According to the U.S. Environmental Protection Agency, free product should be addressed during the early phases of response to a confirmed release. The primary objective of 40 CFR 280.64 is to remove free product in a manner that minimizes the spread of contamination into previously uncontaminated zones. EPA has clarified that the focus is on preventing migration rather than removing every measurable amount of product (see EPA’s Technical Compendium clarification).

Recovery potential is greatest early in the process, when LNAPL saturations are higher. Industry guidance from the Interstate Technology & Regulatory Council (ITRC) and the Federal Remediation Technologies Roundtable supports aggressive recovery of mobile free product as a way to reduce mass, limit further migration, and allow many sites to transition later to lower-cost strategies such as natural source zone depletion.

In Texas, the TCEQ Risk-Based NAPL Management guidance also addresses the evaluation and management of NAPL as part of effective site remediation.

Efficient free product removal reduces risk, limits plume expansion, and supports more cost-effective overall site management.