bulk chemical analyses indicate that the mineralisation in the Vienna Wood can be classified into the Zn-(Cu-Pb) type of mineralisation. The tenors of the ore and mineral assemblage resemble those of the Mid-oceanic ridge system and ancient ophiolite hosted massive sulphide deposits of Cyprus and Oman.

Jan 1, 2002

Copper was first produced in Australia in 1844, at the Kapunda Mine in South Australia, and, by 18i>0, production exceeded 2,000 tons of copper a year. Output increased ,steadily, reaching a peak of 14,00Qo tons a year in 1867 and 1868, when the Burra Burra and Kapunda Mines in South Australia and the Peak Downs Moine at Clermont, Queensland, were at the height of their production. At this period, Australian copper formed a considerable percentage of the world's supply, its output equalling, for a short time, that of the United States. Production declined to between 3,000 and 4,000 tons a year after the closing of' these three mines between 18717 and 1879, and, at this stage, the Australian output came chiefly from the Wallatoo and Moonta mines in South Australia. About 19000, it began to rise again, with the extension of the railway to the copper fields of Chillagoe and Cloncurry, and, between 1905 and 1912, was at its greatest, with a maximum of 47,774 tons of copper in 1912. During this period, Australia contributed 4,7 per cent. of the world's annual production, and ranked among the six major copper-producing countries of the world (Table 1).

Jan 1, 1943

By P Aspinall

Safe work Australia (SWA) has a number of proposed amendments to existing Workplace Exposure Standard (WES) values that may dramatically change how mining workplaces using personal gas monitoring instruments will operate. In consultation with leading gas monitor manufacturers and distributors, an assessment of common Australian alarm settings values and analysis of potential frequency of increased alarm likelihoods has been conducted. This assessment explores the relationships between current monitoring practices, using instruments as health and not just safety tools and identify what will be needed to minimise worker ‘alarm fatigue’ and for common tasks to continue safely. This paper provides the necessary information to aid industry and hygienists to be ‘future ready’ given the likely impact that order of magnitude reductions in time weighted average (TWA) values for NO2, SO2, H2S and other common gases will have on current working practices. Reductions to gas alarm values will provide significant challenges to existing work methods and will require, practical application of the pending future values. Improvements and awareness of instrument capabilities by safety and hygiene professionals will better utilise gas monitors real-time data monitoring capacity and no longer be just ‘safe or not-safe’ instruments. The presentation seeks to promote the practical steps required in setting alarms based on risk consequence and likelihood, increase general awareness of the tools and data available in modern instruments and will enable industry professionals to better manage the challenges of any potential future changes.

Apr 16, 2024