- 344 - The crisis management premises must be designed for hazards in excess of the current frame of reference. They will have to be accessible and habitable during long-duration crises and designed to accommodate the teams necessary for long-term site management. The control rooms are also crucial for crisis management and their accessibility and habitability must ensure that all the facilities on a given site can be operated and monitored in the event of releases of hazardous or radioactive substances. The Fukushima events showed that an off-site hazard can affect several facilities on a given site at the same time. In the CSA reports, the licensees stated that the current organisation did not take account of this possibility. ASN will thus be asking the licensees to supplement their crisis organisation, so that they are able to manage a "multi-facility" event. For multi-licensee sites, it is also important that the licensees coordinate their crisis management and mitigate impacts on neighbouring facilities. This point will be the subject of a requirement for reinforced coordination between the licensees of nuclear, but also non-nuclear facilities. Finally, during the inspections carried out in 2011, ASN observed that the sites have concluded agreements with external entities for management of a crisis situation. The site agreements with hospitals are frequently very old, with some of them dating back to 1989. ASN will thus be asking the licensees to regularly update these agreements and regularly test them. Integrating organisational and human factors and use of contractors ASN considers that additional steps must be taken regarding emergency situation management and the training of the personnel involved. It will thus be asking the licensees to define the human interventions required to manage the extreme situations studied by the CSAs and take account of crisis team shift changes and the intervention logistics necessary. ASN will also be asking the licensees to send it the list of skills required for crisis management, stipulating whether or not these skills are liable to be provided by the outside contractors. The licensees shall prove that their organisation ensures the availability of the skills necessary in the event of a crisis, in particular if outside contractors could be used. Finally, ASN will be asking the licensees to provide training and preparation for their personnel liable to intervene in extreme situations, to guarantee that they can be mobilised during such a situation and ensure that the outside contractors liable to intervene in crisis management adopt similar preparation and training requirements for their own personnel. 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 the prevention of such accidents, facility maintenance and the quality of operations. The conditions for the use of subcontracting are thus of particular importance and should enable the licensee to retain complete control and full responsibility for the safety of its facility. Based on the CSAs, ASN considers that the monitoring of subcontractors performing activities important for safety needs to be strengthened and that this monitoring must in particular not be delegated. ASN has included a requirement to this end in the draft order setting out the general rules concerning BNIs. ASN also considers that the proposal by EDF, CEA and AREVA to limit subcontracting to tier 3 is an interesting suggestion worth examining. It recommends that research programs on these subjects be engaged, both nationally and at a European level. Finally, ASN will propose setting up a working group on these subjects, comprising the licensees, trades union organisations, the HCTISN, the Ministry for Labour and the ministries responsible for nuclear safety. Furthermore, ASN considers that the renewal of the licensees' workforces and skills, at a time when there is major generational turnover combined with considerable work subsequent to the CSAs, is a fundamental point to which ASN will be paying very close attention. Special requirements The diversity of activities carried out in the fuel cycle facilities leads to the identification of specific feared accident situations that are different from those considered for the reactors. The licensees had to identify accident situations beyond the scenarios hitherto considered and to integrate them into the CSA approach.
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