The Office of Emergency Management (OEM) takes exception to the narrow definition of training in the Federal Register Notice. It is nationally recognized that "training" in any capacity is not complete unless it has been validated by exercise. To exclude exercise from a "training program" is to leave the training incomplete. Historically, both the Federal Emergency Management Agency (FEMA), the Environmental Protection Agency (EPA), and the Department of Energy (DOE) have used "exercise" as a validation tool within their training programs. A good example is DOE's Radiological Emergency Response Operations Course (RERO). This course is not complete until all participants have taken part in a full-scale exercise, testing the information covered in the class. lt is inappropriate for DOE to exclude this vital tool from the States within the Section 180(c) training grant.
Exercise is also a valuable tool in determining training needs. All three federal agencies previously mentioned use this method to assess internal and external training needs. DOE's proposal to limit the grant to "training" only, excluding exercise, is not in line with nationally accepted training assessment practices.
The proposal limits the recipients from building new programs and states that it is only to be used for augmenting existing training programs. (1) What if no program(s) exist? (2) If a jurisdiction is starting from scratch in this area, are they then excluded from participating? (3) How does this exclusion assist public safety? In many jurisdictions, a new program would be necessary. It is our conclusion that this exclusion should be removed.
The formula for determining a state's award does not allow for the current response readiness level of each jurisdiction. Some states will need more help in getting started. The current proposal does not address this need. Rural areas, regardless of "miles traveled" will not be starting at par with more metropolitan areas. The formula should be changed to account for this difference.
The proposal limits equipment purchases to "training related" equipment only. This exclusion lets the states purchase and use modern equipment to train first responders but forces these responders to use antiquated equipment or at worse, no equipment at all for real emergencies. (1) How does DOE justify training state and local responders for this type of emergency and not providing them the " Response Tools" required for the job? (2) Why is it assumed that a jurisdiction would have access to these types of tools/equipment before the high-level waste shipments start? We suggest that the restriction on equipment purchases be removed from the grant.
The proposal does not address the needs of volunteer responders in rural jurisdictions. It is imperative that these special needs be addressed in the scope of the grant. More freedom is needed in the grant to allow states to address these special needs. The site of transfer station(s) and the interim storage site state will have special needs both in training and equipment that are not addressed in the proposal. In the proposal, all states are treated the same regardless of differing needs. The scope of the grant should be changed to allow for these differences.
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State of Nevada
Nuclear Waste Project Office
Carson City, NV 89710