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. . Facility Name ....::J~o!.!.h!.l.Jn~J.:.. -'R~i:!;.:il~e=.ly~·~C~o.:... ------- Inspection Date 4/6/83

... Location --"25:J2~8!.-.:ilS.aa•llilemlll...lS.~Jt....:·'---------- :J.

lnspectors

Woburn MA. R. Cleary

Contact People Jack ·Riley - owner. H. Waldorf

Dick Jones - · chemist

Phone Number 933-5900 In Compliance? D. :E.Q. E. License No. ~N:.::o:.:.:n~e _________ _ _ __ yes ---- Nc t. P .A. I. D. No. ...:MAD~,:;:;OO~l~0~3::,:58~7.::.2__;, ____ _

I. Facility Type and Process Descri'Ption ~·, Tr., ~

f ili Cattle ·hides into finished leather, on a contract basis . Riley's This ac ty proce~ses

customers are primarily manufacturers of shoes , belts and personal goods. This plant

operates on a srawwered shifts .s AM to 9 m. Since tannerv wastes were delisted by the

~A in 1981 and · are no longer considered hazardous wastes . this company may apply to the ...

Department to be taken pff the hazardous waste generator list. A tour of the plant revealed

sever~l issues pf Concern with reward to the ~oburn project. Unit process s observed

during this inspectipp. alooa with raw materials used. are summarized follows :

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John J. Riley Tannery, WoburnSummary Hatrix of Unit Processing of Cattle Hides

Raw Materials andUnit Process Storage Location Wastes Discharged

A. Fleshing Mechanical Wastewater to catch·basingrease to rendering tank­recycled

B. Beamhouse ­Paddle Mixers wastewater to catch basin

1. Soaking "Triton-NlOl", Phenolic detergent­inside tank2. Dehairing and lime in bags inside SodiumReliming h~drosulfide-drums outside.

c. Tanning-rotating mills wastewater to catch basin1. Bating Sodium formate - bags inside

formic Acid drums outsideAmmonium sulfates,"Tamol F," ororon-bags inside.2. Pickling Brine and sufluric acid- tanks inside

3. Tanning Chromium sulfate chrome liquor­drums inside S :.>dium bicarbonatebags inside.

D. Color Mills wastewater to catch basin

1. Retan Acrylics and proprietarycompounds-drums inside2. Coloring Anilinedyes - drums inside3. Fat li ­ Oils, emulsifiers, sulfatesquoring drums inside."Hardol" oil - tank insideClay and flour fillers - bagsinside.

E. Pasting, washing and Drying wastewater to catch basin Alkaline, cellulosepaste solutiondrums inside

F. Stre ching no wastewater"m rdol" oil - insid drums

"lsoparL" aliphilic hydro­c rbon - ( 9 rrifin) drumsin id

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G. Buffing mechanical process chrome leather dust to cyclone collector and wate spra~Buffing sludge to drying bed.

H. Finishing Operations

1. Seasoning - Various waterbased mixtures 2. Laquering, coating water curtain spray waste

and filming - rotary spray water to catch basin. Pape1 filters to trash

Process uses various compounds, depending on product type, all stored inside in 55 gallon drum~ most are blended dressings:

Types of coating Types of solvents

Nitrocellulose and polyurethane diisobutylketonelaquers. Water dispersable resins, "methylcellusolve" or "T-235" acrylonitrile pigment: carboxybuta­ (ethylene glycolmonomethylether) dieneacrylonitril~ carboxybutadiene "butylcellusolve"acrylonitrile-styrene,carboxybuta (ethyleneglycolmonomethylether)diene acrylo nitrile-acrylic. butylacetate

tributylphosphate diisobutyl acetone

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II. Summary of Viclations or Deficier:cies ·~ith References to Haurdous WasteLa~s and Regulations. ~

A. No specific violations with reference to· hazardous waste regulations atthe John J. Riley Company were noted.

B. Beatrice Foods appears to be in violation of MGL c. 21C s. 5 which prohibitsdisposal of hazardous waste without a license. Under s. 9 of this chapterthe Department may require the production or analysis of samples.

C. ~ith reference to non-hazardous sludges John J. Riley Co appears to be in violation of M.G.L. c. 24 section 43 which prohibits the discharge of oollutan1to waters of the Commonwealth without a yalid permit. Under M.G.L. c. 83 s. 7the Department may order a sewage treatment plant to improve its operation toabate water pollution.

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III. Inspection Discussion

A. Wastewater

1. Wastewater from most unit processes flows to a common catch basin where some settling and solids removal occurs. The largest volume of the 350,000 GPD flow is from the beamhouse, tanning, and color mill operation.

2. The ~IDC, under current litigation, will require further treatment, Mr. Jones and Mr. Riley indicated they had hired an engineer to cost-out wastewater treatment upgrading including pH control, chromium removal, oil and grease removal and sulfides reduction.

B. Sludge management

1. Sludges, which are the skimmings and bottom solids from the waste water catch basin arc being stockpiled onsite, on an emba'bkment above the railroad track and the company's well house. Some erosion of the stockpiled sludge is occuring down to the railroad drainage ditch. This drainage flows south to the wetlands above Whittemore Pond.

2. The sludge appears to be non-hazardous based on laboratory analysis shown us by Mr. Riley:

Cd - 0.036 ppm Cr - 4.4 ppm E.P. Extract, Skinner S. Sherman Labs Pb - 0.15 ppm

3. Buffing dust sludge is being stockpiled at another location at the northwest corner of the drying building. Company data indicated the following test result

Buffing Sludge Buffing Sludge Liquor

Cd - 0.011 ppm r.r - l. 8 ppm Cr - 136.0 ppm Pb - 0.48 ppm

4. Past sludge disposal practices have consisted of burial of dry and semiliquid sludges on the northern portion of the property . : Two old sludge lagoons and burial areas, approximately 1/4 acre in size were viewed during the inspection. One is approximately ~ f ull ofwater, of unknown depth. The other is a depression which is dry and egetated , other than two "puddles"of whitei green liquid . Mr. Jones stated these old lagoons had b en tested for organics two years ago and none were detected.

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5. Mr. Riley declined to provide copies of the sludge and well test results due to a pending lawsuit.

6. Department Policy on Sludge: The Department is authorized by the Massachusetts Clean Waters Act by MGL Chapter 21 Section 26-53 to regulate or pr ohibit discharge of pollutant to ground or surface waters without a valid permit. Mass. G.L. Chapter 83 section 7 authorizes the Department to order a sewage treatment plant to improve its works or operation in order to prevent or abate water pollution. In so far as the Riley Tannery is permitted to discharge to the MDC sewer system, and is operating their catch basin "treatment works" to remove solids, they should f all within the perview of the above section.

7. It appears, f rom in fo rmation prov...J t:J L1 t he company, that sludge being s tockpiled and disposed of on-site is a non-hazardous industrial s ludge. However, this facility should be required by the Department to provide documentation tha t the sludge generated exibits none of the character istics of a hazardous waste, as defined in 310 CMR 30.120. In part icular: the company should show the department evidence that the s ludge wi ll not generate toxic gases, as described i n 310 CMR 30. 124(e); and that the s ludge does not contain the followi ng EP Toxic mat erials in excess of the concentrations described i n 310 CMR 30.1 25 :

Cadmium, + Chromium in the hexava l ent form Cr 6 and Lead .

In view of t he previous contamination of nearby wells with halogenated solvents, it is suggested that they be required to do a purgeable organics on their sludge .

8 . It is recommended that Riley ' s be ordered by t he Department t o t ake the following actions :

a . Submit plans for the control and collec t i on of l eacha t e f rom sludg stockpiling areas.

b. Submit plans for the design and oper ation of sludge l andf ill i ng on-site, conforming to RCRA standards of 40 CFR 257. Alterna­tiv ly, Riley ' s could ither submit documentation of the ace pt nee of their sludg for off-site disposal or submit pl ns to the Department for 1 nd application of t heir sludge on it .

9. It is f lt th t th abov r ndations conform closely to the most r c nt policy mor ndum on subj ct (Policy 17, 3/31/83) from he Divi ion of H z rdous W s

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C. Raw Materials:

1) The summary matrix of unit processes (section I) lists raw materials used by the Riley Tannery and their place of storage. These materials were either observw during this inspection or. were stated verbally by Mr. Jones. Mr. Riley stated that he feels Riley has never used any "toxic" materials, except, "20 years ago, under a government contract, for leather to go to Vietnam."

2) The raw materials or derivatives discussed below are listed in 310 OtR 30.133 as "Hazardous Wastes which are discared commercial chemical products or OFF-specification batches of commercial chemical products or spill residues of either". It should be noted that these substances are considered hazardous only if discarded in their pure (or off-sepcification) commercial form. As such, these raw materials are not considered waste as they are currently being us ed by this fac ility . They are listed f or background i nformation only:

Raw Material Was te listed in 310 CMR 30.133

Phenolic Deter gents Phenol Ua88 plus 11 other phenolic compounds

Anil i ne Aniline U012

Formic Acid Formic Aci d Ul23

Acrylonitr ile Pigments Acrylonitrile P-his U009

D. Process Water is supplied t hrough 2 wells

1) Wel l Ul , closest to the plant and west of the B&M tracks, is labeled well U439in the E&E Final report . It has exhibited low levels of cholorinated solvents compared with other contaminated wells . Mr . Jones indicated that when they have tested .t his well levels of the halogenated solvents have been at either low levels or non-detectable .

2) Their well 12, located east of t he B&M tracks , i s labeled well /16 in t he E&E Final Report. Levels of halogenated solvents in this well were high, with trichloroethylene at 1372 ppb in 1981 .

3) Mr . Jones s tated tha t the proces s water s upply, f rom the above 2 wells , was cross- connec t ed with the city water s upply up until 1980.

E • Ai r emmiss i ons :

1) A recent ai r i nsp ct ion r por t on this plant is included in t h fil . It contains mor d tailed i nforma t ion on VOC us A small sampl paint spray booth at th plant is st ck vent d . Total VOC emmission for all proc s 1 . v por tion) ba d on us in t h air insp ction r por r 82. 57 tons/yr.

2) Th buffing 1 th r du t to w t r spr y cyclon coll c or wi h

8 . 3. cone min his ludge).

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F . Property of Beatrice .Foods East of B&M Tracks

1) The property is still owned by Beatrice Foods, however, Mr. Riley stated that John J. Riley Inc. still retain water rights to well #2 (E&E#6). It should be noted, for purposes of any future· enforcement in this area, that Beatrice Foods sold the plant itself back to John J. Riley Co. in January 1983.

2) This property was the location of disposal of hazardous waste drums and "oily residues". Beatrice Foods was ordered to remove these wastes in October of 1980.

3) Based on an inspection of the property it appears that the area east of the MDC/Woburn sewer lines and closest south to Whitney barrel has been recently disturbed by heavy equipment Mr. Riley stated he had had some of the scrap metal and old drums removed. He also stated that the newly constructed fences near the well and at the Whitney property boundry were intended to prevent future access to this area from Salem St.

4) Scrap metal and rusting old drums and refuse are scattered throughout the property. A large pile of these (15 to 20) drums is located opposite the train "depot" at the Leachmere Warehouse. At the base of the sewer manhole in this area a small spot of oily, tarry residue was noted. No other distinctive oily residues or recently dumped refuse were observed on the site. No obvious vegetation stress was noted.

5) Owing to the age of these wastes, it will be difficult to determine the type, if any, of hazardous residues in and under the old drums. For this reason, it is suggested Beatrice Foods, be required to provide sample analysis from soils in this area, before any cleanup, to determine if they contain either EP Toxic wastes or any of the several halogenated solvents which have contaminated nearby wells. Based on the sample results, the Department can then decide on the specific requirements for tne physical removal of these wastes by Beatrice Foods.

6) According to Mr. Riley, Beatrice Foods plans to donate this site to either the City of Woburn or a non-profit organization called "Wildlands" in the near future. A quick response to the situation on this site is advisable.

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III. Inspection Discussion ~

See sheets previous ~ 1\ .·~

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IV. Recommendations to Actions

A. Issue an order to Beatrice Foods requiring the analysis of soils and any empty drum residues from the property located east of the B&M Railroad tracks and North of Salem St. otherwise known as lot #42-14-73AC on the City of Woburn Planning Board Map # P-16.

B. Issue an order to John J. Riley Co. requiring: 1) Analysis of sludge for Hazardous Waste characteristics of reactivity as

defined in 310 CMR 30.124(e), and EP Toxicity as defined in 310 CMR 30.125 2) Submission of plans for collection and control of leachate at the sludge

stockpiling area· 3) Submission of plans for the on-site disposal of dewatered sludge or

documentation of acceptance of sludge for disposal off-site.

V. Hazardous Waste Profile

K054 K055 K056 Tannery Wastes- delisted in 1981 " K057

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V~. Information Requests

A. Inspector from Industry · ...

1) Previously issued(ID#MAD001035872. Mr. Jones requested this number so he could apply to have them removed from the generator's list.

...~ . 2) If they submit test results on sludge &well now, will the Dept.

'protect their confidentiallity with regard to ·a pending lawsuit?-.--' .-· , . ­B. .Industry from Inspector :_ ·.··

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