B
CEASE FIRE! Campaign Technology Criteria
- Overall protection of human health and the environment:1
- Treatment method is fully protective of human and ecological health and prevents toxic emissions.
- Treatment method offers maximum protection to workers.
- Treatment method is sensitive to the elevated levels of pollution that already exist in the area (such as current [nitrogen oxides], and ground-level ozone levels).
- Treatment method does not cause or contribute to soil, air, or water pollution.
- Any residue from treatment is fully and accurately characterized and safely disposed of.
- Treatment method offers maximum safety controls to prevent any and all releases.
- Treatment method prevents the potential for catastrophic release.
- Treatment method has aggressive process safety management protocols.
- Treatment method is fully protective of human health and the environment even when full characterization of wastes is not possible.
- Treatment method is fully protective of marine and aquatic receptors and ecosystems, including fisheries.
- Monitorability:
- Treatment method can be monitored effectively, both at the site and in the surrounding community, and tested to assure protective levels of contamination before any possible release (sometimes referred to as hold, test, and release).
- All effluents from the treatment system should be monitorable, including solids, gases, and liquids.
- Long-term effectiveness and permanence:
- Treatment method is a complete solution, minimizing the need for additional treatment, long-term storage or disposal in the future.
- Treatment method does not require long-term maintenance, storage and monitoring and effectively eliminates any long-term liability to this or future generations.
- Treatment method allows the property to be returned to unrestricted and productive use.
- Treatment method is superior when fiscal considerations are fully inclusive of ecological, environmental, health, remedial, investigative, site closure, residual contamination burden, and other life-cycle costs.
- Reduction of toxicity, mobility, or volume through treatment:
- Treatment method/remedy does not create a more toxic byproduct (such as dioxins and products of incomplete combustion) that does not already have an authorized treatment plan.
- Treatment method is effective at safely treating dunnage, packaging, and other related materials that require treatment or specialized disposal.
- Treatment method will safely and effectively treat degradation products, impurities, cross-contaminants, and other inadvertent byproducts and constituents, including depleted uranium.
- Short-term effectiveness:
- Treatment method can be implemented safely and quickly to replace the use of open burning/open detonation.
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1 Source: https://cswab.org/wp-content/uploads/2017/03/Cease-FireCampaign-Alternative-Technology-Criteria-FINAL.pdf.
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Implementability:
- Treatment method is legal.
- Treatment method can be implemented within the federal and state environmental standards, regulations, and advisories.
- State/territorial acceptance:
- Treatment method is supported by state or U.S. territorial government and environmental regulators.
- Community acceptance:
- Treatment method is supported by local community leaders.
- Treatment method is supported by the affected community.
- Treatment method safety controls are supported by local first responders.
- Treatment method health and safety precautions are supported by onsite workers.
- Environmental justice:
- Treatment method is supported by tribes and indigenous peoples who are both directly and indirectly impacted.
- Treatment method reflects and honors the cultural values of tribes and indigenous peoples who are both directly and indirectly impacted.
- Treatment method is not opposed by tribal government.
- Treatment method is not opposed by tribal elders.
- Treatment method offers maximum protection when evaluated in terms of indirect exposures. Examples include, but are not limited to, consumption of fish and wild game, and consumption and use of medicinal plants.
- Treatment method will achieve short-term and long-term compliance with tribal environmental regulations, standards, and health advisory levels.
- Treatment method offers maximum protection when evaluated in terms of disproportionate impact to disadvantaged, vulnerable, or susceptible populations.
- Treatment method offers maximum protection when evaluated in terms of cumulative, additive, and synergistic direct and indirect risks to residents, workers, onsite personnel, and others.
- Treatment method achieves compliance with Health Advisory Levels (or equivalent) when enforceable environmental standards are unavailable—for example, as with emerging contaminants.
- Treatment method does not put other global communities at risk.
- Treatment method will incentivize and encourage the development of advanced alternative technologies.
- Transparency:
- The treatment method does not utilize “resource recovery,” “energy generation” or other incidental outcomes to avoid regulation under [the Resource Conservation and Recovery Act] and other applicable laws and regulations.
- The treatment method does not encourage rolling (successive) short-term emergency permits.
- All monitoring data is immediately published in an accessible format to assure that community members, workers, and soldiers are informed and empowered in the decision-making process.
- Details of how the technology and its pollution abatement systems work are fully disclosed to assure that community members, workers, onsite personnel, and soldiers are informed and empowered in the decision-making process.