- 340 - Concerning the surveillance of subcontracted activities, the elements presented comprise few actual details of the skills and responsibilities associated with the contractor surveillance duties and the methods for training the personnel in charge of these duties. ASN notes that CEA envisages taking no particular steps to reinforce its requirements on this subject, after pointing out that it had not identified any particular difficulties when reviewing the conditions for resorting to the use of outside contractors. CEA recently submitted a report on its subcontracting policy. ASN will review this report and decide on what steps are to be taken subsequently. 7.3 ILL Scope of activities concerned The ILL indicates that its policy for operation of the RHF is based on management of the core professions and know-how needed to guarantee the safety and availability of the required scientific operations. Consequently, the ILL performs the following operations with its own personnel: all RHF operational activities; all major maintenance operations (regular thimble replacements, replacement of the reflective tank, the RHF vessel); the majority of inspections and periodic tests (CEP); activities related to site and environment radiation protection (under the responsibility of the ILL radiation protection safety and environment department). The following activities are subcontracted: very particular tests (such as the tests of the HEPA filters and the PAI (iodine trapping), performed by specialist contractors who generally intervene on the entire nuclear fleet); certain "conventional" maintenance and troubleshooting operations, o design studies; o manufacturing.; o certain activities defined or chosen according to an annual programme. The ILL specifies that for management of a crisis, CEA could assist it by making premises and crisis management resources available in the event of a site evacuation, and by providing aid to the injured and in the event of a fire (pending intervention by the Departmental Fire and Emergency Service (SDIS)). To summarise, the ILL indicates that the use of contractors is limited to those fields of activity which do not risk leading to a loss of responsibility and autonomy. Contractor selection procedures For contractor selection, the ILL refers to a quality assurance note (NAQ n°12) which details the steps involved in the contractor selection process: creation of the call for bids file, transmission of the call for bids file and examination of responses to it. This examination takes account of quality assurance criteria such as the supplier's organisation and how it processes nonconformities. Steps taken to ensure satisfactory intervention conditions for outside contractors Given the nature of the work involved and the management system in place, entailing compliance with the prevention plans and application for and then granting of work permits, the ILL does not require any particular safety qualifications of its contractors. The ILL mentions two principal arrangements governing management of the conditions for intervention by outside contractors on the site: a security memo "Steps to be taken concerning outside contractors" based on Decree 92-158 of 20/02/1992 and articles R 237-1 to 28 of the Labour Code; Quality Assurance Note NAQ N° 34 "Work permit procedure ".
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