NUREG-1302, Forwards Matl on CRGR Meeting 180 Re NUREG-1301 & NUREG-1302 & Summary of Discussions of Proposal to Eliminate CRGR Review of Certain Rev to 10CFR50.55a
| ML20029E204 | |
| Person / Time | |
|---|---|
| Issue date: | 05/09/1994 |
| From: | Allison D NRC |
| To: | NRC |
| Shared Package | |
| ML20028G711 | List: |
| References | |
| RTR-NUREG-1301, RTR-NUREG-1302, RTR-REGGD-01.035, RTR-REGGD-1.035 NUDOCS 9405170212 | |
| Download: ML20029E204 (300) | |
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March 23, 1990 MEMORANDUM FOR:
James M. Taylor Executive Director for Operations FROM:
Edward L. Jordan, Chairman Committee to Review Generic Requirements
SUBJECT:
MINUTES OF CRGR MEETING NUMBER 180 The Committee to Review Generic Requirements (CRGR) met on Wednesday, February 28,1990 from 1:00-5:00 p.m.
A list of attendees at the meeting is attached (Enclosure 1).
The following items were addressed at the meeting:
1.
J. Cunningham (NRR) and T. Essig (NRR) presented for CRGR review two proposed NUREG reports (NUREG-1301 and NUREG-1302) containing guidance to licensees for implementing Generic Letter 89-01 on moving Radiological Effluent Technical Specifications to the Offsite Dose Calculation Manual.
The Comittee recommended approval and issuance of the proposed guidance subject to several recommedations to be coordinated with the CRGR staff and final review by CRGR of the revised implementing generic letter.
This matter is discussed in Enclosure 2.
2.
R. Bosnak (RES) and G. Milman (RES) presented for CRGR review a proposal to eliminate CRGR review of certain revisions to 10 CFR 50.55a (Codes and Standards).
The Committee deferred to current OGC guidance that the backfit rule does not apply to routine updates of the ASME Code, but will continue reviewing proposed revisions to 10 CFR 50.55a, in accordance with the provisions of the CRGR Charter.
This matter is discussed in.
3.
The Committee discussed the schedule and possible location for the next plant visit by CRGR.
This matter is discussed in Enclosure 4.
4.
The Committee discussed preliminarily possible changes to the CRGR Charter, but made no final decisions or recommendations at this time.
Update of the Charter will be considered further at a future meeting.
This matter is discussed in Enclosure 5.
In accordance with the ED0's July 18, 1983 directive concerning " Feedback and Closure of CRGR Reviews," a written response is required from the cognizant office to report agreement or disagreement with the CRGR recommendations in these minutes.
The response, which is required within five working days after receipt of these minutes, is to be forwarded to the CRGR Chairman and if there is disagreement with CRGR recommendations, to the E00 for decisionmaking.
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James M. Taylor Questions concerning these meeting minutes should be referrea to Dennis Allison (492-4148).
Origina! Si;nto 0y:
E. L. Jordan Edward L. Jordan, Chairman Committee to Review Generic Requirements
Enclosures:
As stated cc w/ enclosures:
Commission (5)
SECY J. Lieberman P. Norry D. Williams Regional Administrators CRGR Members Distribution:
Central File (w/o encl.)
PDR (NRC/CRGR) (w/o encl.)
P. Kadambi CRGR CF CRGR SF M. Taylor J. Cunningham 1
R. Bosnak i
T. Essig 1
G. Milman S. Crockett E. Jakel E. Jordan D. Ross J. Conran D. Allison 1
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0FC AEOD:CRGR AEOD: DD,,
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4 NAME J'dnrkn DFRoss
.-f_ _'J o r a n DATE 3/26/90 3/Dt/90 3/' 7/90 0FFICIAL RECORD COPY l
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Attendance List for CRGR Meeting No. 180 February 28, 1990 Members E. Jordan J. Sniezek L. Reyes G. Arlotto D. Ross J. Moore NRC Staff J. Heltemes J. Conran D. Allison L. J. Cunningham T. Essig J. Wang R. Paltemaa R. Bosnak S. Crockett M. Taylor E. Jakel P. Khadambi i
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. to the Minutes of CRGR Meeting No. 180 Proposed NUREG-1001 and NUREG-1302 (Guidance for Moving RETS to Offsite Dose Calculation Manual)
February 28, 1990 TOPIC J. Cunningham (NRR) and T. Essig (NRR) presented for CRGR review proposed NUREG-1301 (Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for PWRs) and proposed NUREG-1302 (Offsite Dose Calculati n Guidance: Standard Radiological Effluent Controls for BWRs).
The purpose' -
the proposed NUREGs is to provide additional guidance to licensees on imp 1 menting Generic Letter 89-01; that generic letter, which was reviewed by ' 'GR at Meeting No. 154, allows licensees to simplify existing plant Tech Sper by moving the Radiological Effluent Technical Specifications (RETS) for their facilities into their Offsite Dose Calculation Manuals (0DCMs).
Briefing slides used by the staff to guide their presentation and discussion with the Committee at this meeting are enclosed (see Attachment).
BACKGROUND The documents submitted to CRGR for review in this matter were transmitted by memorandum dated November 24, 1989, J.H. Sniezek to E.L. Jordan; that initial review package included the following documents:
1.
Draft NUREG-1301, dated November 1989, "Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Pressurized Water Reactors".
' 2.
Draft NUREG 1302, dated November 1989, "Offsite Dose Calculation Manual P
Guidance: Standard Radiological Effluent Controls for Boiling Water Reactors".
3.
"CRGR Review Package", undated.
(Staff responses to items in Section IV.B. of the CRGR Charter)
CONCLUSIONS / RECOMMENDATIONS As a result of their review of this matter, including the discussions with the staff at this meeting, the Committee recommended in favor of issuance of the proposed guidance, subject to the following recommendations:
1.
The NUREGS should be promulgated to affected licensees as attachments to a Supplement to Generic Letter 89-01; the wording of the Supplement should indicate explicitly that the NUREG guidance contains no new requirements, and that licensee implementation of the new guidance is completely voluntary (i.e., does not involve any backfit).
The wording
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of the Supplement should be coordinated closely with the CRGR staff; and the sponsoring staf f should submit the Supple'ient and transmittal letter to CRGR for final review on a negative consent basis.
2.
Within about two years, after gaining experience with application of the new guidance, the staff should consider converting it into a more-standard form of guidance, e.g., a Regulatory Guide.
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s6 PURPOSE i
l TO BRIEF THE CRGE ON THE FOLLOWLYG:
OVERVIEW 0F TWO NUREGs WHICH NRR DESIRES TO PUBLISH DISCUSSION OF RELATED INFORMATION
/ BACKGROUND AND HISTORY
/ ENABLING DOCUMENT (GL 89-01)
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OVERVIEW OF PRESENTATION Clarification and corrections to 11/24/89 o~
CRGR package History of NUREG-1301 and -1302 o,-
Key features of Generic Letter 89 o--
Programmatic underpinnings in TS after o--
RETS removal Key elements of NUREG-1301 and -1302 o,-
.i CHANGES TO NRR MEMORANDUM ON PUBLICATION OF NUREG-1301 AND 1302 PAGE & ITE'd EXISTING IANGUAGE CLARIFICATION / CORRECTION Memo enclosure, "... responsibility for Clarification: programmatic P. 3, Item 111 specific programmatic details will be removed from details will be trans-RETS (NRC control) and placed ferred to the licensee" in the ODCM (a licensee document)
Memo enclosure, "...it is immaAlately Corrections: " it is immediately P. 4, Item IV obvious that these obvious that existing effluent requirements must con-control programs would continue tinue to be met" on their present course" Memo enclosure, "... appropriate licensee Clarification: committees P. 5, item E committees..."
refers primarily to the unit revier group (or equivalent onsite committee), but allows for the fact that some licen-sees may have an additional committee (s) sharing this function (e.g., a corporate.
i level committee)
NUREG-1301 and "3/4 limiting condition "3/4 effluent controls and
-1302, Table of for operations and sur-surveillance requirements" Contents veillance requirements" Draft trans-See revised letter mittal letter
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'l HISTORY OF NUREG-1301 AND 1302 May 1978: Began as NUREG-0472 and -0473 A
Draft RETS guidance for 10 CPR 50, v
Appendix I implementation Reviewed and approved by RRRC-v Transmitted to all licensees (Rev. 0) as j
v a draft j
A November 1978: Rev.1 issued in draft form after AIP, et al. comments July 1979: Rev. 2 issued in draft form A
A 1981-1987: Staff review of RETS submittals l
A November 1987: All RETS reviews complete Draft guidance evolved to Rev. 7
)
v v Drafts available in PDR
/
January 1989: GL 89-01 issued A
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KEY FEATURES I
GENERIC LETTER 89-01 i
T Technical Specification Improvement Program was impetus T
Allows licensees to remove RETS from TS and transferred to ODCM Program is voluntary No new requirements imposed, however, ODCM to be submitted when revised i
T Specifies programmatic underpinnings to remain behind in TS T
Does not contain guidance for format and details to be transferred Genesis of NUREG-1301 and -1302 m
e b
PROGRAMMATIC UNDERPINNINGS IN TS AFTER RETS REMOVAL Effluent Controls Program -- 10 areas m
10 CFR 20.106. and Appendix B a
o 40 CFR 190 o
Details to be in ODCM
.i Radiological Environmental Monitoring Program a
Program parameters o
Conformance to Appendix I o
o Land use census Interlaboratory Comparison Program (QA) a o
Details to be in ODCM
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PROGRAMMATIC UNDERPINNINGS IN TS AFTER RETS REMOVAL (PART 2) l l
Reporting and records u
ODCM change control (shift control from NRC to licensee) a Reviewed and approved by onsite review group o
a Must maintain level of effluent control l
Must submit complete copy of revised ODCM to NRC 0
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KEY ELEMENTS OF NUREG-1301 AND 1302 l
Reflects 12 years of collective staff RETS experience e
Specifications become controls e
Effluent controls and surveillance requirements
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Instrumentation Radioactive effluents (concentrations and doses)
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Radiological environmental monitoring Controls transferred to a licensee-controlled document (0DCM)
Use of guidance is strictly voluntary e
e Related material Branch technical position on REMP
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General contents of ODCM
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3 to the Minutes of CRGR Meating No. 180 Proposal by RES to Eliminate CRGR Revi3w of Certain Revisions to 10 CFR 50.55a February 28, 1990 TOPIC R. Bosnak (RES) and G. Milman (RES) presented a proposed procedure regarding revisions to 10 CFR 50.55a.
The staff proposed to eliminate CRGR review of changes to 10 CFR 50.55a when adopting new Editions of or Addenda to the ASME Code.
Further, such actions would not be subject to backfit considerations.
Any proposed NRC exceptions to the ASHE Code would be reviewed by the CRGR and would be subject to backfit considerations.
The slides used by the staff in its presentation are provided as Attachment 1 to this. enclosure.
BACKGROUND The staff's proposal was transmitted in a memorandum dated February 14, 1990 from L. Shao to E. Jordan.
The same subject had previously been considered at Meeting No. 115 (where the
' proposal was not accepted) and had been briefly raised at Meeting No.175.
During these discussions (at Meeting No.180) reference was made to a memorandum dated March 15, 1990 from S. Treby, OGC, to E. Beckjord, RES.
This memorandum expressed an 0GC position that routine updates to 10 CFR 50.55a, which incorporate by reference new versions of the ASME Code, were not subject to the backfit provisions of 10 CFR 50.109.
CONCLUSIONS / RECOMMENDATIONS The Committee indicated that, with regard to the applicability of 10 CFR 50.109, it would defer to the OGC position.
The Committee did wish to continue reviewing revisions to 10 CFR 50.55a in accordance with its charter.
)
Although the revisions would not normally have to pass the substantial safety benefit test of 10 CFR 50.109, the Committee would want to know the cost and would expect a complete review package.
Proposed NRC exceptions to the ASME q
Code would be considered subject to 10 CFR 50.109 and would have to be j
justified accordingly.
It was noted that cost was not to be a consideration for any adequate protection backfits under 10 CFR 50.109, except in deciding which among several acceptable alternatives to specify.
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- %Y CRGR MEEIING NO. 180 FEBRUARY 28, 1990 ISSUES FOR DISCUSSION CONCERT!ING AMENDMENTS TO 10 CFR 50.55a
- 1. APPLICABILITY OF BACKFIT PROVISIONS OF 10 CFR 50.109
- 2. SCOPE OF CRGR REVIEW 1
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BACKFIT ISSUES 50,109 AND 50,55A i
l B ACK FITTING l
S0.55a (g )(4 )- i i 0 50.109 Unckntting.
(ii) Inservice examinations of compo-(n)(1) Backfitting is defined as the nents, inservice tests to verify oper-modification of or addition to systems, ational readiness of pumps and valves structures, components, or design of a whose function is required for safety, facility; or the design approval or and system pressure tests, conducted manufacturing license for a facility; or during successive 120-month inspec-the procedures or organization re-tion intervals shall comply with the quired to design, construct or operate requirements of the latest edition and a facility; any of which may result addenda of the Code incorporated by from a new or amended provision in reference in paragraph (b) of this sec-the Commission rules or the impost-tion 12 months prior to the start of tion of a regulatory staff position in-the 120-month inspection
- interval, terpreting the Commission rules that subject to the limitations and modifi-is either new or different from a previ-cations listed in paragraph (b) of this ously applicable staff position after:
section.
50.55A(G)(4)ll HAS EXPLICIT REQUIREMENTS TO USE THE LATEST UPDATED CODE EDITION AND ADDENDA INCORPORATED BY REFERENCE DURING EACH 120 MONTH INTERVAL.
THE FACT THAT CODE REQUIREMENTS WILL CHANGE WAS ANTICIPATED AND THEREFORE-THEIR IMPOSITION IS NOT A BACKFIT.
50.55A(G) PREDATES 50.109 AND IS NEITHER NEW NOR DIFFERENT.
02/28/90 1
BACKFIT ISSUES VUGRt.PH
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NUCLEAR REACTOR REGULATION (NRR) SEMINAR JULY 8, 1986 I
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BACKFIT POLICY
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DEDROGR OFFICE
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BACKFIT MC 0514-052 BACKFITTING IS DEFINED AS THE MODIFICATION OF OR ADDIT 10N TO SYSTEMS, STRUCTURES, COMPONENTS, OR DESIGN OF A FACILITY: OR THE DESIGN APPROVAL OR MANUFACTURING LICENSE FOR A FACILITY; OR THE PROCEDURES OR ORGANIZATION REQUIRED TO DESIGN,. CONSTRUCT OR OPERATE A FACILITY; ANY OF WHICH MAY RESULT FROM A NEW OR AMENDED-PROVISION IN THE COMMISSION RULES OR THE IMPOSITION OF A REGU-LATORY STAFF POSITION INTERPRETING THE COMMISSION RULES THAT IS EITHER NEW OR DIFFERENT FROM A PREVIOUSLY APPLICABLE STAFF POSITION AFTER CERTAIN SPECIFIED DATES.
BACKFITTING !S " PLANT-SPECIFIC" WHEN IT INVOLVES THE IMPOSITION OF A POSITION THAT IS UNICUE TO A PARTICULAR UNIT.
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APPLICABLE-REGULATORY STAFF POSITIONS o
THOSE ALREADY IMPOSED UPON OR COMMITTED TO BY A LICENSEE i
o THREE BASIC TYPES 1.
LEGAL REQUIREMENTS SUCH AS IN EXPLICIT REGULATIONS, ORDERS, PLANT LICENSES (AMENDMENTS, CONDITIONS.
TECHNICAL SPECIFICATIONS).
NOTE THAT SOME REGULATIONS HAVE UPDATE FEATURES BUILT IN; AS FOR EXAMPLE, 10 CFR 50.55A, CODES AND STANDARDS.
SUCH UPDATE REQUIREMENTS ARE APPLICABLE AS DESCRIBED IN THE REGULATION.
2.
WRITTEN CCMMITMENTS SUCH AS-CONTAINED IN THE FSAR, i
LERs, AND DOCKETED CORRESPONDENCE, INCLUDING RESPONSES T0-lE BULLETINS, RESPONSES TO GENERIC LETTERS, RESPONSES TO INSPECTION REPORTS, OR RESPONSES T0 NOTICE' 0F VIOLATIONS, AND CONFIRMATORY ACTION LETTERS.
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,i;PLICABLE REGULATORY STAFF POS!TIONS (CONTINUED) a 3.
NRC STAFF POSITIONS THAT ARE DOCUMENTED, APPROVED, EXPLICIT INTEPPRETATIONS OF THE MORE GENERAL REGULATIONS, AND ARE CONTAINED IN DOCUMENTS SUCH AS THE-SRP, ERANCH TECHNICAL POSITIONS, REGULATORY GUIDES,-
GEMERIC LETTERS AND IE BULLETINS, AND TO WHICH A j
LICENSEE HAS PREVIOUSLY COMMITTED TO OR RELIED UPON, HOWEVER, SUCH POSITIONS AS THESE ARE NOT CONSIDERED j
APPLICABLE STAFF POSITIONS TO THE EXTENT THAT NRC STAFF HAS, IN A PREVIOUS.L! CENSING OR-INSPECTION ACTION, TACITLY OR EXPLICITLY EXCEPTED THE LICENSEE FROM PART OR ALL OF THE POSITION.
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4 PROPOSED PROCEDURE FOR PROCESSING OF AMENDMENTS TO 10 CFR 50.55A TYPE OF AMENDMENT APPLICATION OF BACKFIT RULE SCOPE OF CRGR REVIEW (SECTION XI)
ROUTINE UPDATE-NO NOT A BACKFIT. THEREFORE, NOT PROPOSED RULE - SUBMITTED FOR MODIFICATIONS OR LIMITATIONS.
SUBJECT TO BACKFIT PROVISIONS OF 10 INFORMATION: SIGNIFICANT CHANGES WILL BE (MAY INCLUDE !NCREASED OR CFR 50.109.
HIGHLIGHTED. PRESENTATION NOT REQUIRED.
DECREASED REQUIREMENTS)
[ EXAMPLE: SIMPLE UPDATE OF FINAL RULE - SUBMITTED FOR INFORMATION, REFERENCE TO SECTION lil/XI WITH RESOLUTION OF PUBLIC COMMENTS.
RULES FOR CLASS 1,2,3 PRESENTATION ONLY IN EVENT OF SIGNIFICANT COMPONENTS)
PUBLIC COMMENTS.
UPDATE - INCLUDES NRC MODIFICATIONS OR LIMITATIONS SUBJECT PROPOSED AND FINAL RULES - PRESENTATION SPECIFIED MODIFICATIONS OR TO BACKFIT; BALANCE OF UPDATE NOT ON MODIFICATIONS AND LIMITATIONS.
LIMITATIONS.
SUBJECT TO BACKFIT PROVISIONS.
[ EXAMPLE: ADDITION OF AUGMENTED REACTOR VESSEL EXAMINATION.]
EXPANSION - INCORPORATE BY SUBJECT TO BACKFIT PROVISIONS.
PROPOSED AND FINAL RULES - PRESENTATIONS REFERENCE PORTIONS OF ASME ON PORTIONS OF ASME CODE NOT PREVIOUSLY 1
CODE NOT PREVIOUSLY ENDORSED.
ENDORSED.
[ EXAMPLE: INCLUSION OF SUBSECTION IWE, "lSi OF METAL CONTAINMENTS *]
EDITORIAUFORMAT-NO NOT SUBJECT TO BACKVIT PROVISIONS.
PROPOSED AND FINAL RULES - SUBMITTED VOR TECHNICAL CHANGES.
INFORMATION.
[ EXAMPLE: SEPARATION OF RULES IN REGULATION FOR ISI AND IST)
(SECTION lii)
ALL FORWARD FIT ONLY SAME AS FOR SECTION XI AMENDMENTS a -
b PROPOSED PROCEDURE FOR PROCESSING OF REVISIONS TO REGULATORY GUIDES 1.84,1.85, AND 1.147 TYPE OF REVISION APPLICATION OF BACKFIT RULE SCOPE OF CRGR REVIEW ROUTINE ANNUAL REVISION -
VOLUNTARY IMPLEMENTATION. NOT REGULATORY GUIDE SUBMITTED FOR N_Q MODIFICATIONS OR A BACKFIT.
INFORMATION. PRESENTATION NOT LIMITATIONS.
REQUIRED.
ANNUAL REVISION - ENDORSES VOLUNTARY IMPLEMENTATION. NOT PRESENTATION ON CODE CASES WITH ONE OR MORE CODE CASES A BACKFIT.
MODIFICATIONS OR LIMITATIONS.
WITH LIMITATIONS OR MODIFICATIONS.
NOTE:
REGULATORY GUIDE 1.84 - DESIGN AND FABRICATION - ASME SECTION lil REGULATORY GUIDE 1.85 - MATERIALS - ASME SECYlON lli REGULATORY GUIDE 1.147 - INSERVICE INSPECTION - ASME SECTION XI
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.. to the Minutes of CRGR Meeting No. 180 Next Plant Visit February 28, 1990 TOPIC The Committee briefly discussed plans for its next plant visit.
j CONCLUSIONS / RECOMMENDATIONS It was considered desirable to visit a Westinghouse plant that:
1.
Had not previously been visited by CRGR, 2.
Was not included in the regulatory impact survey.
3.
Was not on the problem plant list.
Was not Turkey Point, Diablo Canyon or Trojan.
The visit should be scheduled for July or August.
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J to the Minutes of CRGR Meeting No. 180 Charter Revisions February 28, 1990 TOPIC The Committee briefly discussed revising its Charter.
A marked up Charter had been prepared by the CRGR staff to provide some initial suggestions.
The following points were mentioned:
1.
Charter revision had been raised for discussion for routine maintenance purposes.
2.
It might not be necessary or desirable to revise the Charter at this time.
3.
If the Charter is revised, it might be better to start from scratch rather than marking up the current Charter.
4.
In any event, the Charter would not be revised until the results of the regulatory impact survey are known.
CONCLUSIONS / RECOMMENDATIONS It was agreed that members would provide any Charter changes they believed were appropriate at the meeting after next (in one month).
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