The Federal Facility Agreement and Consent Order (FFACO, Appendix VI, 2000) prescribes a Corrective Action Strategy which involves preparing and implementing a Corrective Action Investigation Plan (CAIP), preparing a Corrective Action Decision Document (CADD), preparing and implementing a Corrective Action Plan (CAP), and finally preparing a Closure Report (CR) that leads to Long-Term Stewardship.

A corrective action is an action or series of actions taken to correct deficiencies in the disposal or containment of pollutants, hazardous wastes, and solid wastes. The intent is to prevent releases and/or potential releases into the environment or discharges and/or potential discharges of such materials into waters of the state in accordance with an approved corrective action plan. A corrective action may range from no action to clean closure where all pollutants and/or hazardous wastes are removed from the site.

The term corrective action site (CAS) is used to refer to the sites potentially requiring corrective action(s) and may include solid waste management units or individual disposal or release sites. A corrective action unit (CAU) is one or more corrective action sites grouped geographically, by technical similarity, agency responsibility, or for other appropriate reasons, for purposes of determining corrective actions. Off-Sites within the state of Nevada consist of the Project Shoal Area (PSA) and the Central Nevada Test Area (CNTA), each considered a separate CAU based on geographic location.

A series of documents is prepared for each CAU to plan and guide corrective action investigation and corrective action activities. Each of these documents requires the approval of NDEP. These include the following:

  • Corrective Action Investigation Plan(s) (CAIP) is a document that provides or references all the specific information for planning investigation activities associated with corrective action units. A CAIP may reference information in the optional CAU work plan or other applicable documents. If a CAU work plan is not developed, then the CAIP must include or reference all the management, technical, quality assurance, health and safety, public involvement, field sampling, and waste management information needed to conduct the investigations in compliance with established procedures and protocols.

  • Corrective Action Unit Work Plan(s) (CAU work plan) is an optional planning document that provides information for a CAU or a collection of CAUs where significant commonality exists. This plan may be developed to eliminate redundant CAU documentation and may contain management, technical, quality assurance, health and safety, public involvement, field sampling, and waste management information. This common information will be referenced in appropriate CAIPs.

  • Corrective Action Decision Document (CADD) is document that provides the corrective action that is selected as the result of investigation activities and the rationale for its selection. The rationale consists of an analysis of the possible alternatives and may reflect a decision ranging from no action to clean closure.

  • Corrective Action Plan (CAP) is a document that provides the plan for implementing the selected corrective action alternative. This plan shall contain a detailed description of the proposed actions that will be taken to achieve the degree of containment set forth in the NDEP-approved CADD.

  • Streamlined Approach for Environmental Restoration (SAFER) Plan is a document that provides a plan for initiating and completing corrective actions at CAUs where enough information exists to predict the appropriate corrective action before completing a CAI. The plan will incorporate the essential elements of the CAIP, the CADD, and the CAP to allow work to proceed directly from the CAI to the corrective action.

  • The Closure Report (CR) is a document that states that the completed corrective action was conducted in accordance with the approved CAP and provides to NDEP all necessary support data to confirm that the appropriate corrective action took place.

  • A Notice of completion is an NDEP-issued document signifying the completion of the CAU corrective action in accordance with the approved plans.