Experts: J. Noeggerath and C. A. Casto

8.1. NATIONAL EMERGENCY PLANNING

Since its independence in 1991, Slovenia has made considerable efforts and progress to work out new National Protection and Rescue Plans in the event of man-made and natural accidents. Relevant parts of this national planning existed before 1991. Recently, The National Protection and Rescue Plan in the Event of a Nuclear Accident (NPRPENA) was developed and explicitly excludes radiological emergencies (sources, transport etc.). Contributors to this new off-site national emergency preparedness and response plan for nuclear emergencies are several governmental authorities of different ministries.

Slovenia appears to have well developed emergency preparedness capabilities which address all aspects of radiological emergencies. IAEA’s Report on Transport Safety Appraisal Service for Slovenia (IAEA/NSWR/TRANSAS/99/01, Aug. 1999) confirmed that especially in the field of radioactive transport, good emergency preparedness and response capabilities exist. However, there is no specific National Protection and Rescue Plan in the Event of a Radiological Accident. The government should take prompt action to develop this plan.

8.2. NATIONAL EMERGENCY PLAN FOR NUCLEAR EVENTS

The National Protection and Rescue Plan in the Event of a Nuclear Accident (NPRPENA) should be a general description which also defines the duties and responsibilities of all responding organizations. High attention has to be given to the integration of all interfaces and relationships between the various involved organizations.

The Slovenian approved national plan has not been finalized and not been exercised.

Apart from the national plan, regional and local off-site plans have been developed and set in place by the corresponding authorities. The Krš ko NPP on-site Emergency and Response Plan was established on the basis of US NUREG-0654. A system for emergency response classification has been developed to determine the level of response required.

The national plan is based on legislation of different periods. It adopts parts of the former Legislation of the Republic of Yugoslavia, its province Slovenia, the present legislation of the Republic of Slovenia and on NRC Regulation (NUREG-0654). Further, it is also intended to adopt most of the IAEA’s requirements in this plan. The appendices of this plan will include the SNSA’s Nuclear Emergency Response Plan (NERP), plans of other ministries as well as procedures, e.g. for public and media information, exercises and other relevant activities. The plan also covers the nuclear research reactor TRIGA.

8.3. ROLES AND RESPONSIBILITIES

Owing to the present legislative situation, there are several national authorities with obviously insufficient co-ordinated competences appointed with the development of the NPRPENA. In the following text, only the duties of Administration for Civil Protection and Disaster Relief (ACPDR) and the SNSA are considered.

The leading party is the ACPDR and a governmental group, the National Civil Protection Headquarters (NCPH) in the case of an emergency. ACPDR is responsible for the developing and co-ordination of the national plan. NCPH manages the co-ordination, decision-making and enforcement of activities to protect off-site public health and property in the case of a nuclear or radiation accident. The SNSA is the independent competent expert authority for inspection and enforcement concerning the compliance of the on-site RNEPRP of nuclear facilities to approved standards. Also, the SNSA supports NCPH in the event of a radiological or nuclear emergency with information, data and evaluations necessary to enable NCPH to make appropriate decisions on protective actions for the public. The latter means there is an important interface function of the SNSA between on-site and off-site nuclear and radiation safety aspects of nuclear emergency preparedness and response.

The NPRPENA was developed in 1998 by ACPDR and in that time presented as a draft version to the SNSA and others. The national plan showed a serious lack of co-ordination between involved authorities and organizations on the different levels. The plan could therefore not ensure that detail planning on the different levels was integrated and consolidated. Later proposals of the SNSA to adjust and strengthen the necessary co-ordination between the authorities concerned in the national plan with the help of the Agency’s TECDOC-953 have not been incorporated. The Team points out that technical knowledge on the specifics of nuclear and radiological emergencies are a prerequisite to developing a coherent and integrated national emergency plan for nuclear emergencies. Radiation protection and nuclear safety are not technical core competences of ACPDR. The necessary co-ordination between both national authorities ACPDR/NCPH and the SNSA is not ensured.

Despite the adoption of this plan by the government in April 1999 and its decision to set the plan in place by September 1999, it is evident that several safety important parts (appendices) of the national plan are still missing. There is evidence that the coherence of national, regional/local emergency planning is not optimal.

Consequently, the national plan is not finalized and it is questionable if the NPRPENA is entirely operational in all aspects due to the present state.

It was explained to the Team that the government of Slovenia is planning to set up a governmental commission concerning the national nuclear emergency plan. Intention of this commission is to enhance the further development and implementation of the existing plan. The Team strongly supports this intention.

8.4. THE SNSA EMERGENCY PREPAREDNESS AND RESPONSE PLAN

The SNSA’s emergency preparedness is established in many different procedures. Up to now, the SNSA has not completed its RNERP with a comprehensive and consistent representation and description of the core process - Emergency Preparedness and Response. Further, some SNSA’s emergency procedures are not yet officially in place. Emergency planning is a “living” process. The completion of the SNSA’s RNERP is an important prerequisite to emphasize and fully integrate an effective emergency preparedness in the organization.

The SNSA’s notification by the National Notification Center in case of an emergency is ensured by a weekly, on-call officer. The notification of this person is accomplished by mobile phone. This person has to alert the SNSA’s emergency staff.

A certain part of the SNSA staff have responsibilities concerning emergency preparedness. Because of the SNSA's limited staff it was necessary to add members of other relevant authorized organizations in the SNSA’s emergency preparedness shifts on an almost voluntary basis.

The responsibilities of the emergency groups in the SNSA are defined in emergency procedures which are part of the draft version of the SNSA-RNERP. The available emergency staff is divided into two shifts. Everyone is within reach via pager or mobile phone.

Both shifts consist of three action-groups: a group for reactor accident progression assessment, a group for dose assessment and a group for providing information and support. After their arrival to the SNSA’s emergency localities they follow their specific tasks through the use of procedures.

Immediately after the initial notification a SNSA-inspector is sent as a contact to the nuclear facility’s Technical Support Center (TSC).

The SNSA-Emergency Director is responsible for all activities of the SNSA-Emergency Center (SEC) during an event of a severe nuclear or radiological accident. He co-ordinates necessary SEC-tasks and he has to provide independent competent expert support to the Command Board of the CNPH.

The SNSA receives its data on an emergency from KNPP via on-line systems. These are a meteorological and radiological data transfer system and the ERDS-Emergency Response Data System which gives online access of safety relevant operation parameters. A source term code is still not available in the emergency group. A source term code should be provided to effectively support the reactor safety group in the evaluation of accident and dose rate progression. For the communication with the involved parties there are fax machines, telex or a (dedicated) phone line available.

The SNSA’s communication equipment for emergency preparedness and evaluation is on a sufficient and appropriate level.

The space at the SNSA’s office is limited. In case of an emergency alert, the SNSA emergency assessment groups will start to work in their normal offices with the support and communication equipment. The SNSA does not have a dedicated facility for this purpose. The emergency fitness of the SNSA offices has not been optimized. These rooms should have all emergency related documentation (EPR-plan and procedures, maps, oversight system plans, plant/system descriptions (SAR) relevant phone numbers). A rapid and safe access to this documentation should be ensured. Cabinets with emergency relevant materials and documents are not well labelled. Oversight maps with emergency zones are missing. Also the meeting room of the SEC-Director does not fulfil the appropriate standard for an emergency.

See recommendation in Section 8.3.1. of this report.

8.5. DRILLS AND EXERCISES

Drills and exercises on different levels are important to show the effectiveness of the national plan as well as the effectiveness of the SNSA and others. It demonstrates further the ability of different organizations to co-operate and interface appropriately. Regular drills and exercises are an unalterable assumption to permanent improvement in this field. Since 1993 several tabletop exercises have been conducted.

No unannounced SNSA in-house drills have been conducted up to now. Consequently, there is no proof that a sufficient degree of preparedness under the given conditions is guaranteed. There is a lack of experience if the organization and infrastructure under more realistic circumstances is able to manage a nuclear or radiation accident. Results of these drills should be carefully evaluated in order to continuously optimize emergency preparedness organization and infrastructure. For example, drills should also be conducted beyond regular office-times and in typical holiday times to experience extreme but probable staff shortages.

No national comprehensive full scope exercise has been conducted for six years. The effectiveness of the draft national plan has not yet been tested. The demonstration of a coherent, orderly and effective co-operation of national, regional, local and the KNPP according to the introduced procedures in the case of an nuclear emergency has not yet been given. Although, the Croatian border touches almost the 10 km –Urgent Protective Actions Zone, the regional Headquarters for Civil Protection in Croatia have not yet been periodically involved in emergency exercises.

8.6. INFORMATION TO THE PUBLIC

In the case of an alert, the SNSA information for public and media will be given in agreement with the KNPP. In the case of a Site Emergency or a General Emergency the SNSA information will be given in agreement with the command of the NCPH. Neither the national plan nor SNSR’s RNERP gives at present clear statements on an integral information policy towards the public and the media in case of a severe accident.

The SNSA as the competent technical nuclear safety authority should be basically authorized to give an independent information to the public in the case of an emergency. In order to avoid misunderstandings their information should be co-ordinated with the other involved parties. However, the SNSA should provide the public with independent assessment of the emergency conditions.

The government should take in account the recommendation already made under 8.2.1.

See recommendation in Section 8.3.1. of this report.

8.7. INTERNATIONAL ACTIVITIES

Slovenia is party to the Convention on Early Notification of a Nuclear Accident and to the Convention on the Assistance in the Case of a Nuclear Accident or Radiological Emergency. Further, it is party of several bilateral agreements with neighbouring countries in the field of early notification. Other international agreements are in preparation. The SNSA and others took active part in several international projects and exercises related to emergency preparedness and response.