The value of a Conceptual Site Model (CSM) as a basis for contaminant exposure and environmental risk assessments is now well established for many Federal and State regulatory programs.  In recent years, the CSM idea has been applied to characterizing LNAPL-bearing earth materials that serve as a source for contaminants of concern (COCs).  ASTM (2007) has developed guidance for developing an LNAPL-based CSM (LCSM) which can be applied to risk-based decision-making at petroleum-impacted sites.  An LCSM describes the physical and chemical state and setting of the 3-dimensional LNAPL body from which estimates of flux, risk and remedial actions are determined. Several State UST regulatory agencies are formulating new LNAPL policies that permit risk-based decisions related to endpoints and site closures.  These programs will need clear guidance on how the LCSM is formulated and linked to the larger CSM for risk assessments.  This paper reviews new LNAPL policy developments in Delaware and Texas and suggests an approach for characterizing an LCSM and linking it to the site-wide CSM in the exposure and risk assessment modeling phase.  LCSM development can benefit the management of large portfolios of sites by prioritizing and ranking the sites on the basis of potential risks.  A case study example of LCSM development will illustrate the benefits of having a LCSM that evolves as more site information is collected. During phase 1, the LNAPL body is characterized for the objective of demonstrating that the practical limit of LNAPL recovery has been reached.  During phase 2, the stability of the LNAPL plume is verified while tracer testing, MNA parameter and COC migration monitoring supports a risk assessment that may show the endpoint objectives are achievable within a reasonable time frame.