EPA 520/1-89-029
 USER'S GUIDE FOR THE COMPLY-R CODE


            (Revision 1)
U.S.  ENVIRONMENTAL PROTECTION AGEKCY
    Office of Radiation Programs
         401 M Street, S.W.
        Washington, DC 20460
            October 1989

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               "UNITED STATES ENVIRONMENTAL           AGENCY
                             WASHINGTON, D.C. 20460

                                                              OPRCE OF
                                                            AIR AND RADIATION
MEMORANDUM

SUBJECT:  COMPLY-R Computer Program for Determining Compliance
          with 40 CFR 61, Subpart B

FROM:     Albert Colli, Environmental Engineer  oM^Cv&U
          Environmental Standards Branch

TO:       Milton W. Laumering
          Radiation Program Manager, Region 8

     Enclosed is an updated version (1.2) of COMPLY-R and its
user's guide to be used to determine compliance with 40 CFR Part
61, Subpart B.  We have included a sufficient number of copies to
distribute to owners or operators of underground uranium mines in
your region to replace version 1.0 of COMPLY-R.  The first
version does not completely account for the in-growt:h of
daughters from the point of release to the receptor.  This has
been revised in version 1.2.

     In addition, the instructions for entering a stack distance
file are unclear in the first version.  We have modified version
1.2 of COMPLY-R and its user's guide to make the program and
instructions as clear as possible.

     Several changes have been made to the User's Guide for
COMPLY-R.  On page 3-6, line 11 of paragraph 3, the words "TO"
and "FROM" have been reversed and the sample problem has changed
slightly.  Also, we have added "exit" before "diameter11 on page
3-5, paragraph 2, line 1, because of comments pointing out that
the vent diameter should be more properly taken at the exit of
the vent.  We have also updated the names and           of some
of the regional program managers.

     We have enclosed sufficient numbers of COMPLY-R and its
user's guide for you to distribute to owners or operators of
underground uraniura nines in your region.  The revised version of
the User's Guide to COMPLY-R has been entered into the docket.
Please call me at 475-9610 if you need any additional
information.
cc;  Terrenes A. Mclaughlin
     Barbara Durso

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                     TABLE  OF  CONTENTS

Section                                                 page

1.0  INTRODUCTION                                       1-1

2.0  HOW TO SET UP YOUR SYSTEM                          2-1
     2.1  Making a Working Copy                         2-1
     2.2  Running the COMPLY  Program                    2-2
     2.3  Output                                        2-2

3.0  DETAILED INPUT  GUIDANCE                            3-1
     3.1  Overview                                      3-1
     3.2  Format for Entering Numerical Values          3-2
     3.3  Beginning  Message                             3-2
     3.4  Output to  Printer or File                     3-2
     3.5  Title                                         3-3
     3.6  Title Page                                    3-3
     3.7  Number of  Release Points                      3-3
     3.8  Release Rates                                 3-4
     3.9  Release Height                                3-4
     3.10 Vent Diameter                                 3-5
     3.11 Volumetric Flow Rate                          3-5
     3.12 Distance from Source to Receptor              3-5
     3.13 Vent and Air Temperatures                     3-5
     3.14 Wind Speed                              •      3-6
     3.15 Wind Rose                                     3-6
     3.16 Multiple Release Points                       3-11

4.0  OUTPUT                                             4-1

REFERENCES                                              5-1
                           ill

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              TABLE OF CONTENTS  (continued)

Sectj.on . _                                               Page

Appendix A - How to Handle  Errors                       A-I

Appendix B - Sample Problems                            B-l

Appendix C - Obtaining and  Organizing  Wind  Rose  Data    C-l

Appendix D - Suitability of Wind Rose  Data  from         D-l
             an Offsite Location

Appendix G - Meteorological Model                       G-l

Appendix H - Dose Calculations                          H-l

Appendix I - Resolving Problems and  Contacting          1-1
             the EPA

                     LIST OF FIGURES

No.                                                    Page_

C-l         Sample Graphical Wind Rose                 C-5

1-1         EPA Regional Offices                       1-2

                      LIST  OF  TABLES

No.                                                    Pag£

3-1         Abbreviated Sample Wind Rose               3-10

C-l         Sample Wind Direction Versus wind          C-6
            Speed Tabulation

C-2         Sample STAR Data                           C-7

C-3         Sample STAR Data                           C-8

C-4         Tabular Form of Graphic Wind Rose          C-9

C-5         Average Wind Speeds for Each Class         C-9

C-6         Wind Rose Data  Suitable for Use  in         C-10
            the COMPLY Code

C-7         Form for Wind Rose Data                    C-ll

1-1         EPA Regional Program Managers              1-3

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       ~*           1.0  INTRODUCTION

The COMPLY-R computer program may be used to demonstrate
compliance with the National Emission Standards for Hazardous
Air Pollutants (NESHAPS) in 40 CFR 61, Subpart B.  The
program can be used by owner or operators of underground
uranium mines to determine the dose to the maximally exposed
individual from Radon-222 emissions,

At all levels, the program will determine whether you are in
compliance or whether you exceed the standard.  The program
is designed to be easy to run and requires only minimum
input.  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 EP&89, is all that you need to
send to the EPA if you are required CD report,
                           1-1

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              2.0   HOW  TO  SET  UP  YOUR SYSTEM

COMPLY requites an  IBM PC or  PC-compatible  computer  having at
least 512  kilobytes  of memory/ at  least  one floppy disk drive
and a printer,  A  hard disk makes  the  system easier  to  run.
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  ap  this way,  you  will
have to adapt these instructions accordingly,

The program is on one  360 kilobyte diskette  marked CGMPLY-R,
If you have a hard disk,  put  the COMPLY-R diskette in drive
A, type copy A;*.* C:  and press Enter.   This will  result in
the program and all the data  being copied onto  the hard disk,

If you have two floppy  disk drives but do not have a hard
disk,  put the COMPLY-R  diskette in drive A  and  a  blank
diskette in drive B.   Use the DOS  DISKCGPY  command to copy
all the information on  the original diskette to the blank
diskette:

    DISKCOPY A;  B:
                           2-1

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2.2  RUNNING THE COMPLY PROGRAM
    ~

If you are not using the hard disk,  place  your  copy  of  the
COMPLY-R diskette in drive A.

You start the program by typing COMPLY-R and pressing 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.

2.3  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.
                           2-2

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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 
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0,012 you may  type  0.012,  .012,  1.2e-2,  1.2E-2,  or  1.2-2.
    +z
    NGTE;r~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  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 PILE

The program first asks  you  whether you wish to have your
                           3-2

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output sent airectly  to  the printer  or  stored  in  a  file  or, 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.

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  tide 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  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 how
                           3-3

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many  release points  (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  3.16,  Multiple Release  Points.)

Each  release point in a  problem is  treated  individually;  that
is, you must supply the  release rates, release  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).

3.8   RELEASE RATES

The program next  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.  When the release  rates have been  specified  for  each
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.

3.9  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 vent parameters if you  have
more than one  vent.  The release height  is  the  elevation  view
distance (in meters)  from the ground to  the  point of  release.
                           3-4

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If you specify a release height other  than  zero,  the  program
will ask you about the configuration of  the  vent.   If  the
vent is"not vertical or the flow is impeded  by  a  restriction
such as a rain cover, momentum rise will  be  zero.

3.10 VENT DIAMETER

You may or may not be asked for the inside exit diameter  (in
meters) of the vent.  This number is needed  only  if tne
release height is greater than zero.

3.11 VOLUMETRIC FLOW RATE
You may be asked for the volumetric flow rate from  the  vent
[cubic meters per second {m /s}].  The logic of when you
are asked for this is the same as for the vent diameter.  To
                                      3          3
convert from cubic feet per minute (ft /min) to ra /s,
multiply ft /rain by 4.7xlO™4.
3.12 DISTANCE FROM SOURCE TO RECEPTOR

This is the straight-line distance  (in meters) from the
source to the nearest receptor measured along the ground.   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 3.15.

3.13 VENT AND AIR TEMPERATURES

If the vent height is greater than  zero, the program will ask
you for the annual average outside  air temperature in degrees
F. This has a default value of 55 °F.  The program will
then ask for the vent temperature in degrees F.  This, too,
                           3-5

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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.   The  vent  temperature must  be
equal to or greater  than  the  air  temperature,

3.14 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 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,

3,15 WIND ROSE

A wind rose is a table showing how frequently the  wind blows
from a given direction with a given  speed.  You will be asked
if you wish to put in a wind  rose.   If you do not  choose co
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.  You may
put these distances in from the  keyboard  (following the
instructions on the screen) or you may 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.
                           3-6

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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
B:STKDISK.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 onsite 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 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
                           3-7

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wnen supplying the wind  rose  data.   Before  you  start  the
problem, check to make sure  that your  wind  cose  data  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 roust 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. Source of the data,
  2. Dates covered
  3. 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).

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
                           3-8

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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 knotsf 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  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  cairns) must
        be  between 0.99 and 1.01,
                           3-9

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  o     All the wind  speeds  must  be  greater  tnan O.I
        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  dcive).
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:WINBROSE.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 tun a problem  and tell the  computer  you want to  use
a wind rose file, the program will as,k 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 example,  if the
default drive  is drive  C and the  wind rose file  is called
ROSIE.DAT on drive B,  you would type  B:RQSIE.DAT.

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

       Table 3-1.  Abbreviated  Sample Wind Rose
Wind
FROM
Calm
' N '
'MNE1

Frequency
0.063
0,022
0.034
Speed
m/s

2,1
3.2
                             0.042     2.5
                           3-10

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whether you enter  the  wind  cose  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  yesf  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.

3.16 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,

3.16.1  MULTIPLE RELEASE  POINTS WITH NO  WIND  ROSE

Ogtion _1.  If you are  not using a  wind rose,  you may run
multiple vents 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 over-estimate 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.

Oj?tion^2. The other option  is  to run  N separate problems  if
there are N release points, and use  the  multiple vent
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.
                           3-11

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    Release                      Receptor
     Point                 a         b
       I"                D(xla)     D(xlfa)    D(xlc
       2                 D(x2a}     D(x2b3    D{x2c
       3                 D
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i.  Run a single-vent 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 vent 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 release point to  receptor  1 to
   a very large number (we suggest 10  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 the release point to receptor 1.
   Then run this problem using the multiple stack  option.
   This gives you the dose to receptor 1  from  all  the release
   points,

3.  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.
                           3-13

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                       4,0  OUTPUT

The output is self-explanatory.   The  input  is  printed  out
just as you entered  it.

If you elected to have the output sent  to a  princer,  it  will
appear there automatically.   (You must  have  the  printer
turned on,}  If you  choose 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:MYQUT

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
pc inthead.  Then type

   PRINT AlMYGUT

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

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                        REFERENCES

BRIGGS84, Briggs, G.A.  "Plume Rise and  Buoyancy  Effects,"  in
^tmgjsph er i_c Sc i e nee a_nd powej: 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,

EPA89, "A Guide for Demonstrating Compliance with the  Clean
Air Act Standards for Radionuclide Emissions from
NEC-Licenced and Non-DOE Federal  Facilities,"
EPA 520/1-89-002, October 1989.

EVANS8G,  "Engineer's Guide to the Elementary Behavior  of
Radon Daughters," Evans, D.E,, Health Physics, 3B, 1173-1199,
1980.

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

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

UNSCEAR77, "Sources and Effects of Ionizing Radiation,"
United Nations Scientific Committee on  the Effects of  Atomic
Radiation, Report to the General Assembly, United Nations,
New York, 1977.
                           5-1

-------
             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. MACHI_NE^pOES 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.
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.   The
program allows you to enter numerical  values in a number of
different ways.  For example, to enter 1400 you may type
                           A-l

-------
    .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. --

    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.

3.  ERROR MESSAGED "I canjt find (file name).   It's not 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,

    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.  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 WINDROSB.DAT and is on drive
    B, then you must enter B:WINDRQSE.DAT when the machine asks
    you for the file name.
                               A-2

-------
4 .  ERROR MESSAGE FOR PI STANCE OR WIND ROSE FILE:___
   (aj   "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 PROBLEM

The sample problem that follows is intended  to  show  the
output from CQMPLY-R and how the program calculates  dose
                           B-l

-------
40 CFR Parr 61
National Emission Standards
for Hazardous Air Pollutants
                    REPORT ON COMPLIANCE WITH

        THE CLEAN AIR ACT LIMITS FOR RADIONUCLIDE EMISSIONS

                FROM THE COMPLY-R CODE, VERSION 1.2
                Prepared byi

                ABC ENERGY INC.
                NICE MINE
                SOMEWHERE,  CO

                JOHN DOE
                (555) 555-5555
                Prepared for:

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

-------
          Release Rate
 Stack    (curies/YEAR)

    I ~      S.OOOE-t-03
    2       2.0QQE-'-03
SITE DATA FOR VENT 1.

    Release Height  2.00 meters.

    Vertical momentum present for vent   1

    Vent diameter  2.50 meters.

    Volumetric flow rate is  40.000 cu m/sec,

   STACK DISTANCES, FILE; N
DIR
N
NNE
NE
ENE
E
ESE
SE
SSE
S
ssw
sw
wsw
w
ww
NW
NNW
Distance
(meters)
30000.0
25000.0
25000.0
25000.0
20000.0
20000.0
20000.0
20000.0
15000,0
15000.0
20000.0
20000.0
15000.0
20000.0
25000.0
30000.0
SITE DATA FOR VENT  2.

    R@l®ase Height   1.00 meters.

    Vertical momentum NOT present  for  vent    2

    Vent diameter   1.50 meters.

    Volumetric flow rate is   35.000  cu m/s©c.
                        B-3

-------
         DIR

         N
         NNE
         NE
         INE
         E
         ESE
         SE
         SSE
         S
         SSW
         sw
         wsw
         w
         WNW
         NW
         NNW
Distance
(meters)

 30000.0
 25000.0
 2 5 C 0 C . 0
 2 50 CO
 20000
 •20000
 20000
 20000
 15000
 15000,
 20000,
 20000,
 15000,
 20000.
 25000.
, 0
,0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 30000.0
WINDRQSE DATA, FILE; W

Source of wind rose data:
Dates of coverage:
Wind rose location:
Distance to facility:

Percent calm:  O.oi
wind
FROM

 N
 RNE
 NE
 ENE
 E
 ESE
 SE
 SSE
 S
 SSW
 sw
 wsw
 w
 WNW
 NW
 NNW
          GRAND JUNCTION
          5/£"-5/89
          GR,-.. D JUNCTION
          40
Frequency
0.054
0,081
0.113
0.053
0.071
0.043
0.047
0.038
0.145
0. 104
0.074
0,029
0.036
0.038
0.044
0.021
speed
(meters/s)
3.84
4.62
3.89
2.91
2.44
2.85
3,95'
4.86
4.83
5.18
4,91
4,21
4,01
5.54
5.03
4.69
                   B-4

-------
     Default  air  temperature  not used,
     Air  temperature   54.0  (degrees  F).

     Default  vent temperature used (55.0  degrees F) .  Vent; 1,

     The  receptor exposed to  the highest  concentration is located
         15000. meters to the W.  Vent  I.

     Default  vent temperature not used. Vent  2.
     Vent temperature   57.0  {degrees F) ,

     The  receptor exposed to  the highest  concentration is located
         15000. meters to the W.  Vent  2.
     Input parameters  outside  the  "normal"  range:

        None.
 RESULTS:


     Effective dose equivalent;         1.6 (mrem/year)

     Complies with emission standards.

     *** This facility is in COMPLIANCE ***

********** END OF COMPLIANCE REPORT **********
                              B-5

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

As noted'tn the  body  of  this  report,  there  are three possible
sources of  wind  rose  data:  (1)  onsite 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 onsite meteorological" tower, you must
get wind rose data from  another source.  See  Appendix D  for
guidelines as to what constitutes  acceptable  data.

For offsite 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 (35 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  cose.

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.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
                           C-2

-------
required  for  use  in COMPLY.   They  consist  of both tables-and
graghs.   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  Np  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,

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

-------
We first  sum  the  frequencies  in  each  sector  to  get  the
fraction  of time  the wind  blows  from  that  direction;  i.e.,
              • •
           •  13
           j
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.
where U. is the average wind speed  in  sector  i, and  u.  is
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 ,

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-4

-------
j  c
               ic "ind rose

-------
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416
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-------
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-------
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-------
    Table C-4. Tabular  form  of  graphical  wind rose
Sector
Calms
N
NNE
NE
ENE
E
ESE
SE
SSE
S
ssw
sw
wsw
w
WNW
NW
NNW
F
1
0-3 4
il . 8
4
2
2
2
3
3
3
2
4
3
5
6
5
4
3
2
requency Wind Speed is
234
Wind Speed, mi/h
-12 13-15 16-18
-
.3
.6
.7
.9
.6
.2
.6
,9
.4
.4
.2
.1
.7
.0
.6
.9
_
0.
0.
0,
0.
0.
0,
0.
0,
0.
0.
• 1.
2.
2.
1.
1.
0.

8
2
2
3
4
4
4
3
5
8
7
4
1
4
1
9

0
0

0
0
0
0
0
0
0
1
1
1
1
0
0
_
.2
.1
0
.1
.1
.2
.1
.1
.1
.5
,1
.9
.6
.2
.7
,4
in Class
5
19-24






0


0
0
0
1
0
0
0
0
-
0
0
Q
0
0
*
0
0
*
B
*
#
*
V
«
e






1


1
2
5
1
8
6
4
1
j, percen
6
25-31
-
0
0
0
0
0
0
0
• o
0
0
0.1
0.3
0.2
0.1
0.1
0
t
1
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
                               Average
      Class     Speed           Speed
      	Range	i	mi/h
        _        0-3 realm!       CaTrfT
        2        4-12             8
        3       13-15            14
        4       16-18            17
        5       19-24            21
        6       25-31            28
        7         32             32
                         C-9

-------
Table C-6t_Wind rose data suitable for use  in the
         ~ COMPLY code

                                  Average Speed
     Wind Prom	Frequency       mi/h      m/s
calm
N
NNE
NE
ENE
E
ESE
SE
SSE
S
ssw
sw
wsw
w
WNW
NW
NNW
Sum
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
0.999
	
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-10

-------
Table C-7.  Form foe wind cose data

Wind                       Wind
FROM      Frequency1      Speed2

CALM                  XXXXXXXXXXXXX

N

NNE

NE

ENE

E

ESE

SE

SSE

S

ssw

sw

wsw

w

WNW

NW

NNW

Total3
Notes:

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

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

In general, it is very  unlikely that  the  wind  cose daca from
somewhere else will exactly  duplicate  the weather  pdtcer,".5 at
your site.  Thus, you must find a location,  fairly close,  tnat
duplicates the conditions at your  location as  closely as
possible.  The factors  that  most  affect  the  wind speed and
direction are as follows:

 1 .  T he^elevat^o n r e^a t jlv e t o_t he _su r r o unding  area

   A location on a hill or plateau can have  different wind
   conditions than the  lower surrounding  area.
 2. ?c~e n c ep £ a
   A location in a valley can have  different  wind  conditions
   than the terrain around it.  The  wind  tends  to  channel
   through a valley,

 3. ^Pre^sence^^gf ji^lar_ge 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 ver sus ' rura1

   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  G  -  METEOROLOGICAL MODEL

The meteb'cological  model  is  similar  to  that  used in NCRP
Commentary  3  (NCRP89),  it  is  described below.

The air concentration is

   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 unless there  is a
wind rose), Q is the release rate (Ci/sec),  u is the annual
average wind speed  (m/s), H  is  the vent height  (m), and
P(x,H) (m~2) is defined by

   P(x,H) - {2.032/xCr }exp[-0.5(H/g;)2J,         (1)
                     &             Z
                             -1/2
where 7"_ =  0.06x(l  -»- O.OOlSx)     , and  x  is  the distance
       z
between the source  and  the receptor  (m).   The equation for
f is based  on neutral atmospheric stability  (Class  D).   The
<&
function P(x,H) is  zero at x -  0, rises to a  maximum at some
distance x__._, and  then declines  as  x is  increased  beyond
          Hicl A,
x   .  For  distances less than  xmax> p  is  taken to  be
       H)*  This produces a conservative  (over-estimate)  of
       centration at distances  less  than  *„,„ and leads to
                                           ma X
the curves  shown in Figure 3 of NCRP Commentary 3.

Plume Rise

Plume rise  is used  only when the  vent is  vertical and  has  no
rain protector or other impediment to flow.   The  larger of
momentum or buoyant plume rise  is used,  not their sura.

Momentum plume rise is estimated  using  a  simplified method
                           G-l

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 based  on the  equations in BRIGGS84U  The momentum flux, F ,
 is .given by BRIGGS84 (the equation following Briggs' equation
 8.36);  i.e.,

    Fm  = />  V/(3.14/*),                         (2)
     ID    h  S        a

 where  w  is the  stack velocity,  V the volumetric flow rate,
        w
 and  f*  and  f>  are the air and stack gas densities.

 Equation 8.99  of BRIGGS84 is as  follows:

                                          (3)

 where  U is  the mean wind speed (with a wind rose U =
Ef.u.f  where  f is the frequency  and u the wind speed for
 direction  i),  uft is the  friction velocity {taken to be 0/12
 per  BRIGGS86), h  the stack height, and &,h 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  [«h  =  0.9(U/u.)1'/2Fjs/2/(^ U) ], we can
 circumvent  the need for  an iterative solution.  By using ft =
 0.4  +  1.2/R (R=w /U) as  suggested in BHIGGS84, and assuming
                 o
 that U/u^  =12 (a moderately conservative value, from
 BRIGGS86),  then  equation (8) becomes
   Ah  =
 Q.93[75Fm/U+3/R)  IT]377  [ (h
     *»  IN           rf
                   U(l-f3/R}]1/7                    (4)
                            G-2

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Buoyant plume rise is estimated using a simplified  method
suggested in BRIGGS84 and based on the equations  given  in  tnat
study. ~

The buoyant fiux, F^, is given by the equation following
equation 8.35 of BRIGGS84; i.e.,

        Fb ~~ g(/*a * f3}V//°a                    (5)

where g is the acceleration of gravity (9.81 m/s).

Equation 8,97 of BRIGGS84 is as follows:

    Ah = l,2[Fb/{Uu^)]3/5(hs +^h)2/5.      (6)

Assuming that U/u* = 12 as above, and assuming for  the
moment that h  on the right hand side is 0, then
             o

    &h - C23,7)5/3Fb/U3 = 195Fb/U3  ,          (7)

Using this approximation for   h on  the right hand  side of
equation (11) leads to
           23.7[Fb/U3J3/5(hs + 195Fb/U3)2/5, (8)

The effective stack height, hef£» is hs + &h, where^h is
the larger of momentum or buoyant plume rise.
                            G-3

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                              APPENDIX  H  -  DOSE  CALCULATIONS




              The dose  from  radon  and  its  daughters  is  calculated  as


              follows:





              Dose = C  x 1012 x 1Q~3 x 10~2  x 8760/170  x  DF  x





                           [F.  ,     F,  +  (1-P.  ,    )  F   ,]
                              indoors   in        indoor   outj




              where   C =  radon concentration  at the  receptor,  Ci/m


                      1012 =    pCi/Ci





                      10"3 • m3/liter




                      1Q~2 -    Wl-liter/pci




                      8760/170 = Wl months/yr





                      F.      = fraction of  time spent  indoors  (0.75)
                       indoor




                      F,  «     indoor equilibrium fraction





                      F    = outdoor equilibrium fraction





                      DF = dose factor, 920  mrem-WLM





          The indoor equilibrium fraction is obtained from an outdoor


          equilibrium fraction,





                           1.0 - 0.0479 exp{-t/4.39) -  2.1963 exp(-t/38.6)





\ t/     ,               +1.2442exp(-t/28.4)
 >



 / '  .- '  . ,-v-     where t is the transit time in minutes.

     r .(

    If '  '




                                         H-l

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The above equation is based on the ingtowtn model of  EVANS8Q and
the alpha data of UNSCEAR77.

With t = 11.8 min, F  .  = 0.2 which is consistent with the
observed equilibrium fraction in mine vents.  Thus

    t = 11.8 + x/60u

where x is the distance to the receptor  (m) and u the annual
average wind speed (m/s).  Thus, the outdoor equilibrium fraction
at the receptor is 0.2 plus the increase that occurs  during
transit.

There is empirical evidence indicating that when there are no
radon decay products in ventilation air  the indoor equilibrium
fraction is 0,35, and when the decay products in the  ventilation
air are in equilibrium,  the indoor fraction is 0.70.  Thus,

    F.   = 0.35(1 + F  . ) ,
     in             out'
                               H-2

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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.  EPA
    Regional Offices are depicted in Figure 1-1,  A list of the
    EPA Regional Program Managers and their telephone numbers is
    included as Table I-rl.

    While most facilities will be able to demonstrate compliance
    by one of the methods described in this report, if none of
    these procedures works  for your facility,  you should contact
    the EPA 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  User's Guide for the COMPLY-R Code
    and 5 1/4-inch diskettes containing the code and all the data
    files can be obtained from;
                 Program Management Office   ANR-459
                 Office of Radiation Programs
                 Environmental Protection Agency
                 401 H St.,  SW
                 Washington,  DC  20460.
                               1-1

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                     ii P A  ?.e H i o n a *  0 f i i c6:
  -0&
I
                        1-2

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             Table  1-1.  EPA Regional Program Managers
                                                 Telephone  No.
Tom D'Avanzo
Radiation Program Manager, Region
Environmental Protection Agency
John F. Kennedy Federal Building
Boston, MA  02203
FTS;
COMM:
 617
835-4502
565-4502
Paul A Giardina
Radiation Program Manager, Region
Environmental Protection Agency
Room 1137-L
26 Federal Plaza
New York, NY  10278
FTS;
COMM:
(212)
264-4110
264-4110
Lewis Felleisen
Radiation Program Manager, Region 3
Special Program Section (3AM12)
Environmental Protection Agency
841 Chestnut Street
Philadelphia, PA  19107
FTS:
COMM:
(215)
597-9705
597-9705
Chuck Wakamo
Radiation Program Manager, Region
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, GA  30365
FTS:        257-3907
COMM: (404) 347-3907
Gary V. Gulezian
Radiation Program Manager, Region
Environmental Protection Agency
230 S. Dearborn Street (5AR26)
Chicago, IL  60604
FTS:        886-6258
COMM: (312) 353-2206
Donna Aseenzi
Radiation Program Manager, Region 6
Air, Pesticides and Toxics Division
Air Program Branch (6T-E)
Environmental Protection Agency
1445 Ross Avenue
Dallas, TX  75202-2733
FTS:        255-7223
COMM: (214) 655-7223
                               1-3

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             ?able I-I.  EPA Regional  Program Man
                                              Telephone No
Carl Walter
Radiation Program Manager, Region
Environmental Protection Agency
726 Minnesota Avenue
Kansas City, KS  66101
FTS:        276-7600
COMM; (913) 551-7600
Milton W. Lammering
Radiation Program Manager, Region 8
Environmental Protection Agency
Suite 500
999 18th Street
Denver, CO  80202-2405
FTS:
COMM:
(303)
            330-1713
            293-1713
Michael S. Bandrowski
Radiation Program Manager, Region
Environmental Protection Agency
215 Fremont Street, CA1-1)
San Francisco, CA  94105
FTS:
COMM;
(415
            556-5285
            556-5285
Jerry Leitch
Radiation Program Manager, Region 10
Environmental Protection Agency
1200 Sixth Avenue, (AG-082)
Seattle, WA  98101
FTS;
COMM
(206)
            399-7660
            442-7660
                               1-4

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