RECOMMENDATIONS

1. High priority should be given by the Government of Slovenia and by the SNSA to finalize all the activities that are related to the preparation and promulgation of the new law related to nuclear, radiation and waste safety. The new law should be in line with the best international practices.
2. In the new law, a clearer definition of the areas on which the different governmental bodies have authority and of the relationships between them in the authorization process of nuclear installations and radiation sources should be provided. In particular, the SNSA should be clearly assigned the authority, responsibilities and functions it needs as the regulatory body.
3. The issue of the appeal procedure should be revisited in the frame of the new law.
4. In the new law appropriate provisions should be established to ensure the performance of an effective independent assessment in the licensing process. These provisions should provide the SNSA the authority and the resources to contract external organizations. The SNSA should establish the appropriate procedures to ensure that for the activities contracted, the organizations are independent from the licensee.
5. In the new law provisions should be established to define the funding system of the SNSA. Fees collection from the licensee could be considered as a resource to fund independent assessment activities as recommended in Section 1.4.1. (d).
6. After the promulgation of the new law, the adequacy of the resources provided to the SNSA should be re-evaluated to ensure that all the responsibilities and functions assigned to the SNSA can be effectively carried out.
7. The SNSA should define clearly its policy, objectives and strategies related to regulation of nuclear, radiation, radioactive waste and transport safety and communicate them to the staff, licensees and public.
8. The Slovenian Government should establish effective co-ordination of activities of all parties involved in the development of the new draft law on nuclear, radiation and radioactive waste safety.
9. Provisions for Periodic Safety Review should be included in the new law on nuclear, radiation and radioactive waste safety.
10. In the development of the new law on nuclear, radiation radioactive waste and transport safety the role of the Nuclear Safety Expert Commission should be reviewed in order to ensure that it provides independent advice to the regulatory body.
11. The SNSA core competence should be reinforced in the safety assessment area.
12. The SNSA should continue its efforts in establishing a formal internal QA programme. In particular, it should develop a manual for conducting inspections.
13. The SNSA should further strengthen its activities in the area of evaluation of operational experience feedback and to engage additional resources inside its own organization or obtain support from appropriate technical institutions or experts.
14. The SNSA should ensure that all safety justifications, being part of current licensing basis, are identified, accessible and under the SNSA’s control.
15. The SNSA should further develop its technical capabilities, in order to be able to make independent decisions in the area of nuclear safety.
16. The Slovenian Government should develop in the new law a long-term policy on the role of the authorized organizations in the framework of the independent regulatory safety assessment process. The current competencies of the authorized organizations should continue to be recognized.
17. The SNSA should consider strengthening the annual inspection programme through further development of a systematic approach. The SNSA should consider focusing the inspector’s activities on directly implementing this inspection programme.
18. The SNSA should strengthen their regulatory processes by developing an enforcement policy that establishes criteria for the identification and processing of major non-compliances with licence requirements.
19. The government should take prompt action to develop their “National Protection and Rescue Plan in the Event of a Radiological Emergency”.
20. The government should take prompt action to conduct a complete and thorough review of the competencies and responsibilities of the Administration for Civil Protection and Disaster Relief/National Civil Protection Headquarters (ACPDR/NCPH) and the SNSA. This should be done on the basis of their specific core competencies concerning radiological and nuclear emergency planning of these both authorities.
21. The Emergency Preparedness and Response Plan of the SNSA should be completed promptly.
22. The SNSA should ensure that external staff involved in emergency preparedness fulfills all necessary requirements in the field of emergency preparedness and response.
23. A national comprehensive full scope exercise should be conducted in the next two years.
24. The government should seek regular participation by the Civil Protection authorities in Croatia concerning emergency drills.
25. The waste classification system should be reviewed for all facilities and activities generating nuclear waste within Slovenia. Definitions for waste types within the classification system should be developed by the SNSA.
26. Clearance criteria and procedures should be developed by the SNSA and applied in Slovenia.
27. The SNSA should direct the Agency for Radioactive Waste Management (ARAO) to review and evaluate the time schedule for siting and completion of the low and intermediate level waste (LILW) repository.
28. The SNSA could, in preparation of new legislation, establish the necessary licensing requirements for decommissioning. The decommissioning plan for nuclear facilities other than NPP should be requested and evaluated by the SNSA.
29. The SNSA should develop a policy document concerning a standard format for analysing ALARA optimization planning in nuclear facilities. In addition, the SNSA and the Ministry of Health should develop ALARA optimization policy documents for radiation sources used in industrial and medical applications.
30. The new legislation should include the requirement for all dosimetry services to be authorized or accredited by the relevant regulatory authority.
31. The Government of Slovenia should ensure that a programme to determine patient doses in diagnostic radiological and nuclear medicine procedures and that those doses are compared with the guidance levels recommended in the IAEA SS – 115 - International Basic Standards for Protection against Ionizing Radiation and for the Safety of Radiation Sources, and in other countries.
32. The SNSA and NPP should develop a regular meeting schedule with a standing agenda to convey and discuss the regulatory strategy, current safety issues and to facilitate implementation of the regulatory processes. Actions from these meetings should be completed as agreed upon.

SUGGESTIONS

1. In the preparation of the new law, the SNSA could make use of the assistance offered in this area by the IAEA and the European Commission.
2. The SNSA could reconsider its policy on public information to ensure that its authorities, responsibilities, policies, objectives and strategies related to safety are clearly understood and communicated to the public. This could help to build public confidence in the role of the SNSA as a regulator.
3. The SNSA should define its policy and requirements on Periodic Safety Review and communicate them in a timely manner to the utility.
4. Consideration should be given by the SNSA to the establishment of a systematic training programme plan to meet individual SNSA staff needs. For example staff training in plant system analysis could be strengthened. Training in effective project management could also be considered.
5. The SNSA could benefit from performing self-assessment of its structure and activities and could adopt and maintain systems for prioritizing, planning and monitoring its work, processes and outputs.
6. The SNSA may promote stronger, systematic communications amongst its divisions by holding more staff meetings at regular intervals.
   
7. The SNSA should licence operational personnel for the research reactor as for NPP personnel.
8. The SNSA should, in the case of large projects, consider the appointment of a project manager, who would be responsible for the co-ordination of all the review and assessment activities and for the integration of the review results. This would promote a uniform approach and provide better support to the staff and to the management.
9. The SNSA is advised to continue and intensify its contacts with the operator and its participation in the discussions during the independent review activities carried out by the authorized organizations.
10. The SNSA could consider optimizing their systematic inspection programme through the use of integrated plant performance assessments, probabilistic risk assessments and, if feasible, development of safety performance indicators.
11. The SNSA should fully implement their training requirements for inspectors. This should include providing additional training on inspection techniques and risk assessment. Additionally, this suggestion includes reviewing the training of authorized institution personnel used during outages.
12. Implementation of the new legislation for nuclear and radiation safety could be realized commensurate with the global strategies of the involved regulatory bodies. A possible approach could be that the use of regulations is kept at a minimum and that guides incorporate elements of technical nature. Guides should be issued by the regulatory body having authority in the concerned field. The new legislation should support this approach.
13. The SNSA should optimize the use of specific rooms for a safe and rapid emergency preparedness and response.
14. Unannounced in-house drills should be exercised at least once per year to demonstrate the preparedness of the SNSA’s shift and infrastructure fitness in an emergency.
15. The SNSA should liaise with other government organizations involved in the regulatory control of the rehabilitation of the uranium mine and mill site to ensure that appropriate regulatory control over the radiation aspects of the rehabilitation process is provided.
16. The SNSA should develop a policy document setting out their requirements for the rehabilitation of the radioactive waste at the uranium mine and mill site.
17. The SNSA could take a proactive role in ensuring that the public is adequately informed even in the early phase of site selection process for waste repositories.
18. The SNSA could review and evaluate the Strategy on Spent Fuel Management at regular intervals.
19. The SNSA could review the decommissioning plan for Krš ko NPP at regular intervals.
20. The SNSA and Health Inspectorate could verify the quality of environmental measurements carried out by the authorized organizations.
21. The SNSA and the Ministry of Health should co-operate in the development and maintenance of databases on occupational exposures to radiation.
22. The regulatory authorities should consider reviewing at regular intervals the adequacy of the authorization given to the authorized organizations in the radiation protection area.
23. The regulatory authorities should ensure that criteria are developed for the training and examination of radiation protection experts in Slovenia, and that authorized users of radiation sources should employ the services of radiation protection experts where required.
24. The SNSA could develop a clear regulatory strategy for assessing licensee's safety culture.
25. The SNSA could perform its own safety culture assessment.

1. 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.
2. The Nuclear Safety Division has taken the initiative to develop administrative tools to enhance the quality of the safety review activities and to develop data bases as support for the management of licensing and assessment activities.
3. Inspectors are provided CD-ROM versions of the plant’s technical specifications and safety analysis report. This improves the effectiveness of the inspection programme.
4. The SNSA has taken the initiative to translate into Slovenian main IAEA Codes and Guides on nuclear safety and to make them publicly available.
5. The SNSA has taken active part in establishment of bilateral agreements on early exchange of information in case of nuclear accidents with several neighbouring countries.
6. The SNSA conducted a serious evaluation of the emergency preparedness of regional and national organizations during three OECD-INEX-2 exercises. The SNSA developed conclusions and identified areas that need further improvement.
7. The Ministry of Health, upon the SNSA advice, maintains an inventory of all sources in Slovenia. The inventory includes details on the inspection reports of each radiation source, and the Ministry of Health and The SNSA have put in place procedures to ensure that an inspection is carried out each year, that advice is provided to authorized users on the correct handling and storage of radiation sources.