Notes from the RMLLWB Meeting

Several items were discussed at the June 11, 2013 Rocky Mountain Low-Level Waste Board (RMLLWB) Regular Meeting, such as issues the Regional disposal facility is encountering during the application and permitting process of the importation of oil and gas NORM into the compact. The Regional disposal facility reported that a significant quantity of filter socks are being disposed of, especially from the Bakken fields from North Dakota. Various landfills located in moderate proximity to the Bakken fields are rejecting loads of filter socks even under 5 pCi/g with concerns of legal recourse. The Regional disposal facility located in Colorado also reported that a significant amount of NORM/TENORM from the oil and gas industry is being imported in from Texas and New Mexico.

In order for the Regional disposal facility to accept waste from outside of Colorado, New Mexico and Nevada, the waste must be permitted through the RMLLWB. In an effort to be more competitive with surrounding disposal facilities located outside of the compact, the issue of the advance payment for the application fee was addressed. The RMLLWB import permit application process has several approvals, and seems to be delaying how soon the generators can dispose of their NORM/TENORM waste at the facility. Most oil and gas companies have internal check request procedures that steer the company representatives away from sending material to the Regional disposal facility. During the meeting, NORM SOLUTIONS suggested the Board accept credit card payments for the application fees, as most company representatives are issued credit cards. The Board stated that they will entertain the credit card acceptance suggestion by evaluating the administrative impact to the compact as well as additional costs for the credit card fees.

Another alternative to the advance payment of the application fees issue could be for the Regional disposal facility to pay the fees for the generators to speed the application process, and then include the cost on the invoice for the disposal of the material. However, this option includes an additional risk to the Regional disposal facility for non-payment for the application fee, and any other administrative costs for filing and submitting applications.
In addition, after each import permit is approved by the Board, it is reviewed by the Colorado Department of Public Health and Environment. Due to limited funds and personnel, the entire approval process for the importation of NORM/TENORM takes more time than the exportation of NORM/TENORM. The executive director of the Board also suggested that an application form be created and implemented to further streamline the approval process. The Board also suggested that the Regional disposal facility draft a letter outlining these key issues and presenting it to the Board, with possibly meeting with the Board to discuss.