2000 CPEO Military List Archive

From: Lenny Siegel <lsiegel@cpeo.org>
Date: Fri, 21 Apr 2000 08:14:39 -0700 (PDT)
Reply: cpeo-military
Subject: [CPEO-MEF] Range Rule Risk Methodology
At long last, a version (March, 2000) of the Interim Range Rule Risk
Methodology is ready for public review and comments. CPEO has a limited
number of copies that it will make available to public stakeholders
willing to wade through the 200-page document. Please contact us as
415/405-7750 or send an e-mail to <cpeo@cpeo.org>. (We will refer other
requests to the Army and its contractors. The document is available
electronically for those people who have the bandwidth to handle such
large documents.)

The Interim Range Rule Risk Methodology (IR3M) is a support document for
the pending Range Rule, but it is not a "rule" itself. It is an
adaptation of the National Contingency Plan (NCP) that is designed to
facilitate the selection of responses at closed, transferred, and
transferring munitions ranges, providing iterative data quality
objectives as well as a qualitative scheme for weighing the NCP criteria
to address both explosive and toxic risk.

The IR3M is "Interim" because it does not include site close-out
criteria. While some people may consider this a weakness of the
methodology, efforts between regulators and the Army team leading R3M
development to come up with such criteria foundered over arguments over
the suitability of quantitative risk assessment.

As I have written before, I think the IR3M contains many positive
features, but that its complexity and length may make it difficult for
many stakeholders to play a constructive role in the decision-making
process. Furthermore, it may take some time to refine the prescriptive
algorithms - that is, the method for combining qualitative rankings -
built into this version of the IR3M.

But the document is far from final. The Defense Department is seeking
feedback and for the entire Range Rule to take full legal effect, U.S.
EPA has to buy into the process. Even then, if the Range Rule and its
accompanying methodology prove unsatisfactory, states with significant
range contamination may choose to exercise their own legal authorities
independent of the new federal process.


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 222B View St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/968-1126

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