DSHW-2009-007080 - 0901a0688013a386

ATK
ALLIANT TECHSYSTEMS
January 19,2006
8200-FY06-039
Dennis R. Downs
Division of Solid and Hazardous Waste
Department of Environmental Quality
P. O. Box 144880
Salt Lake City, UT 84114-4880
Attention: Jeff Vandel
ATK Thiokol Inc.
P.O. Box 707
Brigham City, UT 84302-0707
Tel [phone]
Fax [phone]
RECEIVED
UTKH'DTVrsTON OF
SOLID & HAZARDOUS WASTE
Subject: Request For Emergency Permit To Bum Dropped Flares In Place, ATK
Thiokol-Promontory EPA ID number UTD009081357
ATK Thiokol-Promontory has a contract to perform drop tests for lOea. LUU-19 and
lOea. LUU-2 flares at T-20. The test consists of a 40' drop onto a 4" thick metal plate, to
simulate dropping a flare on a Navy ship deck, to determine if the flare will ignite. Based
on past testing, we believe that most of the flares will not ignite. Damage resulting from
the drop has been found to render the flares unsafe to move. Therefore, ATK Thiokol
requests an emergency permit to allow buming of the units in place. We request the
duration of this permit to mn from January 19 -26,2006.
Each dropped flare will be treated before the next test will begin. Our proposed
management plan for these flares is as follows:
1) After the drop, the flare will be inspected to determine in the igniter has popped out.
2) If the igniter has popped out, the igniter will be remotely picked up and placed into a 5-
gallon bucket of water for desensitizing. The flare and igniter (if intact) will be remotely
slid off the metal plate and onto the adjacent concrete for treatment.
3) A de-mining flare will be positioned over the dropped flare then ignited remotely. The
de-mining flare will in tum ignite the dropped flare which should bum to completion.
4) After cool down, the flare and bum residue will be cleaned up and placed into a
properly labeled super sack.
I
5) Upon completion of all testing, the super sacks and bucket of water with igniters will
be transported to the M-136 bum grounds for thermal treatment. The previously bumed
flares and residue will be re-biimed to reduce the water reactivity potential from unburned
magnesium. The igniters in the bucket of water will be bumed to inert the blasting caps.
Both of these items will carry a D003 EPA waste code.
If you have any question or need additional clarification, please contact Gene Curtis of
my staff at [phone]. Thanks for your assistance on this matter.
Sincerely,
G. E. Gooch, Manager
Environmental Services