RECOMMENDATION 94-3 TO THE SECRETARY OF ENERGY
                      pursuant to 42 U.S.C.  2286a(5)
                   Atomic Energy Act of 1954, as amended.



Dated:  September 26, 1994

In its Recommendation 90-5, the Defense Nuclear Facilities Safety
Board (Board) recommended that a site-wide Systematic Evaluation
Program be conducted at the Rocky Flats Plant (now the Rocky
Flats Environmental Technology Site), to determine if safety
upgrades should be instituted to enable the defense nuclear
buildings and facilities to meet current safety requirements. 
The mission of the Rocky Flats Environmental Technology Site has
changed since the issuance of Recommendation 90-5, and the
Implementation Plan for the Recommendation has been revised to
more directly address the current mission of the Site.

The Board has been informed in briefings by the Department of
Energy (DOE) that Building 371 is considered to be structurally
the best on-site facility for the storage of plutonium, and that
steps are therefore scheduled that in time will move the major
part of the Site's plutonium inventory into storage in this
building.  As a result, Building 371 will assume a unique role as
the storehouse which contains the largest single accumulation of
plutonium in the DOE complex.  It follows that potential health
and safety issues associated with this proposed use of the
building also assume very high importance.

Accordingly, the Board has been reviewing potential public health
and safety issues at Building 371, and in particular, the
building's capacity to provide reasonable assurance of protection
of public health and safety should it be subjected to external
forces from natural phenomena (earthquakes, extreme winds, and
floods).  The Board has observed that DOE's ongoing studies in
the Systematic Evaluation Program to better identify the
potential hazards from natural phenomena at Building 371 and to
establish means of protecting against them are not well
integrated.  An effective Systematic Evaluation Program requires
a more thorough application of the systems engineering process. 
The Board has concluded that activities currently underway in
this respect, to prepare Building 371 for its extended role in
storage of plutonium, are not logically structured and are not
sufficiently encompassing in either detail or scope to assure
that the health and safety of the public will be adequately
protected.

Therefore, the Board recommends:

1.   That an Integrated Program Plan be formulated to address the
     civil-structural-seismic safety issues and evaluations
     related to the planned use of Building 371 for storage of
     plutonium and related functions.  This plan needs to be
     founded on the principles of systems engineering and
     realistic schedules.  Several studies, pertinent to such a
     plan, are geologic fault investigations, groundmotion
     studies, dynamic building analyses, and soil-structure
     interaction analyses.  These studies and other elements need
     to be combined with the building mission and any other
     functional criteria using systems engineering principles to
     develop the Integrated Program Plan.

2.   That the above plan address and explain any requirements for
     changes to the current Safety Analysis Report and how such
     changes will be accomplished.  This includes effects from
     earthquakes, extreme winds, and floods.

3.   That a comprehensive document be completed describing in
     detail the structural analysis methodology and standards for
     the building analysis.  This includes explaining analytical
     methods used and their applicability to the configuration of
     Building 371.

4.   That the integrated program plan use both deterministic and
     probabilistic methods to establish the vibratory
     groundmotion criteria that will be used in the structural
     evaluation of Building 371.  This includes a rationale for
     reconciling differences between the two methods.  Moreover,
     these criteria should incorporate the results of a carefully
     planned and executed site geological faulting
     investigations.

5.   That a hazard classification be selected for Building 371
     which is supported by rational analysis.  This requires
     consideration of the mission, period of intended use, and
     importance of the building.

6.   That the Integrated Program Plan, consistent with the hazard
     classification, include the plan for classification of
     safety systems on a rational basis consistent with the
     mission, life, and importance of Building 371.  Issues
     associated with hazard classification and classification of
     safety systems are discussed in the Board's April 29, 1994,
     letter to Under Secretary Curtis.
     
7.   That any standards used in evaluating hazards from natural
     and man-made phenomena be comparable to those used in
     commercial nuclear practice.

8.   That the Program Plan and the results of its activities be
     used to specify building upgrade and improvements consistent
     with the mission of Building 371.


                                                                  
                                   John T. Conway, Chairman