- 199 - 7.3 Conclusions on the conditions for the use of contractor companies In the CSA reports, EDF says that it can guarantee the compatibility of its industrial subcontracting policy with its full responsibility as licensee for nuclear safety and radiation protection. EDF believes that it has put into place: a clear "do or buy" industrial policy and an industrial fabric strategy based on the availability of the facilities and nuclear safety, a qualification system guaranteeing the human resources, means and competence of the contractor companies, a transparent system for placing contracts, leaving considerable room for the "best bidder", technical, quality, nuclear safety and radiation protection requirements that are clearly laid out in the specifications prepared by EDF. Only bids meeting these requirements are selected for the commercial negotiation phase and bids with an "abnormally" low price are eliminated from the process, mandatory justification by the contractor companies of the actual training to their employees before they intervene on the site, monitoring of the activities of contractor companies on EDF NPPs, before and during the reactor outage, included in the operating experience feedback process, the goal of dosimetry reduction, through the design of the interventions, monitoring of the activities carried out by the contractors able to ensure the required level of quality. This monitoring by the monitoring supervisors enables the qualification of the contractor companies to be verified and renewed. In the CSA reports, EDF announces the following two areas for improvement: limiting subcontracting to 3 tiers as of the call for bids stage. These measures would not modify the provisions in force for monitoring of the subcontractors. tightening up the provisions of the Progress and Sustainable Development Charter and the advances made as a result of the MOPIA project, in particular concerning the working conditions for the employees of contractor companies. This would take the form of the inclusion of "social specifications" in the calls for bids and contracts. ASN considers that these two points presented by EDF are a step in the right direction towards improving the conditions for the use of contractor companies. However, EDF must provide information to prove that these two measures, in particular limiting subcontracting to 3 tiers, will enable it to effectively retain its full responsibility for nuclear safety and radiation protection. On the basis of the IRSN report and the opinion issued by the Advisory Committees for "Reactors" and "Plants", subsequent to their meetings of 8th, 9th and 10th November 2011 devoted to reviewing the postFukushima complementary safety assessments conducted in 2011 by the licensee EDF, ASN considers that the aspects relating to subcontracting are a key element which can determine the operational robustness of the facilities. ASN will be asking EDF for additional information as the data given in the CSA reports are insufficient on the following points: Incomplete or missing figures concerning: o the proportion, nationwide, of outside staff for each trade identified, o the annual number of monitoring activities performed by the monitoring supervisors, compared with the number of tasks performed by the contractor employees, according to the various trades identified and their importance for safety; as well as the number of monitoring activities subcontracted; o the number of hours of mandatory training received by the EDF staff, so that for an equivalent trade or function, it can be compared with the number of hours of the same training received by each contractor employee,
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