TUS (Tracking Ultraviolet Set-up), the first orbital telescope of ultra-high energy cosmic rays (UHECRs), has demonstrated that instruments of this kind have much broader capabilities and can also detect meteors, transient luminous events, anthropogenic glow and other processes taking place in Earth atmosphere in the UV frequency range. In this short letter, we address the question if an orbital UHECR detector can also register gamma-ray bursts (GRBs) via the fluorescent glow of irradiated nocturnal atmosphere. An analysis of the Fermi GBM catalog of GRBs and properties of several active and perspective instruments reveals that a detector with parameters of the optical system similar to those of the KLYPVE-EUSO (K-EUSO) or POEMMA telescopes and an appropriate \slow-mode" trigger will be able to observe only two GRBs in average every year of operation. POEMMA will register up to 3-4 GRBs in a year of operation in the stereo mode.
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