2004 Interim Record of Decision - Establishing the Standard
The 2004 IROD was the first significant federal policy commitment to lead remediation in the Omaha region. Cleanup actions before this had been temporary removals, targeting the most contaminated yards. That interim record solidified those short-term responses into a formal, science-based policy to guide all future work. It marked the point when the EPA formally acknowledged Omaha's contamination as a large-scale public health issue that required a long-term solution.
Option Four was selected because it offered the most comprehensive and long-term protection for residents. Alternative options would have left substantial contamination on site and ongoing exposure risks for children through partial removals of soil, administrative controls alone, or other means. Option Four, by contrast, got at the root of the problem by excavating and replacing contaminated soil, stabilizing exterior lead-based paint, and revegetating affected properties to prevent recontamination. The method addressed both the immediate hazards and the need for a durable remedy.
EPA also regarded Option Four as the only alternative that would meet the health-based goal stated in the IROD and ensure that Omaha's children faced no more than a five percent chance of having blood-lead levels above 10 µg/dL. It melded environmental action with public health programs, including lead education and medical outreach. It set the precedent for how EPA Region 7 would address urban lead contamination. Although expensive and complex, Option Four was the cornerstone policy that shifted Omaha's cleanup from emergency response to long-term federal stewardship.
There was a great degree of pushback regarding this decision. The document specified that the highest priority yards and lots would be dealt with first. Schools, residences that exceeded 400ppm, and residences where a child had an elevated blood lead level (according to the afforementioned standard above). This left many people wondering about the efficiency of this program, and how the remediations would be structured. On top of this, residents of the community took issue with the fact that only the yard soil would be removed, leaving flower beds, trees, landscaping, and foundation lines untouched. (U.S Environmental Protection Agency Public Meeting 2004)
U.S Environmental Protection Agency. “2004 INTERIM RECORD OF DECISION.” U.S Environmental Protection Agency, 15 Dec. 2004, semspub.epa.gov/work/07/40161817.pdf