DSHW-2008-001274 - 0901a0688013a187

RECEIVED
SEP 2 ^ 2008
September 23, 2008 UJAH DIVISION OF
8200-FY09-036 SOLID & HAZARDOUS WASTE
Dennis R. Downs m?>. 03^I
Division ofSolid and Hazardous Waste
Department ofEnviromnental 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 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-burned. As a result, the ignition system may become compromised
making 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-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 State 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 notity 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 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 simplity tracking ofthe expiration date of this permit, we request that it become
effective on October 1, 2008 and run on a calendar-quarter basis or as close to the quarter as
possible.
ATK appreciates your help and cooperation in enabling us to manage these un-burned flares in a
safe and responsible manner. Ifyou have any question or need additional clarification, please
contact Gene Curtis of my staff at [phone].
Sincerely,
David P. Gosen, P.E.
Director, Environment^ Services
C: Jeff Vandel, DSHW
Gene Curtis, ATK Launch Systems