Guidance May Impact Compliance Procedures for LNAPL Recovery and Remediation
In February 2023, the United States Environmental Protection Agency (EPA) issued a communication that provided important clarifications on the basis of federal regulations governing free product removal and their expectations on how free product removal and remediation should be addressed. The EPA’s clarifications support a modern framework for light non-aqueous phase liquid (LNAPL) site management and may impact compliance procedures for recovery and remediation.
Regulatory Background
Federal requirements for free product removal from underground storage tanks were established in 1988 (40 CFR 280.64):
“At sites where investigations…indicate the presence of free product, owners and operators must remove free product to the maximum extent practicable as determined by the implementing agency…”
Albeit short, this requirement was extremely consequential relative to the regulations and policy subsequently developed by state Underground Storage Tank (UST) programs, and to the scope of work and cost incurred by those responsible for corrective action of UST releases. Some state agencies have taken the position that the accumulation of ANY free product in a monitoring well triggers removal, while others have onerous “maximum allowable thickness” criteria. Furthermore, some agencies have applied this “free product removal to the maximum extent practicable” standard (often referred to as the maximum extent practicable or MEP requirement) to releases from something other than a UST (or aboveground storage tank [AST]), such as a pipeline; or even to the presence of hydrocarbons in the form of dense, nonaqueous phase liquid (DNAPL).
Depending on the scale of the site, addressing the MEP requirement can cost responsible parties hundreds of thousands or even millions of dollars, even when ongoing product removal does not provide commensurate value in terms of reducing risk or altering the scope of appropriate long-term site stewardship.
Important EPA Clarifications and Expectations
In their February 2023 communication, the EPA emphasized that 40 CFR 280.64 does NOT require removal of all measurable free product, clarified that the objective underlying the MEP requirement was to prevent migration and acknowledged that not all free product in the subsurface is capable of migrating.
The communication states: “The federal regulation was written to require owners to remove free product during the early phases of a response to a confirmed release. EPA’s intention was to mitigate the risk of free product spreading to uncontaminated areas of a site.”
Recovery potential is greatest in the early stages of a response when LNAPL saturations are higher and in a more limited footprint. If aggressive recovery is undertaken soon after a release, a significant portion or even the majority of the LNAPL mass can be recovered, and the potential for further migration can be effectively mitigated. By contrast, at old release sites where migration expanded the footprint of the LNAPL zone and where water table fluctuations and other natural processes have reduced the LNAPL saturation within the footprint, free product recovery efforts are unlikely to significantly alter the potential for further migration or other potential risks posed by the residual LNAPL.
In their communication, the EPA recognized that the understanding of LNAPL mobility and behavior has increased significantly in the 35 years since promulgation of 40 CFR 280.64, and that even the “free product” term has been superseded by modern definitions of LNAPL in its various states of potential mobility.
The following are key definitions from the Interstate Technology and Regulatory Council (ITRC)1 LNAPL-3 guidance (endorsed by the EPA in the communication):
- Residual LNAPL: The fraction of an LNAPL body that will remain immobile and hydraulically unrecoverable under prevailing hydraulic conditions (i.e., will not flow into a well).
- Mobile LNAPL: LNAPL that exists above residual saturation levels such that it may be observed in wells. Mobile LNAPL has the potential to migrate, but not all mobile LNAPL is migrating LNAPL.
- Migrating LNAPL: A LNAPL body that is expanding laterally or vertically into areas previously un-impacted by LNAPL.
In their communication, the EPA specifically acknowledged that abatement of mobile and residual LNAPL is not necessary to meet the MEP requirement of 40 CFR 280.64.
The EPA also acknowledged the importance of a risk-based approach to LNAPL site remediation and the need for remediation decision-making to consider potential risks posed by further groundwater contamination or vapor intrusion. In their communication, the EPA recommended that the approaches to assessing and remediating LNAPL described in ITRC’s LNAPL-3 guidance be considered by the implementing agencies. LNAPL-3 is a web-based guidance document that provides clear guidance on understanding and setting risk-based remediation goals, understanding the appropriate role of LNAPL recovery, recognizing the practical endpoint of LNAPL recovery operations, and when to transition to technologies more appropriate for remaining LNAPL (including Natural Source Zone Depletion or NSZD).
In the brief update on free product removal provided in the EPA’s February 2023 communication, the EPA does not delve into the details of any specific state regulations, or specific alternatives to state free product recovery criteria (e.g., maximum allowable LNAPL accumulation in monitoring wells). However, in their recommendation to consider the ITRC LNAPL-3 guidance, the EPA is opening the door to the modern paradigm and tools for assessing LNAPL recovery, including LNAPL transmissivity (a metric far superior to LNAPL thickness measurements for assessing LNAPL recoverability) and NSZD rate measurements (as a metric to be considered in establishing an LNAPL recovery endpoint).
TRC Strategic Tip
The EPA’s February 2023 communication should be a useful tool in advocating for the application of knowledge-driven, risk-based approaches to LNAPL recovery and LNAPL site remediation when dealing with regulatory agencies that have not yet fully transitioned to the modern framework of LNAPL site management.
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NERC’s CIP-008 standard aims to mitigate reliability risks resulting from a Cyber Security Incident by specifying incident response requirements. Newly proposed revisions would augment mandatory reporting to include incidents that compromise, or attempt to compromise, a utility’s Electronic Security Perimeter (ESP) or associated Electronic Access Control or Monitoring Systems (EACMS).
Cold Weather Reliability Preparedness and Hardening
March 22, 2021
The latest weather impacts to power reliability have accelerated the need for mandatory regulatory compliance changes.
TRC Companies Inc. Acquires EMI Consulting
January 27, 2021
Today TRC Companies (“TRC”), announces the expansion of its advanced energy capabilities with the acquisition of EMI Consulting (“EMI”), a Seattle based firm that consults on the strategic development of clean energy solutions including energy efficiency, demand management, decarbonization and customer engagement.
FERC Issues Annual Report on Critical Infrastructure Protection (CIP) Reliability Audits
November 17, 2020
In its 2020 Report on CIP Reliability Audits, the Federal Energy Regulatory Commission found that most of the cybersecurity protection processes and procedures adopted by utilities met the mandatory CIP requirements for protecting the Bulk Electric System. However, there are areas for improvement.
TRC Digital partners with Dominion Energy to evolve its distributed energy resource strategy
September 22, 2020
Dominion Energy, one of the nation’s largest producers and transporters of energy, has partnered with TRC Digital to evaluate, implement and integrate technology to further the utility’s distributed energy goals. TRC Digital will facilitate Dominion Energy’s strategy development and technology execution, allowing Dominion Energy and its customers to accelerate the shift to distributed energy resources (DER) and net carbon reduction.
NERC Issues 2020 State of Reliability Report
September 22, 2020
The Report identifies areas of ongoing concern including generation reserve margins and the reliability risk from shifting the resource mix toward renewables.
TRC Digital and Reactive help utilities measure inertia for a more resilient grid
September 21, 2020
Together, TRC and Reactive combine TRC’s industry-leading power engineering expertise with Reactive’s machine learning software to provide utility teams with high-resolution frequency monitoring and automatic event analysis.
NERC Issues Lessons Learned on Misoperations Due to Mixing Relay Technologies
August 13, 2020
On July 10, 2020 NERC released new Lessons Learned guidance to address situations where multiple composite protection systems have misoperated as a result of mixing protective relay technologies at the remote terminals of directional comparison blocking (DCB) schemes. This technical information will help utilities improve the reliability of the Bulk Power System.
NERC Reliability Standard PRC-024-3 Approved: Frequency and Voltage Protection Settings for Generating Resources
July 28, 2020
On July 9, 2020 NERC standard PRC-024-3 was approved, paving the way for improved protection systems in support of keeping generating resources connected during defined frequency and voltage excursions.
Summary of NERC CIP Standards Updates
June 29, 2020
FERC has released a notice of inquiry seeking comments on potential enhancements to NERC’s Critical Infrastructure Protection (CIP) Reliability Standards.
TRC Digital Partners with Treverity to Put Utility Engineers at the Center of Their Data
June 26, 2020
As part of TRC’s LineHub solution, Treverity helps transmission engineers get a holistic view of the grid through powerful digital data visualization and a customer-centric user interface.
Strategic Electrification
February 4, 2020
As we look to spur strategic electrification across the US, it will be up energy providers and solution implementers to continue sharing ideas, insights and lessons learned
NERC Reliability Report Prioritizes Power System Security Risks for Action
January 2, 2020
NERC’s 2019 ERO Reliability Risk Priorities Report identified and prioritized the major risks facing the utility industry with a particular focus on security issues.
TRC Expands Presence in Power Market with Acquisition of Ohio-based IJUS
October 1, 2018
LOWELL, Mass. – TRC, a leading provider of end-to-end engineering, consulting and construction management solutions fueled by innovative technology, announced today it has acquired IJUS, a top power/utility engineering firm based in Gahanna, Ohio. Terms of the deal were not disclosed.
NERC Proposes Compliance Monitoring and Enforcement Plan for 2019
September 26, 2018
This month, NERC released the first draft of its 2019 Compliance Monitoring and Enforcement Plan (CMEP) which identifies power delivery system risks and outlines compliance audit requirements for next year. The risk elements outlined in the plan include significant differences from previous years, as shown in the table below. Each NERC region must consider these risks as they develop their monitoring and audit scopes for utilities. Utilities should be prepared to be audited and implement any necessary compliance initiatives in these areas.
NERC Standard Extends Maintenance Program Obligations to Generators
February 3, 2014
The approval of NERC Standard PRC-005-2 extends protection system maintenance obligations to Generators and crates one comprehensive standard establishing minimum maintenance activities and maximum time intervals for protection systems and load shedding equipment affecting the bulk electric system.
EPA Issues Regulations for Oil and Natural Gas Sector Tank Emissions
April 30, 2024
Storage Vessel or Tank Battery Operators Must Reduce Emissions by 95%.
PHMSA Gas Transmission RIN2 Rule Now Effective
July 24, 2023
TRC summarizes the revised or added sections of RIN2.
EPA Proposes Regulation of Green House Gas Emissions
July 10, 2023
This article highlights the EPA’s proposed rules to regulate greenhouse gas emissions from power plants and the potential impact on new and existing fossil fuel-fired facilities.
EPA Issues Clarification of Free Product Removal Requirements
June 20, 2023
EPA recently clarified requirements for LNAPL recovery and remediation.
Modernize Your Field Services with GIS and Work Order Management Combined
June 15, 2023
The role of field service management continues to dominate the world economy, as the market grows at an exponential rate. The market was estimated at 3.2 billion in 2021 and is projected to reach 5.7 billion by the end of 2026.
PHMSA Issues Gas Gathering Final Rule Summary & Requirements
November 30, 2021
PHMSA announced that they issued a final rule that significantly expands Federal pipeline safety oversight to all onshore gas gathering pipelines.
The Price of Natural Gas: Onward and Upward or Just a Temporary Blip?
November 12, 2021
Most industry experts agree that weather aside, the global energy and gas markets are likely to remain uncertain with supply and market demand becoming tighter and more challenging to forecast.
2021 EPA TRI Reporting Requirements for Natural Gas Processing Facilities
July 12, 2021
Indication EPA finalizing a rule to add natural gas extraction or processing plants to EPCRA Toxics Release Inventory (TRI) reporting.
PHMSA Protecting our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act of 2020
June 11, 2021
PHMSA announced it has submitted an advisory bulletin underscoring to pipeline and pipeline facility operators requirements to minimize methane emissions.
DHS Announces New Cybersecurity Requirements for Critical Pipeline Owners and Operators
June 3, 2021
The Security Directive will require critical pipeline owners and operators to report confirmed and potential cybersecurity incidents.
TCEQ to Assume Oil and Gas Wastewater Permitting from RRC
January 11, 2021
Historically, the Railroad Commission of Texas has been responsible for wastewater permitting of upstream oil and gas facilities under a Memorandum of Understanding with the Texas Commission on Environmental Quality.
INGAA Foundation Interview with Lauren O’Donnell
June 22, 2020
TRC’s own Lauren O’Donnell is currently the elected Chair of the INGAA Foundation. The Foundation’s primary activity is to sponsor research aimed at promoting natural gas use and safe, efficient pipeline construction and operation.
NERC Calls for New Approach to Reliability Planning Due to Gas Supply Disruption Risks
December 14, 2017
A recently published NERC report concludes that as reliance on natural gas to meet electric generation requirements increases, additional planning and operational measures must be considered to mitigate power system reliability risks.
Webinar Replay
March 26, 2024
TRC’s panel of practitioners discuss the Hydrogen Hub (H2Hub) funding provisions of the Bipartisan Infrastructure Bill (BIL).
U.S. EPA’s EJScreen Evolves as the Agency Advances Environmental Justice
August 21, 2023
EJScreen is currently at the forefront of federal efforts to identify potential disproportionate environmental burdens and communities with potential environmental justice (EJ) concerns.
U.S. EPA and Army Corps of Engineers to Develop Revised Rule to Define “Waters of the United States”
August 8, 2023
The US EPA and Army Corps of Engineering are redefining “Waters of the United States”.
Regulators Update Design Storm Rainfall Depths in Response to Climate Science Projections and Recent Storm Data
August 3, 2023
Regulators are responding to anticipated increases in extreme rainfall events by updating design storm rainfall depth regulations.
EPA Issues Clarification of Free Product Removal Requirements
June 20, 2023
EPA recently clarified requirements for LNAPL recovery and remediation.
New Executive Order 14096 Broadens Environmental Justice Initiatives
May 9, 2023
Executive Order 14096, Revitalizing Our Nation’s Commitment to Environmental Justice for All, seeks to deepen the Biden administration’s “whole-of-government” approach to environmental justice (EJ) by fully integrating the consideration of unserved and overburdened communities and populations into all aspects of federal agency planning and delivery of services.
TRC Assists in Securing $11M in funding for small Communities
April 14, 2023
On May 18, 2023, EPA published the proposed Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals from Electric Utilities; Legacy CCR Surface Impoundments (proposed rule) in the Federal Register to amend subpart D of part 257 of Title 40 [Docket ID No. EPA-HQ-OLEM-2020-0107; FRL–7814-02-OLEM]. TRC initially summarized key aspects of EPA’s proposed rule in Summary of Proposed Coal Combustion Residuals Legacy CCR Surface Impoundments Rule, June 15, 2023. Drawing from our expertise and extensive experience supporting utilities as they navigate the intricacies of the CCR rule, TRC has submitted public comments related to EPA’s proposed compliance timeline and schedule.
Proactive Enforcement is Key in the EPA FY2022-2026 Strategy
October 19, 2022
A core element of the EPA FY2022-2026 Strategic Plan focuses on environmental compliance.
Preparing for EPA Inspections in Environmental Justice Communities
October 4, 2022
The EPA Office of Enforcement and Compliance Assurance Have Expanded Goals to Strengthen Enforcement and Protections Within EJ Communities
New National Emerging Contaminants Research Initiative
September 12, 2022
The Executive Office of the President of the United States announced a National Emerging Contaminant Research Initiative
Locana Awarded Wildlife Habitat Analysis Task Order For The Bureau Of Land Management
April 27, 2022
Locana, a leading geographic data and technology company, has won a 10-year National Geospatial Data and Technology Support Services contract for the U.S. Bureau of Land Management (BLM).
TRC Acquires New Jersey’s Clean Energy Program Contract and Assumes Program Administrator Role
January 17, 2021
NEW BRUNSWICK, NJ and LOWELL, MA. – Jan. 17, 2017 – TRC Companies Inc., a recognized leader in engineering, environmental consulting and construction-management services, today announced it has acquired the contract to serve as Program Administrator of New Jersey’s Clean Energy Program™ (NJCEP), which has provided more than $300 million annually in support to homeowners, businesses…
Ecological Risk of PFAS from AFFF-Impacted Sites
June 30, 2020
The facts on evaluating exposure to wildlife
Security Stew: How to Follow the Federal Regulatory Recipe for Safe Chemical Storage
September 19, 2017
Three different federal agencies regulate the storage of chemicals at facilities in the United States – and each for different reasons. Learn about the various rules from the alphabet soup of agencies (DHS, EPA and OSHA) involved and how to keep your business compliant.
TRC and partners win $1 million grant for engineering innovative New York microgrid
April 20, 2017
TRC is proud to support Huntington, NY bolster power reliability and climate-change resiliency with a sophisticated new “community microgrid’’ combining solar energy, a fuel cell, biogas and traditional natural gas to deliver electricity and heat to local customers and institutions.
EPA to Include CERCLA Sites and RCRA Facilities in Site Remediation NESHAP
June 23, 2016
EPA has published a proposed rule that would extend the requirements of the Site Remediation National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations to previously exempt soil and groundwater remediation activities under CERCLA and RCRA.
Manchester Moves Legacy Sites
April 9, 2014
The City of Manchester, NH continues to transform blighted areas of the City into community-based redevelopment projects supported by EPA’s Brownfields Program to improve the environment and public health and expand opportunities for neighborhood and economic development.
The Importance of Effective Construction Management in Data Centers
January 7, 2025
In today’s digital age, data centers form the backbone of cloud computing, artificial intelligence and the vast array of digital services we rely on daily. As the demand for data centers rises, companies are racing to expand these facilities.
EPA Issues Regulations for Oil and Natural Gas Sector Tank Emissions
April 30, 2024
Storage Vessel or Tank Battery Operators Must Reduce Emissions by 95%.