[CPEO-MEF] ASTSWMO criticizes Munitions Prioritization Rule

[Lenny Siegel <lsiegel@cpeo.org>]

The Associations of State and Territorial Solid Waste Management
Officials, representing state environmental regulators across the
country, has submitted detailed comments critical of the Defense
Department's draft Munitions Response Site Prioritization Protocol,
proposed formally as a rule on August 22, 2003. In a November 20, 2003
letter, Clarence Smith of Illinois EPA, Chair of ASTSWMO Federal
Facilities Research Subcommittee, wrote:

"Attempting to develop such a protocol in the short time provided has
been understandably challenging.  However, we continue to identify what
is deemed as 'fatal flaws' with the Proposed Rule as it is currently
presented.  Many of these concerns have been previously provided to DoD
through both oral and written comments.  The Subcommittee believes that
before the Proposed Rule is finalized and priorities assigned to sites
identified in the inventory, additional independent peer review, outside
DoD's testing work groups, is critical to substantiate the Proposed
Rule's intent of assigning priorities based on factors such as safety
and environmental hazard potential.  If an independent peer review were
conducted, the ASTSWMO Federal Facilities Research Subcommittee would
welcome an invitation to be a part of that external peer review.   As
described below, the Proposed Rule's 'scoring' within each element may,
in many instances, misrepresent real public health concerns that could
make a site's priority too high or too low."

To download the complete ASTSWMO letter and comments, go to
http://www.astswmo.org/whatsnew.htm and click on the second bullet. To
use the full URL,
http://www.astswmo.org/Publications/Federal%20Facilities%20Files/ASTSWMO%20comments%20via%20email.doc,
you'll probably need to cut and paste.

To download the rule from the Federal Register, go to
http://a257.g.akamaitech.net/7/257/2422/14mar20010800/edocket.access.gpo.gov/2003/pdf/03-21013.pdf.
You might need to cut and paste that, too.

-- 


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918
<lsiegel@cpeo.org>
http://www.cpeo.org

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