DAQ-2024-007248

DEPARTMENT OF THE ARMY
INSTALLATION MANAGEIIIENT COilIMAND
HEADQUARTERS, UNITED STATES ARMY GARRISON, DUGWAY PROVING GROUND
DUGWAYUT 8402
February 20,2024
Office of the Garrison Manager TJTAH DEPABTMENT OF
ENVIRONMENTAL OUALITY
f lB 'lB',:r',U,
D,*JEftdoP:limr.t,
Dear Mr. Bird:
On behalf of U.S. Army Dugway Proving Ground (DPG) and in accordance with
(!AW DPG Title V Operating Permit condition I1.8.11.b.1.k.3, I am pleased to submit
one copy of the Non-burning Alternatives to Fire & Long-term Projections Report.
This report includes a list of areas treated using non-burning alternatives to fire
conducted during calendar year 2023 and projections of future prescribed fire
activities for upcoming calendar yeat 2024.
Please direct your staff to contact Boyd Roberts of the Division of Environmental
Programs at [phone] with any questions or comments regarding this matter.
IAW operating permit provision l.K and Utah Administrative Code R307-415-5d
and based on information and belief formed after reasonable inquiry, I certify that
the statements and information in this document are true, accurate, and complete.
Sincerely,
4"rr2%
Christopher D. Damour
Garrison Manager
Mr. Bryce Bird
Director
Utah Division of Air Quality
P.O. Box 144820
Salt Lake City, Utah 84114-4820
Enclosure
B-2-10706
U.S. Army Dugway Proving Ground
Non-burning Alternatives to Fire &
Long-term Fire Proiections Report
February 6, 2024
I.'TAH DEPARTMENT OF
ENVIRONMENTAL OUALITY
FIB 2 tj tt)?:4
DIVISION OF AIR QUALITy
Submitted By
Division of Environmenta! Programs
U.S. Army Dugway Proving Ground
Dugway, UT 84022-5000
Prepared By
Mellor Engineering
Dugway Operations
Building 6672, Stark Road
Dugway, Utah84022
TABLE OF CONTENTS
1.0 lntroduction ........ ..................1
2.0 Non-burning Alternatives to Fire...... .................,..,..1
2.1 Aeria! Herbicide Application ............ 1
2.2Granular Herbicide Application.......... ..............2
2.3 Firebreaks........... ...........2
2.4 Tumbleweed Control ......................2
3.0 Long-term Fire Projections ....................3
3.1 Small Prescribed Fires (de minimus) ...............3
3.2 Small Prescribed Pile Fires (de minimus)............. .....,...... 3
List of Abbreviations/Acronyms
cY23
cY24
DPG
TVOP
UDAQ
U.S.
Calendar year 21023
Calendar year 2024
Dugway Proving Ground
Title V Operating Permit
Utah Division of Air Quality
United States
1.0 lntroduction
U.S. Army Dugway Proving Ground (DPG) Title V Operating Permit (TVOP) Number
4500003005 issued by the State of Utah Division of Air Quality (UDAQ), sets DPG's
operating requirements in accordance with Utah Administrative Code R307,
Environmental Quality, Air Quality. TVOP condition 11.B.1.k.3 "Prescribed Fires" requires
DPG to submit an annual report containing a list of areas treated using non-burning
alternatives to fire conducted during the previous calendar year, in addition to projections
of future prescribed fire activities planned for the upcoming calendar year.
The report is presented in the following sections:
. Section 2.0 - Non-burning Alternatives to Fire. Section 3.0 - Long-term Fire Projections
2.0 Non-burning Alternatives to Fire
This section describes non-burning alternatives to fire conducted during calendar year
2023 (CY23). The following information is provided for each alternative action:
o Description of the alternative action.o Number of acres.. Location of area.
2.1 Aerial Herbicide Application
DPG in collaboration with Hill Air Force Base employed Youngstown Air Force Reserve
91Oth Airlift Wing C-130 aircraft and crew to conduct aerial application of herbicide on
approximately 1 ,477 along the Stark Road corridor between English Village and Ditto,
and around the boundary of the White Sage Mortar Range, to control undesirable invasive
vegetation and facilitate firebreak establishment and maintenance. This project is
implemented to control invasive weed species at DPG, which produce severe and
dangerous conditions for range fire ignition. Aerial application of a selective herbicide
was used to eliminate or reduce weeds and prevent or minimize the extent of range fires.
The herbicide, imazapic, (trade name Plateau@), was chosen for its target weed
specificity, low toxicity to humans, animals, and the environment. A specially equipped
C-130 fixed wing aircraft conducted the aerial application in October of 2023, spraying
100-200 footwide swaths along Stark Road between English Village and Ditto and around
the interior boundary of the White Sage Mortar Range.
The totalarea of application was approximately 1,477 acres. Locations of aerialtreatment
areas have been provided in Appendix A, Map 1, "C130 Herbicide Operation".
2.2 Granular Herbicide Appl ication
DPG also conducted dispersal of granular herbicides by helicopter on approximately 850
acres creating 35 miles of fuel breaks for the purpose of firebreak establishment,
maintenance, and control of undesirable non-native vegetation. This project was
implemented to control invasive weed species at DPG and lower the risk of range fire
ignition. The herbicide used, imazapic, commonly referred to by its trade name, Open
Range G@, was chosen for its specific characteristics that meet DPG's need to eliminate
multiple invasive weed species with very low toxicity to wildlife and the environment.
Open Range G@ is a pre-emergent herbicide that kills cheatgrass seeds as they
germinate, which provides effective control for up to 2 years.
Application of the granular herbicide occurred along Rough Haul Road, firebreaks and
roads that run from Rough Haul Road to the Dugway eastern boundary, and along West
Five Mile Road.
The totalarea of application was approximately 2,327 acres. Locations of aerialtreatment
areas have been provided in Appendix A, Map 2, "Heli Herbicide Operation".
2.3 Firebreaks
Unpaved dirt roads located source-wide are considered key fire access roads and serve
as firebreaks. Unpaved dirt roads including those which parallel fencelines are graded
and maintained annually. Key roads include North Village lnterior Security Fence Line
Road from the eastern main gate around Colonel Hill and English Village and back to
Stark Road; East Security Fence Line Road from Stark Road south along this eastern
security fence line around to Durand Road; North Gate Road; Downwind West Road to
Pigeon Loft Road; Road 5700; North Rough Haul Road; Newt's Alley; White Sage Impact
Area; and Camp Tumbleweed Road.
All locations of unpaved dirt road firebreak areas have been provided in Appendix A, Map
3, " Roads/Fenceline Graded and Maintained as Firebreaks".
2.4 Tumbleweed Control
Each year, primarily in spring, certain segments of the DPG fences build up with mounds
of loose, dead tumbleweeds which blow in and stick against the fencelines. Many ravines,
ditches, and depressions accumulate tumbleweed which greatly increasing fire hazards.
Extreme fire behavior can be expected from these situations. Controlling tumbleweeds
and managing areas where tumbleweeds accumulates by manually removing them
reduce fire spread rates. During CY23, tumbleweed caches located source-wide were
removed using hand tools and a baler for gathering and transporting baled tumbleweeds
to the landfill.
2
Locations of primary fencelines which collect tumbleweed caches have been provided in
Appendix A, Map 4,.Primary Fenceline Tumbleweed Collection Areas".
3.0 Long-term Fire Projections
By treating fuels in advance, DPG can mitigate and reduce the risk of wildland fires by
eliminating or reducing flammable fuels through prescribed burn activities. Long-term fire
projections detailing planned prescribed burn activities projected to occur during calendar
year 2024 (CY24) have been outlined in sections 3.1 and 3.2 below.
3.1 Small Prescribed Fires (de minimus)
Strip burning vegetation benefits certain fuelbreaks in the late spring or early summer
months when the fire weather (danger) is low enough to permit fire spread, but easy to
contain or control. As part of a fuelbreak efficiency, DPG could potentially burn a
maximum of four (4) plots during CY24. Each individua! plot is between 5 - 20 acres with
the planned prescribed fire area within DPG proper equaling no more than 50 acres total
during CY24.
3.2 Small Prescribed Piled Material (de minimus)
Small prescribed pile fires involving tumbleweed caches may occur during early spring,
CY24, dependent upon the severity of cache accumulations. While most tumbleweed
removal occurs manually as described in Section 2.0, an overabundance of tumbleweed
caches may prompt the need for small prescribed pile fires. On average, based on
historic information and estimated tumbleweed growth, de minimus small prescribed pile
fires occurring on DPG range between 0 - 3 per calendar year. The maximum plots
burned per day, not to exceed two, would equal between 5,000 - 30,000 cubic feet of
piled material per burn.
Designated de minimus prescribed burn plots in CY24 are located within DPG proper
along Rough Haul Road, Durand Road, Manookin Road and along the fencelines in White
Sage and English Village areas. Locations of primary fencelines which collect
tumbleweed caches have been provided in Appendix, Map 4, "Primary Fenceline
Tumbleweed Collection Areas".
APPENDIX A
MAPS
Table of Contents
Appendix A
Map 1. Aerial Herbicide Application .................. A-1
Map 2. Heli Herbicide Operation.............. .........4-2
Map 3. Roads/Fenceline Graded and Maintained as Firebreaks. ......... A-3
Map 4. Primary Fenceline Tumbleweed Collection Areas .................... A-4
Map 1. Aerial Herbicide Application
2023 C130 Herbicide S
A-1
NI
tro
.J(ELo
CLo
op
o
llLoT
o
c.i
CLo
=
co
I
o.Y
Go
-oo
iI
o(E
Eo
'6
'd
E
Ec
(U
EoE
(E
o
o
=oo
olt
oE
Got
c"j
o-
G
=
s
I
o(oo
o
oo
Eo
Eoo
=o
-o
E
o
=oo
LolL
G
E
L&
+
o-
(u
=
APPENDIX B
REFERENCES
Table of Gontents
Appendix B
References .................... B-1
2.
References
1. State of Utah Department of Environmental Quality (UDEQ), Utah Division of Air Quality (UDAQ),
Salt Lake City, Utah, TiUe V Operating Permit 4500003005 lssued to United Stat6 (U.S.) Army
Dugway Proving Ground (DPG), Utah.
United States (U.S.) Army, Dugway Proving Ground, Dugway, Utah, lntegnted Wdland Firc
Managoment Plan, June 2017.
Utah Offtce of Administrative Rules, Utah Administrative Code, R307. EnvironmentalQuality, Alr
Quality.
UTAH DEPARTMENT OF
EIWIRONMEI{TAL OUALITY
FEB 28 2024
DIVISION OF AIR QUAUTY
B-1