CAG Questions About the Interim Report

December 2004

On December 15, 2004, the Environmental Protection Agency released their Interim Record of Decision on the Omaha Lead Site. The record made it abundantly clear that there must be a plan enacted upon “to protect the residents of Omaha that are at greater risk from highly contaminated soils while a final remedy is being developed for remaining properties that are contaminated at low to moderate levels” (EPA, 1). Prior to the document’s release, the EPA opened a 30-day public comment period which began on July 16, 2004. They took hundreds of questions and comments from the public and groups like the CAG.  The number of replies were so great that the EPA extended the comment period three separate times and ended on November 1, 2004. The final responsiveness summary was 54 pages long even when similar comments and questions were grouped together.

The Community Action Group was one of the parties that participated heavily during the public comment period. They did more than just simply ask questions and voice their opinions though. The CAG sent a “Comprehensive Plan for the Elimination of Lead Hazards in Omaha, Nebraska” (EPA, 8). The plan consisted of multiple layers to ensure a complete coverage to combat lead poisoning in Omahans. This ranged from the education of the dangers of lead to parents and homeowners with potentially lead contaminated soil to making sure there were consistent and available data accessible on blood levels in those tested for lead poisoning and on houses that were tested for lead concentration in the soil. The CAG also sent a funding plan that they recommended the EPA use to make sure the objectives that both the EPA and the CAG hoped to achieve in lead remediations were achieved successfully. CAG wanted the money to go to a non-profit body to be a watchdog for all the agencies and programs involved in the Omaha Lead Site. They also wanted to fund programs that could reach everyone in Omaha without language or cultural barriers stopping them. These programs would help to educate and bring awareness to families on the dangers of lead and how they can remediate any lead problems they have in or around their homes. The funds would also help children get blood tested, monitor the ones tested with elevated lead in their blood in their homes to try and identify the cause of their lead poisoning.

After the two plans they recommended, the Cag then asked several questions to the EPA about the proposed plan. Two important questions on the mind of the members of the CAG were “how will risks associated with excavation and transportation of lead impacted soils to and residents be addressed? What will be the impacts to local neighborhoods and residents of increased truck traffic from implementation of EPA's proposed remedy?” (EPA, 9). And

“If an onsite soil repository were to be created, where will it be located? Will the public have any input into the decisions made regarding siting such a repository? If the soil is used as beneficial fill, what are the implications regarding risk to receptors living and working near the fill area? Will the public have any input into the decisions made regarding the use of the soil as fill material. (EPA, 10). 

The EPA’s response was that both the removal companies contracted with the remediation efforts and the potential dump sites would need to follow and meet several guidelines before they would be allowed to work with the lead contaminated soil. The need for a dump site specifically for the lead contaminated soil at the time the report was made was not decided yet, but the EPA was steadfast that the requirements for such a site would be staunchly upheld and public comment on the potential location would be welcomed (EPA, 9-10). The response from the EPA and taking eight pages to answer specifically on the CAG’s comments and questions show that the EPA valued their input on the matter of lead remediation in Omaha.