Comment submitted by T. Naquin

-Is the presentation and format of the document useful and appropriate for its intended purpose? The presentation is useful because what is at stake needs to be elevated to response organizations conciousness. If an explosion occurs, it will likely be treated as a conventional explosion unless 'someone' announces that an RDD/IND will be or has been detonated. Current OSHA guidance for emergency responders raises no point of differentiation early on to confirm whether radioactive or nuclear material may be involved in an explosion, though responders have received training in regards to what are RDD/INDs. -Are the proposed PAGS for the early and intermediate phases implementable? If an explosion occurs, it will likely be treated as a conventional explosion unless 'someone' announces that an RDD/IND will be or has been detonated. As stated in the FR, there would be many lifesaving and first-aid actions occurring and that discovery or detection may not occur for days or weeks. I think this renders the early phase PAGS not practically implementable. While it is 'nice to be able to do' guidance, the information needed by decision makers for first responders or the general public would not be available until the early phase has passed. Interrmediate PAGS appear very implementable.