EPA 520/1-89-003
  USER'S  GUIDE FOR THE COMPLY CODE

             (Revision 2)
U.S. ENVIRONMENTAL PROTECTION AGENCY
 Office of Radiation and Indoor Air
         401 M Street,  S.W.
        Washington,  DC 20460
            October 1989
                                              Printed on Recycled Paper

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                     TABLE OF CONTENTS
   Section

 1.0  INTRODUCTION

 2.0  HOW TO SET UP YOUR SYSTEM
     2.1  Making a Working Copy
     2.2  Running the COMPLY Program
     2.3  Choosing Where to Start
     2.4  Warning Messages
     2.5  Output

 3.0  DETAILED INPUT GUIDANCE
     3.1  Overview
     3.2  Format for Entering Numerical Values
     3.3  Beginning Message
     3.4  Output to Printer or File
     3.5  Title
     3.6  Title Page
     3.7  Level
     3.8  Number of Release Points
     3.9  Nuclide Names
     3.10 Concentration and Possession Tables
     3.11 Release Rates
     3.12 Release Height
     3.13 Building Height
     3.14 Same Building
     3.15 Stack Diameter
     3.16 Volumetric Flow Rate
     3.17 Distance from Source to Receptor
     3.18 Building Width
     3.19 Building Length
     3.20 Stack and Air Temperatures
     3.21 Wind Speed
     3.22 Distances to Sources of Vegetables,
          Milk, and Meat
     3.23 Wind Rose
     3.24 Multiple Release Points

4.0  OUTPUT

REFERENCES
Page

1-1

2-1
2-1
2-2
2-3
2-3
2-3

3-1
3-3
3-4
3-4
3-4
3-5
3-5
3-5
3-5
3-7
3-9
3-11
3-11
3-12
3-12
3-14
3-14
3-15
3-15
3-15
3-17
3-17

3-19
3-20
3-25

4-1

5-1
                            iii

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               TABLE OF CONTENTS (continued)
   Section
Appendix A
Appendix B
Appendix C
Appendix D
     How to Handle Errors
     Sample Problems
     Obtaining and Organizing Wind Rose Data
     Suitability of Wind Rose Data from
     an Offsite Location
Appendix E - List of Nuclides
Appendix F
Appendix G
Appendix H
Appendix I
     Determination of Distances Between  ,
     Release Point and Receptor When Both
     Are on the Same Building
     Meteorological Model
     Dose Calculations
     Resolving Problems and Contacting
     the EPA
Page
A-l
B-l
C-l
D-l

E-l
F-l

G-l
H-l
1-1
No.
3-1
3-2

3-3
C-l
F-l

1-1
                      LIST OF FIGURES
Stack and Building Heights
Distance Between Source and Nearest
Receptor or Farm
Building Width and Length
Sample Graphical Wind Rose
Measuring Distances on Building
Surfaces
EPA Regional Offices
Page
3-13

3-16
3-18
C-6
F-2

1-2
                             iv

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                TABLE  OF CONTENTS  (continued)
No.

2-1



3-1

C-l



C-2

C-3

C-4

C-5

C-6



C-7

H-l

1-1
               LIST OF TABLES



Input Parameters Required for
Various Methods

Abbreviated Sample Wind Rose

Sample Wind Direction Versus Wind
Speed Tabulation

Sample STAR Data

Sample STAR Data

Tabular Form of Graphic Wind Rose

Average Wind Speeds for Each Glass

Wind Rose Data Suitable for Use in
the COMPLY Code

Form for Wind Rose Data

Parameters Used in NCRP and COMPLY

EPA Regional Program Managers
 Page

 2-4



 3-25

 C-7



 C-8

 C-9

 C-10

 C-10

 C-ll



 C-12

H-4

1-3

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                     1.0 INTRODUCTION

 The COMPLY computer program may be used to demonstrate
 compliance with the National Emission Standards for
 Hazardous Air Pollutants (NESHAPS)  in 40 CFR 61,  Subpart
 I.   It has various levels of complexity,  the simplest
 being a computerized version of the tables of
 concentration and possession limits in EPA89.   The  most
 complicated is an air dispersion calculation using  a
 wind rose.

 At  all levels,  the program will determine whether you
 are in compliance with the standards,  or  whether  you
 exceed the standards.

 The program is  designed to be easy  to  run and requires
 only minimum input.  As it proceeds, it asks for  the
 information it  needs,  and  if at any point the program
 determines  that you meet the exemption limits,  it will
 stop and tell you.  If  you do not meet the exemption
 limits at one level, COMPLY will allow you to go to the
next higher  (more complicated)  level.  At the end, the
program will create a report containing all the input
values and the  results of  its calculations.  This
report, along with the supporting documentation
described in EPA89, is all that you need to send to the
EPA if you are required to report.
                          1-1

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                2.0  HOW TO SET UP YOUR SYSTEM

 COMPLY requires an IBM PC or PC-compatible computer
 having at least 512 kilobytes of memory,  either two
 floppy disk drives or one floppy disk and a hard disk,
 and a printer.   The operating system must be DOS.

 The following instructions are written for the novice PC
 user.   We ask the expert user to be  patient with some of
 the long explanations.

 2.1  MAKING A WORKING COPY

 In  the following explanation,  we assume that the hard
 disk (if one exists on your system)  is named "C:",  the
 first floppy disk drive is named "A:",  and the second
 floppy disk drive (if one exists)  is named "B:".  This
 configuration is fairly standard.  If your system is  not
 set up this way,  you will have to adapt these
 instructions accordingly.

 The program and  data files are on two 360  kilobyte
 diskettes;  one marked COMPLY-EXE  and the other
 COMPLY-DATA.

 If  you have a hard disk, put the  COMPLY-EXE diskette  in
 drive  A, type A:INSTALL, and press Enter.  Once the
 first  diskette has been copied, you will be asked to put
 the  COMPLY-DATA diskette in.  This will result in the
program and  all the data being copied onto the hard
disk.  It will create a directory called C:  COMPLY and
a batch file, which will start the program when you give
 it the command COMPLY.  (You do not have to know
anything about directories or batch files to run
COMPLY.)
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If you have two floppy disk drives but do not have a
hard disk, put the COMPLY-EXE diskette in drive A: and a
blank diskette in drive B:.  Use the DOS DISKCOPY
command to copy all the information on the original
diskette to the blank diskette:                  •

      DISKCOPY A: B:

When the first diskette has been copied, remove both it
and the copy.  Put the COMPLY-DATA diskette in drive A:
and another blank diskette in drive B:.  Then use the
DISKCOPY command to copy the information to the blank
diskette.

2.2  RUNNING THE COMPLY PROGRAM

If you are using a hard disk, start the program by
typing COMPLY.  If you are not using the hard disk,
place your copy of the COMPLY-EXE diskette in drive A:
and your copy of the COMPLY-DATA diskette in drive B:.
If the default drive is B:, simply type COMPLY and press
enter to start; otherwise, type B:COMPLY and press
enter.

After a short delay (while the program is transferred
from the disk into memory), a message will appear on the
screen telling you how to proceed.

A detailed description of each input parameter is given
in Section 3.  Table 2-1 is a list of these parameters,
with a brief indication of when each is needed.  Not
shown in Table 2-1 are responses that require you to
choose between two options; for example, whether you
want the input values of your release rates to be in
curies per year  (Ci/yr) or curies per second (Ci/s).
                           2-2

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2.3  CHOOSING WHERE TO START

To decide where you want to start, see Section 3.1,
Overview, and EPA89.  If you believe that you will be
exempt at level 1 using the possession or concentration
tables, start at level 1; otherwise, go directly to
level 2.  If you decide to begin at level 2, before you
start, gather as much of the information listed in Table
2-1 as you think you will need.  Then just follow the
instructions on the screen.  If you are not particularly
familiar with computers, practice running the sample
problem in Appendix B first.

2.4  WARNING MESSAGES

Each input parameter (except for the release rates,
concentrations, and annual possession amounts) has a
"normal range."  If you enter a value outside this
range, the program will ask you if you want to change
the value.  If you enter N for no, it will proceed; if
you enter Y for yes, it will allow you to go back and
change the value of that parameter.  This feature is
intended to minimize typing errors.

2.5  OUTPUT

The first page of the output is a cover sheet containing
the facility name and other identifying information.
Succeeding pages reproduce the information you gave the
program and the,results of its calculations.  At
level 1, you are told whether or not you are in
compliance.  At levels 2, 3, and 4, the doses are
printed, along with a statement as to whether or not you
are in compliance with the standard.
                           2-3

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Table 2-1. Input Parameters
Methods
Parameter
Nuclide names
Concentrations
Annual possession amounts
Release rates
Release height
Building height
Stack or vent diameter*
Volumetric flow rate (m3/s)A
Distance from source to
receptor
Building width8
Wind speedc
Distances to sources of
food production (farms)D
Stack temperature (°F)E
Ambient air temperature (°F)E
Wind roseF
Building length0
Required for
Needed at
Levels
1-4
1
1
1-4
2-4
2-4
2-4
2-4
2-4
2-4
2-4
3-4
4
4
4
4
Various
Default
Value
None
None
None
None
None
None
None
0.3
None
None
2
None
55
55
None
None
Notes:
A.   Needed at levels 2 and 3 only if source and
     receptor are on the same building.  Needed at level
     4 if source and receptor are on the same building
     or if stack height is more than 2.5 times the
     building height.
B.   Needed only if stack height is less than or equal
     to 2.5 times the building height.
C.   At level 4, needed if user has not specified a wind
     rose.
D.   At level 3, there are two farms—one for vegetables
     and one for milk and meat.  At level 4, there are
     three farms—one each for vegetables, milk, and
     meat.
E.   Needed only if stack height is greater than 2.5
     times the building height.
F.   Needed only if user has specified he wants it.
G.   Needed only if stack height is less than or equal
     to 2.5 times the building height and the user has
     specified a wind rose.

                           2-4

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               3.0  DETAILED INPUT GUIDANCE
 3.1  OVERVIEW
 The following instructions may seem complicated at
 first;  this is because we have tried to cover every
 contingency.   It may be wise to start running the
 program using the sample problem (Appendix B)  as a guide
 and read the  explanation as you proceed.   This will make
 the explanation more concrete,  not  just an abstract set
 of  instructions.

 The program will ask you for input  as it is needed.   It
 will begin  by asking whether you want the output to go
 to  a file or  to the  printer.   It will then ask for
 information regarding your company  and facility.   Next
 it  will  ask if you wish to use  the  possession  or
 concentration limit  tables.   If you are in compliance at
 this level, you may  go to  a higher  level  to determine
 whether  you are exempt.  If you exceed the exemption
 limits,  it  will ask  if you wish to  go to  the next level.

 The program has three levels  of complexity beyond the
 possession  or concentration limit tables.   Level  2  is
 the lowest, requiring a minimum of  input,  and  level  4 is
 the highest,  requiring the  most input.   (Levels  2  and 3
 correspond  to the  NCRP Screening levels 2  and  3.  NCRP
 Screening Level  1  is  not used.   See NCRP89.)  While  the
higher levels  require  more  input, they have less
conservatism  built into the dose estimate.  Thus, even
 if  the dose estimate  at level 2 exceeds the limit, you
may  be able to. demonstrate  compliance at level 3.
                           3-1

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You may start at any level; however, we recommend you
begin at the lowest level, because the lower the level
at which you meet the standard, the fewer input numbers
you have to supply and justify.  Moreover, all the input
you supply at the lower levels (except at the possession
or concentration limit level) will be saved for use at
the higher levels, so that you do not have to enter the
values more than once.

Under certain unusual circumstances, the dose calculated
at level 3 may be slightly higher than that calculated
at level 2.  For example, this can occur if all the
receptor's food is grown at home and the dose from one
or more of the radionuclides is dominated by the food
pathways.  This is an artifact of the NCRP method, which
was deliberately kept very simple so that it could be
done by hand.

At level 4, you are given the choice of whether to put
in a wind rose.  If you choose not to, the results at
level 4 will quite possibly be about the same as those
at level 3.

If the calculated dose at any level is less than the
compliance limit, you may proceed to the next level to
see whether you are exempt.  If you are in compliance,
but not exempt, you must report your results to the EPA.
If you cannot demonstrate compliance after having tried
all levels, contact your regional EPA office  (see
Appendix I).

A few of the input parameters have default values.
However, if you have site-specific values for these
parameters, we strongly recommend that you use them,
                           3-2

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because the default values are generally quite
conservative and will therefore result in higher dose
estimates.

Each of the input parameters is described below.  They
are presented in the order in which the program most
commonly asks for them.  Once a value has been requested
and supplied, the program will not ask for it again when
you move to higher levels.

If you decide to stop while you are running the program,
simply hold down the Ctrl key and press the Break key
(on IBM keyboards, this is also the Scroll Lock key),
and the program will stop.  The Ctrl and C keys will
also stop the program.  If you do stop, you lose all of
the data entered up to that point and must start over
from the beginning.

3.2  FORMAT FOR ENTERING NUMERICAL VALUES

The program allows you to enter numerical values in
different ways.  For example, to enter 1400, you may
type either 1400, 1400., 1.4e3, 1.4E3, 1.4e+3, 1.4E+3,
or 1.4+3.  To enter 0.012, you may type 0.012, .012,
1.2e-2, 1.2E-2, or 1.2-2.

     NOTE:  The lower case L is not a numeral 1 as it is
     on typewriter keyboards.  You must use the "1" key.

The following formats are NOT correct: 1,400, 1.4x10+3,
012, and 1.2x10-2.  If you type 1,400, the program will
not recognize this as 1400, but it will not give you an
error message.  It will ignore everything after the
comma and treat the value as 1.  The program will read
                           3-3

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012 as 12, not .012.  The other two incorrect forms will
result in an error message.

     NOTE:  If you recognize an error before you press
     the Enter key, you may correct it using the
     backspace key (the left-pointing arrow key on the
     upper right of the keyboard).

After you type in the value, you must press the Enter
key.  Only then will the machine recognize that you have
given it the value it has asked for.  If the program is
looking for a numerical value and you press Enter
without giving it one, it will not proceed but will
simply wait for you to give it the value.  It will not
ask you for it again; it will simply stare back at you.

3.3  BEGINNING MESSAGE

The first thing that will show on your screen is an
introductory message with a brief description of the
code.  To continue, simply press the Enter key.

3.4  OUTPUT TO PRINTER OR FILE

The program first asks you whether you wish to have your
output sent directly to the printer or stored in a file
on a disk.  If you choose the printer, the output will
be printed as you go along.  You must have your printer
turned on, or the program will not run.  If you choose
to have your output sent to a file, the program will ask
you for a file name.  If you want the output file to be
stored on a disk other than the default disk, you must
supply the name of the disk drive along with the file
name (e.g., B:REPORT.DAT) to store it on drive B.
                           3-4

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 Before printing the results,  align the paper in the
 printer so  that the output will  not overlap from page to
 page;  align the top of  the sheet with the  print head.
 Turn the printer off momentarily and then  back on.
 (Some  printers  will advance the  paper to the position it
 was in when the printer was first  turned on.)

 3.5  TITLE

 The program asks you to type  in  a  title for your
 problem.  You may type  in  anything you like,  up to  78
 characters  and  numbers.

 3.6  TITLE  PAGE

 You will be asked to supply your company name,  the  name
 of your facility, its address, and the name  and
 telephone number of a contact person.

 3.7  LEVEL

 The program will ask you if you wish to use  either the
 concentration or possession table.   If you choose not to
 use the concentration or possession limit option, or if
 you exceed  the  limits in these tables  and choose to go
 to a higher level,  the program will ask you which level
 (2-4)  you desire.   We suggest you start at level 2,  the
 simplest level,  but you may start at any level you
desire.

 3.8  NUMBER OF RELEASE POINTS

The program will ask if you have more than one release
point.   If the response is Y for yes, it will then ask
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how many release points (stacks or vents')  there  are.
If you have more than one, you may be able to run them
all  in one problem, or you may have to make several
runs.  (See the discussion in Section 3.24, Multiple
Release Points.)  If you do not have any stacks or vents
(the emissions are through windows and doors), type
in a 1.

Each release point in a problem is treated individually;
that is, you must supply the release rates, release
height, building height, etc., for each point.  It is
very important to keep track of which parameters go with
each release point.  We strongly suggest that you fill
out Worksheet D in the guidance document (EPA89).

If you have many release points and would like to reduce
bookkeeping requirements, you may assume that all the
radionuclides from your facility are released from the
stack or vent having the potential for causing the
highest dose.  Similarly, you may assume that all the
release points from a building can be replaced by a
single stack or vent having the potential for causing
the highest dose.  In either case, the stack or vent
having the potential for causing the highest dose must
be determined by running COMPLY with a unit release of
any one of your radionuclides from a selection of stacks
or vents.  The selection should be based on factors such
as distance to the receptor, building configuration and
meteorological data if a wind rose is used.  If you
consolidate releases, you must make the stack or vent
height no greater than the building height.
                           3-6
     'The code does  not distinguish between  stacks and
vents.  We include both terms here simply to make  it clear
that both are covered.

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 Alternative procedures for consolidating releases may be
 used if you have approval from the EPA.

 3.9 NUCLIDE NAMES

 The program will ask you for the name of each
 radionuclide emitted from your facility.   If you are
 going to use the concentration table and the same
 nuclide is released from more than one stack or vent,
 put in its name only once.

 The program will ask if you want to put  the  list of
 radionuclides from the keyboard (K)  or from  the
 file (F).   If this is the first time you are running the
 code,  type "K" for keyboard.   The program will  then  ask
 you if you want to save your entries in  a file.   If  you
 answer yes,  it will ask you for a file name.  It
 requires  a different file name for each  release point;
 thus you  must be prepared to supply as many  file names
 as  release points.   For example,  if you have three
 release points,  you may choose NUCS1.DAT,  NUCS2.DAT  and
 NUCS3.DAT.   If you want to  save the files on a  drive
 other  than the default drive;  the file names must
 include the drive on which  they are to be saved (i.e.,
 A:NUCS1,  etc.  to save them  on  drive A).

 Note that  you cannot create or modify  them using  an
 editor or  a word processor.  Their  creation must  be  from
 the  keyboard,  and any modifications must  be carried  out
 using  COMPLY.  You  can  change  the file name using DOS.
 We suggest that  you use the file option as it will save
 you  from having  to  re-enter the nuclide names each time
 you  run the program.  The program allows you to add or
 remove entries if you wish.  If you add or remove
 entries, however, you cannot save the modified file
under  its old name; you must give it a new name.
                           3-7

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If you are going to use the possession table and a
nuclide exists in more than one physical form (gas,
liquid, or solid), you should enter its name as many
times as it has physical forms.  (See EPA 88.)

The names must be of the form CS-137 for cesium-137,
CO-60 for cobalt-60, and so on.  They may be in upper-
or lower-case letters or a mixture of the two.  The dash
(-) is a necessary part of the name.  If the nuclide has
an M following the atomic weight, it must be included as
well (e.g., AG-110M).  If a nuclide is not included in
the data tables supplied with the program, the program
will tell you.  If you make a mistake typing the name
(e.g., CA-137 for CS-137), the program will respond "I
can't find that nuclide."  So you should check your
typing before assuming that you have a nuclide that is
not on the list in Appendix E.  If you really do have a
nuclide that is not on the list, contact your EPA
regional office.  (See Appendix I.)

If daughters are released along with their parent, they,
as well as the parent, must be included on your release
list.  That is, if you are releasing SR-90, you may be
releasing its Y-90 daughter.  The program automatically
handles the ingrowth of daughters after release of the
parent.

The program will display the "inhalation class" along
with the nuclide names.  This is the default lung
clearance class used by the program.  You may change
this; however, if you do you MUST COMPLETELY JUSTIFY
your choice in the documentation included with your
report.  Changes to the lung clearance class should only
                           3-8

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 be made if you have data supporting the decision.   If
 you have changed the clearance class,  the fact that you
 have will be highlighted in the output.

 After you have typed in all the nuclide names,  enter a
 blank line (just press the enter key)  or type END  to
 indicate that you are finished.   The program will  then
 display your input and ask if  it is correct.   If it is,
 the program will proceed.   If  there is an error, the
 program will allow you to  make changes.

 Note that if you make changes,  you  must rename  the
 nuclide file (unless that  is its initial creation).

 3.10 CONCENTRATION AND POSSESSION TABLES

 If  you choose the concentration  limits,  the program will
 ask if anyone lives within three stack diameters.   If
 you answer yes,  you cannot use the  concentration table.
 If  you answer no,  the program will  ask for the
 concentration of each nuclide.   This is  the average
 annual concentration in the stack.  If a given nuclide
 is  released from more than one stack or vent, proceed as
 follows:   Determine which  stack  has the maximum
 concentration of a  given nuclide and for that stack
 enter  the  actual  concentration.   For the other stacks in
which  that  nuclide  has a lower concentration, enter a
 zero for the  concentration  of that nuclide.  For
example, if stack one has a Kr-85 concentration of
1.0 Ci/cubic meter  and stack 2 has a concentration of
1.5 Ci/cubic meter,  enter 0 for  stack  1 and 1.5 for
stack  2.  Once you have entered the concentrations and
confirmed that they  are correct, COMPLY will then
determine if you meet the compliance limits given in
EPA89.
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The possession table option is similar to the
concentration option except that there are more
questions.  These deal with whether an individual lives
closer than 10 meters from the release point and whether
food is produced within 100 meters of the release point.
If the answer to either of these questions is yes, you
are not allowed to use the possession limit table, and
the program will ask if you want to go to a higher
level.  It will ask for the possession quantities by
stack.  You do not have to identify the quantities by
stack unless you want to.  You may associate all the
quantities with one stack if you wish, putting in all
zeros for the other stacks.

COMPLY will then ask for the annual possession quantity
of each radionuclide you identified earlier and the
physical form of each radionuclide (gas, liquid or
powder, or solid).  (See EPA89.)  You will also be asked
if each radionuclide is exposed to a temperature greater
than 100 °C (212  °F), or boils at a temperature less than
100 °C  (212 °F).  If so, the form of the nuclide will be
changed to a gas, no matter what form you have entered.
As with the concentration limits, you will be given an
opportunity to correct any wrong entries.

Refer to Worksheet F of EPA89 to determine if you are
exempt from reporting, in compliance, or not in
compliance.  If you are in compliance but not exempt,
you may wish to go to a higher level.  This gives you
the chance to determine if you meet the exemption limit
using levels 2-4.
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 3.11 RELEASE  RATES

 If you use  levels 2-4,  the program  asks you whether  you
 want to put in release  rates  in Curies/year or
 Curies/second.  After you have told it which you want
 (Y for years, S for seconds), it will ask you for the
 release rates from each release point one at a time, by
 nuclide.   (See the worksheets in EPA89 for instructions
 on how to estimate release rates.)   When the release
 rates have  been specified for each  stack or vent, the
 program will  show on the screen what you have put in and
 ask you if  the values are satisfactory.  If you don't
 like what you see, enter an N and the program will
 instruct you  on how to  fix the incorrect values.  If you
 enter a Y,  it will proceed to the next step.

 3.12 RELEASE  HEIGHT

 If you have multiple release points, and have not
 completed Worksheet D of EPA89, we  suggest you do so.
 It is a useful way to keep track of  all your stack
 parameters  if you have more than one stack or vent.  The
 release height is the elevation view distance (in
 meters) from the ground to the point of release (the top
 of the stack or vent, regardless of whether the stack is
 on a building or is a separate structure).  (See
 Figure 3-1.)  If the release is from a vent on the side
 of the building, the release point  is the elevation view
 distance from the ground to the center of the vent.  If
 there is more than one stack or vent, see the discussion
 on multiple release points in Section 3.24.   If the
release is not from a stack or vent, enter zero for the
release height.
                          3-11

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     NOTE:  The program checks for "unusual" values for
     the release height and many of the other
     parameters.  If you enter a value that is outside
     the "usual" range (smaller or larger), it will ask
     you if you want to change it.  If the value is
     indeed correct, simply answer N for no and the
     problem will proceed using the value you put in.
     If it is incorrect, the program will let you change
     the value.

3.13 BUILDING HEIGHT

This is the height  (in meters) of the building from the
ground to the roof.  Do not include the stack or vent
height in the building height even if the stack or vent
is on the building.  (See Figure 3-1.)  The stack or
vent height may be  less than the building height (e.g.,
a vent from the side of a building).  If you enter a
release height that is less than the building height,
the computer program will ask you to verify that this is
what you want, because It is fairly unusual and the
program wants to confirm that you have put in the
correct numbers.  If the numbers are correct, enter Y
and continue.  If you have inadvertently entered a wrong
number, enter N and the program will ask you again for
both the release height and building height.

3.14 SAME BUILDING
If the release height is less than 2.5 times the
building height, you will be asked if the source and
receptor are on the same building.  If they are, enter
Y; if not, enter N.  While it is unlikely that the
source and receptor would be on the same building, it is
possible, for example, to have a small laboratory in an
apartment building.
                          3-12

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GROUND LEVEL v
                    0--T
                        H
                                              H
                 h, - BUILDING HEIGHT

                 H -STACKHEIGHT
     Figure 3-1.   Stack and building heights
                      3-13

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3.15 STACK DIAMETER

You may or may not be asked for the inside diameter  (in
meters) of the stack or vent.  At levels 2 and 3, this
number is needed only if the source and receptor are on
the same building.  At level 4, it is needed if the
source and receptor are on the same building or if the
stack is greater than 2.5 times the building height, in
which case it is used to estimate plume rise.  If the
stack or vent is other than circular, determine its
equivalent circular diameter from D = (1.3A)?/2, where A
is the flow area of the stack.

3.16 VOLUMETRIC FLOW RATE

You may be asked for the volumetric flow rate from the
stack or vent [cubic meters per second (m3/s) ].   The
logic of when you are asked for this is the same as for
the stack diameter.  There is a default value of
0.3 m3/s.   If you do not know the  volumetric flow rate,
you may use this default value.  To convert from cubic
feet per minute  (ft3/min)  to m3/s, multiply ft3/min by
4.7X10"4.

This is the volumetric flow rate out of the stack.  If
the temperature of the air flowing through the stack is
significantly different from that of the air flowing
through the fan, the Volumetric flow rate up the stack
will be different from that through the fan.  With a
100 °F  temperature difference,  the difference could be
on the order of 20 percent.  If there is more than one
stack or vent, see Section 3.24.
                          3-14

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 3.17  DISTANCE FROM SOURCE TO RECEPTOR

 If  the source and receptor are not on the same building,
 this  is the straight-line distance (in meters)  from the
 source to the nearest receptor measured along the
 ground.   (See Figure 3-2.)   If the source and receptor
 are on the same building,  it is the shortest distance
 between the source and receptor measured along the
 building surfaces.   (See  Appendix F.)   At level 4,  if
 you choose to put in a wind rose,  you must also supply
 the straight-line distance to the nearest receptor for
 each  of 16 sectors.   This is discussed in the
 description of the wind rose in Section 3.23.

 3.18  BUILDING WIDTH

 If  the stack height is less than 2.5  times the  building
 height,  you will be asked to supply the building width
 (in meters).   When there  is no wind rose (levels 2  and 3
 and level  4  without a wind  rose),  this  is  the plan  view
 dimension  perpendicular to  a line  from  the release  point
 to  the closest receptor.   (See Figure 3-3.)  In Figure
 3-3,  W is  the actual  width,  but WB is the dimension to
 use when there is  no  wind rose.  At level  4 with a  wind
 rose,  the  "width"  is  either W  or L (one  of  the  two  plan
 view  dimensions).   (See Figure 3-3 and the  following
 discussion of building length.)

 3.19  BUILDING LENGTH

At  level 4,  if you put in a wind rose and the stack
height is  less than 2.5 times the building height, you
will be asked  for the building  length (in meters).  This
                          3-15

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     RELEASE POINT
                                  RECEPTOR
                                  (NEAREST RESIDENT
                                  OR FARM)
     d - DISTANCE TO NEAREST RECEPTOR OR FARM
Figure 3-2
Distance between source and
nearest receptor
                      3-16

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 "length"  is the dimension perpendicular to the dimension
 supplied  in Section  3.18.   (See Figure 3-3.)  It can be
 equal to  the width already put in at levels 2 or 3  if
 that is the smaller  dimension.

 3.20 STACK AND AIR TEMPERATURES

 At level  4, if the stack height is greater than 2.5
 times the building height, the program will ask you for
 the annual average air temperature in degrees F.  This
 has a default value  of 55 °F.   The program will  then ask
 for the stack temperature in degrees F.  This, too, has
 a default value of 55 °F.   If  you  choose  the default
 values for both of these temperatures, the plume rise
 due to buoyancy effects will be zero.  It is to your
 benefit to put in the actual temperatures, because
 buoyant plume rise can significantly increase the
 effective stack height.  The stack temperature must be
 equal to  or greater  than the air temperature.   If it is
 not, the  program will ask you to re-enter the stack
 temperature.

 3.21 WIND SPEED

 The program will ask if you want to use the default wind
 speed of  2 m/s.  This is the annual average wind speed
 (m/s) without regard to the wind direction.  It is used
 at levels 2 and 3 and at level 4 if you do not put in a
wind rose.  If you do not know the wind speed, you may
use the default value; however, this is fairly
 conservative.   If you do not want to use the default
value,  the program will ask you for your value.
                          3-17

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                         CLOSEST
                         RESIDENT
               RELEASE
               POINT
              W
W. - BUILDING WIDTH WHEN THERE IS NO WIND ROSE

W - ACTUAL BUILDING WIDTH

L - BUILDING WIDTH
  Figure 3-3   Building width and length
                   3-18

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3.22 DISTANCES TO SOURCES OF VEGETABLES, MILK, AND MEAT

At level 3, you will be asked to supply the distances to
two kinds of farms—one producing vegetables and one
producing both milk and meat.  If the receptor can
produce significant quantities of either vegetables or
milk and meat at home, enter an H; otherwise, type in
the distance to the nearest potential location for the
production of that commodity.  If the receptor is on the
same building as the release, the program allows
vegetables, milk, and meat to be produced on the
building.  However, because this is a rare situation,
the program asks if you want to change the value.  If
you do, enter Y.  The program will ask you for the
distance again, and you can enter the distance to the
nearest potential location where that commodity can be
produced.

The guidelines on the locations are as follows:  There
are two scenarios.  The first is that the source of
emissions is in a location where it is not possible to
produce a significant quantity of a given food at the
location of the receptor.  This could be an urban
setting where local zoning laws or lack of proper land
makes it impractical for the receptor to produce a
significant fraction of his diet.  Or it could be a
rural setting in which the climate or terrain makes it
impossible to raise local crops.  The second scenario is
the case in which the receptor is able to produce a
given commodity at his home.  Whether he actually does
so is moot.  If he is able to, then it must be assumed
that he does.  You must be prepared to justify whichever
scenario you choose.  Obviously, the more conservative
the scenario, the easier it is to justify.
                          3-19

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Level 4 is similar to  level 3 except that there are
three types of farms:  vegetables, milk, and meat.  Thus
you must supply up to  three distances  (which may be
equal).  The directions to the farms are not required,
because the computer searches for the direction in which
the concentration is at a maximum.  The location chosen
at level 3 for the production of vegetables will be
carried forward to level 4; thus, if you ran a problem
at level 3 and then moved on to level 4, you will not be
asked again where vegetables are produced.  In addition,
at least one of the two distances for milk production
and meat production at level 4 must match the distance
supplied at level 3 for the farm producing both milk and
meat.

3.23 WIND ROSE

A wind rose is a table showing how frequently the wind
blows from a given direction with a given speed.  At
level 4, you will be asked if you wish to put in a wind
rose.  At levels 2 and 3 (and at level 4 if you do not
choose to put in a wind rose), the wind is assumed to
blow toward the receptor 25 percent of the time.  This
is conservative, because at most sites the maximum
frequency for a given  direction is about 10-15 percent.
If you choose to put in a wind rose, enter Y; if not,
enter N.

If you choose to use a wind rose, then the program will
ask you for a distance table for each release point.
The distances correspond to the directions FROM the
release point.TO the closest receptor in each of 16
sectors and must be greater than zero.   (See Figure
3-2.)  You may put these distances in from the keyboard
(following the instructions on the screen)  or you may
                          3-20

-------
set up distance  files ahead of time and use these.   If
you put them  in  from the keyboard, the program will
create files  for you so that you do not have to enter
them again if you re-run the problem.

Before the program creates each file, it will ask you
for a file name.  The name you give it should include
the .disk drive you want it on (if other than the default
drive).  For  example, if you want to call the file
STKDISK.DAT and  you would like it to be on drive B,  you
would type BrSTKDISK.DAT.  To put it on the default
drive, you would type only STKDISK.DAT.  The DAT
extension (.DAT) makes it easy to identify your data
files.  If there is already a file by that name, the
program will  ask you for a different name.  You will
need to supply one set of distances for each release
point.

Wind rose data can be obtained from several sources:
on-site measurements, a local meteorological station
(usually at the  local airport),  and the National
Climatic Data Center in Asheville,  North Carolina.   See
Appendix C for a description of data available from  the
National Climatic Data Center and how to put such data
in the form needed here.

If you do not have an on-site meteorological tower,  you
must use data from another source.   In general,  the data
must be from measurements made at a location meeting the
guidelines given in Appendix D.   However,  specific
exceptions might be made on a case-by-case basis,
depending on how close the dose estimates are to the
limits and the similarity of the terrain in the local
area to the terrain where the data were collected.  The
                          3-21

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data should either be for the period covered by the
assessment or be long-term average data (covering at
least 5 years).  The averaging period does not have to
include the assessment period.

Meteorologists have adopted the convention of presenting
these data in terms of the direction the wind is blowing
from, for each of 16 sectors.  This can easily lead to
errors when supplying the wind rose data.   Before you
start the problem, check to make sure that your wind
rose data and your distances are in the form of FROM
rather than TO.  Embarrassing errors have been caused by
putting in wind rose data that were exactly the reverse
of what the user thought they were.

If you indicate that you want to put in a wind rose,
then the program will ask you whether you want to put it
in from a file or from the keyboard.  The first time you
run the code, you must put in the wind rose data from
the keyboard.

Before asking you for the wind rose data,  the program
will ask you to provide the following information:

  1. The source of the data;
  2. The dates covered;
  3. The location where the measurements were made;
  4. The distance from your facility to the measurement
     location; and
  5. Units for the wind speed (just follow the
     instructions on the screen).
                          3-22

-------
 The source of the data might be one of those listed
 above,  e.g.,  the National Climatic Data Center.   The
 dates covered correspond to the period during which the
 meteorological measurements were made.   The location of
 the measurements is the name of the weather station,  and
 the distance  is the distance from your facility  to that
 weather station.

 The program next asks  you for the percentage of  calms.
 Usually given on wind  roses,  this represents the period
 of  time the wind speed is less than (generally)  3 mph.
 If  it is not  given,  check your source  of data to see  if
 it  has  been factored in.   If  the calms  have been
 factored into the data,  enter a zero for the fraction of
 calms when the program asks for it.

 Wind speed data are  usually given in either miles per
 hour (mph)  or knots, and the  program requires
 meters/second (m/s).   The conversion factors are as
 follows:

      To obtain m/s from mph,  multiply mph by 0.45.

      To obtain m/s from knots,  multiply  knots by 0.51.

 The  program will  ask you what your wind  speed units are
 and  will do the conversion  for  you.  All the
 instructions  for  entering the wind rose data will appear
 on your screen.  We suggest that you have the data ready
when you are  asked for  it.  To  that end. Table C-7 in
Appendix C  is  supplied  for use  in preparing your wind
rose data.   When the data have  all been entered,  they
will be displayed on the  screen, and you will be asked
 if they are correct.  If you answer Y for yes, the
computer will use the data you typed in to create
                          3-23

-------
a wind rose file.  This is done for your convenience, so
that if you want to re-run the problem for some reason,
you do not have to put in the wind rose data again.  If
the wind rose is not correct, answer N for no, and the
program will give you instructions for fixing it.

These restrictions apply to the values for the
distances, frequencies, and wind speeds:

  o  All the frequencies (except for calms) must be
     greater than zero.

  o  The sum of all the frequencies (including calms)
     must be between 0.99 and 1.01.

  o  All the wind speeds must be greater than 0.1
     meter/second.

Before the program creates the file, it will ask you for
a file name.  The name you give it should include the
disk drive that you want it on (if other than the
default drive).  For example, if you decide to name the
file WINDROSE.DAT and you would like it to be put on
drive B, then you would type in B:WINDROSE.DAT.  If you
want to put it on the default drive, you need type only
WINDROSE.DAT.  It is handy to put a DAT extension  (the
DAT) on all data files to make it easy to identify them.

When you run a problem and tell the computer you want to
use a wind rose file, the program will ask you for the
file name.  If the file is not on the same disk as the
program, you must tell the program where it is.  For
                          3-24

-------
example, if the default drive is drive C and the wind
rose file is called ROSIE.DAT on drive B, you would type
B:ROSIE.DAT.  If the source and receptor are on the same
building surface, the wind rose is used only for
estimating the air concentration at the farms.

An abbreviated version of a wind rose is given in
Table 3-1.

       Table 3-1.  Abbreviated Sample Wind Rose

          Wind             Speed
          FROM  Frequency   m/s
          Calm    0.063
          ' N '   0.022
          'NNE1   0.034
          2.1
          3.2
           'NNW'
0.042
2.5
Whether you enter the wind rose from a file or from the
keyboard, the program will print it out and ask you if
it is correct.  If you enter Y for yes, it will proceed
with the problem.  If you enter N, the program will
allow you to fix it.  The instructions will appear on
the screen.

3.24 MULTIPLE RELEASE POINTS

The way you handle multiple release points depends in
part on whether you are using a wind rose.  When you
have multiple release points, you must supply the
distance from each release point to each receptor.
                          3-25

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3.24.1  MULTIPLE RELEASE POINTS WITH NO WIND ROSE

Option 1.  If you are running levels 2 or 3, or level 4
without a wind rose, you may run multiple stacks in one
problem.  The program adds the dose to the closest
individual from release point 1 to that from release
point 2, and so on.  This will overestimate the dose if
different individuals in widely separated locations are
exposed to the various release points, because Option 1
assumes the same individual is in all the locations at
once.

Option 2. The other option is to run N separate problems
if there are N release points, and use the multiple
stack option.  This method is more complicated; however,
it eliminates the conservatism inherent in Option 1.
The method is best explained by the table below, which
illustrates the procedure for three release points.
    Release
     Point
       1
       2
       3

      Sum
a
D(xla)
D(x2a)
D(X3J
Receptor
b
D(xlb)
D(x2b)
D(x3b)
c
D(xlc)
DCx^)
D(x3c)
In this table, receptor a is the closest receptor to
release point 1, receptor b to release point 2, and so
on.  The distance xu is the distance from release
point 1 to receptor a, xlb is the distance from release
point 1 to receptor b, and so on.  The dose D(xu) is the
dose to receptor a from stack 1, and so on.  The total
                          3-26

-------
dose Da to receptor a is the output from problem a, Db
the output  from problem b,  and  so  on.   Each of the three
columns represents  a  single problem.   You will not see
the individual doses  D(Xla) , etc.,  only the  totals  (Da,
Db/ and Dc) .  The dose to be reported is the maximum of
Da/ Db, or Dc.

3.24.2  MULTIPLE RELEASE POINTS WITH A WIND ROSE

Option 1. The first option  is to run one multistack
problem.  This will require a distance file for each
stack but only one  wind rose file.  All of  the
meteorological parameters will  be  the  same;  only the
distances from the  release  points  to the receptors will
be different.  This is  similar  to  the  first option for
multiple release points with no wind rose,  because it is
as if the person lives  in all the  worst locations  for
all release points.

Option 2. The other option  is to run 2N problems for  N
release points.  This will  require 2N  sets  of  distances.
If you choose this  option,  you  must do  the  following:

1.   Run a single-stack problem for release point  1
     using the actual distances from the release point
     to the nearest receptors in all 16 sectors.  This
     will give you the  dose from stack  1 to receptor  1
     (the receptor receiving the highest dose  from
     release point  1)  and will tell you which  sector he
     lives in.

2.   Having done step 1, determine from the output the
     location of receptor 1.  Create new distance files
     for release point  2, 3, etc.,  setting all the
     distances except the one in the direction from each
                          3-27

-------
3.
release point to receptor 1 to a very large number
(we suggest 106 meters) .  This will prevent the
program from calculating the dose to someone in a
sector other than the one of interest.  For each
distance file in the direction of receptor 1, put
in the actual distance from receptor 1 to the
release point.  Then run this problem using the
multiple stack option.  This gives you the dose to
receptor 1 from all the release points.

Repeat steps 1 and 2 for the remaining release
points to get the doses to receptor 2 from release
points 1, 2, 3, etc. The dose to use in determining
whether or not you are in compliance is that of the
problem having the highest total dose from all the
release points.
                          3-28

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                       4.0   OUTPUT

The output is self-explanatory.  The input is printed
out just as you entered it.  You should use Worksheet F
of EPA89 to determine whether you are exempt from
reporting, in compliance, or not in compliance.

If you elected to have the output sent to a printer, it
will appear there automatically.  (You must have the
printer turned on.)  If you chose to have it sent to a
file, you may examine the file on the screen or you may
print it out.  One way to examine the file on the screen
is to use the MORE command.  If the file is named MYOUT
on drive A, type in

     MORE  A:MYOUT

This will result in the file being displayed on the
screen 23 lines at a time.   You can see 23 more lines by
pressing any key.  The next 23 lines will then scroll
up.  In this way, you can work your way through the file
(but only from front to back).

If you want to print the file, make sure the printer is
turned on and that the top of the sheet is lined up with
the printhead.  Then type

     PRINT A:MYOUT

This will cause the file to be printed.
                           4-1

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                       REFERENCES

BAKER76, Baker, D.A./ Hoenes, G.R., and Soldat, J.R.,
"FOOD—An Interactive Code to Calculate Internal
Radiation Doses from Contaminated Food Products," Proc.
of Conference on Environmental Modeling and Simulation,
EPA 600/9-76-016, April 19-22, 1976, Cincinnati, Ohio,
July 1976.

BRIGGS84, Briggs, G.A. "Plume Rise and Buoyancy
Effects," in Atmospheric Science and Power Production.
Darryl Randerson, Ed., U.S. Department of Energy, 1984.

BRIGGS86, Memo from G.A. Briggs, U.S. Environmental
Protection Agency, to D.A. Baker, Battelle-Pacific
Northwest Laboratories, 1986.

DOE88, "External Dose-Rate Conversion Factors for
Calculation of Dose to the Public," U.S. Department of
Energy, July 1988.

EPA79, "AIRDOS-EPA: A Computerized Methodology for
Estimating Environmental Concentrations and Dose to Man
from Airborne Releases of Radionuclides,"
EPA 520/1-79-009, U.S. Environmental Protection Agency,
Office of Radiation Programs, 1979.

EPA83, "Background Information Document, Proposed
Standards for Radionuclides," EPA 520/1-83-001, U.S.
Environmental Protection Agency, Office of Radiation
Programs, Washington, DC, March 1983.
                           5-1

-------
EPA88, "Federal Guidance Report No. 11:  Limiting Values
of Radionuclide Intake and Air Concentration and Dose
Conversion Factors for Inhalation, Submersion, and
Ingestion," EPA 520/1-88-020, U.S. Environmental
Protection Agency, Office of Radiation Programs,
September 1988.

EPA89, "A Guide for Determining Compliance with the
Clean Air Act Standards for Radionuclide Emissions from
NRC-Licensed and Non-DOE Federal Facilities"
EPA 520/1-89-002, U.S. Environmental Protection Agency,
Office of Radiation Programs, October 1989.

EPA89a, "Background Information Document, Environmental
Impact Statement for Proposed NESHAPS for Radionuclides,
Volume I, Risk Assessment Methodology,"
EPA 520/1-89-005, U.S. Environmental Protection Agency,
Office of Radiation Programs, October 1989.

IA82, "Generic Models and Parameters for Assessing the
Environmental Transfer of Radionuclides from Routine
Releases," Safety Series No. 57, International Atomic
Energy Agency, Vienna, 1982.

KASNER56, Kasner, E. and Newman, J., Mathematics and the
Imagination. Simon and Schuster, New York, 1956.

NCRP89, "Screening Techniques for Determining Compliance
with Environmental Standards," NCRP Commentary No. 3,
National Council on Radiation Protection and
Measurements, Revision of January 1989 with Addendum of
October 1989. .
                           5-2

-------
NELSON87, Personal communication with Dr. C. Nelson of
the Office of Radiation Programs, U.S. Environmental
Protection Agency, 1987.

SCA89, "An Analysis of the Uncertainties in the Risk
Assessment Performed in Support of the NESHAPS for
Radionuclides", S. Cohen and Associates, McLean, VA,.
September 1989.

SKRABLE74, Skrable, K.W., et. al., "A General Equation
for the Kinetics of Linear First Order Phenomena and
Suggested Applications," Health Physics, 27. 155, 1974.

WILSON82, Wilson, D.J. and Britter, R.E., "Estimates of
Building Surface Concentrations from Nearby Point
Sources," Atmospheric Environmentf  16, 11,  2631, 1982.
                          5-3

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            APPENDIX A -  HOW TO  HANDLE  ERRORS

In most cases, if you make an incorrect entry, the
program will tell you what is wrong and allow you to
correct it.  In some cases, the program cannot identify
the error.  In those cases, we have programmed the
machine to suggest possible problems, but finding the
difficulty is up to you.   These types of problems are
covered here.  We have included here all the potential
difficulties anticipated.  If you encounter one that is
not on the list, please notify your EPA Regional Office.

1. MACHINE DOES NOT RESPOND AFTER YOU HAVE TYPED IN
   VALUE

Have you pressed Enter?  You must press Enter to have
the machine digest your answer to its question.

Have you pressed Enter without typing in a value?  If
the program wants you to type in a number, and you just
press Enter, it will wait patiently for you to enter a
number.

2. ERROR MESSAGE; "There is something wrong with your
   input value..."

You may have made a typographical error.  Try typing in
the value again.  Be sure to use the proper format.  You
may have used the lower case "L" for a numeral 1.
Unlike most typewriters,  the computer keyboard has a
separate key for the numeral 1.

You may have entered a value using an improper format.
                          A-l

-------
The program allows  you to enter  numerical  values in a
number  of  different ways.   For example,  to enter 1400
you may type either 1400,  1400.,  1.4e3,  1.4E3,  l.4e+3,
1.4E+3, or 1.4+3.   To  enter 0.012, you may type 0.012,
.012, 1.2e-2,  1.2E-2,  or  1.2-2.

The following formats  are NOT correct: 1,400 or
1.4x10+3,  and 012 or 1.2x10-2.

If you  type 1,400,  the program will not  recognize this
as 1400, but it will not  give you an error message.   It
will ignore everything after the  comma and treat the
value as 1.   The program will read 012 as  12, not .012.
The other  two incorrect forms will result  in an error
message.
                                              It's not
3. ERROR MESSAGE: "I can't find (file nameV.
on the default drive..."
The data files supplied with the program must be on the
default drive.  If for some reason they are not there,
you will get this error message and the program will
stop.

The following are the names of the data files that are
supplied with the program; and must be on the default
drive:

     HALFLIFE.DAT, INDX.DAT, NUCS.DAT,
     TABLE2.DAT, TABLE21.DAT, TABLE22.DAT, TABLE3.DAT,
     TABLE5.DAT, TABLE7.DAT,
     TABLEB2.DAT,
     TABLEC5.DAT, TABLEC6.DAT,  TABLEL4.DAT,
     TITLE.DAT, TREE.DAT,  XMPTCON.DAT, XMPTPOS.DAT
                          A-2

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 Check your  diskette(s)  to make  sure  that  the files  are
 all  there by using the  directory  command  (if the
 original diskette is  in drive A,  this  is  DIR *.DAT)  and
 then set up your system again as  described  in Section 2
 in the main part of this guide.   If  some  files are
 missing, order a new  copy of the  program  and data files.

 If you do not have a  hard disk, check  your  original
 diskettes to see if all of the  above files  are there.
 Assuming they are there, follow the  instructions given
 in Section  2.1, "Making a Working Copy."  Be sure to put
 the  COMPLY-EXE diskette in drive  A:  and the COMPLY-DATA
 diskette in drive B:.

 If the missing file is  your wind  rose  or  distance file,
 check to see that it  has the name you  think it has and
 that it is  on the disk  drive you  think it is on.  If the
 name is not what you  thought it was, or it  is  on a
 different drive, start  over and give the  program the
 correct file name when  asked.   If it is not on the
 default drive, you must tell the  machine  where it is.
 For  example, if the default drive is drive  A or  C, and
 the  wind rose file is named WINDROSE.DAT  and is  on drive
 B, then you must enter  BiWINDROSE.DAT when  the machine
 asks you for the file name.

 4. ERROR MESSAGE FOR DISTANCE OR WIND ROSE  FILE;
      (a)   "There is something wrong with  DATA  line..."
      (b)   "Error at line *** in GETWRF..."
      (c)   "Error at line *** in GETWDF..."

You should never get these messages.   If you do, delete
the file that is causing the problem (by typing DEL  file
name) and start over using the program to make a new
file.
                          A-3

-------

-------
              APPENDIX B - SAMPLE PROBLEMS

The sample problem that follows is intended to show the
output from COMPLY and how the results can change from
level to level.

The problem starts with the use of the Possession Table
(Level 1).  At this level the facility is not in
compliance.  The problem for Levels 2 and 3 is the same
as the sample problem given in NCRP Commentary No. 3
(NCRP89).  The facility is in compliance at both of
these levels, the dose at Level 3 being slightly less
than Level 2.  Level 4 shows the use of wind rose and
separate locations for the production of milk and meat.
Note that the significantly lower dose at Level 4 is not
necessarily typical.
                          B-l

-------
COMPLY: VI.5d.
40 CFR Part 61
National Emission Standards
for Hazardous Air Pollutants
                    REPORT ON COMPLIANCE WITH

        THE CLEAN AIR ACT LIMITS FOR RADIONUCLIDE EMISSIONS

                 FROM THE COMPLY CODE, VERSION 1.5d
                Prepared by:
                ABC Corporation
                XYZ Site
                1000 Main St., Short Pump, VA 12345

                J. Jones, Health Physicist
                (123) 456-7890
                Prepared for:

                U.S. Environmental Protection Agency
                Office of Radiation Programs
                Washington, D.C.  20460
                                 B-2

-------
COMPLY: VI.5d.
Test
SCREENING LEVEL 1


 DATA ENTERED:


     Annual possession limits used.

               Annual Amount  Physical
     Nuclide     (ci/year)      Form

     1-131          2.00E-03   Gaseous
     SE-75          2.00E-03   Gaseous
     SR-85          3.50E+00   Liquid


 NOTES:


     Input parameters outside the "normal" range:


         None.


 RESULTS:
     You possess        4.0 times the allowable amount
     given in the possession table.

     *** Failed at level 1.
                                 B-3

-------
COMPLY: VI. 5d.
Test
SCREENING LEVEL 2
 DATA ENTERED:
     Nuclide
 Release Rate
(curies/SECOND)
     1-131     D  3.200E-10
     SE-75     W  1.600E-09
     SR-85     Y  9.400E-09
     Release height 25, meters.
     Building height 20 meters.
     The source and receptor are not on the same building.
     Distance from the source to the receptor is 200 meters.
     Building width 50 meters.
     Default mean wind speed not used.
     Mean wind speed is  3.00 m/sec.

 NOTES:

     Input parameters outside the "normal" range:
         None.
 RESULTS:
     Effective dose equivalent:
     Effective dose equivalent:
     *** comply at level 2.
                      6.7 mrem/yr.
                      0.6 mrem/yr due to Iodine.
                                B-4

-------
COMPLY: VI.5d.
Test
SCREENING LEVEL 3

 DATA ENTERED:

     He produces his own VEGETABLES at home.
     Distance from the SOURCE to the FARM producing
     MILK and MEAT is 2000 meters.

 NOTES:

     Input parameters outside the "normal" range:
         None.
 RESULTS:
     Effective dose equivalent:
     Effective dose equivalent:
     *** Comply at level 3.
3.0 mrem/yr.
0.1 mrem/yr due to Iodine.
                                B-5

-------
COMPLY: VI.5d.
Test
SCREENING LEVEL 4
 DATA ENTERED:
     Building length 50 meters.

     STACK DISTANCES, FILE: c:\comply\staktest.dat
          DIR

          N
          NNE
          NE
          ENE
          E
          ESE
          SE
          SSE
          S
          SSW
          SW
          WSW
          W
          WNW
          NW
          NNW
Distance
(meters)

   240.0
   270.0
   230.0
   240.0
   280.0
   220.0
   220.0
   210.0
   200.0
   225.0
   230.0
   210.0
   220.0
   220,
   230.
0
0
   250.0
                              B-6

-------
COMPLY:
Wlh
SOL
Dat
Win
Dis
Per
Win
FRC
N
NN
NE
EN
E
ES
SE
SS
S
SS
SW
WS
W
WN
NW
NN
Dis
MIL
Dis
MEA
NOTES:
The

He
He

He

Inp


VI. 5d.
DROSE DATA, FILE: c:\comply\windtest.dat
rce of wind rose data: Nat. Climatic Data Center
es of coverage: 1975-1980
d rose location: Richmond, VA
tance to facility: 15 Miles
cent calm: 0.12
d Speed
M Frequency (meters/s)
0.053 4.10
E 0.029 3.90
0.029 3.80
E 0.033 3.90
0.041 3.90
E 0.039 4.20
0.041 3.90
E 0.033 3.90
0.051 4.00
W 0.049 4.50
0.086 4.90
W 0.118 5.40
0.104 5.40
W 0.073 5.40
0.059 4.90
W 0.043 4.50
tance from the SOURCE to the FARM producing
K is 2500 meters.
tance from the SOURCE to the FARM producing
r is 2000 meters.

receptor exposed to the highest concentration is located
240. meters from the source in the ENE sector.
produces his own VEGETABLES at his home.
jets his MEAT from a farm located
2000. meters from the source in the ENE sector.
jets his MILK from a farm located
2500. meters from the source in the ENE sector.
it parameters outside the "normal" range:
None.
B-7

-------
COMPLY: VI.5d.
 RESULTS:
     Effective dose equivalent:-        0.2 mrem/yr.
     Effective dose equivalent:    6.0E-03 mrem/yr due to Iodine.
     *** Comply at level 4.
     This facility is in COMPLIANCE.
     It may or may not be EXEMPT from reporting to the EPA.
     You may contact your regional EPA office for more information.

********** END OF COMPLIANCE REPORT **********
                                 B-8

-------
APPENDIX C - OBTAINING AND ORGANIZING WIND ROSE DATA

As noted in the body of this report, there are three
possible sources of wind rose data:  (1) on-site
measurements,  (2) a local weather station (usually
located at airports), and (3) the National Climatic Data
Center in Asheville, North Carolina  (telephone
704-259-0682).

If you do not have an on-site meteorological tower, you
must get wind rose data from another source.  See
Appendix D for guidelines as to what constitutes
acceptable data.

For off-site data, we recommend that you contact the
National Climatic Data Center because (1) they have
trained personnel who can advise you regarding the
locations for which they have data,  (2) it is fairly
easy to put their data in the proper form, and (3) data
are available for several hundred locations around the
country.  Data from local airports may not have been
reduced to usable form; that is, the measurements may be
hourly or daily, which would mean you would have to
consolidate between about 400 and 9000 data points for
one year.  Moreover, the airport data may already be in
the National Climatic Data Center data base.

Three kinds of data are available from the National
Climatic Data Center: Wind Direction Versus Wind Speed
Tabulations, STability ARray (STAR) data, and
Wind-Ceiling-Visibility data.  Each of these is
discussed below.

C.I  WIND DIRECTION VERSUS WIND SPEED TABULATIONS

If the National Climatic Data Center has one of these
tabulations available that is suitable for your site,  we
                          C-l

-------
recommend that it be your first choice, because it is
already in the form you need.  Table C-l is a sample
tabulation; the last two columns are what you use to
create your wind rose.

C.2  STABILITY ARRAY  (STAR) DATA

The second kind of data available from the National
Climatic Data Center is the so-called STAR data.  These
data (or their equivalent) are fairly extensive, but a
subset can be used for COMPLY.  The data are on tape or
hard copy.  Unless you have access to a tape reader, you
should not order the tape.  The data consist of 13
tables; only the last 2 are of interest here.  The
next-to-last column of the next-to-last sheet contains
the average wind speed (in knots) for each sector.  The
last column of the last sheet contains the fraction of
the time the wind blows from each direction.

     NOTE:  The calms are distributed among the
     frequencies, so that if you use the STAR data you
     should put in a 0 for calms when you run COMPLY.

Tables C-2 and C-3 show the organization of the last 2
of the 13 STAR tables.  The appropriate columns are
marked.

While the STAR data are as convenient as the Wind
Direction Versus Wind Speed Tabulations, not as many
locations have been put into this data base.  Thus, you
may not be able to find data from a nearby location.
                           C-2

-------
 C.3  WIND-CEILING-VISIBILITY DATA

 The Wind-Ceiling-Visibility data are, for the most part,
 30-year averages  (1948-1978).  Compiled for the Federal
 Aviation Administration, they are not in the exact form
 required for use  in COMPLY.  They consist of both tables
 and graphs.  The  graphic data are in the form shown in
 Figure C-l.  The  tabular data supplied with the graphic
 data are not useful for your purpose.  You must use the
 data from the graphic wind rose to construct a table of
 wind speeds and frequencies.

 To construct your table from Figure C-l, follow this
 procedure.

 The numbers inside the segments represent the percentage
 of the time that  the wind blows from a particular
 direction within  a range of wind speeds.  The speed
 range lies between the values shown on the concentric
 circles in the sector marked N.

 In the sector marked N, the first of the concentric
 circles has a 4 on it.  This represents the lower limit
 of the wind speed.  The next concentric circle has a 13
 on it.  Inside the segment bounded by these two sectors
 is a 4.3.  This means that 4.3 percent of the time the
wind is from the  north, with a speed between 4 and 12
miles per hour.   The convention is to use the lower
value as the lower limit of the range and the higher
value minus 1 mi/h as the upper limit.   The calms are
given in the innermost circles (0-3 mph).

From the graph in Figure C-l,  we can construct
Table C-4.
                          C-3

-------
To construct the simplified wind rose needed for the
COMPLY program, we need the average wind speed from each
direction and the fraction of the time the wind blows
from that direction.  The average wind speeds for each
class are as given in Table C-5.

We first sum the frequencies in each sector to get the
fraction of time the wind blows from that direction;
i.e.,
where f§ is the frequency of the time the wind speed in
sector i is in class j .

To compute the average speed for the sector, we multiply
the average speed in each class by its frequency, sum
them, and divide by the sum of the frequencies in that
sector .
is
where U; is  the average wind speed in sector  i,  and Uj
the average wind speed for  class  j  (from Table  C-4) .

This is not the true average speed  for the sector,
because we did not account  for calms.  The program will
ask you for the fraction of the time the wind is calm
 (in this case,  0.118)  and make the  correction for you.
                           C-4

-------
An example of a calculation is as follows: with the wind
from the north, the sum of the frequencies is 4.3 + 0.8
+ 0.2 = 5.3, and the average wind speed is (8x4.3 +
14x0.8 + 17x0.2)/5.3 = 9.2.

The result of these operations for the sample data is
given in Table C-6.  The last column has the wind speed
in m/s, the unit required for COMPLY.  The conversion
factor is m/s = mi/h times 0.447.

Table C-7 is provided to assist you in preparing the
wind rose data.
                          C-5

-------
FIGURE C-l  SAMPLE GRAPHICAL WIND ROSE
                  C-6

-------
o
vj
Table c-l sample wind Direction Versus wind Spe
WIND DIRECTION VERSUS WIND SPEED
STATION NAME/NAMBER Hypothetical/12345 DATA Frequency pE(
SPEED GROUPS IN MPH




Mo
AN
















Code

















xSp««l
<*\.
N
NNE
NE
ENE
E
ESE
SE
SSE
S
SSW
SW
WSW
W
WNW
NW
NNW
Calm
Total
Percent
0-3
769
477
348
277
424
330
268
357
642
286
335
396
507
456
397
416
2471
9156
31.3
4-7
1491
1137
808
435
373
235
222
467
1070
390
309
366
765
919
609
670

10266
35.1
8-12
1186
670
347
69
43
43
114
560
1067
228
126
120
325
462
252
235

5847
20.0
13-15
302
137
35
3
4
10
70
547
513
56
33
12
35
30
29
70

1886
6.5
16-18
149
50

1
2
4
56
513
374
25
10
1
3
7
11
75

1281
4.4
MO : MI - Annual; 1 - January; 2 - February;
CODE : Blank • All Weather; 10 - VFR; 20 » IFR;
19-24
85
29


3
7
27
255
156
7
2



7
37

615
2.1

30 - IL
25-31
41




2
2
47
15
1




1
21

130
0.4
32-38
15





1
3
1






15

35
0.1
ad Tabulation
HOD OF RECORD
39 * Or.



















12 - December.
S
Total
4038
2500
1538
785
849
631
760
2749
3838
993
815
895
1635
1874
1306
1539
2471
29216


i
1965-9174

Pdfodnt
13.8
8.6
5.3
2.7
2.9
2.2
2.6
9.4
13.1
3.4
2.8
3.1
5.6
6.4
4.5
5.3
8.5
100.0


Avo.
SpOBd
7.8
7.3
6.3
5.0
4.4
4.7
7.5
11.8
9.3
6.6
5.5
5.0
5.7
6.0
5.9
7.0

6.8




-------
o
oo
ANNUAL

DIRECTION
N
NNE
NE
ENE
E
ESE
SE
SSE
S
SSW
SW
WSW
W
WNW
NW
NNW
AVG
TOTAL
TOTAL NUMBER
TOTAL NUMBER
Table C-2 Sample STAR DATA
RELATIVE FREQUENCY DISTRIBUTION STATION =94823 PITTSBURGH. PA 24085



1979
SPEED(KTS)

1-3 4-fi 7-10 11-16 17-21 GREATER THAN 21
39
33
40
36
73
45
68
50
83
35
45
49
58
48
38
20
3.0
768
216
119
175
114
164
106
193
180
289
93
166
143
223
168
95
76
5.1
2520
OF OBSERVATIONS
OF CALMS
= 609
365
95
93
142
159
79
107
112
210
141
301
242
338
198
160
212
8.4
2954
95
0
15
36
43
32
52
14
43
76
194
280
349
158
119
136
12.9
1650
0
0
0
1
0
0
0
0
0
4
17
37
72
31
12
2
18.5
176
0
0
0
0
1
0
0
0
0
1
20
35
20
5
1
0
25.0
83


AVG SPD TOTAL
7.7
6.1
5.9
7.1
6.6
6.6
6.4
5.9
6.3
8.1
9.3
10.4
10.0
8.9
8.8
8.8
7.6

715
255
323
329
440
242
420
356
625
350
743
786
1060
608
425
454


= 8760







-------
O
\o
Table C-3 Sample STAR DATA
ANNUAL RELATIVE FREQUENCY DISTRIBUTION


DIRECTION
N
NNE
NE
ENE
. E
ESE
SE
SSE
S
SSW
SW
WSW
W
WNW
NW
NNW
TOTAL
PITTSBURGH. PA 24085 1979
SPEED(KTS>
0-3 4-6 7-10 11-16 17-21 GREATER THAN
0.009844 0.024658 0.041667 0.010845 0.000000 0.000000
0.006981 0.013584 0.010845 0.000913 0.000000 0.000000
0.009112 0.019977 0.010616 0.001712 0.0000000.000000
0.007281 0.013014 0.016210 0.004110 0.0001140.000000
0.0133440.018721 0.018151 0.004909 0.0000000.000114
0.008330 0.012100 0.009018 0.003653 0.000000 0.000000
0.013281 0.022032 0.012215 0.005936 0.000000 0.000000
0.010571 0.020548 0.012785 0.001598 0.000000 0.000000
0.017340 0.032991 0.023973 0.004909 0.000000 0.000000
0.006702 0.010616 0.016096 0.008676 0.000457 0.000114
0.009598 0.018950 0.034361 0.022146 0.001941 0.002283
0.009653 0.016324 0.027626 0.031963 0.004224 0.003995
0.012562 0.025457 0.038584 0.039840 0.008219 0.002283
0.010046 0.019178 0.022603 0.018037 0.003539 0.000571
0.007150 0.010845 0.018265 0.013584 0.0013700.000114
0.005395 0.008676 0.024201 0.015525 0.000228 0.000000
0.157192 0.287671 0.337214 0.188356 0.020091 0.009475
STATION =94823


21 TOTAL
0.087013
0.032323
0.041418
0.040729
0.055239
0.033101
0.053464
0.045502
0.079212
0.042661
0.089279
0.093786
0.126946
0.073973
0.051328
0.054025

TOTAL RELATIVE FREQUENCY OF OBSERVATIONS = 1 .000001
TOTAL RELATIVE FREQUENCY OF CALMS DISTRIBUTED ABOVE = 0.069521

-------
      Table C-4.  Tabular form of graphical wind rose
j-
Sector
Calms
N
NNE
NE
ENE
E
ESE
SE
SSE
S
ssw
sw
wsw
w
WNW
NW
NNW
1
0-3
11.8
-
-
-
—
—
—
-
—
—
—
-
—
-
—
—
—
2
4-12
—
4.3
2.6
2.7
2.9
3.6
3.2
3.6
2.9
4.4
3.4
5.2
6.1
5.7
4.0
3.6
2.9
3
Wind Speed,
13-15 1
-
0.8
0.2
0.2
0.3
0.4
0.4
0.4
0.3
0.5
0.8
1.7
2.4
2.1
1.4
1.1
0.9
4
mi/h
6-18
—
0.2
0.1
0
0.1
0.1
0.2
0.1
0.1
0.1
0.5
1.1
1.9
1.6
1.2
0.7
0.4
5
19-24
-
0
0
0
0
0
0.1
0
0
0.1
0.2
0.5
1.1
0.8
0.6
0.4
0.1
6
25-31
-
0
0
0
0
0
0
0
0
0
0
0.1
0.3
0.2
0.1
0.1
0
... • ' 7
32
-
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Table C-5.  Average wind speeds for each class
      Class
Speed
Range
Average
 Speed
  mi/h
        1
        2
        3
        4
        5
        6
        7
 0-3 (calm)
 4-12
13-15
16-18
19-24
25-31
  32
   Calm
   8
  14
  17
  21
  28
  32
                           C-10

-------
Table C-6. Wind rose data  suitable  for use  in the
           COMPLY  code
   Wind From
   Sum
0.999
                                    Average Speed
Calm
N
NNE
NE
ENE
E
ESE
SE
SSE
S
SSW
SW
WSW
W
WNW
NW
NNW
0.118
0.053
0.029
0.029
0.033
0.041
0.039
0.041
0.033
0.051
0.049
0.086
0.118
0.104
0.073
0.059
0.043

9.2
8.7
8.4
8.8
8.8
9.4
8.8
8.8
9.0
10
11
12
12
12
11
10

4.1
3.9
3.8
3.9
3.9
4.2
3.9
3.9
4.0
4.5
4.9
5.4
5.4
5.4
4.9
4.5
The frequencies must sum to between 0.99 and 1.01 to be accepted
by COMPLY.  Use three decimal places with the frequencies, to
make sure their sum is within these limits.
                              C-ll

-------
Table C-7.  Form for wind rose data

Wind                       Wind
FROM      Frequency1       Speed2

CALM                  XXXXXXXXXXXXX

N

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WWW

NW

NNW

Total3
Notes:

1. Expressed as fraction, NOT percent; i.e.
.025, not 2.5%.
2. Must be greater than 0.1 m/s.
3. Must be between 0.99 and 1.01.
             C-12

-------
APPENDIX D - SUITABILITY OF WIND ROSE DATA FROM AN
            OFFSITE LOCATION

In general, it is very unlikely that the wind rose data
from somewhere else will exactly duplicate the weather
patterns at your site.  Thus, you must find a location,
fairly close, that duplicates the conditions at your
location as closely as possible.  The factors that most
affect the wind speed and direction are as follows:

 !•  The elevation relative to the surrounding ai-ea

   A location on a hill or plateau can have different
   wind conditions than the lower surrounding area.

 2.  Presence  of a valley

  A location in a valley can have different  wind
  conditions than the terrain around  it.   The wind
  tends to channel through a valley.

 3-  Presence  of a large body  of water

  The presence of  large bodies of water can  influence
  the wind patterns.

4. Topography

  The wind patterns for hilly  terrain can be quite
  different from those for flat terrain.
                         D-l

-------
 5. Urban versus rural

   The wind patterns for urban locations can be quite
   different from those in the surrounding rural or
   suburban areas because of the heat island effect.

The measurements should come from a meteorological tower
located within 50 miles of the site.

The measurements should either cover the same year as
the assessment period, or be long-term averages (at
least 5 years).  The period over which the long-term
average data were obtained does not have to include the
assessment period.

It is unlikely that any facility not having onsite
measurements will be able to obtain data having all
these factors at their optimum conditions.  Moreover,
there are no firm guidelines as to what constitutes
"good" data;  that is, data representative of the
conditions at your site.  If your calculated doses are
well below the limits, then the representativeness of
the meteorological data is not critical.  However, if
you are close to the dose limits, or exceed them, you
should consult a qualified meteorologist.  The EPA will
make the final determination as to whether or not the
data you chose are satisfactory.
                           D-2

-------
APPENDIX E - LIST OF NUCLIDES IN COMPLY
    Ac-225
    Ac-227
    Ac-228
    Ag-106
    Ag-106m

    Ag-108m
    Ag-llOm
    Ag-lll
    Al-26
    Am-241

    Am-242
    Am-242m
    Am-243
    Am-244
    Am-245

    Am-246
    Ar-37
    Ar-41
    As-72
    As-73

    As-74
    As-76
    As-77
    At-211
    Au-193

    Au-194
    Au-195
    Au-198
    Au-199
    Ba-131

    Ba-133
    Ba-133m
    Ba-135m
    Ba-139
    Ba-140

    Ba-141
    Ba-142
    Be-7
    Be-10
    Bi-206
 Bi-207
 Bi-210
 Bi-212
 Bi-213
 Bi-214

 Bk-249
 Bk-250
 Br-77
 Br-80
 Br-80m

 Br-82
 Br-83
 Br-84
 C-ll
 C-14

 Ca-4l
 Ca-45
 Ca-47
 Cd-109
 Cd-113

 Cd-113m
 Cd-115
 Cd-115m
 Cd-117
 Cd-ll7m

 Ce-139
 Ce-141
 Ce-143
 Ce-144
 Cf-248

 Cf-249
 Cf-250
 Cf-251
 Cf-252
Cf-253

Cf-254
Cl-36
Cl-38
Cm-242
Cm-243
                 E-l

-------
APPENDIX E - LIST OF NUCLIDES IN COMPLY
     Cm-244
     Cm-245
     Cm-246
     Cm-247
     Cm-248

     Cm-249
     Cm-250
     Co-56
     Co-57
     Co-58

     Co-58m
     Co-60
     Co-6Om
     CO-61
     Cr-49

     Cr-51
     CS-129
     CS-131
     CS-132
     CS-134

     Cs-134m
     Cs-135
     CS-136
     CS-137
     Cs-138

     CU-61
     CU-64
     CU-67
     Dy-157
     Dy-165

     Dy-166
     Er-169
     Er-171
     Es-253
     Es-254

     Es-254m
     Eu-152
     Eu-152m
     EU-154
     Eu-155
EU-156
F-18
Fe-52
Fe-55
Fe-59

Fm-254
Fm-255
Fr-223
Ga-66
Ga-67

Ga-68
Ga-72
Gd-152
Gd-153
Gd-159

Ge-68
Ge-71
Ge-77
H-3
Hf-181

Hg~193m
Hg-197
Hg-l97m
Hg-203
Ho-166

HO-166m
1-123
1-124
1-125
1-126

1-128
1-129
1-130
1-131
1-132

1-133
1-134
1-135
In-Ill
In-113m
                   E-2

-------
APPENDIX E - LIST OF NUCLIDES IN COMPLY
     In-114m
     In-115
     In-115m
     In-116m
     In-117

     In-ll7m
     Ir-190
     Ir-192
     Ir-194
     Ir-l94m

    K-40
    K-42
    K-43
    K-44
    Kr-79

    Kr-81
    Kr-83m
    Kr-85
    Kr-85m
    Kr-87

    Kr-88
    La-140
    La-141
    La-142
    Lu-177

    Lu-177m
    Mg-28
    Mn-52
    Mn-52m
    Mn-53

    Mn-54
    Mn-56
    Mo-9 3
    Mo-9 9
    Mo-101

    N-13
    Na-22
    Na-24
    Nb-90
    Nb-93m
    Nb-94
 Nb-95
 Nb-95m
 Nb-96
 Nb-97
 Nd-147

 Nd-149
 Ni-56
 Ni-57
 Ni-59
 Ni-63

 Ni-65
 Np-235
 Np-237
 Np-238
 Np-239

 Np-240
 Np-240m
 0-15
 Os-185
 Os-191m

 Os-191
 Os-193
 P-32
 P-33
 Pa-230

 Pa-231
 Pa-233
 Pa-234
 Pb-203
 Pb-205

 Pb-209
 Pb*210
 Pb-211
 Pb-212
 Pb-214

 Pd-103
 Pd-107
 Pd-109
Pm-143
Pm-144
Pm-145
                 E-3

-------
APPENDIX E - LIST OF NUCLIDES IN COMPLY
     Pm-146
     Pm-147
     Pm-148
     Pm-148m
     Pm-149

     Pm-151
     Po-210
     Pr-142
     Pr-143
     Pr-144

     Pt-191
     Pt-193
     Pt-193m
     Pt-195m
     Pt-197

     Pt-197m
     Pu-236
     Pu-237
     Pu-238
     PU-239

     Pu-240
     Pu-241
     Pu-242
     Pu-243
     PU-244

     Pu-245
     PU-246
     Ra-223
     Ra-224
     Ra-225

     Ra-226
     Ra-228
     Rb-81
     Rb-83
     Rb-84

     Rb-86
     Rb-87
     Rb-88
     Rb-8B
     Re-184
Re-184m
Re-186
Re-187
Re-188
Rh-103m

Rh-105
Ru-97
Ru-103
RU-105
RU-106

S-35
Sb-117
Sb-122
Sb-124
Sb-125

Sb-126
Sb-126m
Sb-127
Sb-129
Sc-44

Sc-46
Sc-47
Sc-48
Sc-49
Se-73

Se-75
Se-79
Si-31
Si-32
Sm-147

Sm-151
Sm-153
Sn-113
Sn-117m
Sn-119m

Sn-123
Sn-125
Sn-126
Sr-82
Sr-85
                   E-4

-------
APPENDIX E - LIST OF NUCLIDES IN COMPLY
     Sr-85m
     Sr-87m
     Sr-89
     sr-90
     Sr-91

     Sr-92
     Ta-182
     Tb-157
     Tb-160
     Tc-95

     Tc-95m
     Tc-96
     Tc-96m
     Tc-97
     Tc-97m

     Tc-98
     Tc-99
     Tc-99m
    Tc-101
    Te-121

    Te-121m
    Te-123
    Te-123m
    Te-125ffi
    Te-127

    Te-127m
    Te-129
    Te-129m
    Te-131
    Te-131m

    Te-132
    Te-133
    Te-133m
    Te-134
    Th-226

    Th-227
    Th-228
    Th-229
    Th-230
    Th-231
 Th-232
 Th-234
 Ti-44
 Ti-45
 Tl-200

 Tl-201
 Tl-202
 Tl-204
 Tm-170
 Tm-171

 U-230
 U-231
 U-232
 U-233
 U-234

 U-235
 U-236
 U-237
 U-238
 U-239

 U-240
 V-48
 V-49
 W-181
 W-185

 W-187
 W-188
 Xe-122
 Xe-123
 Xe-125

 Xe-127
 Xe-129m
 Xe-131m
 Xe-133
 Xe-133m

 Xe-135
 Xe-135m
Xe-138
Y-86
Y-87
                 E-5

-------
APPENDIX E - LIST OF NUCLIDES IN COMPLY
     Y-88
     Y-90
     Y-90m
     Y-91
     Y-91m

     Y-92
     Y-93
     Yb-169
     Yb-175
     Zn-62
Zn-65
Zn-69
Zn-69m
Zr-86
Zr-88

Zr-89
Zr-93
Zr-95
Zr-97
                   E-6

-------
APPENDIX F -
DETERMINATION OF DISTANCES BETWEEN
RELEASE POINT AND RECEPTOR WHEN BOTH ARE
ON THE SAME BUILDING
When both the release point and the receptor are on the
same building, the distance between them is measured
along the building surface as shown in Figures F-l(a)
and F-l(c).  It should be the minimum distance, and the
easiest way to determine it is to unfold the surfaces as
shown in Figures F-l(b) and F-l(d).  The obvious path is
not always the shortest (see page 181 of KASNER56);
however, the difference between the obvious and shortest
paths is small and can be neglected.
                          F-l

-------
      Rgure F-1 - Measuring Distances on Bulldihg Surfaces
(a)
(b)
(c)
(d)
I   X'
                            F-2

-------
             APPENDIX G - METEOROLOGICAL MODEL

 G.I  Levels 2 and 3

 The meteorological model for levels 2 and 3 is the same
 as that used in NCRP Commentary 3  (NCRP89).  It is
 described below.

 The method for calculating the air concentration at the
 receptor's location x meters from the source depends
 upon the configuration of the stack and the location of
 the receptor relative to the building.  There are two
 main subdivisions—one for tall stacks and one for short
 stacks where building wake effects are important.

 G.I.I  Tall stacks (H > 2.5hb)

 If the release is from a stack whose height,  H (m),  is
 more than 2.5  times  the building height,  hb (m), then
 the following  equation is used even if the source  and
 receptor are on the  same building:

    C = fQP(x,H)/u,

 where f is  the  fraction of  the  time the wind blows from
 the source  to the receptor  (taken to be 0.25), Q is the
 release rate (Ci/yr), u is  the  annual  average wind speed
 (m/s),  and  P(x,H)  (nr2)  is defined by
 P(x. H) = (2 . 032/xaz) exp [-0.5(fl/a,)'2]
                                      (1)
where az = 0.06x(l + 0.0015x)-1/2, and x is the distance
between the source and the receptor (m).  The equation
                           G-l

-------
for  3D)
                                                  (3)
when the distance between the source and receptor is
greater than three times the diameter of the stack.

The distance, x,  is the shortest distance between the
source and the receptor measured along the building
surface.  (See Appendix F.)
                              G-2

-------
 G.I.2.2  Source and receptor not on same building

 If the source and receptor are not on the same building,
 then either,
C=0 .
                      (x < 2 .
                                      (4)
 when x is less than or equal to 2.5 times the square
 root of the building area,  Ao(m?).  In the above
 equation,   K - 1 meter,  or/
  C = fQB/u     (x> 2.5A|/2)
                             (5)
 when x is greater than 2.5  times the square root of the

 building area.     B = 2.032/(xJ^ j  ,  and
The concentration at farms producing various  foods  is
calculated the same way.  The distance, x,  in this  case
is the distance from the source to the farm.  If the
user specifies that the food is produced at home, x for
the farm is the same as the distance from the source to
the receptor.

G.2  Level 4

G.2.1  Differences Between Level 4 and Levels 2 and 3

At level 4, the method is almost the same as given  above
for levels 2 and 3.  There are four differences.

The first is that f and u may be supplied by the user
                           G-3

-------
for each of 16 sectors around the release point (a wind
rose).  (The user must also supply the distance to the
closest receptor in each of these sectors.)  If the user
does not choose to supply a wind rose, then f is taken
to be 0.25 just as at levels 2 and 3.  If there is a
wind rose, the code searches the sectors to find the
receptor exposed to the highest concentration.

The second difference is that plume- rise (momentum or
buoyant) is accounted for.

The third difference is that the code uses the
user-supplied distance to the farms producing
vegetables, milk, and meat in the sector having the
maximum value of f/u to estimate the concentration at
each farm.  If the user specifies that the food is
produced at home, then the concentration is that at the
location of the receptor, just as for levels 2 and 3.

The fourth difference is that, with the receptor on the
same building as the source, the air concentration is
the smaller of either:
     C = 0.1Q/V, or
     C = 30Q/(ux2)
                          (6)
when the receptor is more than three stack diameters
from the source  (See WILSONS2, page 2640).

6.2.2  Plume Rise

Plume rise is used only when the stack height is greater
                           G-4

-------
 than 2.5 times the building height  (no building wake
 effects) .  The larger of momentum or buoyant plume rise
 is used, not their sum.

 Momentum plume rise is estimated using a simplified
 method based on the equations in BRIGGS84.  The momentum
 flux,  Fm,  is given by BRIGGS84 (the equation following
 Briggs' equation 8.36); i.e.,
   "» = PsVslV(3.14pa),
                        (7)
 where wg is the stack velocity and p, and ps are the  air
 and stack gas densities.
 Equation 8.99 of BRIGGS84 is as follows:
  AA = 0 .93 [Fa / (P2tfu.) ] a/? (hs+Ah) if'
                                     (8)
 where U is  the  mean wind  speed (with a wind rose

  u=jLfiui i where f  is the frequency and u the wind

 speed for direction i), u. is the friction  velocity
 (taken  to be  U/12 per  BRIGGS86),  hs the stack height,
 and Ah  the  plume rise.

 This  equation must  be  solved iteratively.  However, by
 using equation  8.100 of BRIGGS84  to  approximate the  h

 on the right  hand side  [A=0 .9 (D/uJ 1/2F^/2/ (ptf) ]  ,  we can

 circumvent  the need  for an iterative solution.   By using
0= 0.4 + 1.2/R as suggested  in BRIGGS84,  and  assuming
that U/u. =12 (a moderately conservative value, from
BRIGGS86),  then equation  (8) becomes
                           G-5

-------
      .93 [75Fffl/ C (1+
                          3/7
(9)
Buoyant plume rise  is  estimated using a simplified
method suggested  in BRIGGS84  and based on the equations
given in that study.

The buoyant flux, Fb,  is given by the  equation following
equation 8.35 of  BRIGGS84;  i.e.,
where g is the  acceleration of gravity (9.81 m/s)
Equation  8.97  of  BRIGGS84 is as follows:
 AA-1.2 [F.YE7U.2) ]3/5 (hs+AA)2/5
                              .  (ID
Assuming that U/u. = 12 as above,  and  assuming for the
moment that hs on the right hand side  is  0,  then
 Ah = (23.7)5/3F,./C73 = 195Fb/C73
                               . (12)
Using this  approximation for  Ah on the right hand side
of  equation (11)  leads to
 AA-23.7EFJ, C7]   (hs+19SFb U       ^ ^^
The effective stack height,  heff/ is h.  + Ah,  where Ah is
the larger  of momentum or buoyant plume rise.
                            G-6

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                APPENDIX H - DOSE CALCULATIONS

 The dose calculations for levels 2 and 3 are the same as
 those used in NCRP Commentary 3 (NCRP89).  At level 4,
 the methods are generally the same, but there are some
 differences.  The contribution of daughter radionuclides
 to the dose from external exposure is handled internally
 by the program, rather than being built into the dose
 factors.   Build-up of daughters in the food chain is
 also calculated by the program instead of being
 compensated for in the dose factors.   In the ensuing
 discussion,  the differential equations are solved using
 the method described in SKRABLE74.

 The air concentration for estimating  the exposure from
 immersion and inhalation is handled as follows:   The
 concentration of the parent,  Nt, is calculated from,
          "Al
   dt
where NA1 is the concentration of parent atoms,
 (=cair/^i) / and Cgj,. is the concentration of parent
calculated  from C^  =  Q(C/Q).

The daughter concentration is,
The initial condition is N;  =  0  at  t  =  0.   The  equations
are solved for t = T, where T is the transport time from
the source to the receptor  (= x/u) where x is the
distance and u the average wind speed.

The concentration of daughters contributing to the dose
                          H-l

-------
from exposure to contaminated ground was estimated as
follows :
where v is the deposition velocity and Xw is the
environmental removal constant.  All the concentrations
are zero initially.  The equations are solved for
t - 100 y.

Grow- in of daughters in the food chain is accounted for
as follows:  The concentration on the leaves of plants
is given by,
Because Y = m/A, this becomes,
  dN,
    XI,
   dt
and the  equations  for the daughters are,
where K is  the plant mass  growing  on  area A,  fr is the
retention fraction,  )^ the weathering constant, and Y
the biomass per unit area  at harvest.   The  initial
concentrations are all  zero.  These differential
equations are solved for the N's at t = te,  the length
of the  growing season.   The N's are converted to
activity by the
                           H-2

-------
 equation C-
 The concentration in the soil available for uptake by
 the roots of the plants is given by,
        dt
                               *Ri
where M is the mass of soil in the root zone,  A the
surface area of soil on which radioactivity deposits,  v
the  deposition velocity,  and Xw the removal  constant for
harvesting and leaching.   Because  P (the areal density
of the root zone)  is equal to M/A,  equations become,
       dN0j^
                           \ ,VM
   dt
The concentration in the plant is simply
and the total concentration is the sum of the leaf and
soil uptake concentrations.  The equations are solved
for t = 100 y time for build-up, and the N's are
converted to activity by
After harvest, slaughter, or milking, the parent and
                          H-3

-------
daughter nuclides behave according to
       dt
  dN^
   dt
The initial values are the values at the end of the
growing season.  The times are the delay times for the
vegetables, meat and milk.  Note that the concentrations
are assumed to be constant from the time that the animal
eats the forage until it is milked or slaughtered.

These concentrations are used with the pathways
equations in NCRP Commentary No. 3 to calculate intake
and dose.  The sources for the dose conversion factors
are EPA88  (internal) and DOE88  (external).  The soil to
plant concentration ratios and animal product transfer
factors are from the sources in NCRP Commentary No. 3.

Tritium and carbon-14 at level 4 are treated slightly
differently than in NCRP Commentary No. 3.  The NCRP
approach assumes that the specific activity of carbon-14
and tritium are the same in the food as in the
atmosphere.  We used a similar approach, described in
BAKER76.  Instead of assuming that the specific activity
of tritium is the same in the food product as in the
atmosphere, however, the BAKER76 method accounts for
some dilution by nontritiated water.  In addition, we
used the BAKER76 equations directly, rather than using
transfer factors.

Wet deposition is treated as follows.  According to
IA82, the washout factor, W  (1/m2),  is given by
                           H-4

-------
 where N is the number of sectors, c is a factor equal to
 l.SxlO-5 (particulates)  or 1.2xlO'5 (iodine)  yr/mm-sec, R
 is the rainfall rate in sector i, m/yr, Xj the distance
 from the source to the receptor, and Uj the annual
 average wind speed.

 We define the "wet deposition velocity," Vw as
 Vw
 where Aw  is the  flux of the material  deposited on the
 ground (ci/m2-sec) and C the air concentration (Ci/m3)
 The flux  is given by
   = QW
where Q  is  the  annual  average  release rate.
Combining these equations,
The total deposition is then the sum of the wet  and  dry
deposition velocities.  The precipitation rate is taken
to be 1 meter per year.

The only other difference between level 4 and level  3 is
the values of the parameters.  The values used at level
4 are those from EPA79 (AIRDOS-EPA) and EPA83.   Table
H-l compares the two sets of values.
                          H-5

-------
                         Table H-1.  Parameters used in NCRP and COMPLY
Symbol              Definition

RMCONR      Removal constant, 1 /yr
DEPTIM       Period of long-term buildup in soil, yr
VDEP         Deposition velocity, m/day (noble gases)
VDEP         Deposition velocity, m/day (iodine)
VDEP         Deposition velocity, m/day (particles)
FRVEG        Fraction  of activity intercepted
              & retained (veg)
FRMLK        Fraction  of activity intercepted & retained
              on forage or feed (milk)
FRMEA        Fraction  of activity intercepted & retained
              on forage or feed (meat)
TWEATH      Weathering half life, days
TEVEG        Period of above-ground exposure, days {veg)
TEMLK        Period of above-ground exposure, days (milk)
TEMEA        Period of above-ground exposure, days (meat)
YVEG         Edible crop per sq m at harvest, kg/sq m (veg)
YMLK         Edible crop per sq m at harvest, kg/sq m
              (milk)
YMEA         Edible crop per sq m at harvest, kg/sq m
              (meat)
PVEG         Areal density of effective root zone, kg/sq m
PMLK         Areal density of effective root zone, kg/sq m
PMEA         Areal density of effective root zone, kg/sq m
QMLK         Feed or forage consumption rate, kg/day (dairy)
QMEA        Feed or forage consumption rate, kg/day (meat)
QWMEA      Water consumption by dairy cow, kg/day (dairy)
                                                                    NCRP
             COMPLY*
0.01
30
0
1000
1000
0.25
0.25
0.25
14
60
30
30
2
0.015
100
0
860
210
0.1**
0.18**
1.8**
12
60
30
30
1.0**
0.12
1.0*
0.12
200
200
200
16
12
N/A
1.0**
220
220
220
16
12
60
  *Taken from EPA89a
  **Value of FR at Level 4 of COMPLY represents the ratio of Fr/Y.
                                              H-6

-------
      Table H-l.   Parameters used in NCRP and COMPLY (continued)
Symbol            Definition

QWMEA   Water consumption by beef cattle, kg/day
CH20    Concentration of water vapor in atmosphere,
        kg/m3
CCARB   Concentration of carbon in atmosphere, kg/m3
FHVEG   Fraction of hydrogen in vegetables
FHMEAT  Fraction of hydrogen in meat
FHMILK  Fraction of hydrogen in milk
FHFEED  Fraction of hydrogen in animal feed or forage
FCVEG   Fraction of carbon in vegetables
FCMEAT  Fraction of carbon in meat
FCMILK  Fraction of carbon in milk
CVEG1   Human vegetable consumption, kg/yr
CMILK1  Human milk consumption, kg/yr
CMEAT1  Human meat consumption, kg/yr
BREATH  Breathing rate, m3/yr  (cannot now  be
        changed)
DELVEG  Delay time, harvest to consumption, days
DELMLK  Delay time, milking to consumption days
DELMET  Delay time, slaughter to consumption, day
NCRP COMPLY
 N/A
50
u*
u*
u*
u*
u*
u*
u*
u*
u*
200
300
100
8000
1
2
7
0.008
1.6E-4
0.1
0.1
0.11
0.07
0.09
0.24
0.07
70
160
75
8000
11
2
17
          *Unknown-value not given in NCRP Commentary No.  3
                                 H-7

-------

-------
   APPENDIX I   RESOLVING PROBLEMS AND CONTACTING THE EPA

 I.I EPA CONTACTS

 If you do not understand any steps or have trouble with
 any of the calculations described in this document,  you
 should contact the Program Manager at your regional EPA
 office.   You should also contact the Regional Program
 Manager if you are unable to demonstrate compliance at
 level 4 of the COMPLY code.   EPA Regional Offices are
 depicted in Figure l-l.   A list  of the regional  EPA
 Regional Program Managers and their telephone numbers is
 included as Table  1-1.

 While most facilities will be able to demonstrate
 compliance by one  of the levels  described in  this report,
 if none  of these levels  works for your facility,  you
 should contact the EPA Regional  Program Manager  at your
 regional EPA office to determine the  next step.

 1.2 SOURCES

 NCRP  Commentary No.  3 may  be  obtained  from the National
 Council  on Radiation Protection  and Measurements,  7910
 Woodmont Avenue, Bethesda, Maryland 20814.  The telephone
 number is  301-657-2652.

Additional  copies of the guidance document for compliance
with 40 CFR 61,  Subpart I, or the User's Guide for the
 COMPLY Code and  5 I/4-inch diskettes containing the code
and all the data files can be obtained from:
        Program Management Office   6601J
        Office of Radiation and Indoor Air
        Environmental Protection Agency
        401 M St., SW
        Washington, DC  20460.
                           1-1

-------
        Figure 1-1  EPA Regional  Offices
Regions
 4 — Alabama
 10-Alaska
 9 — Arizona
 6 ~ Arkansas
 9 — California
 8 - Colorado
 1 -- Connecticut
 3 - Delaware
 3 - D.C.
 4 - Florida
 4 ~ Georgia
 9 — Hawaii
 10-Idaho
 5 - Illinois
 7 — Iowa
 7 — Kansas
 4 — Kentucky
 6 - Louisana
Regions
  1 - Maine
  3 - Maryland
  1 — Massachusetts
  5 — Michigan
  5 - Minnesota
  4 - Mississippi
  7 - Missouri
  8 - Montana
  7 - Nebraska
  9 - Nevada
  1 - New Hampshire
  2 - New Jersey
  6 - New Mexico
  2 - New York
  4 - North Carolina
  5 - Ohio
  6 — Oklahoma
  10 — Oregon
Regions
  3 - Pennsylvania
  1 •- Rhode Island
  4 - South Carolina
  8 - South Dakota
  4 - Tennessee
  6 - Texas
  8 - Utah
  1 - Vermont
  3 - Virginia
 10 - Washington
  3 - West Virginia
  5 - Wisconsin
  8 - Wyoming
  9 - American Samoa
  9 - Guam
  2 - Virgin Islands
                            1-2

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          Table I-l.  EPA Regional Program Managers
                                              Telephone No.
Tom  D'Avanzo
Radiation Program Manager, Region 1
Environmental  Protection  Agency
John F. Kennedy  Federal Building /  ATR
One  Congress Street
Boston, MA  02203
 (617) 565-4502
Paul A Giardina
Radiation Program Manager, Region 2
Environmental Protection Agency
Jacob K. Javits Federal Building  /  1005A
26 Federal Plaza
New York, NY  10278
(212) 264-4110
Lewis Felleisen
Radiation Program Manager, Region 3
Special Program Section
Environmental Protection Agency
841 Chestnut Street / 3AT12
Philadelphia, PA  19107
(215) 597-8326
Chuck Wakamo
Radiation Program Manager, Region 4
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, GA  30365
(404)  347-3907
Jack Barnett
Radiation Program Manager, Region 5
Environmental Protection Agency
77 West Jackson Blvd. / AT18J
Chicago, IL  60604-3507
(312)  886-6175
Donna Ascenzi
Radiation Program Manager,  Region 6
Air Program Branch (6T-E)
Air, Pesticides and Toxics Division
Environmental Protection Agency
1445 Ross Avenue
Dallas, TX  75202-2733
(214)  655-7224
                            1-3

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  Table  5-1.   EPA Regional Program Managers  (continued)
                                              TelephoneNo.
Gale'A. Wright
Radiation Program Manager,  Region 7
Environmental Protection Agency
726 Minnesota Avenue
Kansas City, KS  66101
(913)  551-7681
Milton W. Lammering
Radiation Program Manager, Region 8
Environmental Protection Agency
Suite 500
999 18th Street
Denver, CO  80202-2405
(303)  293-1440
Michael S. Bandrowski
Radiation Program Manager, Region 9
Environmental Protection Agency
75 Hawthorne Street  (A-l-1)
San Francisco, CA  94105
(415)  744-1048
Jerry Leitch
Radiation Program Manager, Region 10
Environmental Protection Agency
1200 Sixth Avenue, Mail Stop AT-082
Seattle, WA  98101
(206)  442-7660
                            1-4

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