HomeMy WebLinkAbout1988-04-26; City Council; 9404; Draft Hazardous Waste Master PlanClQOF CARLSBAD - AQENQBILL
AR* 9</oy
MTG 4/26/88
DEPT. U/M
TITLE:
PRESENTATION Or URAr 1 COUM 1 1 ilA^AKUUUo
WASTE MASTER PLAN
DEPT. HD./*^(
\i P-/^CITY ATTXJaU^J
CITY MGFF^T^00oo
o
CO
0)c
4-1c
oO
01
•rl
tU
4-1
4-1cd
O4-1
C
Cfl
i-Hp-
4J4-1
nj
O.•H
0)
'O0)M
cu
6013(LI
ocfl
•H
Oid
ou
oi_l
O
OO
RECOMMENDED ACTION:
Accept the Draft Plan for staff review and comment by June 30,
1988.
ITEM EXPLANATION:
In 1986, Assembly Bill 2948 (Tanner) was adopted by the
legislature and approved by the governor. Among other things,
the Tanner Bill authorized counties to prepare hazardous waste
management plans describing how all of the hazardous waste stream
can safely be managed within the county. Should a county elect
to prepare its own hazardous waste management plan an advisory
committee must be established to assist in the preparation of the
plan; the plan must include certain prescribed guidelines; the
plan must be approved by a majority of the cities representing a
majority of the population in each county and the plan must be
enforced by the county and each of the cities in the county.
The County of San Diego determined to prepare a hazardous waste
management plan and appointed an advisory committee to assist in
preparing the plan. The utilities and Maintenance Director
represents the City on the advisory committee.
The advisory committee has completed a draft Hazardous Waste
Management Plan and the Board of Supervisors has accepted the
draft plan for distribution to public and private agencies for
review and comment by June 30, 1988.
County staff will formally present the Plan to the Council
provide additional information about the Plan and the approval
process .
FISCAL IMPACT:
Staff time required to review and provide comments is unknown.
Costs incurred can be absorbed within existing budgets.
EXHIBITS;
1. Executive Summary of Draft Hazardous Waste Management Plan
of the County of San Diego.
Board of Supervisors
irl»« f. illbrir
Gcori* f. B*ll«y
SWIM Goldlnj
Leon L. Nttlitts
John MicOoiMld
District Dm
District T«o
District Three
District Four
District Five
Nomw w. Hicnr. CHIEF ADHIIHSTUTIVE OFFICER
1
HAZARDOUS WASTE MANAGEMENT PLAH
COUNTY OF SAN DIEGO
Prepared By
HAZARDOUS HASTE MANAGEMENT PROJECT STAFF
NORMAN U. MICKEY
Chief Administrative Officer
March 31, 1988
BT
CHAPTER I - EXECUTIVE SUMMARY
We live In a time of advanced technology and a high standard of living.
This industrial age has lent itself to a great dependence upon the
use of products containing chemical substances and/or requiring the
use of chemicals in their manufacture and packaging. While our quality
of life and economic stability may, in some sense, be dependent on
these products, we are, at the same time, threatened by the mismanagement
of their chemical remains or the hazardous waste generated.
The answer to the critical issue of hazardous waste management lies
in a comprehensive, cooperative planning effort among government,
industry, environmental organizations, and the public. Given this
planning arena, it is possible to remedy the past mismanagement of
hazardous waste by developing strategies to improve the capability
for the safe management of these chemical, by-'prpcfucts. Not only must
we move away from land disposal of Hazardous waste toward effective
treatment and disposal in way^-'xthat are'.safe to\ ^he environment and
to human health, but we must- also take a hard t^ok at reducing the
waste generated by fjpemxall segments of society— from large industry
to small business, fr^nv governments to households.' ' ' : '-San Diego toinrty is committed toward the development of solutions to
the complex\ issues of hazardous waste management. We are faced with
a problem that requires "extensive planning, cooperation and coordination
from all avenu.es. of our vital community. It is this planning partnership
that will ultimately ensure the productive economic growth of this
county, without threatening our quality of life, public health, and
the environment.
II. INTRODUCTION
PURPOSE
The San Diego County Hazardous Waste Management Plan is the primary
planning document providing the overall policy direction toward the
effective management of the County's hazardous waste. The plan
establishes programs to manage hazardous waste safely within the County
and is the guide for local decisions regarding hazardous waste issues.
LEGAL AUTHORITY
The plan was prepared pursuant to State Assembly Bill 2948 (Tanner,
1986) which authorizes local government to develop comprehensive
hazardous waste management plans, streamlines the permitting process
for hazardous waste treatment facilities, and prohibits the disposal
of untreated hazardous waste in landfills as of May 8, 1990.
1-1
o o
PLAN FORMAT AND CONTENT
The plan It organized into nine chapters. These address each of the
important components of a local hazardous waste management strategy,
including:
- a description of the hazardous materials and hazardous waste
regulatory framework
- an analysis of the hazardous waste produced in the county
- the potential for source reduction and recycling
- the type and capacity of existing facilities
- the need for additional treatment facilities
X>- criteria for siting needed facilities,,
,- recommendations, policies and 'implementation strategies
\ \ , \ \PLAN DEVELOPMENT AND ADOPTION PROCESS \V\ \\ '• " \The plan has been developed \foic adopt ftyp and implementation by the
County of San Diego and. the eighteen (18; incorporated cities in the
county. ."* . - - :" O
The plan was developed by the staff of the County Environmental Health
Services and' the San Diega. Association of Governments. A 31 member
Advisory Committee, appointed by the Board of Supervisors, provided
plan oversight \and po-1 icy direction.
The law requires .that the plan be adopted by the Board of Supervisors
and by 50% of the cities representing 50% of the population in the
incorporated areas of the county. The final plan must also be approved
by the State Department of Health Services. An Environmental Impact
Report on the plan will be prepared in compliance with the California
Environmental Quality Act (CEQA). In addition, the plan will be used
in the development of the regional plan for Southern California, as
well as the statewide plan for California.
III. GENERAL BACKGROUND INFORMATION
HISTORY OF THE HAZARDOUS WASTE DISPOSAL PROBLEM
Historically, the majority of hazardous waste generated in San Diego
County has been disposed of directly in land disposal facilities.
Presently, there are no hazardous waste landfills in Southern California.
This land disposal crisis along with associated environmental and public
health concerns pointed to the need to explore alternative solutions
to this traditional reliance on land disposal. These solutions focus
on a hierarchy of management approaches to reduce the wastes generated
or to treat hazardous waste produced rather than to simply bury them.
1-2
'***%
HAZARDOUS HASTE CHARACTERISTICS
Hazardous waste is any waste material that has the potential to damage
human health or the environment. A vast array of consumer goods such
as televisions, computers, automobiles, and medicines, generate hazardous
waste. Hazardous waste may be toxic, corrosive, reactive, and/or
flammable. The risk posed by a particular waste depends on its chemical
composition, physical state, concentration, its availability for exposure
to people and the environment, and the manner in which it is handled
and managed.
HAZARDOUS WASTE MANAGEMENT METHODOLOGIES
Hazardous waste should be managed following a hierarchy of preferred
alternatives. The first priority is the reduction of the hazardous
waste at the source, because it eliminates or mijwinizes the problem
and risk and avoids the need for further handling^ On^site and off-site
recycling, recovery and reuse is the next.^priority\ \This is followed
by on-site and off-site treatment of hazardous Wastes. Treatment
techniques can physically or chemically alte.p-.the wastes to eliminate
or diminish their hazardous properties, and often redufcp>their volumes.
Finally, land disposal facilities will continue to be necessary for
the management of residuals produced by these treatment technologies.
HAZARDOUS WASTrFACILITIES '
Hazardous waste", treatment methods fall within six basic types of
hazardous waste facilities, each of which can include a number of
specific treatment".methods. These six types are:
- Transfer and Storage Facilities
- Recycling Facilities
- Aqueous Treatment Facilities
- Solidification or Stabilization Facilities
- Incineration Facilities
- Residuals Repositories
LEGISLATIVE HISTORY
Hazardous waste management is a heavily regulated field. The primary
statutes regulating hazardous waste handling and disposal are the Federal
Resource Conservation and Recovery Act (RCRA) and the State Hazardous
Waste Control Act (Health and Safety Code, Chapter 6.5). The RCRA
regulations provide definitions of hazardous waste and requirements
for storage, transportation, "cradle to grave" management, and hazardous
waste facilities. Chapter 6.5 establishes the minimum standards and
regulations for hazardous waste handling, processing, and disposal.
This regulatory framework is constantly changing as the number of state
and federal regulations increases.
1-3
o o
IV. EXISTING MANAGEMENT SYSTEM
Although a number of agencies enforce hazardous materials and waste
management .regulations, San Diego County has a centralized program
that takes a systematic approach to hazardous materials management.
This program is administered by the San Diego County Department of
Health Services' Hazardous Materials Management Division (HMMD). Created
in 1981, HMMD administers a comprehensive program which includes elements
in hazardous waste, hazardous materials, underground storage tanks,
emergency response, and planning.
The Hazardous Materials Management Division is organized to contain
the following program elements:
- inspection and enforcement activities^ related to federal,
state and local regulations ,-'\
<,,\- hazardous waste and hazardous materials .disclosurex > \ \;. .•' X. \- inspection and enforcement df " yndergrouhriX storage tank laws
and regulations t,x\ \ •'
\ ... >s ''••• ^
- hazardous materials emergency response capability and complaint
response ,*-^"\
- abandoned hazardous waste disposal site investigations~ '- household hazardous waste
\ •- '•• '.
- governmental agency coordination activities
POLICIES
There is little disagreement that a comprehensive hazardous waste
management program is the most efficient mechanism in addressing
hazardous materials and hazardous waste issues. The plan recommends
that HMMD continue its aggressive approach to these problems and expand
or improve activities. The policies for this chapter are:
IV-A. New Businesses Generating Hazardous Waste
ENSURE THAT NEW AND PROPOSED BUSINESSES USING HAZARDOUS
MATERIALS AND GENERATING HAZARDOUS HASTES ARE SCREENED
BY CITY AND COUNTY AGENCIES.
IV-B. Hazardous Haste Data Management System
ENSURE THAT COMPLETE AND ACCURATE INFORMATION IS AVAILABLE
ON ALL HAZARDOUS HASTE GENERATED, HANDLED, STORED,
TREATED, TRANSPORTED AND DISPOSED OF IN SAN DIEGO COUNTY.
1-4
c
Technical Assistance to Industry
;; ENSURE THAT INDUSTRY IS ABLE TO ASSUME GREATER
" RESPONSIBILITY FOR HAZARDOUS HASTE MANAGEMENT BY PROVIDING
A TECHNICAL ASSISTANCE PROGRAM ENCOMPASSING ALL ASPECTS
OF HAZARDOUS HASTE MANAGEMENT.
IV-D. Contaminated Hazardous Waste Sites
ENSURE TIMELY AND COMPLETE CLEANUP OF CONTAMINATED
HAZARDOUS HASTE SITES IN SAN DIEGO COUNTY.
IV-E. Household Hazardous Waste
ENCOURAGE REDUCTION OF HOUSEHOLD HAZARDOUS HASTE
GENERATION BY PROMOTING SAFE SUBSTITUTES AND RECYCLING
THROUGH COMMUNITY EDUCATION TO ALL RESIDENTS OF SAN
DIEGO. >*-.
-•' <*
ENCOURAGE THE SAFE DISPOSAL OF HOUSEHOLD HAZARDOUS HASTE
BY PROVIDING CONVENIENT .DISPOSALv ALTERNATIVES TO ALL
RESIDENTS IN SAN DIEGO. \\
V. HAZARDOUS HASTE MINIMIZATION
VWaste minimization " is the first priority in the hazardous waste
management hierarchy! Reduction in the generation of hazardous waste
will in turn" reduce the need for treatment, storage, and disposal of
hazardous waste A Waste minimization techniques focus on source reduction
and recycling activities that reduce the volume or toxicity of the
waste. Generally, waste minimization techniques can be grouped into
four categories:
1. Inventory management and improved operations
2. Modification of equipment
3. Production process changes, and
4. Recycling and reuse
The County Hazardous Materials Management Division has developed an
outreach program for industry that focuses on hazardous waste
minimization education and technical assistance. This program, Promote
Landfill Alternatives Now (P.L.A.N.), is designed as a cooperative
effort between government and industry and will have a positive impact
on reducing the volume of hazardous waste produced in San Diego County.
It is projected that through an aggressive implementation program,
up to 75% of the generated waste could be recycled, if efficient waste
segregation is accomplished, and that 30% could be eliminated if
efficient waste minimization techniques are employed. These waste
reduction activities could have a significant impact on facility siting
needs.
1-5
POLICIES
The County oust continue its efforts in promoting hazardous waste
minimizaticifr,' This commitment to reduce the generation of hazardous
waste in San Diego will be facilitated by the following policies:
V-A. Promote Waste Minimization
ENCOURAGE INDUSTRY TO REDUCE ITS HAZARDOUS HASTE BY A
COUNTYWIDE GOAL OF 301 WITHIN THE NEXT FIVE YEARS BY
PROMOTING HASTE MINIMIZATION AS THE FIRST PRIORITY IN
THE HAZARDOUS HASTE MANAGEMENT HIERARCHY.
V-B. Hazardous Waste Minimization Opportunity Assessments
ENCOURAGE INDUSTRY TO CONDUCT HASTE MINIMIZATION
OPPORTUNITY ASSESSMENTS TO DETERMINE . THEIR POTENTIAL
FOR SOURCE REDUCTION AND RECYCLING.\ s
V-C. Incentives for Waste Minimization. \ \' ; v'
ESTABLISH A REWARD PROGRAM TO RECOGNIZE INDUSTRIES THAT
IMPLEMENT HASTE MINIMIZATION SUCCESSFULLY.
V-D. Annual Waste Minimization Report
PREPARE AN ANNUAL REPORT ON THE PROGRESS OF HASTE
MINIMIZATION IN THE COUNTY.
' V
V-E. Financial and Technical Assistance for Waste Minimization
ENSURE THAT FINANCIAL AND TECHNICAL ASSISTANCE PROGRAMS
ARE AVAILABLE FOR HAZARDOUS HASTE MINIMIZATION PROJECTS.
VI. CURRENT HASTE GENERATION AND FACILITY NEEDS
In order to make realistic decisions regarding the management of
hazardous waste, an accurate analysis of the scope of the problem needed
to be conducted. An extensive data analysis produced a complete picture
of the problem, taking into consideration the special situations faced
by the County.
In 1986, San Diego County generated 93,100 tons of hazardous waste
that went off-site for treatment or disposal. The corresponding volume
in each of the Generalized Treatment Methods (GTM) is as follows:
1-6
Generalized Treatment Method Total Tons %
Oil Recowlfy 47,000 50%
Stabilization 26,000 28%
Aqueous Treatment with Metals 10,000 11%
Solvent Recovery 5,200 6%
Incineration 3,700 4%
Aqueous Treatment with Organics 700 1%
Other Recycling 500 1%
93,100 100%
Of the total volume, 44% is generated within San Diego City, and 23%
is generated by the Navy jit Naval facilities.
San Diego's Treatment, Storage, and Disposal Facilities currently provide
industry with a total treatment capacity^-o'f3l22,700 tons per year.
The largest capacity is found in the OilYWafrer Separation technology,
followed by Aqueous Treatment of Orgarfffcs, and1..Stabilization.
*- '*" -i *.
'*• '"Given our current hazardotrsN, waste generation volumes and treatment
capability, it can be concluded that, if we were to manage all our
hazardous waste wtttrtn the borders of the county, the facility surplus
and shortfall would be as follows:
•;Shortfal1 Capacity Surplus Capacity
Incineration Aqueous Treatment/Metals
Oil Recovery Aqueous Treatment/Organics
Stabilization Oil/Mater Separation
POLICIES.
In developing the waste generation information in this chapter, it
was revealed that San Diego County military installations are pursuing
innovative techniques for managing hazardous wastes. It was recognized
that enhanced opportunities for information sharing would benefit both
the military and the Hazardous Materials Management Division. The
policy for this chapter is:
VI-A. Hazardous Materials Management Divsion and the Military
ENHANCE THE RELATIONSHIP BETWEEN THE HAZARDOUS MATERIALS
MANAGEMENT DIVSION AND THE REGION'S MILITARY IN AREAS
OF COMMON CONCERN.
VII. PROJECTED HAZARDOUS WASTE GENERATION AND FACILITY NEEDS
Projecting the hazardous waste generation and facility needs to the
year 2000 is a complex task. The number of variables and the projection
methodology are, of course, static and are to be used for planning
purposes only. However, forecasting models have provided an excellent
tool for decision makers to realistically shape the future of hazardous
waste management policies.
1-7
o
A total volume of 133,900 tons of hazardous waste is expected to be
produced 111 the year 2000. Based on the total treatment capacity
expected tot: be available in the year 2000 the facility shortfall and
surplus capacity would be as follows:
Shortfall Capacity Surplus Capacity
Solvent Recovery Aqueous Treatment/Metals
Oil Recycling Aqueous Treatment/Organic
Stabilization Oil/Water Separation
Incineration
Other Recycling
Of the treatment technologies for which there is a projected shortfall,
only the Oil Recycling and Stabilization volumes are great enough to
make San Diego-based facilities economical based on the San Diego
wastestream alone. \ \
- • V\ \
POLICIES • ..--'
*'\ • • ' " "•Projecting future need is a valuable activity critica-T for providing
a systematic approach to ...the hazardous waste problem. This chapter
makes significant conclus"Fons\that focus on the following policies:
S \ " V
VII-Av Residual Repositories
\ ENSURE THAT ADEQUATE FACILITIES ARE AVAILABLE TO
DISPOSE OF HAZARDOUS WASTE AND TREATMENT RESIDUALS.
VII-B. Fuel Contaminated Soil
ENCOURAGE THE APPLICATION OF ON-SITE TREATMENT
TECHNOLOGIES TO SOILS CONTAMINATED FROM LEAKING
UNDERGROUND STORAGE TANKS.
VII-C. Updates of Hazardous Waste Information
PROVIDE ANNUAL OR SEMI-ANNUAL UPDATES OF HAZARDOUS
HASTE GENERATION INFORMATION AND FACILITY NEEDS.
VIII. SITING AND PERMITTING OF HAZARDOUS HASTE FACILITIES
Siting hazardous waste treatment facilities is a public process that
must weigh economic with health and environmental concerns. The siting/
permitting process outlined in this Chapter provides numerous
opportunities for public input. Public participation and full disclosure
are balanced in this strategy with the authority and responsibility
of local government to meet the environmental, public health and economic
needs of its citizenry.
Siting criteria have been developed to assess the appropriateness of
a site or area for a hazardous waste facility. These criteria are
1-8
designed to reduce the possible environmental or public health risks
associated with the development of a facility. The objectives of these
criteria art to:
- Protect the health and safety of the residents of San Diego
County
- Ensure the structural stability of the facility
- Protect surface water quality
- Protect groundwater quality
- Protect environmentally sensitive areas
- Ensure safe transportation of hazardous waste
- Protect the social and economic development goals of the
county , '.; s \
\ \
A summary of these siting criteria are found in TaVe, 1-1.
f' . ' V^
POLICIES \ \ \ , ''\
.S*~\ \ V-- \ ""''The siting and permitting prpce^s^ for hazardous waste treatment
facilities j>-a dynamic planniitg^to'61 that can establish the direction
of hazardtfus^waste management "alternatives. The policies for this
strategy are as\fbjlowsv \ V*
\ \ \ \ \>
VIIVX) Jlncinerable Wastes
ENCOURAGE THE USE OF PREFERRED ALTERNATE MANAGEMENT
TECHNIQUES FOR SPECIFIC HAZARDOUS UASTESTREAMS
THAT HAVE INCINERATION AS THE PRIMARY TREATMENT
TREATMENT TECHNOLOGY.
VIII-B. Siting Criteria for Off-Site. Hazardous Waste Treatment
Facilities
ENSURE THE PROTECTION OF RESIDENTS OF SAN DIEGO
COUNTY FROM RISKS ASSOCIATED WITH OFF-SITE HAZARDOUS
HASTE TREATMENT FACILITIES.
VIII-C. Conditional Use Permit for Off-Site Treatment
Facilities
ENSURE THAT OFF-SITE HAZARDOUS WASTE TREATMENT
FACILITIES ARE SUBJECT TO COMPLETE LOCAL REVIEW.
VIII-D. Conditional Use Permit for On-Site Treatment
Facilities
ENSURE THAT ON-SITE HAZARDOUS WASTE TREATMENT
FACILITIES ARE SUBJECT TO FULL LOCAL REVIEW.
1-9
7
TABLE 1-1 SUMMARY OF
HAZARDOUS HASTE FACILITY SITING CRITERIA IN SAN DIEGO COUNTY
I
»—«o
Protect the Residents of San Diego
SITING FACTOR
Proximity to Populations
•roximlty to Immobile Population
[Hospitals, convalescent homes,
prisons, childcare facilities,and K-12 schools)
Capability of Emergency Service
Ensure the Structural Stability
of the Facility
Proximity to Active or Potentially
Active Fault
SITING CRITERIA
Hazardous Haste Facilities Residuals Repository
\ •:
If handling Ignltable, volatile or reac
wastes, should be" .2000 fee^ unless candemonstrate piibllc^s protected.
I<\ ha/idling Ignltable, volatile or reactive
wastes within one mtle, risk assessment
should be dope.
Locate where fire department Is trained
'for hazardous material accidents, mutual
aid agreements In place, and response
time meets NFPA recommendations. Hay requireadditional design features or on-site
emergency services.
2000 feet from nearest residence
and areas designated for future
residential use In local general
plans.
If handling Ignltable. volatile
or reactive wastes within onemile, risk assessment should be
done.
Locate where fire department is
trained for hazardous material
accidents, mutual aid agreements
place, and response time meets
NFPA recommendations. May
require additional design
features or on-site emergency
services.
In
200 feet from a known active fault 200 feet from a known active fault
*Th1s Is a condensed summary of the siting criteria. For a complete discussion, refer to Appendix VIII-A of the San Diego County
Hazardous Waste Management Plan, 1988.
o
o
SITING FACTOR
SITING CRITERIA
Hazardous Haste Facilities Residuals Repositories
Ensure the Structural Stability
of the Facility (continued)
Flood Hazard Areas
Areas Subject to Tsunamis,
Seiches, and Storm Surges
Dam Failure Inundation Areas
Slope Stability
Subs1dence/L1qu1faction
Aqueducts and Reservoirs
Discharge of Treated Effluent
Should avoid, unless designed to
prevent Inundation
Should avoid unless constructed to
preclude failure
Should avoid
Should avoid such areas unless vengineered to preclude.failure
\
Should avoid such areas unless
engineered to preclude failure
V \. • •
Locate so as to minimize threats to.drinking water
\ • ' ' .
\ If generating wastewater. should
\be located In areas with adequatesewer capacity.
Prohibited 1n areas subject to
100 year flood
Prohibited
\ Should avoid
\ \
I •
\ \\ \
\ Prohibited 1n areas of potential
\rapid geologic change
Prohibited In areas of potential
rapid geologic change
Locate so as to minimize threats
to drinking water
If generating wastewater, should
be located In areas with adequatesewer capacity.
o
CD
no
3Ctt>
O.
OProtect Broundwater
Proximity to Supply Wells
State Water Resources Control Board
and Department of Health Services
require severe restriction and
monitoring of vertical and lateralmovement of liquids In a repository,
Including the standards for location
and design.
Locate outside cone of depressionof wells and well fields.I
*Th1s 1s a condensed summary of the siting criteria. For a complete discussion, refer to Appendix VIII-A of the San Diego County
Hazardous Waste Management Plan, 1988.
SITING FACTOR
SITING CRITERIA
Hazardous Haste Facilities Residuals Repository
Protect Groundwater (continued)
Depth to Groundwater
Groundwater Monitoring
Major Aquifer Recharge Areas
Permeability of Surfldal Materials
Existing Groundwater Quality
Foundation design to preclude
failure due to high water
conditions.
Monitoring required of facilities
.handling liquids.
At least % mile from potential
drinking water supply If
subsurface treatment or storage.
Others, supply Increased spillcontainment and Inspection.
>/ v
If located on highly perineablematerialsl(:pro'vide Increased
spill containment and Inspection.
\ Increased spill containment and
^1 inspection In high groundwater
quality areas.
State Water Resources Control Board
and Department of Health Services
require severe restriction and
monitoring of vertical and lateral
movement of liquids '.n a repository,
Including the standards for locationand design.O
oo
oo
3CIPO.
Air Quality
Risk analysis for any type of facility should address both toxic and non-toxicemissions Issues.
Protect Environmentally Sensitive Areas
Wetlands
Endangered Species Habitats
Should avoid
Should avoid
Should avoid
Should avoid
*TMs Is a condensed summary of the siting criteria. For a complete discussion, refer to Appendix VIII-A of the San Diego County
Hazardous Waste Management Plan. 1988.
SITING FACTOR
SITING CRITERIA
Hazardous Haste Facilities Residuals Repository
Protect Environmentally Sensitive
Areas (continued)
Natural, Recreational, Aesthetic
Resources
Prime Agricultural Lands
Mineral Deposits
Public Facilities/Military Reservations
Safe Transportation of Hazardous Haste
Proximity to Areas of Waste Generation -'
Distance from a Major Route
Structures Fronting Minor Routes
Highway Accident Rate
Capacity Versus Average Annual Dally
Traffic (AADT) of Access Roads
Should avoid
Should avoid
Should not preclude extraction
Should avoid
Should avoid
Should not preclude extraction
DOD policy to avoid siting all facilities'on'military lands. Siting on acase-by-case basis could be considered In Special circumstances. Case-by-caseconsideration for, o£her public facilities.
One-way transportation should not
exceed one day, mostly on major
routes.
Minimize distance traveled on
minor roads.
VShould minimize travel time
Locate near an exit of a major route
or routes used locally for truck traffic
Minimize home, hospitals and school on route. Evaluate population at risk.
Minimize exposure to traffic and accidents.
Facility developer may upgrade the road(s) to provide additional capacity.
o
OO
n>
Q.
O
*Th1s 1s a condensed summary of the siting criteria. For a complete discussion, refer to Appendix VIII-A of the San Diego County
Hazardous Waste Management Plan, 1988.
SITING FACTOR
SITING CRITERIA
Hazardous Haste Facilities Residuals Repository
Protect Social and Economic Goals
Consistency with the General Plan
Changes 1n Real Property Values
Direct Revenue to Local Jurisdictions
Changes 1n Employment
All facilities should be located in areas consistent with the General Plan.
If these social/econojntc Issues etye\ge, the applicant should finance a study to
evaluate each issue.
03
OO
*Th1s Is a condensed summary
Hazardous Waste Management Plan,
•' •.\\\*^
of the Citing criteria.*, nor a complete
an, 19§8% \ \ ^
discussion, refer to Appendix VIII-A of the San Diego County
CDQ.
O
t- *••
'
IX. GOALS. POLICIES AND IMPLEMENTATION STRATEGY
This charier of the Plan focuses on the necessary implementation
activitiai>' that will ensure that the Plan is a workable document for
the citie* and the County of San Diego. It includes a summary of the
overall policy direction for hazardous waste management activities
in San Diego County. It also proposes an implementation strategy to
accomplish these policies, as well as identifying responsible agencies
and funding sources.
The overall goal of the Hazardous Waste Management Plan is:
TO ESTABLISH A SYSTEM FOR MANAGING HAZARDOUS MATERIALS, INCLUDING
WASTES, TO PROTECT PUBLIC HEALTH, SAFETY AND WELFARE, CONSISTENT
WITH THE ECONOMIC VIABILITY OF SAN DIEGO COUNTY.
This goal can be accomplished through a series of policies and
implementing actions that focus on the safe management of hazardous
waste in San Diego. These policies were developed and discussed fully
in their chapters of origination, and have been grouped into five areas.
'''"• \Comprehensive Hazardous Waste Management System .. \
Goal; TO DEVELOP A COMPREHENSIVE PROGRAM F6R\THE SAFE MANAGEMENT
OF ALL HAZARDOUS WASTES IN SAN DIEGO COUNTY.
Policies: IV-A. New Businesses Generating Hazardous Waste
IV-B^ Data Management System
IV-C. Technical, Assistance to Industry
IV-E. Household-'Hazardous Wastes
VI-A. HMMB,and the Military
•»'*'
Hazardous Waste Minimization
Goal: TO ENCOURAGE INDUSTRY TO INCORPORATE THE PROPER HIERARCHY
OF WASTE MANAGEMENT ALTERNATIVES THAT WILL REDUCE THE
GENERATION OF HAZARDOUS WASTE DISCHARGED TO THE ENVIRONMENT.
Policies: V-A. Promote Waste Minimization
V-B. Hazardous Waste Minimization Opportunity
Assessments
V-C. Incentives for Waste Minimization
V-D. Annual Waste Minimization Report
V-E. Financial and Technical Assistance for Waste
Minimization
1-15
Siting and Permitting of Hazardous Haste Facilities
Goal: T0 ACCELERATE THE SITING AND PERMITTING OF HAZARDOUS WASTE
v||CILITIES.>* ,*- f
Policies?!!? VII-C. Updates on Hazardous Waste Information
"' VIII-B. Siting Criteria for Off-Site Hazardous Waste
Treatment Facilities
VIII-C. Conditional Use Permit for Off-Site Treatment
Facilities
VIII-D. Conditional Use Permit for On-Site Treatment
Facilities
Targeted Hazardous Wastes .."
Goal: TO ENSURE THAT AN ACCURATE xA^SESSifl IS MADE OF THE NEED
FOR RESIDUALS REPOSITORIES^ AND INCINERATION FACILITIES, AND
THAT CONTAMINATED SITES ARE "CLEANED-UP ftf 'A TIMELY MANNER.
X\ \ •? V>
Policies: IV-D. Contaminated Hazardous Waste Sites
VII-B. ^ Fuel Contaminated>.,Soil
VIII-A'. Reduce Incinerable Wastes
VII-A. Residual Repositories
Hazardous Haste Management Plan Implementation
Goal: TO ENSURE THAT THE SAN DIEGO COUNTY HAZARDOUS WASTE MANAGEMENT
PLAN IS ACCURATE AND UP-TO-DATE.
<*
Policies: IX-A. Plan Adoption
IX-B. Public Information and Participation
IX-C. Plan Updates
IX-D. Funding for Plan Updates
IX-E. Plan Implementation
A summary of these policies can be found on the Table 1-2.
1-16
c o
PLAN APPROVAL
3ir
AB 2948 (Tanner, 1986) requires that the Final Hazardous Waste Management
Plan be approved by a majority of the cities within the county which
contain a majority of the population of the incorporated area.
The County and cities of San Diego will be requested to take the
following actions on the Final Hazardous Waste Management Plan:
1. Approve the Plan for submittal to State DOHS
2. Agree to do the following within 180 days of DOHS approval:
a. Adopt a policy to consider the data, policies and
recommendations of the San Diego County Hazardous Waste
Management Plan in evaluating applications for facility siting.
b. Adopt the siting criteria in the San Diego County Hazardous
Waste Management Plan for use in evaluating facility
applications.
c. Use the designated areas identified in the\§an Diego County
Hazardous Waste Management Plan as the basis for accepting
facility applications.
.v"'"' '"
d. Adopt the model1" Conditional Use Permit, or other equivalent
procedural means, for processing and evaluating facility
permits^-—
v *•
e. Consider, approval and- use of the Southern California Hazardous
Waste Management Plan and intergovernmental agreements and
incentives program in evaluating applications for facility
siting. ,-'
The actions in number 2 can be accomplished through adoption of
ordinances and general plan amendments.
1-17
TABLE 1-2
COMPREHENSIVE HAZARDOUS WASTE MANAGEMENT
GOAL: To Develop A Comprehensive Program for the Safe Management of All Hazardous Wastes In San Diego County.
POLICIES IMPLEMENTATION STRATEGY RESPONSIBLE AGENCIES
(assigned implementation activity)
FISCAL IMPACT/FUNDING SOURCES
IV-A. Hew Businesses Generating Hazardous Waste 1. Develop « node] ordinance, designed to
Ensure that new and proposed businesses
using hazardous materials and generating
hazardous wastes are screened by City and
County regulatory agencies.
screen new businesses generating hazardous
waste, for the cities and county to modify
to their, specific needs.
2. Adopt the ordinance utilizing the local
planning and regulatory license process.
Hazardous Materials Management
Division (all)
Hazardous Waste Hanagenent Plan Advisory
Committee (1)
Appropriate City Departments (2)
Appropriate County Departments (2)
This Is a new program.
Estimated County cost: Included In the
cost of plan approval (Policy IX-A)
Funding source: AS 2948 (Tanner. 1986)
Phase III funding
IV-B. Data Management System
Ensure that complete and accurate Information
is available on all hazardous waste generated,
handled, stored, treated, transported and
disposed of in San Diego County.
1. Modify the HHHD data collection system
to include the following additional Information:
a. on-slte treatment
b. disposition of off-site waste
2. Provide training for all HMHO Inspectors to
standardize the Information collected.
3. Increase the level of analytic capability
to continue the efficient integration between
DOHS and HMMD data systems.
Hazardous Materials Management
Division (all)
State Department of Health Services (3)
This is a new program.
Estimated County cost:
$11.000 one-time-only
Proposed funding source:
AB 2948 (Tanner, 1986) Phase III
funding
IV-C. Technical Assistance to Industry
Ensure that businesses are able to assume
responsibility for hazardous waste management
by providing technical assistance In all
aspects of the field.
1. Establish.and maintain a hazardous waste
Information clearinghouse.
2. Provide training for HHHD staff on all
aspects of hazardous waste management.
3. Work with industry groups to provide
educational opportunities on all aspects
of hazardous waste management. ' •
Hazardous Materials Management
Division (all)
State Department of Health Services (all)
This Is an existing program.
Estimated County cost: This policy adds
no cost to the existing program
budget.
Funding source: Fee-for-service permits
COMPREHENSIVE HAZARDOUS WASTE MANAGEMENT
(continued)
TABLE 1-2 (continued)
POLICIES IMPLEMENTATION STRATEGY RESPONSIBLE AGENCIES
(assigned implementation activity)
FISCAL IMPAqyflMJDMG SOURCES
ii—•to
1V-E. Household Hazardous Hastes
Encourage reduction of household hazardous
waste generation by promoting safe
substitutes and recycling through community
education to all residents of San Diego.
Encourage the safe disposal of household
hazardous waste by providing convenient
disposal alternatives to all residents
In San Diego.
1. Provide an effective community education
program which focuses on use of safe substitutes
prudent purchasing, and recycling opportunities.
2. Develop recycling alternatives for all
possible wastestreams. ' •
3. Determine appropriate locations for
permanent household hazardous waste collection
sites.
4. Apply for end receive appropriate permits
from the State Department of Health Services.
5. Evaluate the effectiveness of permanent
collection sites as a means to meet the
timely needs of residents, and to determine if
additional sites would be beneficial.
6. Continue district collection events as'
permanent collection sites are being established.
Evaluate role of district events In program
publicity and amend number of events per year as
appropriate in combination with permanent sites
for a comprehensive and effective program.
7. Continue door-to-door pickup for elderly and
disabled.residents. • •
8. Explore new sources of program funding
Including state and federal funds and encouragement
of product taxes.
Hazardous Materials Management
Division (all) '• '
Appropriate City Departments (3.6)
Appropriate County Departments (3.6)
State Department of Health Services (4)
This is an existing program.
Estimated County cost: This policy ad
no cost to the existing program b
Funding sources: County Department of
Public Works-Solid Haste Enterprise
Fund
San Diego City Water Utilities
Department
Encina Hater Pollution Control
District
o
VI-A. HHHO and Military
Enhance the relationship between the
Hazardous Materials Management Division
and the region's military in areas of
common concern.
1. A task force should be developed
consisting of staff from the HHMD and each
of the County's military bases.
2. The task force should explore areas of
common concern and formulate recommendation
for cooperative solutions.
Hazardous Materials Manage
Division (all)
U.S. Navy (all)
U.S. Marines (all)
ent This is a new program.
Estimated County cost:
$8,000 one-time-only
Proposed funding source:
AB 2948 (Tanner. 1986) Phase III
funding
J
TABLE 1-2 (continued)
HAZARDOUS WASTE MINIMIZATION
GOAL: To Encourage Industry to Incorporate the Proper Hierarchy of Waste Management Alternatives
Which Will Reduce The Generation Of Hazardous Waste Discharged to the Environment.
POLICIES IMPLEMENTATION STRATEGY RESPONSIBLE AGENCIES
(assigned Implementation^ activity)
FISCAL IMPACT/FUNDING SOURCES
iroo
V-A. Promote Waste Minimization
Encourage Industry to reduce Its hazardous
waste by a countywlde goal of 30S within
the next five years by promoting waste
minimization as the first priority In the
hazardous waste management hierarchy.
1. Provide training to HHHO inspectors and
representatives of other environmental regulatory
agencies on waste minimization techniques.
2. Increase the level of technical assistance to
hazardous waste generators by emphasizing the
benefits of waste minimization.
Hazardous Materials Management
Division (all) . \
State Department of Health Services (all)
This 1s a modification of an existing
program.
Estimated County cost:
$3,100 one-time-only
$1.200 annually
Funding source:
AB 2948 (Tanner. 1986) Phase III
funding
Proposed State legislation
(Policy IX-D)
V-B. Hazardous Haste Minimization
Opportunity Assessments
Encourage businesses to conduct waste
minimization opportunity assessments to
determine their potential for source
reduction and recycling.
1. Conduct hazardous waste minimization
opportunity assessments for generators.
2. Require existing businesses to submit
hazardous waste minimization plans.
3. Require new businesses to prepare and submit
a hazardous waste minimization plan when
applying for hazardous waste permits.
4. Cities should adopt a mechanism to require
businesses to prepare, submit, and implement
hazardous waste minimization plans.
Hazardous Materials Management
Division (1.2.3)
Appropriate City Departments (4)
Appropriate County Departments (4)
This is • modification of an existing
program.
Estimated County cost: $8,400 annually
Funding source: Proposed State legislation
(Policy IX-D)
HAZARDOUS WASTE MINIMIZATION
(continued)
TABLE 1-2 (continued)
POLICIES IMPLEMENTATION STRATEGY RESPONSIBLE AGENCIES
(assigned implementation activity)
FISCAL IMPACT/fUWIMG SOURCES
V-C. Incentives for Waste Minimization
Establish a reward program to recognize
businesses that Implement waste
minimization successfully.
t. Enhance the public relations/community awareness
component of the Promote Landfill Alternatives Now!
(P.l.A.H.I) by conducting the following tasks:
a) Establish evaluation criteria for selecting
waste minimization programs.
b) Award city and county proclamations to
selected businesses.
2. Conduct a media campaign designed to recognize
these businesses.
3. Explore the modification of the existing
hazardous waste penult fee structure to reward
those businesses that have successful waste
minimization programs.
Hazardous Materials Manage*
Division faff) f
Board of Supervisors (1.2)
.City Councils (1,2)
snt This Is a new program.
Estimated County cost: $5.700 annually
Funding source: Proposed State
legislation (Policy IX-0)o
Ir\>
V-0. Annual Waste Minimization Report
Prepare an annual report on the progress
of waste minimization efforts In the
county.
1. Prepare an annual report which analyzes the
progress of waste minimization efforts In
San Diego.
2. Incorporate the findings of the annual report
Into the Hazardous Waste Management Plan updates.
County Hazardous Materials Management
Division (all)
This Is a new program.
Estimated County cost: $4.200 annually
Funding source: Proposed State
legislation (Policy IX-D)
V-E. Financial and Technical Assistance
for Haste Minimization
Ensure that financial and technical
assistance programs are available for
hazardous waste minimization projects.
1. Assess the applicability of grant and/or loan
programs for Industry waste minimization projects.
2. Explore the Introduction of legislation which
would provide waste minimization Incentives to
Industry through grants, loans', tax breaks, or
other financial mechanisms.
3. Continue to promote hazardous waste
minimization through P.L.A.N.! by providing
technical expertise In alternative management
techniques.
State Department of Health Services (all)
Hazardous Materials Management
Division (all)
Various Lending Institutions (all)
This Is • new program.
Estimated County cost: $2.600 annual 1v
Funding source: Proposed State
legislation (Policy IX-0)
SITING AND PERMITTING OF HAZARDOUS WASTE FACILITIES
TABLE 1-2 (continued)
GOAL: To Accelerate the Siting and Permitting of Needed Hazardous Waste Facilities.
POLICIES IMPLEMENTATION STRATEGY RESPONSIBLE AGENCIES
(assigned impjeineptation activity)
FISCAL IMPACT/FUNDING SOURCES
VIl-C. Updates on Hazardous Waste Information
Provide annual or semi-annual updates of
hazardous waste generation information and
facility needs.
1. Request DOHS to make specified changes in
the HUIS format.
2. Request DOHS to provide HUIS information
on an annual or semi-annual basis.
3. Modify the HHHO Inspection forms as
necessary to obtain needed information.
4. Provide jurisdictions with an annual update
of hazardous waste generation information and
facility needs.
.Hazardous Materials Management
Division (all)
State Department of Health Services (1.2)
This is a new program.
Estimated County cost: $9.000 annually
Funding source: Proposed State
legislation (Policy IX-C)
lroro V11I-A. Siting Criteria for Off-Site
Hazardous Waste Treatment Facilities
Ensure the protection of the residents of
San Diego County from risks associated with
off-site hazardous waste treatment facilities.
Incorporate the designated general areas
and siting criteria Into City and .County
General Plans to be used to determine
locations for off-site hazardous waste
treatment facilities.
Appropriate County Departments
Appropriate City Departments
This is a new program.
Estimated County cost: Included In the
of plan approval (Policy IX-A)
Funding source: AB 2948 (Tanner. 1986)
Phase III funding
VI11-C. Conditional Use Permit for Off-Site
Treatment Facilities
Ensure that off-site hazardous waste treatment
facilities are subject to complete local
review.
1. The model Conditional Use Permit (CUP)
contained In the Plan Includes the
applicable provisions of Chapter 6.5 and
references the need for an environmental
review and risk assessment. This permit
was developed by the City of San Diego.
2. The model CUP should be the basis for
adoption for a CUP by the County and each
of the cities of San Diego.
Hazardous Waste Management Plan
Advisory Committee (all)
County of San Diego (2)
Cities of San Diego (2)
This is a new program.
Estimated County cost: Included in the
cost of plan approval (Policy IX-A)
Funding source: AB 2948 (Tanner. 1986)
Phase III funding
<•
TABLE 1-2 (continued)
SITING AND PERMITTING OF HAZARDOUS WASTE FACILITIES
(continued)
POLICIES IMPLEMENTATION STRATEGY RESPONSIBLE AGENCIES
(assigned implementation activity)
FISCAL IMPACT/FUNDING SOURCES
VIII-0. Conditional Use Peralt for On-Slte
Treatment Facilities
Ensure that on-slte hazardous waste treatment
.facilities are subject to full local review.
1. The model Conditional Use Pewit (CUP)
contained in the Plan also applies to on-site
TSDFs.
2. The node] CUP should be the basis foe
adoption of a CUP by the County and each of
the cities of San Diego.
Hazardous Waste Management Plan
Advisory Comittee (all)
County of San Diego (2)
Cities of San Diego (2)\
""
This is a new prograi.
Estimated County cost: Included in
cost of plan approval (Policy IX-A)
Funding source: AB 2948 (Tanner. 1986)
Phase III funding
r\>\\
o
L
TARGETED HAZARDOUS WASTES
TABLE 1-2 (continued)
GOAL: To ensure that an accurate assessment is made of the need for residuals repositories and incineration factHifff
and that contaminated sites are cleaned-up in a timely manner.
POLICIES IMPLEMENTATION STRATEGY RESPONSIBLE,. AGE
(assigned implementation activity)
FISCAL IMPACT/FUNDING SOURCES
1V-D. Contaminated Hazardous Waste Sites
Ensure timely and complete alligation of
contaminated hazardous waste sites in
San Diego County.
Iro
1. The HMHO should work closely with the
OOHS in establishing and meeting the timelines
for Mitigation of the region's "Superfund" sites.
2. The County should work with the affected
cities of San Diego to develop a common
strategy for addressing the complex land use
issues.
3. The County and cities should seek
legislative and/or legal remedies to these
Issues.
State Department of HeaNth Services
Hazardous Materials Management
Division (all)
County of San Diego (2.3)
Cities of San Diego (2.3)
(1) This is an existing program.
Estimated County cost: This policy
adds no cost to the existing
program budget.
Funding source:
Fee-for-servlce permits
VI1-B. Fuel Contaminated Soil
Encourage the application of on-site
treatment technologies to soils
contaminated from leaking underground
storage tanks.
1. The HHMO should join with state-wide
organizations such as the California
Conference of Directors of Environmental
Health and the County Supervisors Association
of California in petitioning the OOHS to act
quickly to review and permit safe and
effective on-site treatment technologies to
manage contaminated soils.
2. Explore the feasibility of having the
Hazardous Materials Management Division
review on-site treatment permits on behalf
of the state.
State Department of Health Services (all)
Hazardous Materials Management
Division (all)
This is a new program.
Estimated County cost: No additional cost
If the State Department of Health
Services issues permits.
$85.000 annually if the Hazardous
Management Division Issues permits.
Funding source:
Fee-for-service permits
TARGETED HAZARDOUS WASTES
(continued)
TABLE 1-2 (continued)
POLICIES IMPLEMENTATION STRATEGY RESPONSIBLE AGENCIES
(assigned Implementation activity)
FISCAL IMPACT/FUWIMG SOURCES
VIII-B. Reduce Incinerable Wastes
Encourage the use of preferred alternate
management techniques for specific
hazardous wastestreams which have
incineration as the primary treatment
technology.
1. Specific waste minimization strategies
and preferred alternative treatment
techniques should be identified for those
wastestreams appropriate for Incineration.
2. The San Diego County businesses which
generate these wastestreams should be
identified through the HMMD database.
3. Education and technical assistance
should be provided to these targeted
through the HHHO inspection and waste
minimization programs.
Hazardous Materials Management
Division (all) • -•
This Is • new program.
Estimated County cost: Included in the
cost of implementing waste
minimization policies (Chapter V)
Funding source: Proposed State legislation
(Policy U-D)
o
irotn VII-A. Residual Repositories
Ensure that adequate facilities are
available to dispose of hazardous
waste and treatment residuals.
1. Solicit DOHS's approval of the disposal
assessment methodology.
2. Encourage the use of the disposal
assessment methodology by local, regional
and statewide Hazardous Waste Management
Plans.
3. Support efforts to permit "designated
landfills" throughout the State.
Hazardous Materials Management
Division (all)
San Diego County Department of
Public Works (3)
State Department of Health
Services (1,2)
Southern California Hazardous Waste
Management Authority (2)
California Waste Management Board (3)
This is a new program.
Estimated County cost: Included in the
cost of plan approval (Policy IX-A)
Funding source: AB 2948 (Tanner, 1986)
Phase III funding
HAZARDOUS WASTE MANAGEMENT PLAN IMPLEMENTATION
TABLE 1-2 (continued)
GOAL: To ensure that the San Diego County Hazardous Waste Management Plan is accurate and up-to-date.
POLICIES IMPLEMENTATION STRATEGY RESPONSIBLE AGENCIES
(assigned Inplemanation activity)
FISCAL IMPACT/FUNDING SOURCES
IX-A. Plan Adoption
Ensure that the San Diego County Hazardous
Waste Hanagenent Plan Is approved and adopted.
lroen
1. Hake presentations to each of the cities
upon request.
2. Hake unifications to the HUMP, based on
the Input from the public, the State Department
of Health Services and the cities of
San Diego.
3. Present the final HUH? to the Board of
Supervisors and the cities of San Diego County
on or before September 30, 1986, unless an
extension Is granted to February 1, 1989.
4. Request that the Board of Supervisors and
city councils adopt the package of ordinances
and siting criteria.
5. Prepare and ga,1n approval of the EIR.
County Board of Supervisors (3,4.5)
City Councils of San Diego (1.3.4)
San Diego Association of
Governments (1.3,4)
Hazardous Materials Hanagenent
Division (all)
This Is a new program.
Estimated County cost:
$113.500 one-tine-only
Funding source:
AB 2948 (Tanner, 1986) Phase III
funding
IX-B. Public Information and Participation
Ensure that the public has adequate
hazardous waste Information and opportunities
to participate In decisions on hazardous
waste Issues.
1. Continue efforts to Inform the public
of county hazardous waste issues (I.e.
"HA2PLAN NEUS* newsletter, presentations
to Community planning Groups, etc.)
2. Develop a multi-media campaign
(brochures, slide shows) to facilitate In
the public presentations.
3. Provide an open-door policy to discuss
hazardous waste Issues with the media and
citizen groups.
Hazardous Materials Management
Division (all)
San Diego Association of
Governments (all)
This is a new program.
Estimated County cost:
$57,000 one-time-only
Funding source: AB 2948 (Tanner,
Phase III funding
1986)
E
g^~
i
z
1-
^ 3
|gS U
5~
LU5
</>3§
1
-Q
0)3
C•r-
+J
Cou
CM
1
LU
CO
1/1LUy
3
|
1 "
I
iu!
>,•w
V) ULU «
^* B
C9 4J
ONSIBLE Anplenentaii»^»VIVI<o
>•u
IS1M
5
*-«
i
~
VILU
U3OL
p
r—
3
C
0 * ~o <• oO ** 1•MM
.* sj
III!
*til
e o 3 *—O M
S ****
sll
^^
*5^•* **S- iM *— ••- Ol••- •- 0 «J
|~ §_i
3> «?« ~ ^
1- O u — w —0 O 11 r-e M i*>r-«s z &*$-
I o S. I S I4» k O *M
||- = 1 3 5
C'
. 1..- s
S- o, >5c c u +>
o 01 e v ^ 'S '
M Ok <« £ (/>•r « *• *> .. »£ § " M ^3« X •» n • <f& -di **^ » « u £•••„;
"S 5 S .^ "" ** 5
« o 's c - eo -a B c o -o ai3 S3 " - S g,22^^ far:55 1 1 i«f
•&I-5SS Sl 5i.S.S-SS-«««5-§«,'g
"5 "I « -o g. S £ § S . = —'^•oa.uc<>j«o.
«1«If!
* u 5
*^ TlM 13 6
wi -O O
3 U. T"•§ 3 ^S
«» N 41 i-01 <« ** Ol
** X £ JU
Q ^ a 3= - 2 ggu s-f— .C * Ua. -w 01
J 1 e E
x e *- o^« ui a. **
u
eau
eOl
eo
M MT 2 =
t- *^ U 41
0 0 f- S> cC *» L. t-
O C 41 41« S » %* gfe • - « S.55
W» U -^ ** « F- *.•»" O U •»- C •« O
i < o « §5. (J -r- M V- C-
^ £ >, £•= °tj
O ** O "••• ** v*
o-jo^-SSSo
? o — — <3 5 u <
ill 1*5 3 al
I tiSI-5^33°s5l5l
0)-1 ffu u •>-;H
« i 3 -M
01 *3 Os?;s
i«i55 5 ». £^ k ° «!• 41 o
:* o o •*-
0»
^ c
5 8 a
i- 41 S« O» «> * U« C Ol« O
« 4^ Q.
*J 01*o o» ** >»
= 1*2
C 3 M 01•0 <fc- 3 0
= a|J1 1 s 1
o « Z I•S " 5 -5.•a « 5 g"c <a -^3 .C 0)
"" til
Q 3 3 Bi wi <qX C 0 .—
/?-** X CO
c ^«
"*" tf .
1513 £ e
"o ""^ i2~!«
B *» O CM B« M *O -S
I1 S ^ " '
slf 2H
VI -M O Ol f— g u c a.
**" "5 't— UJ U.
VI
c
*. E
i I1 a« <*>c o
x e
o e w 5
i? i?1! « .
5 S T "u
c c S S
*• "^ *» o o
« »|| |
J ** N o e
S5 5
A 01
>t OIf
1* 0
5 2*. §o o
1 J*-» *rf
c •*-•S VV0w
^•g£ 3
Ol U
u tt u e•^3 T»
P— O ^ **a! sS
• 2 x332Z
§' S^•^ «» *» C 19** 5 ».1C!15 g g-
Of O M p* •*•B e Q. +*41 Ot 0 <0g 33 S5£.€19^ C Of Olg ~ I S " .5 « i s 5 «& 0> 0 « >—
L. o! S3• 3 C « W Oui o *• « a.i u *o wt *a o« e c <a Q. u—|UJ ID 3 3 a
1-27