Light non-aqueous phase liquid (LNAPL) is defined as "a light, nonaqueous-phase liquid (e.g. oil) that has a density less than water (density<1.0 gm/cm3) and is immiscible in water" (ITRC, 2009). LNAPL is the more accurate term for describing non-dissolved liquid (e.g. gasoline) on or within the groundwater.

As of the date of this document (February 2012) amendments to Michigan's Leaking Underground Storage Tank (LUST) Act (Part 213) have passed the State Senate and have been forwarded to the State House of Representatives. These amendments present new opportunities to achieve "closure" for LUST sites in Michigan. The closure for a great many of these LUST sites has been delayed due to the current or historic presence of "free product" which is more accurately referred to as light non-aqueous phase liquid (LNAPL). The new protocol will no longer be the simple presence of free product/LNAPL, but whether it is mobile or migrating.

Let's continue with our assessment of the liability protections offered under the Ohio Voluntary Action Program (VAP), compared with federal liability protections under CERCLA (Superfund) as well as those available in nearby states. The Ohio VAP is regarded by many developers and their lenders as useful/feasible for only a small number of properties, typically the very largest of projects, due to the cost and time to complete the VAP process. As is the case for many Brownfields, the former owner(s) have vanished or are uncollectible, and the cost for cleanup can often exceed the property value. As a result, many developers are driven to look to "clean" Greenfields as opposed to dealing with the regulatory hassles of Brownfields. This leads to the common "donut hole" around our core cities.