DSHW-2008-002826 - 0901a0688014066b

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June 20,2008
8200-FY09-014
Dennis R. Downs
Division ofSolid and Hazardous Waste
Department of Environmental Quality
P.O. Box 144880
Salt Lake City, UT 84114-4880
JUN 2 h 2003
U lAH DlVISlOlM OF
SOLiD & HAZARDOUS WASTE 0i>dzob9
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 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-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-bumed 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 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 ofthis 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 ofthis emergency permit, ATK will prepare a report of our activities, and
request a new pennit for an additional 90 days to allow continued testing at the Kosmo range.
To help simplify tracking ofthe expiration date ofthis pennit, we request that it become
effective on July 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 ofmy staffat [phone].
Sincerely, ^
David P. Gosen, P.E.
Director, Environmental Services
C: Jeff Vandel, DSHW
Gene Curtis, ATK Launch Systems