DSHW-2010-054673 - 0901a068801eb28a

December 17, 2010 D ETO Cfll /ff""
8200-FY11-056 nCUtlVtU
Scott T. Anderson DEC 2 2 20J0
Utah Division of Solid and Hazardous Waste U fAH DIVISIUlM UF
Department of Environmental Quality SOLID & HAZARDOUS WA^TP
POBox 144880 ^ ^
Salt Lake City, UT 84114-4880 C?^/C7. CP^*^'^3
RE: Request for Emergency Permit to Burn Aircraft Dropped or Ground Launched
Flares in Place at the Kosmo Test Range, ATK Launch Systems-Promontory.
January 1 - March 31, 2011
Dear Mr. Anderson,
ATK Launch 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
otherwise deemed unsafe after deployment. The time period for this permit will be from
January 1 - March 31, 2011.
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-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 underthis permit 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 ofthe 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 bur 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 ofthe 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 January 1, 2011 and run on a quarterly basis.
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 questions or need additional clarifications, please
contact Jason Wells at 435-863-6895.
Sincerely,
David P. Gosen, FyE.
Director, Environmental Services
C: Jeff Vandel, DSHW
Central File