|From:||Lenny Siegel <email@example.com>|
|Date:||Fri, 21 Apr 2000 08:14:39 -0700 (PDT)|
|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 <firstname.lastname@example.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 email@example.com http://www.cpeo.org You can find archived listserve messages on the CPEO website at http://www.cpeo.org/lists/index.html. If this email has been forwarded to you and you'd like to subscribe, please send a message to: firstname.lastname@example.org ________________________________________________________________________ Start an Email List For Free at Topica. http://www.topica.com/register
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