2009 EPA's Final Record of Decision

The 2009 Final Record of Decision was a document produced by the EPA detailing their extended plans for Omaha over the coming decades. Specifically, it outlined all that they had done thus far in the city with current remediation, studies, and research into how to effectively deal with the issue of lead contamination. Part of the order of business with this document was to allocate funds towards various issues surrounding lead in Omaha, particularly with the issues of soil remediation, stabilization of lead-based paint, and health issues including the screening for lead in children. 

One of the issues they had to tackle while administering the money was on what grounds they should allocate money to one method over another, or if they should spend money at all. They did this by building a framework to check every potential cost, ensuring that they would never be spending money frivolously. They developed 9 criteria, and their various plans of action had to satisfy these in order to be accepted as a possible plan of action. There were two threshold criteria which were overall protections of human health and the environment as well as compliance with applicable or relevant and appropriate requirements (ARARs). The first two threshold criteria had to be met, or plans were rejected without further considering the remaining criteria. The five balancing criteria include long-term effectiveness and permanence, reduction in toxicity, mobility, and volume achieved through treatment, implementability, short-term effectiveness, and cost. These were weighed in each plan, but would not be inherent roadblocks to any given plan. And finally, they developed two modifying criteria consisted of state and community acceptance. While these would also not be roadblocks, especially if a given plan was extremely effective, they were still weighed in each plan as they are useful in their own rights. 

With all of this in mind, the EPA set out to make their plan for the city of Omaha. In the end, they allocated over $236 million toward their proposed plan, with health and lead screenings being a significant portion of that. They utilized Douglas County Health Department information from the previous 25 years, which had already been used to decide effective remediation strategies to that point. They determined that it would be helpful to continue lead screenings in children as it could still be used to find remaining or even newly heightened lead zones around the city. They would also be then going to homes where these children who had tested with high levels of lead lived to see if in fact they did have high trace amounts of lead. And even with current lead remediation ongoing and with this plan going into place, they still percieved that this lead issue was such a threat to children that it had to be addressed adequately. 

So, keeping in mind how effective lead screenings had already been to the identifying and addressing of lead contamination, as well as the benefits for the children living in these lead-contaminated areas, they looked at the screenings through the lens of the criterion that they had developed for future spending. Not only did the lead screenings pass through initial two threshold criterion, but they also were shown to be well worth the costs of time and money for their implementation given their effectiveness. This helped them pass the balencing criterion. And with how easy and non-invasive they were also shown to be, they were also able to pass the modifying criterion. The screenings were shown to be so good that they were actually present in each of the two proposed lead remediation plans back in 2009 and are happening still today.