RECOMMENDATION 91-2 TO THE SECRETARY OF ENERGY
                   pursuant to Section 312(5) of the
                Atomic Energy Act of 1954, as amended.



Dated:  March 27, 1991



The principal safety issues to be resolved in connection with
restart of the K-Reactor at the Savannah River Site have been
assembled in the Reactor Operations Management Plan (ROMP) issued
by the Savannah River Site contractor and updated on a number of
occasions.  These issues had been identified in the course of
reviews by a number of organizations, including in-house groups of
the DOE, a committee of the National Research Council of the
National Academies of Science and Engineering, and the Savannah
River contractor.  The issues so identified have been divided into
those that require resolution before the reactor is restarted, and
those that can be addressed over a longer period.  DOE has
apparently found this process of definition and prioritizing of
issues to be acceptable, and the Board has generally regarded it as
orderly and competently done.

However, the Board considers the extension of this process to its
culmination in closure of the issues as equally important, and has
been carefully following its progression.  This has largely been
done through review of the issue closure packages as they have been
received, and further discussion of them with representatives of
the DOE and its contractor.  The Board considers that it must
comment on two aspects of the process.

First, it is seen that the closure packages, which are meant to
document completion of the necessary work regarding each issue,
contain mainly a list of the reports supporting a conclusion that
the issue has been resolved, and the signatures of officials in the
contractor's management chain concurring with the conclusion that
closure has been achieved.  There is no discussion of the relation
of the reports to the issue itself, and no enlightenment is
provided on the reason for concluding that the work has produced
the desired objective.  

During briefings by representatives of the DOE and its Savannah
River Site contractor some months ago, Board members pointed out
that closure packages of this form would cause difficulty to
reviewers, including the Board, because of the failure to provide
the logic to support conclusions.  It was suggested that each
closure package be headed by a brief discussion, stating the issue,
the steps taken to address it, the basis for the conclusion that 




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closure had been successful, and the relation of the referenced
documents.  This text need not be long.  At this stage in the
Board's review, the need for such documentary discussion is even
more evident.  Not only would it aid the Board in its review; it
would show others how these problems of the past have been
corrected.  

Second, the Board is concerned that changes made to the process of
final review and approval of closure of issues indicates a
weakening of DOE's determination to assure itself of resolution of
these problems of the past.  Originally, DOE's formal concurrence
was to be required for closure of each issue in the ROMP.  DOE's
concurrence is no longer required.  It has been restated that
closure of issues is to be dealt with in the DOE's Safety
Evaluation Report (SER) when it is issued.  The current indication
is that this will be done through discussion and description of the
closure process, rather than through stating the DOE's position on
closure of all specific issues.

The Board remains convinced that the issues covered by the ROMP
represent real deficiencies in past practices, and that their
correction is important.  In its reviews of activities to resolve
issues in the ROMP, the Board has observed numerous areas in which
improvement was needed over the measures that had been considered
by the contractor as satisfactory.  These have been transmitted
through formal recommendations and through informal observations
that on the whole have helped to improve the restart activity in
important and often essential ways.  This convinces the Board that
the closure packages deserve DOE's close attention, to the extent
of restoring the original intention of approving the closure issue
by issue.  In the present situation, where the Board reviews each
package to determine adequacy and the DOE does not, DOE is relying
on the Board to do DOE's job. 

In accordance with the above, the Board recommends:


      1.   that each closure package of an issue in the ROMP be
           provided with a brief narrative discussion that clarifies
           the meaning of the issue, describes the steps that were
           taken to resolve it, states the reason for concluding
           that closure has been achieved, and shows how the
           referenced documents support the claim of closure,







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      2.   that the DOE revert to its earlier plan to fully review
           and concur with the determinations of each issue closure.


                                                                                                                                                                                                                                                   /s/

                                                                                                                                                                                                   John T. Conway
                                                                                                                                                                                                   Chairman