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1 - paducah environmental information center

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Annual Site Environmental Report for 1999<br />

actions are intended to be focused in nature,<br />

cleanup standards selected under a specific OU<br />

should also be protective of other exposure<br />

scenarios when applicable. For example, if a<br />

groundwater COC is present within the upper 10'<br />

of soil, then the cleanup standard should not only<br />

be protective of the off-site groundwater user<br />

(off-site resident), but it should also reflect<br />

protection of an industrial worker from direct<br />

contact. In cases where the Surface Soils OU is<br />

targeting a COC to .protect industrial workers<br />

from direct contact, the selected Cleanup<br />

standard should also be designed to be<br />

protective of recreational users and ecosystems<br />

should off-site migration via surface runoff be .a<br />

concern.<br />

When a specific SWMU/w AG has the<br />

potential to impact multiple pathways/receptors,<br />

it may be assigned to two or more OUs. As an<br />

example, the COCs contributing to groundwater<br />

may be addressed under the Groundwater OU,<br />

whereas the surficial contamination presenting a<br />

direct contact risk to industrial workers may be<br />

addressed under the Surface Soils OU.<br />

Upon completion of investigation for the<br />

five OUs, a study will be conducted. The scope<br />

of the Comprehensive Site-Wide OU study will<br />

include a comprehensive site-wide baseline risk<br />

assessment to evaluate any residual risk<br />

remaining at the site after completion of<br />

activities at the five initial OUs, and to evaluate<br />

the cumulative effects from all media. If the<br />

Comprehensive Site-Wide OU risk assessment<br />

concludes the actions taken to date collectively<br />

provide adequate protection to· human health<br />

and the environment, a final Comprehensive<br />

Site-Wide OU Proposed Plan and ROD will be<br />

issued. These reports will be followed by a fmal<br />

remediation report declaring site remediation<br />

complete. In the event the Comprehensive Site­<br />

Wide OU risk assessment determines additional<br />

actions are needed, a feasibility study (FS) will<br />

be developed with the preferred . alternative<br />

documented in a Proposed Plan and ROD,<br />

folloWed by the necessary remedial actions prior<br />

to issufugthe final remediation report. .<br />

........<br />

Remedial Priorities<br />

PGDP currently contains numerous sites<br />

that are subject to the CERCLA cleanup process.<br />

The SMP establishes work priorities based on<br />

factors specified in the FFA. Under the original<br />

strategy, the WAGs were prioritized based on the<br />

following criteria:<br />

• immediate risks,<br />

• hot spots associated with off-site<br />

contamination,<br />

• suspected sources of off-site<br />

contamination,<br />

• suspected sources of on-site<br />

contamination, and<br />

• groundwater and sUrface water.<br />

While several a

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