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HomeMy WebLinkAboutDSHW-2024-005563AZCOM March 27, 2024 Mr. Doug Hansen, Director Utah Department of Environmental Quality AECOM 756 E. Winchester Street Suite400 Salt Lake City, UT 84107 www .aecom.com Division of Waste Management and Radiation Control 195 North 1950 West P.O. Box 144880 Salt Lake City, UT 84116 801 904 4000 tel 801 904 4100 fax Subject: Westinghouse Electric Company, Western Zirconium Plant, 2023 Site Management Plan Inspection and Compliance Letter Report Dear Mr. Hansen: Enclosed please find one PDF copy of the 2023 Site Management Plan Inspection and Compliance Letter Report for the Westinghouse Electric Company, Western Zirconium Plant Facility. Please feel free to contact me at your convenience if you have any questions on this matter. Best Regards, H. Lawrence Cannon, P.G. Project Manager CC: Eric Dodson, Western Zirconium Plant A:COM March 27, 2024 Eric Dodson Westinghouse Electric Company LLC 10000 West 900 South Ogden Utah 84404-9760 AECOM 756 E Winchester Street Suite 400 Salt Lake City, Utah 84107 aecom.com RE: 2023 Site Management Plan Inspection and Compliance Letter Report Dear Mr. Dodson: 801.904.4000 Tel AECOM is pleased to submit this letter report on behalf of Western Zirconium (WZ) to document the results of the 2023 Site Management Plan (SMP) inspection at the WZ facility. The inspection was conducted by Wil Pineda and Lawrence Cannon of AECOM on October 12, 2023, escorted by Eric Dodson of WZ. The inspection was completed in accordance with the requirements of the approved SMP dated April 2022 (Westinghouse, 2022a). Subject Solid Waste Management Units (SWMUs) and Areas of Concern (AOCs) are depicted on Figure 1 and Figure 2. Field inspection forms are provided as Attachment 1 and a photograph log is provided as Attachment 2 (Note, the photo locations and direction taken is depicted in the Figures). The purpose of the SMP is to provide a management protocol for the Subject Areas requiring site management. The SMP outlines controls, corrective measures, and long-term monitoring needed to protect human health and the environment. Section 3 of the SMP summarizes site management activities that are required to ensure that risks from residual chemical constituents remaining in soil, sediment, surface water, and groundwater are mitigated or adequately managed for protection of human health and the environment. The specific site management requirements are summarized in Table 2 of the SMP for each Subject Area. A SMP Compliance Report is required to be submitted to the Director of the Utah Department of Environmental Quality (UDEQ), the Division of Water Quality (UDWQ), and the Division of Waste Management and Radiation Control (UDWMRC) annually to document the results of site inspections and compliance with SMP requirements. Institutional, Administrative, and Engineering Controls required by the SMP are discussed in the following sections. Land Use Restrictions The facility is fenced and is in an area zoned for industrial use. As such, the current zoning precludes development for residential land use. Additional land use restrictions have been imposed to prevent residential development (including childcare facilities and early education schools) and ensure that the WZ facility is used solely for commercial and industrial purposes in the future. Similarly, no edible crops shall be grown on the property without the approval of UDEQ. Land use restrictions are included in the Environmental Covenant. A:COM No change in land use was observed during the 2023 inspection. There are no recommendations based on the 2023 SMP inspection. Groundwater and Surface Water Monitoring Groundwater under the WZ facility and within the shallow unconfined aquifer shall not be used for potable, culinary, domestic, process, irrigation, or any other purposes. Groundwater use restrictions for the area are included in the Environmental Covenant. Groundwater and surface water monitoring and reporting have been initiated at the facility and shall continue to be conducted in accordance with the most recent Ongoing Monitoring Plans (OMPs), such as the 2018 Evaporation Pond Area Ongoing Monitoring Plan and the 2022 Plant Area Ongoing Monitoring Plan (Westinghouse, 2022b ). Groundwater and surface water monitoring and reporting are conducted as required by the respective plans and a review was not included in the SMP inspection. There are no recommendations based on the 2023 SMP inspection. Administrative Controls Construction worker hazard notification and construction worker compliance with OSHA 29 CFR 1910.120 are required for construction workers involved in excavation within the areas listed in the SMP. Also, disposal of extracted groundwater and excavated soil must be managed in accordance with the SMP. Administrative Controls are managed by the facility as part of routine operations and a review was not included in the annual inspection. There are no recommendations based on the 2023 SMP inspection. Signage Signage is required at SWMUs and AOCs as listed in the SMP to warn against trespassing, to reduce the occurrence of trespassing, and to advise workers of potential risks. Signs shall be posted in areas where trespassers have entered the property in the past or are likely to enter the property in the future, and around areas where current workers are more likely to enter. Signage was inspected on October 12, 2022, at all SWMUs and AOCs as listed in Table 2 of the SMP (Westinghouse, 2022a). Results of the inspection indicate that signage was acceptable at all locations except for the Mud Flats, which did not have apparent signage. It was noted that due to the close proximity of some SWMU/ AOC boundaries, some signs can mark the east side of one SWMU and west side of another SWMU, i.e. AOC 13 and AOC 15. This was determined to be acceptable for notification of site risks. It was also noted that some signs have different messaging such as: "Controlled Access Area", "Authorized Access Only", or "No Trespassing." Recommendations based on the 2023 SMP inspection are as follows. • Evaluate signage requirements for the Mud Flats area. • Monitor existing signage and make repairs as necessary. 2 A:COM Fencing Fencing is required around the evaporation ponds (SWMUs 3 through 8, SWMUs 34 through 36, and AOC 13) to prevent trespasser and wildlife access to the Pond Area. Fencing around the property perimeter in the Mud Flats area is not required as part of this SMP. Fencing was inspected on October 12, 2023, around the evaporation ponds. All fencing was found to be in good condition. There are no recommendations based on the 2023 SMP inspection. Pavement Cover Pavement cover is required at SWMUs 27, 38, 45, 49, 50, and 52 as part of the soil containment requirements. Pavement condition was inspected on October 12, 2023. All pavement was found to be in place and in acceptable condition with the exception of SWMU 27 which is unpaved. Recommendations based on the 2023 SMP inspection are as follows. • Evaluate the soil containment requirements for SWMU 27. Wildlife Deterrence and Prevention of Habitat Deterrence is required to prevent the ingestion of evaporation pond water by wildlife or the development of habitat for ecological receptors around the ponds or other SWMUS as outlined in the SMP. Fencing around the evaporation ponds will prevent entry of large wildlife by foot into the ponds. Prevention of the formation of any attractive habitat around the ponds is required to deter the gathering of wildlife around the ponds. The areas requiring wildlife deterrence and prevention of habitat are listed in the SMP. A shorebird study was completed for SWMU 44. The final bird deterrent corrective measures for SWMU 44 have been implemented based on the results of the shorebird study. Wildlife Deterrence and Prevention of Habitat was evaluated on October 12, 2023, around the evaporation ponds and at those locations listed in the SMP. WZ has begun an onsite vegetation mitigation program, starting in October 2023; however, effects of the mitigation were not observable at the time of inspection. Moderate vegetation was observed within the fenced area for the evaporation ponds (SWMUs 3, 4, 5, 6, 7, 8, 34, 35, 35A, and 36) and stormwater pond (SWMU 44), which appears to be minimally acceptable for prevention of habitat. The deterrence measures have been completed for SWMU 44, but vegetation was observed to be growing around the perimeter. Soil within SWMU 10 had been graded and was free of vegetation, and only minor vegetation was observed in SWMU 20. Heavy vegetation was observed in SWMUs 18, 26, 27, AOC 13, and AOC 15. Recommendations based on the 2023 SMP inspection are as follows. • Heavy vegetation within SWMUs 18, 26, 27, AOC 13, and AOC 15 needs to be mowed or sprayed. • Vegetation near the evaporation ponds needs to be monitored and potentially mowed or sprayed. • Vegetation at SWMU 44 needs to be monitored and potentially mowed or sprayed. • SWMU 18 should be re-graded to prevent standing water and vegetation growth. • Monitor the progress of the vegetation mitigation program. 3 AS'COM Soil Sampling Soil sampling is required for the Mud Flats area to monitor natural attenuation of contaminants in soil. Monitored natural attenuation soil sampling is required at the Mud Flats Area on a semi-annual basis for the next three years (Woodard and Curran, 2023). Recommendations based on the 2023 SMP inspection are as follows. • Soil sampling at the Mud Flats was conducted in 2023. Results were reported separately and are not discussed further herein. Disposal of Excavated Soil Soils excavated from selected SWMUs or AOCs listed in Table 2 and Table 3 of the SMP must be properly managed to ensure that they are not deposited at any off-site location or used for any industrial or residential purposes. Therefore, all excavated material from these locations that is not replaced back into the original excavation shall be characterized and disposed of at an appropriately licensed treatment, storage, and disposal facility, or tested to show that other handling of the excavated material is appropriate . Disposal activities conducted under the SMP are as follows. • Soil excavated from various drain line repair projects in 2023 were characterized and properly disposed of at an appropriate licensed disposal facility offsite. Conclusions and Recommendations As noted in the SMP, the property owner shall remedy any items that are found to be out of compliance with the requirements of this SMP within 60 days of detection and/or in accordance with guidance from UDWMRC. For convenience, recommendations have been listed as bullets in the text above. If you have any comments or questions, please reach out to me to discuss. Sincerely, AECOM Lawrence Cannon, PG Project Manager Wil Pineda, PE Professional Engineer Attachments 4 A:COM Attachment 1-Site Inspection Forms Attachment 2 -2023 Photograph Log, 2022 Photograph Log Figures Figure 1 -SMP Inspections Figure 2 -SMP Inspections References Westinghouse. 2022a. Western Zirconium Site Management Plan. April 2022. Westinghouse. 2022b. Plant Area Monitoring Plan. June 2022. Woodard and Curran. 2023. Monitored Natural Attenuation Confirmation Soil Sample Results Technical Memorandum 5 SWMU62 SWMU 22 P.€1 AOC7 I Rl!J0 ----- i I, I ~ I Property Boundary ---✓ ' SWMU1~ jswMu3 1 SWMU7 l swMu4 1 9 26 27 I 35 36 A:COM Attachment 1 Site Inspection Forms A:-coM WZ SMP Inspection ~ 2,023 Dale: /0/Lz, ... / 'Z,,.. IProiecl Name: '-'~ St--P :X:...c,-.-....L-'o ...... Prolect No: AECOM Staff Oneite: W:\ "f.-",A. ... Le."-lr,,_,, r ,u-,."""" Tlme Onalte: "'7;Jo Other Personnel Onalte: er:c_ l>o~c> .... t,Yr. Tlme Olfafte: 11! 00 Signaae and Fencina in Acceptable Condition SWMU 2/21/48 Signage:J( Yes o No Notes: SWMU3 Signage: f!5' Yes □ No Fencing: .e(' Yes o No Notes: SWMU4 Slgnage: (<("Yes □ No Fencing:£ Yes □ No Notes: SWMU5 Signage: .("Yes □ No Fencinq: £Yes □ No Notes: < SWMU6 Signage: gt Yes □ No Fencing: i;;l"Yes □ No Notes: SWMU7 Signage: /l!' Yes □ No Fencing: .21' Yes □ No Notes: '-SWMU8 Si1maqe: rfYes □ No Fencing: rif'Yes □ No N otes: SWMU 10 Signage:,.i!l"Yes □ No Notes: SWMU20 Signage,x Yes □ No Notes: SWMU26 Signage:.✓Yes □ No Notes: c~,... I,,,_ l ..,I c .... ,....,, z..,-, c_ --., Al,re. SWMU 27 Signage~Yes □ No Notes: Nos',.~ .. ~ ,e. .. ~.i ~ ,,l, Signage:..d'"Yes □ No Fencing:£Yes □ No -SWMU34 Notes: SWMU35 Signage:..d" Yes □ No Fencing:,e(Yes o No Notes: SWMU35A Signage: Jlf'Yes □ No Fencing: Jlf"Yes o No Notes: SWMU36 Signage: ~es □ No Fencing: D-"'( es □ No Notes: SWMU 38 Signage:J<(Yes o No y ·, Notes: SWMU44 Signage:..2!"Yes o No Notes: f\Jo +r-e~1>L<11,A ,l~M ~-1, Signage:.B'Yes o No Notes: r -\,_,_) t'L,,J ~./"I,.., ... o ...... li. , SWMU45 Signage::;if'Yes □ No -J SWMU49 Notes: SWMU50 Signage:~es □ No Notes: SWMU52 Signage: ~es o No Notes: k, SWMU59 Signage: o/Yes □ No Notes: SWMU60 Signage: ·d' Yes □ No Notes: SWMU62 Signage: ~Yes □ No Notes: AOC1 3 Signage:':..d' Yes □ No Notes: AOC14 Signage:~es □ No Notes: AOC15 Signaqe: 2f"Yes o No Notes: Pond Area GW Signage: i!f"'Yes o No FencinQ:~Yes □ No Notes: Mud Flats Signage: □ YesvNo Notes: Pavement Cover i n Acceptable Condition SWMU 27 Cover: o Yes~ No Notes: Ur.n,o•t-J SWMU38 Cover:£Yes o No Notes: SWMU45 Cover;..a'")'es □ No N otes: SWMU49 Cover:~es o No Notes: SWMU50 Cover;...a-Y es o No Notes: SWMU52 Cover:.2l"'Yes o No Notes: Other General Observations Prepared By: Date: I Page: ,,,-::. ./ 1 o/u .... ( 2,? I 1 of 2 ,, Rev O 2019-07 AECOM WZ SMP Inspection _-1,..uz 1 Date: IO/ 12 / 2 1.. IProl ect Nllme: 1,..1 ?-Sl'--P I::,.,< -:-,,,J.\,, Project No: AECOM Staff Onalte : w. \ i=>~M,I I ',._ r --.--~. Tlme Onslte: 7 '. rn Other Personnel Onslte: Efr~ 1>DJ.~o',.. 1vc Tlme Offalte: 11 ; Ob Prevention of Habitat and Wildlife Deterrence SWMU3 Habitat/Wildlife Mitiaation methods: It-A •. ,.,L up,. LI }, SWMU4 Habitat/Wildlife Mitigation methods: , SWMUS Habitat/Wildlife Mitiaation methods: SWMU6 Habitat/Wildlife Mitlaatlon methods: SWMU7 Habitat/Wildlife Mitlaation methods: SWMU8 Habitat/Wildlife Mitiaation methods: V SWMU 10 Habitat Mitiaation methods: (-,~,..J..eJ._ ,-.:, l ,,,,,,J..,..,l.';,1--.. SWMU 18 Wildlife Miti<1ation methods: lJ,,, -~,,.}.~.,,. ~ ~ f, \-o I,,,, J\.-...v1 ,, a ,,.,I MitiQation methods: rnl... ,._-;-"' 1r "·"' <. \-.\ : .... , SWMU20 Habitat ,·, JJ ~ c.a tf\-</" SWMU26 Habitat Mitiaatlon methods: \/ e,, t,\.-.\1...._ "~t.A.\ l-o L... A. ---_,l!J,J SWMU27 Habitat Mitiaation methods: l}, \,-..4', .. ,_.,1 \_ \,. ,_,..._ . ~J SWMU34 Habitat/Wildlife Mitiaation methods: /1,\ 0 .. A.,.,.k_ v r 1 :\-',~ , SWMU35 Habitat/Wildlife Mitigation methods: . -,I SWMU3SA Habitat/Wildlife MitiQat ion methods: SW MU 36 Habitat/Wildlife Mitigation methods: V SWMU44 Wildlife MitiQation methods: P~ r ~,-.,.t(r V a,\. -..\;o, ""' .\ """ ,r l AOC13 Habitat/Wildlife Mitigation methods: VP-c. \, •• ,k .... "'# ,.A. l, I._ -,, __ J AOC15 Habitat/Wild life Mitiaation methods: ,it , Mud Flats Wildlife Mitigation methods: ,JA MNA Surface Water Monitoring SWMU44 Sampled: □ Yes.ri""No Notes: AOC15 Sampled: □ Yes 12'1110 Notes: Mud Flats Sampled:□ Yesz'No Notes: MNA Soil Samolina Mud Flats Sampled: □ Yes i.r'No Notes: Other Gen eral Observations Prepered er,_, I Date: I Page: / $ I /Dfo..,/ Z,<. I 2 o l 2 Rev 0 2019-0 7 A:COM Attachment 2 2023 Photograph Log 2022 Photograph Log AECOM Western Zirconium 2023 SMP Inspection PHOTOGRAPH LOG I Site Location: I Project No. 10000 W 900 S, Ogden, UT 84404 60659083 SWMU 2/21/48 Photo 1 -SMP Inspection October 12, 2023 SWMU 2/21/48 Photo 2 -SMP Inspection October 12, 2023 1 AECOM Western Zirconium 2023 SMP Inspection PHOTOGRAPH LOG I Site Location: I Project No. 10000 W 900 S, Ogden, UT 84404 60659083 SWMU 2/21/48 Photo 3 -SMP Inspection October 12, 2023 SWMU s 3, 4, 5, 6, 7, 8, 34, 35, 35a, and 36 Photo 4 -SMP Inspection October 12, 2023 Description: Site with sign on the gate, note moderate ve etation . 2 AECOM PHOTOGRAPH LOG Western Zirconium 2023 SMP Inspection I Site Location: I Project No. 10000 W 900 S, Ogden, UT 84404 60659083 SWMU s 3, 4, 5, 6, 7, 8, 34, 35, 35a, and 36 Photo 5 -SMP Inspection October 12, 2023 Description: Site with sign on the fence , note moderate vegetation. SWMU s 3, 4, 5, 6, 7, 8, 34, 35, 35a, and 36 Photo 6 -SMP Inspection October 12, 2023 Description: Site with sign on gate , note moderate ve etation . 3 AECOM PHOTOGRAPH LOG Western Zirconium 2023 SMP Inspection I Site Location: I Project No. 10000 W 900 S , Ogden, UT 84404 60659083 SWMU s 3, 4, 5, 6, 7, 8, 34, 35, 35a, and 36 Photo 7 -SMP Inspection October 12, 2023 Description: Site with sign on gate, note moderate vegetation . SWMU s 3, 4, 5, 6, 7, 8, 34, 35, 35a, and 36 Photo 8 -SMP Inspection October 12, 2023 Description: Site with sign on gate , note moderate ve etation . 4 AECOM Western Zirconium 2023 SMP Inspection PHOTOGRAPH LOG I Site Location: I Project No. 10000 W 900 S, Ogden, UT 84404 60659083 SWMU s 3, 4, 5, 6, 7, 8, 34, 35, 35a, and 36 Photo 9 -SMP Inspection October 12, 2023 Description: Site with sign on gate, note moderate vegetation . SWMUlO Photo 10 -SMP Inspection October 12, 2023 Description: Site with sign, note no vegetation. 5 AECOM Western Zirconium 2023 SMP Inspection PHOTOGRAPH LOG I Site Location: I Project No. 10000 W 900 S, Ogden, UT 84404 60659083 SWMUlO Photo 11 -SMP Inspection October 12, 2023 Description: Site with sign, note no vegetation. SWMU18 Photo 12 -SMP Inspection October 12, 2023 6 AECOM Western Zirconium 2023 SMP Inspection PHOTOGRAPH LOG I Site Location: I Project No. 10000 W 900 S, Ogden, UT 84404 60659083 SWMU20 Photo 13 -SMP Inspection October 12, 2023 Description: Site with sign, note moderatevegeta tion. Direction: Northeast SWMU20 Photo 14 -SMP Inspection October 12, 2023 7 AECOM Western Zirconium 2023 SMP Inspection PHOTOGRAPH LOG I Site Location: I Project No. 10000 W 900 S, Ogden, UT 84404 60659083 SWMU26 Photo 15 -SMP Inspection October 12, 2023 SWMU26 Photo 16 -SMP Inspection October 12, 2023 Description: Site with sign, note moderate vegetation. Direction: Northeast 8 AECOM Western Zirconium 2023 SMP Inspection PHOTOGRAPH LOG I Site Location: I Project No. 10000 W 900 S , Ogden, UT 84404 60659083 SWMU27 Photo 17 -SMP Inspection October 12, 2023 SWMU27 Photo 18 -SMP Inspection October 12, 2023 Description: Site with sign, note moderate vegetation , un aved . 9 AECOM Western Zirconium 2023 SMP Inspection pavement PHOTOGRAPH LOG I Site Location: I Project No. 10000 W 900 S, Ogden, UT 84404 60659083 SWMU38 SWMU44 Photo 20 -SMP Inspection October 12, 2023 Description: Site with sign, note moderate vegetation around erimeter. 10 AECOM Western Zirconium 2023 SMP Inspection pavement. PHOTOGRAPH LOG I Site Location: I Project No. 10000 W 900 S, Ogden, UT 84404 60659083 SWMU45 Photo 21 -SMP Inspection October 12, 2023 SWMU49 Description: Sign on adjacent building. SWMU 49 is to the east outside of the fenced area. Note surrounding Direction: North avement. 11 AECOM Western Zirconium 2023 SMP Inspection PHOTOGRAPH LOG I Site Location: I Project No. 10000 W 900 S, Ogden, UT 84404 60659083 SWMU50 Photo 23 -SMP Inspection October 12, 2023 Description: Site with sign, note surrounding pavement. SWMU52 Photo 24 -SMP Inspection October 12, 2023 avement. 12 AECOM Western Zirconium 2023 SMP Inspection pavement. PHOTOGRAPH LOG I Site Location: I Project No. 10000 W 900 S, Ogden, UT 84404 60659083 SWMU52 Photo 25 -SMP Inspection October 12, 2023 SWMU59 Photo 26 -SMP Inspection October 12, 2023 13 AECOM Western Zirconium 2023 SMP Inspection PHOTOGRAPH LOG I Site Location: I Project No. 10000 W 900 S, Ogden, UT 84404 60659083 SWMU59 Photo 27 -SMP Inspection October 12, 2023 SWMU60 Photo 28 -SMP Inspection October 12, 2023 14 AECOM Western Zirconium 2023 SMP Inspection PHOTOGRAPH LOG I Site Location: I Project No. 10000 W 900 S, Ogden, UT 84404 60659083 SWMU62 Photo 29 -SMP Inspection October 12, 2023 SWMU62 Photo 30 -SMP Inspection October 12, 2023 15 AECOM Western Zirconium 2023 SMP Inspection PHOTOGRAPH LOG I Site Location: I Project No. 10000 W 900 S, Ogden, UT 84404 60659083 AOC 13 and 15 Photo 31 -SMP Inspection October 12, 2023 Description: Site with sign, note heavy vegetation AOC 13 and 15 Photo 32 -SMP Inspection October 12, 2023 Description: Site with sign , note heavy vegetation 16 AECOM Western Zirconium 2023 SMP Inspection PHOTOGRAPH LOG I Site Location: I Project No. 10000 W 900 S, Ogden, UT 84404 60659083 AOC 15 Photo 33 -SMP Inspection October 12, 2023 Description: Site with sign, note heavy vegetation AOC 14 Photo 34 -SMP Inspection October 12, 2023 17 AECOM Western Zirconium 2023 SMP Inspection PHOTOGRAPH LOG I Site Location: I Project No. 10000 W 900 S, Ogden, UT 84404 60659083 Pond Area Groundwater Current Year (2023) No Photo Description: Pond area overview I Direction: South Mud Flats Photo 35 -SMP Inspection October 12, 2023 Description: Mud flats, note minimal vegetation 18 AECOM Western Zirconium 2023 SMP Inspection PHOTOGRAPH LOG I Site Location: I Project No. 10000 W 900 S, Ogden, UT 84404 60659083 Mud Flats Photo 36 -SMP Inspection October 12, 2023 Description: Mud flats, note minimal vegetation 19 AECOM PHOTOGRAPH LOG Western Zirconium 2022 SMP Inspection I Site Location: 10000 W 900 S, Ogden, UT 84404 I Project No. 60659083 SWMU 2/21/48 Photo 1 -Current Year (2022) MAIL LOG Description: Photograph depicts site with sign, facing northwest. SWMU 2/21/48 Photo 2 -Current Year (2022) PREFS ~-. 041 263462 ~/~~.i -t2.230~7 f • t 4247,ff MAIL MAP Description: Photograph depicts site with sign, facing east. 1 AECOM Western Zirconium 2022 SMP Inspection PREFS PHOTOGRAPH LOG I Site Location: 10000 W 900 S, Ogden, UT 84404 SWMU s 3, 4, 5, 6, 7, 8, 34, 35, 35a, and 36 Photo 1 -Current Year (2022) I Project No. 60659083 MAIL Description: Photograph depicts site with sign on gate, facing east near SWMU 34, 35 , 35a, note minimal ve etation. SWMU s 3, 4, 5, 6, 7, 8, 34, 35, 35a, and 36 Description: Photograph depicts site with sign inside of the fence, facing northeast near SWMU 34, 35, 35a, note minimal ve etation. 2 AECOM Western Zirconium 2022 SMP Inspection PHOTOGRAPH LOG I Site Location: 10000 W 900 S, Ogden, UT 84404 SWMU s 3, 4, 5, 6, 7, 8, 34, 35, 35a, and 36 Photo 3 -Current Year (2022) I Project No. 60659083 Description: Photograph depicts site with sign on gate, facing southeast toward SWMU 36, note minimal ve etation. SWMU s 3, 4, 5, 6, 7, 8, 34, 35, 35a, and 36 Photo 4 -Current Year (2022) MAIL Description: Photograph depicts site with sign on gate, facing northwest near SWMU 7, note minimal ve etation. 3 AECOM Western Zirconium 2022 SMP Inspection PREFS PHOTOGRAPH LOG I Site Location: 10000 W 900 S, Ogden, UT 84404 SWMU s 3, 4, 5, 6, 7, 8, 34, 35, 35a, and 36 I Project No. 60659083 Description: Photograph depicts site with sign on gate, facing north near SWMU 4, note minimal vegetation. SWMU s 3, 4, 5, 6, 7, 8, 34, 35, 35a, and 36 Photo 6 -Current Year (2022) PREFS MAIL Description: Photograph depicts area to the south of SWMU 4, facing southeast, note minimal vegetation. 4 AECOM PHOTOGRAPH LOG Western Zirconium 2022 SMP Inspection I Site Location: 10000 W 900 S, Ogden, UT 84404 SWMUlO Description: Photograph depicts site with sign, facing west, note minimal vegetation. SWMUlO Photo 2 -Current Year (2022) PREFS ~T-: _ _ ·+o!! 1 260402 ° 1 -112 .220979 ~ t. 4233tt ; _ _ . _. Description: Photograph depicts site with sign, facing southeast, note minimal vegetation. I Project No. 60659083 5 AECOM PHOTOGRAPH LOG Western Zirconium 2022 SMP Inspection I Site Location: 10000 W 900 S, Ogden, UT 84404 I Project No. 60659083 SWMU18 Photo 1 -Current Year (2022) Description: Photograph depicts site facing north, note heavy vegetation. SWMU18 Photo 2 -Current Year (2022) PREFS MAIL Description: Photograph depicts site facing north, note heavy vegetation. 6 AECOM PHOTOGRAPH LOG Western Zirconium 2022 SMP Inspection I Site Location: 10000 W 900 S, Ogden, UT 84404 SWMU20 Photo 1 -Current Year (2022) Description: Photograph depicts site with sign, facing east, note moderate vegetation. SWMU26 Photo 1 -Current Year (2022) Description: Photograph depicts site with sign, facing east, note moderate vegetation. I Project No. 60659083 7 AECOM PHOTOGRAPH LOG Western Zirconium 2022 SMP Inspection I Site Location: 10000 W 900 S, Ogden, UT 84404 SWMU27 Photo 1 -Current Year (2022) Description: Photograph depicts site with sign, facing east, note moderate vegetation. SWMU27 Photo 2 -Current Year (2022) I Project No. 60659083 MAIL LOG Description: Photograph depicts site with sign, facing southeast, note moderate vegetation. 8 AECOM PHOTOGRAPH LOG Western Zirconium 2022 SMP Inspection I Site Location: 10000 W 900 S, Ogden, UT 84404 SWMU38 Description: Photograph depicts site with sign, facing north. SWMU38 Description: Photograph depicts site, facing north, note surrounding pavement. I Project No. 60659083 9 AECOM Western Zirconium 2022 SMP Inspection PREFS PHOTOGRAPH LOG I Site Location: 10000 W 900 S, Ogden, UT 84404 I Project No. 60659083 SWMU44 Photo 1 -Current Year (2022) MAIL Description: Photograph depicts site with sign, facing southeast. Note, no trespassing sign and moderate ve etation around erimeter. SWMU44 Photo 2 -Current Year (2022) PREFS +041 .263949 ° / -112 .228342 ° t 4231 ft MAIL MAP ◄N ► LOG Description: Photograph depicts site, facing north. Note moderate vegetation around perimeter. 10 AECOM Western Zirconium 2022 SMP Inspection MAP PHOTOGRAPH LOG I Site Location: 10000 W 900 S, Ogden, UT 84404 I Project No. 60659083 SWMU44 Photo 3 -Current Year (2022) +041 .263948 ° / -112 .228341 ° t 4230ft MAIL ◄N ► LOG Description: Photograph depicts site north of the stormwater ditch (AOC 15), facing northeast. SWMU44 Photo 4 -Current Year (2022) +041 .266533 ° / -112 .227967 ° t 4225ft MAIL MAP ◄N ► LOG Description: Photograph depicts site on the northern property boundary, facing east. Note moderate vegetation around erimeter. 11 AECOM Western Zirconium 2022 SMP Inspection PHOTOGRAPH LOG I Site Location: 10000 W 900 S, Ogden, UT 84404 I Project No. 60659083 SWMU45 Description: Photograph depicts site with sign, facing southwest, note surrounding pavement. SWMU49 Description: Photograph depicts sign on adjacent building, facing northeast. SWMU 49 is to the east outside of the fenced area. Note surroundin avement. 12 AECOM PHOTOGRAPH LOG Western Zirconium 2022 SMP Inspection I Site Location: 10000 W 900 S, Ogden, UT 84404 SWMUSO Photo 1 -Current Year (2022) Description: Photograph depicts site with sign, facing east, note surrounding pavement. SWMU52 Description: Photograph depicts site with sign, facing north, note surrounding pavement. I Project No. 60659083 13 AECOM PHOTOGRAPH LOG Western Zirconium 2022 SMP Inspection I Site Location: 10000 W 900 S, Ogden, UT 84404 SWMU52 Description: Photograph depicts site with sign, facing west, note surrounding pavement. SWMU59 Photo 1 -Current Year (2022) PREFS Description: Photograph depicts site with sign, facing east. I Project No. 60659083 MAIL 14 AECOM PHOTOGRAPH LOG Western Zirconium 2022 SMP Inspection I Site Location: 10000 W 900 S, Ogden, UT 84404 I Project No. 60659083 SWMU59 Photo 2 -Current Year (2022) MAIL LOG Description: Photograph depicts site with sign, facing southeast. SWMU60 Photo 1 -Current Year (2022) PREFS ____..,..___,. MAIL Description: Photograph depicts site with sign, facing southeast. 15 AECOM PHOTOGRAPH LOG Western Zirconium 2022 SMP Inspection I Site Location: 10000 W 900 S, Ogden, UT 84404 I Project No. 60659083 SWMU60 Photo 2 -Current Year (2022) Description: Photograph depicts site with sign, facing southwest. SWMU62 Photo 2 -Current Year (2022) Description: Photograph depicts site with sign, facing west/northwest. 16 AECOM PHOTOGRAPH LOG Western Zirconium 2022 SMP Inspection I Site Location: 10000 W 900 S, Ogden, UT 84404 SWMU62 Photo 1 -Current Year (2022) Description: Photograph depicts site with sign, facing west. AOC 13 and 15 Photo 1 -Current Year (2022) PREFS Description: Photograph depicts site with sign, facing northeast, note heavy vegetation. I Project No. 60659083 MAIL 17 AECOM PHOTOGRAPH LOG Western Zirconium 2022 SMP Inspection I Site Location: 10000 W 900 S, Ogden, UT 84404 AOC 13 and 15 Photo 2 -Current Year (2022) +041 .263656 ° /~112,228396 ~ .t _4222ft Description: Photograph depicts site with sign, facing southeast, note heavy vegetation . AOC14 Description: Photograph depicts site with sign, facing southwest I Project No. 60659083 MAIL 18 AECOM PHOTOGRAPH LOG Western Zirconium 2022 SMP Inspection I Site Location: 10000 W 900 S, Ogden, UT 84404 I Project No. 60659083 Pond Area Groundwater Photo 1 -Current Year (2022) Description: Photograph depicts pond area overview, facing north. Mud Flats Description: Photograph depicts mud flats overview, facing northeast, note minimal vegetation. 19 AECOM Western Zirconium 2022 SMP Inspection PHOTOGRAPH LOG I Site Location: 10000 W 900 S, Ogden, UT 84404 Mud Flats Photo 2 -Current Year (2022) I Project No. 60659083 MAIL LOG Description: Photograph depicts mud flats overview, facing southeast, note minimal vegetation. 20 A:COM Attachment 3 Phragmites Mitigation Attachment 3 -Phragmites Mitigation The dominant vegetation at SWMU 18, 20, 26, 27, AOC-13, and AOC-15 is phragmites. Phragmites is an aggressive, tall, dense, wetland to upland grass that crowds out native vegetation. Phragmites is generally dormant from late October to late March in Utah. It has an extensive underground rhizome system that can spread up to a half mile in length. The extensive rhizome system makes phragmites challenging to control and the use of a single control method may not be effective. Disturbance to any single area may increase the density and spread of the invasive phragmites stand. General methods of control are listed in the below sections. Biological Control Methods There are no successful biological control methods for controlling phragmites. Cultural Control Methods Cultural control methods involve changing the environment or cultural practice of the land to benefit desirable plants rather than invasive plants, like phragmites. Cultural controls may include, but are not limited to, draining or filling an area to reduce soil moisture content. Implementation of AOC-15 design and workplan would be an example of a cultural control method that could be implemented on site. Dry soils inhibit phragmites seed germination while moist soils provide ideal conditions for phragmites seed germination. It is important to drain water and to keep the soil as dry as possible to reduce phragmites habitat. Mechanical Control Phragmites growth can be inhibited by methods such as mechanical remove, mowing, or the use of geotextile fabrics. Mechanical removal is the most difficult to achieve due to the extensive rhizome systan ofphragmites. Simple tilling or disking of the soil will promote spread of the plant. Mowing or cutting of phragmites in mid-summer to fall is an effective means to reduce growth if done on a frequent basis. Herbicide Control Treatment with herbicides is the preferred way to control phragmites and greatly reduces the mass of the rhizome zone. Herbicides containing glyphosate and imazapyr are recommended. Formulations of the~ products labeled for use near water include Rodeo, AquaNeat, Aquastar (glyphosate), and Habitat ( imazapyr). Glyphosate and imazapyr are both non-selective herbicides and will kill any plants they contact The primary difference is that glyphosate has no soil activity while imazapyr can be taken up from the soil by the roots. The preferred herbicide application period is from June to October while the plant is still green and is actively growing. Dead material after spraying should be removed from the landscape with special care taken to prevent spreading of seeds. In each subsequent year, the goal is to inhibit new seed production by spraying early and often to keep the biomass minimal. Land managers have found that phragmites cannot be controlled with a single treatment and will require multiple years of treatment to control (2 to 3 years or longer). An invasive weed control program should be prepared and tailored to the WZ site. In each subsequent year, treated areas should be monitored and follow-up treatments applied to surviving weeds as needed. Short-term Control of Phragmites Treatment with herbicides is the preferred short-term method for controlling phragmites. Spray only when the plants are green and growing (generally from spring through late summer) for the best results. Repeated application is recommended monthly so long as repetition does not exceed the label requirements for maximum quantity applied . In addition to herbicide application, addition of mowing is recommended to reduce plant biomass, particularly in late fall where large stand are already present and their over-winter biomass will hinder herbicide spray contact with green vegetation in the spring. Mowing is not recommended less than two weeks to a month prior to application of the herbicide because the herbicide must contact the plant green leaves during their active growing season. Herbicide is not effective on plant stems. Long-term control of Phragmites Where not in conflict with US Army Corps of Engineers regulations, placement of fill material in wet or moist areas will dry site soils and reduce phragmites habitat. If filling over existing established stands of phragmites, at least one round of spraying prior to filling will be required Mowing ( or compressing) prior to fill placement is necessary to ensure at least 2 feet of fill is placed over the top of the vegetation. Allow a minimum of two weeks between spraying and mowing to allow the plants to wilt. This will allow enough time for the herbicide to travel into underground rhizome system of the plant. After filling, inspect the area frequently for any new invasive plants and spot treat impacted areas with an herbicide prior to flowering or seed development. Generally, spraying before the plant is one foot tall and mowing 2 weeks later would be ideal. AOC-15 interim corrective action (stormwater pipe installation) is an example of a cultural long term control method to reduce phragmites in the area between the Plant area and Pond area of the site. AOC-15 interim action includes installation of a high-density polyethylene (HDPE) pipe to convey water to the stormwater holding pond, installation of an HDPE geomembrane beneath the pipe to provide a separation between surface water and groundwater, placement of engineered fill material over the area to improve drainage and allow the soils to dry. After completion of AOC-15, the area would be less susceptible to invasive weeds such as phragmites. The area should be inspected frequently for any invasive weeds after construction. If invasive weeds are discovered after construction, the impacted area should be spot treated with an herbicide prior to plant flowering. Additionally, noninvasive plants species should be managed by mechanically mowing to reduce habit. Wet Area Application and Protocol Due to the prevalence of phragmites in wetlands and waterways, a non-toxic herbicide approved for application in water must be used in wet areas, such as AquaNeat or Rodeo, which are non-selective herbicides. In areas 25 feet away from wetlands or surface water, any non-selective herbicide may be used containing glyphosate or imazapyr. Addition of a surfactant in the herbicide mixture may be necessary in wetlands or waterways.