An evaluation of the effectiveness of the EPA comply code to demonstrate compliance with radionuclide emission standards at three manufacturing facilities

Measurements of airborne radionuclide emissions and associated environmental concentrations were made at, and in the vicinity of, two urban and one suburban facility where radiolabeled chemicals for biomedical research and radiopharmaceuticals are manufactured. Emission, environmental and meteorological measurements were used in the EPA COMPLY code and in environmental assessment models developed specifically for these sites to compare their ability to predict off-site measurements. The models and code were then used to determine potential dose to hypothetical maximally exposed receptors and the ability of these methods to demonstrate whether these facilities comply with proposed radionuclide emission standards assessed. In no case did the models and code seriously underestimate off-site impacts. However, for certain radionuclides and chemical forms, the EPA COMPLY code was found to overestimate off-site impacts by such a large factor as to render its value questionable for determining regulatory compliance. Recommendations are offered for changing the code to enable it to be more serviceable to radionuclide users and regulators