ML20125C343
| ML20125C343 | |
| Person / Time | |
|---|---|
| Issue date: | 08/21/1984 |
| From: | Seeman M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Nelson T AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20125C314 | List: |
| References | |
| FOIA-85-54 NUDOCS 8506120016 | |
| Download: ML20125C343 (9) | |
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j MKearney 6 DMattson 7Ip J0 Bunting LHigginbotham Mr. Tom Nelson MKnapp P.O. Box 1591 LBarrett Sioux Falls, South Dakota 57101 HMiller MJBell
Dear Mr. Nelson:
REBrowning Pursuant to our August 16, 1984 conversation on liability issues for low-level radioactive waste disposal facilities, I am sending you the following information for the low-level waste siting work you are doing for the City of Edgemont, South Dakota:
-- The name of the former DOE attorney who dealt with liability issues is Mr.
Omer F. Brown II. His mailing address is Shaeffer, Brown, and Cooper, 1575 Eye Street N.W., Suite 1025 Washington, D.C. 20005. Telephone Number is 202-289-3591. I have also enclosed an extra copy of a speech on liability issues prepared by Brown. -
-- The Advance Notice of Proposed Rulemaking on financial responsibility for cleanup of accidental releases of radioactive materials was sent to the States for review and comment the week of August 13, 1984. In South Dakota, this package was sent to Joel Smith, Administrator of the Office of Air Quality and Solid Waste, at the Department of Water and Natural Resources.
His telephone number is 605-773-3329.
-- Enclosed is an extra copy of the interview with the American Nuclear Insurer's Vice-President discussing insurance and liability issues of low-level waste disposal sites.
Good luck on your project, and feel free to contact me if you need further information.
Mary Jo Seeman, Program Analyst
Enclosures:
- 1. Speech by Omer F. Brown, II
- 2. Interview with American Nuclear Insurer's Vice-President 8506120016 850207 PDR FDIA PAY 85-54 PDR OFC : --------.LYgf3
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NC ANERICAN NUCLEAR INSURERS........ON LIABILITY INSURANCE & LLW MANAGEMENT For the past several months state officials, federal agencies, public interest groups and potential LLW site operators have been involved in discussions of third party liability with regard to LLW site development and operation. This interview with American Nuclear Insurers top executives was conducted by Exchange Publisher Edward L. Helminskiin order to provide the Exchange network the best possible information on the current status of liability protection against nuclear hazards associated with LLW management. The ANI executives that partipated in this discussion were Mr. John Quattrocchi, Vice President, Liability Underwriting, Dr. L. P. Mariani, Vice President, Nuclear Engineering and Mr. R.
Sanacore, Operations Manager.
What is ANI and how did it come to be?
What about coverage for low level
- waste?
ANI is a joint underwriting ~ association - a As far as our insurance coverage, a pool of insurance companies that was set up distinction is made between low-level some 27 years ago for the purpose of waste operators and the generators of by-insuring the nuclear risk. The pooling product material. Let me see if I can concept was devised as a means of coming up illustrate.
with large amounts of insurance capacity, since no single insurance company could We don't insure a single hospital, for provide the kinds of insurance dollars that exam ple. Of course, many hospitals, cer-were reouired to cover what was then a tainly all the larger hospitals, have developing technology. nuclear medicine departments that work with radioactive isotopes for canc
. Who are ANI Clients? patients and for other purposes. They a all insured by the conventional insuranc We insure on the liability sid e, every market. The reason for that, frankly, is operating power reactor in the United that 27 years ago when the pools were States; as far as we know every operating created it was decided that the by-product commercial fuel fabrication facility and material exposure did not present any sort every commercial waste burial facility in of catastrophic risk. It is in fact viewed as the United States. And, through re- a commonplace activity, and one that the .
insurance arrangements we also insure most conventional insurance market was willing -
of the reactors in the free world. Now, I'm to insure.
i referring 'here to liability insurance. ,
We essentially insure the fuel cycle. That We also do provide first party property is really the line of demarkation .. we ,
insurance. And here we also insure a major insure the fuel cyc'le and conventional segment of the power reactor commmity, insurance markets insure the isotope risk.
with a segment insured via self-insurance programs. Do you cover the transport of radioactiV8 materials?
We share the liability insurance market with ,
MAELU - the Mutual Atomic Energy Liability We can cover the transportation exposure. -f Underwriters insurance counterpart. As I For example, the transportation of materials
} noted earlier, ANI is the pool formed by the to and from reactor sites and the transport i stock owned insurance companies, MAELU is l
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the underwriting pool formed by the mutual of lowlevel a low levelwaste wasteburialfromsite a reactor is cover facility]
insurance companies. Together we provide under the policy we issue to a react -
$160 million dollars of liability insurance operator. The limit of protection is $1 protection at reactor power plants pursuant million for each shipment.
to the Price Anderson Act.
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Reactor operators are required to provide Let's go back to the delineation I drew revidence of financial protection to NRC in earlier -- radioactive by-product material b
- V rder to obtain an operating license. In versus low-level reactor waste. If you order to fulfill this requirement, all have are talking about a shipment made up solely elected to purchase a facility form liability of by-product materials from, for example, a policy from ANI and from MAELU. facility like a hospital or a radio-pharmaceutical manufacturer -- that ship-Now the policies that we write for reactor ment could be covered by the conventional operators contain a provision called the insurance market. However, once the
" insured shipment provision". Under this shipment arrives at a low level waste burial provision we provide liability insurance for facility, then the policy that we issued to shipments of nuclear materials including the low level waste operator would provide waste from a reactor facility to a burial protection while the material is at the facility. So that if an incident of some facility.
type were to occur en route from the reactor to the waste burial facility we would be A shipment, from a hospital or from a waste obligated to defend the reactor operator storage location that involves only with respect to his liability for that hospital-type waste (i.e. by-product ma-incident and if the operator were found to be terial) would be covered under a conven-Ifable, we would pay on his behalf. tional general liability policy. There is no need for a nuclear pool policy. This is Now, I might also mention one key point, and the line of demarkation that I mentioned that is under the facility form policy, the earlier -- fuel cycle versus non-fuel cycle.
insured is anyone -- anyone who is legally This separation exists simply because the liable for a nuclear incident. The policy conventional market 6 willing to insure the is written to protect the reactor operator, isotope exposure.
but anyone liable for the nuclear hazard Oesulting from nuclear materials from a on occasion, we have covered an isotope (Aeactor is covered by our policy. Now this risk where very large q uantities were is a very important point. We need to involved. But for the most part the discuss this at length. There is one conventional insurance market is available exception and that is the U.S. government or to cover liability associated with the use or any of its agencies. handling of isotopes.
What our facility form policy does is protect Most of the interest in the states, with anyone with respect to their legalliability regard to liability protection, is focused on as far as the nuclear risk is concerned. Iow-level waste disposal facilities.
For example, during the transportation of Could you walk through the specifics of the radioactive waste from a reactor to a waste type of protection ANI provides, starting .
burial facility anyone would be insured, and first with a brief explanation of the role of we would be obligated to defend anyone who the Price Anderson Act?
is sued for bodily injury or g6pMy damage as a result of a nuclear incident that occurs The Price Anderson Act stipulates that during an "instred shipment." Now this reactor operators must provide proof of would include the reactor operator, the financial protection in order to be granted waste burial operator, the trucker, the an operating license. As a method to waste processor, the generator -- anybody provide that financial protection, all who might be liable for the nuclear incident reactor operators to date have elected to covered under our policy. come to us to purchase a facility form liability policy as evidence that they are ANI covers liability risk for nuclear meeting the financial protection require-hazards with respect to transport of ments of the Act. The policies that we radioactive materials from nuclear reactor provide -- the facility form liability policy lants. What about a shipment from a large -- is essentially location oriented, meaning oker or from an institutional generator? that we provide the operator of the facility i
7 Remenettw Eschange,
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with protection against liability for Now what is the relationship of Price incidents that occur at the defined location Anderson to a low-level waste facility?
or during the course of transportation to or from these facilities. The Price Anderson Act at present does no extend to low-level waste burial facilities Under the Act, a reactor operator has to with the exception of the transportation provide proof of financial protection in an exposure from a reactor facility to the amount equivalent to the maximum liability waste burial facility.
insurance capacity available to private sources. And that would be through ANI or For a shipment of low-level waste from a MAELU. Currently the maximum amount of reactor facility to the burial facility all of liability- insurance available is $160 the provisions of Price Anderson apply. In million. other words, the $160 million primary limit, the secondary financial protection limit, I might mention that when the pools were the cap, and so forth. All of that would created back in 1957 that limit was $60 apply. Once the material arrives at the million. Over the years, we've increased low-level waste burial facility there is no that and today that limit is $160 million. Price Anderson protection, per se.
Now, in addition to what is provided under As I indicated earlier, however, all the Price Anderson Act there is a program operating commercial waste burial fa-that provides excess insurance, if you will, cilities in the country, to my knowledge, in the form of retrospective payments from purchase insurance from us. Th'e dif-the utilities themselves. If an incident ference is that they are not required to.
occurs,in which damages exceed the primary There is no requirement that they purchase layer of protection -- in other words, the our insurance. And I contrast that to the
$160 million of primary liability insurance - reactor situation where insurance is
- each reactor operator that is a participant req uired in relation to the financia in what is called the secondary financial protection req uirement of the Pric protection program would accept on a Anderson Act. There is no insurance retrospective basis, his share of the excess req uirement, at waste burial facilities, loss -- that is the loss in excess of $160 although again all of the operators to my million -- up to a maximum of $5 million per knowledge, do purchase insurance.
~ reactor owned or operated.
What level of insurance is now available to So the liability insurance orogram works an operator of a low-level waste facility?
like this. You first have S160 million of primary liability insurance. And then there Well, as I mentioned earlier, we currently is the secondary financial protection have available a total of $160 million in the program, which currently has 82 licensed form of liability insurance. And again, reactors as participants -- 82 x 5, that's that's available through both pools -- ANI S410 million dollars. So what we have is and MAELU. Incidentally, of that total --
$160 million on a primary basis, $410 on an of the S160 million total- 77-1/2 percent of excess basis for a total of $570 million. that -- or $124 million -- comes from the And that constitutes the cap or liability American Nuclear Insurors --
and the
, limit above which no one is legally liable. balance of 22-1/2 percent is derived from MAELU.
I should quickly say, however, that under The Price Anderson Act, if the cap on Now, when you say a total-- does that mean liability is approached, or is exceeded, the a total for a single site or a total available Congress would be approached to assess the for all the sites in the country?
l situation and take whatever action it deems appropriate to protect the health and safety That is a per site limit. S160 million would of the public. So, in es's ence the pubIfc be available on a per site basis.
would not be left unprotected. g 8 a a.m.
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' Have there been any third party liability institutional care period, assuming, of l 1mias against any of the operators of the course, the low-level waste burial facility I w-level waste disposal facilities? continues to meet our engineering and underwriting requirements.
To my knowledge we have not received any So there isn't any time limitation. ANI third party liability claims arising out of would provide third party protection for low-level waste burial operations, 100--200--years as long as the premium was Some states, particularly in the Northeast, paid and the operator met your technical are interested in having third party liability requirements?
protection prior to a LLW facility becoming Well, at this point in time -- we're not in a operational. Could you provide that type position to guarantee that we would provide of protection? liability protection in 200 years, but let me If there are no nuclear materials on site say that we are available to provide i
therefore no nuclear hazards, the ANI insurance during the post-closure and policy would not apply since its scope is institutional care period subject to our limited to the nuclear hazard. If there underwriting requirements and the main-were some radioisotopes on the site prior to tenance of adequate engineering safeguards the initiation of burial operations, the at that facility. And I might mention that isotope risk could be covered by the there are facilities around the country that conventional insurance market, have been decommissioned and for which we continue to provide insurance.
What you're saying is that in the construction stage a LLW site could be What are some of these facilities?
conventionally insured and then shift to the One is the Pathfinder facility, another is the pool when nuclear materials are taken in? Carolinas, Virginia facility. There are r3 that's right. Yes. Lia- others, small reactors that were operated Vubstantially some years ago and have been decom-bility insurance would be available from missioned for years. We also continue to birth to death, if you will. Prior to the time that low-level waste arrives at the provide liability coverage at the three low-site the liability arises out of whatever level radwaste facilities that are no longer operations are going on at the time. These accepting waste.
activities could be covered under a Are you confident that there are sufficient conventional insurance policy. Once the nuclear material arrives at the site we resources in the pool to meet the insurance would, of course, take over and issue a needs of new regional disposal facilities?
nuclear liability policy. However, since As I indicated we have at present $160 our policy is limited to providing liability million in liability capacity on a per site protection for the nuclear hazard, conven- basis. But I should add that an operator of tional insurance coverage for non-nuclear hazards should be maintained. a low-level waste disposal facility is not obligated to purchase the maximum liability Wat happens when the site is closed? Do insurance capacity under the Price Anderson you provide liability insurance during the Act. To put it another way, the Price post-closure and institutional control Anderson Act does not extend to low level period? waste burial operators. So that they can purchase any limit they so choose. The In essence we would be talking about the $160 million is available if they choose to same policy. I might mention that our purchase that. limit.
policies are continuous unless cancelled or terminated. So that, yes, we are available Do you see any reason for a state to " set a
-- we can cover and continue to cover a low-minimum floor" of liability insurance that a level waste burial facility during the low level waste disposal operator would 9 Ramonethe Enchaser I
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have to ptschasa?
' You mentioned that in determining I don't really think that that would be for us premium you rely upon a techni to say. I would point out that when the engineering analysis of the site and Price Anderson Act was developed it was operation of the facility. Could you explain specifically limited to facilities such the manner in which you carry out this power as reactor facilities, research analysis? When would you initiate this reactor facilities, fuel reprocessing fa- work?
cilities and plutonium fuel fabricators.
Well first a request would have to be mat is ANI's view of setting up a Price received at an appropriate time from an Anderson type program for low level waste operator. Our first decision is whether we facilities? Does the liability risk warrant want to provide coverage, such a program?
When is the appropriate time to make a We have been insuring the nuclear risk for request?
27 years and to my knowledge, we have not received any third party-liability claims The appropriate time for determining from the low level waste burial activity, whether we can provide insurance seems to As far as what a state should or should not be early in che game, let me leave it at that.
do, I don't think that would be for us to say.
Can you narrow that down a little?
Could you estimate the premium costs of a
$160 millim dollar policy for a low level Well, I think that the questidn of waste disposal facility? insurability always comes after we have completed certain fundamental examinations No, not without the details of the site. A of the site. Generally speaking this would premium is dependent on several factors include a hydrological examination, that are site specific, therefore it is topographical plan examination, a seism impossible to estimate without site logical examination --a look to see if the specifics. But let's go through how we surrounding natural factors could affect would go about developing a premium. our exposure in any way that might not be acceptable to us.
First we look at such factors as location --
where the site is located. Is it in an Do you have your own team of engineers
- ' isolated area, a rural area? What are the carry out this analysis or do you accept the property values in the area surrounding the data provided by the client seeking the low level waste site? We look at the insurance?
volume of materials buried. We look at the radioactive contents of the materials. We We accept the data generated by the client, look at the major isotopes that would be We use this data in conjmetion with data included within the volume of the materials. our engineers gather at the site to do an Based on those factors we come up with insurability analysis. Usually much of premiums that are consistent on a this data is generated as part of the l comparative risk basis with other facilities licensing process and it normally has a that have been previously rated. great deal of legitimacy. Our role is to carry out a technical risk evaluation and to
! Would the premium annount to substantial assure ourselves that due process and I
percentage of the overall disposal fees reasonable safety results are coming out of charged to generators? a well managed site. We don't do all the work, in that we use some of the licensing l Well, I don't know about percentages, but it data, i would be a very, very small -- very small fraction. I would think an infinitesimal What happens if there is a difference o fraction. opinion between your staff and the client' 10
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.i the design parameters, the integrity of a between a licensee and licensor, because in acion? Say for example, the client doing so we would take on some of the state aintains that the natural surroundings are functions. We feel that what we do in terms sufficient but you determine a dam is of technical certification for insurance necessary to prevent site flooding? purposes, determines whether we'll provide coverage. We do not guarantee the Wellif an issue of that magnitude,like a dam operation of the facility, as f ar as public came up, it would have usually been brought health and safety.
to our attention by the potential operator.
Most of the time we get into the picture a As far as underwriting a policy, we are just little bit further on down the line and an saying that we are willing to sit down with issue like whether a dam should be built our underwriters talk it over, if we say okay would probably have already been discussed to the technical assessment, we'll provide and brought up by the various interests covarage under certain circumstances, involved. We then ask ourselves how do we feel about that issue, whether the dam from I should add one other important factor.
our point of view is better and then we would We have a proprietary relationship with our ask the question "If there was not a dam insured. Once we have determined the would we provide coverage?" We would terms of insurability we don't go around make that assessment ourselves. sharing that with other people.
Now let's say the state has determined that Do you perform engineering assessments on the dam is needed on technica1 grounds. We a periodic basis?
may then ask for additional specifications from the potential client. Or we, our- We go through an engineering assessment of selves, might hire outside technical experts insured waste disposal site operations do study the issues that the state has about every six months to two years. The Caised. frequency is based on our assessment of the type of activity that is going on, the level From what you are saying it seems to me that of operation to make sure the risk remains a host state going through a licensing what we believe it to be at time of policy process should require that the operator issuance. We ask, will operations increase?
demonstrate that insurance is obtainable Will they remain the same?
prior to issuing a license.
What happens then?
That's just the way that power reactor licenses are issued by NRC. Over the years After we have completed our assessment we we have grown comfortable with the NRC sit down with the client, to discuss any ,
licensing process. Now, if states were to problems we may have. We point to get involved in this kind of licensing possible insurance deficiencies but we do activity and if we thought that it was a not necessarily make prescriptive technical really good licensing process then we would recommendations on how the client should be willing to go along for the most part with address the problems, the kinds of investigation that the process called for. We don't feel that we should be We may point out for example that a client's too Involved, however, in setting up the workers are getting too much exposure. It licensing procedure or the requirement for is up to the client to provide a remedy. We insurance. do not say "Have all your workers wear special gloves", that's the client's Couldn't the state licensing authority decision. We negotiate an acceptable actually use ANI as a back-up technical remedy and make a determination on any advisor in determining the structure of a adj ustments to our policy. In the vast license? majority of instances we do not say "Do this p
dNI could not j uxtapose themselves or we will cancel your policy." ' We seek alleviation of what we consider to be excess i II o ._.__
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insurance risk and frequently leave it up to Well, I don't know, from a legal sense.
our clients to decide to just how to do it. think, again, that's a cuestion that's reall
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What about a situation, where a trench at a not for us to decide -- it's a question for the state. But I will say this -- our policy site is found to have a water run off does have that very unique feature to it --
problem, and has contaminated a pond that that is, the broad definition of insured.
is off-site. The pond must be cleaned.
What would ANI coverage provide? Because of this broad definition a policy issued to a regional low level radioactive ANI provides coverage off-site only through waste site operator would not only cover the language of our policies. We do not the operator but would cover the compact i
provide coverage for on-site property and its entities. It would provide thrid damage. We only provide coverage for bodily party liability coverage to the host state injury or property damage to third parties, and any party state with respect to their j Our policies do not cover on-site property damage. There is an exclusion in the liability for a nuclear incident at the site.
policy for any damage -- any property What your saying is that once a policy is damage to any property on-site. ANI only written to cover a low level burial site, all responds to third party actions for bodily third party nuclear liability is taken care injury or property damage to off-site of?
property owned by the general public. We do not provide coverage for any remedial Yes, that's right. If there is a shipment of action or for cleaning up a site. low level waste from a reactor, or a nuclear How can a state protect itself against the fuel-related facility, then if you have an
! I. possibility of an expensive clean-up? incident that results in a third party Ifability claim - either injury to the public There are of course ways that can be or for some damage to the off-site areas e developed that's correct. We, ANI would be defendinM by the states to protect anybody, with the exception of the federal themselves from injury if they so choose. government,-- anybody that might be liable There are things that the state can do to for those inj tries or damages. Anyone who insure itself if it so chooses, and funds can is involved in the operation of the site or
( be made available for that purpose. delivery of waste that we are covering.
1 Would this type of coverage be available Let's consider a hypothetical incident:
from the ANI pool? Say a shipment from a reactor facility in Michigan was on its way to a burial site in No. not at this time. Up to this point we Illinois and somewhere enroute an accident have not been approached by any of our occured in Illinois, and there were waste site clients about such coverage. allegations of inj uries and property damage We, of course, would consider any request to third parties. In this case it would be that an insured may make, and, if the demand the reactor operator's policy that would for that kind of thing develops we would apply to that shipment. And, again ANI take a hard look at it. I can't say that we would act to defend -- defend anybody who would do anything about it. But we would might be sued with respect to this legal certainly act to consider a request from our liability for the nuclear incident and we l insured.
would pay up to the policy limit if liability was assessed.
There has been and continues to be a lot of interest in the Northeast about the concept Now, what if someone sued the state of cf shared liability. Illinois in fact just Illinois?
adopted an amended Midwest compact requiring shared liability among all party Let's take a particular accident scenario, states. In your view does a host state gain The truck hit a pothole on an Illinois toll anything from a shared-liability program? road. And it's alleged by a third party -
(3 the inj tred party -
that the reactor Is there any other issue you would like to
(" ) operator is liable because that's where the bring to our readers attention?
material came from and the trucker is liable because he's hauling the material, and also We would like to cover two other points we the state is liable because if the pothole talked about only briefly --the question of wasn't there the accidsnt wouldn't have insurance rating and how we develop happened. Now, the point is, we would premiums. And, one issue that has not been defend the reactor operator, the trucker and mentioned - existence of a refund procedure defend the state. If the state was found that we have in place to return to our legally liable for the damages to the third insured portions of the premiums they pay party, then we would pay. to us based on loss experience.
What if the state of Illinois alleges that the The rating process in this business, as you reason the accident happened is that the might imagine, is based almost entirely on truck was not checked and packaged right j udgment. This is so because of the lack because Mighigan didn't enforce its laws't of any real loss experience. The nuclear industry has exhibited a very fine safety It would be up to a court to assess liability. record over the years and there is no We would defend all the parties that were actuarial base with which to determine sued. But it is up to the court to assess rates. So in the absence of actuarial the liability. statistics j udgment again is the key Would the liability of either state be different if there was a legal document, In recognition of the role that judgment committing each other to sharing the plays we have created what we call the liability. industry credit rating plan. And what it
] Not really, no. Everybody is an insured says in essence is that based on the loss experience of the industry as a whole - we under the policy. It would be up to a court will refund to our insured, after a 10 year to assess liability. experience period, a portion of the premium that they paid to us ten years ago. Over Let's say you have Michigan and Illinois as the years, under this program, we have j . part of a regional compact. Both states refunded significant amounts of money.
would be insured by ANI under the site l operator's policy. Now, the other point I'd like to make is the issue of a discovery period. We mention-Let me give you one more example to ed that we certainly could consider insuring illustrate how coverage is provided, a waste burial operator during the.
Consider again a shipment from Michigan to institutional care period and post closure.
Illinois and again this is from a reactor site We would have no real problem doing that,
. so it would be the reactor's policy that subject of course to the continued would apply to that shipment. Now, application of adequate engineering safe-enroute there's an accident in Illinois, guards. However, the discovery period a
The truck turns over, on an Illinois toll becomes an issue here. Essentially our l road. Now, there's a mess on the road. policies provide for a ten year discovery Property owned by the state of Illinois is period in which third parties have ten years contaminated. So now, the state of Illinois within which to bring claims against the sues the reactor operator, and the trucker insured once the policy is cancelled. The because the state alleges that the truck's -discovery period does not begin to run until tires were bald. Again, we would be a policy is cancelled. So that if a policy obligated to protect the reactor operator, remains in force, there is no real problem.
the trucker or anybody else, excepting the Once the policy is cancelled, if in fact it's U.S. government, that might be liable for cancelled, then third parties have ten years' G damage to Illinois state property. If they - the discovery period - within which to are found to be liable in a court of law then bring claims.
we would pay. .
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