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IAF Glass Intra-Company Correspondence Libbey-Owens-Ford Company May 6, 1986 It Mr .Jim Eckman , Project Engineer o CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD MAY 8 198b CENTRAL VALLEY REGION 3201 S Street ENVIROMENTAL HEALTH Sacramento, California 95816-7090 PERMIT/SERVICES Dear Mr . Eckman : Thank you for your recent visit to our plant and help with the planning for the clean-up of our two oil spills. As we discussed, you will find enclosed the two recommendations by Woodward-Clyde Consultants for the two separate problems. In the interest of clearly accounting for the first spill of January, 1985 and to reach ultimate agreement on the proper handling of the situation we are submitting the following proposal to you consisting of the following points as we have tentatively agreed to in our discussions : 1 ) The objective of this plan is to have a response to the January 1985 spill which satisfies the need to protect the water quality of this area by either removing the threatening oil or to immobilize it . 2) Approximately 6202 gallons of oil from the 9000 gallons lost have been removed. Recovery amounts are very small now that the water table has receded from the seasonal high in February. It is believed most of the remaining oil is locked in the pore spaces of the soil above the water table. Experience has shown that more oil might be extracted with each succeeding new maximum water table elevation . 3) As long as a water table depression is maintained (consensus seems to favor 1 foot depression) either any remaining oil is restricted to the area or it is extracted by the skimmer pump ; and in winter when new water table heights are reached, freshly liberated oil will migrate to the extraction site. 4) An extraction well should be set into the open excavation and the pit filled in with clean soil ; sand and gravel should be Placed around the well to facilitate oil migration . The well will consist of a 12" or larger PVC screened pipe and fitted with a dual pumping system consisting of surface and subsurface intakes to allow for skimming and maintenance of a fluctuating I foot water table depression . 5) Any remaining oil contaminated soil will not be removed as long as the immobilization system is working or the extraction process has been shown to be successful . The reason for this is the removal of the soil would threaten the integrity of the building foundation and many pipes and utilities in the area.