Experts: C. A. Casto and J. Noeggerath

6.1. ORGANIZATION OF THE INSPECTION PROGRAMME

The SNSA is implementing an effective inspection programme consistent with the requirements of the 1984 Act and the Act on Administration (Off. Gaz. RS, 67/94). In some functional topics, e.g., radiation protection, physical protection and emergency preparedness, their inspection competences overlap with other ministries. In these areas the interfaces between these ministries seems effective. Internal co-ordination with the Nuclear Safety Division appears limited to the use of the inspectors as a supplemental resource for safety assessments.

The scope of the inspection programme includes inspections for the KNPP, the TRIGA Mark II research reactor, radioactive waste storage areas at Podgorica and Zavratec, the uranium mine at Zirovski Vrh and transportation of nuclear material throughout Slovenia.

The SNSA has initiated the development of a more systematic inspection programme and has developed some specific inspection procedures. Implementation of the current inspection programme is based primarily on deterministic considerations, e.g., plant activities, the SNSA management direction and individual inspector’s expertise. There is very limited use of integrated plant assessments, integrated reviews of inspector findings, probabilistic risk insights, or licensing basis configuration verification “vertical slice” inspections. Further, there is no procedure for preparing, conducting or reporting inspection report content. This deficiency is particularly important because it reduces the effectiveness of the inspectors.

Inspectors are responsible for many tasks that divert their attention from implementing a systematic inspection programme. Inspectors are used as a knowledgeable resource for many internal tasks, e.g., supporting licensing reviews, development of the inspection programme and procedures, membership on the Expert Commission on Operator Licences and oversight of the authorized organizations, particularly in preparation for and during outages. Inspectors have little time to pre-establish inspection objectives. Their direct inspection efficiency is low. Their ability to conduct effective team inspections is diminished and there are very few major vertical slice inspections that are often valuable in confirming the design margins of systems. As a result, the inspection programme is not as effective as possible.

The SNSA has developed and implemented a process for licensee’s to report events and emergencies. Inspectors are dispatched as appropriate in response to events and they report their findings to the SNSA management.

6.2. TRAINING AND QUALIFICATION OF INSPECTION STAFF

Training of inspection staff is consistent with IAEA standard guidelines. This includes basic degree requirements, significant technical training and on-the-job training. Inspectors do have some basic risk training. Additional technical training may be provided to the inspectors based upon identified needs. Only inspectors have training in inspection techniques. Personnel in the Nuclear Safety Division are not trained as inspectors nor are the personnel from the authorized organizations who perform independent verifications during outages.

Observations by the Team indicate that the inspectors are highly dedicated and possess a great deal of knowledge about nuclear safety. For inspections at KNPP, there were some indications that the inspectors could focus more on the safety and risk aspects of plant operations during inspections. Many of the issues identified by the inspectors were housekeeping items. It appears as though the inspection techniques used by the inspectors are not leading them to important safety issues. Additionally, in one case the corrective actions solicited by the inspectors did not consider insights from U.S. NRC Manual Chapters 9900, 0610 and Generic Letter 91-18 that may have assisted in resolving this issue.

For outages at KNPP, the authorized organizations are contracted by the SNSA to conduct independent verifications. The scope of the contract is developed by the SNSA. This scope includes both safety and non-safety related work. Over the past few years the non-safety-related portion has declined and is now limited to observations related to reliability of the NPP and safety-related issues. Both the authorized organizations and the NPP comment on the contract. Review by the team indicated that the scope of work performed through the contract still focused on many non-safety related issues. This diverts the attention of these organizations from the safety related aspects of plant operations. After agreement the authorized organizations implement the contract.

Authorized organization personnel performing the outage observations are not trained as inspectors. These personnel do attend a basic nuclear technology programme; nevertheless, without enforcement authority, knowledge of inspection skills, or familiarity of integrated plant operations, the value of these observations is limited. Given that there is no inspector manual, these personnel have little guidance on how to conduct their observations. Consequently, this process seems burdensome because it appears that there is not a significant contribution to plant safety from these observations and management of this process diverts the inspector’s attention from direct inspection efforts.

6.3. METHODS OF INSPECTION

The SNSA’s inspectors are very competent and they understand the principles of safe uses of nuclear materials. Current inspection practices are satisfactory to accomplish the Inspection Division’s goals. With limited inspection planning the inspectors are not as effective as they could be if they had the time to research requirements and establish more specific inspection objectives. They are provided with CD-ROM versions of the plant’s technical specifications and safety analysis report. Inspection techniques include review of acceptance testing, witnessing operations, walk-downs and event follow-up. Quality assurance procedures, although not completely implemented for internal processes, are evident in the inspection programme philosophy. As stated earlier, strengthening the inspection programme and training of inspectors should improve the effectiveness of the inspection programme.

6.4. INSPECTION REPORTS

Inspection reports contain the inspection scope, inspector observations and findings, and agreed upon corrective actions or decrees. Inspectors write the inspection report while on-site. Thus, they are using valuable on-site time to write and there is no management oversight of the work product before it is issued. These inspection reports are provided to the licensees immediately upon completion of the inspection. They are signed both by the inspectors and the licensees. This practice confirms that the licensee acknowledges the inspector’s conclusions. Inspectors use the inspection reports to track commitments. This tracking process seems effective. As stated earlier, there is no process for integration of findings from inspection reports.

No need for recommendations or suggestions was identified in this area.

6.5. REGULATORY ACTION AND ENFORCEMENT

SNSA has the authority to initiate enforcement actions. It does not have a defined, graduated enforcement policy. Minor violations of requirements are corrected through the inspection process. According to the Code of Criminal Procedure and the 1984 Act, more serious violations must be processed through the court system. The applicable laws do not recognize that non-compliances are not willful criminal acts. The SNSA is treated similar to other regulatory bodies in Slovenia in enforcement. They have not taken action to develop a system that provides for varying levels of administrative enforcement; therefore, it is significantly difficult for the SNSA to process any major non-compliances. There seems to be no philosophy for the identification of violations of technical specifications or the safety analysis report. Interviews indicated that the only means to identify these violations is for the licensees to inform the SNSA of any major non-compliances. Assuming the licensees notify the SNSA, or assuming the SNSA inspectors identify major non-compliances, there is no process for the SNSA to impose reasonable corresponding penalties. Most of the inspectors findings are minor issues that are considered to be housekeeping items. Seldom do the inspectors encounter non-compliances with technical specifications.