ML23156A463

PR-MISC - 60FR49928 - Conversion to the Metric System; Policy Statement

ML23156A463
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Issue date:	09/27/1995
From:	Hoyle J NRC/SECY
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PR-MISC, 60FR49928
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ADAMS Template: SECY-067 09/27/1995 PR-MISC - 60FR49928 - CONVERSION TO THE METRIC SYSTEM; POLICY STATEMENT PR-MISC 60FR49928 RULEMAKING COMMENTS Document Sensitivity: Non-sensitive - SUNSI Review Complete

STATUS OF RULEMAKING PROPOSED RULE:

PR-MISC OPEN ITEM (Y/N) N RULE NAME:

CONVERSION TO THE METRIC SYSTEM; POLICY STATEMENT PROPOSED RULE FED REG CITE:

60FR49928 PROPOSED RULE PUBLICATION DATE:

09/27/ 95 ORIGINAL DATE FOR COMMENTS : 12/11/95 NUMBER OF COMMENTS:

EXTENSION DATE:

I I

4 FINAL RULE FED. REG. CITE: 61FR31169 FINAL RULE PUBLICATION DATE: 06/19/ 96 NOTES ON: FINAL POLICY STATEMENT EFFECTIVE 6/19/ 96.

FILE LOCATED ON Pl.

STATUS OF RULE :

HISTORY OF THE RULE PART AFFECTED: PR-MISC RULE TITLE:

CONVERSION TO THE METRIC SYSTEM; POLICY STATEMENT PROPOSED RULE SECY PAPER:

FINAL RULE SECY PAPER: 96-098 PROPOSED RULE SRM DATE:

FINAL RULE SRM DATE:

DATE PROPOSED RULE I

I SIGNED BY SECRETARY:

09 / 14/ 95 DATE FINAL RULE 05/24/ 96 SIGNED BY SECRETARY:

06/12/ 96 STAFF CONTACTS ON THE RULE CONTACT!: FRANK A. COSTANZI CONTACT2:

MAIL STOP: T9-F33 MAIL STOP:

PHONE: 415-6250 PHONE:

DOCKET NO. PR-MISC (60FR49928)

In the Matter of CONVERSION TO THE METRIC SYSTEM; POLICY STATEMENT DATE DATE OF TITLE OR DOCKETED DOCUMENT DESCRIPTION OF DOCUMENT 10/04/95 11/13/95 12/11/95 12/13/95 12/14/95 09/14/95 11/08/95 FEDERAL REGISTER NOTICE:

POLICY STATEMENT; REQUEST FOR PUBLIC COMMENT COMMENT OF NUCLEAR ENERGY INSTITUTE (WILLIAM H. RASIN) (

1) 12/05/95 COMMENT OF DUKE POWER CO (M.S. TUCKMAN) (

2) 12/11/95 COMMENT OF TU ELECTRIC (C. LANCE TERRY, GROUP VICE PRES.) (

3) 12/11/95 COMMENT OF VIRGINIA POWER (ROBERT F. SAUNDERS) (

06/14/96 06/12/96 FEDERAL REGISTER NOTICE:

FINAL POLICY STATEMENT

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DOCKETED

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'96 J 14 p 1 :58 NUCLEAR REGULATORY COMMISSION Conversion to the Metric System; Policy Statenfenfl "

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Nuclear Regulatory Commission.

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ACTION:

Final policy statement.

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SUMMARY

On September 27, 1995, the U. S. Nuclear Regulatory Commission (NRC) published a request for public comment on its existing metrication policy.

This action was taken in accordance with the NRC's policy statement of October 7, 1992, in which the Commission was to assess the state of metric use by the licensed nuclear industry in the United States after 3 years to determine whether the policy should be modified.

The purpose of this notice is to inform the public of the Commission's decision that its Statement of Policy on Conversion to the Metric System does not need to be modified, that it considers this policy final, and that its conversion to the metric system is complete.

EFFECTIVE DATE:

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fDate of ~

OR iR tl:le Federal Register.~

FOR FURTHER INFORMATION CONTACT:

Dr. Frank A. Costanzi, Chairman, NRC Metrication Oversight Committee, U.S. Nuclear Regulatory Commission, Washington, DC 20555; telephone: (301) 415-6250; e-mail FAC@nrc.gov.

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SUPPLEMENTARY INFORMATION:

Background

On September 27, 1995 (60 FR 49928}, the U.S. Nuclear Regulatory Commission (NRC} published a request for public comment on its policy statement on Conversion to the Metric System1 in the Federal Register. This request for public comment was in accordance with the Policy Statement published on October 7, 1992 (57 FR 46202}, which called for the Commission to determine, after 3 years, whether the policy should be modified.

Before the publication of the request for public comment, the NRC staff contacted various industrial, standards, and governmental organizations to determine their view of the policy.

The organizations contacted included the American National Standards Institute (ANSI }, the American Society for Testing and Materials (ASTM}, the American Society of Mechanical Engineers (ASME}, the Institute of Electrical and Electronics Engineers (IEEE), Inc., the Nuclear Energy Institute (NEI}, the Nuclear Utility Backfitting and Reform Group (NUBARG}, the United States Pharmacopeial Convention (USP), Inc., the Society of Nuclear Medicine, and the Organization of Agreement States (OAS}.

Comments Received With few exceptions, these various organizations stated their support for the current NRC policy.

The nuclear power industry position seems to be 1The metric system refers to units bel onging to the Internationale System of Units, which is abbreviated SI (from the French Le Systime Internationale d'Unites}, as interpreted or modified for use in the United States by the Secretary of Commerce.

2

exemplified by the NE! comments in which they continue to support the current NRC Metrication Policy and "a transition to the metric system that is market-driven and avoids a sudden or precipitous move to conduct licensing and regulatory matters in metric units."

As for the standards-setting groups, ASME strongly supports the Omnibus Trade and Competitiveness Act 2 and believes that the NRC policy is in accordance with those requirements.

IEEE related that its "standards are to be primarily metric beginning in 1998 and, with minor exceptions, exclusively metric beginning in 2000." Also, IEEE believes that the United States Government "can and should do more than it has done to further the metrication process in this country."

In response to the NRC's request, IEEE provided the following three comments relating directly to the NRC's position:

(1)

The NRC should drop the use of dual units in its publications and to use "metric units exclusively except where doing so would clearly be detrimental to public health and safety."

(2)

The NRC policy of using the English system for all event reporting and emergency response communications, although prudent in 1992, may now cause confusion and have a negative impact after various relevant standards have been converted.

(3)

The NRC should include the following statement in its policy:

"Nothing in this statement of policy should be interpreted to require the use 20n 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 ~Jq.). Section 5164 of the Act (15 USC 205a) designates the metric system as the preferred system of weights and measures for the 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 1992.

3

of the English system of measurement, or to forbid the use of consensus based standards that are exclusively metric." This was proposed so those in the private sector who wish to move faster than the Government may be protected.

With respect to IEEE's first comment concerning the dropping of dual units, the NRC believes that because of the relatively low number of licensees operating in the metric system, it would not be beneficial to make such a change, especially because it would not lead to any improvement in the public health and safety.

IEEE's second comment calls for dropping that portion of the policy requiring event reporting and emergency communication between licensees and any Government agency to be in the English system of measurement.

IEEE believes that the English-only event reporting and emergency communication may have a negative impact after various relevant standards have been converted to the metric system.

To consider such a change is premature, because the standards refe~red to by IEEE have not been converted.

The IEEE's last comment calls for the insertion of a statement noting that use of the English system is not required and that the use of metric standards is not prohibited. This statement is consistent with the NRC policy as written, with the exception of the use of the English system in event reporting and emergency communication as discussed above.

The USP pointed out that the use of dual units by NRC is in line with USP's position and practice. However, the OAS position is that "to be truly responsive to Congress the Commission now should go on record as requiring the use of SI units in all its communication and documentation." Also, OAS recommended that the NRC "support the dual citation standard with the SI unit appearing first and the English or special units following in brackets or parentheses" to accommodate the editing style of the various States.

As noted 4

in the October 7, 1992, Federal Register notice announcing the NRC's metrication policy, the NRC believed and continues to believe that if metrication were made mandatory by a rulemaking, no corresponding improvement in public health and safety would result but costs would be incurred without benefit. The editing style recommended by OAS is consistent with NRC policy.

Comments were not received from the remaining groups contacted by the NRC staff.

Four letters were received in response to the September 27, 1995, request for public comment.

They were from NEI and three nuclear power utilities. NEI's statement remained consistent with their earlier positions on metrication, namely that they did not believe that it would be in the best interest of safety for the NRC to require nuclear power reactors to be operated using SI units. Also, NEI continues to support the NRC's policy and recommended that the policy remain unchanged.

With respect to the individual utilities which responded, one requested that the NRC not change the part of the policy which requires that all event reporting and emergency response communications between licensees and any Government authority be in the English system of measurement.

Another utility endorsed NEI's position and believes the existing policy is reasonable.

The third utility also endorsed the NEI position and "strongly discourage(d)" any change to that part of the policy reouiring event reporting and emergency response communications between licensees and any Government authorities to be in the English system of measurement.

5

Small Business Regulatory Enforcement Fairness Act In accordance with the Small Business Regulatory Enforcement Fairness Act of 1996, the NRC has determined that this action is not a major rule and has verified this determination wi th the Office of Information and Regulatory Affairs of 0MB.

Statement of Policy The Commission's policy on Conversion to the Metric System remains essentially as stated in the Federal Register (57 FR 46202) of October 7, 1992.

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

In order to facilitate the use of the metric system by licensees and applicants, beginning January 7, 1993, 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 communications directed to the public.

Documents specific to a licensee, such as inspection reports and docketed material dealing with a particular licensee, 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 operat2 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 6

System of Units with the English unit shown in brackets.

The NRC will modify existing documents and procedures as needed to facilita+ ~ 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, if the NRC concludes that the use of any particular system of measurement would be detrimental to the public health and safety, the Commission will proscribe the use of that system by regulation, order, or other appropriate means.

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.

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

Lastly, the e

Commission considers this policy final and conversion to the metric system complete.

The Commission does not intend to revisit this policy unless it is causing an undue burden or hardship.

Dated at Rockville, Maryland, this IJ. ":f day of ~*

1996.

For the Nuclear Regulatory Commission.

Jo Se 7

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Commission.

ROBERT F. SAUNDERS Vice President - Nuclear Operations December 11, 1995 Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn: Docketing and Service Branch

Dear Sir:

DOCKETED USNRC

'95 DEC 14 A10 :09 CONVERSION TO THE METRIC SYSTEM POLICY STATEMENT; REQUEST FOR PUBLIC COMMENT Innsbrook Jechnical center 5000 Dominion Boulevard Glen Allen, Virginia 23060 804*273*2101 VIRGINIA POWER Serial No. GL 95-062 NL&OS/EJL FEDERAL REGISTER/ Vol. 60, No. 187 / SEPTEMBER 27, 1995 / p. 49928 On October 7, 1992 the U. S. Nuclear Regulatory Commission (NRC) published its policy statement on Conversion to the Metric System. The purpose of the current notice is to gain additional information on the state of metric use by N RC licensees so that the Commission may determine whether the NRC's metrication policy should be modified.

We agree with the comments in the notice that have been provided by the Nuclear Energy Institute (NEI). NEI continues to support the current NRC Metrication Policy and counsels that a sudden move to conduct licensing and regulatory matters in metric units should be avoided. We believe that an abrupt conversion to the metric system would cause a substantial increase in human performance errors, and that the conversion process would be costly and burdensome without providing a commensurate benefit.

The cost and burden would result from the additional training, equipment conversions, policy and procedure revisions, etc. that would be required for the implementation of the conversion.

More specifically, the notice describes the current policy requirement that all event reporting and emergency response communications between licensees and any government authorities will be in the English system of measurement. We support this aspect of the policy and strongly discourage any changes at this time.

Finally, we fully endorse the comments sent separately to the NRC by NEI in their letter dated November 8, 1995. We appreciate the opportunity to provide comments on this policy statement.

Very truly yours, Rd~~

R. F. Saunders DEC 2 7 1995 -

AcknowJoogod y card.......................... "'"'"

U.S. NUCLEAR REGULATORY COMMISSIOt-.

DOCKETING & SERVICE SECTION OFFICE OF THE SECRETARY OF THE COMMISSION Document Statistics Postmark Dato _,...'+'-"'"+"......_ ___

Copies Rem,~d_,__ _____ _

l\\dd'l Copies Re;xoduce

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cc: Mr. A. L. MacKinney Project Manager, Special Projects Technical/Regulatory Division Nuclear Energy Institute 1776 I Street N.W.

Suite 400 Washington, DC 20006-3708 Conversion to the Metric System Serial No. GL 95-062 page2 of 2

C. Lance Terry Group Vice Pre.,idem 1UELECTRIC Log # TXX-95307 File # 10010 DOCKETED UStJRC

• 95 OEC 13 P 3 :34 OFFICE or ~[CRF TARY OOCK.... T I

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December 11, 1995 BRAth.:H Secretary, U. S. Nuclear Regulatory Commission Attn: Docketing and Service Branch DOCKET NUMBER PR PROPOSED RULE m>iiic..

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Washington. DC 20555

SUBJECT:

REF:

Gentlemen:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

COMMENTS TO NRC POLICY STATEMENT ON CONVERSION TO THE METRIC SYSTEM 60 Fed. Reg. 49928, September 27, 1995 In the referenced Federal Register notice, the NRC requested comments and additional information on the state of metric system use by NRC licensees so that the Commission may determine whether the NRC's current metrication policy should be modified.

The NRC policy statement on Conversion to the Metric System was published on October 7. 1992 (57 FR 46202).

The statement was in response to the Omnibus Trade and Competitiveness Act of 1988 and Executive Order 12770.

The Commission's policy supports and encourages the use of the metric system of measurement and requires the NRC to follow federal regulations and programs in executing NRC procurements.

It further requires the NRC to publish essentially all documents which are not specific to a given licensee in dual units. i.e., International System of Units first with English units in brackets. A key component of the policy requi res that "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."

As a result, the policy requires that all event reporting and emergency response communications between licensees and any government authorities will be in the Engl ish system of measurement.

rDEC 1 4 1995 Actmowtedged by card........-........ -.-

Energy Plaza 1601 Bryan Street Dallas, Texas 75201-3411

L.S. NUCLEA'; i,.

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DOCKETING & SERV'CE SECTION OFFiCE OF lHE SECRETARY OF THE COMMISSION 0-Jcu:nant Statistics Postmark Date _.u.,~~~ ----

Copies Rec.eiv~d _ _.__ _____ _

Add1 Copies Reproduced --""'-------

Special Distribution~ed:;; -a:i-J:l?S>e,

TXX-95307 Page 2 of 2 As part of the assessment of the state of metric system use and whether the Commission' s policy should be modified, the NRC staff contacted various industrial and standards groups to determi ne their association's view of the current NRC policy. The Nuclear Energy Institute (NEI) response was to support the current NRC Metrication Policy and a transition to the metric system that is market -driven and avoids a sudden or precipitous move to conducting licensing and regulatory matters in metric units.

TU Electric endorses the NEI view and believes the Commission ' s existing policy statement is reasonable as currently written.

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Hr. T. J. Polich, NRR Mr. T. E. Tipton, NEI Sincerely,

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C. L. Terry By:~

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Roger~a 1 ker Regulatory Affairs Manager

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Duke Power Company P.O. Box 1006 DOCKETED usrmc M. S. TuCKMAN Senior Vice President Nuclear Generation (704)382-2200 Office (704)382-4360 Fax Charlotte, NC 28201-/006 DUKEPOWER December 5, 1995 Secretary U. S. Nuclear Regulatory Commission Washington, DC 20555 Attn.: Docketing and Service Branch

• 95 DCC 11 p3:42 DOCKET NUMBER PR PROPOSED RULE f5\\ \\ ;:,s;d

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Subject:

Policy Statement, "Conversion to Metric System," 60 FR 49928, September 27, 1995 Duke Power Company would like to offer the following comments on the Policy Statement, "Conversion to Metric System," 60 FR 49928, September 27, 1995.

Duke Power requests that portion of the p9licy which requires that all event reporting and emergency response communciations between licensee and any Government authority will be in the English system of measurement be retained. During an emergency event, licensees will be communicating with multiple Government authorities (i.e., Federal, State, and Local). Communicating with different governmental authorities in different systems of measurement increases the potential for miscommunication of information vital to public health and safety.

Yours truly, Y\\,~. '\\~

M. S. Tuckman MST/EMK/c:\\doc\\nrcmetr.doc Printed on recycled paper

'DEC 1 4 1995 Acllnowledged by card...................... "...-'""'""

U.S. NUCU:AH REGULATORY COMMISSIOf\\.

DOCKETING & SERVICE SECTION OFFICE OF THE SECRETARY OF THE COMMISSION Doc,c:Bt'! Statistics Postman< Dat3 Jap.~-----

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Special Oistr:bution { \\,ct;.--..:_ ;:xo~

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November 8, 1995 Mr. John C. Hoyle Secretary I

DOCKETED USNRC NUCLEAR ENERG Y I NST I TUTE

• 95 NO\\' 13 A11 : 1 8 OFFICE OF S::":CR[TJ\\RY OOCKE TIHG & 3HlY1CE BRANCI"!

U.S. Nuclear Regulatory Commission Washington, D. C. 20555-0001 ATTENTION:

Dear Mr. Hoyle:

Docketing and Services Branch Conversion to the Metric System - Policy Statement (60 Fed. Reg. 49928-September 27, 1995)

Request for Public Comment William H. Rasin SENIOR VICE PRESIDENT TECHNICAL/REGULATORY The Nuclear Energy Institute (NEl)1 is submitting comments on behalf of the nuclear energy industry in response to the request for public comment on whether the current NRC Metrication Policy should be modified.

Thank you for considering comments by NUMARC, now NEI, of April 24, 1992, supplemented by NEI's letter to Dr. Frank A Costanzi of March 10, 1995. We believe that our earlier comments presented in these two letters are still valid and that current NRC Metrication Policy adequately reflects these comments. We believe that it will not be in the best interests of safety to require a major change in the system of units to which a particular profession or industry segment is accustomed. The examples that you offered in the referenced Federal Register notice relating to radiation oncology and operational health physics illustrate this point; however, there is a possibility of significant errors if unfamiliar systems are required.

1 NEI is the organization responsible for establishing unified nuclear industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include all utilities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel fabrication facilities, materials licensees, and other organizations and individuals involved in the nuclear energy industry. NEI is the successor organization to the Nuclear Management and Resources Council (NUMARC).

OV 1 "B' 19951._

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1776 I STREET, NW SUITE 400 WASHINGTON DC 20006-3708 PHONE 202 739 8088 FAX 202 785 1898

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Mr. John C. Hoyle November 8, 1995 Page 2 While we continue to support the NRC's current policy and practice of using dual units, we believe there will be an orderly conversion to the SI system of units as advanced reactor designs are certified and plants are licensed.

In summary, we recommend that the NRC Metrication Policy Statement as published in the Federal Register on October 7, 1992 (57 Fed. Reg. 46202), remain unchanged.

Sincerely, William H. Rasin WHR/ALM/ec

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Oricj.oal sora ~~~al Renlster OffiCil o\\ the n,uer

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for publication DOCKETED USNRC "95 OCT -4 P 2 :42 OFFICE OF SECRETARY DOCKETING & SERVICE BRANCH NUCLEAR REGULATORY COMMISSION Conversion to the Metric System AGENCY:

Nuclear Regulatory Commission.

ACTION:

Policy statement; request for public comment.

[759O-O1-P]

SUMMARY

On October 7, 1992, the U.S. Nuclear Regulatory Commission (NRC) published its policy statement on Conversion to the Metric System in the Federal Register.

The policy called for the Commission to assess the state of metric use by the licensed nuclear industry in the United States after 3 years to determine whether the policy should be modified.

The purpose of this notice is to gain additional information on the state of metric use by NRC licensees so that the Co11111ission may determine whether the NRC's metrication policy should be modified.

~

-c--Sl,..- \\ \\ J DATES:

The comment period expires on [iRsert a date te allew 75 days Ferr

~ublic cgmm0Rt-3, 1995.

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.

ADDRESSES:

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

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

Co1T111ents may also be delivered to the NRC Public Document Room, 2120 L Street NW. {Lower Level), Washington, DC, between 7:45 a.m. and 4:15 p.m.

Copies of comments received may be examined at the NRC Pubiic Document Room.

For information on submitting convnents electronically, see the discussion under Electronic Access in the Supplementary lnfonnation Section.

FOR FURTHER INFORMATION CONTACT:

Dr. Frank A. Costanzi, Chairman, NRC Metrication Oversight Convnittee, U.S. Nuclear Regulatory Commission, Washington, DC 20555; telephone (301) 415-6250; e-mail FAC@nrc.gov.

SUPPLEMENTARY INFORMATION:

Background

On October 7, 1992 (57 FR 46202), the U.S. Nuclear Regulatory Corrmission (NRC) published its policy statement on Conversion to the Metric System 1 in the Federal Register.

The statement was in response to the Omnibus Trade and Competitiveness Act of 1988 (the Act) and Executive Order 12770.

The policy supports and encourages the use of the metric system of measurement and 1The metric system refers to units belonging to the Internationale System of Units, which is abbreviated SI *(from the French Le Systeme Internationale d'Units), as interpreted or modified for use in the United States by the Secretary of Colllllerce.

2

requires the NRC to follow the Federal Acquisition Regulation and the General Services AdministratiQn metrication program in executing procurements.

It further requires the NRC to publish essentially all documents which are not specific to a given licensee in dual unjts, i.e., International System of Units first with the English unit in brackets. A key component of the policy requires that "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."

As a result, the policy requires that all event reporting and emergency response communications between licensees and any Government authorities will be in the English system of measurement.

Finally, the policy calls for the Conrnission to assess the state of metric use by the licensed nuclear industry in the United States after three years to determine whether the policy should be modified.

In order to implement this last portion of the policy, the NRC staff has undertaken several actions. First, the NRC's Metrication Oversight Committee met to discuss both agency and licensee experiences with the Commission's metrication policy.

Next, representatives of various industrial and standards groups were contacted to determine their association's view of the policy.

The associations contacted included the American National Standards Institute (ANSI), the American Society for Testing and Materials (ASTM), the American Society of Mechanical Engineers (ASME), the Institute of Electrical and Electronics Engineers, Inc. (IEEE), the Nuclear Energy Institute (NEI), the Nuclear Utility Backfitting and Reform Group (NUBARG), the United States Pharmacopeial Convention, Inc. (USP), the Society of Nuclear Medicine, and the Organization of Agreement States (OAS).

The Committee's findings follow.

3

Corrments Received With few exceptions, these various organizations stated their support for the current NRC policy. The nuclear power industry position seems to be exemplified by the NEI connnents-in which they continue to support the current NRC Metrication Policy and "a transition to the metric system that is market-driven and avoids a sudden or precipitous move to conduct licensing and regulatory matters in metric units.* Similarly, although NUBARG did not respond in writing, a phone conversation with a representative indicated that NUBARG was "very comfortablea with the NRC's metrication policy.

As for the standards-setting groups, ASME strongly supports the Omnibus Trade and Competitiveness Act and believes that the NRC policy is in accordance with those requirements.

IEEE related that its "standards are to be primarily metric beginning in 1998 and, with minor exceptions, exclusively metric beginning in 2000.

11 Also, IEEE believes that the United States Government "can and should do more than it has done to further the metrication process in this country."

In response to the NRC's request, IEEE provided the following three connnents relating directly to the NRC's position:

(1)

The NRC should drop the use of dual units in its publications and to use "metric units exclusively except where doing so would clearly be detrimental to public health and safety."

{2)

The NRC policy of using the English system for all event reporting and emergency response corrmunications, although prudent in 1992, may now cause confusion and have a negative impact after various relevant standards have been converted.

(3)

The NRC should include the following statement in its policy:

4

"Nothing in this statement of policy should be interpreted to require the use of the English system of measurement, or to forbid the use of consensus based standards that are exclusively metric." Thts was proposed so elements of the private sector that wish to move faster than the Government may be protected.

The USP pointed out that the use of dual units by NRC is in line with USP's position and practice. However, the OAS position is that "to be truly responsive to Congress the Commission now should go on record as requiring the use of SI units in all its colll'llunication and documentation."

OAS recommended that the NRC "support the dual citation standard with the SI unit appearing first and the English or special units following in brackets or parentheses... " to accolll'llodate the editing style of the various States.

Comments have not been received from the remaining groups.

Status of Licensee Metrication Efforts Reactors Although there are no power reactor licensees operating in the metric system, some of the advanced reactors have vendor-generated licensing documents that use the metric system of measurement.

For example, both of General Electric's applications for the ABWR and SBWR designs have their Standard Safety Analysis Reports (SSAR) in the SI system of measurement.

However, both the Westinghouse AP600 and the ABB-CE System 80+ have their SSARs in the traditional inch-pound system.

The NRC's completed Final Safety Evaluation Reports (FSER) for the System 80+ and the ABWR are in dual units as prescribed by the Commission's policy statement.

When the FSERs for the AP600 5

and the SBWR are publtshed, they also will be in dual units.

Selected Examples of Metric Usage There are varying degrees of use of the metric system of measurement by the non-power reactor nuclear industries. Also, within a particular profession or industry, there are varying degrees of metric use.

For example, in the field of radiation oncology, the centigray (an SI unit} has been the meter of therapy doses, while the m1llicurie and curie (traditional units} are used as the measure expressing quantity or dosages.

Health Physics It is also the case that most of the operational health physics community still uses the traditional system of measurement because of the use of instrumentation that is calibrated or expressed in that system.

Some newer instrumentation that offers dual-unit options will assist in metric conversion, as the new instruments are being integrated into existing stock.

Public Comment The NRC staff, through this request, is inviting comment from interested individuals on the NRC's metrication efforts to learn if there is a need for the ColllTiission to revise its metrication policy.

6

Electronic Access Cori111ents may be submitted electronically, in either ASCII text or Wordperfect format (version 5.1 or later), by calling the NRC Electronic Bulletin Board on FedWorld.

The bulletin board may be accessed using a personal computer, a modem, and one of the. co11111only avail able communications software packages, or directly via lnternet.

If using a personal computer and.modem, the NRC subsystem on FedWorld can be accessed directly by dialing the toll free number: 1-800-303-9672.

Communication software parameters should be set as follows:

Parity to none, data bits to 8, and stop bits to 1 (N,8,1). Using ANSI or VT-100 terminal emulation, the NRC rulemaking subsystems can then be accessed by selecting the "Rules Menu" option from the "NRC Main Menu."

For further information about options available for NRC at FedWorld consult the "Help/Infonnation Center" from the 11NRC Main Menu."

Users will find the "FedWorld Online User's Guides" particularly helpful. Many NRC subsystems and databases also have a "Help/Information Center" option that is tailored to the particular subsystem.

The NRC subsystem on FedWorld can also be accessed by a direct dial phone number for the main FedWorld BBS: 703-321-8020; Telnet via Internet:

fedworld.gov (192.239.93.3); File Transfer Protocol (FTP) via Internet:

ftp.fedworld.gov (192.239.92.205); and World Wide Web using:

http://www.fedworld.gov (this is the Uniform Resource Locator (URL)).

If using a method other than the toll free number to contact FedWorld, then the NRC subsystem will be accessed from the main FedWorld menu by selecting the "F - Regulatory, Government Administration and State Systems", then selecting "A - Regulatory Information Mall".

At that point, a menu will be displayed 7

C that has an option "A - U.S. Nuclear Regulatory Commission" that will take you to the NRC Online main menu.

You can also go directly to_the NRC Online area by typing "/go nrc" at a FedWorld command line. If you access NRC from FedWorld's main menu, then you may return to FedWorld by selecting the "Return to FedWorld" option from the NRC Online Main Menu.

However, if you access NRC at FedWorld by using NRC's toll-free number, you will have full access to all NRC systems but you will not have access to the main FedWorld system.

For more information on NRC bulletin boards call Mr. Arthur Davis, Systems Integration and Development Branch, U.S. Nuclear Regulatory Commission, Washington, DC 20555, telephone (301) 415-5780; e-mail AXD3@nrc.gov.

Lastly, the Act has a reporting requirement for Federal agencies to include an annual metric report as part of their annual budget submission to the Congress.

The reporting requirement expires in the fiscal year after an agency has fully implemented metric usage. Unless the Co11111ission receives co11111ent which would require it to revise its policy, it will consider its policy final and its conversion to the metric system complete.

Dated at Rockville, Maryland this#f.y of~

1995.

For the Nuclear Regulatory Co11111ission Operations 8