- 333 - 7. Conditions for use of outside contractors The Fukushima accident showed that the ability of the licensee and, as applicable, its contractors, to organise their work in severe accident conditions is a key factor in managing such situations. This ability to organise is also a key factor in facility maintenance, the quality of operations and thus the prevention of accidents. The conditions for resorting to subcontracting are thus of particular importance and should enable the licensee to retain complete control of and full responsibility for the safety of its facility. This importance was also underlined by the stakeholders, particularly the HCTISN, as of the beginning of the profess to draft the ASN specifications for the CSAs. The ASN specifications thus asked the licensees to analyse the conditions for the use of outside contractors. Furthermore, and more generally, ASN considers that incorporating socio-organisational and human factors into the safety approach is fundamental and this aspect is covered both in the inspections conducted by ASN and on the occasion of the periodic safety reviews of the facilities. The experience feedback from the Fukushima accident will also be taken into account. ASN reviews the conditions for the use of subcontracting in nuclear facilities during the meetings of the advisory expert committees for reactors and for laboratories and plants, which thus examined CEA's safety and radiation protection management strategy in 2010, and that of AREVA in 2011. It is also carrying out targeted inspections on this topic. 7.1 AREVA Scope of activities concerned The ASN specifications for the CSAs ask AREVA to describe and justify the scope of activities concerned by subcontracting and to demonstrate that this scope is compatible with the licensee's full responsibility for nuclear safety and radiation protection. In its complementary safety assessment, AREVA did not clarify its definition of contractor, nor the acceptable number of subcontracting tiers it considers to be manageable. The licensee does however point out that the chapter of the CSAs report devoted to subcontracting does not concern companies which simply supply equipment or consumables to the nuclear sites, without actually having to intervene on these sites. The AREVA group has defined a list of activities it considers preferable not to outsource. These are the following: production; management of utilities necessary for production; maintenance of the "core process"; maintenance of utilities; project ownership; safety and radiation protection services on each site. With regard to subcontracting, one particularity of the AREVA group is that it has subsidiaries specialising in engineering, provision of services, supply of equipment and performance of special work. The activities outsourced for each of the nuclear sites operated by an entity of the AREVA group can thus be spilt into two categories: activities subcontracted internally within the AREVA group, representing between 40 and 50% of all the activities subcontracted, depending on the site, and generally concerning the following: o transport of radioactive materials; o management of radioactive waste; o engineering, in particular "core process" engineering; o washing of work clothes; o IT services;
RkJQdWJsaXNoZXIy NjQ0NzU=