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NAPL, LNAPL and OHM Source/Migration Control

A topic-specific discussion of the proposed amendments related to NAPL, LNAPL and OHM Source/Migration Control was held at MassDEP on Tuesday, July 30, 2013. The audio of the discussion is available online at archive.org:  http://archive.org/details/July302013NaplAndSourceDiscussion, broken into five 20 minute long segments.  The discussion covered:

  •  Definitions of NAPL and LNAPL and their implications for:

–         Notification
–         SRM
–         Removal to the extent feasible
–         AULs

  •  Wide range of comments related to the proposed definition of Source of OHM and the requirements for “Source” Control

–         Definition of Source of OHM and its relationship to performance standards for plume/migration control
*  “leading edge of a plume” provision; dissolved phase/soil gas not a source
*  plume/migration control provisions

 –         LNAPL “removal to the extent feasible” implies active remediation is required to demonstrate source has been controlled

–         1% Solubility Limit criterion for DNAPL constituents has limitations, particularly as a bright line “Source Control” standard

  • Implementation of the proposed amendments will require timely release of technical guidance related to NAPL – discussion of guidance development scope and goals, including ensuring guidance for MCP users with varying degrees and types of expertise in this area.

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