CAP88-PC is an Environmental Protection Agency (EPA) code approved for demonstrating compliance with National Emission Standard for Hazardous Pollutants (NESHAP), 40 CFR Part 61. A detailed look at the dose methodology for tritium revealed that there are several inconsistencies in the ingestion model when compared with the ingestion model for other radionuclides within the code. The inconsistencies include use of an out-dated tritium ingestion dose conversion factor and hard coding of outdated food consumption parameters for tritium. Correction of these values could result in approximately a 50% reduction in dose from tritium for certain cases.
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