7th Slovenian CNS Report, Answers to Questions of …...Slovenian legislation (Rules JV9) - Number of temporary modifications. All SNSA indicators have the same importance. 13. France

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7th Slovenian CNS Report, Answers to Questions of Other CP – February 2017

No. Country Article Question Answer

1. Austria Section 10.2, p28

Could you please provide the list of indicators of safety culture that are being monitored by Krško NPP, and in particular highlight those that are now in the white or yellow zone? On which basis were the criteria for categorising indicators in 4 zones developed and what is considered in those criteria?

The answer is in the attached file Appendix 1 (Reference to Q1).

2. Austria Section 19.8 p71

Slovenia’s CNS report indicates that the spent fuel pool (SFP) is “inadequate from safety and operational capacity ... until 2023”, and that “in light for possible lifetime extension to 2043...” a Spent Fuel Dry Storage (SFDS) is needed. What are the safety issues related to the SFP, and will those be (fully) resolved when the implemenation of the SUP is completed (as the SFP need to be safety even beyond the operational life of the NPP- precisely 5 years beyond, as indicated in the Appendix II A). In the Appending II A it is stated that “all the available positions in the SFP will be filled by 2019”. If the SFDS is not available at that time, which effects will that have on Krško operations? Regarding the “possible lifetime extension”: Elsewhere in the report it is indicated that the SNSA approved the extension of life of Krško NPP, and presumably Krško operator want to extend the lifetime. What is meant by the statement of “possible lifetime extension” in this section?

1. Due to the stringent requirements after the Fukushima accident and due to stricter requirements arising from the design extension conditions (DEC) requirements, the plant has decided to implement the safety upgrade project (SUP). SUP envisages the construction of a new dry storage and upgrade nuclear safety of the existing spent fuel pool. Both projects prescribed DEC conditions in accordance with the new WENRA requirements from 2014. In 2015 the Krško NPP prepared the conceptual design package for spent fuel dry storage for the purpose of starting a bidding process which is underway. The construction of dry storage of spent nuclear fuel envisaged between 2018 and 2019. The envisaged commencement of transfers of spent nuclear fuel from the pool into dry storage is expected in 2020. At the moment it does not expect a delay in the operation of the spent fuel dry storage. In case of any project delays the Krško NPP will prepare additional analyses of current spent fuel pool operation and management restrictions and propose some options for spent fuel storage for intermediate time. 2. SNSA issued the decision for Ageing Management program (AMP) approval and SAR change. It was issued in June 2012. Nevertheless, for lifetime extension also other requirements have to be met, such as successfully implemented PSR, fully implemented SUP, regular maintenance, good safety culture, etc. with sufficient implementation of approved AMP programs and procedures. The term »possible« is used, because decision regarding lifetime extension depends on the owners, SNSA as mentioned has therefore approved only one of the conditions, which allow lifetime extension.


What are the design basis for the alternate spent fuel pool (SFP) cooling system?

Alternate SFP cooling system will be based on a mobile heat exchanger that will be connected to preinstalled SFP piping. The mobile heat exchanger will have several

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possible sources of cooling water. In addition, fixed sprays will be installed around the SFP to enable cooling of the fuel in case of breached SFP. For detailed description of design basis for the SUP systems see Slovenian NAcP Part IV, Chapter 2 (http://www.ursjv.gov.si/fileadmin/ujv.gov.si/pageuploads/Info_sredisce/Tecaji_konference_seminarji/tecaji_MAAE/SLO_NAcP-2015.pdf )


Where will the additional residual heat removal pump and dedicated heat exchanges be installed? Is this a part of the “BB2 project”?

This equipment will be installed in the existing auxiliary building (seismically qualified, protected against floods and other hazards). This improvement is not part of the BB2 project. It is a part of the 2nd phase of the SUP.


What are the design basis for the BB2 bunker and its equipment (seismic resistance, other external hazards, spectrum of sequences to be protected against)?

For detailed description of design basis for the SUP systems see Slovenian NAcP Part IV, Chapter 2 (http://www.ursjv.gov.si/fileadmin/ujv.gov.si/pageuploads/Info_sredisce/Tecaji_konference_seminarji/tecaji_MAAE/SLO_NAcP-2015.pdf)


The amended Rules JV5 (which are not in force, yet but is expected to be in force soon) encompass the requirements from the WENRA Safety Reference Levels (SRLs) and Safety Objectives for new reactors, including the concept of “practical elimination” of accidents with early or large releases. Once in force would those requirements be applicable to Krško NPP?

All new requirements that were added as a result of WENRA SRLs are also required for the Krško NPP, while not all of the new requirements that are based on the Safety Objectives for New Reactors are required for the Krško plant. Among those is also the concept of "practical elimination". Still, the Krško NPP shall strive towards the "practical elimination" with its future improvements, as much as reasonably practicable. The amended Rules JV5 is in force since December 2016.


The Introduction to the Slovenia's National report states that the delay in the implementing of the post Fukushima measures (SUP) has been due to “financial constrains” (or, as it is stated in the Appendix II A, “owners of the Krško NPP became unwilling to finance the SUP”). Article 11 indicates that financial resources are “adequate”. Does it means that, as of now, all financial resources needed for the implemenation of the SUP and its completion by 2021 are assured?

Yes.

8. Croatia 19.7, 70 In Chapter 10.3 it is indicated that the plant monitors 46 safety and performance indicators while in Chapter 19.7 it is stated

The SNSA has its own set of 38 safety and performance indicators as is described in chapter 10.3 (46 is a mistake) and the Krško NPP has got and monitors a set of more than 140 safety and performance indicators as is described in chapter 19.7. Those two sets are different sets.

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that the plant program covers more than 100 indicators. Please explain.

9. Croatia 13.1, 38 It is stated that SNSA Management System complies with IAEA safety standard GS-R-3. However, this standard has been superseded by GSR Part 2. Are there any plans to update the system in accordance with new IAEA requirements?

SNSA intends to prepare the new version of the SNSA Management System Manual in 2017. The new version will be in line with the IAEA standard GSR Part 2 and will include all additional requirements set by the new IAEA standard. In 2017, SNSA will start with the implementation of the new requirements posed by GSR Part 2, as well.

10. Croatia 12.2, 36 Second Krško NPP periodic safety review had close to 400 issues. Statement on only six new issues is probably valid only for one safety factor?

Yes, it is only for one factor, namely for the Human Factor.

11. Croatia 10.3, 30 Has any particular international guidance been followed in the selection of 46 safety and performance indicators?

Most of the SNSA safety and performance indicators (SPI) are based on IAEA TECDOC 1141, but some of them were developed on SNSA experience and regulation requirements. For detailed description for the performance indicators see Slovenian Annual report, Chapter 2.1.1.2 http://www.ursjv.gov.si/fileadmin/ujv.gov.si/pageuploads/si/Porocila/LetnaPorocila/2008/LP2008-ANG.pdf Development of initial set of indicators is described in the attached article: Plant Safety and Performance Indicators for Regulatory Use, 2004, Matjaž Ferjančič et. al. (See Appendix 2, Reference to Q11).

12. France § 19.7, 70

Slovenia mentioned that Krsko NPP uses set of performance indicators (more than 100) while SNSA developed another set of 36 safety performance indicators. Are the both set of indicators based on specific guide from IAEA “operational SPI IAEA-TECDOC-1141 2000? Could Slovenia give us further examples of these indicators used for operational experience feedback (definition, importance)?

The SNSA and NPP Krško SPI’s are based on IAEA TECDOC-1141. About 60% of the SNSA safety performance indicators (SPI) have the same definitions as NPP Krško, but the other 40% of SPI have different definitions. Exampled of the SNSA indicators are as follows: - Number of violation of licensing requirements (No. of violation of technical specification and regulations) - Number of events (definition: indicator is divided on two parts: No. of events regarding to Krško NPP procedure and No. of reportable events regarding to the Slovenian legislation (Rules JV9) - Number of temporary modifications. All SNSA indicators have the same importance.

13. France § 19.6, 67 to 69

Slovenia specified that from 2013 to 2016, only 13 events were notified to the regulatory authority. Could Slovenia precise the INES level declared for these reported events? Slovenia detailed two events related reactor trips which induced material modifications.

For these 13 events the INES rating 0 was determined. For an event in 2013 "Discovery of damaged fuel rods during core unloading and fuel inspections" the INES report was published on the NEWS website. For another event in 2015 the rating was determined as 0 and the event was not reported to NEWS. For all other events, preliminary ratings were proposed to be level 0 by the operator and a screening by the SNSA confirmed these ratings.

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Had these modifications to be approved by SNSA before to be introduced on site?

Yes, these modifications were approved by regular licencing procedure by the SNSA before being introduced on the site.

14. France § 19.6, 67 to 69

Slovenia mentioned that krsko NPP developed a set of programs in three fields of maintenance, operation and inspection. Must these procedures be validated and approved by the Slovenian Nuclear Safety Administration (SNSA) before their application?

The Krško NPP procedures do not have to be validated and approved by the SNSA before their application, but procedures are subject of SNSA review and validation as part of safety significant modifications or regular regulatory supervision of maintenance, operation and inspection activities.

15. France § 16.4, 55

Slovenia indicates the bigger exercises conducted during the last period, including a regional international exercise. Could Slovenia present the lessons learned from these recent exercises?

The main observation is that internationally, especially regionally, there is not enough collaboration and information sharing and that because of this, response is not consistent.

16. France § 16.3, 55

The information of the public seems to be in place only during the preparedness phase. Is there any mechanism in place to inform the affected population during a real emergency?

The mechanism is in place. For notification purposes there is an alarm system in whole territory of Slovenia. Instructions are given over the national media (radio, TV), thus reaching the whole population if needed.

17. France Article 14.2,

Appendix II, 79

Following the Fukushima event, have the seismic risks been reassessed? If yes, which approach has been chosen and what are the verifications done on NPP existing equipment and buildings? If not, what are the justifications?

After Fukushima accident the EU stress tests were done for the Krško NPP (see the detailed report here: http://www.ursjv.gov.si/fileadmin/ujv.gov.si/pageuploads/si/Novice/Slovenian_Stress_Test_Final_Report.pdf ). The chosen approach for reassessment of seismic risks was in line with the Stress Test Specifications. The reassessment used the data from the detailed seismic PSA analysis, which were done in 1990's and again in 2000's."

18. France § 14.2.1,

46

The ageing management program (AMP) aims at determining whether ageing processes are being managed effectively and if the required safety margins are maintained. What is the schedule of this program? What are the first results? Were modifications of maintenance program implemented to integrate the results?

NPP Krško follows the USA practice, thus the maintenance programs and EQ programs should be in place before the AMP programs are implemented. The AMP programs in the Krško NPP were implemented in the period from 2010 to 2012. Some of the programs were already in place like part of other processes (maintenance, ISI, etc.). Those programs were modified to include ageing management elements. In the Krško NPP 46 AMP programs are in place. Now this programs are continuously updated according to the operating experience from the Krško NPP, as well as from other NPPs and from research activities (NRC, etc.). The results from ageing management activities are collected and assessed. From the results so far there are no major problems. Deviations are promptly remedied.

19. France § 10.2, 28

Slovenia mentions that “the findings and corrective actions for safety culture indicators are communicated all over the NPP

The National report, Chapter 10.2, lists main means for evaluating safety culture of the operator. These include self-assessment of safety culture in 2013 and review of safety culture during the PSR (completed in 2014). Krško NPP uses Operating

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organization. Comparison of safety culture indicators status between 2013 and 2016 show improvement and currently, there are no indicators with “red” status (Unacceptable Zone). There are only indicators in green (excellent), white (normal) and yellow (delayed/behind schedule)”. Could Slovenia explain what are the other means, beyond indicators, to evaluate safety culture?

Experience Program for assessing events that are connected with the safety culture. In May 2015 a new Krško NPP procedure ADP-1.0.050 “Monitoring of Safety Culture and Human Factors” was issued. The SNSA have also performed a thematic inspection in 2016 covering safety culture. This inspection was a follow-up of the inspection conducted in 2014. For the preparation to the inspection the Krško NPP prepared answers to a set of questions, sent to the NPP in advance. The questions were based on the 2014 inspection findings.

20. France General, Summar

y, 94

In the appendix II, Slovenia underlines that new nuclear power plants are to be designed, sited and constructed, consistent with the objective of preventing accidents. The Vienna declaration address also the question of “mitigating possible releases of radionuclides causing long term off site contamination and avoiding early radioactive releases or radioactive releases large enough to require long term protective measures and actions”. Could Slovenia indicate what the objectives to be fulfilled by new builds in terms of mitigation of possible releases with long term off-site contamination are?

Slovenian requirements and regulations are in-line with the newest WENRA RSLs as well as the Safety Objectives for New Reactors, which are basically requiring that:

- accidents without core melt induce no off-site radiological impact or only minor radiological impact (in particular, no necessity of iodine prophylaxis, sheltering nor evacuation,

- reducing potential radioactive releases to the environment from accidents with core melt, also in the long term, by following the qualitative criteria below: (a)accidents with core melt which would lead to early or large releases have to be practically eliminated; (b) for accidents with core melt that have not been practically eliminated, design provisions have to be taken so that only limited protective measures in area and time are needed for the public (no permanent relocation, no need for emergency evacuation outside the immediate vicinity of the plant, limited sheltering, no long term restrictions in food consumption) and that sufficient time is available to implement these measures.

21. France General, Summary, 79 to

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Could Slovenia explain its strategy in international commitment? Can Slovenia explain how does it implement the recommendations of international peer review mission and follow up?

Slovenia does its best to meet all international commitments. As regards the SNSA its international commitments are reflected in its annual work-plan, which consists of actions to be met in the current year. This work-plan is required by the SNSA Management Manual. The recommendations of international peer review missions and their follow-up missions are distributed to responsible persons, who prepare proposals for relevant actions, which are then analysed and an action plan is prepared and agreed by all stakeholders how to meet the recommendations. As regards the recommendation and suggestion, which remained open after 2014 IRRS follow-up mission, the situation with construction of LILW storage is progressing better and the harmonization of emergency planning with Croatia is a bilateral issue, as mentioned in the CNS Report. In this area the progress is not as fast as we would like to have it.

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22. Germany Article 10, p.

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Slovenia mentions that rules JV5 and JV9 have been revised, but not been adopted yet. Until when will these rules be formally adopted?

Both Rules were published in the end of 2016. Namely, the Rules JV5 were published in the Official gazette of the Republic of Slovenia, No. 74/2016 on 25 November 2016. The Rules JV9 were published in the Official gazette of the Republic of Slovenia, No. 81/2016 on 16 December 2016.

23. Germany Article 19, p.

67

Beside the „Abnormal Operating Procedures“ (AOP) and the „Emergency Operating Procedures“ (EOP) did SNSA also review the mentioned „Fire Response Procedures“ (FRP) and „Severe Accident Management Guidelines“ (SAMG)?

The Krško NPP plant specific SAMG were developed in 2000 and were verified and validated in 2001 with use of full scope plant simulator capable of simulation of severe accidents. The SAMG were reviewed also by an IAEA RAMP mission in 2001 where SNSA also participated. The mission report is available on the SNSA website: http://www.ursjv.gov.si/en/info/reports/reports_of_eu_and_expert_missions/ The operator regularly updates the FRP and SAMG and delivers them to the SNSA. The SNSA reviews all the updates in the procedures/guidelines. The new revisions of SAMG are verified during annual emergency exercises which include scenarios of severe accidents. SNSA actively participates at these exercises and therefore reviews implementation of SAMG. According to requirements of Article 40 of the regulation JV5 the Krško NPP submitted an application for a new chapter of the SAR that includes description of AOP, EOP, FRP and SAMG. The SAR changes were reviewed also by a TSO that prepared an independent expert opinion of the impact of changes on nuclear safety. The SNSA currently reviews the application and shall issue a decision (approval) in 2017.

24. Hungary General, p.4

„Knowledge and competence management is getting more and more important with the ageing of the existing regulatory and nuclear power plant staff. Unstable research funding for areas related to nuclear technology and the constant pressure for phasing out the nuclear by some countries, as well as relatively small number of new builds, makes the nuclear technology and safety less attractive for the new young graduates with technical background, who would decide to pursue their careers in the nuclear area. In Slovenia, we try to increase and improve training programme in the Slovenian Nuclear Safety Administration by the implementation of a systematic approach to training. Also the Resolution on Nuclear and Radiation Safety in the Republic of Slovenia for the Period

In the Krško NPP there is a dedicated unit which is in charge of training. The initial training, training to get new knowledge and refreshers are run in line with the extensive programme. The knowledge is successfully transferred to new staff, e.g. in 2015 16 new field operators of different systems were trained. There are dedicated training programs, special courses, hands-on (on-the-job) training, etc. for all categories of workers, which cover their specific duties, as well as training in radiation protection (more than 400 people involved in 2015) and emergency preparedness (more than 500 people involved in 2015). In particular, there is a regular training of reactor operators, who are examined in regular intervals. Before each outage about 1500 people undergo so called “general employee training”.

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2013–2023 should contribute to improving the situation in the area of knowledge and competence management.” What is the specific way as the Krško NPP handles the knowledge and competence management challanges?

25. Hungary Article 8, p.21,

p.82

„When the SNSA employs new (and usually young) members, they usually do not yet have proper competences. In the call for application, only formal requirements are written, such as education, working experience and knowledge of languages. Once employed, the new employee has to pass the state exam for the public servants, which covers mostly general topics.” „SNSA, even under critical financial conditions and with the budget, reduced due to austerity measures, continues to pay attention to education and training with the aim of monitoring and developing the careers of public servants and the creation of conditions for improvement of professional skills of all employees.” What is the specific way as the Slovenian Nuclear Safety Administration handles the knowledge and competence management challanges?

In Slovenia, we try to increase and improve training programme in the Slovenian Nuclear Safety Administration by the implementation of a »Systematic Approach to Training«. Inside this system yearly interviews are used for competences evaluation, gap analyses and training needs assessment. Based on this evaluation yearly Educational and Training Plan is prepared. Training consists of on-the job training, self-study, in-house courses, IAEA workshops and courses etc. SNSA handles the knowledge and competence management challenges in various different ways; we believe that the explanation is well described in first two paragraphs on page 22 of our Report.

26. Hungary Article 8, p.4, p.89., p.22

„Knowledge and competence management is getting more and more important with the ageing of the existing regulatory and nuclear power plant staff. Unstable research funding for areas related to nuclear technology and the constant pressure for phasing out the nuclear by some countries, as well as relatively small number of new builds, makes the nuclear technology and safety less attractive for the new young graduates with

The Slovenian Government does not have any additional method or instrument available for knowledge and competence management besides those described in previous two answers. The Government is setting policies and preparing and issuing legal documents, but does not have any additional role for daily continuous actions in that or in most of other field. The general policy on research and development in nuclear field (knowledge and competences management) is set in the Resolution 2013-2023.

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technical background, who would decide to pursue their careers in the nuclear area. In Slovenia, we try to increase and improve training programme in the Slovenian Nuclear Safety Administration by the implementation of a systematic approach to training. Also the Resolution on Nuclear and Radiation Safety in the Republic of Slovenia for the Period 2013–2023 should contribute to improving the situation in the area of knowledge and competence management.” „environment the human resource capacity and competence across all organizations in the field of nuclear safety can be further developed. SNSA shall organize a meeting, where this topic shall be brainstormed by all involved parties (the utility, the regulatory body, TSOs…). Special action plan shall be prepared and executed to enhance political support to nuclear safety infrastructure.” „It has to be mentioned that due to very strict and restrictive governmental policy on employment for the last few years the SNSA has not employed any new staff member. In 2015 and 2016 such restrictive governmental policy has slightly softened and the filling out vacant posts of workers, who have been retired or have been on maternity or sick leave, is allowed now.” What is the specific way as the Slovenian Government handles the knowledge and competence management challenges?

27. Hungary Article 7.1, p.14

"Several amendments have been introduced... : new provisions to prevent the incorporation of non-conforming, counterfeit, fraudulent and suspect items into nuclear and radiation facilities." How could be these provisions achieved in effect?

It well may be that the provision, which obliges the operator of nuclear and/or radiation facility that (within the context of its management system) establish procedures for ensuring the introduction or installation of only such equipment that complies with the applicable standards, specifications or technical requirements, is difficult to verify and that as such has questionable added value.

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But on the other hand a provision in question is not only of declaratory nature since the operator might be penalized once it is proven that such facility operator has not established or not implemented management system, or if the operator did not include in it a safety culture, as well as in oversight of vendors, contractors and subcontractors or if management system does not include the procedures to ensure the introduction or installation of appropriate equipment.

28. Hungary Article 15.4, p.53

"The Krško NPP updated clearance levels according to the legislation." What is the clearance level now?

Clearance levels are set in the legislation and are in accordance with EU laws and standards. (Decree on Dose Limits, Radioactive Contamination and Intervention Levels (Official Gazette No. 49/04))

29. Hungary Article15.2, p.51

Why does not exist any limit for H-3 and C-14 gaseous effluent in Table 2 ?

All gaseous effluents are limited by the general gaseous effluents release limit, which is set to 50 microSieverts. Some of the limits for individual isotopes were retained, because these values are directly measurable. Those individual isotopes limits were set in the licensing process at the start-up and were retained for historical reasons (and to be able to identify individual trends) after the general limit for gaseous effluents was adopted (which is in terms of effective dose and not in Bq (activity) as the other limits). The US legislation, upon which the re-licensing process was based, does not prescribe individual limits for C-14 and H-3 in gaseous effluents.


"Dose constraint for internal dose is set to 0.2 mSv per year." Is this constraint only used for Krško Plant workers? Is there any internal dose constraint for other type of jobs, e.g. nuclear medicine?

Dose constraint 0,2 mSv per year for internal exposure apply only for the Krško NPP. In general, dose constraints are set for each individual radiation practice. They are set by a person carrying out a radiation practice in cooperation with an independent approved radiation protection expert and confirmed by a regulatory authority in the licencing procedure.


"The exposure data for plant workers include also neutron doses and internal exposures derived from the whole body counter measurements." Are there any nuclide specific measurements used in order to measure the possible radionuclide without measurable gamma-lines?

In the case of internal contamination with tritium the effective dose can be assessed based on the measurement of the H-3 in the urine and on the evaluation of the concentration of tritium in air. Internal exposure due to contamination with alpha emitters can be assessed on the basis of measurements of internal contamination with Co-60 (Co-58), and activity relationships between cobalt and relevant alpha emitter .


"The annual limit for equivalent dose for eye lenses has already been set by the Krško NPP to 20 mSv." How is the dose of eye lenses measured?

The dose to the lens is measured using OSLN dosimeters with open window.


"Regulatory approved dose constraint of effective dose is set to 15 mSv per year for Krško Plant workers of category A." What is the dose limit for other workers in other workplaces e.g. in hospitals or in central

Dose limit is 20 mSv per year for all occupational exposed workers. Dose constraints are set for each individual radiation practice. They are set by a person carrying out a radiation practice in cooperation with an independent approved radiation protection expert and confirmed by a regulatory authority in the licencing procedure.

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radioactive waste storage facility? Is it the same value for category "A" and "B" ?

34. Montenegro 16.2 In subchapter 16.2: Implementation of Emergency Preparedness Measures is emphasized that the SNSA carried out a revision of its emergency preparedness taking into account the latest international developments and lessons learned from the exercises. It is very well known that SNSA has a long tradition in organizing systematic training and exercising for emergency response. This Slovenian experiences and clarifications regarding lessons learned during exercising for emergency preparedness, could be useful for the eventual further revision of the Montenegrin National Action Plan for responding in emergency situations. Q.: Could Slovenia describe more how emergency preparedness is improved/revised based on lessons learned from exercises?

At the SNSA we appreciate acknowledgement of our extensive EPR training programme. However, it is not possible to provide comprehensive answer to your question. The list of lessons from exercises is rather long. But the process is relatively simple. An exercise is analyzed, a report is prepared, where facts are described and compared against criteria for performance and then actions are proposed in an action plan. This is then approved and put in development and implementation.

35. Netherlands Article 8.1,

appendix II, A, ii

Has SNSA defined annual retraining requirements of staff? What is the percentage of working time devoted to training and education?

Part of systematic approach to training system (SAT) is also management of training for the acquisition and maintenance of competencies. Employees during the annual interviews with their superiors propose the changes. In particular, they pay attention to the difference (delta) between the required level of individual competencies and the actual level of competence of the relevant employee. This is the basis for entering the corrections in the database of SAT-SNSA and for the preparation of a training plan. SNSA prepares annual training plan with all training activities. Annual retraining requirements of staff are not numerically defined, but are based on the agreement between employee and his head as it is described above.

36. Netherlands Article 8.1,

appendix II, A, ii

The report is unclear about the status of the R&D programme; what is the result of the new orientation by SNSA?

R&D in Slovenia are in general funded through from the state budget through the research projects with the scientific excellence being the main criteria for selection. In addition, research and engineering institutions are occasionally engaged in R&D projects directly funded by the nuclear industry. Based on the analysis SNSA has made in 2016 about 70 people are financed in Slovenia outside the NPP for different research, development of engineering

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services needed in nuclear fission area. For nuclear fusion projects there is some more financing available.

37. Netherlands Article 14

Life time extension: can Slovenia confirm that the LTE is based on the US LTO approach? Does Slovenia consider an IAEA Salto mission to the Krsko plant?

In 2017 our LTO approach will be reviewed within IAEA LTO module as part of the OSART mission. The possibility for inviting IAEA SALTO mission will be considered near the end of the projected lifetime period in 2023.


How does the regulatory body assess the sufficiency of human and financial resources at the nuclear installations?

There is no formal method of assessment. The SNSA do this through NPP reporting, licensing process, regular meetings, inspection control, etc. The assessment is done indirectly by monitoring potential problems with payments of services to subcontractors or purchasing of new equipment. So far there were no such problems encountered.


WENRA RL: can Slovenia explain how the WENRA RL2014 are distributed between the amended Act and Rule JV?

Almost all WENRA RL are in Rules JV4, JV5 and JV9. Only one WENRA RL is in the Act on Radiation Protection and Nuclear Safety.

40. Netherlands Article 9 Strengthening of the application of Defense in Depth was an important lesson of Fukushima, also in the regulatory context of supervision. Has Germany considered this? What, in the opinion of Slovenia could or should be changed/added to the supervision programmes of regulatory authorities to increase the confidence in the application of DiD at the NPP's? [vraag aan alle landen?]

We cannot say what the Germans have or are doing. As far as Slovenia's opinion it is that the regulator must be aware of all the levels of DiD and must have in place processes for supervising them.

41. Netherlands Article 8.1

Please give some detailed numbers of the 42 employees distributed between the departments of SNSA. What is the annual size in full time equivalent (FTE) of the support by TSOs? The report mentions, since many years SNSA was not able to recruit. How much does SNSA rely on very experienced people and how is this knowledge and know-how going to be preserved and transferred to the younger people? Is there a long-tern HR-plan that covers this?

Distribution of employees within different organizational units of the SNSA (as of December 1, 2016):

• Nuclear Safety Division (12 permanent positions): - Analysis and Operational Feedback (6) - Licensing and Modification (5 + 1 outsourced part time employee) - Head of the division (1)

• Radiation Safety and Materials Division (10 permanent positions): - Licensing and Records (6 + 1 outsourced part time employee) - Monitoring (3) - Head of the division (1)

• Radiation and Nuclear Safety Inspection: (5)

• Emergency Preparedness Division: (4+ 1 outsourced part time employee)

• International Affairs Office: (4)

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• General Affairs Office: (4)

• Quality Manager (1) SNSA does not rely on direct support by TSO to its daily work. TSOs act as independent reviewers of applications submitted to licensees. Their involvements therefore depend on number and complexity of applications. SNSA average employee is 47 years old. The SNSA does not have a formal HR plan, but through years we established so called SAT – Systematic Approach to Training - which once fully operational, will address exactly this question on preservation of knowledge. As regards knowledge transfer to younger people, the situation improved in 2016 when we replaced three people and employed two new ones, who are all significantly below average SNSA employee age.

42. Netherlands Article 7 More and more countries combine the authorities in a single entity for safety and security. Have there been efforts to do that in Slovenia?

It may be that terminology is somewhat confusing, but within the SNSA the nuclear safety and nuclear security are covered both in certain extent: only physical protection is dealt with the Ministry of Interior (MoI) and only fraction of this area is covered by the SNSA. For the time being there are no efforts to transfer the competencies in PP area from the MoI to the SNSA.

43. Netherlands Article 7 What is the type of content in chapter f of the Resolution 2013-2023?

The unofficial English translation of the Resolution is published on our webpage where you can read about the content of chapter 8: OBJECTIVES AND ACTIONS FOR THEIR ACHIEVEMENT UNTIL 2023. URL: http://www.ursjv.gov.si/fileadmin/ujv.gov.si/pageuploads/si/Zakonodaja/SlovenskiPredpisi/PodzakonskiAkti/ang_prevodi/RESOLUTION_-_unofficial_translation_za_splet.pdf

44. Netherlands General What do you consider the main findings and resulting actions, from your evaluation of the IAEA Fukushima report?

We didn't do any special evaluation of that report. As far as we are concerned, the post-Fukushima improvements were done in a systematic way with the implementation of stress tests and the preparation and implementation of the National action plans, in which we have included also reports from other organizations and not just the ENSREG recommendations and recommendations from the 2nd extraordinary CSN meeting (e.g. IAEA Action Plan, NRC's Near-Term Task Force Review, and ASME Report).

45. Netherlands General, PSR2

The report contains 397 recommendations, 152 of them will be re-evaluated in the context of the third periodic safety review. This looks like a 10 year delay of implementation. Could you please explain this?

There are 152 issues remaining, which are not part of Implementation Action Plan, but this only means that their implementation will not be followed. Many of them will be solved anyway before the 3rd PSR. They are considered not to have a potential to degrade plant’s status, either as single issues or through combinations of issues. It shall be noted that also some issues remaining from the PSR1 were included directly in the PSR2 re-evaluation, assessment and re-ranking and the conclusion about plant status is not affected by them. Therefore, these 152 remaining issues would not change the conclusions regarding the plant safety status

13

46. Netherlands General The report mentions the resolution on nuclear safety and radiation protection 2013-2023. What does it specifically contain?

We would suggest to look at the document itself. The unofficial English translation of the Resolution is published on our webpage where you can learn all about the content of the Resolution. Link to the resolution is: http://www.ursjv.gov.si/fileadmin/ujv.gov.si/pageuploads/si/Zakonodaja/SlovenskiPredpisi/PodzakonskiAkti/ang_prevodi/RESOLUTION_-_unofficial_translation_za_splet.pdf

47. Russian Federation

Article 8.1

The Report mentions that there are two regulatory authorities in Slovenia: SNSA – in the area of nuclear and radiation safety (its structure includes Division of Emergency Preparedness) and SRPA – accountable for radiation protection and use of radiation sources in health and veterinary care. According to the Report, these two regulatory bodies are established within different ministries. Could you please tell how the interaction of the above bodies takes place, in particular, in case of emergency at a NPP?

Both regulatory bodies (SNSA within the Ministry of Environment and Spatial Planning and SRPA within the Ministry of Health) share the same Act (on Ionising Radiation Protection and Nuclear Safety) and implementing secondary legislation; furthermore, they share the electronic databases (registers of radiation sources and radiation activities/facilities; central records of personal doses; …) and from time to time conduct the joint inspection with radiation sources users. The SRPA personnel is taking place in the group of emergency management, which is formed within the SNSA in the event of an emergency.


Introduction,

Article 19.8

Is the capacity of the at-reactor spent fuel pool sufficient for full or partial core unloading in case of unexpected emergencies and under the current occupancy of the spent fuel pool to ensure criticality safety?

Yes, this is the case.


Introduction, p.3

It is stated in page 3 of the Report that erection and commissioning of dry spent fuel storage facility will be completed by the year 2020 and the capacity of at-reactor spent fuel pool will be fill out in 2019. Where the spent nuclear fuel will be taken after the year 2019?

The construction of dry storage of spent nuclear fuel envisaged between 2018 and 2019. The envisaged commencement of transfers of spent nuclear fuel from the spent fuel pool into dry storage is expected in 2020. It has to be mentioned that it is expected that existing spent fuel will be filled out during the outage in 2019 in autumn, the room for full core unload is always available in the spent fuel pool. In 2020 the outage is not planned. The next spent fuel unload from the core is expected in spring 2021. At the moment a delay in the operation of the spent fuel dry storage is not expected. In case of any project delays, the Krško NPP will prepare additional analyses of current spent fuel pool operation and management restrictions and propose some options for spent fuel storage for intermediate time. As the existent SFP will be in operation all the time during the plant operation and minimum 5 years after the plant shut down, the Krško NPP can temporarily store fuel assemblies from the reactor for at least 5 years in the SFP and later on transfer

14

them into dry storage building in several campaigns. 4 campaigns of transfers of casks with spent nuclear fuel are envisaged.


Introduction, p.4

Page 4 in Slovenian Report talks about "unstable research funding for areas related to nuclear technology…". Wouldn't this instability affect fulfilment by Slovenia of the provisions of the Convention Article 11, according to which "each Contracting Party shall take the appropriate steps to ensure that adequate financial resources are available to support the safety of each nuclear installation throughout its life"?

We believe that the referenced part on “unstable research funding for areas related to nuclear technology…" has been taken out from the context of whole paragraph of our Report which relates primarily to the unattractiveness of nuclear technology and safety for the new young graduates with technical background, who would decide to pursue their careers in the nuclear area. This problem is somewhat acute in recruiting young professionals to the regulatory bodies and authorized organizations, but not in human resources for nuclear facilities. As reported under the Article 11 of our Report “….For the time being, the Krško NPP operator has allotted enough financial resources for maintaining the appropriate level of nuclear safety.”

51. Slovakia Article 17.1, p.

58

Safety Analysis Report is required for the approval of the construction of a facility. An investor, who intends to construct the nuclear facility, needs to submit a Safety Analysis Report together with the application for the approval. Please explain if the interested public has access to involved in SAR in full scope or the sensitive information are excluded from this SAR? If the exclusion is made who is responsible for the process of exclusion and in which legal instrument this procedure is described? Has the public at large access to the SAR (full scope) according to the Aarhus Convention?

In case that the interested public wanted access to the SAR, full scope access is already restricted by the provisions of the Ionising Radiation Protection and Nuclear Safety Act itself, which provides (Article 72) that the investor must accompanied the safety report (referred to in the preceding Article) by a Plan of physical protection as a separate classified document in accordance with the rules of confidentiality. Other reasons that allow the individual parts of the SAR not to be revealed to the public are following those as they are provided by the Aarhus Convention in its Article 4.


55

"In line with the Council Directive 89/618 EURATOM on informing the general public about the health protection measures, the Krško NPP prepared an information brochure entitled “How to Act in a Nuclear Emergency” for people living within the area of planned urgent protective actions."

The valid national plan defines four zones: 3 km, 10 km, 25 km and the whole state. People living in the 10 km zone receive the information brochure. This is for informing them. For notification purposes there is an alarm system in whole territory of Slovenia. Instructions are given over the national media, thus reaching the whole population if needed.

15

How big is the area of planned urgent protective actions? By which means citizens are informed beyond this area?


55

"After adopting new regulation in 2010, the potassium iodide tablets were pre-distributed in 10 km radius around the Krško NPP in 2013 and regional stock piles established around the country." What are the procedures/rules for distribution of iodine tablets from regional stockpiles and who is in charge of administering the distribution? Who is financing the stockpiles?

The Civil Protection is in charge, but detailed procedures have not been developed yet. There are problems with financing the distribution from the stockpiles during an emergency. The problem is rather complex. The regional stockpiles are part of national reserves and therefore financed by the government.


55

"The SNSA maintains and develops MKSID, which is a dedicated web based communication system during radiation emergencies for information and document exchange. There are 29 national organizations connected by the system." Is this platform and the corresponding communication lines designed to resist natural disasters?

Yes, to some extent The communication system of the state administration is used, which has the highest priority of rerouting in case of loss of some connection lines. However, it would be quite difficult to assure similar resistance of all connections against natural disaster as such resistance is foreseen for nuclear power plant itself. We are regularly exercising the work of emergency teams also without the MKSID thereby simulating such natural disasters.


55

"The SNSA carried out a smaller scale revision of its emergency preparedness and its emergency team in 2015, taking into account the latest international developments and lessons learned from the exercises." Please provide outcomes of this revision? What specific changes were adopted?

We introduced deputy team director. We introduced emergency cycle of one hour for managing the team - a meeting of subgroups leaders and draft reports to be repeated in one hour. Then we cut the number of staff in the two subgroups, relocating staff to other critical positions.


55

Slovakia commends Republic of Slovenia for its extensive systematic efforts with regard to training and exercises. a) Please elaborate in some detail on what exactly comprises a national exercise as mentioned in the report? b) Regarding the recent INEX 5 exercise, what are the main

National exercise means that the exercise is conducted on a national level and managed by the civil protection and that it includes all the levels of response, from national, regional and down to local and the operator. The main observation for the INEX 5 is that internationally, especially regionally, there is not enough collaboration and information sharing and that because of this, response is not consistent.

16

outcomes/observations/lessons learned from Slovenia’s point of view?


55

"Emergency plans are public documents and should be presented to the public within 90 days after their adoption." How are these documents published in order the public can get acquainted with them?

Mostly on-line. Sometimes a public presentation of a certain EPR arrangements may be organized, but participation of public is usually low.


54

"The prompt notification of the authorities of an event, without an undue delay, is stipulated and the public needs to be informed about important facts in the emergency plans." What are the forms and channels used to inform public without undue delay? What is the understanding of “undue delay”?

For notification purposes there is an alarm system in whole territory of Slovenia. Instructions are given over the national media, thus reaching the whole population if needed. Undue delay means that information should be issued to the public promptly, i.e. immediately, unless there is a good reason to wait.

59. Slovakia General, Appendix I, p. 74

In part A. 3 of Appendix I is listed - Act on Third Party Liability for Nuclear Damage (Off. Gaz. SFRY, 22/1978 and 34/1979); - Act on Liability for Nuclear Damage (Off. Gaz. RS, 77/2010), The Act from 2010 amends the former Act from 1978 or it replaced former Act or both Acts are still in force?

It is rather complicated to explain in short the status of both acts; very shortly the answer would be that 2010 Act replaces the one from 1978, except its Article 20 (prescription periods), which is still applicable until the whole 2010 Act will become applicable. Namely, some provisions of 2010 Act shall apply within 6 months after last (2004) Protocol to amend Paris Convention and Protocol to amend Brussels Supplementary Convention enter into force.

60. Slovakia Article 7.1, p. 14 - 16

+ Appendi

x I, p. 73-74

In this chapter and appendix I of national report set of legal instruments described. Please explain if all pieces of legislation went through European comments procedure according to Articles 30 – 33 Euratom Treaty and also according to EU Directive 1535/2015 (previous EU Directive 98/34 and 98/48).

Not until now; new drafts of our legislation, needed for transposition of the “new” BSS, will be sent to the EC in accordance with Art. 33 of Euratom Treaty. No regulation specified in the Appendix 1 of our Report was ever sent to the EC in accordance with the EU Directive 1535/2015.

61. Sweden Article17.1,

Page 58, 17.1 Evaluati

Does the Slovenian legislation allow for restricting man-made activities in the area of a nuclear facility such not allowing new industries being established, not allowing additional urbanisation (premises), etc. in

Yes. For that we have a special Governmental decree, the UV3, "Decree on the areas of limited use of space due to a nuclear facility and the conditions of facility construction in these areas".

17

on of Site

related

order to reduce external threats but also to simplify potentiual future EPR activities?

You can find the unofficial English translation of UV3 here: http://www.ursjv.gov.si/fileadmin/ujv.gov.si/pageuploads/si/Zakonodaja/SlovenskiPredpisi/PodzakonskiAkti/ang_prevodi/UV3.pdf


Page 55-56, Last

para on page 55

into fi

Who is responsible for coordination of the on-site emergency plan and the municipal and national plans? When is this work done - continuosly or at specific intervals? What new elements are expected in the new National Nuclear or Radiological Plan? Who is performing the drafting and stakeholder process in preparing the new national plan? Are the local and municipal emergency preparedness and response staff involved in this drafting work?

The Civil Protection Administration is responsible for coordination. The work is done continuously, but when there is a new revision of a national plan, then there is a special emphasis given to harmonization. We want to introduce the reflex evacuation in case of a general emergency at the NPP. Then to improve on protective actions, e.g. to extend precautionary evacuation from the current 3 km to the 10 km zone. The SNSA and the Civil Protection Administration are drafting the national plan. When it reaches appropriate level of expected quality, it is then submitted to other participating organization for comments. Yes, this includes local and municipal levels.

63. Sweden Article 15,

Page 51,

Table 2

Are the large variation in released iodine and other gaseous activity during 2013-2015 due to the fuel damages (rod fretting) or is the cause something else?

Yes, fuel damage was the main reason for these variations. The annual variances are also caused by the operating cycle, which is 18-month cycle, which means that every third year there is no outage and less releases. Even without additional variance due to fuel damage, releases in such years (in this case 2014) are lower.

64. Sweden Article15, Page 49, 15.1

Dose Limits and

Control of

It is stated that individual exposures are measured by OSL dosimeters and electronic alarm dosimeters. Furthermore, the exposure data for plant workers include also doses from neutron exposure and from internal exposure. How are the individual neutron doses measured? How are dosimeters calibrated, does SRPA maintain national secondary standards traceable to primary standards or are foreign laboratories used for calibration?

Gamma, beta and neutron dose is calculated using OSLN dosimeters. Detector film covered with Li-6 is used for neutron detection. Calibration or test for neutron dosimeters is carried out once a year in the NPP at the reference point adjacent the opening in the containment. The reference point was set by IRSN (Institut de Radioprotection et de Surete Nucléaire).


Page 43, 14.1 Comprehensive

and System

at

It is stated that "the 2009 Rules of Radiation and Nuclear Safety Factors (JV5), revised in 2016 and to be published in autumn (of 2016), prescribes that the safety analysis report must provide information on the facility at a level of detail allowing independent assessment of the facility. It also gives an exhaustive list of topics which have to be included...". How was independent review

The safety analysis report (SAR) is the basic document for safety assessment of nuclear facility. All information from SAR, including references, is essential for independent review of current facility configuration against to its design bases. The independent expert safety assessment is obligatory for all safety important modifications as explain in Chapter 14.1 on page 44. The similar requirements for the SAR content and licensing of safety important modifications were set also before 2009 Rules of Radiation and nuclear safety. In the new Rules from 2016 all WENRA requirements from 2014 are included.

18

performed earlier? Is it not always needed to go into also the references of the SAR and more detailed material in order to do an independent assessment? Please explain the meaning of this.


Page 42, 13.4

The SNSA Review

and Contro

The SNSA approved the NPP Krško 2nd PSR (PSR 2). The review identified 3 unresolved or partially unresolved issues from PSR 1 and 4 new issues - are we here taking about issues referring to Quality Assurance and management issues? The unresolved issues were "mostly related to review and hierarchy of plant documents, scope of internal audits and the performance and responsibility of committees". On page 44 (Article 14) it is stated that the first periodic Safety Review action plan was completed in 2015. How come there were still open issues from PSR 1 (albeit of low safety significance) not being resolved before the PSR 2 was performed?

Yes, these are issues from safety factor Quality Assurance and Management. However, methodological approach used in PSR is defined in each PSR program. PSR findings are prioritized according to their impact on safety. Significant issues are included in the action plan and should be implemented in 5 years. Non-significant issues are not included in action plan but are included directly in the next PSR re-evaluation like the mentioned issues from PSR1 which were not part of the PSR1 action plan. On page 85 of the CNS report (Appendices, B. Planned Measures to Improve Safety) it is clearly stated that PSR2 identified 397 findings of which 20 have already been completed, 225 of them were included in action plan and 152 of them will be re-evaluated in the context of the third periodic safety review.

67. Sweden Article 11.1,

Page 32 11.1

Financial

resources

It is stated that for the time being, the Krško NPP operator has alloted enough financial resources for maintaing the appropriate level of nuclear safety. Is this the view of SNSA or the view of the operator? If the latter, on what basis is this statement made? The suitability of ensuring financial resources, the amount thereof and the forms of warranties, etc. are assessed by SNSA during the procedure for issuing of the operationm licence for a radiation or nuclear facility. In case of the Krško NPP, is such an evaluation by SNSA performed again or at some interval during the operational period?

It is a view of the SNSA (and not disputed by NPP Krško) that the operator has allotted enough financial resources for maintaining the appropriate level of nuclear safety. For such an assessment the SNSA did not prepare any specific analysis, which would be based on qualitative and quantitative indicators. Such assessment is based primarily on “soft” indicators, such as the fact that the Krško NPP “Safety Upgrade Program” implementation, requested by the SNSA with its decision in the context of "post-Fukushima" actions, is progressing according to schedule and/or that on the Krško NPP initiative each year several major modifications are licensed and later on performed. Furthermore, the operator has no difficulties to allocate the prescribed amount of money to the Decommissioning Fund and meets all other (including financial) obligations imposed on him by legislation. Among them also insurance arrangements necessary for the coverage of third party liability.


Page 30, 10.4

The IRRS-mission check-up in 2014 left one recommendation open, referring to the construction of a repository for low- and internmediate level radioactive waste, which

The investment programme for the construction of LILW repository at location Vrbina was signed in summer 2014. The field research was carried out and the documentation for obtaining a construction license, Environmental Impact Assessment Report and Draft of Safety Report were prepared by the investor

19

Priority to

Safety Provisi

had not progressed as planned (no visible progress since 2011). Referring to this, and the lack of space at the exisiting storage facility at the power plant in Krško, has there been any progress on this issue since 2014? If so, what has been done and what are the schedule for this work?

(Agency for Radioactive Waste Management) and have been under revision. Formal licensing is expected in 2017, while the construction is envisaged to be carried out between 2017 and 2019. The start of the LILW repository operation is planned for 2020.


Page 30, 10.3 Regulat

ory Oversight of Li

Since 2007 the SNSA has initiated a new regulatory approach in supervising the activities at the Krško NPP by a set of 46 indicators that are collected through weekly, monthly, quarterly or annual reports from the Krško NPP. The purpose is to identify potential weaknesses that might lead to a degradation of safety. Was this system introduced as a complement to the existing regulatory regime or did it replace older regulatory/inspection practices? Is there any analysis of the impact and effectiveness of this system?

Actually the SNSA monitors a set of 38 safety and performance indicators (SPI) and not the set of 46 SPI (mistake in chapter 10.3). The system was introduced as an addition to the existing regulatory practices and did not replace any of them. The set of 38 safety indicators are being updated monthly, three monthly, yearly or every fuel cycle. So far there were no bad experiences with it. The best example of its benefit was in the summer of 2013, when the escalating problems of leaking fuel were first time detected from these indicators. SNSA has never had a need to make any formal and documented analysis of the system, as there were never problems encountered with this system.


Page 28,

Priority to

Safety

In 2013 the Krško NPP conducted self-assessment of safety culture. Positive changes were visible (e.g. in the areas of knowledge transfer, horizontal communication) and the organizational units developed plans to improve safety culture. Overall impression from self-assessment was that NEK has an excellent safety culture. In 2014 the 2nd PSR at Krško NPP, including also review of safety culture, was completed. The PSR concluded that Krško NPP has a decent safety culture with a deep understanding of nuclear safety concept of the plant as well as a willingness to continuosly improve and develop competences and understanding of hazards. Areas of improvements were identified. It might be a language issue but the conclusions from 2013 and 2014 change

The conclusions »excellent« and »decent« were both determined by the NPP staff. However, we can see from the SNSA inspections, safety culture indicators and PSR report, that the NPP is really making continuous progress in its safety culture. Anyway, this does not mean that there is not a chance for improving it, so there is an action plan in progress following the self-assessment of the safety culture. After the PSR report on safety culture was delivered, the SNSA insisted that all of the safety culture findings shall be implemented. The PSR action plan includes these safety culture actions and SNSA follows the implementation of these actions. The SNSA also follows the condition of the NPP safety culture by topical inspections, that are described in Chapters 10.2 and 12.2 of the National report.

20

from excellent safety culture to decent safety culture? What is the view of SNSA about this difference - was it real or just an issue of wording? Did SNSA follow up on the PSR action plan for improvements after implementation?


Page 22, 8.1 Regulat

ory Body

It is stated that the governmental policy of not increasing the number of civil servants in administration led to that SNSA substantially improved its management system and increased its effectiveness. Which areas were SNSA less effective in and where were staff reductions made?

First of all, it should be mentioned that in the field of employment the governmental policy has become slightly relaxed now, which is also evident from the answer to the question below. In the past, because of rigorous recruitment policy, the SNSA suffered a lack of personnel in the both main “technical” divisions, i.e. Nuclear Safety and Radiation Safety and Materials as well as in “Emergency Preparedness Division, while other organizational units were more stable. Instead of listing “less effective areas” of the SNSA’s work let us explain that we’ve strengthened our management system in the way to strictly follow the internal SNSA’s procedures and guidelines, in some areas of our work we’ve improved equipment and technical capabilities; furthermore, we’ve also improved the flow of information and ensure that the synergistic effects of increased employee involvement are better.


Page 21-22,

8.1 SNSA

At the end of 2015, 42 persons were employed at SNSA. Could you inform us how these 42 persons are distributed according to the organisational layout in Figure 1? Are the administrative staff (IT, education, personnel, managament system, economy ) etc. found at the General Affairs Office? How much staff would then be available for each "organisational box", 3-4 persons? On page 22 it is stated that an additional number of 20 persons would be needed if a second nuclear power unit would be constructed. Which areas would these persons be needed in (inspection, licensing, monitoring)? How many persons are involved in work with future radíoactive waste repositories and the national requirements needed for such activities?

Distribution of employees within different organizational units of the SNSA (as per December 1, 2016):

• Nuclear Safety Division (12 permanent positions): - Analysis and Operational Feedback (6) - Licensing and Modification (5 + 1 outsourced part time employee) - Head of the division (1)

• Radiation Safety and Materials Division (10 permanent positions): - Licensing and Records (6 + 1 outsourced part time employee) - Monitoring (3) - Head of the division (1)

• Radiation and Nuclear Safety Inspection: (5)

• Emergency Preparedness Division: (4+ 1 outsourced part time employee)

• International Affairs Office: (4)

• General Affairs Office: (4)

• Quality Manager (1)

As it can be seen from the above distribution the General Affairs Office employs only 4 persons (two lawyers and two administrative staff – mostly for work in main

21

office, mailroom and archives); according to principles of legislation which regulate the governmental organization, some functions (as for example IT, HR and finance) are centralised within the respective Ministry (i.e. Ministry of Environment and Spatial Planning) for all the organizational entities of such size (less than 50 employees). If a second nuclear power unit were to be constructed, the main areas in which additional personnel would be needed are assessment and licensing as well as inspection. The exact number of employees involved in work with future radioactive waste repositories and the preparation of the appropriate national requirements is hard to indicate; what we can report is the total number of hours of all SNSA’s employees spent in 2015 for this tasks, i.e. 450 hours.


Page 17, 7.1

Description of

Legislative

The division of the responsibilities between SNSA and SRPA is not really fully consistent between page 17, 7.2: "The responsibility for supervision of nuclear safety in nuclear facilities and radiation practice outside the medicine and veterinary activities lies with SNSA, while the responisbility for the supervision of radiation practices in medicine and veterinary activities lies with SRPA..." and on page 20: (Art.8 Regultory Body): "The SNSA is accountable for nuclear safety and safety of industrial sources while SRPA is accountable for RP of patients, medical surveillance of exposed workers, radiological surveillance of workplaces, dosimetry and dose registers and education in the area of RP". Could you please clarify the situation, does SRPA has a responibility of more than medical exposure and veterinary activities? Who is responsible for dosimetry services, calibration of instruments and dosemeters, national dose registers, education etc in the RP area?

It well may be that both descriptions in our Report you are referring to are inconsistent and confusing. The division of competencies and responsibilities are primarily designated in the governmental Decree on bodies affiliated to ministries – in general terms; in more detailed way it is defined in the Ionising Radiation Protection and Nuclear Safety Act and implementing secondary legislation (governmental decrees and ministerial rules). To make it short: Radiation protection, in general, is within the responsibilities of SRPA, thus all areas mentioned in your question " authorization of dosimetry services, oversight of calibration of instruments and dosimeters, keeping of national dose register of occupational workers, RP education programs" are within the responsibility of SRPA. and the SRPA for all mentioned when relates to practice within the medicine and veterinary activities.


Page

With dues respect, "the preparedness principle" is not something which is very frequently used internationally?! Is this

You are right when asserting that the “preparedness principle” is not something which is very frequently used internationally. On the other hand, we believe that this fact does not constitute an obstacle for introducing in national legislation a new

22

16, 7.1 Descript

ion of Legislati

ve

alluding to emergency preparednees or does it have another meaning? Is it the "precautionary principle" which is referred to?

principle, which is (at the same time) not inconsistent with other internationally recognized principles. The wording of this principle reads (in unofficial English translation): “The operator of a radiation facility and the operator of a nuclear facility must be ready to implement intervention measures in case of emergencies (the preparedness principle).”

75. Sweden Article 6, Page 13, 6.3 Events in the Krško NPP

One of the reported events was damaged fuel assemblies and "one part of fuel rod in the fuel transfer channel". Could you give more information about this event. Was there any notice during operation of possible damaged fuel? Is the composition of noble gases and iodine continuosly monitored in the off-gas system? what were the experience and conclusions from this event regarding future activities - what is done to improve the situation?

More information on the event with discovery of damaged fuel assemblies in 2013 is available in INES report http://www.ursjv.gov.si/fileadmin/ujv.gov.si/pageuploads/si/INES/Slovenia_8oct13.pdf and in report IRS 8376. Since IRS reports are restricted, you shall contact your National IRS officer to get access to this report. Activity of primary coolant is sampled and measured daily and then weekly values are reported to the SNSA. Fission product gases are stored in Gas Decay Tanks to decrease their activity prior to release to the atmosphere, with monitoring of the released activity. To improve the situation with fuel integrity, the up-flow conversion modification was performed in 2015 and there was no fuel damage in next fuel cycle (completed in October 2016). More on this modification is written in National report, Appendix B Planned Measures to Improve Safety, iii. Reactor Vessel Up-Flow Conversion, p. 90. During outage 2016 a modified type of fuel assemblies was used in the core, with changes of mixing grids and bottom nozzle to improve robustness against vibrations and debris in the primary coolant system.

76. Sweden Article 6, Page 12 6.1 Stress Tests and

Post-Fukush

At the beginning of 2014 SNSA reviewed all reports on the PSR2 prepared by the (licensee/operator of ) Krško NPP in the period of 2010 to 2013. The final PSR2 report concludes that there are no major findings, the plant is safe, as it was planned, and it can continue safe operation. In May 2014, SNSA approved the PSR2 and the associated implementation plan. What were the conclusions of SNSA? Is the Krško NPP "safe enough", improvements are not needed or improvements are conditional for to continued safe operation?

The SNSA concluded that cumulative effect of issues should not prevent NEK to operate safety until the next PSR3, however implementation of additional, selected issues would even further improve the overall safety of the plant. Implementation of improvements is a condition for continued safe operation. Those improvements are specified in the SNSA approval decision and shall be implemented by the 30.05.2019 in accordance with the action plan.

77. Sweden General, Page 5,

It is estimated that, conservatively, in 2015 the effective dose received by members of

No, the direct irradiation even at the NPP fence cannot be determined because it is small compared to the natural background, but the TLDs are placed at the NPP

23

last section/paragraph on the pa

the public as a result of Krško NPP emissions amounts to a value of less than 0.3 mikrosievert per year. Is there any pathway in the calculations of dose to members of the public which consists of direct radiation (elevated level of bkg radiation) during operation of the power plant? How close are members of the public (i.e. persons not classified as ocuppatinally exposed) to the operating reactor?

fence to determine any increase of direct radiation. Thus, direct irradiation does not figure prominently in the dose calculations. The closest residential houses are roughly 1 km away from the reactor, with the closest village approximately 1,5 km away (Spodnji Stari Grad).

78. Sweden Article 12, p.36

How to understand independency of the Independent Safety Engineering Group, is this function within or outside of the operational organization of the licensee?

In the case of analysis of human errors independency of the Independent Safety Engineering Group is to be understood as a separate division within the operational organization which is performing tasks as, interviews, reviews, assessment etc. independently and separately from all other groups within the operational organization of the licensee.

79. Sweden Article 11.1, p.32

As Krsko Board / Supervisory Board decides on the price of a kWh, how is the Slovenian decommissioning fund fee in relation to the kWh price?

Payments into the Fund was until 2004 provided by the Krško NPP. From the year 2004 on, the “ELES GEN”, which was later renamed the “GEN energija” is obliged to make payments. “GEN energija” is an electricity power company, which is the legal successor of Slovenian investors in the Krško NPP. The financial assets of the Fund are collected through a levy for the kWhe delivered to the Slovenian grid since 1996. Due to a revision of the Decommissioning Programme in 2004, in 2005 the levy was increased to 0.30 euro cents per kWhe delivered to the Slovenian electricity power company GEN energija d.o.o. It is independent of the market price of the electricity.

80. Sweden Article 8.2, p.23

Does exist a synergy between the Krsko Fund for Decommissioning and SNSA and who is deciding the levy for every kWh of the Slovenian share of electric energy produced by the Krško NPP?

The Fund for Decommissioning is a legal entity established by the Government of Slovenia in 1994 by the Act. The levy for the Decommissioning Fund is determined by the Slovenian Government based on (updated) Decommissioning Programe based on (updated) costs of the Krško NPP decomissioning and radioactive waste management described in the Decommissioning Programe

81. Sweden Article 6, 13, 6.3

Events

One sentence per event is a little bit too short regarding events' description. Some of the events are described in detail in 19.6, would it be possible to receive a short description of

In chapter 6.3 of Slovenian CNS Report are written the following events, which occurred in the period 2013-2016: Partial loss of operability of the Passive Containment Filter Venting system: The event occurred because there was a wrong valve installed on one of the nitrogen feed lines (the other feed line was operable). Additional human errors were

24

in Krsko NPP

a safety impact of the other events especially operability of PCFV?

made at replacing the valve what led to a rupture disk in the control valve to burst open. However, this did not have any impact on the operability of the PCFVS which would (in case of high pressure inside containment) be able to vent the containment atmosphere through the iodine filter to the environment. Therefore, the nuclear safety of the plant was not affected. - Discovery of damaged fuel assemblies and one part of fuel rod in the fuel transfer channel (discussed in detail in chapter 2.1.1.3 in the annual report: http://www.ursjv.gov.si/fileadmin/ujv.gov.si/pageuploads/si/Porocila/LetnaPorocila/2013/Ang._LP_2013.pdf and in http://www.ursjv.gov.si/fileadmin/ujv.gov.si/pageuploads/Anglesko_LP_2015.pdf), - Reactor trip due to spurious actuation reactor protection signal Over Power Delta Temperature (discussed in detail in chapter 2.1.1.3 in the annual report: http://www.ursjv.gov.si/fileadmin/ujv.gov.si/pageuploads/si/Porocila/LetnaPorocila/2013/Ang._LP_2013.pdf), - Reactor coolant pump trip due to failure on 400 kV transmission line, - Activation of alarms in seismic monitoring system due to earthquake in the vicinity of the Krško NPP (discussed in detail in chapter 2.1.1.3 in the annual report: http://www.ursjv.gov.si/fileadmin/ujv.gov.si/pageuploads/Anglesko_LP_2015.pdf), - Reactor trip due to sudden main steam line valve closure in 2013 (discussed in detail in chapter 2.1.1.3 in the annual report: http://www.ursjv.gov.si/fileadmin/ujv.gov.si/pageuploads/si/Porocila/LetnaPorocila/2013/Ang._LP_2013.pdf).


Implementation

of ALARA

Is there a national system for establishing education, training and retraining of qualified experts in radiation protection? Is there a national system for certification of such qualified experts?

At the moment there are 20 certified qualified experts (in Slovenian legislation they are called "approved radiation protection experts –RPEs") in the country, in some work sectors only one or two. Training scheme at the national level is thus not feasible. Training certificates from abroad are taken into account in RPE recognition process. The system for approval of radiation protection experts is in place since 2007. RPEs are approved by Slovenian Radiation Protection Administration (SRPA) on case-by-case basis. Approval is a two steps process. Application is first reviewed by a special commission which checks formal education (at least university degree is required, i.e. EQF level 7) and work experience (after obtaining a university degree at least 7 years of work experience in the field of RP is required) and takes into account personal references of the applicant. Typical references taken into account are risk assessments, scientific articles, training certificates in the field radiation protection (e.g. from Oak Ridge, IAEA), project reports in field of radiation protection, prior engagement as an IAEA expert, etc. Commission draws up an opinion. Commission opinion is a base for SRPA to issue an approval. RPEs have to renew their approval every 5 years.

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Implementation

of ALARA

An "independent qualified expert" prepares an overall radiation survey and gives opinion twice a year regarding activities at RPU. Is it a question of qualified expert within radiation protection, and where in the organization is this expert placed? Has this qualified expert access to the higher management in order to promote matters of importance regarding decisions that have, or can have, impact on radiation protection?

IOS (Institute of Occupational Safety) provides independent external radiological examinations. The Institute is a qualified technical support organization in the field of radiation protection and measurements of radioactivity.


Implementation

of ALARA

It is mentioned, that RPU is separated from other organization units. Please, explain in which ways it is ensured that the responsibility for ALARA and radiation protection is taken by all affected units in the organization.

RPU is set up in such a way which ensures that its management and personnel are not under any internal or external commercial, financial and other pressure and influence that may adversely affect the quality of their work.

85. Sweden Article 15, 50, 15.1 Dose Limits

etc

Which work categories (such as mechanics, insulation etc) are the most exposed at Krsko NPP? Do you have dose statistics for such categories of workers?

The most exposed workers in the NPP are radiologists, employees in decontamination and waste processing, mechanical maintenance (reactor group, steam generators, snubbers, insulation workers), operators. For these groups dosimetric statistics are kept (collective dose, number of workers, highest dose, mean dose).

86. Sweden Article 15, 49, 15.1 Dose Limits

etc

Your Regulatory approved dose constraint, effective dose, is set to 15 mSv per year. Are there any ambitions to implement a lower dose constraint as a means of optimization? If not, why?

Operational constraints for the full body dose of NPP due to external radiation exposure is set to 10 mSv per year. For exceeding these limits approval of the Head of RPU and technical director is required.

87. Switzerland Vienna Declarat

ion

General question What issues have you faced or expect to face in applying the Vienna Declaration principles and objectives to your existing fleet or new build of Nuclear Power Plants?

None. The SNSA and also Slovenian industry follow best practice of western Europe and also United States, incorporating it in the legislation and practice (e.g. WENRA requirements). The implementation of Vienna Declaration is described on page 94 and 95 of the Slovenian report.


ion

Principle 3 How do your national requirements and regulations take into account the relevant IAEA Safety Standards throughout the life-time of a Nuclear Power Plant.

When the relevant IAEA Standards are issued, they are thoroughly reviewed if their requirements need to be transposed into domestic legislation.

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ion

2.3 Do your national requirements and regulations require reasonably practicable/achievable safety improvements to be implemented in a timely manner – if so, against what risk/engineering objective or limit are these judged and can you give practical examples?

Yes. Examples of requirements are as follows: - In JV9 article 44 is requirement regarding PSR: “Improvement measures shall be implemented by the licensee as a result of the review, in a timely manner.” No risk/engineering objective or limit are prescribed. -In JV5 article 60 is requirement regarding Safety policy of the licensee. Safety policy shall require continuous improvement of nuclear and radiological safety on the basis of: “Timely implementation of the reasonably practicable safety improvements identified” No risk/engineering objective or limit are prescribed. - In JV9 article 6 is requirement regarding operating experience: “The licensee shall ensure that timely and appropriate corrective actions are implemented to prevent recurrence and to counteract developments adverse to nuclear and radiological safety.” In this case we have criteria: “Corrective actions indicated by the analysis of events, such as technical modifications, administrative measures, personnel training or activities in the field of SSC maintenance, testing and inspection, shall be implemented in a timely manner and properly to decrease the probability of recurrence of the same or similar events and to improve radiation or nuclear safety of the facility. The operability of the SSC shall be confirmed by appropriate testing and inspection after completion of the corrective action. Provision must be made to verify the effectiveness of corrective measures.


ion

2.2 Do your national requirements and regulatory framework require the performance of periodic comprehensive and systematic safety assessments of existing NPPs – if so, against what criteria/benchmarks are these assessments completed and how do you ensure the findings of such assessments are implemented?

National requirements and regulatory framework regarding safety assessments are described in chapter 14 of Slovenian Report on Nuclear Safety. General criteria are determined in our regulations. In addition, more detailed criteria and benchmarks are taken from relevant IAEA documents and from the USA NRC regulatory documents (CFR, RG, NUREG, etc.) The important findings are typically collected in so-called action plans (one example is PSR action plan for improvements) which are approved by the SNSA. Licensee should report about status of implementation and the SNSA also inspects if actions are implemented.


ion

Principle 2 2.1 How do your national requirements and regulations address the application of the principles and safety objectives of the Vienna Declaration to existing NPPs?

The implementation of Vienna Declaration is described in page 94 and 95 of the Slovenian report. Comprehensive and systematic safety assessments are performed within a mandatory periodic safety review, which is described in B. Planned Measures to Improve Safety (i), as well as it is mentioned in other chapters, e.g. on Articles 6.2, 10.1, 12, 14, 17.3.

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With the transposition of amended Nuclear Safety Directive, which has got similar requirements as regards to existing NPPS as the Vienna Declaration, we met also the provisions of the latter.


ion

Mitigation 1.3 How do your national requirements and regulations incorporate appropriate technical criteria and standards to address the objective of mitigating against possible releases of radionuclides causing long-term offsite contamination and avoiding early radioactive releases or radioactive releases large enough to require long-term protective measures and actions. For example: can you describe the measures you have in place to protect against severe accidents and your accident management arrangements - how do you protect staff during accident management? Consider for instance inclusion of implementation of Regulatory requirements for: • Engineered systems to protect the containment; • engineered systems to cool the molten core; • severe accident management, protection of staff during the accident. • Provision and resilience of Emergency Mitigation Equipment (EME)

Slovenian national requirements are in-line with the newest WENRA SRL. The Krško NPP has already implemented most of the new requirements. For detailed information regarding the measures to protect against core damage, information about the protection of containment, and about implementation of SAMGs, see our national reports: "Slovenian national report on nuclear stress tests" and "Update of the Slovenian NAcP - December 2014" (http://www.ursjv.gov.si/fileadmin/ujv.gov.si/pageuploads/si/Novice/Slovenian_Stress_Test_Final_Report.pdf, http://www.ursjv.gov.si/fileadmin/ujv.gov.si/pageuploads/Info_sredisce/Tecaji_konference_seminarji/tecaji_MAAE/SLO_NAcP-2015.pdf ).


ion

Prevention 1.2 How does your national requirements and regulations incorporate appropriate technical criteria and standards to address the objective of preventing accidents in the commissioning and operation of new nuclear power plants? For example: can you describe the basic design objectives and the measures you have in place to ensure the robustness and

Slovenian national requirements are in-line with the newest WENRA SRL. The Krško NPP has already implemented most of the new requirements. The Krško NPP is still in the process of implementing its post-Fukushima Safety Upgrade Program (SUP). These will additionally enhance DiD, finish implementation of DEC measures, practically eliminate high pressure core melt scenario, and so forth.

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independence of defense in depth measures? Consider for instance inclusion of implementation of Regulatory requirements for: • Robustness of DiD and independency of the levels of DiD; • Design Extension Conditions (DEC); • practical elimination of high pressure core melt scenarios; • achieving a very low core melt frequency; • protecting digital safety equipment against Common Cause Failure (CCF). • External events analysis


ion

Principle 1 1.1 How do you define ‘a new nuclear power plant’? For example: do you consider a power plant to cease being a ‘new nuclear power plant’ once operation begins?

We do not have a definition for it, but the new plant would basically be the plant, which meets all legislative requirements for the new plants (without any exemptions).

95. USA Article 11,

Appendix II A ii pg. 83

The report states that SNSA will expand its research and development strategy. Will SNSA be challenged by limited resources?

Of course the available resources are one of the boundary conditions in determining research and development strategy and activities. As the governmental restrictions because of economic crisis are being lifted only in recent time, the expansion of R&D projects at SNSA is only limited.

96. USA Article 16,

Appendix II B iv pg. 91

The report states that coordination with Croatia in the area of emergency measures needs to be continued. How will this coordination be continued and enhanced?

By introducing regular meetings on operational level between the regulators. The objective is to get to know differences in understanding of the EPR arrangements in both countries in order to find common grounds. This will then form the basis to agree on operational coordination during an emergency.

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Appendix 1 Reference to question number 1

30

31

32

Appendix 2 Reference to question number 11

33

34

35

36

37

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Documents

7th Slovenian CNS Report, Answers to Questions of …...Slovenian legislation (Rules JV9) - Number of temporary modifications. All SNSA indicators have the same importance. 13. France