- 339 - especially in terms of security and safety". The contractor is therefore chosen taking account of price, the contractor's technical capability, quality and safety results and organisation. Steps taken to ensure satisfactory intervention conditions for outside contractors CEA is responsible for general coordination of the preventive measures it takes and those taken by the head of the outside contractor. In this respect, it defines the rules and steps taken for risk prevention and ensures that they are implemented. CEA indicates that an inspection is carried out on the workplace, the facilities and the equipment contained therein, prior to any intervention by workers from outside contractors, in particular to present the radiological risks specific to the facility and to the activities concerned. With regard to radiation protection, CEA specifies that the head of the facility "calls on the technical expertise of the department with competence for radiation protection at CEA (SCR/CEA) and coordinates the interactions between the SCR and the outside contractor". Moreover, the outside contractor's person competent in radiation protection (PCR/EE) "acts under the responsibility of his or her employer and has responsibility for implementing the measures relating to radiation protection, in particular as defined in the specifications, the contract, the prevention plan and, as applicable, the agreement signed with CEA". The SCR/CEA ensures that the persons in charge of radiation protection at the outside contractor "have assimilated the radiation protection frame of reference requirements mentioned in the specifications and the prevention plan and, with the agreement of the Head of the facility, carry out the necessary spot-checks (sampling cheks) ( )". The SCR/CEA may "suspend the work of the outside contractor at any moment if it observes a real risk". Finally, CEA recalls that "the radiological protection measures and the level of personnel surveillance are the same for all exposed workers (CEA and outside contractors)". With regard to management of the competence of the staff involved, CEA stipulates various measures according to the BNIs. Thus, for Osiris, CEA stipulates that "measures to promote a safety culture are put into place for outside operators or workers in the facilities ( )". For Phénix, "there is a specific training module for contractors who are to work in the facility ( )". Methods for monitoring subcontracted activities CEA states that monitoring of the contracted services is carried out "in all fields concerning performance of the contract (safety, security, legal, technical, social, etc.) and, as necessary, involves the support units in the centres". CEA ensures that the contractor and any subcontractors "have set up an organisation appropriate to the nature of the contracted work and able to meet the safety and security objectives". The surveillance provisions implemented vary according to the BNIs, but in general a CEA operative is designated for each contracted service. They monitor and exercise surveillance of the activities subcontracted and ensure compliance with the safety and security frames of reference. For the Phénix facility it is stipulated that "the surveillance of a contractor is performed by the project management and directly by CEA or by an external inspection organisation (designated and monitored by CEA)". ASN opinion on the conditions for use of outside contractors Generally speaking, it would appear that the files transmitted by CEA comply structurally with the ASN specifications, presenting the steps taken for the four topics requested; scope of activities subcontracted, contractor selection procedures, conditions for intervention by the contractors and surveillance of subcontracted activities. However, the information actually transmitted leads us to make the following remarks. With regard to the scope of activities subcontracted, it would appear that the information forwarded by CEA only partially complies with the ASN request. Furthermore, a recent generic instruction showed that CEA does not have any formal tools for anticipating the skills requirements that would necessitate resorting to subcontracting. CEA describes the provisions governing the intervention conditions for outside contractors, particularly in the safety and radiation protection fields. With regard to training, the arrangements for evaluating what was actually learned during the training are not described.
RkJQdWJsaXNoZXIy NjQ0NzU=