Experts: V. Ranguelova and L. Matteocci

The Regulatory Body, as defined in the IAEA Safety Standards Series, comprises not only the SNSA which is the main part in charge of regulation of nuclear, radiation, radioactive waste and transport safety under the relevant legislation, but also other parts of governmental organization as described in Section 1. This section discusses regulatory body organizational aspects as related to the SNSA. The organizations of other bodies charged with some regulatory responsibilities are mentioned in other chapters of this report where appropriate.

3.1. ORGANIZATIONAL STRUCTURE

The primary task of the SNSA is to oversee and assess the nuclear safety and radiation protection of nuclear installations in Slovenia. The SNSA is part of the Ministry for Environment and Spatial Planning and is headed by a Director who is appointed by the government at the proposal of the Ministry of Environment and Spatial Planning.

The SNSA consists of the following five divisions:

• Division of nuclear safety;
• Division of radiation safety;
• Division of nuclear and radioactive materials;
• Division of legal affairs and international co-operation;
• Division of inspection control.

There are no resident site inspectors and no regional offices.

The scheme of the SNSA organizational structure is shown in Appendix II.

A Nuclear Safety Expert Commission was established by the 1980 Act on Performing protection against ionizing radiation and on measures for the safety of nuclear plants and installations. This Commission has the role of advising the Ministries, drafting laws and regulations, advising on important licensing issues, and reviewing the SNSA annual report. The Commission is chaired by the SNSA Director and has representatives of different ministries, experts in nuclear and radiation safety from Slovenia, one representative from the NPP Krš ko and one expert, representing the Croatian Administration.

The Nuclear Safety Expert Commission could be used by the SNSA in a more effective manner to provide independent advice in the regulatory decision making. In order to do that it should however enhance its independence both from the SNSA and from the operator.

3.2. STAFFING AND TRAINING

The SNSA currently employs 34 persons. According to their basic education, they can be divided into the following groups: engineers, physicists, other scientists, technical and general administration staff. Annex 3 shows the current allocation of the personnel to the different divisions. Twelve posts are still vacant.

The staff number of the SNSA has been gradually increasing in the recent years by recruiting new personnel mainly from institutes, universities and the industry. The staff strength has however been quite unstable and there is still a lack of qualified and experienced personnel in the most critical areas. It was recognized that some of the new staff members left the SNSA after completing their postgraduate education, which was supported by the SNSA. The reasons for this relatively high staff turnover are not evident.

As described in Section 2.2 of this report, the legislation system in Slovenia requires that an independent review and assessment of licensing submissions is performed by authorized organizations (TSOs) and provided to the SNSA. It is important for the SNSA to have individuals on the staff who are capable of assessing, on an overall basis, the safety of a nuclear facility. During the IRRT mission (see also Section 5 of this report) it was noted that the SNSA could benefit from increase of human resources and further enhancement of its competence in integrated safety assessment and project management. This addition in the staff capabilities should allow the SNSA to enhance its ability to manage the support provided by external organizations and to review their deliverable on a more sound basis, consistent with the SNSA safety requirements and approach.

The SNSA invests a great deal of time and money in the training of its staff. For example, in 1997 there were 90 man weeks dedicated to the training of the personnel in Slovenia and abroad. The SNSA staff participates in courses, seminars and workshops, organized by the IAEA, EU through PHARE programme, OECD\NEA, USNRC and others. All the SNSA inspectors have been trained on NPP simulators. Though very extensive, the training programme could further benefit from better planning and focusing on specific SNSA staff needs.

3.3. EFFECTIVENESS OF THE REGULATORY BODY

Since its creation in 1987, the SNSA has evolved and matured as a regulator, with a clear separation between regulation and promotion of nuclear energy. In general it operates according to international practices and methodologies and benefits from relevant experience of other countries.

At the moment, no formal Quality Assurance (QA) system is in place in the SNSA. However, some basic requirements pertaining to quality systems are covered by internal administrative practices. Some considerations were given to improving the internal communications arrangements, preparation of detailed job descriptions, work planning and prioritization, and evelopment of some internal guidance and procedures. Some good practices on work optimization were identified in the area of review and assessment (see Section 5). It appears that the SNSA may further benefit from applying a systematic approach in identifying those areas where its effectiveness could be improved.

In the Peer Discussions on Assessment of Regulatory Effectiveness held at the IAEA in April/May 1999, it was recognized that a regulatory body is effective when, given the necessary authority and resources as prerequisites, it:

• ensures that an acceptable level of safety is being maintained by the regulated operating organizations;
• takes appropriate actions to prevent degradation of safety;
• performs its regulatory functions in a timely and cost effective manner as well as in a manner that ensures the confidence of the operating organizations, the general public and the government; and
• strives for continuous improvements to its performance.

See recommendation in Section 6.1.1.(a) of this report.

3.4. INTERNATIONAL CO-OPERATION AND LIAISON

The SNSA has established bilateral co-operation arrangements with the regulatory bodies of Hungary, Austria, the USA, Canada and Slovakia, while those with the Republic of Korea, South Africa, France and the Czech Republic are under preparation. An agreement is also under discussion with Italy.

There is very good co-operation between Slovenia and IAEA, and it is most effective in the area of technical assistance provided by the IAEA and in the participation of Slovenian experts in international meetings. The relation with the EU has been realized primarily through the participation of the SNSA experts in the PHARE and RAMG assistance projects and in the CONCERT Group and Nuclear Regulatory Working Group meetings. The co-operation with the EU has been recently intensified due to accession activities initiated for Slovenia.

The contacts with OECD/NEA remain informal and non-institutional since Slovenia is not yet a member of the OECD, although application has been submitted two years ago. Nevertheless, the co-operation proved to be fruitful and is carried out through participation of Slovenian experts in training courses, seminars organized by OECD/NEA and INEX emergency exercises. Slovenian government also applied for accession to Paris Third Party Liability in the Field of Nuclear Energy and Brussels Convention Supplementary to the Paris Convention.

1. Good Practice - The SNSA has established a very effective communication line with the US NRC to receive timely information on modifications to NRC regulations and guides. All the SNSA inspectors have received training at the USNRC inspector training center on the basis of the bilateral agreement between the two regulatory bodies.