APPENDIX M - CCAMP CONSTRUCTION GRANTS, GROUNDWATER DISCHARGE PERMIT AND 



GROUNDWATER CLASSIFICATION RECOMMENDATIONS 



December, 1987 Page M-2 



as expeditiously as possible. 



Monetary support from the federal government, through the Construction 

 Grants program, has been crucial in allowing many municipalities to take 

 steps to deal comprehensively with their wastewater problems. In the past 

 EPA has been reluctant to support the same advanced levels of treatment for 

 systems discharging to the ground as for those discharging to surface wa- 

 ters. That position has been influenced by an imbalance at the federal 

 level between the incomplete EPA authority over groundwater and the compre- 

 hensive EPA control over surface water. EPA's classification of land appli- 

 cation as an alternative technology (entitling the applicant to an in- 

 creased federal funding match) is a further example of the inconsistency of 

 EPA's approach to ground and surface waters. EPA's lower standards for 

 ground discharges, in addition to being inconsistent with EPA's Groundwater 

 Protection Strategy and Cape Cod's status as a sole source aquifer, result 

 in a fragmented approach to the jointly administered Construction Grants 

 program. CCAMP recognizes that this recommendation must be implemented at 

 the national, not state or EPA regional level. 



Both the groundwater discharge permit program and the groundwater clas- 

 sification system are relatively new programs. Despite the progress that 

 has been made by the discharge permit program so far, numerous sources of 

 domestic and industrial groundwater discharges remain unregulated. Resourc- 

 es have not been adequate to enable DWPC to regulate all categories of 

 small businesses that may be discharging contaminants directly to septic 

 systems. Though it is not clear what the cumulative effect of these many 

 unregulated discharges is on the ground water quality of Cape Cod, CCAMP 

 believes that a strong groundwater discharge permit program could be a 

 critical factor in the prevention of contamination. CCAMP is carrying out a 

 detailed land use study in one Zone II in the most heavily developed area 

 of Barnstable. This study will enable CCAMP to identify the industries 

 that pose the greatest threat to ground water and to assess the magnitude 

 of the work to be done by DWPC. 



INSTITUTIONS COMMITTEE RECOMMENDATIONS 



(PRIORITY RECOMMENDATIONS ARE MARKED WITH AN ASTERISK) 



CONSTRUCTION GRANTS 



1.* EPA should change its policies in response to DEQE's request that it 

 fund the full federal share of Construction Grants projects that are 

 designed to meet a stricter state standard for discharge to the 

 ground. It appears that current EPA operating policies may be suffi- 

 ciently flexible for EPA to fund at the usual level a project with 

 higher levels of treatment designed to meet a higher state standard 



