We also have a general concern that the proposal to conform to international standards does not take into account the special nature of transportation in the United States. Whereas Germany is about the size of Oregon, transportation distance within and between the countries of Europe is much less than the estimated 2,400 mile trip to Nevada from eastern power plant locations. We did not see discussion of the issues of distance or the possible differences between the United States and Europe that could make adoption of these standards or portions of them unwise for the United States. One of our primary concerns and perspectives is the possibility of being first responders to a radiological emergency in a rural area. In our county, first responders are volunteers.
Training is limited.
These rules should consider the lowest level of training for emergency response, and that the rules should be developed to protect emergency responders and other personnel who could be expected to be around these types of shipments. While it is commendable that the NRC held more than one meeting about these proposed changes, it is unfortunate that the final meeting, in Oakland, CA was held just four days before the end of the comment period. The tightness of that timing is a challenge for those who attended and wish to put comments in writing based on the information at the meeting. Changing Part 71 to SI units only Keep the dual labeling. Emergency responders need clear information from the start, and labeling requirements for the United States should be consistent with measurements and terminology familiar to residents of this country.