RE: FGR-13

["Joe Alvarez" <jalvarez@auxier.com>]

EPA has already published cancer risk factors for chemical carcinogens as 
the HEAST (Health Effects Assessment Summary Tables) tables where 
radionuclides are also found.  EPA believes that FGR-13 will level the 
playing field, i.e., take away the advantage that radiation has.  Indeed, 
EPA maintains that radiation is a previleged pollutant because dose rather 
than risk is the standard for regulation.  FGR-13 being risk-based will 
remove the previledge.

Joe Alvarez
Auxier & Assoc.
jalvarez@auxier.com

-----Original Message-----
From:	Jesse H. Coleman [SMTP:radshoals@airnet.net]
Sent:	Wednesday, May 13, 1998 9:38 AM
To:	Multiple recipients of list
Subject:	FGR-13

RADSAFERS,

Without setting off another fiery LN-T discussion, I would
like to ask the following question.

In his Reply to Comments Regarding FGR-13, page 7 of the May '98
HP Newsletter, C. B. Nelson (EPA Environmental Engineer) states:

"Use of the linear no-threshold (LN-T) concept ... is
well-established policy.  EPA has, for over two decades, based
its regulations of most carcinogens on this assumption."

Question:  Has EPA published a list of cancer risk factors for
chemical carcinogens or is ionizing radiation the only carcinogen
to receive this treatment?

I would like to see such a list.  Then we could calculate the
cancer mortality risk from, for example, those nasty carcinogens
in a hamburger.  We could then even the playing field by
comparing a hamburger stand with a nuclear reactor.

If EPA has not given the public a cancer mortality risk factor
for some chemical like di-methyl-nasty, then maybe EPA should
delay FGR-13 untill such a list is completed.

Jesse Coleman

RADSHOALS@AIRNET.NET