APPENDIX N - CCAMP HAZARDOUS MATERIALS USE AND DISPOSAL RECOMMENDATIONS 

 December 1987 Page N-4 



Construction Grants, the Groundwater Discharge Penult Program, and 

 Groundwater Classification) , this program has been underutilized and 

 understaffed. In examining the regulation of toxic and hazardous materials 

 on Cape Cod, It became apparent once again to CCAMP how crucial this 

 program is for the protection of groundwater. Particularly neglected by 

 this program are discharges from commercial establishments in unsewered 

 areas on Cape Cod. This program must be given adequate resources and 

 enforcement support to fulfill its regulatory role and address these 

 potentially serious sources of contamination. 



In an in-depth study of a 3550-acre Zone II for nine public supply welis in 

 Barnstable, CCAMP found 48 businesses that may be discharging illegally to 

 the ground. Out of 141 businesses in the Zone meeting a threshold quantity 

 of toxic or hazardous materials storage requiring compliance with a town 

 bylaw, these 48 do not have EPA manifest notification numbers, do not have 

 tight tanks and are not covered by the groundwater discharge permit 

 program. It is likely that a number of these 48 are discharging industrial 

 wastes to septic systems and should be regulated by DWPC. 



The lack of a strong discharge permit program presence on Cape Cod has also 

 led to considerable confusion on the part of local Boards of Health over 

 DEQE policy on floor drains at existing facilities. DEQE/DWPC should 

 address this in a memo or a workshop or by coordinating with the RPA to 

 explain the state policy to local agents. 



6. Zone lis Should Guide Inspection/Enforcement Priorities . 



DHW and DWPC should use delineated Zone lis or proximity to public water- 

 supply wells (within 1/2 mile of well if Zone II has not yet been 

 delineated) to guide inspection and enforcement priorities. Last year, DHW 

 experimented with a number of different approaches to setting these 

 priorities, including type of business, but location relative to a public 

 well was not considered. Targeting facilities within wellhead protection 

 areas should be agency policy and should be practiced by the appropriate 

 programs. It may be useful to insert this into annual program plans. 



EPA's RCRA Office should support this method of setting priorities and 

 encourage its use in the Region I states. 



7. State and Federal Funding of Innovative Outreach Programs at the Regional 

 Level . 



DEQE, DEM and EPA should aggressively encourage innovative outreach pro- 

 grams at the regional level involving education, organized milk runs, 

 registration of waste generators, organized waste collections for 

 households and very small waste generators, waste exchanges and other 

 efforts. This encouragement should include financial support and technical 

 assistance. There should be intensive lobbying for the necessary funds and 

 authority. These agencies should then be responsible for transferring the 

 methods from successful pilot projects to other areas. The RPAs should 



