CHAPTER 6 - ANALYSIS OF LAND-USE WITHIN ZOC FOR TOXIC AND HAZARDOUS MAT. 

 Cape Cod Aquifer Management Project Final Report Page 61 



economies of scale. For example, the BOH has organized a battery recy- 

 cling drop off day with the cooperation of a local automotive business. 

 Fifteen businesses brought in approximately 500 batteries and were then 

 required to set up an exchange program to prevent such an accumulation in 

 the future . 



While the BOH's approach has been quite successful, it would not be as 

 effective in a less developed area where there may only be one printing or 

 dry cleaning business in town. In this case, the networking of several 

 neighboring towns should be pursued for the hauling of waste for each type 

 of business. Regional planning agencies (RPAs) or health departments 

 should have an important role in setting up these hauling pools by working 

 through professional business associations and labor unions. DEQE and EPA 

 should encourage and fund regional planning agencies to inventory these 

 activities and to develop appropriate programs to respond to these needs. 



The Groundwater Discharge Permit Program (See Appendix M) 



DEQE has concentrated implementation of the Groundwater Discharge 

 Permit Program on municipal wastewater treatment and other large -volume 

 domestic wastewater flows and on those who voluntarily apply for permits. 

 This program leaves commercial facilities at the low end of the priority 

 scale. For example, only one industrial and four domestic groundwater 

 discharge permits have been issued in ZOC #1. Out of lAl businesses meet- 

 ing the threshold quantity information on the toxic and hazardous materi- 

 als bylaws, 48 do not have EPA manifest notification numbers, are not 

 sewered, do not have tight underground storage tanks (USTS) and are not 

 covered by the groundwater permit program. 



This poses the question of how these 48 businesses are disposing of 

 their wastes. Although some of these firms may not discharge their wastes 

 because they have unregulated tight tanks and mechanically contain their 

 waste, a portion probably do discharge wastes directly to septic systems. 

 These 48 businesses are good candidates for an inspection by DEQE staff 

 because there is a good potential that a number of these facilities are 

 discharging wastes illegally. 



The groundwater discharge permit program is a very powerful yet under 

 utilized groundwater protection tool. This program permits the regulators 

 to provide businesses with the incentives, through permit issuance and 

 denial, to change improper waste -disposal practices. Currently, DEQE's 

 Division of Water Pollution Control (DWPC) does not have adequate resourc- 

 es to aggressively implement this program and pursue the existing backlog, 

 as well as investigate cases in wellhead-protection areas. Thus, a host 

 of commercial businesses that may be discharging industrial wastes direct- 

 ly to septic systems in close proximity to public-supply wells are being 

 neglected. DWPC staff should utilize existing data, referrals, local BOH 

 priorities and wellhead-protection area boundaries to target their inspec- 

 tions and enforcement activities. 



