The URL can be used to link to this page

Home My WebLink AboutDSHW-2024-004872 Westinghouse Electric Company Nuclear Fuel Western Zirconium 10,000 West 900 South Ogden, Utah 84404-9760 USA February 23, 2024 Doug Hansen, Director Utah Division of Waste Management and Radiation Control 195 North 1950 West 2nd Floor P.O. Box 144880 Salt Lake City, Utah 84114-4880 Re: Drain Line Monitoring Field Activities 2023 Dear Mr. Hansen: The intent of this letter is to fulfill the requirements from the approved drain line monitoring letter dated 8/15/2023 for reporting field activities completed in 2023 at Western Zirconium. Western Zirconium will provide an inventory of the drain lines, history of the findings and corrective actions, inspection status, and inspection schedule for the field activities for 2024. During 2023 Western Zirconium contracted with Woodard & Curran to develop an inspection and repair plan for the site. Western Zirconium also partnered with Waste Recovery Systems to conduct drain inspections. Approximately 5,400 feet of drain lines were inspected during 2023 which is estimated to be approximately 60-75% of the facility’s linear drain line pipe. Western Zirconium inspected all drain lines that were able to be accessed. The inaccessible drain lines have been documented along with methods to gain access during 2024. Drain Line Inventory, Inspection Status, and Inspection Schedule 2023 Figure 1 is an updated map of the drain lines for the Western Zirconium site. The drain lines that are colored green represent drain lines that were accessible and inspected. The orange- colored lines were areas that were not accessible for inspection. Reasons for inaccessibility include sagging lines, tight pipe angles, debris and deposits, obstacles, and surcharged water levels. The dark blue lines represent drain lines that were repaired or replaced. The lighter blue lines indicate drain lines that were removed from service. The red lines represent drain lines that need repair that are out of service. Table 1 comprises the drain line inventory that was inspected during 2023. Table 1 shows the department, the pipe ID, pipe size and material, the inspected length, and the survey date. Table 2 indicates the lines that were not able to be inspected due to various obstacles. The Table 2 shows the department, the pipe ID, pipe size and material, and survey date, inspection notes, and recommendation to gain access for inspection. Findings and Corrective Actions During the 2023 field activities Western Zirconium found some compromised drain lines. The following section outline Western Zirconium findings regarding these compromised drain lines, corrective actions taken, and the status of the corrective actions for the field activities competed during 2023. All the findings were reported to the DEQ per requirements in our approved drain line approval letter. Loca�on: Pickle Facility Date no�fied: April 20, 2023 Date report submited: May 2, 2023 Finding: The release was discovered by Western Zirconium personnel during prepara�on to conduct a camera inspec�on of the underground drain line. Camera access to the underground drain line was from an in-ground sump at the billet pickle facility. When piping was removed to access the drain line, an elbow connec�ng the sump to the drain line piping was observed to have failed. At the same �me, an inspec�on of the main pickle building floor was being conducted. A small hole was observed in the floor where a water line form the Pickle Air Scrubber was located. The damaged concrete extended to the soil contact. Therefore, it is suspected that acid may have reached the soil at this loca�on. This loca�on is associated with AOC 1. Correc�ve Ac�ons: The failed drain line was found to be constructed of PVC, which does not meet the requirements of the Westinghouse piping standard. The pipe was replaced with HDPE piping that is compatible with the chemicals used in the area. Contaminated soil that could be reached was removed. The hole was filled in with concrete to restore the subfloor. The stainless-steel sump was repaired and placed back into service. In addition, the damaged concrete was repaired and placed back into service. No soil excavation was possible because it is beneath the building. Status: Complete Loca�on: Pickle Facility Date no�fied: June 13, 2023 Date report submited: June 15, 2023 Finding: During the camera inspec�on it appears to show a piece of rebar extending into the pipe at the failure point, which likely was the cause of the rupture. It’s unknown how the rebar became embedded in the pipe. A few feet away from the ruptured sec�on the camera also found a joint where two sec�ons of pipe are held together with a hugger clamp that was seperated. This is likely the loca�on of a previous repair, although Wes�nghouse does not have a record of a repair at this loca�on. Hugger clamps were used to mechanically hold two sec�ons of pipe together in repairs performed during the early years of plant opera�on. Hugger clamps tend to corrode in the soil and fail over �me, so this is a loca�on of concern and poten�al leakage. Wes�nghouse banned the use of hugger clamps on drain lines approximately 10 years ago. This loca�on is associated with AOC 1. Correc�ve Ac�ons: The loca�on of this line break cannot be easily excavated because it is under a concrete pad that provides secondary containment for the bulk acid tanks. Wes�nghouse has plugged this line and has abandoned it in place. A new line has been installed around the storage pad in an accessible loca�on and it will �e into the main drain line from the pickle area. A temporary above ground line was installed to carry spend pickle acid from Billet Pickle to the main drain line while the permanent new drain line is installed. The new drain line has been installed and is opera�onal. Access ports were installed in the new line to allow regular inspec�on and cleaning. Status: Complete Loca�on: Pickle Facility Date no�fied: June 29, 2023 Date report submited: July 7, 2023 Finding: This drain line break is in the same line that was reported on June 13th, 2023, upstream of the previously reported line break. The leak was due to a failed pipe. When the previous line break (June 13, 2023) was discovered, the line was blocked, and construc�on of this new drain line commenced. This loca�on is associated with AOC 1. Correc�ve Ac�ons: A temporary above ground line was installed to carry spend pickle acid from Billet Pickle to the main drain line while the permanent new drain line is installed. The new drain line has been installed and is opera�onal. Access ports were installed in the new line to allow regular inspec�on and cleaning. Status: Complete Loca�on: Reduc�on Department Date no�fied: August 28, 2023 Date report submited: September 7, 2023 Finding: The sec�on of drain line that was compromised runs behind (east side) of the Reduc�ons process area. Some separated joints and cracks were found during the camera inspec�on. This loca�on is associated with SWMU 37/57. Correc�ve Ac�ons: The drain line from Reduc�ons to the main line was shut down when Western Zirconium became aware of the compromised drain line. The drain line was taken out of service. A new drain line was installed in the loca�on of the compromised drain line and is now in service. Status: Complete Loca�on: Chlorina�on Department Date no�fied: September 1, 2023 Date report submited: September 13, 2023 Finding: The drain line is connected to the Chlorina�on department was found to be compromised during the camera inspec�on. This sec�on runs behind (east side) of the Chlorina�on process area. The compromised areas in the line are breaks and cracks. The Chlorina�on area is associated with SWMU 45 and AOC 5. Correc�ve Ac�ons: The drain line from the Chlorina�on department to the main line was shut down when Western Zirconium became aware of the compromised drain line. The drain line was taken out of service. A temporary line is in place to support the Chlorina�on department. The drain line is currently being replaced. Status: Currently under construc�on Loca�on: Separa�ons Department Date no�fied: September 20, 2023 Date report submited: October 3, 2023 Finding: The sec�on of the drain line that was compromised runs inside and under the Separa�ons building in area 7. The inspec�on found breaks and cracks in the drain line under the Separa�ons building. The Separa�ons area is associated with SWMU 54. Correc�ve Ac�ons: The drain line from Separa�ons to the main line was shut down when Western Zirconium became aware of the compromised drain line. The drain line was taken out of service. A temporary line is in place to support the Separa�ons department. The compromised drain line was abandoned and a new sump and drain line was installed to replace the flood drain and facilitate future inspec�ons. Status: Complete Inspection Schedule for 2024 As indicated in the findings and corrective action section construction of new drain lines for the Chlorination department are still in progress. As soon as these drain lines are completed the next step will be to construct access points around the site to access the non-inspected drain lines outlined in Table 3. Table 3 is a list of the proposed manhole locations to gain access to the areas that weren’t accessible during the 2023 field activities. Some of these manholes will be cast in place during normal operations others will be precast manholes that will be installed during planned maintenance shutdowns. Once the manholes and access points are installed Waste Recovery Systems will be brought back onsite to inspect the remaining non-inspected drain lines. All the findings were reported to the DEQ per requirements in our approved drain line approval letter. A final report will be submitted once all the drain lines are inspected, and all repairs and replacements have been completed. This report will also include the required inspection schedule and its frequency. Should you have any questions, please feel free to contact me at (801) 247-0239. Thank You, Eric Dodson, PE Principal Environmental Engineer Westinghouse, Western Zirconium eric.dodson@westinghouse.com Table 1 Department Pipe ID Size/Material Segment Length Inspected (ft) Survey Date Flat Product 84 Truck 4” / HDPE 27 4/20/2023 Flat Product F27C-BE-N 6” / HDPE 84 4/20/2023 Flat Product F27-BE-S 6” / HDPE 73 4/20/2023 Flat Product F27C-CE-E 6” / HDPE 55 4/20/2023 Flat Product F27C-DS-S 6” / HDPE 154 4/20/2023 Flat Product F27C-EE-E 6” / HDPE 162 4/20/2023 Flat Product F27C-P-W 6” / HDPE 14 4/21/2023 Flat Product F31C-A-E 4” / HDPE 60 4/20/2023 Flat Product F31C-A-W 4” / HDPE 78 4/20/2023 Flat Product F69-ZE-E 6” / HDPE 85 9/25/2023 Flat Product F69C-FB-E 4” / PVC 31 9/25/2023 Flat Product F75-AW-E 6” / HDPE 9 4/21/2023 Flat Product F75C-P-N 6” / HDPE 175 9/1/2023 Flat Product F75C-P-S 6” / HDPE 2 4/21/2023 Flat Product F76C-AW-W 6” / HDPE 175 4/21/2023 Flat Product F8C-A-S 4” / HDPE 44 4/20/2023 Round Product F50C-E-E 3” / Cast 71 9/22/2023 Round Product F59-FW-W 3” / HDPE 17 9/22/2023 Round Product F60FN-N 3” / PVC 39 9/22/2023 Round Product F62-CO-N 3” / HDPE / PVC 41 9/22/2023 Round Product F75C-B-S 6” / HDPE 6 4/21/2023 Round Product F78C-P-N 3” / HDPE 24 9/22/2023 Melting F47C-N 6” / HDPE 36 4/21/2023 Melting F47C-S 6” / HDPE 44 4/21/2023 Melting F45C-P-S 4” / HDPE 146 9/22/2023 Melting F48C-S 4” / HDPE 130 9/21/2023 Reduction R12C-C 6” / PVC 107 8/24/2023 Reduction R12C-V-W 5” 40 8/25/2023 Reduction R12C-V-W2 5” / PVC 135 8/25/2023 Reduction R13P-N 3” / PVC 25 8/21/2023 Reduction R14P-W 3” / PVC 84 8/21/2023 Reduction R15C-P-W 5” / PVC 42 8/22/2023 Reduction R16 4” 0 8/23/2023 Reduction R16-FAW-W 4” / PVC 45 8/23/2023 Reduction R16-FBW-W 4” / PVC 10 8/23/2023 Reduction R17-P-E 6” / HDPE 8 8/23/2023 Reduction R19-FA-S 6” / HDPE 39 8/23/2023 Reduction R19-FA-W 6” / HDPE 34 8/23/2023 Reduction R22-P-N 3” / PVC 1 8/23/2023 Reduction R22-P-W 3” / PVC 5 8/23/2023 Table 1 continued Department Pipe ID Size/Material Segment Length Inspected (ft) Survey Date Reduction R25C-V-SW1 6” / HDPE 110 8/23/2023 Reduction R26C-VC-W 5” / HDPE 100 8/28/2023 Reduction R26C-VE-S 5” / HDPE 209 8/28/2023 Reduction R26C-VE-W 5” / HDPE 172 8/28/2023 Reduction R26-VG-E 5” / HDPE 92 8/28/2023 Reduction R26C-VG-N 5” / HDPE 124 8/28/2023 Reduction R28-VB-E 5” / HDPE 18 8/28/2023 Reduction R3-AF-N 4” / PVC 23 8/22/2023 Reduction R3-FBN-N 4” / PVC 5 9/26/2023 Reduction R3-FC-W 4” / PVC 76 9/26/2023 Reduction R3-R-N 5” / HDPE 145 8/22/2023 Reduction R6-CAR-W 5” / HDPE 85 8/22/2023 Reduction R6C-V-N 5” / HDPE 160 8/22/2023 Reduction R6C-V-S 3” / HDPE 22 8/22/2023 Reduction R8-P-S 4” / PVC 52 8/24/2023 Reduction R9-FC-N 4” / PVC 42 8/24/2023 Reduction R98-FA-N 4” / PVC 14 8/24/2023 Reduction R98-FB-S 4” / PVC 12 8/24/2023 Reduction R98-FC-N 4” / PVC 10 8/24/2023 Chlorination C1-PA-E 3” / HDPE 23 8/29/2023 Chlorination C1-PB-N 3” / HDPE 14 8/29/2023 Chlorination C11-FAW-W 4” / PVC 25 8/29/2023 Chlorination C13-AF-S 4” / PVC 20 8/29/2023 Chlorination C13-BF-N 4” / PVC 20 8/29/2023 Chlorination C14-P 4” 10 8/29/2023 Chlorination C9C-P-S 6” / PVC 70 8/31/2023 Separations S03 5” / HDPE 123 9/19/2023 Separations S06-BLT-W 2” / HDPE 141 9/20/2023 Separations S06-P-S 2” / Kynar 212 9/19/2023 Separations S08-CO-S 6” / HDPE 142 9/20/2023 Separations S14C-FAE 4” / PVC 57 9/18/2023 Separations S14C-FCS 4” / PVC 5 9/18/2023 Separations S30C-P-E 3” / HDPE 156 9/2/2023 Separations S33-P-S 2” / HDPE 193.6 9/20/2023 Separations S36C-BLT-W 2” / HDPE 40 9/20/2023 Separations S43C-RSW-W 3” / HDPE 195 9/20/2023 Separations D96-PA-S 3” / PVC 105 8/30/2023 Department Pipe ID Size/Material Survey Date Inspection Notes Recommendation Flat Product F91 9/25/2023 Abandoned Survey - Inaccessible @ 0' Install infrastructure improvements to allow access RoundProduct F57C-C 9/22/2023 Obstacle Construction Debris @ 0’Heavy Clean / Camera Inspection RoundProduct F74C-C 9/25/2023 Abandoned Survey - no indentified access Ground Penetrating Radar Survey to identify access RoundProduct F78C 9/22/2023 Deposits Settled Other (DSZ) >30% @ 0’Install infrastructure improvements to allow for cleaning and scoping RoundProduct F8C-P 4” / HDPE 4/21/2023 Misc. Water Level (MWL) 10% @ 0’Monitor Reduction R10-F-W 8/24/2023 Deposits Settled Other (DSZ) >30% @ 0’Heavy Clean / Camera Inspection Reduction R21-P 4” 8/23/2023 Obstacle Other >30% @ 0’Heavy Clean / Camera Inspection Reduction R7-FA-S 8/24/2023 Deposits Settled Compacted >30% @ 0’Heavy Clean / Camera Inspection Chlorination C1 8/29/2023 Misc. Water Level (MWL) 10% @ 0’Monitor / Jetting Operation and Maintenance Chlorination C11 8/29/2023 Misc. Water Level (MWL) 10% @ 0’Monitor / Jetting Operation and Maintenance Chlorination C12C 8/30/2023 Abandoned Survey -Surcharged @ 0’ Install infrastructure improvements to allow for isolation and dewatering Chlorination C13 8/29/2023 Misc. Water Level (MWL) 10% @ 0’Monitor / Jetting Operation and Maintenance Chlorination C15-P 8/29/2023 Abandoned Survey – Inaccessible @ 0’ Install infrastructure improvements to allow access Chlorination C24 8/29/2023 Abandoned Survey – No identified access Ground Penetrating Radar Survey to identify access Chlorination C26-E 8/29/2023 Abandoned Survey – No identified access Ground Penetrating Radar Survey to identify access Chlorination C30-E 8/29/2023 Abandoned Survey – No identified access Ground Penetrating Radar Survey to identify access PCD Main F76C-AE HDPE 9/26/2023 Abandoned Survey -Surcharged @ 0’ Install infrastructure improvements to allow for isolation and dewatering PCD Main M1-AS 9/26/2023 Abandoned Survey – unobservable @ 0’ Boiler Shut down and line cooling to eliminate steam PCD Main M4-E 9/26/2023 Abandoned Survey -Surcharged @ 0’ Install infrastructure improvements to allow for isolation and dewatering PCD Main M5-E 9/26/2023 Abandoned Survey -Surcharged @ 0’Install infrastructure improvements to allow for isolation and dewatering PCD Main M7 9/26/2023 Abandoned Survey -Surcharged @ 0’ Install infrastructure improvements to allow for isolation and dewatering PCD Main PCD-AW_EQT HDPE 9/26/2023 Abandoned Survey -Surcharged @ 0’ Install infrastructure improvements to allow for isolation and dewatering Separations S01 9/20/2023 Abandoned Survey -Surcharged @ 0’ Install infrastructure improvements to allow for isolation and dewatering Separations S02 HDPE 9/20/2023 Abandoned Survey -Surcharged @ 0’ Install infrastructure improvements to allow for isolation and dewatering Separations S03CA-CSW_BLT 5” / HDPE 9/18/2023 Abandoned Survey -Surcharged @ 0’ Install infrastructure improvements to allow for isolation and dewatering Separations S14C-FD-E 4” / PVC 9/18/2023 Deposits Settled Other >30% @ 0’Heavy Clean / Camera Inspection Separations S43C_Pond 9/20/2023 Abandoned Survey -Surcharged @ 0’ Install infrastructure improvements to allow for isolation and dewatering Table 2 Table 3 Department Pipe ID 2024 Construction Projects for Inspection Access Separations S43C / Manhole to access, clean, and meter line from the BLTs and investigate continued line to west. Separations S43C / Manholes every 300-400' east to pond continue east to pond Separations S43C / Manholes every 300-400' east to pond continue east to pond Chlorination C12C / F77C Manhole to isolate chlorination from jacuzzi, access, and clean all lines Chlorination C12C Manhole to access and clean all lines northwest of Bldg. #35 Chlorination C12 / C15 / C13 Manhole to access and clean all lines combine C15 with C13 and C12 -Abandon C43 Chlorination C12 / C9C Manhole to access and clean all lines from pad 45 Chlorination C9C Line repair from Pad 45 Chlorination C12 / C1 Manhole to access and clean all lines - Rehab C12C-CAS to manhole Chlorination C14 Sump to replace broken structure and inlet to allow access Chlorination Jacuzzi Single manhole at junction of all lines for isolation of department flows Reductions R12 / R9 / R7 Sump to replace clean out for access and clean lines Bldg. #19 Flat Product F91 Replace trap for access to mop sink drain out of F76 Flat Product F78C Additional cleanout sump on E/W line inside Bldg. #107 Flat Product F31C Sump to clean and access lines in Bldg. #94 Flat Product F75C / F78C Manhole to access and clean both lines outside of Bldg. #107 Round / Melting F75F / F48 / F45C Manhole to access and clean all lines Maintenance M4/ S96 Manhole to isolate, access, and clean all lines