ML23153A037

NPR-MISC. (92-1) - 57FR04891 - Conversion to the Metric System

ML23153A037
Person / Time
Issue date:	02/10/1992
From:	Hoyle J NRC/SECY
To:
References
NPR-MISC. (92-1), 57FR04891
Download: ML23153A037 (1)

Text

DOCUMENT DATE:

TITLE:

CASE

REFERENCE:

KEYWORD:

ADAMS Template: SECY-067 02/10/1992 NPR-MISC. (92-1) - 57FR04891 - CONVERSION TO THE METRIC SYSTEM NPR-MISC. (92-1) 57FR04891 RULEMAKING COMMENTS Document Sensitivity: Non-sensitive - SUNSI Review Complete

STATUS OF RULEMAKING PROPOSED RULE:

NPR-MISC. (92-1)

OPEN ITEM (Y/N) N RULE NAME:

CONVERSION TO THE METRIC SYSTEM PROPOSED RULE FED REG CITE:

57FR04891 PROPOSED RULE PUBLICATION DATE:

02/10/92 ORIGINAL DATE FOR COMMENTS: 04/27/92 NUMBER OF COMMENTS:

EXTENSION DATE:

I I

9 FINAL RULE FED. REG. CITE: 57FR46202 FINAL RULE PUBLICATION DATE: 10/07/92 NOTES ON POLICY STATEMENT.

FILE LOCATED ON Pl.

STATUS F RULE THE STAFF CONTACT OR VIEW THE RULEMAXING HISTORY PRESS PAGE DOWN KEY HISTORY OF THE RULE PART AFFECTED: NPR-MISC. (92-1)

RULE TITLE:

CONVERSION TO THE METRIC SYSTEM PROPOSED RULE SECY PAPER: 91-390 FINAL RULE SECY PAPER: 92-303 PROPOSED RULE DATE PROPOSED RULE SRM DATE:

01/08/92 SIGNED BY SECRETARY:

FINAL RULE SRM DATE:

I I

DATE FINAL RULE SIGNED BY SECRETARY:

STAFF CONTACTS ON THE RULE I

I I

I CONTACTl: DR. FRANK A. COSTANZI CONTACT2:

MAIL STOP: NLS-007 PHONE: 492-3760 MAIL STOP:

PHONE:

DOCKET NO. PR-MISC. (92-1)

(57FR04891 )

In t he Matter of CONVERSION TO THE METRIC SYSTEM DATE DATE OF TITLE OR DOCKETED DOCUMENT DESCRIPTION OF DOCUMENT 02/05/92 01/30/92 FEDERAL REGISTER NOTICE - PROPOSED RULE 03/20/92 03/17/92 COMMENT OF MAYO RADIATION SAFETY COMMITTEE (RICHARD J. VETTER, PH.D.) (

1) 03/30/92 03/24/92 COMMENT OF OMAHA PUBLIC POWER DISTRICT (W. G. GATES) (

2) 04/22/92 04/16/92 COMMENT OF FLORIDA POWER AND LIGHT COMPANY (W. H. BOHLKE) (

3) 04/28/92 04/24/92 COMMENT OF NUCLEAR MANAGEMENT & RESOURCES COUNCIL (RON SIMARD) (

4) 04/30/92 04/24/92 COMMENT OF PHILADELPH IA ELECTRIC COMPANY (G. J. BECK) (

5) 04/30/92 COMMENT OF TENNESSEE VALLEY AUTHORITY (M. J. BURZYNSKI) (

6) 04/27/92 04/30/92 04/28/92 COMMENT OF WESTINGHOUSE CORPORATION (NICHOLAS J. LIPARULO) (

7) 05/04/92 04/27/92 COMMENT OF SOUTH CAROLINA ELECTRIC & GAS CO.

(JOHN L. SKOLDS) (

8) 05/04/92 04/29/92 COMMENT OF FRANK JACKSON, KATIE PERSUT, C. LAY (

9) 10/05/92 09/30/92 FINAL POLICY STATEMENT

DOCl(ET NUMBER R ~....

P(§~SE~

~ LE1?;~) ;

NUCLEAR REGULATORY COMMISSION Conversion to the Metric System AGENCY:

Nuclear Regulatory Commission.

ACTION:

Policy statement.

DO CK 1(17590-01]

US>.;~C "92 OCT -5 P 1 :56

SUMMARY

The Nuclear Regulatory Commission (NRC) is issuing its policy on metrication. This action is in response to the Omnibus Trade and Competitiveness Act of 1988, Executive Order 12770 of July 25, 1991, as well as concerns of certain NRC licensees and other interested parties. The policy, which affects the NRC's licensees and applicants, is designed to allow them to respond to market forces in determining the extent and timing for their use of the metric system of measurement.

The policy also affects the NRC in that the NRC will adhere to the Federal Acquisition Regulation and the General Services Administration (GSA) metrication program for its own purchases.

The policy affirms that use of the metric system of measurement by Commission licensees is in accordance with protection of the public health and safety.

EFFECTIVE DATE:

[Insert date of publication.]

ADDRESSES:

Documents referenced in this policy statement are available for inspection in the NRC Public Document Room, 2120 L Street, NW. (Lower level),

Washington, DC, between 7:45 am and 4:15 pm.

FOR FURTHER INFORMATION CONTACT:

Dr. Frank A. Costanzi, Chairman, NRC Metrication Oversight Coninittee, U.S. Nuclear Regulatory Commission, Washington, DC 20555, telephone:

(301) 492-3760.

SUPPLEMENTARY INFORMATION:

Background

On August 10, 1988, Congress passed the Omnibus Trade and Competitiveness Act (the Act), (19 USC 2901 et seq.), which amended the Metric Conversion Act of 1975, (15 USC 205a et seq.). Section 5164 of the Act (15 USC 205a) designates the metric system as the preferred system of weights and measures for United States trade and commerce.

The Act also requires that all Federal agencies convert to the metric system of measurement in their procurements, grants, and other business-related activities by the end of fiscal year (FY) 1992, "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 non-metric units," (Section 5614(b)(2)).

Summary of Public Conunents In response to the Act, the NRC published a metrication policy statement for comment in the Federal Register on February 10, 1992 (57 FR 4891).

As a result, comments were provided by twelve responders, including five power reactor licensees, three standards organizations, one comment each from a 2

reactor vendor, a materials licensee, the Nuclear Management and Resources Council (NUMARC), and a joint letter submitted by three individuals. All commenters supported the policy. However, the materials licensee strongly advocated rulemaking to require licensees to use the metric system of measurement.

The analysis of the advantages and disadvantages of a policy statement versus a rulemaking was presented in the Federal Register Notice issuing the draft policy statement for cOD1Dent.

The basis of the NRC's position was that no corresponding improvement in the public health and safety would result, but costs would be incurred without benefit, if metrication were made mandatory by a rulemaking.

The commenter's argument was not persuasive, and the NRC continues to believe that rulemaking is not appropriate at this time.

NUMARC argued that because most of the analytical codes, references, and resource data, as well as standards for component sizes (i.e., pipe sizes, fasteners, etc.) still generally use the English system in this country, the primary units shown in regulatory documents presenting dual units should be the measurement system in which the parameter was _derived, with the secondary unit clearly labeled and shown parenthetically. Three of the utilities commenting endorsed the NUMARC letter. However, the Commission believes that the English units should be provided in brackets after the use of the International System of Units (SI) since the SI system has been mandated by Congress to be the preferred system of weights and measures for U.S. trade and convnerce.

A letter submitted by three individuals also supported the policy statement. While they supported the statement, they called for strong incentives such as requiring all future licensing of "newu applicants in the 3

industry to be in metric.

For the NRC to require this type of action, it would need to show that the benefit of the action, such as the reduction of risk or improvement in administrative efficiency, would outweigh its costs.

The NRC believes that this activity is best determined by the market forces, 1

and not by the NRC requiring the action, especially if the action is not initiated in response to an issue involving public health and safety. These commenters also asked that any new self-supporting units at existing plants be licensed only in the metric system.

However, even if the self-supporting unit were designed and built in metric, the emergency response activity is station-wide and, therefore, must be in English units. These individuals also suggested that the NRC only grant licenses to parties operating in metric after the year 2000. Again, this type of requirement could only be accomplished by the NRC if it could demonstrate that the action provided a safety or other benefit commensurate with the cost. The NRC does not believe that to be the case, and again believes that the market forces are the best guides for this type of action.

A tax incentive for licensees converting to the metric system before the year 2000 was also suggested by these individuals. This recommendation is not possible for the NRC to pursue because the NRC does not have taxing authority.

Lastly, the conunenters suggested that the NRC make grants available to parties requiring financial help and who choose to voluntarily convert to the metric system.

The NRC's grants are research and development related and are meant to focus on new and improved technologies.

The NRC believes conversion to metric is market driven, and use of grant funds for this purpose is not in keeping with the spirit of either the NRC grants program or this action.

4

Upon publication of the draft policy statement, the NRC sought co11111ent from several organizations involved 1n developing national consensus standards. Specifically, the NRC inquired as to the impact of metrication on NRC regulations as it relates to National and International Standards, including the extent to which sufficient guidance is presently available to licensees and prospective applicants on the selection of metric equivalents of co1m1on mechanical and electrical components that have safety-related functions.

Letters were sent to the American National Standards Institute (ANSI), the American Society for Testing and Materials (ASTM), the American Society of Mechanical Engineers (ASME), and the Institute of Electrical and Electronics Engineers, Inc. {IEEE).

ASME and IEEE responded that they supported the policy. Although ASTM noted that it could not schedule the appropriate co11111ittees to meet and discuss the NRC's policy until after the comment period expired, the ASTM indicated that it requires the inclusion of metric (SI) units in all 9,000 ASTM standards, allowing the technical co11111ittees to decide whether SI or English units are the preferred unit of measurement used in the co11111ittee's document.

If both units of measurement are used in the document, the order in which they appear is determined by the committee preparing the document.

The IEEE stated that its policy is to provide technical literature and standards in the measurement system that the industry requires. Further, the IEEE stated that it is studying the need to provide more or all of its technical literature and standards in metric (SI) units and that the decision will be heavily influenced by the desires of the users of its standards, such as the NRC and electric utility industry.

5

None of the standards organizations co111T1ented on the availability of hardware.

ANSI did not respond and when contacted by telephone indicated that it did not intend to conunent.

For clarity, the Commission has decided to list which documents will be published in dual units. These documents include new regulations, major amendments to regulations, regulatory guides, NUREG-series documents, policy statements, information notices, generic letters, bulletins, and all written communications directed to the public.

Paperwork Reduction Act Statement This policy statement contains no information collection requirements and, therefore, is not subject to the requirements of the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.).

Statement of Policy The NRC supports and encourages the use of the metric system of measurement by the licensed nuclear industry.

In order to facilitate the use of the metric system by licensees and applicants, beginning [3 months after date of publication] the NRC will publish the following documents in dual units:

new regulations, major amendments to existing regulations, regulatory guides, NUREG-series documents, policy statements, information notices, generic letters, bulletins, and all written co11111unications directed to the public. Documents specific to a licensee, such as inspection reports and 6

docketed material dealing with a particular license, will be in the system of units employed by the licensee. This protocol reflects a general approach that only documents applicable to all licensees, or to all licensees of a given type in which a licensee may operate in the metric system will contain dual units, otherwise English or metric units alone are permissible.

In dual-unit documents, the first unit presented will be in the International System of Units with the English unit shown in brackets. The NRC will modify existing documents and procedures as needed to facilitate use of the metric system by licensees and applicants.

In addition, the NRC will provide staff training as needed.

Further, through its participation in national, international, professional, and industry standards organizations and committees and through its work with other industry organizations and groups, the NRC will encourage and further the use of the metric system in formulating and adopting standards and policies for the licensed nuclear industry.

However, should the NRC conclude that the use of any particular system of measurement be detrimental to the public health and safety, the Commission will proscribe, by regulation, order, or other appropriate means, the use of that system.

In particular, all event reporting and emergency response communications between licensees, the NRC, and State and local authorities will be in the English system of measurement. After 3 years, the Convnission will assess the state of metric use by the licensed nuclear industry in the United States to determine whether this policy should be modified.

Lastly, 7

~

the NRC will follow the Federal Acquisition Regulation and the General Services Administration metrication progra111 in executing procurements.

Dated at Rockville, Maryland this..3.12!day of ~bli 1992.

Fr the Nuclear Regulatory C011111ission.

Samuel J. Chilk, Secretary of the 8

-DOCKET NUMBER PR PROPO ED RULE.~-t-....,;_,,~

c, 7 p. /ll ~i-q/

uoc;KETED USNRC Frank Jackson, Katie Persut, "92 HAY -4 P\\2 :23 Charlie lay:

1804 Fraternity Park Drive ufF!CE OF SECt~ElAR.Y oocKf!iNG & suNtU Knoxville, Tennessee 37916 BR NCI*\\

Secretary, U.S. Nuclear Regulatory Commission Washington D.C. 20555 Attn: Docketing and Service Branch In response to the policy statement issued by the Nuclear Regulatory Commission regarding the conversion to the metric system, we wish to submit the following comments.

The first purpose of this policy as addressed by the Nuclear Regulatory Commission is to respond to the Omnibus Trade and Competitiveness Act of 1988 and the Metric and Conversion Act of 1975.

We agree that this policy statement does fullfill the requirements of these two pieces of legislation. Additionally, we believe it to be of upmost e

importance for the NRC to encourage conversion to the metric system for the good of the national and public interest.

This conversion is needed especially in light of newer nuclear plant designs. These newer designs are being created in metric units to facilitate the worldwide market. With conversion we would help to insure

-... \\ "

that the U.S. remains competitive in this indtislry/

In addition to competition, conversion allows exchange of.cpmpatible parts, equipment,

• .. ;... ~i\\

i

~ ~

and systems between worldwide nuclear plants in ca~~-:l~E:~.. ~ncy.

While the NRC currently conducts most licensing activities in English units, some documents have been published in dual units from time to (j)

~UL. 16 1992

• Acknowledged bJ1'8fd....,..., '"'":.;;*-.. ;;

• *r-

• I

'tt'!

,~,._...

• 1 I

.r

111 I,

time. We would suggest that in order to promote familiarity with the metric system, it is important to publish all future documents in dual units. It is obvious that as long as the metric system seems foreign to the American public, then conversion will always be treated in a hostile manner. Dual publishing is only one way that this stigma of the metric system can be elliminated. Other means to familiarize use include dual publishing of nuclear codes and regulations. _However, we would point out that requiring outright conversion is not the answer.

As stated in the Federal Register, to require the conversion to the metric system, the NRC would have to demonstrate that the conversion would be both pratical and efficient business related activities and insure that no loss of markets would be afflicted on U.S. firms. Present belief is that complete conversion would in fact be harmful to U.S. businesses.

However, this is argueable on the basis that as we pointed out, plants are now being designed on the metric scale to facilitate worldwide marketing.

Therefore, the continuance of the usage of the English system will eventually be detremental to U.S. firms in the global market.

We must point out that we in no way support or condone a hurried conversion to the metric syste1n. Any abrupt change would prove undesirable for the following reasons:

• F.xisting plants have no global or economic need to switch

• Conversion would mean economic disaster and would be burdensome for companies unable to switch

• Fxemptions would become lengthy and time consuming for the Commission

• Unfamiliarity with the metric system could lead to disaster

,r

• l

• Massive retraining of all personel would have to be conducted for operations to continue

• The market mechanism itself will eventually facilitate the need for conversion to the metric system We support the NRC's decision to encourage metric conversion by engaging in the policy statement procedure as opposed to formal rulemaking. We support the policy statement, because it insures that the NRC 's resources will not be diverted from safety concerns and used instead to monitor responses resulting from a rule requiring conversion.

We also believe that to force conversion on plants may result in licensees giving little attention to safety considerations, because they are too busy rushing to convert.

Therefore, we support the policy statement, but insist that it is the responsibility of the NRC to insure that the conversion to the metric system does continue and comes about as smoothly as possible. The policy statement must go beyond encouragement alone. There must be a strong incentive to promote the changes which are needed. This policy is in response to legislation as early as the Conversion Act of 1975. The NRC must not let another seventeen years go by with only a few substantive changes. Canada has already successfully converted to the metric system and it is time for the U.S. to follow. As a global society emerges which primarily runs on the metric system, the market mechanism will e entually create the need for U.S. firms to adopt metric units. The NRC should consider expanding the policy to include some rules to speed up

this process and we would suggest the following to be incorporated into already existing plans:

• Future licensing for all "new 11 petitioners in the industry to be granted solely in the metric system

• Any new self-supporting units at existing plants to be licensed only in the metric units

• After the year 2000, licenses will only be granted to parties already operating in metric

• Possible tax incentives for parties converting before the year 2000

• Make grants available to parties requiring financial help and who choose to voluntarily convert to metric These steps would in fact aid in the speed at which the U.S. faces conversion. The NRC is now in the position to move forward with its initiative. The policy statement will urge firms to familiarize themselves with the metric system. Additionally, dual publishing will give workers exposure to the metric system. This should help in the prevention of e

disaster. By implementing the above suggestions, it should be feasible to convert to the metric system inn a more efficient and timely manner.

~

South Carolina Electric & Gas Company P.O. Box 88 Jenkinsville, SC 29065 (803) 345-4040 SCE&G Allt:IIIIIICornpany OQCK~ T NUMBER p RGPO,.. r D RULE~~...,;,,.~a~

(s-1 Fr< ~kl)

Mr. Samuel J. Chilk Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 April 27, 1992 Attention: Docketing and Service Branch

Subject:

VIRGIL C. SUMMER NUCLEAR STATION DOCKET NO. 50/395 OPERATING LICENSE NPF-12 John L. Skolds Vice President Nuclear Operations 1,LlCK[ i [i1 U:iHRC

• 92 MAY -4 P\\2 :23 COMMENTS ON PROPOSED RULE - CONVERSION TO THE METRIC SYSTEM

{PR 920006)

South Carolina Electric & Gas Company {SCE&G) has reviewed the proposed policy statement, 11Conversion to the Metric System, 11 as published in the Federal Register, 57FR4891, dated February 10, 1992.

SCE&G endorses the comments provided by NUMARC on behalf of the nuclear industry, particularly on the discussions concerning the next generation of plants which would have an orderly transition to the metric system.

SCE&G also concurs with the NRC position that the NRC will not allow licensees to convert systems of units where such conversion might be detrimental to public health and safety.

SCE&G also agrees with the use of the English system for event reporting and emergency response communication.

If you have any questions, please call.

RJB:JLS: led c:

O. W. Dixon Jr.

R.R. Mahan R. J. White G. F. Wunder General Managers NSRC RTS

{PR 920006)

Fi le (811.02)

£"~

John L. Skolds NUCLEAR EXCELLENCE - A SUMMER TRADITION!

JUL 16 \\992 Acknowledged by1ard......... ~nm,a\\~,

Postmark D te

~

9 :2-..

Co)'.ne:; Recei\\" j

/

-~--=-----

Add' l Copies Rep v.. 11,.ed _3--

S;:,ecial Distribution P /} Y2..

r2.

Cot-f

DOC 'ET NUMBER p M 11 S r,

PROPOSED RULE_;;,_.........-/ --

~~ ~

[51 Ffl L,n,J Westinghouse Electric Corporation Energy Systems Mr. Samuel J. Chilk Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTENTION:

Docketing and Service Branch Box 355 Pittsburgh Pennsylvania 15230-0355 ET-NRC-92-3693 NSRA-APSL-92-.;0_.,,__

,o APR 30 1992 DOCKETING&

SERVICE BRANCH SEOY-NRc

SUBJECT:

,9 >-,.__

~

PROPOSED POLICY STATEMENT: CONVERSION TO THE ME 1ctsr7-;(

SYSTEM 57 FED. REG. 4891 (FEBRUARY 10, 1992) REQUEST FOR COMMENTS

Dear Mr. Chilk:

Westinghouse is pleased to provide comments on the proposed policy statement on the conversion to the metric system.

The development of the AP600 was initiated in 1984. A contract with the Department of Energy and EPRI resulted in completion of a conceptual design in 1989. Westinghouse was awarded a second contract in 1989 by the Department of Energy to further develop the AP600 conceptual design into a certified nuclear power plant design. The AP600 is being developed based on the English system of units. The Standard Safety Analysis Report (SSAR) and Probabilistic Risk Assessment Report are being written in the English system and will be submitted to the NRC for review in June, 1992. The present Nuclear Power Oversight Committee schedule is for the NRC to issue the AP600 Safety Analysis Report (SER) in January 1994.

Requiring conversion of the AP600 development work, the SSAR and the PRA Report into the metric system through a rulemaking would not produce a safety benefit commensurate with the expense of the conversion.

Westinghouse supports the proposed policy statement that allows the industry to voluntarily convert to the metric system as the market forces dictate. This approach allows time for the standards and regulations to be converted in advance and the supporting infrastructure to be developed.

We appreciate the opportunity to comment on the proposed policy statement and support the NRC efforts to carefully

• plement a transition to the metric system.

~

~lo, Manager Nuclear Safety and Regulatory Activities

/nja cc:

B. A McIntyre Westinghouse 0439A

~UL 16._

AcknowtedQad bf Clftl.. ~

...... ~

Postm~r~ o:.... 2,Y/JtJ P;2.. _ r-~~).__ o r-. 'll;_~/c,l..

Caries H'.)c,fr *,,J-'/'-------

Add'I Cor;;e<: 0 - J "jt A21 J Special Distri:::L.i,,.,'1 1101G 1'!....T J2S UJ g t4-v..2..*L _{~ ~

v-_~

t.l.!Ll(l,._~ j C..Op ~I po Ir Cost ei,:r,7..' s_/]J..9 2-

DOCKET NUMBER R PROPOSED RULE p m I ~'1C; \\

(!?.IR 4 8' '_:_J COCKETED USt*mC ilE

• 92 nPR 30 P 1 :5?

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 APR 2 7 1992 U.S. Nuclear Regulatory Commission ATTN:

Mr. Samuel J. Chilk Secretary of the Commission Docketing and Service Branch Washington, DC 20555

Dear Mr. Chilk:

,Fr.

_ *r 1.,' JI.,

NUCLEAR REGULATORY COMMISSION (NRC) -

REQUEST FOR COMMENT ON POLICY STATEMENT, CONVERSION TO METRIC SYSTEM The Tennessee Valley Authority (TVA) has reviewed the subject policy statement, which was noticed in the February 10, 1992, Federal Register (57FR4891) and is pleased to provide the following comments.

~TARY iWICf.

TVA supports the comments on this proposal made by the Nuclear Management and Resources Council (NUMARC) regarding NRC's decision to encourage but not require the use of the metric system.

The proposed policy statement is consistent with TVA's Metric Transition Plan which was submitted to the Department of Commerce last November in compliance with Executive Order 12770, "Metric Usage in Federal Government Programs."

TVA appreciates this opportunity to respond to this request for comments.

Sincerely, 11} a;~ u~Ji"

. :~:~Y, Nuclear Licensing and Regulatory Affairs cc:

See page 2 Acknowledged by llllftl.~.. :~

U.S. NUCLc:.~.R Pl:Gi..'LAT oor -,.,..

\\

J--1 I

Postmark Date

i. f?

Copies Received. __

Add'f Copies Rapr due; J _} _ __

~

ial Distnbu:,on 'P't>_'is_ KI:' h ~

e s A-~ c os_=t-~_x:\\3- ~

Mr. Samuel J. Chilk Page 2 APR 2 7 1992 cc:

U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Dr. Frank A. Costanzi, Chairman Metrication Oversight Committee, U.S. Nuclear Regulatory Commission Washington, DC 20555

DOCKET NUMBER PROPOSED RULE p PHILADELPIDA ELECTRIC COM;;-;.P.~

~

4g0<fi])

NUCLEAR GROUP HEADQUARTERS l v Lt\\[ ~ Li)

Ci'~ - /

955-65 CHESTERBROOK BLVD.

U~NHC

/

WAYNE, PA 19087-5691 (215) 640-6000 NUCLEAR ENGINEERING & SERVICES DEPARl"MENT Mr. Samuel J. Chilk Secretary of the Commission Nuclear Regulatory Commission Attn: Docketing and Service Branch Washington, DC 20555

Subject:

Philadelphia Electric Company Comments Concerning the Nuclear Regulatory Commission's Proposed Policy Statement, "Conversion to the Metric System"

Dear Mr. Chilk:

This l ett e r is be i ng submitted i n r esponse to the Nuclear Regulatory Commission's (NRC's) request for comments regarding the Proposed Policy Statement, "Conversion to the Metric System," published in the Federal Register (57 FR 4891, dated February 10, 1992).

Philadelphia Electric Company (PECo) appreciates the opportunity to comment on this proposed policy statement to allow licensees an opportunity to respond to market forces in determining the extent and timing for use of the metric system as the standard unit of measurement.

This metric system conversion effort is the result of a Congressional mandate stipulating that Federal agencies begin using the metric system of measurement in their business-related activities, were ever possible, by the end of fiscal year 1992.

This proposed policy statement offers two (2) options for implementing the use of the metric system.

One option (i.e., Option 1) would require licensees and license applicants to use the metric system in dealing with the NRC through a rulemaking action.

The second option (i.e., Option 2) would encourage NRC licensees and license applicants to use the metric system through a policy statement.

PECo supports Option 2 as an acceptable method of implementing the metric system for use by the industry.

Furthermore, we endorse the Nuclear Management and Resources Council's (NUMARC 's) position and comments concerning this proposed policy statement.

If you have any questions, please do not hesitate to contact us.

Very truly yours, Manager Licensing Section JUL 16 1992.

Acknowledged by card

""IIEiSOWOC:Utlten:;;:e;wA

1., _'; NUCLEAR r-cr-M HSSIO DOC<'

• TON RY Copies ReceiVtl __

Add'I Copies I

" 3__

Special Distributir, "f D I..b..S o.s T tt '("\\.

NUCLEAR MANAGEMENT AND RESOURCES COUNCIL 1776 Eye Street. N.W

• Suite 300

• Washington, DC 20006-2496 (202) 872-1280 "92 Mr. Samuel J. Chilk Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D. C. 20555 ATTENTION:

Docketing and Service Branch RE:

Proposed Policy Statement: Conversion to the Metric System 57 Fed. Reg. 4891 (February 10, 1992)

Request for Comments

Dear Mr. Chil k:

The Nuclear Management and Resources Council, Inc. (NUMARC) 1, on behalf of the nuclear industry, is pleased to provide comments on the proposed policy statement on conversion to the metric system.

We support the proposed Policy Statement which, while affirming the commitment to metrication, recognizes that a sudden or precipitous move to conduct licensing and regulatory matters in metric units and convert regulatory documents to the metric system for existing operating plants would be disruptive. Additionally, the proposed policy recognizes the safety risks in an abrupt introduction of unfamiliar measurement systems in an operating environment.

The proposed Policy Statement recognizes that the transition to the metric system will be market driven. Current plants are built to codes and standards which are generally derived and written in the English system of units. Replacement components and parts must be obtained using the unit system for which the original items were purchased. As the next generation of plants, some of which have been designed to meet the requirements of an 1 NUMARC is the organization of the nuclear power industry that is responsible for coordinating the combined efforts of all utilities licensed by the NRC to construct or operate nuclear power plants, and of other nuclear industry organizations, in all matters involving generic regulatory policy issues and on the regulatory aspects of generic operational and technical issues affecting the nuclear power industry. Every utility responsible for constructing or operating a commercial nuclear power plant in the United States is a member of NUMARC.

In addition, NUMARC's members include major architect/engineering firms and all of the major nuclear steam supply system vendors.

JUL 16 199t~

Acknowledged by cam coill~ll:S:CU:$0"'.S.MN;;

U.S. NUCLE/\\R RE:

ClMM 1t*,J.

DOCKETING &

OFFICE OF OF 1 *r.

Postmarr D.~** tfJ_ ~ -~

Coples Rect -. *

\\

Add'I Copies F'r*,,, 1cr,1 2__

S cial D1::l:ibu;.... *

~

- "R5,.µ..S

~.st~('\\

Mr. Samuel J. Chilk April 24, 1992 Page 2 international marketplace, are licensed, constructed, and operated, we would expect to see an orderly transition to the metric system.

We do have some concern over the proposed practice of publishing all new rulemaking actions and other related documents in dual units with the English units shown parenthetically. Since most of the analytical codes, references, and resource data as well as standards for component sizes (i.e., pipe sizes, fasteners, etc.) still generally use the English system in this country, we recommend that the primary units shown in regulatory documents be the unit in which the parameter was derived, with the secondary unit clearly labeled and shown parenthetically.

Finally, we concur with the NRC position that the NRC will not allow licensees to convert systems of units where such conversion might be detrimental to public health and safety.

We strongly support the use of the English system for event reporting and emergency response communications.

On behalf of the nuclear industry, we appreciate the opportunity to comment on the proposed Policy Statement, and we support the NRC efforts to accommodate both systems of units and to encourage a careful and deliberate transition to the metric system, driven by general acceptance of metrication by codes and standards and U. S. industry as a whole.

s~* _r"J~~

Ro Simard, Director Ind stry Relations and Administration Division

DOCKET NUMBER PR Vl/1.

PROPOSED RULE 1 '

1 1 S <;;.

(!1f~-~~o/

P.O. Box 14000, Juno Beach, FL 33408-0420 l JCKL I Ll, Li::iNHC

• 92 APR 22 P 2 :43 Mr. Samuel J. Chilk Secretary of the Commission

u. s. Nuclear Regulatory Commission Washington, D. c.

20555 Attention: Docketing and Service Branch Re:

Proposed Policy Statement; Conversion to the Metric System 57 FR 4891 (February 10, 1992)

Request for Comments

Dear Mr. Chilk:

APR 1 6 1992 L-92-102 Florida Power and Light Company (FPL) is the licensed operator of two nuclear power plant units in Dade County, Florida and two nuclear power plant units in St. Lucie County, Florida.

FPL has reviewed the proposed policy statement and concurs with its issuance because it provides flexibility not available through rulemaking, it avoids an abrupt conversion to metric units, and it allows licensees to schedule conversion(s) when there would be neither economic disadvantage nor safety detriment.

FPL appreciates the opportunity to submit these comments.

Very truly yours, W. H. Bohlke Vice President Nuclear Engineering and Licensing WHB/JRL/dmb an FPL Group company JUL 16 ~----

Acknowtedged by card wmhlhUUIU:Clihll "'"'""

J '3 NUCLEAR REGULATORY COMMISSIOfl.

DOCKETINr, & SERVICr:: SECTION OFF,C': C,F THE ECViETARY C~ 1liE COM;-;11$S;C'.~

Document Statistics Postmark Date _'f+-1-/~)--'-k ___ _

~~~~re~d_1_ 1 _____ _

Add'l Copies Reprc:iucr.-<i _____ _

Special Distribution _______ _

45-5124 March 24, 1992 LIC-92-096R Mr. Samuel J. Chilk Secretary of the Commission Omaha Public Power District 444 South 16th Street Mall Omaha, Nebraska 68102-2247 402/636-2000 U. S. Nuclear Regulatory Commission Washington, DC 20555

References:

Docket No. 50-285 Gent lemen:

• 92 HAR 30 P 3 : 1 3

,:JFF!C ~: Of S[Ci~t T M '

QOCKC! ING.x-, Sr i<VICf BR ANCH

SUBJECT:

Comments on Petition for Rulemaking:

Conversion to the Metric System Omaha Public Power District (OPPD) has reviewed the subject petition for rulemaking as published in the Federal Register on February 10, 1992 (57 FR 4891) and provides the following comment.

OPPD supports Option 2.

In Option 2 the NRC, through a pol icy statement, encourages licensees and license applicants to use the metric system.

If you should have any questions, please contact me.

Sincerely W. G. Gates Division Manager Nuclear Operations WGG/sel c:

LeBoeuf, Lamb, Leiby & MacRae D. L. Wigginton, NRC Senior Project Manager S. D. Bloom, NRC Project Engineer R. D. Martin, NRC Regional Administrator, Region IV R. P. Mullikin, NRC Senior Resident Inspector Employment with Equal Opportunity Male/Female APR 1 5 1992 Acknowledged by card"... "..........,.,,,,,:::;;;

U.S. NUCLE R AEGULATOR COMMISSIO DOCKETING & SERVICE SECTION OFFICE OF THE SECRETARY OF THE COMMISSION Document Statistics Postmark Date _3'--l--~...-7 ____ _

Copies Received _______ _

Add'I Copies Reproduced _

s....

s 7

DOC:-.~T NUMBER PROPOSED RULE Pl rn i s C.

Cr j - I' (5" 7 FR '{~rj_)

-;J Mayo Clinic Rochester, Minnesota 55905 Teleph~~t1tt 284-2511 Richard J. Vetter, Ph.D.

Radiation Safety Office Secretary U.S. Nuclear Regulatory Co~ion Washington, DC 20555 Attention Docketin~ and Service Branch

Dear Sir or Madam:

(J)

This letter is in response to the proposed policy statement on Conversion to the Metric System published in the Federal Register, Vol 57, No. 27, Monday, February 10, 1992. This proposed policy and response have been reviewed by the Mayo Radiation Safety Committee.

The following comments are offered for your consideration.

We consider the proposed policy [to convert to the metric system] to be a positive step toward continuity in international radiation protection policy and a positive step in net overall benefit for radioactive material users in the United States. We support option 1 requiring licensees to use the metric system.

Specific comments:

While not all radioactive materials users interact internationally (the proposed policy states that marketing and business aspects of nuclear power plants use the English system of units),

companies that sell instrumentation, radiation protection equipment, dosimetry, etc. must supply these items in two different sets of units for the international market. So, while the change to metric may not appear as an advantage to some users, the burden of not switching to metric for companies that support these users is one of economics that eventually will be passed on to all users.

Since the Omnibus Trade and Competitiveness Act requires all federal agencies to convert to the metric system, the need for NRC and other regulatory inspectors to know both systems becomes a burden. Unless licensees are required, rather than encouraged, to change to the new system, regulators must have enough knowledge of both systems to be effective.

The Discussion portion of the policy states that licensed nuclear plants do not participate in world markets. However, it is apparent that reactor designers do and that they have chosen to develop designs using the metric system.

Also in the Discussion, it is stated that a requirement to use the metric system would be an undue burden for licensees who do not deal in an international market. On the contrary, if a large percentage of licensees change to the metric system, those that do not change will place an undue burden on the NRC and radiation protection supply companies who must maintain use of both systems, and they will need to understand the metric units to communicate with those that do change.

APR 15 1992 Acknowledged by card.. "... _'"'"'"""'"nffl

U.S. NUCLEAR REGULATORY COMMISSIOt-..

DOCKETING & SERVICE SECTION OFFICE OF THE SECRETARY OF THE COMMISSION Document Statistics Postmark Date =-3...... /_? ____ _

Copies Received r I Add1 Copies Rep-ro-duc-.,ed-3 ____

Special Distribu~oo f "l>_ R 1 R r ~ s C l)

a.

-z_

U.S. Nuclear Regulatory Commission Page 2 March 17, 1992 As a broadscope licensee, we realize and understand that changing to metric is a time-consuming effort with no apparent health and safety benefit. However, a failure to change also carries burdens associated with conversions that must be made in day-to-day radiation protection (receipt of packages with units in metric, shipment of packages outside the U.S.,

any dealings with companies outside the U.S., submissions to international journals, and interpretation of journal articles, NCRP, and ICRP documents). In this country we are expected to be fluent in both systems of units, yet are not allowed to use metric units for recordkeeping.

Mandatory conversion to the metric system could be done in phases by type of licensee. It appears that the impact on nuclear power plants may be such that a longer period of implementation may be necessary. However, for others, it may only be a matter of changing the format of some records (since some institutions may still maintain old instrumentation in non-metric units but simply convert to metric units for recordkeeping). Implementation of the new 10 CFR 20 in January 1993 provides an excellent opportunity to make the necessary conversion.

While we do support option 2, encouraging licensees to use the metric system, we strongly advocate option 1, requiring the change. We appreciate the opportunity to comment on these proposed rules and would be happy to supply further comments or information if requested.

Sincerely yours,

£~L~

Radiation Safety Officer RJV/cg

u~e1

! *OCKET NUMBER R I

\\

PRoPosEo RULE P m I s c__

(er~ -v 0_.7Ft'-/t'i}j NUCLEAR REGULATORY COMMISSION Conversion to the Metric System AGENCY:

Nuclear Regulatory Commission.

ACTION:

Proposed policy statement.

• 92 FEB -5 P 3 :27

SUMMARY

The Nuclear Regulatory Commission {NRC) is issuing its proposed policy on metrication for public comment.

This action is in response to the Omnibus Trade and Competitiveness Act of 1988, Executive Order 12770 of July 25, 1991 as well as the concerns of certain licensees and groups.

The proposed policy which would affect the NRC's licensees and applicants, is designed to allow them to respond to market forces in determining the extent and timing for their use of the metric system of measurement.

The proposed policy also affects the NRC in that the NRC will adhere to the Federal Acquisition Regulation and the General Service Administration {GSA) metrication program for its own purchases.

The proposed policy would affirm that use of the metric system of mea*surement by Commission 1 icensees is in accordance with protection of the public health and safety.

'I-/,. 7 /q,_

DATES:

The comment period expires on [insert a date to allow 75 days for public comment], 1991.

Comments received after this time will be considered if it is practical to do so, but assurance of consideration cannot be given except for comments received on or before this date.

1

ADDRESSES:

Mail written comments to the Secretary, U.S. Nuclear Regulatory Conmission, Washington, DC 20555, Attention: Docketing and Service Branch.

Deliver co11111ents to One White Flint North, 11555 Rockville Pike, Rockville, Maryland, between 7:30 a.m. and 4:15 p.m. on Federal workdays.

Comments may also be delivered to the NRC Public Document Room, 2120 L Street NW. (Lower Level), Washington, DC, between 7:45 am and 4:15 pm Copies of conunents received may be examined at the NRC Public Document Room.

FOR FURTHER INFORMATION CONTACT:

Dr. Frank A. Costanzi, Chairman, NRC Metrication Oversight Conmittee, U.S. Nuclear Regulatory Co11111ission, Washington, DC 1 20555, telephone:

(301) 492-3760.

SUPPLEMENTARY INFORMATION:

Background

On August 10, 1988, Congress passed the Omnibus Trade and Competitiveness Act (the Act), (19 USC 2901 et seq.), which amended the Metric Conversion Act of 1975, (15 USC 205a et seq.). Section 5164 of the Act (15 USC 205a) designates the metric system as the preferred system of weights and measures for U.S. trade and conmerce.

Congress noted that use of the metric system will improve the competitive position of U.S. products in international markets.

World trade is increasingly conducted in metric units. The European Economic Comnunity's intention to end the use of dual units and to operate exclusively in metric units after January 1, 1992, will further solidify the metric system as the measurement of conunerce.

2

In an effort to effect an orderly change to metric units, the Act requires that all Federal agencies convert to the metric system of measurement in their procurements, grants, and other business-related activities by the end of fiscal year (FY) 1992, "except to the extent that such use is impractical or is likely to cause significant inefficiencies or loss of markets to U.S. firms, such as when foreign competitors are producing competing products in non-metric units,n Section 5614(b)(2).

The mandate by Congress, together with economic pressure on U.S.

companies to compete in global markets, has increased the motivation for metric conversion within the United States. Many corporations involved in international business and trade are presently converting to the metric system.

Some industry codes and standards developed in the United States use the metric system in the form of dual unit reporting or conversion tables.

New codes and standards are increasingly being written in metric units to maintain their international presence and acceptance.

The NRC believes that conversion to the metric system is important to the national interest. The Corrrnission strongly encourages its licensees and license applicants to employ the metric system of measurement wherever and whenever its use is not potentially detrimental to the public health and safety or uneconomic.

This policy statement puts forth the NRC's planned activities regarding its use of the metric system in accordance with the Act.

The term "metric system" refers to the International System of Units as established by the General Conference of Weights and Measures in 1960 as interpreted or modified for the United States by the Secretary of Co1T111erce.

There may be market-driven voluntary support for use of the metric system among some Corrrnission licensees, given that by January 1, 1992, 3

countries in the European Economic Comnunity will convert from dual units to metric units only. After this conversion, it appears that users of radioactive materials will encourage suppliers to adopt rounded metric units because this will be a more convenient measure.

Further, some new nuclear plant designs are being developed in metric units to facilitate worldwide marketing.

The Asea Brown Boveri (ABB) PIUS design, the Canadian CANDU-3 reactor, and portions of General Electric's Advanced Boiling Water Reactor are examples.

The NRC currently conducts most licensing activities in English units.

However, regulations and other regulatory documents have been published in dual units from time to time to allow use of the metric system by licensees if they so desire.

For example, some of the requirements in 10 CFR Part 71 concerning the packaging and transportation of radioactive material are in dual units.

In March 1989, the NRC formed a metrication committee to consider how the provisions of the Act could best be implemented.

The corrm1ttee identified the NRC activities that would be appropriately considered as "business-related activities* under the Act.

The committee also made a number of findings and recorrmendations that have served to provide the foundation of this policy statement.

On November 14 and 15, 1989, the NRC hosted a public workshop in Baltimore, Maryland, to collect information from the nuclear industry, suppliers, research institutions, academia, State governments, and other i.nterested parties regarding recommendations concerning, possible strategies for, and effects of NRC conversion to the metric system.

The salient points 4

made at the workshop are suD111arized in a Corrmission paper, "Report on the Progress of Metrication Activities in the NRC," SECY-90-106, March 21, 1990.

The staff has developed and will publish a NUREG-series report entitled "Review of Metric Conversion Practices and Experience." Its objective is to provide background information to aid metrication planning activities within the NRC.

Included in the report are discussions of the status of metric conversion in the U.S. utility industry, the metrication experfence in Canada's nuclear power industry, and the metrication experiences of U.S.

industries and those of other Federal agencies.

Discussion The purpose of this policy statement is to inform NRC licensees and the public as to how the Co11111ission intends to meet its obligations under the Act.

In developing the policy, NRC is seeking to promote the use of the *metric system of measurement by the licensed nuclear industry while ensuring that protection of the health and safety of the public is maintained, ~iverse viewpoints are considered, and the public is involved.

In developing the policy, the Corrmission considered a range of alternatives by which it might comply with the Act.

The current practice of the NRC is to operate in English units.

However, this ~ractice will not continue for several reasons.

First, to require the continued use of the English system, exclusively, the NRC would need to demonstrate that conversion of all of its procurements, grants, and other business-related activities to the metric system would be impractical or would be likely to cause significant inefficiencies or loss of markets to U.S.

5

firms.

The experience of Canada in general, and its nuclear utilities in particular, in converting to metric strongly argues against such a demonstration.

Second, there is evidence that some NRC materials licensees involved in export trade may wish to operate in metric. If the NRC persisted in operating only in English units, these licensees could suffer a loss of market share because of this NRC practice. Third, some of the planned advanced reactors are being designed in metric, and, if constructed, will operate in metric.

One alternative for compliance with the Act would be an abrupt conversion of NRC activities to metric units. However, this action appears to be neither necessary nor prudent for several reasons. First, licensed nuclear power plants are operated by regulated monopolies or public entities that are not involved in the export business. They, like the bulk of NRC materials licensees, do not participate in world markets. Therefore, the prospect of competitive advantage of employing the metric system of measurement is not directly relevant to these licensees. Second, the NRC has not received any petition for rulemaking from any licensee or applicant requesting it to amend its regulations to conduct licensing and regulatory matters in the metric system.

Third, an abrupt and universal conversion to metric could possibly deleteriously affect the public health and safety because the introduction of an unfamiliar measurement system could lead to cpnfusion and mistakes. This is particularly true in the case of an emergency where quick decisive action will be needed in a high-stress situation. Existing emergency plans are written in English units, and the individuals who would need to act in an emergency, be they licensee personnel or agents of local government, are generally conversant only in English units. Fourth, requiring licensees whose 6

market uses the English system to deal with the NRC only in metric units would pose an economic burden on those licensees with no safety or other benefit.

A practical approach to using the metric system is one that is both consistent with the intent and direction of the Act and yet does not introduce the safety concerns noted above or result in an economic burden to licensees or applicants. This type of approach would result in the use of the metric

.system by those licensees and license applicants for whom the use of the metric system presents no economic disadvantage and no safety detriment to the public.

One option would be to require, by rulemaking, licensees and applicants to use the metric system by some date except where this use would raise* potential public health and safety concerns or would otherwise be impractical. Another option would be to encourage, as a matter of NRC policy, the use of the metric system by applicants and licensees but allow the action of the market forces to determine which applicants and licensees employ the metric system, with due consideration for safety. Under both options, changes to NRC documents and procedures would need to be made to facilitate applicants' and licensees' use of the metric system.

The arguments for and against these options are set forth below.

Option I. Require licensees and license applicants to use the metric system in dealings with the NRC through a rulemaking action.

The rulemaking option would involve the public in the decision, result in a clear and certain date after which new applications would have to be in the metric system of measurement, and provide strong evidence that the NRC is fully committed to the intent of the legislation. However, requiring the use of the metric system by rule would force applicants and licensees for whom use 7

of the metric system would introduce safety concerns or cause economic penalties without connensurate benefit to seek and justify an exemption to the Co1T1T1ission's regulations. If,all power plant licensees were required to convert to the metric system by rulemaking, the NRC would expect them to request exemptions on the basis of incurred costs with no safety benefit.

Similarly, future power plant applicants whose applications reference certified designs based on the English system would be expected to prefer submitting their applications in English units and to plan, build, operate, and maintain their prospective plants in the English system.

If these applicants were required to use the metric system by rule, the NRC would expect them to request an exemption on the basis that there is no safety benefit (i.e., reduction in risk) against which to offset the cost of converting the certified designs to metric.

In addition, materials licensees whose market and principal business dealings operate in the English system of units would not be likely to see any incentive to use metric and could be expected to seek exemptions.

While the NRC could attempt to identify categories of these applicants and licensees and specifically exempt them in the rule, some applicants and licensees would still need to seek an exemption. Those applicants and licensees would be forced to incur the cost of seeking an exemption to a requirement that has no associated safety benefit. Finally, NRC resources would have to be diverted from dealing with safety issues to instituting the requisite metric conversion rulemaking and executing conforming changes to convert pertinent regulations, guides, and standards to metric to allow affected applicants and licensees to demonstrate compliance in the metric system.

8

Option 2.

Encourage NRC licensees and license ~pplicants to use the metric system through a policy statement.

Through a policy statement, the Co11111ission would encourage use of the metric system and conmit the agency to work with licensees and applicants and with national, international, professional, and industry standards-setting bodies (e.g., ANSI, ASTH, ASME) to ensure metric-compatible regulations and regulatory guidance.

Proceeding by policy statement would meet the obligations of the agency under the law to convert its "business-related activities" to the metric system of measurement *to the extent practica]N without imposing an unnecessary burden on licensees or applicants who, for safety or economic reasons, cannot use the metric system and who, otherwise, would have to request exceptions from a Co11111ission regulation.

However, proceeding through a non-binding statement of policy rather than through a binding regulation might be interpreted to be inconsistent with the leadership role in converting the U.S. economy to metric envisioned by the Congress in passing the Act.

Moreover, changing NRC documents and procedures to facilitate a voluntary use of metric by applicants and licensees would require expenditure of NRC resources.

However, this *voluntary metrication" can be acco11111odated as needed to support individual license reviews and rulemaking actions without the major program disruption that would occur if all relevant licensing documents and procedures were to be converted by some fixed date, which would seem necessary if the Commission were to require by rulemaking the use of the metric system.

9

Decision Rationale Expenditure of either licensee or Co11111ission resources with no offsetting safety or administrative benefit is contrary to sound regulation.

Ir. this regard, the NRC notes the unique responsibilities of the agency in that its business activities are to ensure public health and safety in the co11111ercial use of nuclear materials through its program of licensing and regulation. The Co11111ission can assume that a licensee or applicant would use the metric system voluntarily when it is economically attractive to do so.

Howe~er, any effort on the NRC's part to use metric units must consider the impact on the regulated industry (existing and future), the NRC, Agreement States, and other affected agencies.

For example, under the Atomic Energy Act of 1954, as amended, Agreement States are required to adopt rules for radiation protection comparable to the NRC's within 3 years after the NRC amends a regulation.

Some States may not possess the resources to convert their dealings with their licensees to metric. Moreover, in some States,

/

changes in regulations require action by the State legislature.

The NRC does not perceive any economic need for or benefit to existing nuclear power plant licensees to convert to metric.

Nor does the NRC see any benefit to fuel cycle facilities that serve the present domestic nuclear power industry from the conversion. Moreover, while there is nothing inherently safe or unsafe in any measurement system, changing power plant qperations from a familiar system to an unfamiliar system could be detrimental to safety.

Use of unfamiliar units could result in operator error or incorrect or ineffective maintenance that could lead to an emergency.

Use of unfamiliar untts during an emergency could cause mistakes as well as misconvnunicati.on with and 10

confusion of those State and local government individuals who need to respond to emergencies, making their response less effective than it might be otherwise. These individuals and their organizations are not subject to NRC regulations and are beyond the reach of NRC's metrication policy and efforts~

The NRC should not and will not allow licensees whose conversion might be detrimental to public health and safety to do so, voluntarily or otherwise.

In particular, event reporting and emergency response co11111unications between licensees, the NRC, and State and local authorities for the present must be in the English system so as not to bring potential confusion to an emergency situation.

Other existing licensees (e.g., source and byproduct material licensees) may indeed have some economic incentive for converting if they perceive a market advantage in doing so. Moreover, as stated previously, there may be some advantage to applicants for advanced reactor licenses and new fuel cycle and materials licenses to employ the metric system.

Whether the Conun1ss1on proceeds by rulemaking or through a policy statement, the endpoint is likely to be the same.

Each option will result in a mix of licensees and applicants using both the metric and the English systems.

Therefore, it 1s the Commission's view that the prudent course is to encourage and facilitate the use of the metric system by the industry that it regulates but not to attempt to force its use where it would be unsafe or impractical. Thus the Commission is complying with the Act by issuing a policy statement that (1)

Encourages the use of the metric system by its licensees and applicants; 11

(2)

Indicates that the Conmission will initiate NRC staff training in the metric system and modify documents and procedures as needed to facilitate and support the use of the metric system by applicants and licensees;

{3)

Commits the NRC to begin that process by publishing all new rulemak1ng actions and other related documents, e.g., regulatory guides, in dual units at the earliest date practical, but no later than September 30, 1992.

(4)

Pledges the NRC to work with and encourage the licensed nuclear industry to employ the metric system through NRC staff participation in the activities of appropriate standards-setting organizations and other industry groups; (5)

Requires use of the English system for event reporting and emergency response. communications between licensees, the NRC, and State and local authorities; and (6)

Commits the staff to revisit this policy in 3 years to determine if any changes are necessary.

With respect to the publishing of all regulatory activities and documents in dual units, parameters will be published first in the I

International System of Units with the Inglish unit equivalents following parenthetically.

1 When possible, all new specifications will be derived using the metric system.

If a conflict or inconsistency with existing safety requirements would result, the new specification will be derived in the English system.

1Equivalent means precise value in the alternative system of units to the same number of significant figures as the original.

For example, the metric equivalent of 0.10 mCi is 3.7 MBq, but the equivalent of 1 x 10-1 mCi is 4 MBq.

12

This action would comply with the requirement of the Act for the Colllllission to convert its business practices to the metric system to the extent practical and would conform to the spirit of the Act by encouraging the use of the metric system of measurement.

In addition, this action responds to Executive Order 12770, "Metric usage in Federal Government Programs,1' which was signed by the President on July 25, 1991.

Its purpose is to "to implement the congressional designation of the metric system of measurement as the preferred system of weights and measures for United States trade and commerce."

Further, the Executive Order directs all executive branch departments and agencies "to take all appropriate measures within their authority to carry out the provisions of this order.

11 These responsibilities basically include --

(1)

Drafting a metric conversion plan by November 30, 1991; (2)

Establishing the metric system of measurement in procurements, grants, and other business-related activities by September 30, 1992; (3)

Increasing understanding of the metric system through educational information and guidance and in Government publications; (4)

Seeking appropriate aid, assistance, and cooperation of other affected parties in implementing this order; and (5)

Designating a senior-level official as the Metric Executive to assist in the implementation of the order.

The Executive Order also calls for metrication progress reports to be made to the President and the Congress.

The proposed policy statement serves the purpose of responding to the first two responsibilities by defining the agency's metric conversion plan, and establishing the NRC's use of the metric system, to the extent practical. The third and fourth responsibilities are 13

also addressed in the statement through the commitments to initiate staff training in the metric system, the publication of NRC documents in dual units, and the pledge "to work with and encourage the licensed nuclear industry to employ the metric ~ystem.... " The publication of this policy for public comment is another vehicle for complying with the fourth item.

Paperwork Reduction Act Statement This policy statement contains no information collection requirements and therefore is not subject to the requirements of the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.).

Statement of Policy The NRC supports and encourages the use of the metric system of measurement by the licensed nuclear industry.

In order to facilitate the use of the metric system by licensees and applicants, beginning September 30,.

1992, the NRC will publish all regulatory actions and related documents in dual units. These include new regulations, major amendments to existing regulations, regulatory guides, and NUREG-series documents.

The NRC will modify existing documents and procedures as needed to facilitate use of the metric system by licensees and appltcants.

In addition, the NRC will initiate a program of staff training in the metric system.

Further, through its participation on national, international, professional, and industry standards organizations and connnittees and through its work with other industry organizations and groups, the NRC will encourage and further the use of the 14

metric system in formulating and adopting standards and policies for the licensed nuclear industry.

However, should the use of any particular system prove to be detrimental to the public health and safety, the Corrmission will proscribe, by regulation, order, or other appropriate means, the use of that system.

In particular, all event reporting and emergency response corrmunications between licensees, the NRC, and State and local authorities will be in the Eng,li sh system of measurement,. After 3 years, the Corrmi ssi on will assss the state of metric use by the licensed nuclear industry in the United States to determine whether this policy should be modified.

Lastly, the NRC will follow the Federal Acquisition Regulation in executing procurements.

Public Corrment NRC is interested in receiving public corrment on any aspect of this proposed policy statement.

In particular, the NRC is interested in corrments on the extent to which guidance is presently available on the selection of "metric equivalent" corrmon mechanical and electrical components, especially those that may have safety-related functions (e.g., selection of the appropriate metric thread size and pitch for a safety-related closure, or selection of the appropriate metric wire size for a safety-related electrical circuit).

In addition, the NRC is interested in any possible impacts of metrication on NRC regulations as they relate to national and international standards such as those developed by the ASME, ANSI, and IEEE. 15

All convnents should include a basis and rationale for suggested changes.

Dated at Rockville, Maryland, this 3t/!day of Jo..~, 1992.

For the Nuclear Regulatory Commission.

16