Experts: M. Šváb and M. Maris

The legal framework in Slovenia, as described in Section 4, has attributed to the authorized organizations the role of the prime independent reviewers and assessors. The licensee has to submit a safety substantiation first to at least one of these organizations, depending on their authorized scope of work. These organizations deliver their independent review report to the licensee. Only in the case that this report contains a favourable conclusion can the licensee submit a safety substantiation together with this review report to the regulatory body.

In this Section of the report, main attention was given to the review and assessment activities of the nuclear regulatory body, the SNSA.

The present licensing system favours the use of the very valuable competences and experiences in the various organizations, which is a very positive aspect. At the same time the SNSA is working hard to keep abreast of all important safety issues. This is not easy due to the privileged relations between the licensee and the authorized organizations during the discussions of their points of view on a safety substantiation. The SNSA has also limited funds to contract independent outside experts for specific assessments.

At present it is clear that the SNSA has insufficient capability to perform a complete and thorough safety review and assessment. The man-years that experienced staff can devote to review and assessment of nuclear safety aspects is far too few.

The SNSA has not developed its competences and capacities in order to be capable of at least integrating the conclusions of the authorized organizations and its own evaluations into a coherent and well balanced regulatory position. A critical review of the regulatory approach and roles of the different regulatory bodies in the area of nuclear and radiation safety in Slovenia and appropriate decisions on state level are needed.

Currently, the SNSA needs external expert assistance in reviewing nuclear safety issues related to the modernization program of the Krško NPP in order to be able to cope with their minimum duties as a nuclear regulatory body. For the longer term, the SNSA should be able to reach a more stable staffing in order to build up its competence and experience and it may need a permanent and dedicated external technical support, depending on the future developments in Slovenia.

5.1. LEGISLATIVE GROUNDS FOR REVIEW AND ASSESSMENT

The main licensing document for any nuclear installation is the Safety Analysis Report (SAR). Preliminary SAR (PSAR) is required for construction licence and Final SAR (FSAR) for operation licence by the Act No. 62/84. The content of a SAR is defined by Regulation E-2.

The SNSA can contract external experts as support for the review of the SAR. No national requirements exist on how to perform review and assessment of SAR.

The responsibility for all activities related to the SAR changes and its safety assessment primarily rests on the licensee.

Detailed requirements on licensee management of SAR changes and plant modifications, i.e. criteria to categorize them, content of a request for modification approval (application document), documents updating, are not established either in regulations or in the operation licence.

Regulation E-1, Section 36, issued on the basis of Act No. 62/84, establishes beside others: “In proposing any changes of the operational limits and conditions, any changes of the already approved documentation and in solving open questions on nuclear safety, the operating organization shall, in addition to the required documentation, also submit an opinion of the experts who are not engaged in performing the tasks and duties related to the production process control and surveying of such processes and who are not proposing these changes.”

Based on the mentioned requirement the licensee is obliged to submit to the SNSA an independent opinion on proposed modifications. For such a type of work only organizations authorized by the SNSA can be contracted.

See recommendation in Section 5.3.1. of this report.

The Nuclear Safety Division (NSD) of the SNSA has eleven positions, seven of which are filled. Only three staff members can be considered as sufficiently trained. They are very motivated and take initiatives at their working level in order to improve the quality and the management of their work. Inspectors also carry out safety reviews, in co-operation with NSD. Due to other duties to be fulfilled by NSD, the overall time devoted to review of nuclear safety review and assessment in the SNSA is about 2 full–time equivalent posts.

The present Slovenian regulatory framework relies basically on the technical competence of the authorized organizations and on the authority of the SNSA for issuing decisions. In practice, the SNSA has difficulties in assuring its role as a nuclear regulator the way it is understood at international level. Indeed, a typical regulatory duty is to integrate all independent reviews, either from external organizations or from its own experts, into a coherent and well balanced conclusion. A better stability of the staff, effective training, increased involvement in all independent safety reviews and reinforcement of integrated analysis and project management capabilities is required to reach this objective.

See also recommendation in Section 3.2.1. (a) of this report

5.3. ORGANIZATIONS PERFORMING EXPERTISE SERVICES

The role and position of organizations performing expertise services are very similar to their duties in the former Yugoslavia. They have been originally licensed to perform work for nuclear installations by the Republic Committee for Energy, Industry and Civil Engineering and to perform work in the area of radiation protection by the Ministry of Health. The role of this Republic Committee, related to nuclear safety, has been taken over by the SNSA. The organizations are authorized by the SNSA on the basis of criteria established by the SNSA and for the areas in which they deliver expertise services. These organizations need to have implemented Quality Assurance (QA) systems, accepted by the SNSA. The authorization is prolonged based on the results of the QA audits organized by the SNSA and carried out approximately in a two-year period. The SNSA invites the NPP representatives to every audit of this nature.

The authorized organizations are performing on one side the independent review, which is required by Regulation E-1 (in that case they are contracted by the plant); on the other side they are contracted by the SNSA to support its technical review of licensee submittals (this is however done in very few cases) and to carry out inspection during outages. In addition to these official duties, the authorized organizations are a number of times contracted by the Krško NPP and by its own subcontractors for delivering expert assessment services.

The SNSA contracts each year to the Electroinstitute Milan Vidmar (EIMV) a package of inspection activities to be carried out during the outage/refueling of the Krško NPP. EIMV co-ordinates these inspections and performs them in co-operation with other authorized organizations, which are subcontractors of EIMV. EIMV issues a written statement whether the SNSA should or should not consent with the startup of the plant after the refuelling. Similar statements are issued for each step of the startup when reactor is increasing its power up to nominal power. EIMV also establishes a final report on inspection activities during an outage, which is submitted to the regulatory authority. This report contains the records of their inspection activities and findings, as well as their written consents with the results of the inspections performed by all participating authorized organizations.

The possible expert services available to the SNSA are very limited due to the budget of regulator and also due to conflict of interest (in some cases). Indeed, the authorized organizations cannot support the SNSA in case they performed the independent review or the assessment services for the subject for which the SNSA would like to acquire technical advice.

The position of the authorized organizations in the field of nuclear safety is strong due to their acquired technical competences and their legally defined role as independent reviewers. Unfortunately their expertise is rarely directly available for the SNSA, which lacks relevant technical capability in the field of nuclear safety and radiation protection.

Due to the historic developments in the former Federal Republic of Yugoslavia, the authorized organizations play an important role as independent inspector, reviewer and assessor of nuclear safety issues. Similar situations in central and western Europe have occurred, in that experienced research organizations play a main role in safety review and assessment. This system has proven to work well if these organizations work mainly as a technical support for the regulatory body, which means that sufficient funding is available for this process. The situation in the nuclear area in Slovenia can be optimized, whereby both organizations and regulatory body benefit. A re-orientation of some part of the dedicated budget to finance independent technical support institution, which should work almost always for the nuclear regulatory body, is a way that should be investigated. This dedicated budget should be managed by the SNSA.

The review and assessment of the application submitted to the SNSA is done through the process as follows:

• The application is given to appointed division (person) by decision of the board of division heads and director.
• The assessment of the application (documentation) is done in the division concerned. If necessary (in order to assure the review of all technical areas of the application), a review/position of the other divisions can be asked by the appointed division (person), but the process is not formalized. An internal procedure for performing the review does not exist in the SNSA.
• The responsible person (in the division) prepares an official reaction of the SNSA, which could be in the form of a decision, partial decision, refusal, request for additional information etc. The SNSA Director signs the SNSA reaction.

The regulatory review process is an important activity, which should be kept well under control. The SNSA is making efforts to achieve the highest performance with a limited number of staff. The SNSA could profit from the introduction of organizational arrangements, which would emphasize, where feasible, delegation of responsibilities and authorities and other arrangements, which would improve internal co-ordination on working level. Such delegation of responsibility would lead to a better support of the management.

In the Nuclear Safety Division (NSD) the review practice is partially described.

The head of the division establishes the yearly programme for the SNSA review activities in the area of nuclear safety, co-ordinated by NSD. The programme covers estimated activities from the point of view of needed staffing and financing and presents the time schedule for the different reviews.

In order to be more effective and better co-ordinated the NSD regularly organizes internal meetings where staff opinions on division activities are discussed. The NSD also closely co-operates with the inspection division. The inspectors are included in safety evaluation performed by NSD and NSD is taking advantage of the analysis of the inspection reports.

The files dedicated to different modifications are well kept. The filing system allows reasonable traceability of the reviews and assessment already finished.

NSD staff took initiatives which are recognized as good practices and which are administrative supports for the performance of their work such as:

• draft format for establishing safety review results (memos);
• draft guidance to be used for the checking of the updated SAR;
• draft guidance for analyzing the NPP modifications, which do not need a licence;
• the intention to perform guidance for analysing modifications needing licence;
• use of databases to manage review, assessment and licensing process of the modernization programme of the NPP;
• use of databases for managing applications by the operator related to modifications.

The technical guidance for performing the safety reviews in the area of nuclear safety is the NUREG 0800 document. The administrative support documents contain elements, which relate to 10 CFR 50.59 on control of modifications.