APPENDIX I 



CAPE COD AQUIFER MANAGEMENT PROJECT (CCAMP) RECOMMENDATIONS 



ENHANCED GROUNDWATER PROTECTION IN LANDFILL PROGRAMS 



December, 1986 



Introduction 



The following recommendations are the result of the Cape Cod Aquifer 

 Management Project's examination of the current status of groundwater 

 protection from contamination from landfills on Cape Cod. The Project's 

 major emphasis is on improving federal, state and local coordination in 

 protecting the groundwater resource and ensuring that groundwater concerns 

 are at the forefront of all relevant policy considerations. The first 

 issue the Project's Institutions Work Group explored was landfills. We 

 examined current and proposed DEQE regulations and guidelines and spoke 

 extensively with people in different DEQE divisions as well as local land- 

 fill operators and town representatives. Because regulations protecting 

 groundwater from landfill leachate are largely a state responsibility, 

 this particular set of recommendations focuses almost exclusively on DEQE 

 programs . 



We began our study of landfills at a time when the DEQE landfill pro- 

 gram was emerging from a period of several years of dormancy. The lega- 

 cies of that period, historical siting and operating errors and uncertain- 

 ty over the outcome of the Norfolk court case involving Proposition 2 1/2 

 all combine to create a very difficult regulatory situation. Neverthe- 

 less, the best protection for groundwater is a strong, comprehensive state 

 landfill program with clearly defined policy goals and regulations and 

 adequate staff resources. 



Unfortunately, the current DEQE landfill program does not adequately 

 address groundwater protection. Generally, we found that groundwater 

 considerations were not given sufficient deliberation in program manage- 

 ment and decision-making. Further, we observed that basic rules, proce- 

 dures and definitions relative to groundwater are inconsistent between the 

 landfill program and other groundwater based programs within DEQE. To 

 correct this, we believe it is imperative that the landfill program incor- 

 porate groundwater protection considerations in its operating procedures 

 and do so in a manner that provides consistency with groundwater policy 

 and procedures throughout DEQE. 



New guidelines are currently being drafted and reviewed by solid waste 



