^-r—-v? r.r,~j.Vj [ALLIANCETechnologies Corporation ^, - •• , • ,
./" / — T~c I ". ......__... ^.^_
June 24, 1992
Attorney Lloyd SelbstU.S. Environmental Protection AgencyAssistant Regional CouncilJFK Federal Building, RCT-23Boston, Massachusetts 02203
Reference: Contract No. 68-W9-0003, TES 6Worlc Assignment No. C01155Fletcher's Paint WorksPotentially Responsible Party Search(Ref. l635-293)
Si—-: t'uiui Rvcu idb
I5KI:Ak:Ol KLk:
Subject: Deliverable:
Dear Mr. Selbst:
Interview Report No. 4
As directed by the EPA Work Assignment Manager, enclosed is a copyof the Interview Report No. 4 for the Fletcher's Paint Works site,Milford, New Hampshire.
The interviews were conducted by the Blake investigative Agency, aTES -6 Team member, from May 8, 1992 to May 16, 1992. A copy of anaffidavit obtained during this period is provided in appendix A.A copy of the Interview Reports are included in Appendix B. Thissubmit tal satisfies a deliverable requirement for this WorkAssignment and is an Attorney Work Product, prepared inanticipation of Litigation.
Questions regarding this submission should be directed to theAlliance Project Manager, Martha Sparlin at (508) 970-5757 ext5266.
Sincerely yours,
Martha SparlinProject Manager
MS /egEnclosure
cc: Mary H. Grealish/EPA Regional Project Officer (letter only)Cheryl Sprague/EPA Work Assignment ManagerNancy Toy/TES-6 Contracting Officer (letter only)William J. Farino/Alliance Regional Manager (letter only)
813453
INTERIM DELIVERABLEINTERVIEW REPORT NO. 4
FLETCHER'S PAINT WORKSPOTENTIALLY RESPONSIBLE PARTY SEARCH
MILFORD, NEW HAMPSHIRE
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCYWaste Management Division
JFK Federal BuildingBoston, Massachusetts 02203
Work Assignment No.:EPA Site/Facility I.D. No.:
Contract No.:Alliance Document No.:Alliance Project No.:
Alliance Project Manager:Alliance Telephone No.:
Subcontractors:-TechLaw-Temple Barker & Sloane
-Blake Investigative Agency
EPA Work Assignment Manager:Telephone No.:Date Prepared:
C01155
NHDOO1079649
68-W9-0003 (TES-6)A92-8141-635-293-0-1BD1-0
Martha Sparlin(508) 970-5600
Kimberly Rees (617) 720-0320
Marc Blaustein (617) 861-7580
Marty Blake (617) 479-0113
Cheryl Sprague(617) 573-9624June 24, 1992
RECYCLED PAPER
ALLIANCE TECHNOLOGIES CORPORATIONBoott Mills South
Foot of John StreetLowell, Massachusetts 01852
(508) 970-5600
ENFORCEMENT CONFIDENTIAL
Privileged WorkProduct Prepared in
Anticipation of Litigation813454
TABLE OF CONTENTS
Section Page
1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
2.0 PROJECT APPROACH . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
3.0 RESULTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Appendices Page
A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A - l
B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-l
TABLES
Number Page
1 Interview Contacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
A92-814.txt
RECYCLED PAPER ENFORCEMENT CONFIDENTIAL
PrMtogtd Worknroduct Pteparf i
Anticipation of Litigation
813455ALLIANCE
Privileged WorkProduct Prepared in
!.» PRODUCTION Anticipation of IJBgaBonThe following Draft Interview Report No. 4 is prepared under EPA Contract No. 68-W9-0003, (TES-6) Work Assignment No. CO 1155. EPA requested assistance toconduct interviews detailed in Alliance Technologies Revised Work Plan No. 1, datedMarch 4, 1992.
As part of the assignment, Alliance was requested by EPA to conduct additionalinvestigative work which included obtaining a signed affidavit by Mr. Elmer Cozzens,a former employee of General Electric, and conducting several interviews ofindividuals who have knowledge of the operations and procedures at the SpragueElectric facilities located in Kingston, New York, and North Adams, Massachusetts.This report provides the results of those interviews.
Blake Investigative Agency (BIA) was tasked by Alliance to conduct the interviews asspecified by the EPA approved Work Plan (Task 5) dated October 14, 1991. At therequest of EPA, Alliance is submitting the BIA interview reports unedited. Allianceacknowledges that some or all of the reports may contain some typographical errors,and therefore are being submitted as DRAFT reports. Corrections to these reports willbe made prior to their inclusion into the Final Report for this site.
2.0 PROJECT APPROACH
Alliance directed Blake Investigative Agency (BIA) to conduct interviews of formeremployees of Sprague Electric. This report presents the results of BIA's effortsconducted from May 8 to May 16, 1992.
3.0 RESULTS
Blake Investigative Agency personnel travelled to North Adams, Massachusetts tointerview one previously identified former employee of Sprague Electric who mightpossibly provide information pertaining to its operations.
The original interviewee provided additional leads which resulted in BIA personnelconducting a total of ten new interviews.
A total of eleven individuals were interviewed during this period. Table 1 providesthe names of the individuals interviewed and the date on which the interview occurred.Mr. Cozzens was included in the Table as BIA personnel revisited him to obtain thesigned affidavit of information provided during a previous field investigation. A copyof the document identified as the affidavit of Elmer Cozzens is attached to this reportas Appendix A. The original affidavit was submitted to the EPA WAM by BIApersonnel. BIA's investigative reports are provided in Appendix B.
A92-814.txt 1 SI 3 4 56
mRECYCLED PAPER ENFORCEMENT CONFIDENTIAL l± ALLIANCE-
TABLE 1. INTERVIEW CONTACTS
Privileged WorkProduct Prepared in
Anticipation of Litigation
Name Date Result Employer
Stanley Bagdon
Joe Bianchi
Florence Clough
Elmer Cozzens
Lou Damiano
Emile Jobin
John Rosse
5/12/92 Interviewed
5/10/92 Interviewed
5/16/92 Interviewed
5/13/92 InterviewedAffidavit
5/14/92 Interviewed(Telephone)
5/15/92 Interviewed
5/12/92 Interviewed
5/16/92 Interviewed
5/15/92 Interviewed
Sprague ElectricNorth Adams, MA - 1943-1978
Sprague ElectricNorth Adams, MA - 1950-1982
Sprague ElectricNorth Adams, MA - 1942-1979
General ElectricBurlington, VT - 1951-1956Hudson Falls, NY - 1956-1987Ft. Edwards, NY
Sprague ElectricNorth Adams, MA - 1942-1972
Sprague ElectricNorth Adams, MA - 1951-1979
Sprague ElectricNorth Adams, MA - 1950-1977
Sprague ElectricNorth Adams, MA - 1941-1979
Sprague ElectricNorth Adams, MA - 1936-1980
A92-814.txt
RECYCLED PAPER ENFORCEMENT CONFIDENTIAL
S13457Xrt ALLIANCEf4*f4f^ Technolr.i.rsCoioO'awn
TABLE 1 (CONTINUED)
Privileged WorkProduct Prepared In
Anticipation of Litigation
Name Date Result Employer
James Smith 5/8/92 Interviewed
Peter Wol 5/9/92 Interviewed
Sprague ElectricKingston, NY - 1953-1957Nashua and Concord, NH -1959-1980
Sprague ElectricNorth Adams, MA - 1955-1969
1980-1987Visalia, CA - 1969-1972Nashua, NH - 1972-1975
A92-814.txt
RECYCLED PAPER ENFORCEMENT CONFIDENTIAL
913453
ALLIANCE
Twelve additional names have been obtained as a result of this investigative effort. However,five of the twelve have been determined to be deceased. It is anticipated that BIA will attemptto contact the remaining seven after discussion with Alliance and EPA, to determine whether ornot current employees of General Electric and Sprague Commonwealth may be interviewed.
area.1. Larry Mareau - Believed to be in2. Vincent Tassone - Believed _______3. John Ager - GE employee ^^^^^^ - not contacted.4. Ted Candilaro - Sprague Electric employee - not contacted.
6. Bob Hayes - Security Guard - Sprague Commonwealth, not contacted.7. Walt Maynard - Believed to be inl
Privileged WorkProduct Prepared in
Anticipation of LitigationA92-814.txt
RECYCLED PAPER ENFORCEMENT CONFIDENTIALS4W4
313459ALLIANCETecnno»og»es Co potation
APPENDIX A
A92-814.txt
Privileged WorkProduct Prepared in
Anticipation of Litigation
A-I 813460RECYCLED PAPER ENFORCEMENT CONFIDENTIAL ^ ALLIANCE
Technologies Co'uoralion
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813462
APPENDIX B
Privileged WorkProduct Prepared in
Anticipation of Litigation
313463RECYCLED PAPER ENFORCEMENT CONFIDENTIAL ALLIANCE
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HI _ __ _ __„ _ _ _ _ _
IN ANTICIPATION OF LITIGAiiiENFORCEMENTCONFIDENTIAL"
Details of a conference with Stanley Bag don - 5/12/92
At approximately 11:3O A.M., I met Mr. Bagdon at his home
located at _ _ _ _ ^ ^ ^ ^ ^ ^ ^ ^ ^ lHis telephone number is
He was employed by Sprague Electric, -From 1943
until he retired in 1978. This report was prepared by the Blake
Investigative Agency.
He began work as a Lab Technician and became Production
Foreman, on the -first shift at the Brown St. plant in 1951, where
chloronol was used to impregnate capacitors. The impregnation
department was located in the basement o-f the Brown St. plant.
The process began when paper and foil were wrapped around a
mandrel, after which tabs were welded onto covers. The mandrel
was then placed into a can and a cover was welded onto the can,
which had one small hole in it. This can was degreased and put
into trays or metal baskets and sent to the impregnation
department, where it was placed in a liner, which slid into the
impregnation tank. The liners were 1O' to 12' in length and 3' to
4' in height and filled with baskets of capacitors. After the
liners were placed into the impregnation tanks, the doors to the
tanks were closed and a vacuum was drawn on the tank, while it
was being heated. There were 6 to 7 impregnation tanks, each with
their own vacuum pump. The purpose of the vacuum and heating was
to remove as much moisture from the capacitor as possible, so as
to prevent short circuits within the capacitor. Oil was then
drawn into the liner, under vacuum (see diagram), until all the
capacitors within the liner were covered with oil. The oil level
DRAFT
m^itanley Bagdon Report -5/12/92
by Blake Investigative Agency
in the liner is monitored through a porthole on the tank. The oil
in the liner is then sucked into the capacitors via the small
hole in their covers, after which nitrogen is forced into the
tanks, so that the pressure within the tank is increased, forcing
more oil into the capacitors. If oil overflows the liner, it is
removed through a drain line in the bottom of the tank, after
which it is refiltered and reused.
After the capacitors have been filled with oil, the liner is
removed from the tank, with the oil still covering the
capacitors, and taken to the soldering area, where the hole in
the cover of each capacitor is soldered closed and the oil in
removed from the liner. The capacitors are then degreased and
tested in Post Impregnation.
One of the sources of waste chloronol oil was the soldering
area. The capacitors had lips on them. When they were removed
from the liners, these lips contained oil. When the hole in the
cover of the capacitor was soldered under oil, the oil within the
lip of the capacitor, would become contaminated by the solder. It
could not be refiltered and reused. Each capacitor lip contained
between 1/2 to 1 teaspoon of oil and after they were soldered,
each basket full of capacitors were tipped to drain the oil out
of the capacitor lips. The oil passed through a screen and into a
line, which drained into a 55 gallon barrel. These barrels were,
both open top and bunged, and were removed by the Maintenance
813465 DRAFT
Page III Stanley Bagdon Report - 5/12/92
by Blake Investigative Agency
Department, when -full. He had no knowledge as to the volume of
barrels generated . The barrels, when -full, were placed onto
pallets and removed by forklift.
Another source of waste chloronol also originated at the
soldering station. After the oil was drained from the liners, the
interiors of the liner was cleaned with trichloroethylene. The
residue from this operation which would have been a mixture of
triclor and chloronol, was drained into a bucket, which was
emptied into the screen, which drained into the 55 gallon barrel,
at the soldering station.
When the liners were cleaned at the impregnation station,
this residue of trico and chloronol was emptied into a barrel,
which contained waste pump oil. The waste pump oil would also
contain chloronol and waste, which had been emptied into the
barrel form the vacuum line filter (see diagram).
These barrels which contained waste oil were not labeled,
but they all had funnels in them, through which oil was poured,
and were referred to a junk oil barrels.
He w i l l sign an affidavit containing the aforementioned
i nformation.
313466
DRAFT
Details o-f a con-ference with Joe Bianchi —5/1O/92
At approximately 11:OO A.M., I met Mr. Bianchi at his home
located on ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ H His telephone numbers are
SS # is ^ ^ ^ ^ ^ | He Mas employed by Sprague Electric, -from
1950 until he retired in 1982. This report was prepared by the
Blake Investigative Agency.
He worked at the Brown St. plant in No. Adams, MA, beginning
as a utility man. He became supervisor o-f post impregnation in
1956 and foreman o-f that department in 1958 and remained in that
position, until he retired. Post impregnation involved the
soldering o-f capacitors under oil, degreasing, next testing,
•flash resting, painting, capacity testing, and shipping the
capacitors to the customers.
He said that the Maintenance Department was responsible from
the removal of waste materials, which he believed were sent to
the Salvage Department, located at Marshall St.
DRAFT
513488
Details of a conference with Florence Clough — 5/16/92
At approximately 6:OO P.M., I met Mrs. Clough at her
number is ^ ^ ^ ^ ^ 1 She was employed by Sprague, from 1942
until she retired in 1979. This report was prepared by the Blake
Investigative Agency.
She worked as a secretary in the Purchasing Department, at
Brown St., in the late 1950's and early 196O's. She had no
contact with waste materials.
Larry Moreau, Vincent Tassone, and John Agar worked in the
Brown St. Purchasing Department. Mr. Agar is currently employed
by G.E. in Pittsfield, MA.
or y?:®
SI 3469
Details of a conference with Elmer Cozzens -5/13/92
At approximately 2:00 P.M., I met Mr. Cozzens at his home,
located at ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ Hhfis telephone number is
This report was prepared by the Blake
Investigative Agency.
He was employed by G.E., from 1951 until he retired in 1987.
He worked at the G.E. plant in Burlington, vT, from 1951 until
1956, and at the Hudson Falls and Ft. Edwards, NY plants, from
1956 until 1987.
He was Supervisor of Accounts Payable, at Hudson Falls which
handled the b i l l i n g of the Scrap and Salvage Department, from
1956 until 1961. His affidavit contains all the information he
would recall, regarding accounts payable and Fletcher Paint.
DRA! "T
o13470
Details of a conference with Lou Damiano - 5/14/92
At approximately 6:30 P.M., I contacted Mr. Damiano at his
home via telephone. He resides at
his telephone number is ^ ^ ^ ^ ^ ^ H and his D.O.B. is
He was employed by Sprague Electric, from 1942 until he
retired in 1972. This report was prepared by the Blake
Investigative Agency.
He worked at the Brown St. plant in the Maintanence
Department, as an electrician. He said that barrels of junk oil,
from the impregnation department, were stored in the outside yard
area of the plant. He though that they were removed by Sprague
owned trucks, but was not definite on this point.
He said that Tony Waslonski, Art Caron, and Frank Fortini
worked at the Brown St. plant. I have determined that these men
are deceased.
'f RMIEGED WORK PRODUCT PREPARED.TIC!?,,,,r •!» f\ \\ »^"n *"*x vi
T CONFIDENTIAL"
SI 3 4 71
Details of a conference with Marie Dargie _ 5/15/92
At approximately liOO P.M., I met Mrs. Dargie at her home
located at ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ 1 Her telephone number
i s ^ ^ ^ ^ | her D.O. B. is^ ^ l and ner ss * is
She was employed by Sprague Electric, -from 1951 until
she retired in 1979. This report was prepared by the Blake
Investigative Agency.
She began work in No. Adams as a Stock Clerk and entered the
Purchasing Department in 1955. From 1955 until 1962, she was in
Material Control, whose job was to inform the Purchasing Agent,
what raw material were needed by Production. From 1962 until
1967, she was the assistant Purchasing Manager, who placed all of
the orders for all of the materials needed by Production. From
1967 until 1977, she was the Purchasing Manager, who was in
charge of the entire Purchasing Department.
The removal of waste chloronol was handled by the Scrap and
Salvage Department. Each plant in No. Adams had their own Scrap
and Salvage Department. There were 4 Sprague plants in No. Adams
located on Brown St., Marshall St., Beaver St., and Union St.
Brown St. was the only plant, which used chloronol. Beaver St.
and Union St. manufactured non—chloronol capacitors, marshal 1 St.
was the largest plant and contained corporate offices.
Page II Marie Dargie Report - 5/15/92
by Blake Investigative Agency
Chloronol arrived at the Marshall St. plant in RR cars from
Monsanto, where it was placed into storage tanks. It was then
pumped into a truck, which transported it to the Brown St. plant,
where it was used.
She has never heard of Fletcher Paint. The supervisor of
accounts payable in 195O's and 196O's was Ted Candiloro, who is
still employed by Sprague Electric.
Mrs. Dargie arranged for the disposal of waste chloronol in
the 197O's and said it was transported to New York, for disposal.
In approximately 1987, Sprague Commonwealth purchased the
division, which manufactures non-chloronol capacitors, from
Sprague Electric. They are two different companies.
IMLEGED WORK PRODUCT PREPAREDICIPOT OF LITIGATION
1ENT CONFIDENTIAL"DP/Si 34 73
Details o-f a conference with Emile Jobin— 5/12/92
located on
At approximately 6:OO P.M., I met Mr. Jobin at his home
His telephone number is |
and his SS # is
.oyed by Sprague Electric, from 195O until he
retired in 1977. This report was prepared by the Blake
Investigative Agency.
Mr. Jobin worked in the Maintenance Department at the
Marshall St., Brown St., and Beaver St. plants as a millwright.
He said barrels o-f waste oil were stored on the ground outside o-f
the Brown St., plant. The waste oil was handled by the Salvage
Department at Brown St., which was a separate department -from
Maintenance, until the two departments were merged in the mid—
1950's. He had no contact with waste chloronol.
Lou Damiano, John Sargent, John Rosse, and Andy Giargenti
worked in the Maintenance Department. I have determined that Mr.
Sargent and Mr. Giargenti are deceased.
313^74
mmixucu»»unrv rnuuuuIN ANTICIPATION OF LITIGATEENFORCEMENT CONFIDENTIAL1Details of a conference with John Rosse - 5/16/92
At approximately 11:OO A.M., I met with Mr. Rosse at his
home, . His telephone
number is^ ^ ^ ^ ^ H his D.O.B. is^ ^ ^ | nis ss * is
He was employed by Sprague, from 1941 until he
retired in 1979. This report was prepared by the Blake
Investigative Agency.
He worked in the Maintenance Department as a plumber, at
Beaver St. for 1 year, after which he was transferred to Brown
St. , where he remained, until he retired.
Spills of chloronol onto the floor of the impregnation
department would flow into floor drains, which emptied into the
Hoosuc River.
Waste chloronol was put into barrels, which were removed by
forklift from the impregnation department, and stored in the rear
yard of the plant. John Sargent and Bill Cooper operated the
forklift. I have determined that these men are deceased.
Brown St. had a security guard, who operated an electronic
gate, through which trucks would enter and exit the plant. The
guards had a security log book, into which they would write the
names of the trucks, which entered the facility. Brownie Soja and
Bob Hayes worked as security guards. Mr. Hayes is currently
employed by Sprague Commonwealth.
In order to remove material from the Brown St. plant, one
would have to obtain permission from the corporate offices,
located at Marshall St..
913475
Page II John Rosse Report -5/16/92
by Blake Investigative Agency
He has never heard of Fletcher Paint.
Mr. Rosse said that a large number o-f barrels of waste
chloronol were buried in a dump behind the rear fence of the
Brown St. plant and also barrels were disposed of at the No.
Adams town dump.
jfe;-: )
4 78
Details of a conference with George Roy - 5/15/92
At approximately 4:OO P.M., I met with George Roy. He
is ^ ^ ^ ^ ^ 1 his D.O.B. is ^ ^ H and his SS # is
He was employed by Sprague Electric, -from 1936 until he
retired in 1982. This report was prepared by the Blake
Investigative Agency.
He was the supervisor o-f warehousing, which handled all
incoming materials to the plants. Chloronol originally came in 55
gallon barrels and Sprague went to bulk purchasing in the late
195O's. The chloronol always came from Monsanto.
At Brown St., barrels of waste chloronol were removed from
the impregnation department, by the Scrap and Salvage department,
and stored in the yard outside of the building, maybe in a wooden
structure.
Lawrence Moreau was in charge of the Purchasing Department
at Brown St. in the 195O's and 196O's and would have handled the
sale of waste pyranol.
He said that Charles Mil son and Walt Maynard, worked in
Scrap and Salvage. I have determined that Mr. Wilson is deceased.
Mr. Roy said that all of Sprague Electric's records,
including records from the Purchasing Department, are stored in
the basement of Building 15 at Marshall St.
*, p?~a " • ""H ;;
-<~3,
Details o-f a conference with James Smith -5/8/92
At approximately 1:OO P.M., I met Mr. Smith at his home
located at ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ H His telephone number is^H
He was employed by Sprague Electric, -from 1953
until he retired in 198O. This report was prepared by the Blake
Investigative Agency.
Mr. Smith worked at the Sprague -facilities in Kingston, NY
from 1953 until 1957, and in Nashua and Concord, NH, from 1959
until 198O, as an engineer. He was never employed in the facility
in No. Adams, MA and had no contact with PCB's.
He said that Sprague Electric was now owned by a company
from Pennsylvania, named Loral. Besides the plants in Nashua and
Concord, NH, Sprague has a plant in Saco, ME.
He mentioned the name of Peter Wol, as having worked at the
No. Adams plant.
DRAFT
313478
Details o-f a conference with Peter Wol - 5/9/92
At approximately 11:OO A.M., I met Mr. Wol at his home
located on ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ 1 His telephone number is
I He was employed by Sprague Electric, -from 1955
until he retired in 1987. This report was prepared by the Blake
Investigative Agency.
He worked in No. Adams, MA from 1955 until 1969 and from
198O until 1987. From 1969 until 1972, he worked at the Visalia,
CA plant and from 1972 until 1975, he was at the Nashua, NH
facility. Mr. Wol is an engineer, who worked in the field of
miniature circuits, and had no contact with PCB's.
He said that aroclor oil was called cnloronol at Sprague
Electric and was used at the Brown St. plant, in No. Adams, MA
Joe Bianchi worked at the Brown St. plant.
"iiifel,"
DRAFT
313479