For more than 35 years, SN3 has provided radioactive and hazardous waste management services to DOE and private sector clients. Our experience in waste management encompasses hazardous wastes, solid wastes, and radioactive wastes [including transuranic (TRU), low-level, and mixed waste].
Our waste management experience extends from characterization, treatment, and tracking through storage, transportation, and disposal. We have prepared Part B permit applications for storage, treatment, and disposal units; conducted compliance audits of facilities; and assisted clients in the packaging, transportation, and disposal of a variety of radioactive and hazardous wastes. We support waste management programs at DOE nuclear facilities by developing and maintaining waste management procedures, providing guidance and technical support during waste generation, characterization, packaging, labeling, storage, treatment, and disposal. We manage all waste in accordance with applicable federal and state regulations and DOE Orders prior to its ultimate treatment, storage, and/or disposal. Since 2006, SN3 has managed and operated the DOE’s largest CERCLA and Hazardous Waste Landfill, the Environmental Restoration Disposal Facility (ERDF), at Hanford.
Our approach to waste management during environmental restoration activities consists of two primary elements:
- Develop and implement a compliant waste minimization and source reduction plan so we generate less waste initially.
- Develop and implement a comprehensive waste management plan to assure compliance, yet allow waste management flexibility so we can reduce the cost of waste management and disposal.
Our waste management/minimization plan applies pollution prevention opportunity assessments and return-on-investment evaluations to routinely identify opportunities to reduce waste. Applied together, these two assessment processes evaluate both technical and financial approaches to waste management and minimization. As part of our approach, we also evaluate and assess alternative methods of remediation and new remedial technologies that generate little or no waste. Our experience includes identifying options for treating, reducing, and compliantly disposing of a variety of waste and mixed waste streams, both on-site and off-site.
Landfill Design, Construction, Operation and Maintenance
SN3 has more than 21 years of experience in disposal cell and landfill design, construction, operations, and management. This includes 33 landfills under the DOE Legacy Management contract, management of two CERCLA radioactive waste landfills for DOE; landfill construction and disposal cell design; landfill closure, including engineered design covers and capping; and stewardship for landfills or disposal cells that require constant monitoring, maintenance, and regulatory reporting.
Our waste management experience encompasses hazardous waste, solid waste, mixed and radioactive wastes and extends from characterization, treatment, and tracking through storage, transportation, and disposal. We have prepared Part B permit applications for storage, treatment, and disposal units; conducted compliance audits of facilities; and assisted clients in the packaging, transportation, and disposal of a variety of radioactive and hazardous wastes.
Our technical experts are familiar with many environmental regulations and regulatory agencies and have successful identified where they overlap and conflict, thereby helping our clients avoid regulatory violations and maintain compliant operations. Our expertise extends to the following:
- Clean Air Act
- Clean Water Act
- Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
- Endangered Species Act
- National Environmental Policy Act (NEPA)
- Occupational Safety and Health Administration (OSHA)
- Resource Conservation and Recovery Act (RCRA)
- Toxic Substances Control Act (TSCA)
- Department of Energy (DOE) orders
- Environmental Protection Agency standards
- U.S. Nuclear Regulatory Commission (NRC) regulations
SN3 understands that work performed for our customers must comply with a myriad of statutes, regulations, standards, and orders. Work must also comply with the Endangered Species Act, requirements of the U.S. Fish and Wildlife Service, and a host of state and municipal standards. Knowledge of applicable laws, regulations, and agreements, the basis for their development, and the method and extent to which they are implemented is essential to understanding program needs. Not only do our technical experts understand the laws and regulations, but also the reasons behind those laws and regulations, the many ways they have been interpreted, and the personalities involved in interpreting them. We understand that regulatory and policy needs are based on legal drivers. We also understand that regulatory compliance is often stakeholder-driven. Consequently, one of the keys to project success, in our estimation, is the ability to work with and satisfy federal agencies and states, while at the same time successfully addressing the concerns of landowners, Native American Tribes, environmental groups, and the public.
Strong relationships with local, state, and federal agencies can greatly accelerate work progress in environmental programs. We have found that honest interaction with regulators, no matter how uncomfortable, ultimately leads to a greater number of successful remediations and closures.
We also seek ways to reduce the regulatory burden for each task. We have significantly streamlined the cleanup process at several CERCLA sites. For example, at the Rocky Flats Site, we determined that under CERCLA, a D&D facility is not subject to RCRA permits for treatment of hazardous waste or migratory bird nest removal permits prior to demolition of structures. Although the substantive requirements still applied, waiving the permit requirements resulted in significant cost and schedule savings for our customer.