SECOND FIVE-YEAR REVIEW REPORT FOR

OMAHA LEAD SUPERFUND SITE

DOUGLAS COUNTY, NEBRASKA

Prepared by

U.S. Environmental Protection Agency Region 7

Lenexa, Kansas

Superfund and Emergency Management Division

•g|A(?Ue>Date

11

30467871

Superfund

Table of Contents

LIST OF ABBREVIATIONS & ACRONYMS........... ................................'............................................ iii

I. INTRODUCTION.......................................................................................................... 1Second Five-Year Review Summary Form...........................................................................................2

II. RESPONSE ACTION SUMMARY...................................... ..............................................................3Basis for Taking Action......................................................................................................................... 3Response Actions................................................................................................................................... 3Status of Implementation..... i.................................................................................................................5IC Summary Table........... ....................................................... 6Systems Operations/Operation & Maintenance..................................................................................... 6

III. PROGRESS SINCE THE LAST REVIEW..................... 7

IV. FIVE-YEAR REVIEW PROCESS....................................................................................................... 7Community Notification, Involvement & Site Interviews..................................................................... 7Data Review......................................................................................................... 7Site Inspection........................................................................................................................................ 8

V. TECHNICAL ASSESSMENT............................................................................................................... 8QUESTION A: Is the remedy functioning as intended by the decision documents?......................... 8QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial actionobjectives (RAOs) used at the time of the remedy selection still valid?...............................................9QUESTION C: Has any other information come to light that could call into question the protectiveness of the remedy?.............................................................................................................. 10

VI. ISSUES/RECOMMENDATIONS........................................... ......................................................... 11

VII. PROTECTIVENESS STATEMENT................................................................................................. 12

VIII. NEXT REVIEW................................................................................................................................12

APPENDICES Appendix A - Reference List Appendix B - Site Locator Map Appendix C - Site Status Map

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LIST OF ABBREVIATIONS & ACRONYMS

CERCLACFRDCHDEPAFYRIAICsNPLOUppmRAORODRPMTBCpg/dEUSACEUU/UE

Comprehensive Environmental Response, Compensation, and Liability ActCode of Federal RegulationsDouglas County Health DepartmentU.S. Environmental Protection AgencyFive-Year ReviewInteragency AgreementInstitutional ControlsNational Priorities ListOperable Unitparts per millionRemedial Action Objectives <Record of DecisionRemedial Project ManagerTo be consideredmicrograms per deciliterU.S. Army Corps of EngineersUnlimited use and unrestricted exposure

I. INTRODUCTION

The purpose of a Five-Year Review, or FYR, is to evaluate the implementation and performance of a remedy in order to determine whether the remedy is and will continue to be protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in five-year review reports such as this one. In addition, FYR reports identify issues found during the review, if any, and document recommendations to address them.

The U.S. Environmental Protection Agency is preparing this five-year review pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act, or CERCLA, Section 121, consistent with the National Oil and Hazardous Substances Pollution Contingency Plan, (40 CFR Section 300.430(f)(4)(ii)), and considering EPA policy.

This is the second FYR for the Omaha Lead Superfund Site, or Site. The triggering action for this statutory review is the completion date of the previous FYR. The FYR has been prepared because hazardous substances, pollutants, or contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure, or UU/UE.

The Site consists of two operable units, or OUs, and both OUs will be addressed in this FYR. OU1 addressed child high impact areas such as child daycare facilities, and the most highly contaminated site properties exceeding 800 parts per million, or ppm. OU2 addressed the remaining residential and residential-type properties that exceed risk-based soil lead levels established during the final remedy selection process.

The Omaha Lead Superfund Site FYR was led by Katy Maynard, Remedial Project Manager, or RPM. Participants included Tamara Freeman, Community Engagement Specialist; Steve Kemp, Remedial Project Manager; Elizabeth Hagenmaier, Remedial Project Manager; Venessa Madden, Ecological Risk Assessor; Todd Phillips, Human Health Risk Assessor; Steve Sanders, Site Attorney; and Stacey Strieker, Nebraska Department of Environmental Quality (now known as the Nebraska Department of Environment and Energy). The review began on 8/27/2018.

Site Background

The city of Omaha, Nebraska, covers an area of approximately 130 square miles. According to the 2010 census the city has a population of 408,958. The Site encompasses 27 square miles with a population of approximately 130,000. Appendix B shows the location and extent of the Site. The Site is centered around downtown, bordered on the east by the Missouri River, where two former lead-processing facilities operated. American Smelting and Refining Company, Inc., or ASARCO, operated a lead refinery at 500 Douglas Street in Omaha, Nebraska, for over 125 years, from the early 1870s until 1997. The Aaron Ferer & Sons Company, or Aaron Ferer, and later the Gould Electronics, Inc., or Gould, lead battery recycling plant were located at 555 Farnam Street. Aaron Ferer operated from the early 1950s until 1963, at which point the facility was purchased by Gould, which operated the facility until it closed in 1982. Both the ASARCO and Aaron Ferer/Gould facilities released lead-containing particulates to the atmosphere from their smokestacks which were deposited on surrounding residential properties.'

The Site was proposed for the National Priorities List, or NPL, on February 24, 2002. The proposed NPL listing became final on April 30, 2003.

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The Site includes only those residential properties where soil lead concentrations represent an unacceptable risk to human health. Soil lead concentrations were determined by collecting soil samples from each property. Residential properties where soil sampling indicates soil lead concentrations are below a level of concern are not considered part of the Site. Commercial and industrial properties are also excluded from the Site.

SECOND FIVE-YEAR REVIEW SUMMARY FORM

Lead agency: EPAflf “Other Federal Agency”, enter Agency name]’.

Author name (Federal or State Project Manager): Katy Maynard

Author affiliation: U.S. EPA Region 7

Review period: 8/27/2018 - 5/24/2019

Date of site inspection: 4/30/2019

Type of review: Statutory

Review number: 2

Triggering action date: 9/4/2014

Due date (five years after triggering action date)’. 9/4/2019

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II. RESPONSE ACTION SUMMARY

Basis for Taking Action

The contaminant of concern for soil is lead.

The human health risk assessment for lead focused on young children seven years of age and younger (0 to 84 months) who are residents within the Site. Young children are most susceptible to lead exposure because they have higher contact rates with soil or dust, absorb lead more readily than adults, and are more sensitive to the adverse effects of lead than are older children and adults. The effect of greatest concern in children is impairment of the nervous system, including learning deficits, reduced intelligence, and adverse effects on behavior.

To evaluate risks, the Integrated Exposure Uptake Biokinetic (IEUBK) model was run using site- specific data to predict a lead soil level that will be protective of children and other residents.

Response Actions

In 1998, the Omaha City Council requested assistance from the EPA in addressing the problems with lead contamination in the area. The EPA initiated an investigation into the lead contamination under the authority of CERCLA in 1999. A response action was initiated under CERCLA removal authority and began in August 1999 through an Interagency Agreement, or IA, with the U.S. Army Corps of Engineers, or USACE. The initial removal response actions consisted of excavation and replacement of soil exceeding 800 parts per million, or ppm, lead at residential properties and exceeding 400 ppm lead at child care centers and residences where children with elevated blood lead levels resided.

From 1999 through 2002, excavation of contaminated soil and placement of uncontaminated backfill was completed at 257 properties by the USACE under the IA. In August 2002, a second removal action was initiated at all other residential-type properties where the maximum non-foundation soil lead concentration exceeded an action level of 2,500 ppm. Residential-type properties include single- and multi-family dwellings, apartment complexes, child care centers, vacant lots in residential areas, schools, churches, community centers, parks, greenways, and any other areas where children may be exposed to site-related contaminated media. As cleanups were completed at the most highly contaminated residential properties, the soil lead action level was sequentially reduced to 1,200 ppm and eventually 800 ppm so that soil cleanups could continue under CERCLA removal authority at the properties remaining with the highest mid-yard soil lead levels. At properties determined to be eligible for response under either of the removal actions, soils exceeding the cleanup level of 400 ppm lead were excavated and replaced with clean soil, and excavated areas were revegetated with sod.

The EPA completed excavation of contaminated soil and replacement of uncontaminated backfill at a total of 144 properties through 2003. The EPA and the USACE completed a combined total of 310 properties in 2004. The removal action was completed by the EPA and the USACE at 773 properties in 2005 as work was transitioning to CERCLA remedial authority.

In August 2005, ASARCO filed for bankruptcy protection under Chapter 11 of the Bankruptcy Code in the Southern District of Texas, Corpus Christi Division. The United States filed a proof of claim in the bankruptcy action to cover all past and future costs associated with the Site. The claim with ASARCO for the Site was resolved by the court on July 5, 2009 (Case 05-21207). As a result of the settlement,

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ASARCO paid $186,500,000 plus interest to the EPA. As a result of subsequent court actions,ASARCO paid an additional $16,500,000 to the EPA, for a total of $220,000,000.

Pursuant to Consent Decrees, Union Pacific Railroad Company paid $3.15 million to the Omaha Healthy Kids Alliance and $21.35 million to the EPA in August 2011 (8:ll-cv-00195-LSC-FG3); Gould Electronics Inc. paid $1.1 million to the EPA in August 2011 (8:ll-cv-00195-LSC-FG3); NL Industries paid $624,000 to the EPA in March 2012 (8:12-cv-00059-JMG-CRZ); and Aaron Ferer & Sons Company paid $480,000 to the EPA in February 2013 (8:12-cv-00406-RGK-CRZ).

OU1

In December 2004, the EPA signed an Interim Record of Decision, or ROD for the Site.

• Remedial Action Objective for the remedy selectedo To reduce the risk of exposure of young children to lead such that an individual child, or

group of similarly exposed children, have no greater than a 5 percent chance of having a blood-lead concentration exceeding 10 micrograms per deciliter, or pg/dL.

• Remedy Componentso Excavation, backfilling, and revegetation of lead-contaminated residential soils in an

estimated 5,600 residential-type properties exceeding 800 ppm, and properties exceeding 400 ppm in areas considered high child-impact areas or with a residing child exhibiting an elevated blood-lead level;

o Participation in a comprehensive remedy with other organizations and agencies to characterize and address all identified sources of lead exposure at the Site;

o Stabilization of exterior lead-based paint that threatens the long-term protectiveness achieved through excavation and replacement of lead-contaminated surface soils;

o Removal of interior dust in instances where contaminated soils contribute to interior lead dust loadings; and

o Health education for the Omaha community and medical professionals to support public awareness; exposure prevention programs; in-home assessments; blood-lead screening programs; and diagnosis, treatment, and surveillance programs.

OU2

In May 2009, the EPA signed a final ROD for the Site.

• Remedial Action Objectiveo To reduce the risk of exposure of young children to lead in (or derived from) outdoor

yard soil such that, given typical exposures to lead in air, water and food, the IEUBK model predicts there is no greater than a 5 percent chance an individual child, or group of similarly exposed children, will develop a blood-lead concentration exceeding 10 pg/dL.

• Remedy Componentso Excavation, backfilling and revegetation of lead-contaminated residential soils in an

estimated 9,966 residential-type properties exceeding 400 ppm;o Participation in a comprehensive remedy with other organizations and agencies to

characterize and address all identified sources of lead exposure at the Site;

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o Stabilization of exterior lead-based paint that threatens the long-term protectiveness achieved through excavation and replacement of lead-contaminated surface soils;

o Response to interior dust involving a HEPA vacuum program and health education at remediated properties with interior dust lead levels exceeding eligibility criteria;

o Health education for the Omaha community and medical professionals to support public awareness, exposure prevention programs, in-home assessments, blood-lead screening programs, and diagnosis, treatment, and surveillance programs;

o Operation of a Local Lead Hazard Registry as a type of Institutional Control.

Table 1: Cleanup Levels Selected

Media Cleanup LevelOU1 Soil 800 ppm lead at any residential-type property; 400 ppm lead in high child-

impact areas; 400 ppm lead at properties with a child exhibiting an elevated blood-lead level

OU2 Soil 400 ppm lead for all residential and residential-type properties

Status of Implementation

Implementation of the final remedy began in 2009 and remains ongoing. Initial work was completed by the EPA and in 2015, under a Cooperative Agreement, transitioned to the city of Omaha and the Douglas County Health Department, or DCHD. At the time the EPA transitioned work, lead- contaminated soil had been remediated at 13,090 properties (93%) of the properties eligible for soil remediation, and lead-based paint stabilization was completed on 6,249 (92%) of the eligible properties. The city of Omaha began cleaning up additional residential properties in September 2017. As of December 2018, cleanup activities were completed at 113 properties by the city of Omaha. Within the boundary of the Site, 256 properties remain that have not been sampled and 449 properties where access to the property for remediation has been unsuccessful or denied. As part of the Cooperative Agreement, the DCHD compiles childhood blood-lead data, collects interior dust samples from residences, and provides HEPA vacuum cleaners to address historic releases to home interiors. The DCHD also conducts education and outreach to homeowners and health care providers to increase awareness of the health effects of lead.

Institutional Controls

The institutional control program at the Site is executed through the city of Omaha’s Lead Registry (www.omahalead.orgl. This website is a publicly available database that depicts the status of each of the non-commercial properties within the boundary of the Site. As properties are remediated, the status of the property is changed in an internal EPA database referred to as the Omaha Lead database. The city retrieves selected data from the EPA’s database for use in the Omaha Lead Registry. The Omaha Lead Registry identifies the properties where the soil has been remediated and any lead-based paint has been stabilized. The EPA has been working closely with the city to assist them in the development of a database and application that will be wholly owned by the city of Omaha. Upon completion and

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production release, the city will become the primary data manager for the Omaha Lead data. The EPA will develop a process to pull data from the new city-owned database to ensure that the EPA’s Omaha Lead database continues to be updated.

Partial Deletion Process

As properties are cleaned up pursuant to the ROD for the Site and it is determined that no further response action under CERCLA is appropriate, the properties are eligible for deletion from the NPL.The partial deletion process is conducted in accordance with 40 CFR 300.425(e) and is consistent with the Notice of Policy Change: Partial Deletion of Sites Listed on the National Priorities List 60 FR 55466 (Nov. 1, 1995). The EPA deleted 1,154 properties on December 6, 2013, 294 properties on April 10, 2017, and 101 properties on August 28, 2018, from the Site. All the deleted properties were remediated to levels that allow for unrestricted use and do not require operation or maintenance activities (i.e., there is no contamination left behind at depth that exceeds the cleanup standards specified in the ROD).

IC Summary Table

Table 2: Summary of Planned and/or Implemented ICs

Media, engineered controls, and areas that do not support UU/UE based

on current conditions

ICsNeeded

ICs Called for in the Decision

Documents

ImpactedParcel(s)

ICObjective

Title ofIC Instrument

Implemented and Date (or planned)

Soil Yes YesProperties

Remediated

Provide additional protection of human

health by making information available

to the public about conditions at

individual OLS properties.

Omaha Lead Registry, 2012

Systems Operations/Operation & Maintenance

Because the primary mechanism of contamination was deposition of airborne contaminants from lead smelting operations, the lead concentration found in the soil generally decreases with depth. However, to date the investigation of the Site identified 70 properties where the lead concentration is significantly higher. As with the other residential properties, surface soil at these properties was excavated and removed, and the excavated soil was replaced with a minimum of one foot of clean soil and revegetated. For the present, the clean fill prevents exposure to the remaining underlying contaminated material. The EPA anticipates operation and maintenance activities for properties remediated under OU1 and OU2 to include maintenance of the soil cap and revegetated areas for those properties where lead-contaminated soils are left at depth. In addition, the remedy for both OUs includes implementation and maintenance of institutional controls identifying properties where elevated lead soils remain after remedial actions are completed.

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III. PROGRESS SINCE THE LAST REVIEW

This section includes the protectiveness determinations and statements from the last FYR as well as the recommendations from the last FYR and the current status of those recommendations.

Table 3: Protectiveness Determinations/Statements from the 2014 FYR

ou#ProtectivenessDetermination Protectiveness Statement

1 Will be Protective The remedy at OU1 is expected to be protective of human health and the environment upon

completion. In the interim, remedial activities completed to date have adequately addressed all

exposure pathways that could result in unacceptable risks in these areas.

2 Will be Protective The remedy at OU2 is expected to be protective of human health and the environment upon

completion. In the interim, remedial activities completed to date have adequately addressed all

exposure pathways that could result in unacceptable risks in these areas.

There were no issues and recommendations identified in the last FYR.

IV. FIVE-YEAR REVIEW PROCESS

Community Notification. Involvement & Site Interviews

A public notice was made available by newspaper posting in the Omaha World-Herald newspaper and Omaha Star newspaper on September 19 and September 21, 2018, respectively, stating that the FYR started and inviting the public to submit any comments to the EPA. The results of the review and the report will be made available at the site information repository located at www.epa.gov/superfund/omahalead.

No site interviews were conducted for the second FYR.

Data Review

In general, for activities completed at OUs 1 and 2, under the Cooperative Agreement with the city of Omaha, the city is conducting a visual inspection of soil covers and implementing the institutional control. Since the last FYR, the City has inspected 259 properties where the remedy was implemented. Of the 259 properties inspected, 185 are city-owned, 53 are owned by non-profits, and the remaining 21 are privately owned. Of the 259 properties, 17 had lead concentrations over the cleanup level at the base of excavation. For the 259 properties inspected, it has been determined that for 23% the remedy has not been disturbed, and for 77% the remedy has been disturbed to some extent. The disturbances range from having mostly weeds present instead of grass, to having large bare areas, to the structure being demolished since remediation and the remedy not likely remaining intact due to the demolition.

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Site Inspection

The inspection of the Site was conducted on 4/30/2019. In attendance were RPMs Steve Kemp and Katy Maynard, EPA. The purpose of the inspection was to assess current conditions and the protectiveness of the remedy. RPMs Kemp and Maynard conducted a visual inspection of 35 properties of the 259 properties the city had inspected in 2017 and 2018. The properties inspected were properties with remediation and restoration completed during or before 2015. For purposes of the inspection, the condition of the property where the remedy was implemented was categorized as noted in the table below. Properties noted as having weeds, bare spots, etc., are still considered to be effective in preventing exposure. Properties where demolition of the structure has occurred may have disrupted the remedy to an extent there may be a complete exposure pathway.

Table 4: Inspection Observations

PercentDisturbance

NumberofProperties

Description of Percent Disturbance Category

Intact 4Intact is considered a well-established and maintained lawn with minimal to no weeds or bare spots in the area that was remediated.

<10% 5Less 10 percent is considered to have some weeds or small areas of spotty or dead vegetation but overall the vegetation was in good condition.

10-25% 9These properties had bare areas of soil, spotty vegetation cover or areas of mostly weedy vegetation.

26-50% 3These properties had spotty vegetation, bare areas of soil and/or distressed vegetation.

51-75% 3These properties had mostly weedy vegetation, some bare spots and/or distressed vegetation throughout the remediated area.

76 -100% 11 These properties had the structure demolished.

Total 35

V. TECHNICAL ASSESSMENT

QUESTION A: Is the remedy functioning as intended by the decision documents?

Question A Summary;

For OU1, the completed remedy is functioning as intended by the decision document. There have been 13,203 properties remediated as of December 2018.

For OU2, the city of Omaha and the DCHD are continuing the remedial action. Since the previous FYR, 890 properties have been cleaned up by the EPA and 113 properties have been cleaned up by the city of Omaha, as of December 31, 2018. For properties already addressed under OU2, the remedy is functioning as intended by the decision document.

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For both OUs, the city of Omaha’s Lead Registry serves as an institutional control. It is available to the public, regularly updated, and continuously being visited. Although it is continuously being visited, the EPA is continuing to work with the city to improve public awareness of the Omaha Lead Registry. In addition, operation and maintenance activities continue at the remediated properties to inspect the soil cover and determine whether property use impacts the remedy. Since the last FYR, the city has inspected 259 properties where the remedy was implemented. For these 259 properties inspected, it was determined that, for 23%, the remedy has not been disturbed; and for 77%, the remedy has been disturbed to some extent. The disturbances range anywhere from having mostly weeds present instead of grass, to having large bare areas, to the structure being demolished since remediation and the remedy not likely remaining intact due to the demolition.

QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy selection still valid?

Question B Summary:

The cleanup level selected for residential yards may not protect children to current CDC-acceptable reference value blood-lead concentrations. The EPA will reexamine blood-lead levels and determine whether additional action is warranted.

Changes in Standards and TBCs

For lead in soil, the EPA’s Office of Solid Waste and Emergency Response Directives 9355.4-12 (EPA, 1994) and 9200.4-27P (EPA, 1998) were identified as federal chemical-specific To Be Considered guidance documents. These directives identify 10 pg/dL as the blood-lead level of concern. However, since the time these directives were issued, increasing evidence has shown that blood-lead levels below 10 pg/dL may also have negative health impacts. As a result, on December 22, 2016, the Office of Land and Emergency Management issued Directive 9200.2-167 (EPA, 2016) stating “the current scientific literature on lead toxicology and epidemiology provides evidence that adverse health effects are associated with blood lead levels less than 10 pg/dL.’’ The directive recommends that regions “consider the current scientific conclusions when implementing OLEM’s soil lead policy, specifically referencing the 2012 National Toxicology Program’s Monograph on Health Effects of Low-Level Lead (NTP, 2012) and the EPA’s 2013 Integrated Science Assessment for Lead (EPA, 2013). The directive states that the 2013 ISA found clear evidence of cognitive function deficits at blood-lead levels between 2 and 8 pg/dL, and that the 2012 NTP s monograph found sufficient evidence of effects on cognitive measures and behavior at blood lead levels below 5 pg/dL.

The cleanup level for the Omaha Lead Site was derived based on OSWER’s 1994 and 1998 soil lead directives, which identify 10 pg/dL as the blood-lead level of concern, in contrast with the latest OLEM directive, which indicates that adverse health effects are associated with blood-lead levels of 5 pg/dL, and possibly as low as 2 pg/dL, in young children. If the blood-lead level of concern is revised to a value less than 10 pg/dL, the resulting cleanup level for lead in soil in the OU2 ROD that is based on potential health risks to a child receptor would need to be examined for continued protectiveness.

Changes in Toxicity and Other Contaminant Characteristics

Increasing evidence supports a lower blood-lead level of concern than was used at the time of the ROD.

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Changes in Risk Assessment Methods

Changes in risk assessment methodology have occurred since the risk assessment was completed for the Site. For example, the EPA has completed an update of many of the standard default exposure factors (EPA, 2014); thus, many of the exposure assessment input parameters in the original risk assessment are different than values currently recommended. However, these changes do not have a significant impact on the conclusions of the risk assessment.

Changes in Exposure Pathways

The EPA is not aware of any changes in land use, routes of exposure, contaminants, or toxic byproducts that could impact the protectiveness of the remedy. However, based on the data review, the change in physical site conditions such as the demolition of structures or removal of paved surfaces may create a direct contact exposure pathway.

Ecological routes of exposure have not changed. The Omaha Lead Site is located entirely within an urban area in eastern Omaha and includes only residential properties. The residential soil cleanup level for lead at this Site has been determined to be protective of ecological receptors that would utilize urban environments. This conclusion is based on modeled risks to urban wildlife, which includes sensitive ecological receptors, such as the American robin. Robins are common migratory songbirds in the urban landscape that tend to be highly exposed to contaminated soil due to ingestion of soil invertebrates. As robins are a sensitive ecological receptor, urban wildlife species that are less sensitive should also be protected.

Expected Progress Towards Meeting RAOs

The RAO for OU1 and OU2 is to reduce the risk of exposure of young children to lead such that an individual child, or group of similarly exposed children, have no greater than a 5 percent chance of having a blood-lead concentration exceeding 10 pg/dL. The remedy for OU1 was an interim measure to address the continuing environmental lead exposures to young children while additional study was ongoing to determine a final Preliminary Remediation Goal for the Site. The OU1 Remedial Action, or RA, was considered complete when the final remedy for the Site was promulgated in the OU2 decision document. The remedy for OU2 is ongoing but is progressing as expected towards meeting this RAO.

QUESTION C: Has any other information come to light that could call into question the protectiveness of the remedy?

The EPA is aware of information that could call into question the protectiveness of the remedy. Based on findings in the data review and site inspection sections, site conditions are changing at properties. A change in site conditions could effect the protectiveness of the remedy.

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VI. ISSUES/RECOMMENDATIONS

Issues/Recommendations

OU(s) without Issues/Recommendations Identified in the Five-Year Review:

1

Issues and Recommendations Identified in the Five-Year Review:

OU(s): 2 Issue Category: OtherAssess blood lead levels

Issue: The cleanup levels selected for residential yards may not protect children to current CDC-acceptable reference value blood-lead concentrations.

Recommendation: Region 7 is supporting the reexamination of protectiveness of the OU2 RA in light of OLEM Directive 9200.2-167.The results of the reexamination will be used to determine the continued protectiveness of the OU2 RA and whether additional actions should be taken to further reduce the risk of future elevated blood-lead levels in young children at the site.

Affect Current Protectiveness

Affect Future Protectiveness

PartyResponsible

OversightParty

Milestone Date

No Yes EPA EPA 9/30/2024

OU(s): 2 Issue Category: OtherProperties with a change in site condition

Issue: Properties may have a change in site conditions, such as the structure being demolished that may create an exposure pathway.

Recommendation: To develop an approach to assess the potential recontamination at properties with a change in site conditions.

Affect Current Protectiveness

Affect Future Protectiveness

PartyResponsible

OversightParty

Milestone Date

No Yes EPA EPA 9/30/2024

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VII. PROTECTIVENESS STATEMENT

Protectiveness Statenient(s)

Operable Unit: Protectiveness Determination:1 Protective

Protectiveness Statement: environment.

The remedy for OU1 is protective of human health and the

Protectiveness Statement(s)1 Operable Unit: Protectiveness Determination:1 2 Protectiveness Deferred

Protectiveness Statement: The remedy at OU2 is expected to be protective upon completion of the RA, once the EPA assesses risks associated with soil cleanup levels and associated target blood-lead levels in light of new scientific information. Additionally, some properties have a change in site conditions, and it is currently unknown whether the change in site conditions created an exposure pathway. In the interim, soil excavation activities completed to date have removed the contaminated soils and addressed interior dust and paint exposures, and the cooperative agreements with the city of Omaha and DCHD ensure residential properties continue to be evaluated, remediated and health education delivered as warranted.

VIII. NEXT REVIEW

The next FYR report for the Omaha Lead Superfund Site is required five years from the completion date of this review.

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APPENDIX A

REFERENCE LIST

EPA. 2018. Memorandum Regarding Documentation of Backfill Specification in Remedial Action Contracts for Omaha Superfund Site. April.

Omaha World Herald. 2016. Public Notice of Public Comment Period and Partial Deletion. October.

NTP. 2012. National Toxicology Program Monograph on Health Effects of Low-Level Lead. National Institute of Environmental Health Sciences. June.

APPENDIX B

SITE LOCATOR MAP

GARTER

US 64

BusinessHIGHWAYS

District DOUG lAS

iclud :d Fn NPL Site

MISSOURI

Omaha Lead Superfund Site Omaha, Nebraska

Figure 1 Site Locator

April 15, 2014Legend

Omaha Focus Area

Central Business District

accuracy, completeness, or /,timeliness ot the information Ijshown, and shall not be liable ;lor any injury or loss resulting from reliance upon the information shown.

Date Saved: 8/25/2014 Casey J. McLaughlin

APPENDIX C

SITE STATUS MAP

Omaha Lead Superfund Site Omaha, Nebraska

Site StatusLegend May 1, 2019l l Omaha Focus Area CD State Boundary

CD County Boundary

Park** Paint Stabilization Complete (6.370)M Soil Remediation Complete (13,205)

Central Business District (Excluded From NPL Site)

"7^