ML20062H051

Forwards Draft Ltr to Marsh & Mclennan Nuclear Re Nelia Endorsement Per New Property/Accident Recovery Rule

ML20062H051
Person / Time
Issue date:	11/19/1990
From:	Wood R Office of Nuclear Reactor Regulation
To:	Morrone J AMERICAN NUCLEAR INSURERS
Shared Package
ML20062H053	List: ML20062H051 ML20062H055
References
NUDOCS 9012040062
Download: ML20062H051 (3)

Text

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C November 19, 1990 2,

Mr.-Joseph Harrone Senior Vice President and General Counsel American Nuclear Insurers The Exchange, Suite 245 270 Farmington Ave.

Farmington, Connecticut 06032

Dear Joe:

I received the enclosed letter from Mike Vieten and replied with the enclosed response.

Do you have any comments on either letter?

I would appreciate getting your thoughts.

Sincerely, ORIGIJULL SIGNED By Robert S. Wood Senior Financial Policy Analyst Policy Development and Financial Evaluation Section Policy Development and Technical ~ Support Branch Office of Nuclear Reactor Regulation

Enclosures:

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s October 31, 1990 Mr. Michael J. Vieten Assistant Vice President

-Marsh & McLennan Nuclear 1166 Avenue of the Americas New York, New York 10036 2774 t

Dear Mike:

This responds to your inquiry concerning whether the American Nuclear Insurers' (ANI). endorsement that incorporates the provisions of the new h

h property / accident recovery insurance rule is more restrictive t an t e language of the new rule itself. You refer particularly to the. provisions of

'the rule that identify the types of actions associated respectively)w(ith

= stabilization and decontamination.

As stated in 10 CFR 50.54(w)(4 i),

the objective of stabilization is "... to ensure that the-licensed reactor is in, or is returned to, and can be maintained in, a safe and stable condition The so as-to prevent any significant risk to the public health and safety..."

iobjective of the decontamination or cleanup process is "... to decontami_nate

.the reactor and the reactor station site in accordance with the licensee's

' cleanup plan as approved by order of the Director of the 0ffice of Nuclear Section50.54(w)(2)(ii)providesthatthe Reactor. Regulation...."

stabilization and decontamination reguirements set forth in section 50.54(w)(4) must apply uniformly to all insurance policies required under section 50.54(w).

Asenumeratedinsection50.54(w)(4)(1),"Actionsneededtobringthereactor to and maintain the reactor in a safe and stable condition mg include one or more of the following, as appropriate: [A]Shutdownofthereactor;[B).

Establishment and maintenance of long-term cooling with stable decay heat removal; [C] Maintenance of suberiticality; [0] Control of radioactive or components to minimize releases;and[E]Securingofstructures, systems,ffsitepublicorto radiation exposure to onsite personnel or to the o

. facilitate later decontamination or both."

(emphasisadded)

As enumerated in section 50.54(w)(4)(ii),]" Cleanup operations aja include one or

more of the following, as appropriate: [A Processing any contaminated water s

generated by the accident and by decontamination operations to remove.

radioactive materials;i[B] Decontamination of surfaces inside the auxiliary

and-fuel-handling buildings and the-reactor building to levels consistent with the Cosnission's occupational exposure limits in 10 CFR Part 20, and decontamination or disposal of equipment; [C

Decontamination or removal and

- disposal of internal. parts and damaged fuel from the reactor vessel; and [D]

cleanup of the reactor coolant system." '(emphasis added)

You indicate.that the ANI endorsement might be more restrictive because it states that: stabilization and cleanup "means_ one or more of the following..."

You are correct in noting that, unlike the. language of the endorsement, the

. language of the rule leaves open the possibility of including additional stabilization and cleanup activities beyond those listed. As a practical-

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Michael J. Vieten matter, the activities listed for stabilization and cleanup are sufficiently comprehensive that, because AN1's definitions apparently cite these same

, activities, it does not appear that there would be gaps or restrictions in coverage for stabilization and decontamination. However, we will ask ANI to confirm this interpretation.

Robert 5. Wood, Senior Financial Policy Analyst Policy Development and Financial Evaluation Section Policy Development and Technical Support Branch Program Management, Policy Development and Analysis Staff Office of Nuclear Reactor Regulation cc:

J. Marrone, ANI

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