Conversion to the Metric System; Policy Statement

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 System 1 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. ---------------------------------------------------------------------------

\1\ The metric system refers to units belonging to the Internationale System of Units, which is abbreviated SI (from the French Le Systeme Internationale d'Unites), as interpreted or modified for use in the United States by the Secretary of Commerce. ---------------------------------------------------------------------------

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 exemplified by the NEI 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: ---------------------------------------------------------------------------

\2\ On August 10, 1988, Congress passed the Omnibus Trade and Competitiveness Act (the Act), (19 U.S.C. 2901 et seq.), which amended the Metric Conversion Act of 1975, (15 U.S.C. 205a et seq.). Section 5164 of the Act (15 U.S.C. 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. ---------------------------------------------------------------------------

(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 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 referred 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 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 requiring event reporting and emergency response communications between licensees and any Government authorities to be in the English system of measurement.

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 with the Office of Information and Regulatory Affairs of OMB.

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 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, 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 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 12th day of June 1996.

For the Nuclear Regulatory Commission. John C. Hoyle, Secretary of the Commission. [FR Doc. 96-15397 Filed 6-17-96; 8:45 am] BILLING CODE 7590-01-P