RE: FGR-13 -Reply

[MICHAEL S FORD <MFORD@pantex.com>]

>>>"Joe Alvarez" wrote on Wed 13 May 98  7:57 >>>
... Indeed, EPA maintains that radiation is a privileged pollutant
because dose rather than risk is the standard for regulation. 
FGR-13 being risk-based will remove the previledge....
>>>>>>>>>>>>>>>>>>>>>>>>>>

Let's see.... that wouldn't have anything to do with the fact that there
are known, demonstrable effects from chemicals exposures at the
levels the risk factors are based upon, whereas such is not the case
for the limits at which occupational radiation exposures are set. 
Would it?

EPA has yet to demonstrate that there is any risk associated with
"per Bq" exposures of (enhanced) radioactive materials.  They claim
the pedigrees of the ICRP and NCRP, but ignore UNSCEAR and
even the qualifications of the ICRP/NCRP data where the possible
"no effect" is discussed in the context of LNT.  This is selective
science, not "sound science," as FGR-13 claims.

If they really want to even the playing field, let's talk about
Threshold Limit Values for chemicals AND rad. materials.

In my humble opinion,
v/r
Michael
*************************
Michael S. Ford, CHP
Texas Radiation Advisory Board
Address:
Radiation Safety Department
Battelle Pantex
Amarillo, TX
806.477.5727 phone
806.477.4198 fax
mford@pantex.com
*************************