DSHW-2011-007100 - 0901a0688024b8c9

8200-FY11-015
RECEIVED
JUL 0 5 2011
Scott T. Anderson "/ICUIMIIP
Utah Division of Solid and Hazardous Waste ^^^^A^ADnnncHA/AQTF
Department of Environmental Quality SOLID & nAZARDUUb WAb i c
PO Box 144880 cPO 11. t) I ^M"!
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 Range, ATK Launch Systems-Promontory.
July 1 - September 28, 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 July
1 - September 28, 2011.
ATK currently has contracts in-place with the Department of Defense to manufacture decoy
and illumination flares over the next few years. These contracts require 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 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 perrnit, or as directed by the
agency:
• Box Elder Fire Marshall's Office
o 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 July 1, 2011 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 Jason Wells at 435-863-6895.
Sincerely,
David P. Gosen, P.E.
Director, Environmental Services
G: JeffVandel, DSHW
Central File