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Libbey-Owens-Ford -3- 24 March 1986 water too high, which would force oil into uncontaminated soil. A possible alternative would be to push the oil and emulsion all the way to the surface and collect it there. 3. LOF' s 27 February 1986 letter to me describes the events which resulted in up to 4,100 gallons of autoclave oil being discharged within the bermed tank area on 22/23 February 1986. A basement water sump pump failed and when the water rose, the oil sump pump picked it up and pumped it into the outdoor tank. The water displaced oil , which overflowed. The oil sump is now operated manually. A total of 2,650 gallons of oil were pumped from the dirt and gravel-based containment area. Up to four feet of contaminated soil were removed from the containment area and placed on the ground on the east side of the rail car unloading facility. The soil from the pit was spread there last summer and LOF proposes to do likewise with this soil. LOF did not excavate further for fear of undermining the tank supports. The contamination continues down to an unknown depth. There is a dumpster-like container outside the south side of the contain- ment area. Water is drained from the tank(s) into the container until oil appears. The container is emptied into the oil/water separator. Earlier practice was to drain water directly onto the ground in the containment until the oil appeared. Such a practice, plus the recent overtopping lead me to believe that the ground water and soil could be seriously contamina- ted under and around the tanks. 1 LOF is planning to have an air autoclave in operation by October 1986. Following start-up and shakedown of the air autoclave, the oil tanks would no longer be needed. I told Mr. Quick that cleanup, which would jeop- ardize tank stability, could be delayed until October or soon thereafter, but that borings, trenches, or monitoring wells would be required in that area this spring. Following my inspection we met with Mr. G. Robert Meyer, Plant Manager. Mr. Meyer explained their plans to install an air autoclave. He asked for authori- zation to spread out the oily soil from the tank containment area and to backfill the pit at the leak site after placing a perforated standpipe in it. I told Mr. Meyer that I would review the file information concerning the earlier land spreading and let him know. I also said that they can backfill the hole but that any soil contaminated after backfilling would be looked at the same as in situ soil already contaminated. I did say;that since we haven't required removal of contaminated soil yet, they can reasonably hope that we won't require its removal .