shipments.” Without financial assistance or some other source of revenue, the states would not be able to devote significant resources to developing state and local capabilities specifically for shipments of radioactive waste and material, including shipments of HRCQ material. WIPP funding, for example, helps to defray the costs to state taxpayers of public safety actions in connection with shipments (e.g., safety inspections, security and health physics escorts, emergency responder training, and public information). Private shippers do not provide this type of funding to states in connection with shipments of HRCQ material, even though these materials pose a greater hazard to the public than transuranic waste shipments. As a result, some states have enacted fee systems designed to help offset their costs (see Appendix D). Federal hazardous materials transportation law permits states to charge reasonable fees on shipments as long as the revenue is used for purposes related to hazardous materials shipments. The activities the states undertake in connection with HRCQ shipments are similar to those necessary in connection with shipments of spent nuclear fuel. State shipment fees make it possible for state agencies to undertake these important public safety measures. Section 180(c): Section 180(c) of the Nuclear Waste Policy Act of 1982, as amended (NWPA), requires DOE to provide similar assistance to help states prepare for shipments of spent nuclear fuel and high-level radioactive waste to a federally owned repository or monitored retrievable storage facility. Assistance is not required to be provided to states in preparation for shipments to privately owned interim storage facilities. The Midwestern states maintain that funding and technical assistance under Section 180(c) should be available to the states at least four years prior to shipments. Section 180(c) funding should be predictable and should allow states the maximum flexibility to implement training programs that best meet their needs.
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