DSHW-2010-037669 - 0901a068801c831d

Launch Systems Group &•
P.O. Box 707 B a L,
Brigham City, UT 84302 g^^p ^ ^ £0^0
www.atk.com
UTAH DIVISIUIM uh
SOLID & HAZARDOUS WASTE
sr;-04'/°'° 2010.051 b3
Scott T. Anderson
Utah Division of Solid and Hazardous Waste
Department of Environmental Quality
PO Box 144880
Salt Lake City, UT 84114-4880
RE: Request for Emergency Permit to Burn Aircraft Dropped or Ground Launched Flares in
Place at the Kosmo Test Rang, ATK Space Systems, Promontory.
October 1 - December 31, 2010
Dear Mr. Anderson,
ATK Space Systems-Promontory 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 othenwise deemed unsafe
after deployment. The time period for this permit will be from October 1 - December 31, 2010.
ATK currently has contracts in-place vi/ith 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-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
and M278. These flares range in weight from 5 to 30 Ibs 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 ofthls 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 ofthe expiration date ofthls permit, we
request it become effective on October 1, 2010 and run on a quarterly 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 questions or need additional clarifications, please contact
Bryan Lee Howick at 435-863-6481.
Sincerely,
David P. Gosen, P.E. /
Director, Environmental Services
JeffVandel, DSHW
Central File