- 194 - "engineering consultancy" activities. The breakdown of contractor employees according to the disciplines subcontracted by EDF in 2010 was: Nuclear logistics: 18%, Mechanics Turning Machines: 18%, Automation Electricity: 16%, Non-destructive controls and testing: 7%, Boilermaking Piping: 7%, Heat insulation-Scaffolding: 7%, Civil Engineering: 7%, Welding: 5%, Valves: 5% Security Radiation Protection: 4%, Engineering Consultancy: 4%, Ventilation-Air conditioning: 1%, Audit Consultancy: 1%. In 2010, the contractor company expertise came for the most part within the field of maintenance operations. ASN considers that the information presented by EDF is incomplete. EDF does not specify whether the abovementioned figures concern only the NPPs in service, or also the head office departments (for example, does the 4% "Engineering Consultancy" cover the needs of the head office departments?) and does not define the categories of the professions presented (for example, what is covered by the "Nuclear Logistics" category?). These data should also be supplemented by an evaluation of the proportion of outside workers for each trade identified. This information would for example make it possible to find out whether, for example, the "Valves" activities are primarily carried out by contractor companies or not. ASN also considers that EDF's justification for the use of subcontracting for maintenance and other activities, in particular during reactor outage periods, fails to demonstrate that the various reactor outage periods which take place during the course of the year on each of the NPPs generate seasonal peaks justifying the use of subcontracting. Finally, resorting to subcontracting raises the question of maintaining skills and expertise within the licensee's organisation, in particular in the light of the possible extension of the operating lifetime of the existing nuclear facilities and the significant turnover of manpower. EDF's decision to outsource part of the activity carried out by the above-mentioned trades should not lead to a situation in which the licensee no longer has full control over the scheduling or quality of the maintenance work performed, which would be incompatible with its responsibility for the safety of its facility. EDF also mentions a "risk of loss of project ownership", identified in certain areas important for safety, such as "Valves" or "Piping-welding" operations, which explains its decision as announced in the CSA reports, to bring 200 valve specialists back in-house. EDF does not however specify the general measures taken to limit the risk of losing the skills necessary for the monitoring and oversight of the subcontracted activities. To conclude, ASN considers that EDF has not adequately demonstrated that the scope of the activities subcontracted, both in terms of the types of activities concerned and the internal skills preserved, is compatible with the licensee's prime responsibility for safety and radiation protection. ASN will thus be asking EDF to add to the information provided in the CSA reports, in order to clarify the link between subcontracting and the licensee's exercise of its responsibility. These elements will constitute inputs to the evaluations performed by IRSN and the Advisory Committee for nuclear reactors (GPR), at the request of ASN, on the topic of the subcontracting control.
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