National Park Service Solid Waste Management
National Park Service Solid Waste ManagementDAK Consulting, Inc. PhotoQuick Reference GuideThe above photo shows animal resistant recycling and trashcontainers at a campground in Devils Postpile National Monument.The recycling container (left) has a distinct shape, color, and size, arestricted access opening sized for the items to be recycled, and asecured lid to reduce improper use as a trash receptacle.
National Park Service Solid Waste ManagementQuick Reference GuideProduced by D. A. Kahl Consulting, Inc. for:Environmental Management ProgramPark Facility Management DivisionNational Park ServiceU.S. Department of the InteriorWashington, D.C.October 1, 2007
ContentsChapter 1 - Introduction . 1Purpose, Scope, and Content. 1Chapter 2 - Solid Waste Management . 2Solid Waste Management as Part of the NPS Mission . 2Applicable Laws, Regulations, and Policies . 2Chapter 3 - Integrated Solid Waste Alternatives Program (ISWAP) . 3Chapter 4 - Solid Waste Tracking . 4Tracking Diversion Goals. 5Chapter 5 - Solid Waste Analysis. 6Who and Where: Waste Generator Analysis . 6What: Waste Composition Analysis. 6Chapter 6 - Solid Waste Management Program Analysis . 8Reporting Requirements . 8Chapter 7 - Source Reduction and Reuse. 9Identifying Source Reduction and Reuse Opportunities . 9Source Reduction Strategies . 9Chapter 8 - Recycling . 11Identifying Recycling Opportunities (Sources of Recyclable Materials). 11Key Design and Operating Considerations . 11Other Recycling Program Considerations. 11Chapter 9 - Composting . 13Composting Regulations. 13Identifying Composting Opportunities . 13Key Design and Operating Considerations . 13Other Composting Program Considerations. 13Chapter 10 - Universal Waste and Special Waste Materials . 15Managing Universal and Special Wastes . 15Chapter 11 - Trash Collection and Disposal . 16Key Operating Considerations. 16Collection Systems. 16Disposal Options . 16Chapter 12 - Education and Outreach . 17Chapter 13 - Contracting for Solid Waste Disposal. 18Trash Collection Contracts. 18Concession Contracts. 18Appendix A - Glossary of Acronyms. 19Appendix B – Sample Concession Contract Language . 20
Chapter 1 - IntroductionSolid waste, commonly known as litter, trash, garbage, or refuse, is defined as durable goods,non-durable goods, containers and packaging, food wastes, yard wastes, and miscellaneousinorganic wastes from residential areas, commercial and institutional operations, and publicareas. Generally, the term “solid waste” is used to describe an entire waste stream including allthe materials that will eventually be disposed in landfills or other facilities, as well as all of thematerials which will be separated and recovered for reuse, recycling, or composting. Thematerials in solid waste which are disposed are referred to as trash, or garbage, and the recoveredmaterials are described by the method of recovery, such as recyclable or compostable materials.Domestic sewage sludge and waste water are not considered solid waste.Purpose, Scope, and ContentThis document is meant to serve as an easy-to-use reference guide for solid waste management atnational parks. It provides an overview of topics covered in greater detail in the National ParkService Solid Waste Management Handbook (Handbook). The Handbook provides additionalinformation on regulations, tools, links, and outside resources, as well as resources applicable toNPS partners (i.e., concessioners, contractors, and cooperating associations) and is available onthe National Park Service (NPS) Intranet at:http://classicinside.nps.gov/documents/Solid Waste Management Handbook intropage.pdfThe target audience of this guide includes NPS employees involved in all aspects of solid wastemanagement. While this reference guide should be useful to all parks, it will be particularlyuseful to small parks since solid waste management is typically more complex at larger parks.Chapters 1–6 cover solid waste management, solid waste management planning and analysis,and solid waste program development.Chapters 7–13 provide more detailed information, examples, and steps for developing asuccessful solid waste management program including: source reduction, recycling, composting,universal waste, trash collection and disposal, education and outreach, and disposal contracts.Links to applicable sections of the Handbook and other resources are included at the end of eachchapter in the “For More Information” boxes.Please note that this reference guide and the associated Handbook cover only non-hazardoussolid waste generated at NPS facilities. Also note that the recommendations for wastemanagement practices contained in the reference guide and Handbook do not replace federal,state, or local solid waste management regulations and requirements.National Park Service - Solid Waste Management Quick Reference GuidePage 1
Chapter 2 - Solid Waste ManagementSolid waste management includes collection and disposal of garbage, as well as practices thatreduce the amount of garbage disposed, such as source reduction, reuse, recycling, andcomposting. Safe and sanitary solid waste management is required by federal laws, regulations,and policies, and is encouraged by NPS policies and best management practices (BMPs).Solid Waste Management as Part of the NPS MissionSolid waste management is an integral part of NPS services and facilities that support publicvisitation and NPS staff. NPS solid waste management policy demonstrates the NPS mission topreserve and protect park lands and natural resources. This policy emphasizes reduction, reuse,and recycling to lessen resource consumption, minimize environmental impacts, and provide anenvironmentally appropriate level of services and facilities to support public use and enjoyment.Applicable Laws, Regulations, and PoliciesThere is a large body of federal laws, regulations, and policies covering the proper managementof non-hazardous solid waste within parks. Most of these federal laws, regulations, and policieshave existed for many years and have laid the groundwork for current practices.Executive Order (EO) 13423, Strengthening Federal Environmental, Energy, and TransportationManagement, is the most current and relevant policy for solid waste management programdevelopment and environmental planning at federal facilities. As a result of this EO, the Officeof the Federal Environmental Executive (OFEE), Department of the Interior (DOI), and NPShave all developed and issued policies on solid waste management.The federal statute governing solid waste management is the Resource Conservation andRecovery Act (RCRA). Under Subtitle D of RCRA, states are encouraged to developcomprehensive plans for the management of non-hazardous industrial solid waste and municipalsolid waste (MSW). Subtitle D also sets criteria for MSW landfills and other solid wastedisposal facilities, and prohibits the open dumping of solid waste. The RCRA solid wastemanagement regulations have been promulgated under 40 CFR Parts 239-258FOR MORE INFORMATION: Handbook, Section 1:http://pfmd.nps.gov/EMP/hazmat/EMP LIB/swhandbook/SWHandbook Sec1.htm NPS Environmental Audit Guide, Appendix 14, EnviroCheck Sheet - Solid WasteManagement: http://classicinside.nps.gov/documents/Final EAP Guide 2006.zip EO 13423: http://ofee.gov/eo/EO 13423.pdf RCRA Subtitle D regulations at 40 CFR 239-258:http://www.access.gpo.gov/nara/cfr/waisidx 06/40cfrv24 06.htmlNational Park Service - Solid Waste Management Quick Reference GuidePage 2
Chapter 3 - Integrated Solid Waste Alternatives Program(ISWAP)Integrated solid waste management means that all of the work and programs in solid wastemanagement are considered a unique system. To formalize this system, parks should develop anIntegrated Solid Waste Alternatives Program (ISWAP) to provide coordination and guidance onintegrated solid waste management practices. An ISWAP is recommended for parks as an initialplanning tool for solid waste management, for developing improvements and new programs tomanage solid waste, and as a first step to meeting solid waste management goals. Implementingan ISWAP or updating an ISWAP can be selected as a goal, objective, or target in the park’sEnvironmental Management System (EMS).A solid waste management plan developed according to the recommendations of an establishedISWAP (ISWAP Plan) represents the culmination of an analysis to determine how the park canefficiently manage its entire solid waste stream. As such, an ISWAP Plan documents the park’sefforts in ISWAP planning and design.FOR MORE INFORMATION: Handbook, Section 2:http://pfmd.nps.gov/EMP/hazmat/EMP LIB/swhandbook/SWHandbook Sec2.htm Example ISWAP Plan: http://classicinside.nps.gov/documents/Generic ISWAP.pdfNational Park Service - Solid Waste Management Quick Reference GuidePage 3
Chapter 4 - Solid Waste TrackingTracking the amount of solid waste generated and the associated disposal/recycling costs canprovide valuable information for effective management and improvement of trash and recyclingprograms. Solid waste tracking provides the data needed to determine diversion rates and allowsparks to report and monitor progress towards NPS diversion goals. In addition, these data can beused to meet the annual RCRA reporting requirements for solid waste management andrecycling, and are recorded as part of NPS environmental condition assessments. Tracking ofsolid waste management is also encouraged as a BMP under the NPS Environmental AuditProgram (EAP).Table 1 provides a brief overview of some of the methods used to estimate waste generationamounts with their pros and cons.Table 1 - Methods for Estimating Waste GenerationMethodProsConsRely on contractor estimates.Easiest method for the park.Reasonably accurate, fairly easyparks to develop thesecalculations.Accuracy depends onwhether or not estimates arebased on weight tickets orvolume estimates; and if thecontractor picks up onlypark-generated waste beforedumping at the disposalfacility.Many parks contract outcollection, and parkgenerated material may beonly a portion of the loadweighed on the scale.Seasonal variations in"fullness" may skewestimates.Can be used regardless ofwhether or not NPS crewsempty the container.Location or seasonalvariations in material typesmay skew estimates.Very simple approach.Not accurate.Parks often have differentvisitation patterns, operatingcircumstances, and trashgeneration rates.Recommended if accuratecontractor estimates areavailable.Rely on weight tickets fromdisposal.Recommended if available.Calculate how full eachdumpster or can is, and applyaverage weight/containerestimates to thesecalculations.Recommended if first twomethods are not available.Use average pounds pervisitor estimates.A very accurate measure if parkemployees handle all trashcollection.Not recommended.Parks should evaluate the type of data available and use the most accurate tracking andestimating method for that type of information. The biggest step forward in accuracy is to movebeyond a once-per-year guess or estimate of quantities generated. In all cases, parks shouldadopt a tracking procedure to record actual quantities or quantity estimates continuouslythroughout the year.National Park Service - Solid Waste Management Quick Reference GuidePage 4
Tracking Diversion GoalsBy tracking solid waste generation, the park can determine its diversion rate and report andmonitor its progress towards meeting NPS goals. The diversion rate is the weight of all solidwaste diverted to recycling/composting divided by the weight of all solid waste materialsgenerated expressed as a percentage ([total materials diverted in tons / (total trash disposed of intons total materials diverted in tons] * 100).DOI has set the current diversion rate goal at 50% per year by 2010 (Note: This goal likely to berevised by DOI in the near future; states may have higher recycling goals). This means that 50%of all of the solid waste materials generated by parks should be diverted from disposal at alandfill through reuse, recycling, composting, or energy recovery programs.NPS includes the following activities and materials in the diversion rate calculation numerator(all of which are measured in tons): Reused materials;Recycled materials;Backyard compost;Compost;Universal waste (i.e., fluorescent lamps, batteries, mercury-containing devoices, andpesticides);Waste-to-energy combustion of trash - Energy recovery is required to count as diversion;use the facility weight reduction percentage (accounts for trash residuals and ash which isnot diverted) applied to total tons of trash sent to the facility; andMixed waste composting of trash - Compost product production is required to count asdiversion; use the facility weight reduction percentage (accounts for trash residuals whichare not diverted) applied to total tons of trash sent to the facility).NPS has developed a solid waste tracking tool that can be used to record volume estimates oftrash disposed and materials recycled/composted throughout the year and convert the volumes toweight estimates. This tool includes background calculations that will determine an annualdiversion rate (if it is filled out with a full year’s data on trash and recycling/compostingamounts). The tracking tool is available for downloading at:http://classicinside.nps.gov/documents/SW tracking Tool.xlsFOR MORE INFORMATION: Handbook, Section 3:http://pfmd.nps.gov/EMP/hazmat/EMP LIB/swhandbook/SWHandbook Sec3.htmNational Park Service - Solid Waste Management Quick Reference GuidePage 5
Chapter 5 - Solid Waste AnalysisSolid waste management analysis answers three important questions about trash generated in thepark:1. Who generates solid waste?2. Where is the solid waste being generated?3. What types of solid waste are being generated?This analysis can be very detailed or very general depending on the size of the park, thecomplexity of park operations, and the level of accuracy needed. It is important to getinformation that provides enough detail to identify the best opportunities for new solid wastemanagement programs and to make good decisions on program changes and improvements.Who and Where: Waste Generators AnalysisThis analysis identifies the individual areas and facility types where solid waste is generated inthe park. For a typical park, common solid waste generators include: Visitors in day use areas and campgrounds;Park administration staff and other office staff;Park maintenance operations;Park staff and families in residential areas; andVisitors in partner operated areas.Determining the amounts of solid waste generated in each area can help identify the largest solidwaste generation areas in the park, focus solid waste management resources, and establishimprovements or new programs, such as recycling or composting.What: Waste Composition AnalysisA waste composition analysis is an approximation of the materials and proportions of materialsin the solid waste generated at the park. Typical categories of materials include paper, plastic,metals, glass, wood, food waste, and miscellaneous wastes. A waste composition analysis can bedone for just one part of the park (i.e., park operations, visitor areas, park partner operations) orfor the entire park. Knowing the composition of the solid waste will help to identify materialsthat could be diverted to recycling and composting. In addition, knowing the composition ofwaste generated in a part of the park will allow the park to design a recycling and compostingprogram for a specific part of the park.For smaller parks, or parks with less complex operations, generators and composition of wasteare more predictable. The following table shows a typical waste stream composition fordifferent generator types, noting the main recyclable and compostable components.National Park Service - Solid Waste Management Quick Reference GuidePage 6
WhoVisitorsVisitorsStaffStaffStaffTable 2- Table of Typical Waste Stream CompositionWhereWhatWhat to Do With ItDay useAluminum cansRecyclePlastic bottlesRecycleGlass bottlesRecycleMixed packagingTrashCampgroundPaperRecycle or compostMixed paperRecycle or compostCardboardRecycleAluminum cansRecyclePlastic bottlesRecycleGlass bottlesRecycleFood wasteTrash or compostMixed packagingTrashOfficesPaperRecycle or compostMixed paperRecycle or compostCardboardRecycleAluminum cansRecyclePlastic bottlesRecycleGlass bottlesRecycleMaintenancePaperRecycle or compostMixed paperRecycle or compostCardboardRecycleAluminum cansRecyclePlastic bottlesRecycleGlass bottlesRecycleHousingPaperRecycle or compostMixed paperRecycle or compostCardboardRecycleAluminum cansRecyclePlastic bottlesRecycleGlass bottlesRecycleFood wasteCompostMixed packagingTrashOther ways to estimate waste composition include: Visual checks;Weighted average estimates; andWaste composition studies (i.e., field sorting or “dumpster diving”).FOR MORE INFORMATION: Handbook, Section 4:http://pfmd.nps.gov/EMP/hazmat/EMP LIB/swhandbook/SWHandbook Sec4.htmNational Park Service - Solid Waste Management Quick Reference GuidePage 7
Chapter 6 - Solid Waste Management Program AnalysisAn analysis of the park’s solid waste management program can provide a review of the currentprogram costs, main functions, and effectiveness. This analysis can also provide the startingpoint for developing program improvements, changes, or new program needs.A solid waste program analysis can be conducted using the following steps: Use the tracking and reporting waste stream analysis to identify the park’s solid wasteand recycling quantities, waste composition, and answer the “who, where, and what”questions for waste generators in the park;Review current solid waste management programs, including the current program costs,main functions, and effectiveness;Set goals for program improvements, cost reduction, and increasing diversion throughreuse, recycling, and composting (think of EMS or Government Performance and ResultsAct (GPRA) format for impacts, goals, actions, etc.);Develop recommended steps, programs, staffing, equipment, and material needs; andDevelop a five-year implementation plan. Reporting RequirementsThere are currently several existing reporting requirements that include solid waste managementinformation, including the annual RCRA report on environmental purchasing, wastemanagement, and recycling; the NPS environmental condition assessments; and the NPSenvironmental compliance audits.FOR MORE INFORMATION: Handbook, Section 5:http://pfmd.nps.gov/EMP/hazmat/EMP LIB/swhandbook/SWHandbook Sec5.htmNational Park Service - Solid Waste Management Quick Reference GuidePage 8
Chapter 7 - Source Reduction and ReuseGenerally, source reduction falls into the following categories: Product reuse; Reduced material volume; Reduced toxicity; Increased product lifetime; and Decreased consumption.The design of each source reduction program will differ for each type of solid waste generatorand material.Identifying Source Reduction and Reuse OpportunitiesOne way to identify the many opportunities for source reduction and reuse is to determine thenumber of new materials and new products being used in the park. Alternately, source reductionopportunities can be identified by focusing on the waste generated in the park. Using the “who,where, and what” questions can help identify the largest waste generators and their activities, andthe specific materials in the solid waste stream that could be reduced or replaced.Source Reduction StrategiesParks with limited resources should determine which sources generate the most waste andprioritize waste prevention efforts accordingly. Specific strategies for achieving sourcereduction include: Environmental (“green”) purchasing (EP) – EP can achieve a reduction in solid wastethrough the purchase of environmentally-friendly products and packaging.Reduction and Reuse of Visitor Waste – A first step toward reducing visitor generatedwaste is to reach out to visitors before they ever get to the park. Another way to limitvisitor-generated waste is to physically limit visitor opportunities to use materials and/orgenerate waste once in the park.Reduction and Reuse of Waste from NPS Operations – Park personnel conductactivities that involve the use of a variety of equipment, as well as construction,maintenance, and packaging materials. These activities provide many opportunities forsource reduction and reuse which can benefit park operations.Reduction and Reuse of Waste Generated in Employee Housing – Parks developingsource reduction plans or practices should not overlook the waste generated in employeehousing areas.Reduction and Reuse of Waste Generated by Partners – Since they will beinstrumental in helping parks manage visitor waste, it is important to ensure that all parkpartners are engaged in park planning and implementation of solid waste programs. Mostconcession contracts are now contain language that encourages environmental purchasingand reuse.Reduction and Reuse of Waste from Construction and Rehabilitation – The 2006NPS Management Policies require that all construction projects incorporate Leadership inEnergy and Environmental Design (LEED) standards; some projects must incorporateLEED standards to achieve a LEED “silver” rating.National Park Service - Solid Waste Management Quick Reference GuidePage 9
FOR MORE INFORMATION: Handbook, Section 6:http://pfmd.nps.gov/EMP/hazmat/EMP LIB/swhandbook/SWHandbook Sec6.htm NPS Environmental Purchasing Handbook:http://classicinside.nps.gov/documents/EP Handbook.pdf NPS Environmental Audit Guide, Appendix 14, EnviroCheck Sheet - EnvironmentalPurchasing: http://classicinside.nps.gov/documents/Final EAP Guide 2006.zip The NPS Integrated Pest Management Program website:http://inside.nps.gov/waso/waso.cfm?prg 706&lv 4 The Harpers Ferry Sign Management Program website - provides detailedinformation on the service wide Environmental Sign htm Pacific West Region green purchase guide on construction waste management:http://pfmd2.nps.gov/EMP/hazmat/EMP LIB/Documents/envrion purchase/ConstDemWasteMngmtFeb03.doc EPA Comprehensive Procurement Guideline website: www.epa.gov/cpg Whole Building Design Guide’s Federal Green Construction Guide:http://www.wbdg.org/design/greenspec.phpFor additional information specific to concessions operations: Concession Environmental Management Program (CoEMP) EnviroCheck Sheet Environmental /EnviroCheckSheetGreenProcurement.pdfNational Park Service - Solid Waste Management Quick Reference GuidePage 10
Chapter 8 - RecyclingThe U.S. Environmental Protection Agency (EPA) describes recycling as a series of activitiesthat includes: Collecting recyclable materials that would otherwise be considered waste;Sorting and processing recyclables into raw materials such as fibers; andManufacturing raw materials into new products.Recycling is the most common waste diversion practice at NPS facilities. Effective recyclingprograms require planning and preparation and an ongoing commitment to service, training, andeducation.Identifying Recycling Opportunities (Sources of Recyclable Materials)Generally, the best opportunities for recycling can be found at the park’s major solid wastegenerators. Major solid waste generators include, but are not limited to, visitors, park operations,park staff, and NPS partners.Key Design and Operating ConsiderationsThe steps for designing and operating a recycling program include identifying markets;determining which materials to include in the recycling program; selecting collection containers;operating a collection service for the containers; potentially performing storage, separation, andprocessing functions for the materials; and transporting materials to a recycling market fordonation or sale. When designing and operating a recycling program, some key considerationsare: Recycled materials markets are the foundation of a recycling program.Parks can continue to receive and use funds resulting from the sale of materials recoveredthrough recycling or waste prevention programs.Recycling containers are required for any new or expanded recycling program.The collection vehicles and approach used should be designed to work with the type ofrecycling containers used and could be manual or semi-automated collection.In-park processing includes sorting to separate materials and remove contaminants andbaling or compacting recyclable materials to reduce volume (for storage or transport),processing to meet end-market specifications, or processing for in-park use.Other Recycling Program ConsiderationsThe following should also be taken into consideration in order to develop a sound recyclingprogram: Recycling programs for visitor-generated materials should focus on recycling at visitorcenters, public areas, parking areas, day use areas, and campgrounds. Recycling programs covering park operations can include recycling for maintenanceoperations and recycling at administrative and office areas. Recycling at employee housing can be accomplished with drop-off or curbside collection.National Park Service - Solid Waste Management Quick Reference GuidePage 11
Concession contracts specifically state that concessioners are to maximize solid wastereduction activities, in part through recycling. See Appendix B for sample concessioncontract language. Recyclable materials can be transported directly to a market or a recyclables processor, ortemporarily stored in an interim location in the park to allow transportation of largerquantities on a less frequent basis.FOR MORE INFORMATION: Handbook, Section 7:http://pfmd.nps.gov/EMP/hazmat/EMP LIB/swhandbook/SWHandbook Sec7.htm NPS Environmental Audit Guide, Appendix 14, EnviroCheck Sheets - Solid WasteManagement and Universal Waste Final EAP Guide 2006.zipFor additional information specific to concessions operations: CoEMP EnviroCheck Sheet - Solid Waste /EnviroCheckSheetSolidWasteManagement.pdf CoEMP EnviroCheck Sheet - Universal roCheckSheetuniversalwasteManagement.pdfNational Park Service - Solid Waste Management Quick Reference GuidePage 12
Chapter 9 - CompostingOne of the best ways of reducing the volume of solid waste is by composting organic materials.Composting is a process of accelerated biodegradation and stabilization of organic materialunder controlled conditions. Common composting programs include backyard composting ofresidential food waste, green waste composting programs (yard waste, brush, and wood chips),larger-scale in-vessel food waste composting, and municipal solid waste composting.Composting toilets are a technology addressing septic waste, which is not included in thedefinition of solid waste.Composting Regulati
Oct 01, 2007 · Recovery Act (RCRA). Under Subtitle D of RCRA, states are encouraged to develop comprehensive plans for the management of non-hazardous industrial solid waste and municipal solid waste (MSW). Subtitle D also sets criteria for MSW landfills and other solid waste disposal facilities, and prohibits the open dump
3. Urban waste generation by income level and year 12 4. Waste collection rates by income 15 5. Waste collection rates by region 15 6. Waste composition in China 17 7. Global solid waste composition 17 8. Waste composition by income 19 9. Solid waste composition by income and year 20 10. Waste composition by region 21 11. Total MSW disposed of .
Integrated Solid Waste Management Generation-Source Perspective Residential Collection of Waste Segregation of Waste Recycling waste (organic & inorganic) Waste Exchange Discarded waste Treatment Recovery Final waste Final disposal Hazardous Waste for Treatment & Disposal 3R Services (Healthcare, Laboratory, etc.) Industrial &
state or federal solid waste regulations, just to RCRA Subtitle C (Hazardous Waste). 2. DEFINITION OF HAZARDOUS WASTE 40 CFR 261.3(a) – definition of hazardous waste: (a) A solid waste, as defined in §261.2, is a hazardous waste if: (1) It i
of solid waste generated across the entire city's solid waste stream. Citywide solid waste includes all solid waste which the District of Columbia generates including waste derived from residential and non-residential (commercial) sectors. This data and estimated metrics were made possible by the Waste Characterization Study (2021).
Minnesota's Waste Management Act has been in place since 1980 and establishes criteria for the management of three types of solid waste - mixed municipal solid waste (MMSW), construction and demolition wastes (C&D), and industrial solid waste (ISW). The waste management hierarchy establishes preferred management methods based on environmental
2.1.3 Solid Waste Management in Malaysia In Malaysia, the Solid Waste Department of the Ministry of Housing and Local Government (MHLG) is the authorized body to manage issues regarding solid waste management. Below is the 6-step process of solid waste management in Malaysia (Figure 2.1):
Categories of solid waste . Solid wastes are all materials arising from human activities that are normally solid and are discarded as unwanted. Solid waste can be categorized based on source as shown in table no. 1. Table no. 1: Solid Waste categories based on source Source Typical facilities, activities,or locations where wastes are generated .
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