APPENDIX M - CCAMP CONSTRUCTION GRANTS, GROUNDWATER DISCHARGE PERMIT AND 



GROUNDWATER CLASSIFICATION RECOMMENDATIONS 



December, 1987 Page M-3 



for discharge to the ground in a sole source aquifer with ground and 

 water table conditions such as are found on the Cape. 



2. EPA should reconsider its classification by the 201 grants program 

 of land application as an alternative technology. The extra percent- 

 age of federal and state funding for plants designed to discharge to 

 the ground creates an imbalance in weighing discharges to ground or 

 to surface water. This may encourage the selection of a ground dis- 

 charge based on economic rather than environmental considerations. 

 At the present time, this discussion is purely academic for Cape 

 Cod, as a ground discharge is the only option. 



3.* EPA and DEQE should require consideration of the development of a 

 public water supply as an alternative to sewering in towns where 

 such a trade-off is relevant in the 201 facilities planning process. 

 Throughout the Construction Grants process, EPA and DEQE should 

 encourage coordination between wastewater treatment and water supply 

 planning. 



Background : The majority of Cape towns lack wastewater treatment 

 plants; many have high density zoning with septic systems and pri- 

 vate wells resulting in water quality problems. A wastewater treat- 

 ment plant may be the answer for all or some of these areas. Alterna- 

 tively, the development of a public water supply may be appropriate 

 for some areas. The current 201 facility planning process discourag- 

 es the consideration of the latter option. Water supply planning is 

 not included in the consultant's scope of work because it is not an 

 eligible cost. The consultant is merely reimbursed for a summary of 

 existing water supply plans. This is insufficient. 



Note: This recommendation will also appear in CCAMP recommenda- 

 tions on Water Supply Planning. 



4. DEQE Division of Water Pollution Control and the Division of Water 

 Supply should adopt a formal agreement specifying responsibility for 

 the water supply review of Construction Grants projects, privately 

 funded wastewater treatment facilities, groundwater discharge 

 permits and for DWS input into the groundwater classification 

 process. All Construction Grants projects with groundwater impacts, 

 e.g. land application systems, lagoons, etc., should be reviewed by 

 both DWS and the DWPC groundwater permit program to assess 

 groundwater impacts and to ensure protection for the most beneficial 

 present or future use. Documentation of these reviews should be in 

 writing and maintained as part of the official file. Grant 

 increases or project modifications potentially affecting groundwater 

 should also be in writing and maintained as part of the official 

 file. 



Background: The EPA water supply staff review of Construction 

 Grants projects has been delegated to the state. EPA has requested 

 that a formalized agreement specifying responsibility for this re- 



