1999 EPA's Action Memorandum and Omaha’s Lead Screening Crisis
The EPA’s 1999 Action Memorandum came at a time when Omaha was finally being forced to face how serious its lead problem really was. For years, the Douglas County Health Department had been screening children for lead, and the results kept pointing to the same neighborhoods (mostly older areas east of 42nd Street) where kids were repeatedly showing elevated blood-lead levels. Some zipcodes had rates that were shocking, with roughly a quarter to almost half of tested kids crossing the CDC’s danger line. These numbers weren’t new, but by the late 1990s there was no denying that Omaha had a major public-health issue on its hands.
The memo explains how this happened. For over 100 years Omaha had many lead-using industries focused in the same area. The ASARCO refinery near downtown Omaha being the biggest. It began operating in 1870. This meant that the families living in the surrounding areas spent generations breathing in air that had lead particles in it. The soil then continued to hold lead even though ASARCO shut down in 1996. Other companies added to the mix too, like the Gould battery plant and a handful of paint and metal businesses. When you put all of that together, it makes sense that the neighborhoods downwind ended up with so much soil contamination.
The EPA didn’t just rely on industrial history, though. Much of the push for action came from the blood-lead data collected by Douglas County Health Department. Children ages six months to six years were being screened regularly, and the results clearly mapped out where lead exposure was highest. The zipcodes 68110, 68111, and 68107 continually had the worst numbers. 40% of the kids tested in the 68110 zipcode tested above the 10 µg/dL mark. This threshold was higher than the tests that were happening nationally. The screenings showed that the EPA needed to step in here, where the most kids were being affected and where the environmental hazards were concentrated.
The 1999 memo explains the plan for addressing this. EPA wanted to start what’s called a time-critical removal action, basically an emergency cleanup for places where young children were at the greatest risk. They focused on two groups: child-care facilities with soil tests over 400 mg/kg and homes where any child had tested at 15 µg/dL or more. By the time the memo was submitted, EPA sampling had already found that 39 daycares and more than half of the first 348 homestested were above the soil-lead threshold. Many of these properties sat along a wind pattern that carried dust away from downtown, which fit what soil tests were showing on the ground.
One important detail the memo highlights is how lead moves. This lead is not just sitting still. Things like wind and rain can blow or trail contaminated soil. This also means that when kids come in from being outside, they could be bringing in lead through dust and dirt. One part of a yard can test clean and negative while another part continues to be an exposure risk. This made excavation and soil replacement the most realistic way to reduce exposure.
Another big point in the memo is that local agencies simply didn’t have the money or authority to do cleanup at this scale. Lead removal is expensive, and Omaha needed heavy equipment, disposal plans, and long-term coordination. EPA had to request permission to go over both the usual 12-month limit and the standard two-million-dollar cap for removal actions. Without those exemptions, the cleanup couldn’t have moved forward.
Overall, the Action Memorandum shows how environmental data and public-health screenings came together at the right moment. Omaha was already aware that it had a problem. This document shows that federal involvement finally got involved once they were more knowledgeable about the topic. Blood-lead results helped design the cleanup plan and initiated the start of soil removal work.
United States Environmental Protection Agency. (1999). Action memorandum: Request for removal action, twelve-month exemption, and two-million-dollar exemption at the Omaha Lead Site, Omaha, Nebraska and Council Bluffs, Iowa (EPA Region 7). https://semspub.epa.gov/work/07/95704.pdf