APPENDIX N - CCAMP HAZARDOUS MATERIALS USE AND DISPOSAL RECOMMENDATIONS 

 December 1987 Page N-2 



INSTITUTIONS COMMITTEE RECOMMENDATIONS 



1 . Joint Hazardous Waste and Groundwater Discharge Permit ProEram Inspec - 

 tions: SERO Pilot . 



DEQE should initiate a pilot program in the Southeast Regional Office (SE- 

 RO) to conduct facility inspections jointly across DHW and DWPC programs. 

 DEQE should develop a workgroup of regional inspectors and representatives 

 from the relevant programs in Boston to work out the specifics as soon as 

 possible. A rough framework and workplan should be developed before large 

 numbers of new employees are hired and before next year's workplans are 

 written. 



Discussion: The advantages of a joint inspection program are numerous. 

 They include: more effective and economical use of an inspector's time; a 

 more comprehensive approach to waste disposal; encouraging better overall 

 business management practices; and consistent enforcement across all media 

 of discharge. This approach would foster more efficient and 

 environmentally sound business practices; an operator would think of the 

 various components of his waste stream as a whole and try to reduce the 

 waste generated and then dispose of it properly in a cost-effective manner. 

 Under the joint inspection program, one enforcement notice would be sent 

 noting the violations of the relevant regulations. Any necessary follow-up 

 activity would then be coordinated. CCAMP focused on groundwater related 

 programs but the cross-program inspections could also be set up to include 

 air programs. 



Between 1984-1986, when a very rough count was kept, approximately 5 DHW 

 referrals per week were received by DWPC groundwater discharge permit 

 program staff in the Southeast Region. Each referral means that a facility 

 will probably be re -inspected many months later by another SERO staff 

 person. In the meantime, whatever abuses were noted may still be occurring, 

 resulting in the possible discharge of contaminants directly to the 

 ground. The facility operator may have initiated a change of procedure in 

 response to the DHW visit; he may balk at making additional changes at a 

 later date. Having one inspector, or a team of inspectors trained in both 

 DWPC and DHW program policies and responsible for specific sites will 

 result in clearer communication with the facility owner and the local Board 

 of Health. Further, if one inspector were responsible for all the sites in 

 a particular area, he or she would become familiar with the area's Zone lis 

 and other vulnerable areas such as wetlands. 



There are a number of different models that could be employed for setting 

 up a joint inspection program. An individual could be trained to represent 

 all of the relevant programs or a team approach with an information 

 gathering inspector reporting to a team of professionals from the various 

 programs could be utilized. Whatever model is chosen, it should encompass 



