RECOMMENDATION 94-4 TO THE SECRETARY OF ENERGY
                     pursuant to 42 U.S.C.  2286a(5)
                  Atomic Energy Act of 1954, as amended.



Dated:  September 27, 1994

The Defense Nuclear Facilities Safety Board (Board) has issued a
number of recommendations concerning formality of operations,
including Recommendation 92-5, Discipline of Operations in a
Changing Defense Nuclear Facilities Complex.  In that
recommendation, the Board stated that facilities scheduled for
continued operations should develop a style and level of conduct
of operations which is comparable to that achieved at commercial
nuclear facilities.  Recommendation 92-5 further noted that,
prior to achieving an acceptable level of formality, major
improvements were required in a number of areas, including safety
analysis reports, limiting conditions of operation, and training
and qualification of personnel.

The Board and its staff have been monitoring the Department of
Energy's (DOE) efforts to implement an acceptable level of
conduct of operations at the Y-12 Plant in Oak Ridge, Tennessee,
which is scheduled for continued operations.  The Board has
forwarded a number of reports to DOE during the last two years
indicating the existence of safety-related concerns regarding
operations at Y-12.  DOE and its operating contractor, Martin-
Marietta Energy Systems (MMES), have taken some actions to
correct deficiencies; however, a number of recent events have led
the Board to the conclusion that more aggressive and
comprehensive management actions are required to bring the level
of conduct of operations at Y-12 to a satisfactory level.

The Board notes that during the past four months a number of
violations of Operational Safety Requirements and other safety
limits have occurred at the Y-12 Plant.  Most recently, the
Board's staff identified a substantial violation of nuclear
criticality safety limits within a special nuclear material
storage vault at Y-12.  When the staff identified this deficiency
to on-site personnel, including a senior MMES manager, an MMES
nuclear criticality safety specialist, and one of DOE's facility
representatives, immediate corrective actions that were required
by Y-12 procedures were not taken.  In fact, proper corrective
actions were not taken until the Board's staff informed the DOE
Y-12 Site Manager.  Subsequently MMES curtailed a number of
operations at the Y-12 Plant.  Reviews of compliance with nuclear
criticality safety limits at the Y-12 Plant revealed that a
widespread level of non-compliance exists.

In  its Annual Report to Congress (February 1994) the Board noted
that personnel and procedures are complementary elements in
implementing conduct of operations.  The report stated, "The
health and safety of the public and workers rest on a properly
trained workforce accomplishing tasks in a formal, deliberate
fashion in accordance with reviewed and approved procedures."  In
responding to the Board's Recommendation 93-6, Maintaining Access
to Nuclear Weapons Experience, DOE is evaluating the impact of
expertise presently being lost through ongoing staff reductions
on their ability to perform nuclear weapons dismantlement at Y-
12.

The Board recognizes that DOE and MMES management have begun
taking aggressive actions to correct the specific problems of
adherence to nuclear criticality safety limits, since the nuclear
criticality safety occurrence referred to above.  However, the
Board believes that more remains to be done.  Accordingly, the
Board recommends that:

(1)  DOE determine the immediate actions necessary to resolve the
     nuclear criticality safety  deficiencies at the Y-12 Plant,
     including actions deemed necessary before restarting
     curtailed operations and any compensatory measures
     instituted.  These actions should be documented, along with
     an explanation of how the deficiencies remained undetected
     by MMES and DOE (line and oversight).

(2)  DOE perform the following for defense nuclear facilities at
     the Y-12 Plant:

     (a)  An evaluation of compliance with Operational Safety
          Requirements and Criticality Safety Approvals (CSAs),
          including a determination of the root cause of any
          identified violations.  In performing this assessment,
          DOE should use the experience gained during similar
          reviews at the Los Alamos plutonium facility and during
          the recent "maintenance mode" at the Pantex Plant.

     (b)  A comprehensive review of the nuclear criticality
          safety program at the Y-12 Plant, including: the
          adequacy of procedural controls, the utility of the
          nuclear criticality safety approvals, and a root cause
          analysis of the extensive level of non-compliance found
          in recent reviews.

     (c)  A  comparison of the current level of conduct of
          operations to the level expected by DOE in 
          implementing the Board's Recommendation 92-5.

     (d)  Development of plans, including schedules, to address
          any deficiencies identified in the analyses conducted
          above.

(3)  DOE evaluate the experience, training, and performance of
     key DOE and contractor personnel involved in safety-related
     activities at defense nuclear facilities within the Y-12
     Plant to determine if those personnel have the skills and
     knowledge required to execute their nuclear safety
     responsibilities (in this regard, reference should be made
     to the critical safety elements developed as part of DOE's
     response to the Board's Recommendation 93-1).

(4)  DOE take whatever actions are necessary to correct any
     deficiencies identified in (3) above in the experience,
     training, and performance of DOE and contractor personnel.




                                                                  
                                   John T. Conway, Chairman