ML20033F703

Informs Commission of Progress of Metrication Activities in NRC

ML20033F703
Person / Time
Issue date:	03/21/1990
From:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
TASK-PII, TASK-SE SECY-90-106, NUDOCS 9003260294
Download: ML20033F703 (38)

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March 21, 1990 (Information) srcY-90-106 For:

The Commissioners From:

James M. Taylor, Executive Director for Operations Sub.iect:

REPORT ON THE PROGRESS OF METRICATION ACTIVITIES IN THE NRC Puroose:

The purpose of this report is to inform the Commission of progress made within the NRC in response to the provisions of the Omnibus Trade and Competitiveness Act of 1988 and the development of a draft NRC metrication policy statement.

Discussion:

In March 1989, a Metrication Committee composed of representatives from NRC's major offices was fomed to assess possible agency actions in response to the passage of the Omnibus Trade and Constitivess Act of 1988 whict among other things, stated that tge declared policy of the United States.is

• ... to require that each Federal agency, by e date certain and to the extent economically feasible by the end of the fiscal year 1992, use the metric system of measurement in its procurements, grants, and other business-related activities, except to the extent that such use is imprac+':a1 or is likely to cause significant inefficiencies or loss of markets to United States firms, such as when foreign competitors are producing competing products in non-metric units."

The work of this committee was completed in August 1989, and a report containing the cosmittee's findings and recessendations was submitted to the Director. Office of Nuclear Regulatory Research for review. A copy of the report is attached in response to a request from Consissioner Rogers' staff (Attach-ment 1). The report contains background information on activities both within and outside the agency relating to metrication and discusses how NRC licensing and regulatory functions might be affected by various options for conversion to the metric system. Mr. Beckjord has advised me that the report contair.s useful information in the development of a proposed policy statement. However, the report should not be taken as the staff's final recoseendation, as additional NOTE:

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The Comissioners 2

information is still being gathered and analyzed. However, several of the recommendations contained in the report are directed toward obtaining additional information, and these are being pursued by the staff. Specifically, the staff has (1) conducted a public workshop to solicit the views of the public and the nuclear industry. (2) formed a committee, the Metrication Oversight Comittee, composed of senior representatives from various offices to oversee metric conversion and to assume responsibility for preparing the annual report on NRC's metrication activities to Congress, (3) interacted with other government agencies (e.g., DOE and epa) and Agreement States to obtain their views, and (4) expanded the participation within the agency on addressing the metrication issue to include the regional offices. Other recommendations of the report are also being considered by the Metrication Oversight Comittee. These include the development of a draft policy statement for Comission approval specifying how the NRC intends to implement the Omnibus Trade and Competitiveness Act of 1988.

With respect to the first recomendation cited above, a workshop entitled "Public Workshop on NRC Conversion to the Metric System" was held on November 14 and 15,1989, at the Holiday Inn-Inner Harbor, in Baltimore, Maryland.' The workshop's purpose was to collect information that will assist i

the NRC in developing its policy and potential plans for j

converting certain of its activities to the metric system as required by the Omnibus Trade and Competitiveness Act of 1988, l

The workshop was attended by approximately 75 representatives j

of regulated industries, suppliers, State and local' governments, academia, the public, the NRC, and Federal departments.

Among the salient points expressed at the workshop was the view that because of the increased competitiveness of world l

trade and the present extent of international use of the metric system, conversion within the United States is underway and appears to be inevitable. Additionally, as corporations continue to change to metric units to maintain world-wide economic viability, the effects on interstate commerce within the United States may enhance the motivation for domestic conversion to minimize confusion.

It was also noted that students involved in the U.S. education system today are being

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taught in the metric system and will provide a near-term j

work force that is comfortable with metric units.

It was i

pointed out at the workshop that practically all new physics and engineering textbooks are written in metric units.

It was also noted while students are trained and capable of working in metric, they are often expected by employers to work in the conventional units. Speakers at the workshop

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also noted that the.later our country's conversion begins and the longer it takes, the more costly it will be.

With respect to the anticipated activities of the Metrication Oversight Comittee, its principal goal for the remainder of FY 1990 is the development of an NRC metrication policy statement for Comission consideration. A key element in, the development of this policy statement will be an analysis of the safety implications for NRC and licensee operations as well as costs and benefits of various mttrication options. The analysis will be provided to the Comission in support of the proposed policy statement.

Efforts will continue in FY 1990 and FY 1991 to collect additional information from outside the NRC, especially emphasizing the coordination of our work with

.those agencies having related responsibilities.

As a final point, the Office of Nuclear Regulatory Research provided the Office of the Controller in December 1989 with a letter response to the Congress on the status of HRC's metrication activities for the preceding year end piens for the coming year (Attachment 2).

The letter was included in

" Budget Estimates Fiscal Year 1991," NUREG-1100, Volume 6 January 1990.

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J s M. T or xecutive irector for Operations Attachments:

1.

Metrication Comittee Report Zoltan Rosztoczy, Chairman.

. August 16, 1989 2.

U.S. Nuclect Regulatory Comission Report to Congress on Metrication, January 1990 DISTRIBUTION:

Commissioners OGC OIG I

LSS GPA REGIONAL OFFICES EDO ACRS I

ACNW ASLBP

.ASLAP SECY l

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ATTACHMENT 1 t

METRICATION COMMITTEE REPORT August 16, 1989 Zoltan R. Rosztoezy Chairman O

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.i TABLE OF CONTENTS I

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SUMMARY

1 BACKGROUND...........................

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DISCUSSION...........................

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8 Option 1:

One-Step Conversion Option 2:

Gradual Conversion...............

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Option 3:

Partial Conversion............... 9 FINDINGS...........................

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RECOMMENDATIONS.......................18 REFERENCES..........................

19 TABLES:

Table 1--Summary of Options Considered.............

10 Table 2--Impact for Metric Conversion............

17 ENCLOSURES:

1 --Omnibus Trade and Competitiveness Act --Committee Members t --List of Activities and Schedule for Conversion W

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METRICATION COMMITTEE REPORT

SUMMARY

In March 1989, a Metrication Committee composed of representatives from NRC's majorofficeswasformed.

The Committee was charged with reviewing NRC activities for possible conversion to the metric system, and developing proposed schedules of activities to be converted.

The Committee completed its work in July 1989.

This report presents the Committee's findings and recommendations.

The Committee's findings ' indicate that the offices of NRR, HMSS, AEOD, and RES are most affected by any form of metric conversion and that immediate conversion of al$ NRC activities in the near future is impractical.

Instead, under the options discussed in this o

report, some gradual form of conversion is preferable.

In addition, the Committee recommended that NRC should solicit the views of the 1

Regional Offices, State and Local Governments, other Federal Agencies and the j

t regulated industry prior to submitting a proposed policy statement on metrication for Commission consideration.

BACKGROUND 1

Over the last 4 years, several concerns regarding metric conversion have q

arisen.

In a letter to the NRC Chairman dated January 29, 1985, the Secretary 1

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of Commerce requested help in en6uring that the Federal Government not restrict

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the voluntaty use of the metric system.1 The Office of Nuclear Regulatory Research, on February 25, 1985, responded to the Commerce request and stated the HC intention "to convert tn the estric system at a rate paralleling that being achieved by the industry we regulate.n2 This letter further described the intended use of either " dual dimensioning or $1 metric units alone, as appropriate, in all new or revised NRC regulations and publications."

Also in January 1985, the Committee on Interagency Radiation Research and Policy Coordination (CIRRPC) formed a Metrication Subpanel.

The Policy Subpanel was composed of representatives from eight Federal agencies and was established in order to fornulate and recomend a CIRRPC position on what U.S.,

po W y should be with regard to the use of the International System of Units (51) for radiation quantities and measurements.

The findings of the Policy Subpanel were issued in a report dated December 1986.3 In August 1987, the Office of Nuclear Reactor Regulation sent a letter to the General Electric Company (GE) which transmitted the "GE Advanced Boiling Water Reactor Licensing Reviw Bases."4 Section 3 of this document stated that the safety analysis report may contain metric units in describing the equipment dimensions and performance so long as English units were also included.

In September 1988, the U.S. Council for Energy Awareness (U$CEA), Committee on Radionuclides and Radiopharmaceuticals, sent a letter to NRC regarding the use of metric units.5 The Committee requested that NRC consider the possibility of using rounded whole numbers which have metric equivalence for package sizes.

This request was made because there are strong indications that by January 1, 1992, countries in the European Economic Community will convert from dual units 2

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to metric units cnly. When this is done, it, appears

• that users of radicactive materials will encourage suppliers to adopt rounded onits since this will be a J

j more convenient measure. The NRC responded in November 1988, stating that *NRC J

I does not now prohibit and does not intend to prohibit the use of $1 smits on i

any package labels "O The NRC also stated it would like to develop its t

j implementation program in response to (the Committee's] recommendations because I

the $1 units will likely eventually become the standard in the U.S. as well as j

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the rest of the world." Additionally, NRC would be willing to develop interim I

compliance guidance that would allow licensees whose possession limits are expressed in multiples of millicuries to receive materials packaged in i

l multiples of 40 megabecquerels."

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Prior to 1988, the United States was the only major industrialized nation that l

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was not fully committed to the metric system.

In August of 1988, Congress j

passed the Omnibus Trade and Competitiveness Act (Enc,1osure 1).

This Act l

l contains, among other things, a section on metric usade.

The Act designates l

l the metric system as the preferred system of weights and measures for U.S.

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trade and commerce and requires that, by the end of FY 1992, all Federal i

t agencies convert to the metric system of measurement in their procurements.

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grants, and other business-related activities except to the extent that such i

use is impractical. With respect to implementation of the 1988 Act, each l

agency of the Federal Government is required to establish guidelines to carry l

t out the policy set forth in the law. As part of its annual budget submission, j

l each agency is inttructed to report to Congress on the actions taken during j

l the previous fiscal year, as well as future actions to fully implement the r

metric system of measurement in accordance with that policy.

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To date, many major departments and agencies of the Feyeral Government have 1

taken steps to use the metric system in their daily activities, including procurement, consistent with Federal policy.

GSA has issued a Federal standard i

regarding metric units.7 For the purpose of this report, units referred to as

$1, metric, or $1 metric are in accordance with this standard. Also for the i

purpose of this report, the term "English units is used in a broad sense to i

indicate not only inch / pound units of measurement, but also other units j

i commonly used in the United States, such as curies.

l The Interagency Committee on Metric Policy (ICMP) was established under the j

auspices of the Department of Commerce to coordinate and provide policy guidance on metrication to the heads of all Federal agencies, The Committee is composed of representatives at the assistant secretary level from major Federal j

departments and agencies and is chaired by the Under Secretary of Commerce for j

Technology.

In addition, a Metrication Operating Com,ittee (M00) composed of l

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representatives from major Federal departments and agencies was formed to coordinate Federal interagency 1.M rication activities and to recommend policy l

guidance to the parent committee, the ICMP.

NRC has a rapresentative on both the ICMP and MOC.

In 1986, the ICMP issued a Metric Handbook for Federal Officials, conta'ning recommendations of the Committee regarding government use of the metric system.0 l

1 Currently there is no official NRC policy on metrication.

In the absence of such a policy, agency practices can constitute a de facto policy that may not be fully consistent with Federal legislation and guidance.

This guidance is of i

necessity generic in terms of its applicability to individual agencies and does not preclude the need for an agency policy.

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In late March 1989, NRC formed a Metrication Committee, consisting of representatives of all of the agency's major offices, to consider how the provisions of the Omnibus Trade and Competitiveness Act could best be implemented and to what extent it wc5 practical to implenent th6m in this agency.

A list of Committee members is provided in Enclosure 2.

The l

l Metrication Committee, in carrying out its aandate, had four areas of responsibility:

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Conduct a rev'ew of the various NRC activities and identify those that f all in the "procurements, grants, and other business-related activitie$"

t category addressed in the Trade Act and make a recommendation on which 2

activities would be practien1 to convert to the metric system; l

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Determine how NRC should implenient the conversion, decide what actions are I

needed for conversion with an appropriate schedul,e, and provide recommendations on a metric consersion plan; I

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Develop recommendations on the assignment of responsibilities, including coordir,ating responsibility for the metric conversion plan and preparation

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i of the annual report to Congress; and last, 4,

Consider the periodic review of the agency's progress as it relate ; to I

compliance with metric usage.

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DISCUSS 10N l

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8 The subject of metrication is complex, with many technical, safety, economic, stid political ramifications, However, the inevitability of such a conversion f

taems to be generally accep*.ed.

The NRC recognizes that it must operate within f

thit framework, in order to comply with the Omnibus Trade and Competitiveness l

Act, the Commiss10n should establish a metrication policy.

The NRC policy

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should be consistent with Federal policy and guidance, but should be tailored to interactions with licensees, other goverreental agencies (Federal, State, local, and foreign), the regulated industry, and the public.

The NRC policy should be consistent with the current metrication practices of the nuclear i

industry and should accommodate industry's voluntary, time-phased adoption of 51 metric units.

i In reviewing the mission of the NRC, the Metrication, Committee divided NRC's activities into five general areas:

licensing, emergency response, standards l

development, inspection, and support.

Each of these areas is briefly defined i

below-1.

Licensing includes activities related to license applications, issuance of licenses and amendments, regulatory reviews, hearings, technical 1

specifications, operator examinations, safety evaluation reports, environmental impact statements, and environmental assessments.

NRR, NMSS, and the regional offices shart in accomplishing the activities in this area.

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Emergency response includes at.tivities related principally to the l

operation of the emergency response center and emergency planning.

These activities are primarily accomplished by AE00, NRR, NM$$ and the regional l

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Standards development includes the development of regulations, with which 4

licensees must comply, and regulatory guides, which provide guidance to licensees on compliance with the regulations.

This area also includes j

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-l standard review plans and branch techr.ichi positions.

RES, NRR, and HMS$

j are primarily responsible for activities in this area.

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Inspection covers those activities that ensure the construction and the operation of licensed facilities meet license requirements, identify l

i conditions that may adversely affect public health and safety, provide

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f information used as the basis for issuance, deniel, or amendment of a permit or license, and determine if applicants and licensees have an l

adequate quality assurance program in place.

The regional offices NRR, and NMSS share in accomplishing the activities in this area.

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Support includes all of the other NRC activities needed to support the areas identified above.

It encompasses, for example, activities related i

i to publications, data bases, training, enforcement, personnel, contracting, and accounting.

These activities are carried out primarily h

by AEOD, ADM, OGC, 00, GPA, etc.

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The Committee divided the general areas described above into two categories.

primary activities and secondary activities.

A primary activity is defined as I

one that sets direction for the agency's metric conversion policy.

A secondary i

l activity is one that would follow the direction set by primary activities.

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Using this criteria, the Committee determined that licensing and emergency I

response comprise the primary activities.

Standards development, inspection, j

r and support comprise the secondary activities.

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The Committee considered three options to implement and measure the cost and i

l scheduling impacts of metric conversion.

These are described below:

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I Option 1:

One Step Conversion

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i During the FY 1990-1992 time frame, NRC activities identified for conversion, l

including regulations, would be converted to metric units.

The conversion 9

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period would involve contractual support and NRC costs over a 3 year period.

Af ter FY 1992 NRC would operate only in metric units, and no costs would be incurred for metrication.

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i Option 2:

Gradual Conversion During the FY 1990-1997 time frame, NRC activities identified for conversion would be gradually converted from English units to metric units.

After FY 1997, these activities would be expressed in metric units only.

Under this i

I option, regulations would be converted to dual units (metric equivalent unit j

first, followed by English unit in brackets) during the FY 1990-1992 time f

frame. During FY 1992-1997, regulations would be expressed in dual units, i

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Af ter FY 1997, only metric units would be used.

It ($ expected there would be contractual support and NRC costs involved for the periods FY 1990-1992 and FY 1997.

Option 3:

Partial Conversion Af ter FY 1990, NRC activities for existing facilities would be expressed in either English or metric units at the option of the licensee.

This would be maintained for the life of the facility and any life extension thereto.

New license applications received b,etween FY 1990 1992 would be expressed in either English or metric units at the option of the licensee.

The Commission would require that all new applications received after FY 1992 would be expressed in metric units only.

Under this option, regulations would be converted to dual units (metric equivalent unit first, followed by English unit in brackets) during FY 1990-1992.

From FY 1992 until the final termination or expiration of the operating license of the last Englinh unit facility, regulations would be expressed in dual units.

Af ter the last English unit plant has been phased out, only metric units would be used.

It is expected there would be contractual support and NRC costs involved for the period FY 1990 1992.

Additional conversion costs would be incurred for conversion of regulations to metric units. A summary of these three options is presented in Table 1.

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TABLE I StrmRRY OF OPTIONS CONSIDERED OPTION 3: PARTIAL OPTION 1: DNE-STEP OPTION 2: GRADIAL CONVERSTON CONVERSION CONVERSION LICENSEE English or Fietric Units.

Engifsh or rietric Units, English or fletric Units, ACTIVITIES at Licensee's Op*'w at Licensee's option at Licensee's Option NRC ACTIVITIES After FY 1992 English or Metric Units Existine Facilities:

Metric Units only thre FY 1997 English or Metric Units, at Licensee's Option After FY 1997 Metric Units only After Ff 1997 New Facilities: Metric Units NRC RULES Als After FY 1992 peissued After FY 1992 Reissued After FY 1992 Reissued REGULATORY GUIDES in Metric Units in Dual Units in Dual Units After FY 1997 Reissued Reissued in Metric Units in Metric Units only After last English wait plant is phased out l

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The primary activities identified by the Committee for conversion were reviewed

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I against these options. The options selected for each of the two primary activities were based on the mission of the NRC and with the intent of causing l

the least disruption of licensee operations.

Once the options for the primary activities have been selected, related secondary activities would follow I

established policy. provides a summary of principal NRC activities within the five general areas af fected by metrication, including cost impacts (both NRC and contractual costs) for conversion.

These cost impacts are rough i

j estimates and were the best available under the time constraints imposed on the j

i Committee.

The Committee did not assess licensee costs under metrication.

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Upon development and approval of an NRC implementation plan for metrication, a more exhaustive study on costs would be needed to determine the resource i

impacts required to carry out the NRC's metrication policy.

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FINDINGS 1

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In analyzing the primary and secondary activities for metrication and the t

options considered, the Committee made a number of general observations regarding the conversion process, 1.

Conversion to the metric system has the greatest impact on reactor activities.

The Committee believes that, because current online and near-term plants are designed, constructed, and operated in the English l

measurement system, immediate conversion of NRC activities to metric units i

(Option 1) is not feasible or practical.

Furthermore, it is unlikely that operation of these plants will be converted to' metric units on a voluntary l

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Such a conversion would require considerable change to the plants

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I in the areas of operating instrumentation, revisions to operating manuals, j

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and retraining of personnel.

This upheaval of the plunt operating system would have a considerable potential for operator error and other undesirable safety consequences. Therefore, the safety of the plants that l

are already licensed or in the licensing process, and will operate in the English system, would benefit more from adoption of Option 3.

New reactor j

i license applications received between FY 1990 1992 would be expressed in either English or dual units at the option of the licensee.

All new l

l license applications received af ter FY 1992 would be expressed in metric units only.

l 2.

Materials licensees frequeMiy oeal with products which are inter-I I

nationally traded, such as pharmactuticals or industrial gauges.

It would l

benefit manufacturers if tht same product could pe sold in both domestic and foreign markets.

Similarly, users would benefit if ali available j

products used the same system of measures, since no special training or j

treatment of the product would be required.

Generally, the lifetimes of tnese products are relatively short since new products are continuously l

being placed on the market.

The typical lifetime of an industrial gauge is about 10 years.

NRC and state licenses are issued for a 5 year time l

period.

Thus, in the case of materia'.a licenses, the Committee believes Option 2 would be more desirable and could be achieved over a 5-year j

period during the renewal of the licenses.

t 3.

For fuel cycle facility licensing act M ties, the impact of metrication on normal operations should present no significant problems between the NRC j

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j and the licensee, Fuel cycle facility licenses are renewed every 5 years.

NMSS is currently considering the extension of the license renewal period f

to 10 years. The Committee believes converting NRC's fuel f acility j

licensing activities to metric according to option 2 appears to be the l

r most reasonable.

It should also be noted, however, that these f acilities j

l are tsquired to have emergency plans. Metric conversion of emergency l

response operation is discussed under. Item 7, below.

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4.

For waste activities, the impact of metrication will be minimal, j

i Currently there are three low-level waste sites in operation; two of the i

sites are scheduled for closure in 1992. While these sites are not j

af fected by metrication, the remaining site could be converted under j

i Option 2.

It is interesting to note that the current state license for j

1 the site remaining open af ter 1992 is already using metric units.

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current NRC license is a mixture of English and getric units.

Plans 2

t currently exist to license several new low-level waste sites.

These sites

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l are being developed by individual states for State compacts.

Some of these will be licensed by NRC, others by Agreement States.

The Committee believes that the licensing of new low-level waste sites should be in i

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I metric only.

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5.

In the case of uranium recovery facilities, the impact of metrication should not present significant problems.

Facilities which are closing and are completing reclamation activities could remain under their current mixture of English and metric units.

Facilities that continue to operate

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could be converted under Option 2, while new f acilities could begin operations using the metric system.

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l 6.

Licensing of the high-level waste disposal facility is expected to take i

many years.

DOE is the applicant for this facility.

Potential use of metric units should be discussed with DOE.

The Committee believes metric f

units should be the preferred system of measurement for this facility.

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i 7.

Another primary NRC activity significantly affected by metrication is

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n' NRC's emergency response operation.

This activity serves as the daily and f

immediate interface between NRC and its licensees during abnormal and j

emergency operations.

This activity, must have the capability of directly communicating with licensees (reactor and nonreactor slike) on a real-time l

basis and in a language the licensee understands.

In addition, during an j

f emergency situation, NRC must be able to coordinate with other Federal i

agencies as well as agencies at the State.and local levels.

The vast

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majority of the calls received by the emergency response a: enter concern reactor related problems.

In considering conversion to metric units for j

l emergency response operations, the Committee suggests that the NRC accept whichever units (English or metrie) the licensee decides to use.

On this i

i basis, the emergency response center should be flexible and, sometime in i

the future, should be able to communicate in either English or metric units. Therefore, metrication will have a greatet impact o.n the NRC than on its licensees.

Because of the nature of emergency response operations, the Committee believes that it is important for the NRC to be able to l

1 communicate in the manner that is most convenient to the Itcensee. This j

is essential in order to avoid unnecessary complications during stressful conditions.

l 8.

Standards development activities cut across a wide range of NRC l

activities.

Standards are formulated to protect the public and the 14 1

7 nuclear industry workers from radiation, safeguard nuclear mater?als and f acilities f rom thef t and sabotage, and protect the quality of the f

environment in nuclear activities.

Any effort to convert standards development activities to metric units needs to consider the impact on the licensees we regulate.

For example, rulemaking and regulatory guide development af fecting power reactor licensees should parallel the same I

option previously described in Item 1 of this section.

it.e same is true l

i for all other activities. The Committee believes it is important that n+trication of standards development activitias follow the option l

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l selected for primary activities and incorporate dual units to enhance communication and consistency among and between licensees, and among the l

NRC, its licensees, and State and local governments.

This apptcach will apply to issuance of new regulations or amendments to existing regulations.

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9.

Inspection activities are established to determi,ne whether licensees are l

complying with NRC requirements. When an inspect' ion program discloses

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events or conditions that present a potential or actual threat to pelic j

i health and safety, the environment, or the safeguarding of nuclear materials and facilities, prompt action is taken by the NRC and relevant information is communicated to other parties.

Since, typically, I

i inspections are perforined against a licensee's own procedures, inspections

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should be performed in the same type of units as used by the licensee to j

operate the facility.

In order to aid communication with other parties, af ter FY 1992, inspection reports for English-unit facilities should be l

l prepared in dual units; inspection reports for metric-unit facilities should be prepared in metric units only.

Inspection reports written in j

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this manner would also f acilitate the use of available ',nformation and allow for comparison among similar activities.

10.

The Committee believes that the support activities should be converted to metric units in a manner that parallels the options used for converting the primary activities.

It is expected that NRC costs for converting sura.$rt activities to the metric system would be minimal.

These costs would be principally attributed to in house training in the use of the $1 metric system. These training costs would be incurred for a relatively short period of time (perhaps 2 3 years).

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l 11.

The Committee estimates that based on the assumption that metric conversion begins in FY 1990 the impact on NRC resources for metric l

conversion is on the order of 20-25 FTE's and the contractual support on l

the order of $2 3 million spread over 5-7 years., (See Table 2 and i ).

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The Committee makes the following recommendations:

l 1.

NRC activities related to material licensees should convert to metric i

units during a five year period starting in FY 1992.

Nuclear reactor-l l

related NRC activities should be subject to partial conversion to metric,

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i f

as follows:

Activities addressing existing facilities should use English or metric units at the option of the licensee.

Activities related to facilities spplying for a license after FY 1992 should use metric units.

NRC's emergency response operations should use the same units as the l

licensee is using.

Details on this recommendation can be found on pages,.

l i

11 16 of this report.

2.

NRC should conduct a public workshop to solicit the views of the nuclear industry on conversion to the metric system.

Meetings should also be held l

with other governmental agencies (e.g., DOE and EPA) and Agreement States j

to discuss the scheduled phase-in of the metric system, j

t i

L l

3.

NRC should issue a policy statement regarding the agency's conversion to f

the metric system.

This policy statement would specify how NRC intends to convert to the metric system, encourage metric conversion, provide f

I guidance to NRC staff, and inform industry and the public regarding NRC policy.

f 4.

NRC should consider issuing a rule or amending existing regulations to facilitate the Commission's adoption of the metric system.

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1 5.

NRC should develop an implementation plan that includes issuing specific guidance dealing with metric conversion. Training should be provided to familiarize all NRC personnel with metric conversion factors and to ensure that adequate levels of precision are maintained.

l 6.

NRC should establish a committee composed of senior representatives from 00, NRR, NMS$. RES, and AE00.

This committee would develop an implementation plan, oversee the implementation of the metric conversion, and assume responsibility for preparing the annual report to Congress.

REFERENCES 1.

Letter, M. Baldrige, Secretary of Commerce, to Chairman Palladino, dated January 29,1985(subject:

voluntary use of the metric system).

2.

Letter, R. Minogue, Director, RES, to M. Baldrig, Secretary of Commerce, dated February 25, 1985 (subject:

voluntary use of the metric system).

3.

" Report of the CIRRPC Policy Subpanel on SI Metric Radiation Units,"

December 1986 (Transmitted by letter from W. Graham, Science Advisor to the President, to B. Merrifield, Assistant Secretary for Productivity.

Technology and Innovation, Department of Commerce, dated December 31, 1986).

4.

Letter. T. Murley, Director, NRR, to R. Artigas, Manager, Licensing and Consulting Services, General Electric Company, subject: GE Advanced Boiling Water Reactor Licensing Review Bases, dated August 7, 1987.

J 19 I

1 l

5.

Letter, H. Kramer, Chairman, Committee on Radionuclides and Radiopharmaceutica15, U.S. Council for Energy Awareness, to Chairman Zech, dated September 26,1988(subject: use of $1 units in NRC's regulatory program).

l 6.

Letter, H. Thompson, Director, NM$$, to H. Kramer, Chairman, Committee on 5

Radionuclides and Radiopharmaceuticals, U.S. Council for Energy Awareness, n

dated November 14,1988(subject:,use of $1 units in NRC's regulatory

)

program).

)

7.

" Preferred Metric Units for General Use By the Federal Government,"

l l

Federal Standard 376A, issued by the General Services Administration, May j

l 5, 1983.

}

i 8.

" Metric Handbook for Federal Officials, Recommendntions of the Interagency Committee on Metric Policy." August 1986 (NTIS Accession No. PB86-226370),

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o OMN! SUS TRADE AND COMPETITIVENESS ACT OF 1988 SEC.5164. METRIC USAGE (a)

FINDINGS. - Section 2 of the Metric Conversion Act of 1975 is amended by adding at the end thereof the following new paragraphst

• (3)

World trade is increasingly geared towards the settic system of measurement.

• (4)

Industry in the United States is often at a competitive disadvantage when dealing in international markets because of its nonstandard measurement system, and is sometimes excluded when it is unable to deliver goods which are measured in metric teras.

• (5)

The inherent staplicity of the metric systen of measurement and standardination of weights and measures has led to major cost savings in certain industries which have converted to that system.

• (6)

The Fed' oral Government has a responsibility to develop procedures and techniques to assist industry, especially small business, as it voluntarily converts to the s

metric system of measurement.

• (7)

The metric system of measurement een provide substantial advantages to the Federal Government in its own operations.*

(b)

POLICY. - Section 3 of the Metric Conversion Act of 1975 is amended to read,as follows:

"SEC. 3.

It is therefore the declared policy of the United States --

• (1) to designate the metric system of measurement as the preferred systen of weights and measures for United States trade and commerce.

• (2) to require that each Federal agency by a date certain and to the extent economicalty feasible by the end of the fiscal year 1992, use the attric systen of measurement in its procurements, grants, and other business-related activities, except to the extent that such use is impractical or is likely to cause significant inefficiencies or loss of markets to United States firms, such as when foreign competitors are producing competing products in aca-metric units.

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• (3) to seek out ways to increase understanding of the j

metric system of measurement through educational information and guidance and in Goversiaent publications; and

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• (4) to permit the continued use of traditional systens of j

weights and measures in nonbusiness activities.*

l (c)

IMPLEMENTATION. - The Metric Conversion Act of 1975 is further amended by redesignating section 12 as section 13, and by j

inserting after section 11 the following new sections:

SRC. 12 (a)

As soon as possible after the date of the enactment of this section, each agency of the Federal Government i

shall establish guidelines to carry out the policy set forth in I

section 3 (with particular emphasis upon the policy set forth in paragraph (2) of that section), and as part of its annual budget 4

submission for each fiscal year beginning after such date shall report to the Congress on the actions which it has taken during 1

the previous fiscal year, as well as the actions which it plans for the fiscal year involved, to implement fully the metric systen 1

of measurement in accordance with that policy.

Such reporting shall cease for an agency in the fiscal year after it has fully l

taplemented its efforts under section 3(2).

As used in this

)

i section, the term ' agency of the Federal Government' means an J

Executive agency or military department as those terms as defined l

l' in chapter 1 of title 5. United states Code.

'(b)

At the end of the fiscal year 1992,. the comptroller General shall review the tuplementation of this Act, and upon completion of such review shall report his findings to the Congress along with any legislative reconnendations he may l

have.'

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CorygREWCg COMMITTgg EgPORT

$gc.5164, KETRIC USAGE The Conferees accepted the House version uf the amendments to the Metric Conversion Act of 1975. While both the House and Senate provisions endorsed the initiation of specific prograne to increase U.S. conversion to the metric systen, the conferees chose to accept the greater specificity of the Mouse provision. The International Systes of Units (81) version of metric, as established by the General Conference on Weights and Measures in 1960 and as interpreted or modified by the Secretary of Commerce, is designated as the preferred system of weights and measures for United States trade and commerce and its use is required by each federal agency in its procurements, grants, and other business-related activities, gach agency is awyetted to establish guidelines sintler to Department of Defense (D00) Directive Number 4120.18, dated September 16, 1967 as soon as possible following the date of enactment.

This directive states that it is D0D policy to use metric system in all its activities consistent with security, operational, economical, technical, logistical, and safety requirements.

It then pere specifically spelle put when metr 8-is to be used; who is to establish procedures for preparation, coordin..v and approval of new setric specification and standards; and the Defense o';tcials who sust approve exceptions to use of metric.

D00 representatives, furthermore are directed by the DoD Directive to participate actively in the development of U.S. and international standards using the notric systen and in the yederal Interagency Committee on Metric polley who will have major responsibilities in ensuring the successful Laplementation of this section.

The conferees expect each of these issues to be addressed in the guidelines to be propulgated by soch agency and the Interagency Committee is to be used to achieve as such consistency as possible in the guidelines of the various agencies.

Under the provision adopted by the conferees, conversion. to metric is not required when its use is impractical or is likely to cause significant inefficiencies or loss of markets to United States firms.

such exceptions will be more likely to occur in the early years of this program.

For instance, the DoD directive states that existing designs dimensioned in inch-pound units need not be converted unless it is necessary or advantsgeous to do so, that the measurement units in which a systen is originally designed are to b6 retained for the life of the system, and that during the transition, use of hybrid metric and inch-pound designs may be necessary. Also, certain aerospace systens generally use the English system of measurements worldwide.

It is not the intent of this legislation to force the U.S. aerospace industry, to its financial detriment, to take the lead in metric conversion for these systead. However, new DoD shop, laboratory, and general purpose laboratory equipment under the D0D Directive must be able to operate in metric units; bulk purchases usually are to be rede in metric; and components, subassemblies, and senif abricated materials are to be specified in metric units when economleelly available and technically adequate. purthermore, the conferees expect agencies to assist donestic federal contratters and subcontractors, including small business, in developing the capability to compete in metric units so that increased use of metric by federal agencies does not becone a windf all for companies f rom foreign countries which have already converted.

The ability of federal contractors and suppliers to 40 business in metric should increase U.S. access to foreign markets and decrease our *.rado deficit since metric literacy is a prerequisite to competing in most overseas markets.

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METRICATION COMMITTEE MEMBERS Dr. Zoltan R. Rosrtocry (Chairman) Deputy Director, Division of Regulatory Applications. Office of Huclear Regulatory Research Joseph J. Mate (Executive Secretary), Regulation Development Branch, Of fice of Nuclear Regulatory Research Clifford S. Hither (Recording Secretary), Regulation Development Branch, Office of Nuclear Regulatory Research Anthony J. DiPalo, Regulation Development Branch Of fice of Nuclear Regulatory Research Harold E. Polk, Planning, Program, and ' Management Support Branch Of fice of Nuclear Reactor Regulation Robert L. O'Connell Operations Branch, Division of Industrial and Medical Nuclear Safety. Office of Nuclear Material Safety and Safeguards Steven K. Showe, PWR Tet.hnology Branch, Division of Operational Assessment, Office for Analysis and Evaluation of Operational Data (Technical Training Center)

Eugenia L. Boyle, Trends and Patterns Analysis Branch, Of fice for Analysis and Evaluation of Operational Data Elizabeth A. Hayden, Office of Governmental and Public* Affairs Janice E. Moore, Office of the General Counsel Elise A. Heumann, Program Analysis Branch, Division of Budget and Analysis, Office of the Controller Ronald D. Thompson, Division of Contracts and Property Management, Office of Administration William G. Kennedy, Office of the Executive Director for Operations I

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. s HRC KETRICATION SUM!%RY (Dollars in Thousands) cc:c3 ::::::::::::::::::::::::::::::::::::::::::::::::::::::! NRC COST t

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COMMENTS 1 FTE I CONTR l

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ESTIMATES FISCAL YEAR L

1991 Iui i

January 1990 4

U.S. Nuclear Regulatory Commission

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UNITED 8TATEs

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i January 1990 j

U.S. NUCl. EAR REGULATORY CCHMISSION REPORT TO CONGRESS ON METSICATION i

This report is in tesponse to Public Law 100-418 Section 5164 of the Omnibus Trade and Competitiveness Act of 1988, which requires each Federal government l-agency to report to the. Congress on its metrication activities for the t

l preceding year and plans for the coming year.

During FY 1989, the U.S. Nuclear Regulatory Comission has shown its comitment to developing a metrication policy by having) participated in both the Interagency Comittee on Metric Policy (ICMP and the Metrication Operating Comittee (MOC), and by initiating plans to implement the Act within the NRC to the extent practicable.

Within the NRC, the Office of Nuclear Regulatory Research (RES) has the f

responsibility to develop, for Comission considerationg a policy statenent addressing utilization of the metric system of weights and-measures in NRC's activities.

In order to solicit consents from other NRC offices, in March

[

1989, the Director of RES appointed an ad hoc committee on metrication. The comittee had members from representative NRC offices and was tasked with the responsibility to identify those NRC activities which are candidates for metric conversion. The comittee investigated a wfde range of areas and compl4ted its task in July 1990. Their findings and recommendations suggested additional i

actions, some of which have been initiated.

The recommendations included:

1.

Organize a 2-day workshop to solicit coments from those outside NRC; I

2.

Organize a meeting trtwun the NRC and other governmental agencies (e.g.

DOE and EPA) to discuss the comittee's findings as they affect comon i

issues and overlapping areas of responsibility, such as high-level waste l

and advanced reactor activities; 3.

Issue a policy statement regarding the NRC's conversion to the teetric I

system; 4

Develop an implementation plan that includes issuing specific guidance dealing with metric conversion; and, 5.

Establish an oversight comittee composed of senior representatives from NRC program offices to oversee implementation of the metric conversion.

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Some of these activities have already been effected in FY 1990. A standing i

committee composed of senior representatives from the NRC program offices was The committee's responsibilities are to: provide established in October 1989.

guidance for the development of a metrication policy statement for NRC; develop an implementation plan; provide oversight of the implementation of metric conversion; and prepare the annual metrication report to Congress.

Another recommendation has been acted on in FY 1990 was the metrication workshop. A "Public Workshop on NRC Conversion to the Metric System" was held-on November 14 and 15, 1989 in Baltimore, Maryland. The workshop's purpose was to collect information that will assist the NRC in developing its policy and j

The i

potential plans for converting its activities to the metric system.

workshop was attended by approximately 75 representatives of regulated industries, state and local governments, academia, the public, the NRC and other Federal entities. A good deal of information was received on the benefits and disadvantages of metrication in the areas in which the NRC regulates.

The NRC's metrication goals for the remainder of FY 1990 and FY 1991 include collecting additional information from outside the NRC, especially emphasizing the coordination of our work with those agencies having related or overlapping responsibilities. The NRC also hopes to gain a better understanding of other l

especially in the nuclear area, e.g.,

countries' metrication experiences Canada. ThemaingoalisthedevelopmentoftheNRCmetricationpolicy statement for Commission consideration. Development of an implementation plan will be undertaken after the issuance of the policy statement.

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