Name: James C. Hardeman Jr.

Organization: Georgia Environmental Protection Division

Subject: 180c Review Comment

Response to questions in July 23, 2007 FR Notice.

Question 1.

a. $200K may be adequate for states with a single transportation route. OCRWM should consider additional funding for states with multiple routes.

b. No.

c. Needs assessment should be updated every 3-5 years at a minimum. ~50% of original funding should be adequate.

Question 2.

a. $100K may be adequate for the base amount of a training grant.

b. Base funding is required to maintain training staff and operate the training program, and should remain relatively constant throughout the life of the shipment campaign.

c. Available funding should be allocated in accordance with the formula detailed in the FR notice.

d. No. See 2.b. above.

Question 3.

a. No.

b. Yes, unless the jurisdiction requesting mutual aid agrees to provide training at its expense.

c. 25% - 50% of base amount, unless the jurisdiction requesting mutual aid agrees to provide training at its expense.

d. Yes, unless the jurisdiction requesting mutual aid agrees to provide training at its expense.

Question 4.

a. 5 years prior would be preferable.

b. Yes

c. Yes -- in fact, if shipments are planned along a route / through a state within the next 3 years, a training grant should be provided.

Question 5.

a. No. Fees are levied for security and escort, not emergency response planning and training.

b. DOE should make no such determination.

c. Yes

Questrion 6.

a. 180(c) funding should not be adjusted. Other funding (if available) is campaign-specific.

b. TEPP provides no direct funding. TEPP activities are supplementary to state training activities.

c. There may be some slight synergy in training activities, but full, unadjusted 180(c) funding will be required regardless of other DOE shipment activities in a particular state.

Thank you for the opportunity to comment.

James C. Hardeman, Jr.