DSHW-2024-004876

[Date]
Eric Dodson
Westinghouse Western Zirconium
10,000 West 900 South
Ogden, UT 84404-9760RE:Drain Line Monitoring Field Activities 2023UTD092024934
Dear Mr. Dodson:
The Division of Waste Management and Radiation Control (Division) has completed its review of the Drain Line Monitoring Field Activities 2023 Report (Report), dated February 23, 2024,
summarizing the findings and corrective actionsassociated with the 2023 releases and describing the field activities associated with the drain line inspections and repairs completed
in 2023 at the Western Zirconium Facility. Western Zirconium prepared the 2023 Report to fulfill the drain line requirements detailed in the Division letter dated August 15, 2023.
The Report lists the drain lines that where accessible and inspected, the drain lines that were not accessible for inspection, and a list of proposed manhole locations to gain access
to the drain lines that were not accessible during the 2023 inspection activities. Approximately 5,400 feet of drain lines were inspected during 2023 – equaling approximately 60-75%
of the Western Zirconium facility’s linear drainpipe.
During 2024, Western Zirconium will continue construction of new drain lines for the Chlorination department. Western Zirconium will also construct access points and inspect the non-inspected
drain lines. Once all the drain lines are inspected, Western Zirconium will submit a final report that will include an inspection schedule with specific inspection frequencies based
on the age of the pipe, wastewater components, and environmental risk. The risk ratings, observations, and maintenance activities will be recorded in a Drain Asset Management Program
(DAMP) to help document and maintain the drain line system.
The Report adequately reports the status of the drain line inspection and maintenance project. Please provide a schedule for the drain line work to be conducted during 2024. Please
ensure that all spills/releases are recorded in the spills database to document locations of releases that have not been completely remediated due to access issues. This information
will be required to guide investigation and corrective actions at facility closure.
If you have any questions, please call Karen Wallner at [phone].
Sincerely,
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
DJH/KHW/[???]
c:Scott Braeden, Environmental Director, Weber County Health Department
Brian Cowen, Health Officer, Weber County Health Department
Michela Harris, Deputy Director, Weber County Health Department
Eric Dodson, Westinghouse Western Zirconium (email)[[e-mail]]