APPENDIX M - CCAMP CONSTRUCTION GRANTS, GROUNDWATER DISCHARGE PERMIT AND 



GROUNDWATER CLASSIFICATION RECOMMENDATIONS 



December, 1987 Page M-4 



view be drafted between the Division of Water Supply and Construc- 

 tion Grants. There already exists a procedure for regional water 

 supply input developed by DWPC; this should be formalized. 



GROUNDWATER CLASSIFICATION 



5. * DEQE should immediately pursue the inclusion of an anti-degradation 



provision within the groundwater classification system and/or the 

 banning of certain categorical discharges in vulnerable areas. DEQE 

 should consider requiring all discharges in Zone lis of existing and 

 identified future well sites to meet anti-degradation standards. A 

 mechanism must then be developed for coordinating anti- degradation 

 designations for surface and ground waters. DEQE should articulate 

 a policy encouraging discharges to that resource which is most easi- 

 ly monitored and observed. 



Background; The ambient quality of the water in a Zone II area 

 may be quite high; the current Class I would allow contamination 

 above the present levels, without exceeding drinking water stan- 

 dards. There is always the possibility of a spill or of the failure 

 of the pollution control system in place resulting in a discharge 

 exceeding Class I standards. The consequences of such an occurrence 

 could be particularly severe in a Zone II, especially for an area 

 with no alternate water supply available. Currently, the only 

 anti-degradation designations allowed are for surface waters, forc- 

 ing the use of ground discharges in those areas. The state must be 

 allowed the flexibility of requiring stricter standards in critical 

 areas of either surface or ground waters. 



6. In designating Class III areas, assurance must be made that future 

 water supply demands can be met without the designated areas. DWPC 

 should request specific input, on a case-by case basis, from the 

 Division of Water Supply as to the future needs of a particular 

 area. (See recommendation #3.) 



Background: This is particularly important because the areas that 

 are suitable for wastewater treatment plant location also tend to be 

 suitable for water supply development. It is important to know the 

 water supply needs of an area before allowing a portion of the aqui- 

 fer to be contaminated. 



7. EPA Region I should work out an agreement with DEQE concerning the 

 relationship between Case III and Class III designations. A formal 

 procedure should be established by both parties coordinating these 

 two procedures and establishing responsibility. Special attention 

 should be provided by EPA's Office of Ground Water Protection in 

 reviewing Class III designations in sole source aquifers. 



8. CCAMP supports a stringent review process for the designation of 

 Class III areas and would oppose any efforts to weaken the current 



