**Process to Determine Safety System Oversight Staffing**

[Background]{.underline}

The process for determination of Safety System Oversight (SSO) staffing
levels is based on and adapted from the process used to determine
Facility Representative staffing levels.

[Overview]{.underline}

The steps below describe the process to determine Safety System
Oversight (SSO) staffing for all hazardous facilities at a site. The
process is adapted from the Facility Representative staffing process
which uses the guidance in DOE-STD-1063-2000, *Facility
Representatives.* The Facility Representative staffing process was
modified to address the duties and responsibilities of SSOs described in
DOE M 426.1-1A, *Federal Technical Capability Manual*. This SSO staffing
determination process uses the facility hazards analysis from the
Facility Representative staffing determination process and takes into
account safety system characteristics, including system size, condition,
and complexity; and other factors deemed pertinent. Provided below are
elements that must be met by the analysis, followed by a step-by-step
description of the method and how it can be tailored to meet additional
considerations that may be applicable at each site.

[Methodology]{.underline}

The following elements shall be included in each site analysis.

1.  A relative ranking of facilities and safety systems based on the
    hazards or risks presented to the public, the worker, and/or the
    environment.

2.  A method for ranking facilities and safety systems and prioritizing
    SSO coverage based on hazards or risks, as identified in step 1
    above, and other factors such as facility/system size, operations
    complexity, hazards and risks, etc.

3.  A determination (i.e., an informed management judgment) of SSO FTE
    requirements based on the priority of coverage, the system activity
    level, and the identified base coverage levels adjusted to address
    factors considered in step 2 above.

4.  A determination of actual staffing based on SSO FTE requirements
    adjusted to account for actual staff time available to support the
    SSO function when competing activities such as collateral duties,
    leave, training, etc. are considered.

[Procedure to Perform SSO Staffing Analysis]{.underline}

Procedures for conducting a Safety System Oversight staffing analysis
follow each table. Tables 1 and 2 establish the Facility Hazard Value
and rank the facilities for SSO coverage. Table 3 establishes the Safety
System Adjustment Factor to address system complexity, size, condition,
and rigor of the contractor System Engineer and Configuration Management
programs. Table 4 determines the SSO base time commitments in terms of
technical and administrative duties. Tables 5 and 6 are used to
calculate the amount of SSO time needed for each safety system and
account for multiple systems assigned to a single SSO individual. Table
7 accumulates the time requirements for each assigned SSO, including
other collateral duty and special assignments and concludes whether
adequate SSO resources are applied.

[Procedure to Complete Table 1, *Facility Hazard Ranking
Worksheet*]{.underline}

Table 1 is identical to the table used in the Facility Representative
staffing analysis. If that analysis has been completed, the Facility
Hazard Values can be inserted directly into Table 1. If the Facility
Representative staffing analysis data is not available, the following
procedure is used for Table 1. Using the provided Excel Spreadsheet,
enter in the following data:

1.  On Table 1, *Facility Hazard Ranking Worksheet*, list each hazardous
    facility, or group of facilities, at a site in the Facility Column.

2.  Enter the severity of the hazard to the public, the workers, and the
    environment for each hazard that is present in the facility. The
    severity of the hazard is ranked as follows:

    a.  High Hazard = 3

    b.  Moderate Hazard = 2

    c.  Low Hazard = 1

> The qualitative hazard descriptors are based on existing standards
> where available, such as the chemical hazard class, biological hazard
> categories, laser class, or an analogous judgment where a standard is
> not available or clearly applicable, or where a compendium of
> hazardous elements exist.

3.  The spreadsheet will calculate the Facility Hazard Ranking Value and
    insert it in Table 1, *Facility Hazard Factor,* in Column (b). After
    the Hazard Ranking Values are calculated, arrange the facilities in
    order from highest hazard factor to lowest.

[Procedure to Complete Table 2, *Facility Coverage Ranking
Factor*]{.underline}

Table 2 is identical to the table used in the Facility Representative
staffing analysis. If that analysis has been completed, the Facility
Hazard Ranking Factors (called Coverage Priority Ranking in the Facility
Representative process) can be inserted into Table 2. If the Facility
Representative staffing analysis data is not available, the following
procedure is used for Table 2. Using the provided Excel Spreadsheet,
enter in the following data:

Determine the Facility Hazard Ranking Factor, column h, in Table 2,
*Facility Coverage Ranking Factor*. The Facility Hazard Ranking Factor
is an adjustment to the Facility Hazard Value based on factors such as
the facility size, the material condition of the facility, the
complexity of operations conducted in the facility, the facility's
programmatic importance, and operational rigor. The Facility Hazard
Ranking Factor is calculated by multiplying facility hazard value by the
modifying factors (h=b\*c\*d\*e\*f\*g). Other factors appropriate for a
particular site or facility may also be added, as appropriate, and
included in the calculation. The Facility Hazard Ranking Factor
illuminates the higher priority facilities for the purposes of
qualitatively prioritizing the assignment of SSOs resources to the
safety systems located in those facilities. After the factors have been
calculated, arrange the facilities in the spreadsheet in order of the
Facility Hazard Ranking Factors, highest to lowest. The modifying
factors are defined as follows:

> **Facility Size (c):**
>
> 0.75 - Operations areas less than 10,000 square feet.
>
> 1.0 - Between 10,000 square feet and 100,000 square feet
>
> 1.25 - Operations areas greater than 100,000 square feet.
>
> **Material Condition (d):**
>
> 0.75 - Configuration management program is mature, as-built drawings
> are reasonably accurate, material management/pedigree programs are in
> place, replacement parts for safety systems are available, safety
> systems are reliable, condition similar to what one would expect for a
> new or well maintained facility.
>
> 1.0 - Between .75 and 1.25.
>
> 1.25 - As-built drawings are unavailable or very out-of-date,
> replacement parts for safety systems are hard to get or unavailable,
> safety system reliability is degraded, condition similar to what one
> would expect for an old or poorly maintained facility.
>
> **Operations Complexity (e):**
>
> 0.75 -- Majority of the following conditions are present: One primary
> program/function, less than 250 employees, single chain-of-command,
> modest level of expertise and training required to operate.
>
> 1.0 - Between .75 and 1.25.
>
> 1.25 - Majority of the following conditions are present: Multiple
> distinct programs/functions, many different activities/disciplines,
> many different tenants or chains-of-command, greater than 500
> employees, high level of expertise and training required to operate.
>
> **Programmatic Importance (f):**
>
> 0.75 - Unplanned outages for up to 30 days will not negatively affect
> DOE Strategic Plan deliverables or objectives.
>
> 1.0 - Limited impact on the DOE Strategic Plan deliverables or
> objectives as a result of unplanned outages for up to 30 days.
>
> 1.25 - Significant impact on DOE Strategic Plan deliverables or
> objectives as a result of unplanned outages exceeding 30 days.
>
> **Operational Rigor (g):**
>
> 0.75 -- Well implemented Conduct of Operations Programs. Within the
> last year, zero of the following significant events/accidents:
> radiation over-exposures or uptakes, injuries requiring
> hospitalization, lockout/tagout violations, or environmental releases.
> Within the last year, zero TSR/AB violations. Contractor integrated
> management systems are verified mature.
>
> 1.0 - Between .75 and 1.25.
>
> 1.25 - Conduct of Operations is poorly implemented. Within the last
> year, two or more of the following significant events/accidents:
> radiation over-exposures or uptakes, injuries requiring
> hospitalization, lockout/tagout violations, or environmental releases,
> and more than three TSR/AB violations. Contractor integrated
> management systems not mature.

[Procedure to Complete Table 3, *Safety System Adjustment
Factor*]{.underline}

In Table 3, the facilities should be listed in the rank order
established in Table 2, column h. List each safety system identified in
each facility's authorization basis in Table 4, column (a), underneath
the appropriate facility. In column (b), enter the type of safety
system. These system types should be grouped around SSO disciplines and
will be used to group related systems for assignment to a single SSO.

Enter safety system adjustment values into the table in columns (c),
(d), (e), and (f). These factors are adjustments to the facility hazard
ranking priority to account for system-specific issues, such as such as
system size, design/operational complexity, system/equipment condition,
and effectiveness of the contractor's system engineer program. Other
factors appropriate for a particular site, facility, or system may also
be used. Once the system adjustment factors are calculated, arrange the
systems within each facility from highest system adjustment factor to
lowest. The Nominal Safety System Adjustment Factors are defined and
quantified as follows:

> **System Size (c):**
>
> 0.75 -- The system is reasonably compact in the amount of geographical
> space it occupies. It has few components and minimal or no redundant
> trains. Compact systems are generally confined to a single facility.
>
> 1.0 -- Between 0.75 and 1.25.
>
> 1.25 -- The system covers a large geographical area. It consists of
> two or more trains for redundancy. It has many components and/or
> several subsystems. Large or extensive systems may extend to two or
> more facilities or between areas at a site, such as waste transfer
> piping.
>
> **System Complexity (d):**
>
> 0.75 -- One primary system function, homogeneous process (i.e., an all
> electrical system; an all mechanical piping system; a simple
> ventilation system with controls that remain mostly static over time;
> or systems that require only a modest level of expertise and training
> to maintain, troubleshoot, and operate).
>
> 1.0 -- Between .75 and 1.25.
>
> 1.25 -- Multiple, distinct functions, or several processes combine to
> perform safety function (e.g., ventilation system with intricate
> controls to maintain air balance; a system with automated controls to
> sense off-normal parameters and automatically change system operating
> parameters or modes; a system where a high level of expertise and
> training are required to maintain, troubleshoot, and operate).
>
> **System Condition (e):**
>
> 0.75 -- System consistently operates above the reliability and
> availability goals set by the contractor System Engineer.
> Historically, the system has not caused the challenge of a TSR limit
> or caused entry into an LCO.
>
> 1.0 -- System operates at or near the availability and/or reliability
> goals set by the contractor System Engineer. System requires moderate
> amounts of corrective maintenance, but parts are available and the
> corrective maintenance backlog is managed to a minimum level. System
> failures occasionally impact TSR performance.
>
> 1.25 -- System operates below availability and/or reliability goals
> set by contractor System Engineer. System requires excessive
> corrective maintenance tasks each month, spare parts are not readily
> available, excessive maintenance backlogs (corrective and/or
> preventive). System routinely impacts TSR performance and is in an LCO
> condition for a moderate amount of time.
>
> **Contractor System Engineering Program Implementation (f):**
>
> 0.75 -- Highly Effective - Contractor System Engineer is qualified on
> the system, has moderate to extensive experience with the system,
> monitors system performance, has a history of quick response to system
> problems. Actively manages system performance by appropriate
> performance of predictive maintenance tasks coupled with timely
> preventive maintenance to minimize system downtime. Performs system
> assessments on a regular basis and corrects problems or declining
> trends quickly.
>
> 1.0 -- Effective - Contractor System Engineer is qualified and
> knowledgeable of system. Only minimum actions are conducted to
> maintain system operable. System engineer has little experience with
> the system.
>
> 1.25 -- Ineffective or Non-Existent - No Contractor System Engineer is
> assigned to the system, or the assigned individual is not yet
> qualified on the system. Performance assessments have not been
> conducted and long-standing problems remain unresolved.

[Table 4, *System-Specific Adjusted Base SSO Hours*]{.underline}

Anticipated SSO activities and tasks can be divided into 3 basic
categories: (1) those technical activities that each SSO must perform
that are constant and independent of the intricacy or extent and number
of assigned safety systems; (2) those technical activities that each SSO
must perform that depend on the intricacy or extent and number of
assigned safety systems; and (3) the administrative activities that each
federal staff must perform.

1.  Enter the estimated amount of time SSOs are expected to spend in
    each of the categories of time listed in the table. Times can be
    entered in any of the columns, depending on how often the activity
    is performed. Multiple entries in each row are allowed to account
    for daily, weekly, and monthly meetings, for example.

2.  The technical time estimates used in Table 3 correspond to those
    times that would be reasonably required for a simple safety system
    in a low hazard facility. Factors to account for larger or more
    intricate and multiple assigned systems are addressed later in
    Table 4. Table 3 has several columns to allow time entry on a daily,
    weekly, monthly, etc. basis. Several columns can be used for one
    activity, for example, an SSO may prepare reports on a weekly and
    monthly basis for management, and provide input to the FTCP SSO
    quarterly report. Estimates of these times have been entered in the
    spreadsheet as a basis for all offices to start from. Additional
    activities can be added and times can be adjusted, as necessary,
    with appropriate rationale.

3.  The spreadsheet calculates the Safety System Adjustment Factor in
    column (g) as a product of the Safety System Adjustment Elements.

**Table 5, *System-Specific Adjusted Base SSO Hours***

Table 5 is automatically filled in as data have been entered in previous
worksheets. This table lists the facilities in ranked order according to
the Facility Hazard Ranking Factor from Table 2, with the safety systems
in each facility in ranked order by the Safety System Adjustment Factor
from Table 3. The facility with the largest Facility Hazard Ranking
Factor is listed first[^1], with its associated safety systems. This
focuses attention on the higher hazard facilities for qualitative SSO
resource priority allocations. The result of Table 5 is an adjustment to
the base SSO hours based on safety system size, intricacy, condition,
and the maturity of contractor programs. The Adjusted System Dependent
SSO hours does not account for economies of scale associated with a
single SSO overseeing several systems. That adjustment is made in the
next table.

**Table 6, *Multiple System Assignment Factors***

Table 6 uses the prioritized facility/system list from Table 5 and
groups the systems by system type (which is considered equivalent to SSO
discipline and may correspond to one SSO). The table groups the same
system types together. The system types are arranged in order of the
system type with the largest Safety System Adjustment Factor (Table 3)
to the smallest. Where there are multiple safety systems in a single SSO
discipline, the system type ranking is based on the average Safety
System Adjustment Factor for the systems in the system type. Table 6
adds the SSO fixed technical activity hours, the system-dependent
adjusted hours for the first system assigned, and a portion of the
system-dependent adjusted hours for each additional system to account
for the economies of scale that result from a single SSO being assigned
to 2 or more systems. The factor for determining the portion of the
system-dependent adjusted hours for additional systems is 50% of the
system-dependent adjusted hours. The first system in the multiple system
calculation is always the system with the largest adjusted
system-dependent hours[^2].

**Table 7, *SSO Available Time for Coverage, Assignment-Specific
Analysis***

Table 7 lists the SSOs to be assigned in the same ranked order used in
Table 6. Table 7 calculates the time the SSO has available to perform
the SSO technical duties after deduction of administrative time (leave,
training, timekeeping, etc.), collateral duty time, and special
assignment time. Administrative time is tabulated and summed in Table 3
and inserted into Table 7. The resulting available time to perform SSO
activities is compared to the required SSO time calculated in Table 6. A
final conclusion of coverage adequacy or inadequacy is entered into the
table by testing whether the available time is greater than the needed
SSO time.

[^1]: The spreadsheet requires some modification to implement the
    sorting feature. At the present time, the facilities are not sorted.

[^2]: The logic of this step needs to be programmed into the spreadsheet
    -- right now the formula is manually input in each cell -- the logic
    for selecting the system with the highest number of hours is not yet
    programmed.