HomeMy WebLinkAboutCC Resolution 8513 (Hazardous Waste Management Plan)RESOLUTION NO. 8513
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN RAFAEL, COUN'T'Y
OF MARIN, STATE OF CALIFORNIA, REGARDING REVISIONS TO THE
COUNTY HAZARDOUS WASTE MANAGEMENT PLAN.
WHEREAS, the County of Marin and each of its cities approved the Marin County
Hazardous Waste Management Plan (Plan) in 1989 and submitted it to the
California Department of Health Services (DHS) for approval; and
WHEREAS, the DHS disapproved the Plan, and subsequent legislation provided for
revising and resubmitting said plans for State approval; and
WHEREAS, the attached, proposed revisions are supported by regional DHS staff,
the County Waste Management Advisory Committee, and Board of Supervisors;
and
WHEREAS, the County's Environmental Coordinator has determined that the
proposed revisions are categorically exempt from the requirements of the California
Environmental Quality Act per Section 15162;
NOW, THEREFORE BE IT RESOLVED that the San Rafael City Council approves
the attached revisions to the Marin County Hazardous Waste Management Plan
and recommends that the County Board of Supervisors submit them to the State for
approval.
I, JEANNE M. LEONCINI, Clerk of the City of San Rafael, hereby certify that the
foregoing resolution was duly and regularly introduced and adopted at a REGULAR
meeting of the City Council of said City held on MONDAY, the 16TH
day of SEPTEMBER , 1991, by the following vote, to wit:
AYES: COUNCILMEMBERS: Boro, Shippey, Thayer & Vice Mayor Breiner
NOES: COUNCILMEMBERS: None
ABSENT: COUNCIL1V,MMBERS: Mayor Mulryan
JEATkT E M. LEONC T, City Clerk
Attachment A
PROPOSED REVISIONS TO THE
MARIN COUNTY HAZARDOUS WASTE MANAGEMENT PLAN
June 24, 1991
Proposed revisions to the County Hazardous Waste Management Plan (Plan or
CHWMP) are presented in the following four sections: A.) Fair -share, B.) Siting and
Permitting Process, C.) Siting Criteria, and D.) Mapping of General Areas.
References follow in Section E. Proposed revisions. to the Plan are noted as follows:
indented text = excerpt from original text;
underline = no change; original text was underlined;
stere-eu = deleted text; and
underline with Bold = added text.
A. FAIR -SHARE
The Plan encourages a regional, "fair -share" approach to hazardous waste management
and states that the county will participate in cooperative efforts with other jurisdictions.
The Plan refers to such inter urisdictional agreements in two places:. Policy HW -11 and
Siting Criterion I.A. Modifications to each are proposed below. The modifications
bring the Plan up-to-date regarding Bay Area inter -county agreements and clarify that
proposed facilities are to be consistent with the agreements that are in place when the
facilities are proposed.
Policy HW -11: (page 9-5). Siting Needed Facilities. Marin County and
its cities and towns will support efforts to site and develop facilities that
are needed faeilities to transfer, store, recycle, treat, or dispose of
hazardous wastes In siting these facilities,
Marin County and its cities and towns will participate in cooperative
efforts with jurisdictions within and beyond the county.
[Discussion.] As stated previously, Marin County and its cities and
towns will pursue waste minimization to the maximum extent practical in
order to reduce the need for new offsite hazardous waste management
facilities. Marin County and its cities and towns recognize their
responsibility to work with other governments in the region and the state
in planning for the effective management of hazardous waste generated
in the region and the state, in accordance with the hazardous waste
management hierarchy set forth in Policy No. HW -2.
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To this end, Marin County and its cities and towns encourage multi -
county and regional efforts to plan and implement alternatives to land
disposal of hazardous wastes and to limit the risks posed by
transportation of hazardous wastes around the state. Agreements for
new facilities to provide the offsite capacity needed for hazardous waste
treatment should be reached among jurisdictions according to their fair
share of the hazardous waste stream, each jurisdiction's environmental
suitability for different types of facilities, their economic interests, and
the economic viability of different types and sizes of facilities. Any
facilities ultimately located in Marin County should be designed to serve
generators from inside and outside Marin County, consistent with a
formal interiurisdictional ''agreement
Hefty.
II
In Mav 1990. Marin Countv entered into a Memorandum of
Understanding with the Association of Bav Area Governments and.
its member counties to develop and implement a method to allocate
the resnonsibility for providing hazardous waste'management based
Upon the fair -share principle. The MOU is attached as Appendix G
to this Plan. As stated in Chapter 7 of this Plan. proposed facilities
are to be consistent with interiurisdictional agreements in place at
the time.
Siting Criterion I.A. (page 7-7). Consistencv with Plan Goals and
Policies. All facilities shall be sited to be consistent with the goals and
policies of this Plan. In pce"w, Dnq pro
,,,,.,stem R,, w "fair shm" grin.
inter eeunty agfeeme an hares -d . and with
current interiurisdictional agreements for hazardous waste
management
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B. SITING AND PERNTITING PROCESS
Chapter 7 of the Plan describes the siting and permitting process for hazardous waste
management facilities, such as recycling, treatment, and disposal facilities. The
following additions clarify how the siting criteria, required project application
submittals, and facility performance standards work in concert. In addition, the
revisions proposed below reflect the recent work completed on the siting maps and note
the County's intent to designate general areas on the maps where the siting criteria
might be applicable.
A. INTRODUCTION
[Page 7-1, Paragraph 3] Section 25135.1(d)(6) of the California Health
and Safety Code mires states that the Plan is (a) to identify existing
hazardous waste facilities that can be expanded and general areas or
specific sites for new hazardous waste facilities, or ids (b to
include siting criteria to be used in selecting sites for new hazardous
waste facilities and to designate general areas where the criteria might be
applicable. Marin County believes that it is inappropriate to designate
general or specific areas for new hazardous waste facilities without
complete site information for the county. Therefore, sikg
been developed for use in evaluating petential sites a the time a pr-ej
eountywide; when the updated mirre ret
will be useful fer- identifying and evaluadng potential sites (See also
Seetien D ef this ehap". When this Plan is Fevised in 3 yeafs, the
seefien on available data and fnaps will be updated as paA ef thhee
f-evisien. Therefore this Pian includes siting criteria and mans that
indicate general areas where the siting criteria might be applicable.
This chanter also includes required hermit application submittals
and facilitv performance. Thev focus vrimarily on risk assessment
and facilitv design
The remainder of this chapter does the following:
o describes the facility siting, evaluation and permitting process
(Section B);
o presents the facility siting criteria (Section C);
o diseusses the fnapping presents the maps of general areas where
the siting criteria might be applicable (Section D);
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o describes the pr-ojeet f -Mew f-equifements,th
rea_uired Droiect annlication
submittals (Section E);
o describes the pr-ejeet facility performance standards which must
be met by any proposed hazardous waste management facility
(Section F);
o brieflv discusses onsite and mobile hazardous waste facilities
(Section G): and . -
0 outlines the stare process for annealing local permitting
decisions (Section I).
This chapter is designed to help the potential facility developer understand the
issues of concern in facility siting and design and the level of review and
evaluation required for any proposed hazardous waste management projects.
B. FACILITY SITING. EVALUATION, AND PERMITTING PROCESS
[Remainder of Section B remains unchanged.]
E. PROJECT REVIEW REQUIRFAIENTS
PROJECT APPLICATION SUBMI'T'TALS
[Remainder of Section E remains unchanged.]
F. "Dr�r FACILITY PERFORMANCE STANDARDS
[Remainder of Section F remains unchanged.]
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C. SITING CRITERIA
The Plan includes nineteen siting criteria for hazardous waste management facilities.
Only the criteria for which revisions are proposed are included in this section. The
DHS had also requested explanations for seven criteria, which address parklands and
open space, critical habitats, agricultural lands, mineral resources, cultural and
aesthetic areas, surface water resources, and floodplains. These explanations were
provided, to the satisfaction of the regional DHS staff.
1. Criterion I.A. Consistencv with Plan Goals and Policies (page 7-7).
Siting Criterion I.A. (page 7-7). Consistency with Plan Goals and
Policies. All facilities shall be sited to be consistent with the goals and
policies of this Plan. in Flo any proposed
eensistent with the "fair sha e"—pi-ineiple of equitable afle .,tion--ef4he
or. hfiwrdeus waste fnanageme and with
current interiurisdictional agreements for hazardous waste
management.
(As discussed under fair -share above.)
2. Criterion H.A. Pfexi itv to Distance From Residences (page 7-7).
Buffer zones or setback requirements for this criterion are defined as the
distance between the operational areas within the facility site where
hazardous wastes will be stored, transferred, treated, incinerated, or
disposed of (including equipment cleanup areas) and the nearest
permanent residence or area designated or zoned for residential use,
whichever is closer.
Incineration facilities and treatment, storage, or transfer facilities
handling ignitable, explosive, or reactive wastes must provide a
minimum buffer zone of at least 2,000 feet from the nearest residence,
unless the facility developer can demonstrate that a smaller buffer zone
provides adequate protection for the public in the event of an accident.
For other such facilities, including those for recycling, transfer or
storage of other types of hazardous waste, a buffer zone of at least 500
feet is required, unless the- developer can demonstrate that a smaller
buffer zone provides adequate protection for the public in the event of an
accident.
Additional setbacks may be required to maintain safe distances between a
transfer, storage, or treatment facility or incinerator and any existing
facility handling ignitable, explosive, or reactive materials or wastes.
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The size of the buffer zone shall be based on risk and environmental
assessments that consider the uhvsical and chemical characteristic$
of the specific types of wastes that will be handled. the design
features of the facility. and anv need for buffering residential or
other sensitive areas from adverse impacts.
No residuals repository shall be located such that the active portion of
the facility is within 2,000 feet of a permanent residence or any area
designated for residential use in the applicable general plan, unless the
facility developer proves to the satisfaction of the State Department of
Health Services that a buffer zone of less than 2000 feet is sufficient to
protect the present and future public health and safety [Health and Safety
Code, Section 25202.5(dee
The paragraph added above fulfills the DHS' request to more specifically refer to "risk
assessments".
3. Criterion II.B. Distance from Immobile Populations (page 7-8).
Larger buffer zones are may be required between any hazardous waste
facility and immobile populations such as hospitals, convalescent homes,
facilities for the mentally ill, schools, prisons and so on where
evacuation in the event of an accident at the facility is likely to be
difficult or inadvisable. This is especially true for facilities handling
ignitable, explosive, or reactive wastes. A minimum buffer zone of
5,000 feet between a facility and any immobile population is therefore
required, unless the developer can demonstrate that a smaller buffer zone
provides adequate protection for the immobile population in the event of
the maximum credible accident or fugitive emission incident. The size
of the buffer zone shall be based on risk and environmental
assessments. as described for the criterion above.
The modifications correct an inconsistency in the criterion and clarify that the size of
buffer zone will based on a risk assessment.
4. Criterion III.B. Safe Public Highway Access (page 7-8).
Residual repositories should have good access to major
transportation routes. but may have to be more distant from waste
generation sites than other tvm of facilities because of their need
for larger land areas. All other tvves of facilities should be located
so as to minimize distances to maior transportation routes that are
Wined to accommodate heavy vehicles.
For all facilities. road networks leading to maior transportation
routes should not Dass through residential neighborhoods. should
minimize residential frontages in other areas. and should be
demonstrated to be safe with regard to road design and
construction. accident rates. excessive traffic. etc.
The DHS was concerned about the reference to "divided highways or freeways". The
replacement wording is from the DHS' Guidelines, and expresses the county's intent.
5. Criterion 111. C. Airport Zones (page 7-9).
No l"- ,
depaf4ur,e, er el e f a 7 -Mie c miles-aifpeft-. Hazardous
waste facility sites shall be consistent with the policies of the
"Airport Land Use Plan for Marin County Airport (Gnoss Field)".
Sites in the vicinity of other airports in the countv shall comDly with
federal. state. countv. and citv policies and ordinances re ardin
public safety and land use in the vicinity of airports.
The DHS requested more specificity regarding airports in Marin and a reference to
related land use plans. On June 10, 1991, the Airport Land Use Commission adopted
an Airport Land Use Plan (ALUP) for Marin County's airport, "Gnoss Field". The
ALUP is required under State law and provides land use policies for future
development in the vicinity of the airport. The ALUP designates safety zones in
accordance with state and federal regulations and describes appropriate land uses within
each zone. The ALUP states that all development is prohibited in some areas,
including "FAR Part 77 penetration areas and clear zones", and restricted in other
areas, including "FAR Part 77 non -penetration areas and approach zones" (Marin
County 1991).
6. Criterion N.A. Parklands and Open Space (page 7-9).
No treatment or recycling facility or residuals repository shall be located
in a national, state, regional, county, or city or town park, forest, or
monument; designated National Recreation or Wilderness Area, Wildlife
Refuge, or Wild and Scenic River; or other designated park or open
space identified in a coastal zone plan or applicable city, town, or county
general plan elemen.
Low-volume transfer or storage facilities may be allowed in such areas if
necessary to handle hazardous wastes generated by workers, visitors, or
residents in those areas.
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7. Criterion N.H. Groundwater Resources (page 7-11).
No residuals repository shall be located in any area known to be, or
suspected of to be supplying principal recharge to a fftajef regional
aquifer, „ •+�;� .,,e ,,,,,,a_nr a Vision -fid by Puffq)big-a Ol of
well field fer 90 days. Such areas may be defined and identified in
general, regional, or state plans. Residuals repositories must be located
in conformance with the California Code of Regulations, Title 23,
Chapter 3, Subchapter 15.
No transfer, storage, treatment, or recycling facilities shall be located in
aquifer recharge areas or in areas with permeable surficial soils unless
the facility developer can demonstrate adequate; protection through
properly designed, constructed, and maintained engineered spill
containment, inspection and monitoring measures, and other
environmental protection controls.
within ^ e- �r snion unlc
than an-effeeti•ro hydr .
No facilitv shall be located within a cone of depression created by
pumping a well or well field that is used for domestic. agricultural.
or other commercial nurooses. for 90 days. unless the facility,
developer can demonstrate than an effective hvdrog_eological barrier
to vertical flow exists.
The DHS questioned references to "cone of depression". Much of West Marin depends
on wells for both domestic and commercial (farm) use. The wells often draw from
small aquifers, not the "regional aquifers" mentioned above. Our technical consultants,
CH2M Hill, recommended that the county use cone of depression to identify and
protect these more localized water sources. The criterion has been reworded to indicate
that it is incumbent on the developer to demonstrate the feasibility of locating any
facility in such an area without substantially affecting local groundwater supplies.
8. Criterion V.C. Dam Failure Reed Inundation Areas (page 7-12).
No hazardous waste facility shall be located in areas below anv of the
countv's public dam structures (i.e., reservoir dam, debris basin) that
would be inundated by the flow of water created if the a dam structure
were to fail. These areas may be identified from dam failure inundation
maps from the State Office of Emergency Services, Marin Municipal
Water District. and North Marin Water District,.
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9. Criterion V.D. Soil Stabilitv (page 7-12).
No residual-r-epesitery facility shall be located in areas of potential
rapid geologic change, such as landslide, soil creep, earth flow, other
mass movement of earth material, subsidence, or liquefaction..-,
No tfansfer, storage, t, or zeo
sus unless the facility developer can demonstrate that adequate
containment structures and other engineering features are designed,
constructed and maintained to preclude failure resulting from such
changes.
DHS questioned the greater restriction "for residuals repositories. The County and its
cities maintain policies regarding soil stability and steep slopes. As the existing
policies will operate in tandem with these criteria, it is reasonable to place the burden
of proof with the developer regarding the technical feasibility of a residuals repository,
as well as for other types of facilities.
Wz
D. MAPPING OF GENERAL AREAS
Substantial revisions to the mapping section are suggested to reflect recent updates
made in the County mapping database. The section now includes a series of seven
maps that depict individual siting criteria and a composite map that shows "general
areas where the siting criteria might be applicable".
S
"
Jpter-mined to be needoe. L-. liati ef this faeflity and area identifleatien,
the-Rlw. my in
designate wcrecs ,here the erite. -may b-a-epplleable.
?,!aria -County bo'Uc�ica that the identifleatien ef "
hazudeus etc f--aili ' "
siste speeifie infeEmation. For- this f-easen, the County ehese te develop
siting efiter-ia to be used in seleefiiig sites for- new ha&-ffdeus w
€6ci1:tee nhz��tc�� rx.iused to -luAte-a -srtegt the time
peeped; &fj p-
the siting eri Eerie• fear appfeval.
Jaffa ".ghtb
sh xting-t- efien and tt,en
lI up cs- entially eaplE
at -j x9d its eities de net have eeunty wid
. er--n, w.d .-
•i.\-)ul
whi0h migkt be mapped a i .. A . ate for- hazardous waste faeffifies
based en the Counrj'o k ete-data might be able to aeeeffifn
mapped as appr-epfiate might pr-ev ate after- c and prejea
�erie�v-:
The-4&virtl YJ hi
—10—
The --iri eel hent nor -rim- 2948 for- mappi
demenstr-ate that the ef-itef-ia do net ufffeasenably eliminate an land in th-e
iii uxailW , for- all hazudeus waste faeilit
a IAP; LX;jral Ji
,
designated f indusWaluse n
Ohe Ceun y mid the des; -the ems
//:Irk L✓inaes:—
Some ef the omay b
• ,
for-
€aei4itie3 may nat bo pc«.,:ttea usej c.
exar-pxls, in Fiausalite— Hewevef, as in t}- ty.ting efitefiefl, eiti
or- the Ceunty n3ay modify . eml 111ans and zening to per -mit -a
use.
in amethef example, t rmpr, �n
westefa inizc.a ,
west-ef the -Maw-mea epAy low volume tFms€ef er--srtef-age
a -.,w t` a San Andreas
Faust; -agc r c iiastem ?,,Iar-ift (Siting C-fiter-ien V-A)-.--4)wraU, it
appeafs that thefe is better- petential fer- siting hazafdeus waste fheili
As neted abeve, Mafia County •risk
develepeEs in the pr -e 'ration p:-m�f a p2ojaet. Ren eythe a
pr-eeess and the siting efiter-ia in Ns Plan, tegether- with eNis"g Ce"
app-Ap&t .
- 11 -
moires 7-2 throu h 7- illustrate the application of the siting
criteria. Figures 7-2 through_7-7 plot individual. mappable criteria.
lure 7-8 is a composite of Figures 7-2 through 7-7. The figures
plot only the criteria that can be readily manned at this scale. In
particular. they outline industrial areas. maior transportation
routes. residential areas. parklands and open space. water district
lands, ggricultural preserve zones. mineral resource sites. airports*
seismic setback zones. and dams and dam failure inundation areas.
h ri9"m criteria. such as proximity to immobile populations.
hazardous waste generators. critical habitats. wetlands. cultural and
aesthetic areas. and surface and groundwater resources are best
determined from more detailed map_ s and studies and on-site
investigations.
As shown in the figures. residential. park. and agricultural preserve
lands cover substantial areas of the county. National. State_. and
County parklands alone cover about one-third of the county. The
industrial areas appear to be the most suitable areas in the county
for hazardous waste management facilities. Thev are generally close
to the maior transportation routes and to the commercial districts,
Due to the limited size of the industrial areas and their proximity to
residential areas. however. few appear suitable for large centralized
facilities. Thus, the siting criteria state that the County and cities
may modify theireng eral plans and zoning to permit a hazardous
waste facility in areas not currently designated for industrial use.
As noted above. the locations designated on the maps showeg neral
areas where siting criteria might be applicable. It is the
responsibility of the proiect applicant to demonstrate that the
proposed proiect meets all of the siting criteria. whether or not the
proposed site is within the areas designated on the maul. It is
possible that a particular site within the designated areas may not be
suitable based on other criteria. For example. the figures show
residential areas of the county. but do not show a buffer zone
around them. as this would be determined on a case-bv-case basis.
Conversely. it may be possible that a site outside of the general areas
may actually meet all of the siting criteria.
The County is in the process of updating the Marin Countywide
flan ander mart of this update. is develgning a comprehensive.
computer database for all lands in the county. including the cities
;and towns. The County 'and cities are working jointly on this new
effort. As the database becomes more complete. it will be helpful to
both facility develoners and local governments in evaluating
potential sites for hazardous waste facilities,
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Attachments:
Figure 7-2:
Industrial Areas and
Major Transportation Routes
Figure 7-3:
Residential Areas
Figure 7-4:
Parks, Open Space, and Water District Lands
Figure 7-5:
Agricultural Lands
Figure 7-6:
Mineral Resource Sites
Figure 7-7:
Airport Zones, Seismic Setback Zones, and
Dams and Dam Failure Inundation Areas
Figure 7-8:
Composite Map
SM: chwmp/rev 1
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E. REFERENCES
The following references will be added to the Plan.
Belvedere 1976. General Plan for the City of Belvedere. 1976.
Corte Madera 1975. General Plan for the Town of Corte Madera. 1975, with
amendments to 1981.
DHS 1987. California Department of Health Services (DHS), Toxic Substances
Control Division. Guidelines for the Preparation of Hazardous Waste Manaeement
Plans. June 30, 1987.
Fairfax. General Plan for the Town of Fairfax.
Larkspur 1988. General Plan for the City of Larkspur, 1973, with amendments to
1978; Larkspur City Code, Chapter 18.52; personal communications with Steve
Solomon, Director of Larkspur Planning Department, January 27 and March 10, 1988.
Marin County 1982. Marin County Planning Department. The Marin Countywide
Plan. April 1982. Marin County Code, Title 22. Personal communications with
Mark Riesenfeld, County Planning Director; Scott Hochstrasser, County Planner; and
Alice Miller, County Planner; January and March 1988.
Marin County 1988a. Marin County Planning Department. Environmental Hazards
Element Technical Report #1 (Floods): Flood Hazards: Existine_ Conditions and Recent_
Studies. Draft of February 1988.
Marin County 1988b. Marin County Planning Department. Environmental Ouality
Element Technical Report #2: Mineral Resource Preservation Sites in Marin County.
April 1988.
Marin County 1989. Marin County Planning Department. Environmental Ouality
Element Technical Report #3: Aericulture in Marin. Draft of June 1989.
Marin County 1991. Marin County Planning Department. Airoort Land Use Plan for
Marin County Airport (Gnoss Field). June 10, 1991.
Mill Valley 1989. 1989 Mill Valley General Plan. 1989.
Novato 1988. Zoning map as revised March 1983; personal communication with Mark
Westfall, Community Development Director, March 23, 1988.
Ross 1987. General Plan for the Town of Ross. 1974. Draft General Plan. December
1987.
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San Anselmo 1984. General Plan for the Town of San Anselmo. 1976, with
amendments of 1984.
San Rafael 1988. Citv of San Rafael General Plan 2000. Draft of January 1988.
Personal communication with Jean Freitas, San Rafael City Planner, March 8, 1988.
Sausalito 1988. General Plan Diagram, Part III (Summary Map), 1979, Draft
Marinship Specific Plan, December 1987; Sausalito Zoning Ordinance; personal
communication with Ken Curtis, Sausalito Planning Director, March 14, 1988.
Tiburon 1988. General Plan, Presentation Draft, September 1987. Personal
communication with Jack Lohman, Tiburon Planning Director,. January 20, 1988.
Note: Figures 7-2 through 7-8 were prepared by the Marin County Department of
General Services' Mapping Section.
SM:I/wst/chwmp/revl
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FIGURE 7-3:
RESIDENTIAL AREAS
RESIDENTIAL AREA
0 1 2 3 4 5
(Source, USGS Topographic Maps.)
(More detailed Maps of specific areas are available from County and city Planning Departments.)
MAY 2, 1991
r
0
FIGURE 7-4i
PARKS, UPEN SPACE, AND
WATER DISTRICT LANDS
MAJOR NATIONAL RECREATION AREAS,
SEASHORE AND WILDERNESS AREAS, STATE PARKS,
AND COUNTY AND CITY PARKS AND OPEN SPACE
fel
(Sources Marin County Parks and Open Space 1983,)
MAY 15, 1991
ill
FIGURE 7-5i
AGRICULTURAL LANDS
SCALE IN MILES
0
(Sources Marin County 1989,)
MAY 2, 1991
AGRICULTURAL PRESERVE ZONE
LANDS UNDER PRESERVE CONTRACT, 1988
FIGURE 7-6;
MINERAL RESOURCE SITES
UMINERAL RESOURCE SITE
(Sources Morin County 1988b.)
MAY 2, 1991
AIN
(Sourcest Marin County 1990, California Geologic Maps, Marin County 1988a,)
FIGURE 7-7:
AIRPORT ZONES, SEISMIC SETBACK ZONES,
AND DAM FAILURE INUNDATION AREAS
AIRPORT ZONE
MAY 2, 1991
FIGURE 7-8:
COMPOSITE MAP
AREAS IDENTIFIED IN FIGURES 7-2 TO 7-7
urom tigures /-if -unrougn t-/.)
MAY 15, 1991
NoMEL