Is IDEM allowing nondefault submittals using TPH fractionation?
Yes, IDEM does accept nondefault submittals using TPH fractionation. Guidance for nondefault TPH fractionation is located in the RISC Technical Guide Chapter 8 [PDF]. Top Closure 1. Can plume stability be used for a plume that extends off-site under a private property or underneath a roadway? If plume stability can be used in either of these cases, are institutional controls or a highway authority agreement needed for the property or roadway prior to closing the incident? Plume stability can be used for off site plumes if you have property control through a restrictive covenant or highway authority agreement.