- 195 - 7.2 Management of subcontracted activities 7.2.1 Contractor selection procedures The ASN specifications for the CSAs require a description of the contractor selection procedures: requirements concerning the qualification of the contractor companies (in particular the nuclear safety and radiation protection training of the operatives), formalisation of specifications and types of contracts, procedures for placing of contracts, steps taken to give the subcontracting companies and their employees medium-term visibility concerning their activities. In the CSA reports, EDF lays out a number of the conditions involved in the selection of contractor companies for awarding of contracts: Qualification of the contractor companies (only the first tier subcontractor), issued following an evaluation of the technical know-how (analysis of an "aptitude assessment file") and the organisation (company audit). The order of 10th August 198453 stipulates that the licensee must set up a qualification system for the staff and the technical resources taking part in the performance of an activity concerned by quality. Qualification of the contractor companies by EDF does not extend to the subcontractors of the contracting company, but does cover the evaluation of the contractor's arrangements for monitoring the subcontractors. Qualification is issued for a period of 3 years, but can be called into question at any time, in particular based on the analysis of the contractor evaluation forms (FEP, see § 7.2.3). The possible sanctions are a stricter monitoring, the suspension of qualification and withdrawal of qualification. In 2010, 80 site audits were carried out by the qualification organisation, 86% of the contractor companies were the subject of at least one FEP and 5,803 FEPs concerning on-site maintenance were issued for 499 qualified service contractor companies. The socio-economic capacity of the company selected, in particular its compliance with the socially responsible subcontracting agreement and the sustainable development progress Charter. The actual training for nuclear safety and radiation protection of the employees of the contractor companies (all tiers). EDF states that three to four training courses must be followed by any outside person who is to work in a nuclear zone, regardless of his or her trade ("Advanced radiation protection" (1 to 5 days), "risk prevention" (5 days), "Nuclear Qualification" (1 to 3 days), "Contractor Safety Quality" (5 days)). EDF states that the actual teaching of the programme is checked during the site access formalities and that the knowledge acquired is checked by training organisations from outside EDF, audited by EDF (and the CEFRI54 in the case of training related to radiation protection). The notion of "best bidder". The bids submitted by the candidates for the maintenance contracts are evaluated according to the notion of the "most economically advantageous bid", in other words certain criteria not related simply to price are considered by EDF. EDF in particular stipulates that "the part of the criteria not related to price in the bid evaluation can today reach 20%, half of which is linked to working conditions and the social environment of the work performed.". Finally, EDF mentions the creation of a system of bonuses to provide a greater margin for companies which contributed to the attainment of its objectives, which can be up to 5% of the value of the contract. The bonus system is based half on collective criteria related to the results of the site (duration of the outage, dosimetry, triggering of C3 portals) and half on individual criteria (obtaining a satisfactory A grade evaluation form). EDF also clearly wishes to increase the average duration of the on-site maintenance contracts, which went from 3 years in 2000, to 5 years in 2010. ASN considers that the CSA reports are short of information on the frequency of application and the procedures for following-up the sanctions imposed on the contractor companies checked and penalised. ASN will be asking EDF to complete the CSA reports. ASN considers that it would be opportune to see whether the employees of outside companies actually receive the same level of training as the EDF staff, in particular concerning the potential health risks following exposure 53 Order of 10th August 1984 concerning the quality of the design, construction and operation of basic nuclear installations 54 CEFRI: French Committee for the Certification of Companies for the Training and Supervision of Personnel Working with Ionizing Radiation
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