TOWN OF MILFORD

TOWN OF MILFORD

OFFICE OF THE SELECTMEN

28 May 1991

Julie Belaga, Regional Administrator United States Environmental Protection Agency J. F. Kennedy Federal BuiLding Boston, MA 02203-2211

Re: Savage Well Site, Milford, New Hampshire Selection of Remedy

Dear Ms. Belaga:

The Town of Milford, by its Board of Selectmen, submits for inclusion in the official record, the following position of the Town of Milford as relates to the community acceptance requirements of EPA. It is our understanding that EPA requires that nine evaluation criteria be used to standardize detailed evaluations. These criteria serve as the basis for the feasibility study (FS) and for subsequent selection of the EPA's preferred alternative. By this correspondence, the Board of Selectmen formally notifies the Regional Office of criteria acceptable to the Town of Milford and that the Town, as the former owner of the subject well, requests to be a party to the resolution/remedy process.

The position of the Board of Selectmen and the Town of Milford has always been that any solution to the Savage Well issue must be balanced and pose no threat to the viability, stability and financial soundness of Hitchiner Manufacturing Company, Hendricks Wire and Cable Corporation, New England Steel Fabricators, Inc., and 0. K. Tool Company. As you are aware, there are only two active and viable companies left of the original, potentially-responsible parties; those being Hitchiner Manufacturing and Hendricks Wire and Cable. As such, it is even more imperative that any remediating program be one which minimally impacts the financial, employment and marketability of these two companies. This is the only solution that will be acceptable to the Town of Milford and its Board of Selectmen.

The Board of Selectmen is aware that there will be discussion and concerns over the Savage Well and its aquifer as a water source. We are also cognizant that CERCLA places a high priority on a "principal drinking water supply" which has become contaminated. However, we would be remiss if we did not remind EPA that the Savage Well Site is not now,and is not intended to be in the future, a principal drinking water supply. This position is a result of discussions and opinions from staff of the State of New Hampshire Water Supply and Pollution Control Commission, now Department of Environmental Services, as to how the Town should insure its future drinking water needs. Additionally, when staffdiscussed the potential for reuse of the Savage Well, we were always directed to find other water sources due to the well not having the proper protective radius and due to the nature of its commercial and industrial environment. Of concern to the State was the existence of a major highway and an active railroad which

Town Hall ? Union Square ? Milford, NH 03055 ? (603) 673-2257

Julie Belaga, Savage Well Site

Page 2

increases the potential of an environmental accident. In 1985, after the Savage Well was removed from our system capacity, the Town's analysis of Milford's average daily pumping demand versus total system capacity, without Curtis Well 81, would fall short of meeting State standards by 27%. As a result of this, the Town of Milford and the State Water Supply Division looked at other long term alternatives for the Town. The future status of aquifers in Milford was characterized as follows...

"...with the exception of the Curtis well field, the status of the various aquifers is highly uncertain and will probably continue to be uncertain for the next 2-5 years. Even if continued use with clean up and/or treatment is ultimately considered appropriate, the Savage and Keyes Aquifers will continue to indefinitely be exposed to some risk of contamination due to the high level of industrial and commercial activity on the aquifers; this risk should be a factor in defining the role of these aquifers as future primary supplies for Milford..."

The State advised the Town that long-term alternatives for supplying water to Milford were very limited, and serious consideration should be given to out-oftown alternatives. Four options were identified by the State of New Hampshire Water Supply Division; the most viable one being "...construction of a water main and booster pump station to connect the Milford water system to the Pennichuck Water Works." As such, State officials steered the Town in the direction of finding a safer and more reliable source of drinking water. This was accomplished by entering into an agreement, on 8 June 1987, with Pennichuck Water Works. This agreement will allow the Town of Milford up to two million gallons of water a day.

It is important to note that our decision was based on cost, source reliability, water quality, ability to meet long-term demand requirements, ability to implement, and complexity and safety of operation. The ability to flexibly meet long term quantity and quality requirements was and is the key factor. This Pennichuck agreement insures the Town that a safe potable water supply source, is available for several years hence.

The Milford Boprd of Selectmen has recently been commissioned, to provide the forthcoming town meeting, with a comprehensive analysis of the financial and technical future of the water needs of the Town of Milford. We view this as part of our long range planning/master plan activities. In this study, we assess our municipal water supply on a qualitative and quantitative basis. Milford's water supply is presently derived from three sources; Curtis Wells, Kokko Well, and the Pennichuck Water Works. The three sources presently provide the Town with 2.68 MGD. Upon the upgrading of the Pennichuck booster pump station this will be increased to 3.25 MGD. Under a present estimated maximum daily consumption of approximately 1.5 MGD and an estimated year 2000 maximum daily consumption of 1.9 MGD, it is apparent that the overall supply capacity of Milford is sufficient for some time to come. It is necessary also to determine

the adequacy of supply in the event of the loss of a major water source. Under this emergency scenario, the single largest supply (Curtis Wells) is taken out of consideration and reserve capacity determined, based on full scale operation

Julie Belaga, Savage Well Site

Page 3

of the remaining sources (all sources operating 24 hours daily). Upon elimination of the Curtis Wells, it is found that a reserve supply capacity of 1.7 MGD remains. Under the present average daily demand of 0.8 MGD and corresponding maximum daily demand of 1.5 MGD, the Milford supply is adequate. When the Pennichuck pumps are upsized, the supply capacity is found to be adequate for the year 2000. Thus, the Savage Well is not necessary to satisfy either short range or long range needs. Combining this data with the fact that this area of Town is planned for further expansion of our industrial area and the State of New Hampshire's repeated reluctance to consider, under today's standards, the Savage Well as an acceptable municipal water source, we do hereby request the EPA to choose a course of action in line with this philosophy.

The Town is aware that nine evaluation criteria will be used to standardize the detailed evaluations. These criteria serve as the basis for the feasibility study and subsequent selection of the EPA's preferred alternate. We know that the criteria for State and Community acceptance are normally used to modify the EPA preference for a remedy after the first seven produce a "balanced" remedy. We feel that our Community and State criteria must carry more weight than is the norm. The Board of Selectmen has deep concern that the option finally selected be balanced and holistic in nature from a community impact perspective and, as such, ask that the followings points be considered in the decision making process and that this correspondence be made part of the permanent record.

1. Two of the four PRP'S are out of business in Milford.

2. There is no current exposure risk to human health at the site, the only risk being possible future use of the groundwater for drinking water.

3. The Town and the State would lose over 1000 jobs, tax revenue, damage local business and could result in 500 individuals being added to the Town welfare roles.

4. The Town requests a cost-effective remedy that will allow the remaining companies to survive, remain viable in their traditional market share, prosper and expand.

5. State standard's would preclude the siting of a drinking water well in the Savage aquifer, regardless of how clean the water was, because it is an industrial zone, close to highway and rail.

6. The Town has adequate available water supplies, thus eliminating the need for a rapid and, therefore, expensive remediation.

7. We currently believe the best use of this aquifer is for industrial and commercial use, not for drinking water. This is especially true given the Town's goal of developing further industrial activity in this part of Town.

The Town and its Board of Selectmen wants EPA to recognize our deep concern in fashioning a cost-effective and reasonable remedy for the Savage Well Site, as is required by EPA'S own regulations. We are aware that two of the PRP's, Hitchiner Manufacturing Company and Hendrix Wire and Cable, are prepared to pay for a significant portion of the clean-up, even though the most contaminated

Julie Belaga, Savage Well Site

Page 4

area is not on their property. We believe that it would be wrong, and not in the spirit of current legislation, to expect them to pay for the entire remediation but rather that Superfund monies be used to cover costs outside of the costs that the aforementioned companies are prepared to commit to.

Milford has always dealt with its problems in a cooperative and responsible manner. This is a community issue and we wish to deal with it in that manner. It would be a crime to damage our community with an unworkable solution.

For your consideration, we thank you in advance. Please feel free to contact any of us or our Town Administrator, Lee F. Mayhew, if you have any questions.

Very truly yours,

MILFORD BOARD OF SELECTMEN,

Richard Mace Sr.,Chairman

Richard Medlyn, Vife\Chairman

Rosario Ricciardi

Peter Leishma/i

Ifm/r 27.5.91

CF: Richard Goehlert, EPA Commissioner Robert Varney Philip J. O'Brien, Ph.D William Drescher, Esquire Gregory H. Smith, Esquire Daniel Coolidge, Esauire

 ................
................

In order to avoid copyright disputes, this page is only a partial summary.

Google Online Preview   Download