Environment, Safety and Health
Xron Associates, Inc. provides technical, regulatory and project management services in environmental projects under federal and state environmental laws and regulations and NRC regulations. Services include commercial and government environmental compliance, regulatory analysis, and permitting activities; requirements management; remedial investigation design, implementation, and reporting; and remedial action design and implementation at RCRA, CERCLA and industrial sites. Department of Energy (DOE) services also include mixed and radioactive waste management expertise, Operational Readiness Reviews (ORR) and startup assessments and NRC Spent Nuclear Fuel storage facility licensing tasks.
Xron services include development of environmental regulatory management processes, and development and deployment of software tools to assist managers and operations personnel manage compliance requirements and implementing processes, non-compliance issues, and corrective action processes. Xron develops and supports developments of ISO 14001 Environmental Management System (EMS), such as the EMS certified at the Idaho National Engineering and Environmental Laboratory (INEEL).
- Expert knowledge of environmental compliance requirements such as: Clean Air Act, Clean Water Act, Comprehensive Environmental Response Compensation and Liability Act, Resource Conservation and Recovery Act, Toxic Substances Control Act.
- Regulatory agency and stakeholder interface.
- Radioactive waste management requirements.
- Environmental Management System development and implementation to meet the ISO 14001 standards.
- Expert knowledge of regulatory permitting processes, modifications, and closures.
- Environmental assessment, operational readiness assessment, and compliance audit performance and response reporting.
- Data Quality Objective and Sampling and Analysis Plan preparation and implementation.
- Closure Plan and Remedial Design Report and Remedial Investigation Work Plan preparation and implementation.
- Evaluation and designation of wastes.
Qualifications and Experience
- Developed Remedial Design Report and Remedial Action Work Plan supplement for the K Basins Discharge Chute Grouting
- Provide environmental suppport to the Closure of the 105 K Basins.
- Developed “Activity-Based” environmental compliance procedures in 2002 and 2003. Provided extensive regulatory analysis of environmental requirements, identified applicable environmental requirements and established them in an activity-based requirements process. Developed training on the activity-based system.
- Led the groundwater and vadose zone efforts.
- Performed post tank incident recovery operations consulting at the Plutonium Finishing Plant to evaluate and describe potential compliance scenarios of the subject tank.
- Performed extensive materials and compliance evaluations of tanks at the Plutonium Finishing Plant to identify tanks potentially subject to State of Washington equivalent RCRA regulations.
Idaho National Engineering and Environmental Laboratory
- Developed the ISO 14001 Registered Environmental Management System (EMS) over a 3-year period. Performed initial gap analyses between company processes and procedures and the ISO 14001 standard, made recommendations and developed actions to address gaps, and implemented numerous actions to successfully gain ISO 14001 registration. Represented the company during the initial ISO 14001 registration audit in June of 2002 and 2003 re-registration audits.
- Developed “Activity-Based” environmental compliance procedures 1999-2000. Provided extensive regulatory analysis of environmental requirements, identified applicable environmental requirements and established them in an activity-based requirements process. Responsible for the current maintenance of the requirements documents and implementing procedures.
- Led the 1998 Inactive Facilities and Central Facilities Environmental Compliance Assessment.
- Developed implementing procedures and training materials for Waste Management processes.
- Developed the RCRA Part B Permit Application for the Idaho Nuclear Technology and Engineering Center Liquid Waste Management Facilities.
- Performed Facility Assessment of the Process Equipment Waste Evaporator, Liquid Effluent Treatment and Disposal Facility and The High Level Liquid Waste Evaporator to determine if the facilities could be Part B permitted.
- Developed a RCRA Operating Record Requirements Management System format for TSDs and made recommendations for implementation. Populated a model version of the Operating Record Matrix for the Radioactive Waste Management complex RCRA Permit.
Waste Isolation Pilot Plant
- Developed the Waste Characterization Requirements Management System and database in 2000 and 2001. Identified requirements from seven key WIPP waste management documents including the RCRA Permit, Safety Analysis Report (SAR). TRUPACT II SAR, and Compliance Certification under 40 CFR 191. Provided services in 2002 to update the system.
- Performed environmental compliance operational readiness assessments during the 1996 and 1997 per-operational readiness review.
- Evaluated operational readiness assessment information regarding compliance with the RCRA permit application, providing extensive procedural changes to facilitate RCRA permit implementation.
- Developed the RCRA compliance matrix and permit compliance database and configuration management process modeled after the nuclear unreviewed safety question process.
- Evaluated operational readiness assessment information regarding compliance with the Biannual Environmental Compliance Report (BECR). This report summarizes all Federal and State requirements as well as specific environmental permits other than those associated with RCRA permit. Provided extensive procedural changes to facilitate compliance with BECR requirements.
- Developed environmental incident reporting procedure that integrated Federal State of New Mexico, and local immediate and follow-on reporting requirements.
- Developed a Spill Prevention, Countermeasures and Control Plan (40 CFR 112), tailored to requirements.
- Provided extensive analysis of the NPDES Storm Water System permit compliance.
Industrial Safety and Health
Waste Isolation Pilot Plant
- Developed automated Job Hazard Analysis and Safe-Work Management software that aids worker hazard recognition while simultaneously decreasing the cost of work package preparation.
- Evaluated key aspects of the safety program in preparation for the operational readiness review (29 CFR 1910, 29 CFR 1926, and 30 CFR 57).
- Re-drafted the Safety Manual (29 CFR 1910, 29 CFR 1926, and 30 CFR 57).
- Developed fire brigade approach.
- Developed the approach for implementation of 29 CFR 120 (p) and (q).