APPENDIX M - CCAMP CONSTRUCTION GRANTS, GROUNDWATER DISCHARGE PERMIT AND 



GROUNDWATER CLASSIFICATION RECOMMENDATIONS 



December, 1987 Page M-7 



17. DWPC and DHW should clarify their joint responsibilities concerning 

 the relationships between Class III, Alternate Concentration Limits 

 (ACL's), the Groundwater Discharge Permit program, RCRA licensing, 

 and 21E sites (uncontrolled hazardous waste sites) which require 

 groundwater reclamation work. 



Background: There is considerable overlap between DWPC's and DHW's 

 groundwater - related programs which results in confusion and de- 

 lay. The sooner responsibilities are clarified, the easier it will 

 be for each Division to work as effectively as possible. 



18. EPA should re-examine its definition of regulated wastes under the 

 UIC program to maximize the opportunity for groundwater protection. 

 For optimal groundwater protection, EPA should regulate wastes of 

 concern, not method of disposal. 



Background: Currently, the UIC program covers wastes disposed of in 

 cavities that are deeper than they are wide. The exact same wastes, 

 disposed of in a different manner, are not covered. 



