5.1 This guide will help users answer simple and fundamental questions about the LNAPL occurrence and behavior in the subsurface. It will help users to identify specific risk-based drivers and non-risk factors for action at a site and prioritize resources consistent with these drivers and factors.

5.2 The site management decision process described in this guide includes several features that are only examples of standardized approaches to addressing the objectives of the particular activity. For example, Table 1 provides example indicators of the presence of LNAPL. Table 1 should be customized by the user with a modified list of LNAPL indicators as technically appropriate for the site or group of sites being addressed.

5.3 This guide advocates use of simple analyses and available data for the LCSM in Tier 1 to make use of existing data and to interpret existing data potentially in new ways. The Tier 1 LCSM is designed to identify where additional data may be needed and where decisions can be made using existing data and bounding estimates.

5.4 This guide expands the LCSM in Tier 2 and Tier 3 to a detailed, dynamic description that considers three-dimensional plume geometry, chemistry, and fluxes associated with the LNAPL that are both chemical- and location-specific.

5.5 This guide fosters effective use of existing site data, while recognizing that information may be only indirectly related to the LNAPL body conditions. This guide also provides a framework for collecting additional data and defining the value of improving the LCSM for remedial decisions.

5.6 By defining the key components of the LCSM, this guide helps identify the framework for understanding LNAPL occurrence and behavior at a site. This guide recommends that specific LNAPL site objectives be identified by the user and stakeholders and remediation metrics be based on the LNAPL site objectives. The LNAPL site objectives should be based on a variety of issues, including:

5.6.1 Potential human health risks and risks to relevant ecological receptors and habitats;

5.6.2 Specific regulatory requirements; and

5.6.3 Aesthetic or other management objectives.

5.7 This guide provides a framework by which users specify benefit remediation metrics that are consistent and achievable given the conditions of the LCSM.

5.8 Guidance is focused on the information needed to make sound decisions rather than specific methods or evaluations that might be used in deriving that information. This guide is weighted toward field data rather than modeling, though modeling is clearly recognized as a useful tool in generating scenarios and bracketing conditions of the LNAPL body conditions. Limited examples of site specific data used to develop the LCSM are provided in Appendix X6.

5.9 By defining specific, measurable attributes of remedial actions acting upon an LCSM, users can determine which actions may be feasible and which likely are not, using an evaluation of a consistent set of factors and expectations.

5.10 A sound LCSM will lead to better decisions about remedial actions. The site management decision process premised on the LCSM is intended to result in more efficient and consistent decision-making about LNAPL risk evaluations and remedial actions.

5.11 The complexity of multiphase LNAPL issues and the wide variety of analysis and interpretation methods that are available has lead to uncertainty in decision-making regarding sites with LNAPL and has sometimes resulted in misleading expectations about remedial outcomes.

5.12 Current risk assessment methods often assume the LNAPL is an infinite source of chemicals of concern. The remediation decision-making may be better defined by considering the LNAPL as the source material for chemicals of concern by explicitly characterizing the chemical composition and physical characteristics of the LNAPL body.

5.13 When LNAPL presents the main source of risk, the LNAPL should be the primary target of remedial actions and those remedial actions should be determined by following the decision evaluations described in this guide.

5.14 LNAPL regulatory policies that define remediation metrics by small LNAPL thicknesses in wells are, on a site-specific basis, often inconsistent with risk-based screening levels (RBSLs) and with current technical knowledge regarding LNAPL mobility and recoverability. LNAPL remediation metrics should be connected to the current or potential future exposures and risks, as well as to other non-risk drivers present for a particular site.

5.15 The user of this guide is encouraged to identify the appropriate process for public involvement and stakeholder participation in the development of the LCSM and the site management decision process.

5.16 By providing a flexible framework, this guidance will continue to be applicable in principle while the many unknowns and uncertainties in LNAPL movement and the associated risks in all plume phases (for example, sorbed, dissolved, vapor) are studied through future research efforts. Like the LCSM itself, this is a “living” document that must embrace advances in knowledge and in technology.

1.1 This guide applies to sites with LNAPL present as residual, free, or mobile phases, and anywhere that LNAPL is a source for impacts in soil, ground water, and soil vapor. Use of this guide may show LNAPL to be present where it was previously unrecognized. Information about LNAPL phases and methods for evaluating its potential presence are included in 4.3, guide terminology is in Section 3, and technical glossaries are in Appendix X7 and Appendix X8. Fig. 1 is a flowchart that summarizes the procedures of this guide.

1.2 This guide is intended to supplement the conceptual site model developed in the RBCA process (Guides E1739 and E2081) and in the conceptual site model standard (Guide E1689) by considering LNAPL conditions in sufficient detail to evaluate risks and remedial action options.

1.3 Federal, state, and local regulatory policies and statutes should be followed and form the basis of determining the remedial objectives, whether risk-based or otherwise. Fig. 1 illustrates the interaction between this guide and other related guidance and references.

1.4 Petroleum and other chemical LNAPLs are the primary focus of this guide. Certain technical aspects apply to dense NAPL (DNAPL), but this guide does not address the additional complexities of DNAPLs.

1.5 The composite chemical and physical properties of an LNAPL are a function of the individual chemicals that make-up an LNAPL. The properties of the LNAPL and the subsurface conditions in which it may be present vary widely from site to site. The complexity and level of detail needed in the LCSM varies depending on the exposure pathways and risks and the scope and extent of the remedial actions that are needed. The LCSM follows a tiered development of sufficient detail for risk assessment and remedial action decisions to be made. Additional data collection or technical analysis is typically needed when fundamental questions about the LNAPL cannot be answered with existing information.

1.6 This guide does not develop new risk assessment protocols. It is intended to be used in conjunction with existing risk-based corrective action guidance (for example, Guides E1739 and E2081) and regulatory agency requirements (for example, USEPA 1989, 1991, 1992, 1996, 1997).

1.7 This guide assists the user in developing an LCSM upon which a decision framework is applied to assist the user in selecting remedial action options.

1.8 The goal of this guide is to provide sound technical underpinning to LNAPL corrective action using appropriately scaled, site-specific knowledge of the physical and chemical processes controlling LNAPL and the associated plumes in ground water and soil vapor.

1.9 This guide provides flexibility and assists the user in developing general LNAPL site objectives based on the LCSM. This guide recognizes LNAPL site objectives are determined by regulatory, business, regional, social, and other site-specific factors. Within the context of the Guide E2081 RBCA process, these factors are called the technical policy decisions.

1.10 Remediation metrics are defined based on the site objectives and are measurable attributes of a remedial action. Remediation metrics may include environmental benefits, such as flux control, risk reduction, or chemical longevity reduction. Remediation metrics may also include costs, such as installation costs, energy use, business impairments, waste generation, water disposal, and others. Remediation metrics are used in the decision analysis for remedial options and in tracking the performance of implemented remedial action alternatives.

1.11 This guide does not provide procedures for selecting one type of remedial technology over another. Rather, it recommends that technology selection decisions be based on the LCSM, sound professional judgment, and the LNAPL site objectives. These facets are complex and interdisciplinary. Appropriate user knowledge, skills, and judgment are required.

1.12 This guide is not a detailed procedure for engineering analysis and design of remedial action systems. It is intended to be used by qualified professionals to develop a remediation strategy that is based on the scientific and technical information contained in the LCSM. The remediation strategy should be consistent with the site objectives. Supporting engineering analysis and design should be conducted in accordance with relevant professional engineering standards, codes, and requirements.

1.13 ASTM standards are not federal or state regulations; they are voluntary consensus standards.

1.14 The following principles should be followed when using this guide:

1.14.1 Data and information collected should be relevant to and of sufficient quantity and quality to develop a technically-sound LCSM.

1.14.2 Remedial actions taken should be protective of human health and the environment now and in the future.

1.14.3 Remedial actions should have a reasonable probability of meeting the LNAPL site objectives.

1.14.4 Remedial actions implemented should not result in greater site risk than existed before taking actions.

1.14.5 Applicable federal, state, and local regulations should be followed (for example, waste management requirements, ground water designations, worker protection).

1.15 This guide is organized as follows:

1.15.1 Section 2 lists associated and pertinent ASTM documents.

1.15.2 Section 3 defines terminology used in this guide.

1.15.3 Section 4 includes a summary of this guide.

1.15.4 Section 5 provides the significance and use of this guide.

1.15.5 Section 6 presents the components of the LCSM.

1.15.6 Section 7 offers step-by-step procedures.

1.15.7 Nonmandatory appendices are supplied for the following additional information:

1.15.7.1 Appendix X1 provides additional LNAPL reading.

1.15.7.2 Appendix X2 provides an overview of multiphase modeling.

1.15.7.3 Appendix X3 provides example screening level calculations pertaining to the LCSM.

1.15.7.4 Appendix X4 provides information about data collection techniques.

1.15.7.5 Appendix X5 provides example remediation metrics.

1.15.7.6 Appendix X6 provides two simplified examples of the use of the LNAPL guide.

1.15.7.7 Appendix X7 and Appendix X8 are glossaries of technical terminology relevant for LNAPL decision-making.

1.15.8 A reference list is included at the end of the document.

1.16 The appendices are provided for additional information and are not included as mandatory sections of this guide.

1.17 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety and health practices and determine the applicability of regulatory limitations prior to use.

1.18 This guide offers an organized collection of information or a series of options and does not recommend a specific course of action. This document cannot replace education or experience and should be used in conjunction with professional judgment. Not all aspects of this guide may be applicable in all circumstances. This ASTM standard is not intended to represent or replace the standard of care by which the adequacy of a given professional service must be judged, nor should this document be applied without consideration of a project's many unique aspects. The word “Standard” in the title of this document means only that the document has been approved through the ASTM consensus process.