Which substances are not considered free product for the HOT Generic Remedy?

The answer identifies spill product immediately removed during decommissioning as not considered free product for the HOT Generic Remedy because, once it has been properly removed, it no longer poses an ongoing risk of contamination. Free product generally refers to liquid hydrocarbons that are not dissolved in water and can be recovered or mitigated from the subsurface environment. When a product is actively removed during the decommissioning process, it is no longer contributing to contamination and hence falls outside the parameters that define free product.

Understanding the other choices provides context: natural groundwater can be affected by pollutants, and substances from ongoing operations suggest that there could be an ongoing release or risk, both of which are considered free product. Similarly, product from an unrelated spill nearby may also be classified as free product if it is impacting the site being assessed. Thus, the distinction lies in the effective removal of the specific spill product, which reclassifies its status in terms of environmental risk.