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By W. Collingwood

As openpit mines continue to grow deeper and productivity continues to increase, the management of respirable dust and noxious gases can become a challenge. The natural wind flow in openpit mines is often recirculatory. This recirculation traps dust and gases in deep openpit mines. This problem is particularly acute in high-latitude openpit mines, due to a phenomenon known as atmospheric inversion. In the winter, arctic and subarctic regions experience short days and long nights. This deficit of solar radiation creates a situation in which cold, still air accumulates near the bottom of the pit. In openpit mines, this can result in unhealthy accumulations of gases and other contaminants. In this study, the natural wind flow patterns in and around openpit mines were investigated using a computational fluid dynamics (CfD) program. Two-dimensional models were created for a variety of pit geometries. The effect of depth, slope angle and wind speed on the recirculation pattern in the pit was examined.

Jan 1, 2012

By K. V. Raj

"Air inversion is a meteorological phenomenon generally occurs during winter times. Release of pollutants below the inversion height in an open-pit mine during periods of weak winds and consequently weak vertical mixing may result in very high concentrations of primary and secondary pollutants, causing serious consequences for health and safety of miners. Mine operations cease if the concentration of NOx or CO exceeds the threshold limit value (TLV) of the pollutants. Artificial ventilation is required to dilute the pollutants to an extent that mine workers can safely resume work. Studies of the turbulence parameters suggest that effective ventilation of the pit and removal of pollutants can be accomplished if a large enough mixing length in the open pit can be created. Turbulent mixing by eddies of different length scales under an inversion layer is product of wind shear, thermal gradient and buoyancy. The main result of turbulence is mixing of the atmospheric profile and transport of momentum. Computational fluid dynamics (CFD) Simulation results of a novel mitigation approach using cloud cover will be presented in this paper. INTRODUCTION In extreme climatic conditions, deep open-pit mines tend to trap pollutants at the pit bottom due to air inversions. Keeping open pits adequately ventilated is a considerable challenge for the mining community. Mine operators in cold regions are very familiar with this problem, the severity of which can be judged from Figures 1 and 2. The top portion of the figures show clear sky and snow covered benches. The brown haze, containing various contaminants accumulated over time in the pit under the air inversion, can be seen in the bottom portion of the figures. Several Arctic or subarctic mines have reported air inversions. Even Rio Tinto’s Bingham Canyon pit in Utah has reported local air inversions from time to time [1].Mitigation of pollutants in deep open-pit mines in the Arctic is a challenging task. Release of pollutants below the inversion height in an open-pit mine during periods of weak winds and consequently weak vertical mixing may result in very high concentrations of primary and secondary pollutants, causing serious consequences for human health. Mine operations cease if the concentration of any one of the pollutants (NOx or CO) exceeds the TLV. Sustained cessation of a mine operation has serious economic consequences. For continued mining operation, the levels of pollutants must be below the TLVs. If no significant synoptic meteorological situation changes during an inversion, a warm air mass sits over the cold air mass within the open pit. Artificial ventilation is required to dilute the pollutants to an extent that mine workers can safely resume work. Some of the early approaches in artificially ventilating open pits were attempted in the USSR. Most of the studies by Soviet researchers suggested the use of turbojets and turbo-propeller engines, airscrews, axial pit fans, and meteotrons [2, 3]. However, the majority of these studies were only theoretical in nature, with no evidence of an approach that really worked in practice."

Jan 1, 2017

By V. K. Kollipara

Dust dispersion characteristics in mine airways are important for developing engineering controls for dust and explosions. Authors here have used CFD modeling approach to analyze the dust dispersion characteristics in mine airways. The technique was initially validated with the published field experimental data. The results obtained were in a reasonable agreement. CFD validation results show that in a single entry the dust concentration decreases exponentially as a function of distance. Finer particles can travel up to a distance of 350-400 m away from the source. Parametric studies indicate that air velocity and input dust concentration has significant influence on dust concentration distribution. CFD modeling was then applied to study the dust dispersion characteristics in a room-and-pillar mine layout. Preliminary results show that dust concentration distribution is highly dependent on the airflow patterns and air velocity distribution. The distribution is not exponential until the velocity in the travel way becomes uniform. Data developed in this study may be used to design mine layouts and engineering controls for dust control and explosions.

Jan 1, 2011

By J. C. Edwards, C. C. Hwang

A computational fluid dynamics (CFD) program was applied to fire spread along combustibles in a ventilated mine entry. The rate of flame spread was evaluated for the ribs and roof of a coal mine entry; timber sets; and a conveyor belt. The CFD program models char forming materials with temperature dependent thermal properties. The program solves three dimensional time dependent flow equations with a mixture fraction model for the gas phase reactions. Radiant heat exchange is evaluated for non-scattering gas. The CFD program predicted a flame spread rate of 0.0145 m / s for an actual coal mine fire in which the estimated flame spread rate was 0.0086 m / s. This overestimated flame spread rate was a possible consequence of the presence of inert materials in the mine entry’s roof and ribs. CFD fire spread rate predictions of 0.043 m / s and 0.73 m / s bounded the measured value of 0.27 m / s for fire spread along Douglas Fir timber sets in a tunnel.

Jan 1, 2006

By A. Juganda, Jr. Bogin, J. Brune, J. Grubb, S. Lolon

"Face ignitions at the longwall face are a serious hazard in underground coal operation that can lead to a major mine explosion. Despite having methane monitoring system mounted on the shearer and at various locations on the longwall face, undetected accumulations of methane can still occur and result in face ignitions. With the use of Computational Fluid Dynamics (CFD), the interaction between the air flow at the longwall face and factors that contribute to the accumulation of methane around the longwall face can be modeled and visualized in great detail. The results confirm that the tailgate corner of longwall face is a critical area that is prone to face ignitions and needs to be properly monitored. The occurrence of roof falls on the tailgate entry inby the face and/or poor caving conditions behind the shields can pose a safety risk in the longwall operation. Poor gob caving can lead to insufficient face air quantity to dilute methane at the tailgate corner, while blocking of tailgate by a roof fall can carry methane contaminated air from behind the shields back into the face near the tailgate corner and pull the explosive gas zones (EGZs) inside the gob closer to the face. INTRODUCTION Ignitions of accumulated methane gas at longwall faces are well known to be among the major causes of methane explosion in underground coal longwall mining operations. Some of these ignitions can lead to major mine explosions, such as the Upper Big Branch mine disaster in 2010, in which methane migrated from the gob to the shearer cutting drum where it was ignited, resulting in a major mine disaster (Phillips, 2012). History has shown that, despite having methane monitoring systems mounted on the shearer and various locations at the longwall face and alarms set to 1% CH4 (Mine Safety & Health Administration, 2012), undetected accumulations of explosive methane-air-mixtures can still occur and result in face ignitions. Recent study by Verma and Brune (2016) state that frictional ignitions on longwall faces contributed to 379 incidents or 23% of the total 1,637 cases of face ignitions recorded from 1983 to 2014. The common cause of mine explosions usually involves poorly designed ventilation systems, insufficient ventilation, and inadequate monitoring in critical areas that are prone to methane accumulations. In longwall operation, the tailgate corner of the longwall face can be considered as one such critical area. On-site studies by Krog et al (2006) and Thakur (2008) show that increasing the longwall panel width may also increase cumulative methane emissions at the tailgate. There are also indications that increasing longwall face lengths can result in an increase of the void space behind the face under certain roof conditions (Schatzel et al, 2006). This may cause higher leakage rates from the face to the gob, thus reducing the amount of fresh air available at the tailgate."

Jan 1, 2017

By R. R. Jozefowicz, T. X. Ren, J. S. Edwards

The control of methane emission into underground mine workings is important both for the safety and productivity of the mine. As deeper and gasser coal seams are mined, ventilation methods involving increasing air pressures and quantities across mine workings may not be able to cope consistently with methane emission rates during the production cycle. An accurate prediction of methane emission into mine workings is of great significance in the design of ventilation systems and additional methane control methods if required. Research has been conducted to develop a numerical method for simulating methane flow through strata in which permeability is strongly influenced by mining-induced stress. To achieve this objective, both numerical modelling using Computational Fluid Dynamics (CFD) and laboratory tests on rock samples and granular materials under triaxial stress condition were carried out. Correlation has been established between stress and permeability characteristics of rock-measure rocks and laboratory results are being incorporated into the CFD models. This paper introduces the use of CFD techniques to model methane flow through permeable strata around longwall coal faces currently undertaken at the University of Nottingham.

Jan 1, 1997

By Oluwafemi Salami

Conducting full-scale fire experiments in underground mines is difficult and expensive. Sometimes, it is impossible to carry out fire tests in mines due to the danger they pose to mine workers and the underground facilities. However, understanding the potential occurrence of fires in a mine and their dynamics is critical to developing an appropriate emergency evacuation plan, fire suppression, and firefighting techniques. In this study, a numerical fire model using computational fluid dynamics (CFD) with fire dynamics simulator (FDS) 6.7.6 was developed to examine the influence of tunnel bifurcation on maximum temperature beneath a tunnel ceiling. The model was validated using full-scale experimental data. The maximum ceiling gas temperature predicted using FDS and measured maximum smoke temperature during the experiment shows good agreement. The study shows that bifurcation could lower the maximum ceiling temperature of fire-induced smoke in a subsurface environment. The findings from this study apply to the broader field of ventilation and fire life safety in tunnels and other underground environments.

Jun 23, 2024

By A. Juganda, Jr. Bogin, S. Saki, R. Gilmore, J. Brune, J. Grubb, S. Lolon

"In longwall mines, atmospheric or barometric pressure fluctuations can disturb the pressure balance between the gob and the ventilated working area of the mine, resulting in a phenomenon known as “gob breathing”. Gob breathing triggers a gas flow across the gob and the working areas and may result in a condition where a methane accumulation in the gob flows into the face area forming an explosive mixtures. This paper discusses results of Computational Fluid Dynamics (CFD) modeling carried out to analyze this phenomenon and its impact on the explosive mixture development under a bleeder-ventilated longwall gob panel scheme. Modeling results indicate that the gas inflow and outflow across the gob and the formation of Explosive Gas Zones (EGZs) are directly affected by the barometric pressure changes. Methane gas and EGZs in the gob expand out toward the face and bleeder entries during the falling barometric pressure. Where methane zones interface with mine air, EGZ fringes may form along the face and in the bleeder entries. When the atmospheric pressure increases, an ingression of oxygen into the gob is observed that can also increase EGZs in volume. The findings from this study help assess the methane ignition and explosion risks associated with fluctuating atmospheric pressures. INTRODUCTION Methane explosions continue to be a daunting risk for underground coal miners, although the number of related fatalities and injuries in the U.S. coal mining industry has steadily decreased since the establishment of the U.S. Bureau of Mines in 1910. Still, the consequences of a methane explosion are often disastrous with multiple fatalities and property damage often leading to permanent shutdown of the mine. Methane is formed during the coalification process and is released from the coal seam to the mine atmosphere when the coalbed is disturbed by mining or natural causes such as earthquakes. If not properly diluted by appropriate mine ventilation, this methane may accumulate in the active mine workings and gob areas. Researchers at the Colorado School of Mines have developed numerical models showing how and where explosive methane may accumulate in gob areas. Historical mine explosions appear to show a connection between mine explosions and fluctuating barometric pressure as a result of stormy weather. McIntosh (1957), Boyer (1964), and Kissell et al. (1973) studied the influence of barometric drops on major coal mine disasters in the United States prior to 1970. Their statistical analyses found that a majority of these disasters occurred in the fall and winter months when the barometric pressures were influenced by unstable weather conditions and noted increased methane content in the mine workings during times of falling pressure. Studies conducted by Fauconnier (1992) and Hemp (1994) found similar connections between methane explosions and barometric pressure fluctuations in a majority of gas explosions in South African mines. Ten out of twelve major mine explosions with five or more fatalities in the U.S. after 1970 were found to have occurred during the months of November through April when barometric pressure swings were more abrupt and intense (Lolon et al., 2015)."

Jan 1, 2016

By J. A. Marts, R. C. Gilmore, Jr. Bogin, S. A. Saki, J. F. Brune, J. W. Grubb

The main purpose of mine ventilation design is to provide sufficient quantity and quality of air to the workers and to dilute methane and other contaminants. It is generally perceived that the additional air along the longwall face will improve methane dilution on the face and in the tailgate. However, computational fluid dynamics (CFD) modeling efforts at the Colorado School of Mines (CSM) under a National Institute for Occupational Safety and Health (NIOSH) funded research project have found that higher flow velocities along the longwall face are shown to increase the pressure differential between the gob and longwall face allowing more methane to be entrained in the active face and tailgate (TG) area, thereby negating the dilution effect. The increased face ventilation causes an increase in pressure along the headgate side which allows more oxygen to ingress into the gob area, thereby increasing the amount of oxygen available to form explosive methane air mixtures in the gob and to support spontaneous combustion of the coal. Two things are happening at two different locations along the longwall face, increase in pressure as the flow enters the active area cause an increase in pressure which forces more oxygen into the gob, but as the flow is developed along the longwall face, the higher velocities causes greater pressure drop allowing methane to enter the active face further downstream from the headgate (HG) towards the tailgate side. In this paper, a parametric study will be presented to discuss the effect that varying the face air quantity has on methane concentrations in the tailgate and formation of explosive gas zones (EGZs) in the gob. Counter to conventional wisdom, it appears that increased longwall face air quantities may increase the explosion hazard as they result in increased EGZ volumes in the gob, along with increased methane quantities in the tailgate return.

Jan 1, 2015

By S. Lolon

Spontaneous combustion in underground coal mines has become a serious problem particularly in the caved area (gob). Recent statistic has shown that approximately 17% of total 87 underground coal mine fires in the United States are attributed to spontaneous combustion (De Rosa, 2004). Spontaneous combustion results from a self-heating process in exothermic conditions. The accumulated heat, if not removed, is conducive to the rapid increase of temperature and may result in mine fires or explosions. It is well accepted that the interaction between oxygen and coal substances is the main cause for spontaneous combustion, while other factors such as pyrite, moisture, and bacteria play a secondary role to the self-heating of coal. Therefore, only coal oxidation is considered in this study. Coal oxidation occurs as coal comes into contact with air. This process involves complex phenomena in terms of heat transfer, chemical surface absorption, and energy balance related to inherent properties of coal (Wang et al., 2003). For simulation purpose, overall reactions can be simplified as suggested by Mitchell (1990): C + O2 CO2 + heat [65°- 94°C] (1) CO2 + C 2CO + heat [100°- 150°C] (2) Stoichiometric reactions (1) and (2) show that 2.66 grams of oxygen are required to oxidize 1.0 gram of carbon. Once the temperature exceeds 100°C, the reaction has little chance to stop. The crucial step in reducing spontaneous combustion risk is locating the ignition point of spontaneous combustion (hot spot). This information is useful in the effort of developing a preventive method effectively. In this study, this was conducted based on the best gathered information: ventilation surveys conducted in an existing longwall mine located in the western US; the laboratory experiments performed on a physical gob model; and the CFD models to investigate the flow behavior in the gob, the oxidation of coal, and heat transfer phenomena. The hot spot location is determined as a function of oxygen concentration and gob temperature. The critical values are the following: 5% (by volume) for oxygen and 100°C for gob temperature. CHARACTERISTICS OF GOB MATERIAL AND MODELS Permeability Concept Permeability is one of the key parameters in any study dealing with porous medium. This is determined by particle size and the ratio of void volume to the total volume (porosity) of porous medium. This relationship is known as the Carman-Kozeny equation (Scheidegger, 1957) and is given mathematically as [ ] where k* = theoretical specific permeability, m2 dm = the mean particle size, m n = porosity However, permeability tests with various particle sizes were carried out at the University of Utah?s ventilation model (Figure 1) to verify this relationship. These tests indicated a necessity to modify this theoretical relationship. A factor of 0.898 was obtained to make up the different between theoretical permeability and the experimental one. The modified version of (3) is given by: [ ] This equation is used to determine permeability of the simulated mine gob throughout the study. [ ] Mine Gob Material The gob is represented by zones filled with material of given size distribution. For physical measurements and CFD simulations, the material used were crushed rock and coal. Due to compaction, three different characteristics of gob material were used in the model: unconsolidated, semiconsolidated, and consolidated. In the real condition, the largest coal-rock particles are more likely to be located in the area behind the shields. This material is freshly broken and unconsolidated. The size of these broken particles is based on a study carried out by analyzing images taken from the area behind the shields in three coal mines in the United States (Pappas and Mark, 1993). The results have shown that the mean size of materials behind the shields is about 1.22 m. The permeability associated with this size was then obtained from (4) and permeability tests. This was 4.68 x10-7 m2. For semiconsolidated and consolidated zones, due to the lack of experimental data, these were determined through CFD simulations. These simulations were designed by assigning a permeability of 3.15 x 10-8 m2 for consolidated zone and 7.98 x 10-9 m2 to the other zone. The airflow pattern in the gob assigned with given permeabilities was expected to follow the experimental distribution (Brunner, 1985). The mean particle sizes for the semi-consolidated and consolidated zones were 0.02 and 0.006 m, respectively; smaller than those of the unconsolidated zone. Figure 2 shows the 3D view of permeability changes in the gob.

Jan 1, 2009

By S. Ragab

The objective of flotation models is to predict the recovery rate of minerals from a flotation cell. In this paper a CFD?based flotation models is presented. The model uses first order rate equation, and the collision frequency is estimated using Abrahamson [1] model with input from CFD two-phase simulations. Spatial distributions of dissipation rate and air volume fraction (also called void fraction) are determined by the two-phase hydrodynamic simulations. Knowing these parameters throughout the machine is essential in understanding the effectiveness of different components (rotor, stator or disperser, jets) on the flotation efficiency. Not only the average pulp recovery rate can be estimated but also the regions of high/low recovery rate can be identified. The CFD-based flotation model presented here can be used to determine the dependence of recovery rate constant at any locality within the pulp on particle diameter, particle specific gravity, contact angle, and surface tension.

Jan 1, 2012

By S. M. Hsiung

Chain pillar design formula under weak roof condition was developed by statistically analyzing the results from the three dimensional finite element parametric analyses. The parameters such as mechanical properties of the roof and floor strata, overburden depth, panel width and length, and coal strength were incorporated in the formula. A conversion formula which transfers a rectangular chain pillar into a square chain pillar of equal strength is proposed. The influence of high in-situ horizontal stresses, which are often encountered in the coalfield, on chain pillar stability is also discussed.

Jan 1, 1984

By AKIHIRO YOSHIMURA, HIDEKAZU KATO, KOTA TAKATORI, YASUNARI MATSUNO

Chalcopyrite (CuFeS2) is the most refractory copper mineral when treated in conventional sulfate media leaching systems. This study is the first to examine the use of a dimethyl sulfoxide (CH3SOCH3), or DMSO, solution containing copper chloride (CuCl2) in the leaching of chalcopyrite. The DMSO solution containing CuCl2 could selectively dissolve the valuable metals of copper (Cu) and gold (Au) from chalcopyrite while leaving minerals with little economic value, such as pyrite (FeS2), and the penalty element arsenic (As) in the residues. Leaching chalcopyrite using a DMSO solution that contains CuCl2 offers a number of advantages, including eco-friendliness and easy operation.

By AKIHIRO YOSHIMURA, HIDEKAZU KATO, KOTA TAKATORI, YASUNARI MATSUNO

Chalcopyrite (CuFeS2) is the most refractory copper mineral when treated in conventional sulfate media leaching systems. This is the first study to examine the use of a dimethyl sulfoxide (CH3SOCH3, DMSO) solution containing copper chloride (CuCl2) for the leaching of chalcopyrite. Leaching experiments for a copper concentrate composed mainly of chalcopyrite were conducted at ambient pressure at 313–413 K. The leaching fractions of Cu, Fe, S, Au, and As were investigated. It was found that 90% of the Cu was extracted in 2 h, and 94% was extracted in 4 h at 373 K, which is competitive with other conventional processes. A DMSO solution containing CuCl2 could selectively dissolve the valuable metals Cu and Au from chalcopyrite, but leave minerals with little economic value such as pyrite (FeS2) and As in the residue. Chalcopyrite is oxidized by cupric ion in proportion to the stoichiometric ratio of Cu in the concentrate to the initial cupric ion in the DMSO solution, which is enhanced by the presence of oxygen below 373 K.

Mar 12, 2021

By P. A. Delfosse

Numerous terms are used for rocks containing calcium carbonate so that confusion frequently occurs in the common language. Chalk and marble are two extremes among a wide variety of carbonate rocks including limestones, marls, travertine and other calcareous materials. We will deal mainly with the purest types of natural calcium carbonates which are widely used today in many industrial applications.

Jan 1, 1986

By Chester R. Harris

With the passage of the Occupational Safety and Health Act (OSHA) on December 29, 1970 and the formation and growth of the OSHA Agency it spawned, public consciousness of occupational safety was raised. It became accepted that employees had the right to "a safe and healthful workplace". With the possibility of OSHA inspections, employ ers (particularly those with large workforces) began to give serious con sideration to engineering controls, safety programs, and training in a more uniform manner than previously.

Jan 1, 1991

By Roy Woodall

Successful mineral exploration is the lifeblood of the mining industry. Contrary to what the environmental lobby would have the world believe, the industry is replacing the metals it is extracting. The reserve base has not changed significantly in 20 years (Fig. 1.) Mineral exploration is a research activity. First there is the idea, the vision or the intuitive thought. The experiments follow. These involve repeated phases of data gathering, data interpretation and concept testing through drilling. For many companies, exploration is the main investment in scientific research. Each mineral exploration experiment may involve years of costly work. Despite the improving tools of science and technology, the investment remains high-risk. Only the promise of high rewards, or desire to survive as a mining company, will stimulate the necessary commitment and level of investment. Confidence that an economic return can be achieved, confidence in the science and technology being applied and confidence in the people involved are the foundations upon which successful mineral exploration is built (Woodall, 1984). The challenges facing the explorationist in the 1990s fall into two categories: - the challenge to make the activity economic; and - the challenge to make the activity socially and, therefore, politically acceptable.

Jan 1, 1992

By Dana S. Getman

For 30 years, mining operations worldwide have used diesel-powered mobile machinery to mechanize the mining process. South African diamond mines and some US coal mines have 15 years of experience with this type of equipment. During the past eight years, most of the new gold production from underground mines outside of South Africa has been mined by bulk methods using diesel-powered machinery. The underground mining industry, then, has secured and institutionalized the larger benefits created by a technology that was new to mining engineers in the early 1960s. The state of mechanized diesel-powered underground mining is now mature. To survive, though, mine operators -regardless of commodity mined and position in the commodity cycle-must maximize the benefits of diesel technology. The benefits gained in the next seven to 10 years will be realized by tweaking this component, fine tuning that piece of machinery and demanding optimum use of the technology. Manufacturers of diesel-powered machinery share the condition of maturity with their customers. Larger scale and easy market development have occurred. Much has been made of the potential size of the US coal segment as well as markets in China and the Confederation of Independent States (CIS). Indeed, opportunities do exist in these regions. However, these market development opportunities do not imply the market size trend line remains unchanged. They simply mean the potential market size is within reach. In fact, the market size for the product is shrinking.

Jan 1, 1993

By J. E. Lees

Advanced remote sensing can be a powerful new information tool to help private and public entities make better environmental and resource management decisions. However, some regulated entities are reluctant to develop or use this tool because of their concerns that it will lead to increased risks and costs of environmental legal liability. They fear that new ways of monitoring the environment will increase liability, undermine existing enforcement agreements, reopen compliance agreements, and generally provide a competitive disadvantage to early adopters by accelerating environmental cleanup costs. Others counter that the increased risks are marginal, and that several advantages outweigh these risks, including the opportunity to more effectively manage environmental operations, target and set priorities, measure and track management and compliance effectiveness, provide more defensible environmental assessments and baseline conditions, make and defend optimal siting decisions, and avoid or resolve environmental disputes. This paper offers strategic advice on ways regulated entities can enjoy the benefits of these powerful new information tools while mitigating down-side legal and compliance risks as much as possible.

Jan 1, 1999

By J. E. Lees

Advanced remote sensing can be a powerful new information tool to help private and public entities make better environmental and resource management decisions. However, some regulated entities are reluctant to develop or use this tool because of their concerns that it will lead to increased risks and costs of environmental legal liability. They fear that new ways of monitoring the environment will increase liability, undermine existing enforcement agreements, reopen compliance agreements, and generally provide a competitive disadvantage to early adopters by accelerating environmental cleanup costs. Others counter that the increased risks are marginal, and that several advantages outweigh these risks, including the opportunity to more effectively manage environmental operations, target and set priorities, measure and track management and compliance effectiveness, provide more defensible environmental assessments and baseline conditions, make and defend optimal siting decisions, and avoid or resolve environmental disputes. This paper offers strategic advice on ways regulated entities can enjoy the benefits of these powerful new information tools while mitigating down-side legal and compliance risks as much as possible.

Jan 1, 1999