DSHW-2007-002720 - 0901a0688013f5d8

March 27, 2007 UTAH DIVISION OF
8200-FY07-091 SOLID & HAZARDOUS WASTE
Dennis R. Downs
Division of Solid and Hazardous Waste
Department of Environmental Quality
P. O, Box 144880
Salt Lake City, UT 84114-4880
RE: Subject: Request for Emergency Permit to Burn Aircraft Dropped or Ground
Launched Flares in Place at the Kosmo Test Range, ATK Launch Systems-
Promontory
Dear Mr. Downs,
ATK Launch Systems-Promontory (ATK) requests a 90-day emergency permit to burn aircraft
dropped and ground launched flares in-place if they fail to ignite, partially ignite or are otherwise
deemed unsafe after deployment.
ATK currently has contracts in place with the Department of Defense to manufacture decoy and
illumination flares over the next two years, and possibly longer. This contract includes regular
testing of flares. The test requirements mandate flare deployment in the method they were
designed. As such, they must be ground launched or dropped from aircraft to simulate actual
field conditions. A small percentage of these flares may not deploy as designed and may land
partially or completely un-bumed. As a result, the ignition system may become compromised
making il un-safe to move the flare. ATK's Test Services and the Safety Department have
determined that the only safe way to handle these un-burned flares is to burn them in-place.
Testing of these flares is conducted between Salt Wells Flat and Monument Point in Box Elder
County, in an area commonly called Kosmo. ATK has an agreement issued by the Division of
Forestry, Fire and Stale Lands to perform these tests. The special use lease agreement number is
30000038.
The flares to be tested and covered under this permit include the LUU-19, LUU-1, LUU2-C/B,
M257, M278. These flares range in weight from 5 to 30 lbs. and contain various combinations of
the following ingredients:
• sodium nitrate
• magnesium powder
• potassium nitrate
• cesium nitrate
• silicon
• hexamine
• polyester binder
After testing or burning in-place is completed for a given day, the flare residue and debris is
collected and transported to our Promontory facility for proper disposal.
ATK will notify the following agencies prior to each use of this permit, or as directed by the
agency:
• Box Elder Fire Marshall's Office
• Bear River Health Department
• Division of Forestry, Fire and Stale Lands
Upon expiration of this emergency permit, ATK will prepare a report of our activities, and
request a new permit for an additional 90 days to allow continued testing al the Kosmo range.
To help simplify tracking of the expiration date of this permit, we request that il become
effective on April 1, 2007 and run on a calendar-quarter basis or as close to the quarter as
possible.
ATK did not have cause lo use our emergency permit in the first quarter of 2007. Therefore, a
follow up report will nol be submitted to your office for this quarter.
ATK appreciates your help and cooperation in enabling us lo manage these un-burned flares in a
safe and responsible manner, if you have any question or need additional clarification, please
contact Gene Curtis of my staff at [phone].
Sincerely,
^^a^
David P. Gosen, P.!
Director, Environmental Sfefrvices
C: Jeff Vandel, DSHW
Gene Curtis, ATK Launch Systems