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Advanced Concepts Agenda

Announcing TRI-MEweb ! TRI Process Recap Facility Definitions Reporting Exemptions Guidance Threshold Determination Guidance TRI Alternate Threshold Rule (Form A) Release and Waste Management Reporting Guidance Chemicals for Special Consideration Recent TRI Program Changes

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Advanced Concepts Agenda

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  1. Announcing TRI-MEweb! TRI Process Recap Facility Definitions Reporting Exemptions Guidance Threshold Determination Guidance TRI Alternate Threshold Rule (Form A) Release and Waste Management Reporting Guidance Chemicals for Special Consideration Recent TRI Program Changes TRI Program Information Tools and Assistance Advanced Concepts Agenda

  2. The TRI Process - Recap • Is my facility covered under EPCRA Section 313 (TRI)? • Review NAICS Code Applicability • Employee Threshold Determination • Chemical Use Threshold Determination • For which of the 650 listed TRI chemicals must I submit a TRI report? • How is the chemical used at the facility? Is it manufactured, processed or otherwise used? • How much of the chemical is manufactured, processed, or otherwise used at the facility? Are the TRI regulatory thresholds exceeded? • How do I report? • Submit a Form R or a Form A Certification Statement to EPA and state/tribal authority for each chemical requiring a report. • What do I report? • On-site releases of the chemical • On-site treatment, energy recovery and recycling • Off-site transfers of the chemical • Pollution prevention activities

  3. TRI Process – 2 Part Process Release/Waste Mgmt. Reporting Applicability & Threshold Determinations Use TRI-ME to Complete Form R or From A Identify total releases and off-site transfers Determine quantities of Section 313 chemicals and whether they are manufactured, processed, or otherwise used on-site for the reporting year Identify Section 313 chemicals manufactured, processed, or otherwise used at the site Identify other waste management practices Complete Final QA/QC Identify pollution prevention activities Submit to EPA & State If a Threshold is Exceeded…

  4. Announcing TRI-MEweb! • Available to all facilities in all states in Reporting Year 2007 (RY2007) • Exception is first time filers with EPA • A first time filer is a facility that has never reported to EPA previously and does not have a TRI facility Id (TRIFID) • First time filers are encouraged to download the TRI-MEdesktop application at http://www.epa.gov/tri/report/software/index.htm and submit electronically via CDX • Technical contacts as reported in RY2006 will receive an email or regular mail with information to register with CDX/TRI-MEweb and a facility access key in March, 2008 • If you did not receive notification and are the technical contact for your facility, please contact the CDX help desk at 1-888-890-1995

  5. Important Notice on TRI-MEweb! • TRI-MEweb requires certifiers to register with the Central Data Exchange (CDX) prior to being able to certify TRI-MEweb forms. • Registration includes creating, signing, and sending an electronic signature agreement (ESA) to the TRI data processing center • This process is estimated to take a minimum of 5 business days • Submission of the ESA is one time only as long as the certifier represents the facility • The TRI program recommends that facilities using TRI-MEweb register their certifier immediately upon accessing the application • For more information about TRI-MEweb and TRI-MEdesktop, please visit http://www.epa.gov/tri/report/software/index.htm

  6. TRI-MEweb Registration (Preparer) Preparer Registration Decision Tree Person Identified as a Preparer No Create a CDX Account with the TRI-MEweb Preparer Role Do you have a CDX account? Yes No Add TRI-MEweb Preparer Role to CDX Account Do you have a TRI-MEweb Preparer Role? Yes Log into CDX at https:cdx.epa.gov Select “TRI-MEweb: Prepare Submission” and enter access key to get facility data Note: For more information, see the TRI-MEweb Tutorials at www.epa.gov/tri

  7. TRI-MEweb Registration (Certifier) Certifier Registration Decision Tree Person Identified as a Certifier No Create a CDX Account with the TRI-MEweb Certifier role Do you have a CDX account? Yes No Add TRI-MEweb Certifier Role to CDX Account Do you have a TRI-MEweb Certifier Role? Yes Yes Do you need to add a new TRIFID to your Certifier Account? Add TRIFID to Certifier Role No Log in at https://cdx.epa.gov and certify awaiting forms Note: For more information, see the TRI-MEweb Tutorials at www.epa.gov/tri

  8. Definition of “Facility” • Facility = the TRI reporting unit • Primary NAICS code determination at facility level • Chemical threshold determinations made at facility level • “Facility - all buildings, equipment, structures, and other stationary items which are located on a single site or on contiguous or adjacent sites and which are owned or operated by the same person (or by any person which controls, is controlled by, or under common control with, such person).” (EPCRA §329(4))

  9. Multi-Establishment Facility • Reporting as multi-establishment facility (40 C.F.R. §372.30(c)) • Apply threshold determinations on aggregate amount of chemicals used at facility • Able to file separate Form R reports for each part of the facility (e.g., establishment or grouping of establishments) and the Form Rs must be designated as “part of a facility” in Part I, Section 4.2 • Report all non-exempt releases and other waste management activities of reportable Section 313 chemicals for all parts of a facility • Avoid double-counting at the facility of chemicals involved in intra-facility transfers

  10. De Minimis Exemption • The quantity of a non-PBT Section 313 chemical in a mixture or other trade name product is eligible for the de minimis exemption (40 C.F.R. §372.38) if the chemical is: • An OSHA-defined carcinogen present at a concentration of less than 0.1% by weight (See 29 C.F.R. §1910.1200(d)(4)) • or • Other non-PBT TRI chemicals present at a concentration of less than 1% by weight • The TRI de minimis level appears next to each chemical on the chemical list in Appendix II of the TRI Reporting Forms and Instructions (1.0, 0.1 or * for PBT chemicals where de minimis is not allowed (See 40 C.F.R. §372.38(b))) • Reminder: Naphthalene de minimis changed from 1% to 0.1%, beginning RY 2004

  11. De Minimis Exemption HOW IT WORKS… • De minimis exemption can apply to non-PBT chemicals: • In mixtures or trade name products processed or otherwise used • Only 2 manufacturing activities: • Coincidentally manufactured as impurities that remain in products • Imported in mixtures or other trade name products • De minimis exemption DOES NOT apply to: • Manufacturing chemicals (in most cases), including by-products manufactured coincidentally as a result of manufacturing, processing, otherwise use, or any other waste management activities • Wastes received from off-site • PBT chemicals (except for supplier notification)

  12. PBT Chemicals and the De Minimis Exemption • PBT chemicals are not eligible for the de minimis exemption except for purposes of supplier notification. • Even though a supplier is not required to notify users of the presence of a PBT chemical if it is below the de minimis concentration, the user is still required to consider all quantities of PBT chemicals! • No other EPCRA section 313 exemptions were modified by the PBT rule.

  13. Article Exemption Applicability • To qualify for the article exemption, the article must meet 3 criteria (40 C.F.R. §372.3): • Is formed into a specific shape ordesign during manufacture; and • Has end-use functions dependentin whole or in part on its shape ordesign during end-use; and • Does NOT release a Section 313chemical under normal processingor use conditions at a facility

  14. Article Exemption: How it Works • Releases of a Section 313 chemical from an article may negate the exemption. To maintain the article status, total releases from all like items must be: • In a recognizable form; or • Recycled, directly reused; or • 0.5 pound or less (may be rounded down to zero) • If more than 0.5 pound of a Section 313 chemical is released from all like items in a non-recognizable form and is not recycled or directly reused, none of the items meet the articles exemption • The item must retain at least one dimension (e.g. thickness or diameter) of the item from which it was made to be exempt as an article • See Reporting Forms and Instructions for more information on the article exemption

  15. Article Exemption: Examples • Wire is cut to specified lengths. Wastes include off-spec cuts and dust • Generation of off-spec cuts that are recognizable as articles will not, by itself, negate the article status • Dust and off-spec cuts not recognizable as articles, with greater than 0.5 pound of ANY Section 313 chemical released, and not recycled or directly reused, negate the article status • Fluorescent light bulbs are installed containing mercury. The used bulbs are crushed in an enclosed container for recycling • Crushing bulbs for disposal is not considered release during normal use; exemption is not negated

  16. Article Exemption • Article Exemption is often inappropriately used! • A useful rule of thumb is that whenmetals are machined, cut, or ground,in any manner, the article exemptionmay not be applicable. • The article exemption does NOTapply to the manufacture of articles.

  17. Exemption Guidance Reminder: • Section 313 chemicals in fuels added to motor vehicles not operated by facility do not qualify for the motor vehicle maintenance exemption • Considered toward processing threshold • Laboratory activities exemption only applies to certain activities that take place in a laboratory

  18. Threshold Guidance - Combustion • Section 313 chemicals may be coincidentally manufactured during combustion of: • Oil • Coal • Natural gas • Waste • Other materials • Any Section 313 chemicals in fuel consideredotherwise used

  19. Threshold Guidance - Combustion Reminder: • Section 313 chemicals coincidentallymanufactured (including those manufactured during activities covered under “otherwise use” exemptions)must be considered towards themanufacturing threshold • Includes acid aerosols and metalcompounds manufactured as by-productsof fuel combustion

  20. Threshold Guidance - Recycling Recycling as a Process Activity • The recovery of a listed Section 313chemicalfor further distribution in commerce or commercialuse is “processing” of that chemical • The off-site transfer of a listedSection 313 chemical for recyclingis “processing” of that chemical • Solvents in an on-site recycle/reusesystem: total amount of new chemicaladded during the year is counted as ‘otherwise use.’ The amount re-circulatedin the recycle/reuse system is not consideredtowards the threshold unless it is replaced.

  21. Form A Eligibility • Alternate Threshold Rule (Revised for RY 2006) • If alternate threshold criteria met: • Have the option to file a Form A in lieu of a Form R • No detailed release, other waste management, or source reduction reporting • Submit certification statement (Form A) • Maintain records and calculations used to determine Form A eligibility • TRI Burden Reduction Rule, announced December 18, 2006, expands eligibility for use of Form A.

  22. Alternate Threshold Rule (Non-PBT Chemicals) • Criteria for submitting a Form A for non-PBT chemicals • Do not exceed 1,000,000 pounds of the toxic chemical manufactured, processed, or otherwise used. • Do not exceed 5,000 pounds for the total waste management (i.e., releases including disposal, recycling, energy recovery, and treatment) of the Section 313 chemical.* • Do not exceed 2,000 pounds of releases including disposal (i.e., Section 8.1 and any releases in Section 8.8 of the Form R) *Equivalent to the sum of the quantities calculated for Sections 8.1 - 8.8 of the Form R

  23. Alternate Threshold Rule (PBT Chemicals) • Criteria for submitting a Form A for PBT chemicals • Do not exceed 1,000,000 pounds manufactured, processed, or otherwise used. • Cannot use for dioxin and dioxin-like compounds • No disposal or other releases into the environment of the PBT chemical (i.e., Section 8.1 and any releases reported in Section 8.8) • The total amount of the chemical managed by treatment, energy recovery, and/or recycling is not more than 500 pounds.* *Equivalent to the sum of the quantities calculated for Sections 8.2 - 8.7 and any non-release quantities in Section 8.8 of the Form R

  24. Quiz #1 Question 1 • A facility manufactures 100,000 lbs. of a non-PBT Section 313 chemical. They sell 99,000 lbs. as a product. They emit 500 lbs. to the air out of a stack, and send 500 lbs. off-site for treatment.Do they meet the criteria for submitting a Form A? Select Yes or No. YES NO

  25. Quiz #1 Question 2 • A facility uses 50,000 lbs. of nitric acid as a cleaner. The entire amount is neutralized in their on-site wastewater treatment operation and there are no air or water releases. Do they meet the criteria for submitting a Form A? Select Yes or No. YES NO

  26. Basis of Estimate Codes • One of the following RY 2007 updated “Basis of Estimate” codes must be listed on the Form R for each release and waste management quantity reported: • Continuous monitoring (M1) • Periodic or random monitoring (M2) • Mass balance calculation (C) • Published emissions factors (E1) • Site-specific emissions factors (E2) • Engineering calculations (O) • Everything NOT M1, M2, C, E1, or E2 above, such as: • Best engineering judgment • Equipment efficiency specs • Non-chemical-specific and non-published emission factors • Use the code on the Form R for the method used to estimate the largest portion of the release

  27. Chemical Migration Guidance • Migration of a Section 313 chemical contained in waste released (including disposal) may occur: • Migration of reportable chemical within one environmental medium (e.g., leachate from landfill) • Only required to report initial release of chemical to the environment Year 1 Year 2 500 lbs leachate in year 2 Not reported on Year 2 Form R 2,000 lbs to surface impoundment (Form R, Section 5.5.3B) Landfill Landfill Leachate

  28. Chemical Migration Guidance • Migration of a Section 313 chemical contained in waste released (including disposal) may occur: • Migration of chemical from one environmental medium to another (e.g., volatilization from a landfill) within the reporting year • Release estimates should be calculated and reported for all media in Part II, Sections 5, 6, and 8 of Form R Year 1 Year 1 2,000 lbs to surface impoundment (Form R: 1,000 lbs in Section 5.5.3B) 1,000 lbs to air (Form R: 1,000 lbs in Section 5.1) Landfill Landfill NOTE: If 500 additional lbs of the Year 1 disposal were volatilized in Year 2, 500 lb Of air release should NOT be reported in Section 5.1 of the Year 2 form.

  29. Metals and Metal Compound Category • Elemental metals and metal compound categories are separately listed chemicals under Section 313 • Separate activity threshold determinations • Report for each listing (e.g., nickel or nickel compound) only if the threshold for each listing is exceeded • If threshold exceeded for both the elemental metal and metal category compound (e.g., nickel and nickel compounds), you have options to report separately or file one combined report • If combined, file as metal category compound • The reason both the elemental metal and its compound may be reported on the same compound form is that while the entire weight of the compound is used to determine the threshold, only the amounts of the parent metal are reported on Form R.

  30. Metal Compounds • For threshold calculations, such as coincidental manufacture of metal compounds through combustion of fuels, use the total weight of the compound, not the parent metal • Releases and other waste management estimates (what you report on the Form R): these quantities are based on the parent metal weight only!

  31. Metal Compounds Example • A facility manufactured 200 pounds of lead oxide (PbO) while combusting coal. PbO contains one atom* of lead and one atom of oxygen. For their manufacturing threshold, the facility counts the entire 200 pounds of lead oxide. • In the facilities Form R reporting, they count only the portion of the 200 pounds that comes from the lead, and not the portion that comes from the oxygen. • The atomic weight of lead is ~207,and the atomic weight of oxygen is ~ 16, which means that about 93% of the weight of PbO comes from lead (207/(207 + 16) = 0.93), and about 7% of the weight comes from oxygen (16/(207 + 16) = 0.07). • So, if the facility is reporting a stack release based on 200 pounds of lead oxide manufactured during combustion, they would report 93% of 200 pounds, which is 186 pounds of Pb. * Every atom is assigned a number based on its weight, called the atomic weight. This information is found on the chemical periodic table (readily available on the internet).

  32. Quiz #2 Question 1 1. A facility processes 200,000 lbs. of a mixture containing 10% zinc chromate (ZnCrO4) and 15% chromium dioxide (CrO2) by weight. For which of the following chemical categories was the processing threshold exceeded? A. Chromium compounds only B. Zinc compounds only C. Neither D. Both

  33. Quiz #2 Question 2 • During the year, a facility burns 70,000 tons of coal, which contains elemental manganese (Mn) at 141 parts per million by weight. In combusting the coal, the facility coincidentally manufactures manganese compounds. The facility has no information about the chemical makeup of the manganese compounds manufactured and assumes it is the lowest-weight oxide – MnO. Based on molecular weights (Mn = 55, MnO = 71), the facility knows that 71 lbs. of MnO are formed for every 55 lbs. of Mn combusted. Does the facility exceed a threshold for either manganese or manganese compounds? YES NO

  34. Metal Cyanide Compounds Guidance • A metal cyanide compound, such as cadmium cyanide, requires separate reporting under both cadmium and cyanide* • For reporting cadmium, use entire weight of compound for threshold determinations, and only weight of metal portion of compound for release and other waste management reporting • For reporting cyanide, use weight of entire compound for threshold determinations and weight of entire compound for release and other waste management reporting * Qualifier for cyanide compounds states: X+CN-, where X=H+ or any other group where a formal dissociation may occur. For example, KCN or Ca(CN)2

  35. PBT Chemicals and Thresholds • PBT chemicals are subject to separate and lower thresholds • (See 40 C.F.R. § 372.28) • 100 lbs./yr or less (manufactured, processed, or otherwise used) • Aldrin • Lead* • Lead Cmpds. • Methoxychlor • 10 lbs./yr or less (manufactured, processed, or otherwise used) • Chlordane • Heptachlor • Mercury • Toxaphene • Isodrin • PCBs • 0.1 g/yr or less (manufactured, processed, or otherwise used) • Dioxin and dioxin-like compounds • Pendimethalin • Polycyclic Aromatic Cmpds. • Tetrabromobisphenol A • Trifluralin • Benzo(g,h,i)perylene • Hexachlorobenzene • Mercury compounds • Octachlorostyrene • Pentachlorobenzene PBT Thresholds * Excluding lead in stainless steel, brass, or bronze

  36. Polychlorinated Biphenyls (PCBs) • PBT activity threshold: 10 pounds • Manufacturing: PCBs may be manufactured as a product of incomplete combustion (PIC) • Processing: Recycling or reuse of PCBs • Otherwise use: • On-site treating or disposing PCB-contaminated waste received from off-site • Combusting PCB-contaminated oil

  37. Polychlorinated Biphenyls (PCBs) • NOT manufacturing, processing, or otherwise use • On-site disposal or treatment of PCBs not received from off-site • Off-site shipment of PCBs for disposal or treatment • PCB transformers (and similar electrical equipment) are considered exempt as articles if no PCBs released during normal use • Leaks may negate article exemption

  38. Mercury and Mercury Compounds • PBT activity threshold: • 10 pounds for mercury • 10 pounds for mercury compounds • Combustion of fuels is expected to be a main source of mercury triggering a reporting threshold • Combustion involves the otherwise use of mercury compounds in fuel, and the manufacture of elemental mercury • Amount of fuel required to exceed a threshold • No. 2 Fuel Oil: 1.41 x 109 gallons • Coal: 11,000 – 120,000 tons • No. 6 Fuel Oil: 1.89 x 109 gallons

  39. Mercury and Mercury Compounds • Present in some switches and lights • Otherwise use of bulbs and switches IS article exempt IF less than 0.5 pound of Section 313 chemical released (and not recycled) during reporting year from all like items during normal conditions of processing or use • Adding to manometers is NOT article exempt • Present in Caustics/Acids (if produced in mercury cell process – not common) • May be present in mined ores

  40. PACS and Benzo(g,h,i)perylene • PBT activity threshold • PAC category threshold: 100 pounds • Benzo(g,h,i)perylene threshold: 10 pounds • Present in coal, fuel oil, other petroleum products, such as asphalt and roofing tars • Asphaltic concrete (blacktop) typically contains 4 - 10% paving asphalt • Most uses of blacktop are NOT EXEMPT • Process areas and roadways – NOT EXEMPT • Employee parking lot – EXEMPT • See also EPA’s PACs guidance (http://www.epa.gov/tri/guide_docs/2001/pacs2001.pdf)

  41. PACS and Benzo(g,h,i)perylene (cont.) Quantity required to meet threshold From EPA’s Guidance for Reporting Toxic Chemicals: Polycyclic Aromatic Compounds Category

  42. Dioxin and Dioxin-like Compounds • PBT activity threshold = 0.1 gram manufacture, process, or otherwise use for the entire reporting year! • Dioxins formed as unwanted byproducts when chlorinated materials involved in combustion or other high-temperature processes, such as: • Fossil fuel and wood combustion • Waste incineration • Metallurgical processes • What it takes to exceed the 0.1 gram activity threshold? • 64,500 tons of coal combusted in a utility boiler • 8.33 million gallons of fuel oil combusted in a utility boiler • 1,230 tons copper scrap fed to a secondary copper smelter

  43. Dioxin and Dioxin-like Compounds • Dioxin and Dioxin-like Compounds are reported in Form R, Part II, Section 1.4. • % distribution of each of the 17 members in the chemical category must be reported. • If speciation data are not available, indicate ‘NA.’ • Beginning in Reporting Year 2008, Dioxin and Dioxin Like Compounds Toxicity Equivalency (TEQ) Information Rule goes into effect. • In addition to the total grams released for the entire chemical category, facilities must report the quantity of each of the 17 compounds in the category on a new Form R Schedule 1. • Data will be used to calculate TEQ values that will be made available to the public along with the mass data. • Removes the requirement to report the % distribution of each of the compounds in the category.

  44. Lead and Lead Compounds • Raw materials processed by a variety of facilities may contain metallic lead or lead compounds: • Metal ores • Coal • Wood • Oil & Oil products: heating oils, gasolines • Lead used in solder and other alloys is in the elemental NOT the compound form (i.e., this is lead, not a lead compound) • Lead-acid batteries will typically meet the articles exemption • Removing old paint containing lead and sending it off-site for disposal or treatment is NOT a threshold activity • Other sources of lead and lead compounds for PBT threshold: • Lead solder, lead babbitt, castings/molds, contaminants of aluminum and other common base alloys, X-Ray film • Cement, asphalt, graphite brushes, leaded glass • Transfers of lead and lead compounds off-site for recycling

  45. Lead and Lead Compounds • PBT activity threshold: • 100 pounds for lead (not contained in stainless steel, brass, or bronze) • 100 pounds for lead compounds • Non-PBT activity threshold • Non-PBT thresholds apply to lead contained in stainless steel, brass, or bronze* • 25,000 lbs for manufacture or process • 10,000 lbs for otherwise use *If elemental lead is removed from the qualified alloy, such as vaporization during melting of an alloy, the 100 lb threshold applies

  46. Lead Threshold Determination Flow Chart • Activity thresholds and reporting requirements for lead related to stainless steel, brass or bronze alloy qualifier Did the facility exceed the 25,000/10,000 lb. threshold, considering lead in stainless steel, brass or bronze alloy1 AND lead not stainless steel, brass or bronze alloy? 1 The de minimus exemption may be considered for quantities of the lead in stainless steel, brass or bronze alloy This flowchart does not apply to Lead Compounds, a separately listed TRI chemical YES NO Did the facility exceed the 100 lb. threshold considering only lead not in stainless steel, brass or bronze alloy? Did the facility exceed the 100 lb. threshold considering only lead not in stainless steel, brass or bronze alloy? YES NO YES NO May use Form A2 or R, without range reporting in Sections 5 and 6 of Part II. Report releases and transfers from BOTH leadin stainless steel, brass, or bronze alloy and lead not in stainless steel, brass, or bronze alloy. May use Form A2 or R; range reporting can be used in Sections 5 and 6 of Part II. Report releases and transfers from BOTH leadin stainless steel, brass, or bronze alloy and lead not in stainless steel, brass, or bronze alloy. May use Form A2 or R, without range reporting in Sections 5 and 6 of Part II. Only required to report releases and transfers of lead not in stainless steel, brass, or bronze alloy. No reporting for lead required 2 Must meet additional requirements for Form A use.

  47. Quiz #3 Question 1 • A facility combusts 13,600,000 lbs. of coal to fire its boilers. The coal contains elemental lead (Pb) at 7.0 ppm by weight. In combusting the coal, the facility otherwise uses lead and coincidentally manufactures lead compounds. The facility has no other information about the chemical makeup of the lead compounds manufactured and assumes it is the lowest-weight oxide – PbO. Based on molecular weights (Pb = 207, PbO = 223), the facility knows that 223 lbs. of PbO is formed for every 207 lbs. Pb used.Which of the following thresholds have been exceeded for lead or lead compounds? A. Otherwise Use only B. Manufacturing only C. Neither D. Both

  48. Typical Concentration of Lead in Raw Materials Quantity required to meet 100 lb. Threshold* * Emergency Planning and Community Right-to-Know Act-Section 313: Guidance for Reporting Releases and Other Waste Management Activities of Toxic Chemicals: Lead and LeadCompounds

  49. Nitrate Compounds • Water dissociable nitrate compounds category • Reportable only when in aqueous solution • For threshold determinations, use weight of entire nitrate compound • Calculate only weight of nitrate ion portion when reporting releases and other waste management quantities on Form R • Nitrate compounds are produced most commonly when nitric acid is neutralized or in biological treatment of wastewater • Intake water exemption may apply for nitrates drawn from environmental sources

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