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HomeMy WebLinkAboutDSHW-2010-032923 - 0901a06880177830RECEIVFn MAR 2 n 20-0 SOLID & HA.ZARnOUS WA3T1 Launch Systems Group P.O. Box 707 Brigham City, UT 84302 www.atk.com March 16,2010 8200-FY10-090 Dennis R, Downs Utah Division of Solid and Hazardous Waste Department of Environmental Quality PO Box 144880 Salt Lake City, UT 84114-4880 RE: Request for EmerQency Permit to Burn Aircraft Dropped or Ground Launched Flares in Place at the Kosmo Test Rang, ATK Space Systems, Promontory. ApriM-June 30, 2010 Dear Mr, Downs, ATK Space Systems-Promontory requests a 90-day emergency permit to bum aircrafi dropped and ground launched flares in-place if they fail to ignite, partially ignite or are otherwise deemed unsafe after deployment. The time period for this permit will be from April 1 - June 30, 2010. 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(s). ATK's Test Services and the Safety Department have determined that in this instance, 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 pennit include the LUU-19, LUU-1, LUU2-C/B, M257 and 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 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 the emergency permit, ATK will request a new permit for an additional 90 days to allow continued testing at the Kosmo range. Likewise, a report will be prepared describing our activities during the previous permitting period. To help simplify tracking of the expiration date of this permit, we request it become effective on April 1, 2010 and mn on a quarteriy basis, ATK appreciates your help and cooperation in enabling us to manage these un-burned flares in a safe and responsible manner. If you have any qViestions or need additional clarifications, please contact Bryan Lee Howick at 435-863-6481. Sincerely, David P. Gosen, P.EA Director, Environmental Services C: JeffVandel, DSHW Central File