- To begin, Dr. George F.

Pinder, the plaintiffs expert on

hydrogeology stated: that TCE dumped at graces cryovac site
would reach wells g and H in three years time and TCE dumped
on the Beatrice property would reach the wells in six months
time.
- However these projections were found not to be factually
conducive due to Pinder himself admitting to mathematical
errors including but not limited to the exclusion of the porosity
constant in his own formula, as well as failing to take in account
the industrial well on the 15-acres of the beattrice property.
- On account of these miscalculations the integrity of the Pinders
testimony is severely flawed.
- However, pressing forward. The issue at hand is the
contamination of wells G and H, whose source can be directly
attributed to the subject being brushed aside in this case.
- The largest source of contamination. The Aberjona river.
- Its no secret that the Aberjona River has been a undertaker of
countless pollutants
- Alfred DeFeo, who conducted a 1971 study of the Aberjona River,
has testified that the National Polychemical Company (now
known as Olin Chemical Company) was responsible for dumping
a malodorous reddish waste product on a consistent basis.
- This finding led to multitude of other cases of industrial dumping.
- Other companies associated with the malfeasant disposal of
toxic checmicals include:
o E.C Whitney company, a barrel cleaning firm stationed in
Wilmington
o Raffi & Swanson company, a Wilmington Chemical plant
o International Minerals of Woburn
o Wobern Barrel Company
o As well as the Woburn City Dump
- The method of disposal for these companies was the dumping of
noxious chemicals into Halls brook drainage ditch, a tributary to
Aberjona River.
- In correspondence to the 1971 study, a follow- up study was
conducted in March 1986 revealing that the dumping in regard to
all the companies mentioned was an ongoing operation.
- In addition to these adulterating companies; studies coordinated
by Robert Cady, supervising sanitary engineer with
Massachusetts Division of Water Pollution Control, have
ascertained another firm contributor of pollution.
- The Industri-plex waste site in North Woburn.
- The industri-plex is a highly toxic plant littered with chemicals
such as lead, arsenic, chromium, and Benzene which is a proven
leukemia causing chemical.
 - In fact, the industri-plex has such a high source of toxicity that it
is fifth on the EPAs national priority clean up list ( which is
environmental protection agency)h
- The point is, the Aberjona river is severely contaminated and
calculations show that fifty percent of water being drawn to Wells
G and H are coming directly from the aberjona river. Calculations
that have been backed up by the US geological survey whose
study found that forty percent of water drawn by the wells came
directly from the river.
- The contamination of the wells came from the river not the grace
site.
- As previously stated by our geologist, due to the high density of
the moraine, groundwater exposed to the chemicals in 1960
could not have reached wells G and H by May of 1979.
- However for the sake of argument, completely hypothetical, if
the contaminated grace water did reach the wells, due to the
density of the moraine, our contribution would be five gallons a
minute, which in turn comes out to less than half a percent of the
total contamination.
- The contamination of wells G and H stem from the Aberjona river
and its immense pollution, not W.R. Grace and company.

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