DEVINE & NYQUIST · 2018-09-12 · devine & nyquist attorneys at law 66 hanover street daily mirror office building p.o. box 1540 manchester, new hampshire 03105-1540 lee c. nyquist

DEVINE & NYQUISTATTORNEYS AT LAW

66 HANOVER STREETDAILY MIRROR OFFICE BUILDING

P.O. BOX 1540MANCHESTER, NEW HAMPSHIRE 03105-1540

LEE C. NYQUIST TELEPHONE: (603) 668-5888KEVIN C. DEVINE TELECOPIER: (603) 668-8902COREY BELOBROWT. DAVID PLOURDEMERRICK C. WEINSTEINMAUREEN E. RAICHEHELEN WHITE FITZGIBBON

SENT VIA FAX AND CERTIFIED MAIL

August 9, 1991

Mr. Richard GoehlertU.S. Environmental Protection AgencyWaste Management Division, (HSN/CAN5)J.F. Kennedy Federal BuildingBoston, MA 02203

COMMENTS OF OK TOOL COMPANY. INC. TO THE ENVIRONMENTALPROTECTION AGENCY RE; SAVAGE MUNICIPAL WATER SUPPLY SITE

MILFORD. NEW HAMPSHIRE

On behalf of OK Tool Company, Inc. (OK Tool), I am writing topresent the following comments regarding the RemedialInvestigation/Feasibility Study (RI/FS) submitted by HMM Associatesat the Savage Municipal Water Supply Site (Savage Well Site).I have also attached a letter from Peter J. McGlew, P. E. of AriesEngineering, Inc. containing his comments on the EPA's PreferredRemedial Alternative for the Savage Well Site.

HISTORY OF OK TOOL COMPANY, INC.

In the nineteen thirties Thurston V. Williams purchased apiece of land at what is now the OK Tool plant in Milford. At onetime he operated a gas station on a portion of the land under thename of Monadnock Sales and Service. In 1941 Thurston V. Williamsand Forrest Hussey commenced manufacturing operations at the siteunder the name of "Williams & Hussey". The company manufacturedcontract machinery.

In 1948 the Williams & Hussey partnership was incorporated asthe Williams & Hussey Manufacturing Co., Inc. In approximately1949, the company added a cutting tool manufacturing operation. In1951 the company changed its name to The Williams & Hussey MachineCorporation and that company continued the contract machineryoperations. At the same time, The OK Tool Co., Inc. was formed tohandle the cutting tool manufacturing operations. And in 1980,both companies were merged. At that time, Thurston Williams andForrest Hussey were the principal shareholders of the company alongwith a few minority shareholders who were close friends or family.


Richard GoehlertAugust 9, 1991Page 2

In the early 1980's, Thurston Williams and Forrest Husseybegan looking into selling OK Tool. In 1985 the shareholdersagreed to reorganize the corporate structure of the company bycreating a holding company known as OK Tool Holdings which wouldhold the stock of The OK Tool Co., Inc. and the shares of anothercompany, the Crafts Company, which had manufacturing plants inMassachusetts and Illinois. OK Tool Co. had bought the CraftsCompany in the late 1970's.

In 1986, the reorganization designed by Thurston Williams tookeffect. During the summer and fall of 1986, Williams negotiatedthe sale of the company to David L. Thun and the DLT AcquisitionCorporation. David L. Thun had been working first as an assistantto Thurston Williams and then as president of OK Tool forapproximately on year. The sale to Thun took place on or aboutDecember 11, 1986. However, by April of 1987, Thun and the DLTAcquisition Corporation were in default of of their financingagreements with the former shareholders. The Holdings shareholdersthen negotiated the sale of Holdings and its wholly-ownedsubsidiaries with John C. Pappas, Jr. A purchase and saleagreement was signed in May of 1987 and, in September, 1987, therewas a closing on the sale to Corinthian Properties, Inc., a companyowned by Mr. Pappas.

In June, 1987, OK Tool Comapany, Inc. sold the Ok Tool productline and manufacturing equipment to Muskegan Tool. Allmanufacturing operations of OK Tool Co. had ceased by the beginningof August, 1987. OK Tool then sold the contract machine productline and manufacturing equipment of the Williams & Hussey Divisionof the company to two Milford residents. By February of 1988, themanufacturing operations of the Williams & Hussey Division hadmoved from the OK Tool plant in Milford to its present location inWilton.

When OK Tool was sold to Corinthian Properties in 1987—somefour years after the contamination at this site was discovered—the only disclosure made to Mr. Pappas was that there wereallegations that a minor contamination problem may exist at thesite and that upon further investigation the company would becleared. On those representations, Corinthians bought OK ToolHoldings and its subsidiaries. At the time of Corinthian'spurchase of Holdings and the subsidiaries, the plan was to shutdown OK Tool because it was not profitable and was unable to employany significant number of Milford residents.



When the OK Tool product line and manufacturing equipment weresold to outside interests a significant portion of the monies fromthe sale, almost $300,000, was given to the group of PotentiallyResponsible Parties, including Hitchner, Hendrix and New EnglandSteel Fabricators, to cover OK Tool's share in the EPA RemedialInvestigation/Feasibility Study. The balance of the monies wasused to maintain the building, as well as to support theengineering and legal costs at the site. At the current time, theonly asset of OK Tool is the land and building at the plant siteon Elm Street in Milford New Hampshire.

From the studies at the site it now appears that the priormanufacturing operations and waste management practices of severalcompanies, including OK Tool, may have contributed to thecontamination of the Savage Well aquifer. The same studiesestablish that the manufacturing operations and waste managementpractices of Hitchiner and Hendrix also contributed to thecontamination. To the extent that OK Tool contributed to thecontamination, it was done under the direction and control of theformer shareholders, managers, and operators of the company.

OTHER POTENTIALLY RESPONSIBLE PARTIES

As indicated at the Public Hearing, we were surprised to seethat other PRPs claim that OK Tool was the sole source ofcontamination at this site. Clearly, the scientific studies andother site information indicate that was not the case.

For many years, both Hitchiner and Hendrix dischargedunprocessed waste water into a stream which traveled off of theirproperties. The discharge into this stream is well documented bythe State Files. Hitchner has had a history of fines and problemswith the State regarding waste disposal practices. Hitchiner, infact, paid the consequences of contaminating drinking waterconsumed by cows, which resulted in their death, on a neighboringproperty.

Although Hitchiner claims that its records at this time do notindicate a use of PCE in the past, a number of reports and othersources indicate otherwise. Hitchiner's consultants, Roy F.Weston, Inc., indicate in a Report Of Findings dated March 16, 1984that "Tetrachloroethylene and methyl isobutyl ketone were formerlyused at the plant." (See attached copy of page one of thatreport.)



The State Hydrogeological Study prepared by the N.H. WaterSupply and Pollution Control Commission in January of 1985 alsoindicates that Hitchiner used PCE in the past. (See State Studypage 12).

Hitchiner discharged unprocessed waste for many years into anunlined waste lagoon known as Lake Louise on their property. LakeLouise is well documented on various State Highway maps which havebeen submitted by OK Tool. These maps depict a large ponded areaupgradient of the Hitchiner facility. Former employees ofHitchiner have given statements indicating that unprocessedchemicals were dumped into the lagoon at the direction of LouisGuertin, the Plant Supervisor. The statements further indicatethat they recall Hitchiner's use of PCE or Perc at least in the1970's. These statements have also been provided to the EPA by OKTool.

Under extreme pressure from Hitchiner and its legal counsel,HMM's RI/FS totally avoided any study of the Lake Louise area. Forinexplicable reasons, not one monitoring well and not one soilboring was placed in the area. This is despite the fact thatevidence of its existence was provided to the our consultantsshortly after the study was commenced.

Hendrix clearly admits to using TCA, one of the contaminantsof concern at this site. In addition, Hendix dischargedunprocessed waste water into a discharge stream that flowed off ofits property toward the Savage Well.

REMEDIAL INVESTIGATION/FEASIBILITY STUDY

The site Remedial Investigation report indicates a source ofPCE contamination in the vicinity of the OK Tool facility north ofElm Street and other possible PCE sources to the south of ElmStreet. The Feasibility Study reported an additional potentialPCE source in the vicinity of monitoring well MW-20 locateddowngradient from the Hendrix facility.

A source is a release of contaminants to the soils and groundwater. The PCE released to the Savage Well aquifer may haveincluded both non-aqueous phase PCE solvent and traceconcentrations of dissolved PCE solvent. According to the RemedialInvestigation ground water contour elevation and flow directionfigures, ground water does not flow from the OK Tool Companybuilding to the south of Elm Street where the HitchinerManufacturing Company facility and Hendrix Wire and Cable facilityare located.



According to the Remedial Investigation the ground waterelevation contours and flow direction figures were developed whilethe Hitchiner Manufacturing Company and Hendrix Wire and CableCompany production wells were operating. Further, the changes inthe ground water flow directions during operation of the formerSavage Well would result in a easterly groundwater flow directionmaking it less likely for PCE contaminated ground water to flowfrom the OK Tool facility to the Hitchner and Hendrix facilities.Therefore, dissolved PCE migrating with ground water from the OKTool Company facility source should not result in contaminating theground water at the Hitchiner Manufacturing Company and HendrixWire and Cable Company facilities.

The 1985 DBS Hydrogeologic Study Report of the Savage WellSite reported that Hitchiner Manufacturing Company had used 1,1,1-trichloroethane (TCA) in their process and also used PCE in thepast. Many New England facilities used PCE as a solvent andindustrial degreaser from the 1950s to the late 1970s beforechanging to the less toxic TCA in the late 1970s and early 1980s.Hitchiner Manufacturing has indicated that their records includethe purchase of at least two 55-gallon drums of PCE. Just onegallon of PCE, if dissolved in ground water, could contaminate upto 100 million gallons of ground water at a concentration of 10parts per billion which is twice the EPA drinking water standardfor PCE.

Based on the Remedial Investigation and Feasibility Studyreports and DBS report information, it appears that HitchinerManufacturing and Hendrix Wire and Cable Company have PCEcontaminated ground water on their properties south of Elm Streetthat may be due to their past operations or waste managementpractices.

OK Tool concurs with the EPA in its letter dated March 14,1991 regarding the Revised RI dated February 6, 1991, Sections 1through 5. In that letter, the EPA expressed concern over the"unusual amount of bias in the presentation of the data and theconclusions drawn from the data." (emphasis added) The EPAcorrectly points out that statements about OK Tool "always have atone of being factual. . . [h]owever whenever speaking about the otherpossible sources, the tone is always speculative." The Study showsa bias against OK Tool and clearly favors the other PRPs regardingsources of contamination.



CONCLUSION

The contamination of the Savage Well was discovered in 1983.Since that time the entire Savage Well site including themanufacturing operations of all companies in the vicinity have beenunder the careful watch and control of the N.H. Department ofEnvironmental Services and the EPA.

According to the available records, OK Tool began shippingits chemical wastes off the property to appropriate disposal sitesin accordance with State and federal law in the late 1970's andearly 1980s. In addition, the Company ceased using or purchasingPerchloroethyne (PCE) in 1984.

Clearly, the current ownership did not participate in and hadno control over the prior manufacturing and management practicesthat may have contributed to the problem. In fact, the currentowner of OK Tool, along with Hitchiner and Hendrix, have filed alawsuit against the past owners and operators of the OK Tool Co.seeking contribution from them for the damage they have done to theaquifer. Any assistance that the EPA can provide in that endeavorwould greatly increase the likelihood of causing the people who areactually responsible for the problem to pay for its remediation.

However, it is equally clear from the RI/FS that bothHitchiner and Hendrix also made significant contributions to thecontamination of the site. Their assertions of absolute innocenceand pristine sanctity with regard to the site are as offensive asthey are false. Moreover, their manipulation of the RI/FS,particularly in avoiding study of the former Lake Louise (whoseexistence Hitchiner has even flatly denied) is reprehensible.

Consequently it is with a fair degree of skepticism that OKTool views the results of the RI/FS and with outright contempt thatit views Hitchiner's and Hendrix's assertions of virtual innocenceregarding the site.

However, OK Tool would urge the EPA to select a remedy thatwill not bankrupt the remaining companies. The result would onlyput hundreds of Milford and area residents out of work.



Thank you for your attention to this matter. I would be happyto answer any questions or concerns that you may have.

Very Truly Yours,

Maureen E. Raiche

MER/remcc: John Pappas

Thomas E. Roy, P.E.Peter J. McGlew, P.G.

ENGINEERING, INC. Sgl a %£**' ̂Joseph M. Vercellotti, P.E.

ARIESENGINEERING, If

environmental engineers & hydrogeologists

August 6, 1991File No. 89030

Attorney Maureen RaicheDevine & Nyquist66 Hanover StreetDaily Mirror Office BuildingP.O. Box 1540Manchester, NH 03105-1540

Re: EPA Preferred AlternativeSavage Well Site,Milford, New Hampshire

Dear Attorney Raiche:

In accordance with our discussions, Aries Engineering, Inc.(Aries) is submitting the following comments on EPA's PreferredRemedial Alternative for the Savage Well Site (site) in Milford,New Hampshire.

Aries reviewed the EPA's "Savage Well Municipal Water SupplySite Proposed Plan," dated July 1991, in which the EPA presents thesite preferred remedial alternative. The EPA preferredalternative, known as MM-11A, proposes to pump and treat groundwater in both the concentrated and extended volatile organiccompound (VOC) ground water contaminant plumes. EPA's preferredground water extraction alternative includes one ground waterextraction well at the OK Tool Company pumping at a rate of 250gallons per minute (gpm), one ground water extraction well atHitchiner Manufacturing Company pumping at a rate of 150 gpm, andfour ground water extraction wells in the extended ground watercontaminant plume pumping a total rate of 700 gpm.

Aries' comments on the EPA preferred alternative follow.

Concentrated Ground Water Contaminant Plume

The preferred alternative proposed ground water extractionpumping rate at O.K. Tool would likely capture large amounts ofSouhegan River water. Based on Remedial Investigation (RI) data,Aries estimates the non-pumping ground water flux across the OKTool site is less than 100 gpm. Ground water flux is the volumeper unit of time of ground water flowing through a section of

46 South Main Street • Concord, NH 03301 • 603-226-2545 • FAX: 6C3-226-0374

Devine & Nyquist - August 1991 - File No. 89030

aquifer. Because the Souhegan River is a losing streamhydraulically upgradient to O.K. Tool, increasing ground waterpumping rates at O.K. Tool would likely increase river watercontribution to site ground water flux. This induced infiltrationwould increase ground water flux across the site and a groundwater pumping rate of 250 gpm, river water could make up as much as70% of the water treated by the OK Tool ground water treatmentsystem.

The increase in non-contaminated river water pumped by theextraction well would result in an unnecessarily large capacityground water treatment system and thereby reduce ground watertreatment efficiency.

The RI indicates that there may be possible Dense Non-AqueousPhase Liquid (DNAPL) residual sources at the OK Tool site.Feenstra (1990)' indicates that DNAPL cleanup is limited by the lowsolubility of separate phase DNAPL in ground water. Because of theDNAPL low solubility limitation, increasing the site ground waterflux will not shorten the cleanup time because DNAPL dissolvesslowly in ground water and is difficult to directly remove.Feenstra (1990) estimates DNAPL source lifetime in the subsurfaceto be on the order of decades to a hundred years.

Increasing the ground water flux rate may shorten the cleanuptime for dissolved, mobile contaminants. However, based onresearch by Feenstra (1990), a higher ground water flushing ratewould not clean up a DNAPL residual source faster than a lowflushing rate.

The location of DNAPL sources deep within the aquifer affectsthe design of ground water extraction well pumping levels andlocations. Aries recommends that multilevel monitoring wells beinstalled at the OK Tool site as part of remediation design. Thepurpose of the multilevel monitoring wells would be to assesssource depths and pumping effects at discrete depths in theaquifer.

Source area extraction wells pumping at the depths of DNAPLsources would improve ground water extraction/treatment systemefficiency. The benefits would include:

o Lower ground water pumping rate.

1 Feenstra, S., 1990. Dissolution of Immiscible Phases.Proceedings of DNAPLs in Porous and Fractured Media short course.Waterloo Centre for Groundwater Research.


o Higher contaminant removal rate per volume of watertreated.

o Less adverse impact on other hydrologic systems includingwetlands, streams and the Souhegan River.

o Less treated ground water to discharge.

The remedial design should include ground water modeling toassess pumping rates, ground water capture zones, contaminantattenuation, and potential ground water contaminant plumemigration.

Extended Ground Water Contaminant Plume

The EPA preferred alternative, includes extended ground watercontaminant plume ground water extraction wells No. 2, No. 3 andNo. 4 located near the Souhegan River. The EPA extended groundwater contaminant plume extraction well No. 2 proposed pumping rateis 300 gpm, while EPA proposes pumping ground water extractionwells No. 3 and No. 4 at rates of 50 gpm each.

Because of the high ground water extraction well No. 2 pumpingrate of 300 gpm and its proximity to the Souhegan River, it willlikely capture significant amounts of Souhegan River water in theupgradient portion of its ground water capture zone. The EPAextended ground water contaminant plume preferred alternativeobjective is to capture and remove ground water VOC contaminantsmigrating in the eastern-most portions of the Savage Well aquifer.Pumping and treating clean Souhegan River water does not meet theobjective of removing VOC contaminants from the site aquifer.Further, pumping non-contaminated Souhegan River water with thehigh ground water extraction well No. 2 pumping rate results in anunnecessarily large capacity ground water treatment system andthereby reduces ground water treatment efficiency.

Aries' recommends that ground water extraction well No. 2 berelocated to avoid treating non-contaminated Souhegan River water.Relocated, the ground water extraction well should result in adecreased ground water treatment plant design capacity andincreased ground water treatment plant cost effectiveness.

EPA proposes to locate ground water extraction wells No. 3 andNo. 4 adjacent to the north side of the Souhegan River andapproximately 100 feet south of Purgatory Brook, where it flowsparallel to the Souhegan River. Therefore, ground water extractionwells No. 3 and No. 4 are surrounded by surface water. Thelocations of ground water extraction wells No. 3 and No. 4 willadversely affect their contaminated ground water extractionperformance in the following ways:


o Surface waters surrounding extraction wells No. 3 and No. 4will reduce the estimated ground water capture zones byrecharge of clean surface water to the extraction wells.

o Because ground water extraction wells No. 3 and No. 4 arelocated north of the Souhegan River, extraction well operationwill likely result in inducing VOC contaminated ground waterflow to the North of the Souhegan River.

Therefore, better VOC contaminated ground water extractionwell locations should be considered. Aries recommends pumping atground water extraction well No. 1 in the Savage well vicinity toeffectively cut-off and capture the highly contaminated extendedground water contaminate plume areas that would otherwise migratedowngradient towards ground water extraction wells No. 3 and No. 4.Remedial design studies including ground water modeling andtreatability studies should be conducted before selecting finalsite extraction well locations to capture extended ground watercontaminate plume.

RI data and past site area waste management informationindicates that the extended ground water contaminant plume may beapproaching steady state conditions, and that ground water VOCconcentrations will change little with time. EPA indicates thatportions of the extended ground water contaminate plume not inground water capture zones would undergo natural attenuation andVOC contaminants flowing north and east would be diluted in theclean portions of the aquifer or be discharged into the river wheremuch of the VOC contamination would be expected to decrease. TheEPA estimates the extended ground water contaminant plumeconcentrations would decrease to drinking water standard-concentrations within 25 to 90 years through natural attenuationwithout pumping and treating.

The outlying extended ground water contaminant plume in thevicinity of ground water extraction well No. 2 VOC concentrationsare similar to the other areas in which EPA will allow non-treatedcontaminated ground water to naturally attenuate. Aries recommendsthat attenuation of the outlying extended contaminant plume beimplemented and ground water extraction well No. 2 be deleted.Further, Aries recommends that ground water extraction well No. 1be better located and the ground water pumping rate be reassessedto replace ground water extraction wells No. 3 and No. 4.

The site Risk Assessment (RA) summary provided in the FSdiscusses potential health risks associated with drinking siteground water. The RA concludes the commercial fish hatchery watersupply wells north of the Souhegan River had low VOCconcentrations and the initial RA indicated low health risk impact.

Devine & Nvcruist - August 1991 - File No. 89030

It is noted that the low VOC concentrations in the fish hatcherywater supply wells would be further reduced or removed prior to usebecause the water is aerated which allows residual VOCs tovolatilize. Further, VOCs were not reported in residential wellsnorth of the river that have been tested. RI data indicates thatresidential water supply wells north of the Souhegan River are nothydraulically downgradient of the extended ground water contaminantplume and EPA recommends continued ground water monitoring north ofthe Souhegan River. Because the area south of the Souhegan Riveris supplied drinking water by the municipal water system, there isno documented VOC contamination of residential drinking water wellsnorth of the Souhegan River, and the residential drinking waterwells north of the Souhegan River are not hydraulicallydowngradient of the extended ground water contaminant plume, thereis no apparent exposure to or resulting risk from ingestion of VOCcontaminated ground water.

According to Comprehensive Environmental Response,Compensation, and Liability Act (CERCLA) 40 CFR Section 121d(2)(B)(ii), the site ground water can be treated to 1) backgroundlevels, 2) Maximum Contaminant Levels (MCLs) or 3) AlternateConcentration Levels (ACLs). Attainment areas are designated areaswhere the selected ground water clean up levels will be attained.According to Guidance on remedial actions for contaminated groundwater at Superfund sites (EPA -540-G88 003) CERCLA regulationsallow the aquifer restoration time frame to be driven by practicallimitations imposed by site specific factors such as ground waterplume size, aquifer transmissivity, multiple contamination sources,and contaminant distribution patterns. The base for a longerremediation time frame is the provision of an alternate watersupply, ability to monitor and control the site contamination, andthe use and value of site ground water.

The suitability of site remediation as discussed in the RI andFS is limited because of the likely presence of subsurface DNAPLsources. The presence of DNAPL sources may result in anexcessively long aquifer restoration time. The following sitecharacteristics, consistent with EPA Guidance and CERCLArequirements, indicate a long time frame restoration with limitedtreatment at the sources is warranted:

o The ground water VOC contamination appears due tomultiple sources and results in a widespread ground watercontaminant plume likely emanating from several DNAPL sources.DNAPL source remediations are currently limited to containment typetreatment options.

o The site hydrogeology is complex with several surface waterbodies present, and industrial wells or water supply wellswithdrawing ground water from the aguifer further complicating

Devine & Nvquist - August 1991 - File No. 89030

ground water flow.

o An alternate water supply is in place and only one currentpotential receptor, the commercial fish hatchery wells, hasbeen reported in the site FS. The FS indicates that thepotential environmental impact to the fish hatchery watersupply wells is low.

o The ground water contaminant plume limits have been studiedand it is apparent that limited pumping and treatment can beconducted to contain the source areas.

o The locations of surface water bodies will limit thepumping rate from the OK Tool Company extraction well and willinterfere with the efficient operations of extended groundwater contaminant plume extraction wells No. 2, No. 3, and No.4.

Therefore, Aries recommends that ground water extraction andtreatment at the OK Tool Company, Hitchiner Manufacturing Company,sites and in Savage Well vicinity downgradient from Hendrix Wireand Cable Company be conducted. The remaining less concentratedground water contaminant plume areas not effected by pumping andground water treatment should be allowed to attenuate naturally asthe EPA is suggesting for other site VOC contaminant plume areas.Remedial design studies with ground water modeling, pumping testsand treatability studies should be conducted to assess theappropriate locations of the extractions wells, and monitoringwells effective pumping rates; and appropriate treated ground wateruses which could include industrial or water supply use.

Sincerely,Aries Engineering, Inc.

Peter J. McGlew, P.G., C.G.W.P.Chief Hydrogeologist

PJM/dep

r/

i.

REPORT OF FINDINGS

HYDROGEOLOGIC^ANDWATER QUALITY INVESTIGATIONS

16 March 1984

HITCHINER MANUFACTURING CO.MILFORD, NEW HAMPSHIRE

ROY F. WESTON, INC.2 Chenell Drive

Concord, New Hampshire 03301

1526-08-01

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SECTION 1

INTRODUCTION

1.1 PURPOSE

I n v e s t i g a t i o n s were conduc ted to d e t e r m i n e hydrogeo log iccond i t i ons as well as g round and surface water quality in thev i c i n i t y of the H i t c h i n e r M a n u f a c t u r i n g Company facility inM i l f o r d , New H a m p s h i r e . The inves t iga t ions were designed to

/assess the real or potential effects of Hitchiner's operation onS wa te r q u a l i t y and also to identify any ground or surface waterX con tami nat i on entering onto Hitchiner property that could affect

*L,the quality of process and discharge waters at Hitchiner.

1.2 Background

In F e b r u a r y 1983, the New Hampshire Water Supply and PollutionCont ro l Commiss ion ( N H W S P C C ) , d u r i n g r o u t i n e water qualitym o n i t o r i n g o f the Savage W e l l , f o u n d th i s source to becontaminated by volatile organic compounds. The Savage Well is am u n i c i p a l water supply for the Town of Milford, and the level ofc o n t a m i n a t i o n was such as to have poss ib le a d v e r s e healthe f f e c t s . Consequently, the well was shut down and to this dater e m a i n s ou t o f s e r v i c e . In s e e k i n g ou t the source o fc o n t a m i n a t i o n , NHWSPCC considered the regional groundwater flowpath and immediately suspected the cluster of industries on Route101A s i t u a t e d u p g r a d i e n t f r o m the Savage Wel l . BesidesH i t c h i n e r , these establishments include Hendrix Wire and Cable,OK Tool, New Eng land Steel Fabricators, and a number of smallercommercial businesses.

A n a l y s e s of samples t aken in February and May 1983 by NHWSPCCshowed H i t c h i n e r ' s industrial production well to be contaminated

.by 1.1,1-trichT nrpethane, tetrachloroethvlene , transjdichlorQ-p t h y l e n e , and t r i chl or oe thylene. In addition to the first twos u b s t a n c e s , s u r f a c e d i s c h a r g e s c o n t a i n e d v a r i o u s levels of11\ ~,<M ch j lo r o e t h a n e . a ce tone , m e t h y l ethyl ketone/ and methyli s o b u t v l k e t o n e ( A p p e n d i x A , N H W S P C C r e p o r t ) . O f these

~~ ~f only(l, 1,1-trichloroethane^and a<subs t ances , onlyQ., 1', 1-trichloroethane)and acetone are presentlyused by Hitch>ifer. Te t r a chl or oe t:ketone were fxfrmerly used at the plan,t.used by Hi tch^-ifer . T^fc ra chl oroe^_h yi ^J"* ^ n^ met-hyi—L&obu-ty-l-

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DEVINE & NYQUIST · 2018-09-12 · devine & nyquist attorneys at law 66 hanover street daily mirror office building p.o. box 1540 manchester, new hampshire 03105-1540 lee c. nyquist