- 198 - appropriate measures for monitoring of the activities performed. The monitoring of a task is entrusted to a monitoring supervisor, generally an EDF employee, except, for example, the monitoring of non-destructive testing (NDT) considered by EDF to be a specialised activity requiring specific skills. Monitoring of the contractors carrying out NDT is thus itself subcontracted. EDF states that the monitoring supervisors receive specific professional training for the activities involved, as defined in a monitoring programme. During the performance of the work, the duties of the monitoring supervisor are primarily to ensure the traceability of the monitoring actions performed, to adjust monitoring when the activity performance conditions change (context, volume, etc.) and to take steps in the event of nonconformity with the contractual requirements. After the work is completed, the monitoring supervisor checks the records (filled out monitoring files, available documents, deviations processed with EDF approval, etc.), or has them checked, creates an evaluation of the work from the data collected and the shared findings and completes the drafting of the monitoring report. The result of this monitoring process is officially written up in the work evaluation forms (FEP). The monitoring of subcontractors of the contractor companies is specifically dealt with by EDF. EDF states that it is the responsibility of the contractor company holding the contract to ensure that its subcontractors (tier 2 or higher) comply with the notified requirements. EDF explains that it monitors this follow-up. Since mid-2011, EDF has also been directly monitoring the activities of a subcontractor considered to be deficient, through the production of a work evaluation form (FEP). ASN considers that EDF's response to the specifications on the subject of monitoring of subcontracted activities is detailed but incomplete, because no figures are given. There is in particular the question of the total number of FEPs issued by the monitoring supervisor, in other words does this correspond to the 5,803 FEPs presented in the part on qualification monitoring (§ 7.2.1) in the CSA reports. If so, considerable discrepancies are observed between the sites in 2011 with regard to the number of FEPs issued. Furthermore, no mention is made by EDF of the total number of the interventions by contractor staff to which these 5,803 FEPs would refer. The question then arises of the adequacy of the technical monitoring for the volume of work subcontracted. In addition, EDF proposes no weighting of the monitoring performed according to the type of activity and its importance for safety. EDF subcontracts some monitoring activities, but does not sufficiently explain the type of activity concerned, or the volume and the importance for safety. Neither does EDF mention the temporary contractor groups (GME), in particular how they are qualified and monitored. Finally, ASN notes that EDF provides no information specifying the type of evaluation it performs on the organisation adopted by the contractor companies (tier 1), to enable them in turn to evaluate their contractors of tier 2 or higher. ASN remarks that EDF does not clarify the criteria enabling it to qualify a subcontractor as deficient, thus triggering monitoring of its work, through the production of a work evaluation form (FEP) (system in place since mid -2011). To conclude, ASN considers that in its CSA reports, EDF does not give enough information about the adequacy of monitoring of the different types of subcontracted activities important for safety, whether in terms of volume of monitoring or weighting of monitoring, according to the importance for safety of the activity in question. Moreover, the presentation of the procedures for monitoring the activities subcontracted by EDF raises the question of the dilution of responsibility for monitoring contractors of tier 2 or higher. ASN will thus be asking EDF for additional information to improve supervision of subcontractor management, which will contribute to the assessments carried out at its request by IRSN and the GPR, on the topic of subcontractor oversight.
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