- 337 - The AREVA reports give figures for the surveillance visits carried out in 2010, but they are not complete. In particular, only the level 1 surveillance is mentioned by all the sites (except Tricastin). Moreover, a comparison of these figures shows that the same number of level 1 visits was carried out in 2010 on sites of completely different sizes and risk levels. However, the reports do not indicate how the contractor surveillance results were used and in particular whether or not each licensee analyses experience feedback concerning each contractor, when it holds several contracts, and whether or not there is overall experience feedback with regard to this surveillance. AREVA states that it carries out a subsequent evaluation of its contractors, through the contract assessment form (FAM) which is used to input data into the "contractors" database mentioned in the "Contractor selection methods" chapter above. This FAM is based on the following criteria: the quality and conformity of the response to the call for bids; the organisation of the worksite or the service; the personnel involved (qualifications, training, experience, etc.); the quality of the design studies produced; the inventory and final condition of the worksite; compliance with the technical requirements or the applicable safety, security and environment requirements; the inspections carried out; the quality of performance; the quality of the documents provided. Experience feedback is shared among the licensee and the contractors during meetings that are in principle annual, the general content of which is not specified in the reports and which would not seem to be actually held on all the sites. This sharing of feedback also takes place during the expanded CHSCT meetings, but in a format not specified in the CSA reports. Conclusions on the conditions for use of outside contractors Only two of the four CSA reports (for Mélox and La Hague) comprise conclusions. These however remain extremely general and indicate that the licensee has decided to keep in-house those activities referred to as "core business or expertise" and to choose specialist contractors for specific works, who can provide references in the nuclear sector and who are well-established locally. Thus, in the event of a severe accident situation, the licensee would be able to call on contractors who are well-familiar with the facilities, with expertise in safety, security, health, radiation and environmental protection for intervention on the facilities and who are capable of rapid mobilisation. In the light of the above, ASN is not able to make a full assessment of subcontracting management within the AREVA group, as the data provided are incomplete. In particular, AREVA fails to specify the steps taken to follow-up the ASN requests and observations made on the occasion of previous inspections, especially: the selection criteria and the consideration of financial aspects as opposed to technical safety and radiation protection criteria; the steps taken to ensure satisfactory contractor surveillance; the lack of inspections by the group general management on the topic of subcontracting; the absence of experience feedback on the basis of level 0 or 1 contractor surveillance. ASN also noted that AREVA proposed no measures to tighten up the requirements concerning the conditions for use of outside contractors. AREVA recently submitted a report on the group's subcontracting policy, in particular analysed in terms of nuclear safety, radiation protection, occupational safety and maintaining and developing skills. AREVA thus identified various areas for improvement aiming to: limit to 3 the subcontracting tiers for its operation and service activities;
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