APPENDIX M - CCAMP CONSTRUCTION GRANTS, GROUNDWATER DISCHARGE PERMIT AND 



GROUNDWATER CLASSIFICATION RECOMMENDATIONS 



December, 1987 Page M-6 



examination of commercial categories that are potentially serious 

 sources of localized groundwater contamination. 



Background: DWPC has been tackling some of these commercial catego- 

 ries but not all. DWPC has several laundromats under administrative 

 orders; it has also been pursuing particularly troublesome gas sta- 

 tions. New gas stations applying for permits (not all do) are re- 

 quired to use holding tanks. DWPC has not yet been addressing exist- 

 ing gas stations or photo developers or other small businesses. 



12. DWPC should undertake a critical investigation of its resources 

 division-wide to ensure that they reflect current concerns, knowl- 

 edge, and emphasis on groundwater. If a redistribution of resources 

 is warranted, it should be carried out as soon as possible. CCAMP 

 makes this recommendation fully understanding that some staff desig- 

 nations are not transferrable to other programs, but urges DWPC to 

 seek areas of flexibility within those constraints. 



13. DWPC should make an aggressive effort to get input from the public 

 on proposed groundwater discharge permits. Rather than simply rely- 

 ing on legal notice, DWPC should notify the relevant town agencies 

 of the proposed permits. 



14. DWPC in the regions needs to take a more active role in pursuing 

 violators. This involves carefully reviewing monitoring reports, 

 and following up on projects after permitting through a vigorous 

 inspection effort. Could resources be made available to try out 

 such an effort in the pilot area? 



15. DWPC should automate its permit and classification programs as soon 

 as possible to facilitate the review of monitoring results and to 

 improve planning and tracking capabilities as well as to guide 

 enforcement actions. There should be sufficient resources for DEQE 

 to review permit monitoring results adequately as this is crucial to 

 the groundwater discharge permit program. 



Comment: DWPC has begun action on this recommendation with a 

 grant proposal to EPA for computer help . 



16. DEQE should require a letter of credit, bond or escrow account for 

 all entities, such as private developers, that are installing waste- 

 water treatment systems. 



Background: A permanent entity must be responsible for the 

 long-term maintenance and replacement of a wastewater treatment 

 facility. The state must be able to ensure the accountability and 

 financial viability of entities installing such systems. Legal 

 staff are currently exploring the available options and DEQE should 

 actively support their efforts. 



