Hi Bob,
There were several memory leaks in AOLserver 3.2 that were fixed, if I recall, for AOLserver 3.3 and 3.4.
However, in my most recent nsvhr/nsunix patches (for AOLserver 3.3ad13), I found one uh, semi-major AOLserver bug that I just fixed: in their communication driver interface, they let you define a "free" proc, to presumably, free memory and structures. Guess what, they never bother to call it! Oops. Nssock and nsssl doesn't use it, so most folks never notice, but nsunix uses it. Over time, that could build up to a pretty big memory leak too. In creating the new patches, I put several million requests during testing through nsvhr/nssock and nsvhr/nsunix and didn't note any memory leaks. Those were of static pages and not .tcl pages however, and that's where the more typical AOLserver memory leaks have been found.
My site is down at the moment as I recover from what was supposed to be a minor postgres upgrade, but it should be back up sometime tonight or tomorrow, and you should consider moving to AOLserver 3.3ad13.