DSHW-2007-004358 - 0901a06880154d4f

RECEIVED
December 18, 2007 DEC 19 2007
8200-FY08-051 UTAH Ul VISION 01-
SOLID & HAZARDOUS WASTE
Dennis R. Downs Q-J A^^'^ j
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
Launclied Flares in Place at the Kosmo Test Range and Report of Activities, ATK
Launch Systems-Promontory
Dear Mr. Downs,
ATK Launch Systems-Promontory (ATK) requests a 90-day emergency permit to bum 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 few 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
maidng it 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-bumed flares is to bum 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 State Lands to perform these tests. The special use lease agreement number is
30000038.
The flares to be tested and covered under this pemiit include the LUU-19, LUU-1, HJU2-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 buming 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 Heahh Department
• Division of Forestry, Fire and State 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 at the Kosmo range.
To help simplify tracking of the expiration date of this permit, we request that it become
effective on January 1, 2008 and mn on a calendar-quarter basis or as close to the quarter as
possible.
No flares were de-mined during the forth quarter of 2007. Therefore, this notification will serve
as the required report.
ATK appreciates your help and cooperation in enabling us to manage these un-bumed 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].
Jeff Vandel, DSHW
Gene Curtis, ATK Launch Systems