September 2006 — Corrective Action Plan (CAP) for the Basic Remediation Company (BRC) Common Areas Remediation Project
Pursuant to the Nevada Division of Environmental Protection Settlement Agreement and
Administrative Order on Consent: BMI Common Areas, Phase 3, Basic Remediation Company
(BRC) has prepared this revised Corrective Action Plan (CAP) to present the procedures for
implementing the preferred remedy that has been selected by the Nevada Division of
Environmental Protection (NDEP) in its Record of Decision to address impacted soils at Basic
Environmental Company (BEC) property in Clark County, Nevada.
The revised CAP addresses all prior NDEP (and, in one case Clark County Department of Air Quality and Environmental management, CCDAQEM) Comments that were made pursuant to previous submittals of the CAP. Responses to these Comments, dated December 2, 2005 (by NDEP), March 24, 2006 (by NDEP), August 7, 2006 (by CCDAQEM), August 8, 2006 (by NDEP), and September 8, 2006 (by NDEP) are attached to this revised CAP in Appendix E.
The property represents a portion of what is known as the BMI Common Areas, and consists of
approximately 2,330 acres. The remedy, as stated in the NDEP's Record of Decision (ROD)
dated November 2, 2001, consists of:
- Excavation of impacted soils and associated material containing chemical concentrations
in excess of the site-specific cleanup goals as defined in BRCís draft Closure Plan
(submitted by BRC in August 2006 and in NDEP review);
- Transportation of the impacted soils and associated material for permanent off-site
disposal at a Corrective Action Management Unit (CAMU) located on and adjacent to the
former Basic Management, Inc., (BMI) landfill;
- Interment and containment within the CAMU.
This Corrective Action Plan describes the activities involved in excavating contaminated
materials from their current locations, transporting the materials to the CAMU, and unloading
the contaminated materials into the CAMU. The design, placement, maintenance, and other
parameters of the CAMU will be described in the Remedial Action Plan (RAP),1 that is under
revision and will be submitted by BRC to the NDEP under separate cover.
Following completion of the soil excavation activities, closure sampling and post-remediation
risk assessment will be performed to assess whether remediation has been adequately completed
at the Site, in accordance with the procedures and goals presented in the Closure Plan and the
Statistical Methodology document.