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



Dated: May 17, 1990



The Board has been reviewing a number of safety issues related to
plutonium processing operations at the Rocky Flats Plant. The
reviews have been directed toward ensuring adequate protection of
public health and safety, and involve consideration of actions that
should be taken in the short term (that is, before resumption of
operations), and actions to be taken in the long term, or after
resumption of operations.

With regard to long term safety improvements, the Board believes
that a specific program and process should be developed at the
Rocky Flats Plant to assure proper evaluation and coordination of
the facility changes under consideration. Experience with programs
which involve similar matters, such as the U.S. Nuclear Regulatory
Commission's Systematic Evaluation Program (SEP) for evaluating
older facilities against current standards, has demonstrated the
importance of assuring that there is a mechanism for systematically
reviewing, prioritizing, and integrating various potential facility
changes. For example, at the Rocky Flats Plant it is important that
there be a balanced approach taken concerning the criteria for
improving the seismic resistance of safety equipment, and the
criteria for improving seismic resistance of the building housing
such equipment. The effects of other external events, such as a
severe wind loading or potential flooding problems, and related
design improvements also should be considered in an integrated
manner to ensure that a balanced and integrated level of safety is
achieved.  Also, it would be useful to consider in the same
integrated fashion, the safety issues regarding a comparison of
existing facility design features with those required by commercial
criteria and standards, such as fire protection, as well as the
impact of expected new criteria and standards, such as life
extension.  Use of an integrated program also would permit
appropriate emphasis to be placed on improving defense in depth as
a means for enhancing safety at the plant.  To the extent
reasonable, consideration of probabilistic results may be useful in
assisting in the integration process.

The process for conducting such a systematic and integrated review
needs to be flexible to accommodate the levels of protection to
public health and safety appropriate to the differing operations
carried out in the various buildings at Rocky Flats. We suggest 




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that the Department of Energy take full account of the methodology
and the experience developed by the commercial power reactor
industry under the Nuclear Regulatory Commission's SEP for dealing
with similar issues.

Most of the structures and equipment at Rocky Flats that would be
considered for possible modification under this type of program
were designed and placed in operation long before current technical
standards and criteria, design bases, and analytical procedures
applicable to such structures and equipment were developed. This
does not mean that the structures and equipment are now inadequate
or unsafe because of these developments; rather, it means that 

it may be appropriate over the long run to improve these structures
and equipment on a systematic basis, taking into account the cost
of the improvements, the length of time the Rocky Flats Facility
will continue to be operated, and other relevant factors.  In this
connection, it appears that a backfit policy applicable to the
Rocky Flats Plant will need to be established in order to provide
a framework for making decisions on which of the facility changes
identified under this new program will or will not be implemented.

Considering the current status of the Rocky Flats Plant and the
benefits associated with a systematic evaluation program in
ensuring that public health and safety continue to be adequately
protected, the Board recommends that a Systematic Evaluation
Program be developed and implemented at Rocky Flats Facility
commencing as soon as practicable and completed over about the next
four years. The program should permit appropriate emphasis to be
placed on improving defense in depth at the facility. We recommend
that this Rocky Flats SEP address all outstanding current safety
issues and include, but not be limited to, consideration of the
following items:

      o    Effects of severe external events, with particular
           emphasis on seismic events and high winds;
      o    Effects of severe internal events, with particular
           emphasis on fire;
      o    Ventilation system performance under severe external and
           internal events, including redundancy considerations;
      o    Interaction of equipment and structures due to severe
           internal and external events; and
      o    The basis and procedures for making backfit decisions on
           which of the facility changes identified under the new
           program will or will not be implemented and, where
           appropriate, the schedule for completion of these
           improvements.




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The Board wishes to be informed on a timely basis of the progress
in developing the program and process for conducting the Rocky
Flats SEP.

                                                                                                                                                                                                   /s/

                                                                                                                                                                                                   John T. Conway
                                                                                                                                                                                                   Chairman