DSHW-2013-002764 - 0901a06880365346

UfPO)WI357 March 26, 2013
8200-FY13-074
Division of
Solid and Hazardous Waste
Scott T. Anderson «™ ^ £UIJ
Utah Department of Environmental Quality 2-013~QD2nL
Division of Solid and Hazardous Waste
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 Range, ATK Launch Systems-Promontory.
April 1 - June 29, 2013
Dear Mr. Anderson:
ATK Launch Systems- ATK 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 would be
from April 1 - June 29, 2013.
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 unburned. As a result, the ignition system may become
compromised making it unsafe 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.
March 26, 2013
Mr. Scon T. Anderson. Director
Uiah Division of Solid and Hazardous Waste ATK
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, which is the subject of this request, 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.
ATK appreciates the Division's cooperation in enabling us to manage these unbumed 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,
Robert Ingersoll
Director, Environmental Services
C: JeffVandel, DSHW
Central File