DSHW-2009-016201 - 0901a06880156903

December 14, 2006 [)5Q \ 9 200§
^^™-^^'"-°'^^ UTAH DIVISION 0^
„ . „ „ 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 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 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 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 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 ofthe 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 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 simplify tracking of the expiration date of this permit, we request
that it become effective on January 1, 2007 and mn 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-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].
Sincerely,
David p. Gosen, P.E
Director, Environmental Services
C: Jeff Vandel, DSHW
Randy Wilde, Bear River Health Department
Blain Hemp, State Lands
Gene Curtis, ATK Launch Systems