RECOMMENDATION 90-4 TO THE SECRETARY OF ENERGY
                   pursuant to Section 312(5) of the
                Atomic Energy Act of 1954, as amended.



Dated:  May 3, 1990



In several visits to Rocky Flats, the Board and its experts have
reviewed aspects of operations and activities.  These reviews have
been directed toward ensuring adequate protection of public health
and safety and concern matters that have an important bearing on
resumption of plutonium processing operations.  The Board's reviews
have included such operations-related activities as reconstruction
of drawings of systems important to safety ("red-lining"),
development and validation of plant operating procedures, and
training and requalification of plant operators in plutonium
processing operations.

Several of these contractor activities, which would ordinarily be
conducted in sequential manner, are being carried forward
concurrently.  Because of the interdependence of these activities,
the Board has not yet been able to predict their adequacy at the
time of proposed resumption of plutonium processing operations. 
For example, at the time of our most recent visit, no training
lesson plans had been approved and less than one-third had been
submitted for review.  Training materials that were reviewed
contained extensive on-the-job examination and performance
requirements leading to requalification.  This process will be
time-consuming.

Usual practice in restarting a nuclear facility after an extended
outage is the conduct of a comprehensive operational readiness
review.  Aware of the benefits of this practice in ensuring that
public health and safety are adequately protected, and in view of
the situation, the Board recommends that such a readiness review be
carried out at Rocky Flats prior to resumption of operations.

We recommend that the group constituted to carry out the readiness
review be composed of experienced individuals and that their
backgrounds collectively include all important facets of the unique
operations involved.  We recommend the review include, but not be
limited to, the following items:

      o    Independent assessment of the adequacy and correctness of
           process and utility systems operating procedures. 
           Consistent with the contractor's operating philosophy,
           these procedures should be in sufficient detail to permit
           the use of the "procedural compliance" concept.



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      o    Assessment of the level of knowledge achieved during
           operator requalification as evidenced by review of
           examination questions and examination results, and by
           selective oral examinations of operators by members of
           the review group.

      o    Examination of records of tests and calibration of safety
           systems and other instruments monitoring Limiting
           Conditions of Operation or that satisfy Operating Safety
           Requirements.

      o    Verification that all plant changes including
           modifications of vital safety systems and plutonium
           processing workstations have been reviewed for potential
           impact on procedures, training and requalification, and
           that training and requalification have been done using
           the revised procedures.

      o    Examination of each building's Final Safety Analysis
           Report to ensure that the description of the plant and
           procedures and the accident analysis are consistent with
           the plant as affected by safety related modifications
           made during the outages period.



                                                                                                                                                                                                                                                   /s/

                                                                                                                                                                                                   John T. Conway
                                                                                                                                                                                                   Chairman