Washington, DC

U.S. Office of Personnel Management
Job Grading Appeal Decision
Under section 5346 of title 5, United States Code

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Damon B.Ford
Acting Classification Appeals and FLSA Claims
Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance


12/04/2018

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Date

As provided in section S7-8 of the Operating Manual: Federal Wage System, this decision constitutes a certificate that is mandatory and binding on all administrative, certifying, payroll, disbursing, and accounting officials of the Government.  There is no right of further appeal.  This decision is subject to discretionary review only under conditions and time limits specified in section 532.705(f) of title 5, Code of Federal Regulations (CFR) (address provided in the Introduction to the Position Classification Standards (Introduction), appendix 4, section H).

Introduction

The appellant’s job is currently graded as Boiler Plant Operator, WG-5402-9.  The appellant believes his boiler operating and repair duties and “operator in charge” responsibilities warrant grading his job as Boiler Plant Operator, WG-5402-11.  He works in the Boiler Plant Section (boiler plant), Engineering Service, Veterans Affairs Medical Center (VAMC), Veterans Health Administration (VHA), U.S. Department of Veterans Affairs (VA), in Bedford, Massachusetts.  We have accepted and decided this appeal under section 5346 of title 5, United States Code (U.S.C.).

General issues

The appellant contends he performs the same duties as the higher graded Boiler Plant Operators in his organization, thus his job should be higher graded.  In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of this job.  By law, we must make that decision solely by comparing his current duties and responsibilities to appropriate job grading standards (JGS).  See 5 U.S.C. 5346.  Since comparison to JGSs is the exclusive method for grading jobs, we cannot compare the appellant’s job to others in his organization which may or may not be properly graded as a basis for deciding this appeal.

Like OPM, the appellant’s agency must classify positions based on comparison to OPM’s JGSs and guidelines.  Consequently, the appellant’s agency has primary responsibility for ensuring its positions are graded consistently with OPM appeal decisions.  If the appellant believes his job is graded inconsistently with others, he may pursue this matter by writing to the VA’s headquarters human resources office.  He should specify the precise organizational location, series, title, grade, and responsibilities of the jobs in question.  The agency should explain to him the differences between his job and the others, or grade those jobs in accordance with this appeal decision.

Job information

The appellant operates and performs operator maintenance and repair on the VAMC’s heating equipment to ensure adequate steam and high temperature hot water (HTHW) capacity at the facility.  He starts, regulates, controls, and maintains three 25,000 pound (110 psi) fire tube natural gas fired power boilers (oil is the backup fuel) and associated components.  The boilers have an automated master control system that controls operating temperature, monitors steam flow and oxygen, and controls water and steam pressures.  His duties include taking and recording boiler gauge readings; observing flow meters and charts; performing various water chemical tests and adding chemicals as necessary; ensuring water softening equipment is operating properly; doing maintenance such as installing some parts and gauges and flushing the inside of the boilers with high pressure water.  The boilers have a variety of automated auxiliary equipment including electronically controlled air compressors and water control dampers, de-aerating and condensate tanks, and feed water pumps.

The boiler plant is operational on a 24 hour/7 day a week basis.  One employee is assigned per shift and the shifts are day from 8:00am to 4:00pm, evening from 4:00 pm to 12:00 am, and night from 12:00 am to 8:00 am.  The appellant is assigned to a fixed schedule working the day shift Sunday through Wednesday and Saturday.  The supervisor is present during the normal work week day shift.  When the appellant works weekends, holidays, and when his supervisor is not working Monday through Wednesday, he assumes full responsibility for operation of the plant.  He makes decisions on emergency repairs and may call back employees.

In reaching our job grading decision, we have carefully reviewed all of the information provided by the appellant and his agency, including his official job description (JD), which the appellant and his immediate supervisor state includes inaccuracies.  In addition, to help decide the appeal we conducted separate telephone interviews with the appellant and his immediate supervisor, Boiler Plant Operator Supervisor.

Our findings disclosed the appellant’s official JD is not completely accurate.  For example, the appellant does not need to be knowledgeable of pollution control devices, does not use flue-gas desulfurization systems or sulfur containing fuels and does not control pollutants in flue emissions during combustion.  The responsibilities section includes a statement about grade 10 boiler plant operators making more independent decisions and judgments than operators at the grade 8.  The references to grade levels should be removed and the inaccurate statements about the appellant’s plant operations responsibilities should be corrected.  Despite the JD not being completely accurate, it covers the major duties and responsibilities the appellant performs and we incorporate it by reference into this decision.

Occupation, title, and standard determination

The agency allocated the appellant’s job to the 5402 Boiler Plant Operating occupational series, titling it Boiler Plant Operator.  Jobs in the 5402 series are graded by application of the 5402 JGS.  The appellant does not disagree and, after careful review of the record, we concur.

Grade determination

The 5402 JGS does not describe all possible grade levels for the occupation.  If jobs differ substantially from the skill, knowledge, and other work requirements described in the grade levels of the JGS, they may be graded either above or below the described grades based on application of sound job grading principles.  The 5402 JGS provides for grade-level determination on the basis of four factors: Skill and Knowledge, Responsibility, Physical Effort, and Working Conditions.  Our application of the standard to the appellant’s job follows.

Skill and Knowledge

Grade 8 boiler plant workers require a working knowledge of the structure and operating characteristics of boilers and associated auxiliary equipment, including the location and function of numerous pumps, valves, regulators, gauges, recording instruments, controls, power operated dampers, conveyors, and other equipment associated with clean, safe, and efficient boiler operation.  Grade 8 work entails: (1) knowledge of fuel handling and distribution equipment and systems, fuel firing mechanisms, feed water treatment systems, electrostatic precipitators, flue gas scrubbers, and lime slurry systems; (2) a basic knowledge of the chemical and physical characteristics of fuels and principles of combustion, steam generation, and heat transfer; (3) a working knowledge of the relationship between fuel quality and efficient combustion characteristics; (4) a working knowledge of water tending, analysis, and basic chemical treatments; (5) a general understanding of the individual and combined effects of chemical additives; and, (6) knowledge of basic operations necessary on start-up, shutdown, and re-start procedures and in casualty control.  Grade 8 workers have skill in:  (1) adjusting various conditions such as air temperature, draft, and other furnace conditions; (2) interpreting meter and gauge readings; (3) using hand tools, electric and pneumatic power tools, and specialized tools of the trade; and, (4) applying preventive maintenance procedures and performing limited operational repairs such as cleaning equipment, greasing and oiling moving parts of machinery, repainting equipment, tightening packing bonnets and glands on valves and pumps, repacking valves, replacing pumps, and assisting higher grade workers in more difficult repairs and replacements.  They are able to recognize malfunctioning equipment and systems and potentially dangerous operating conditions.  

Grade 10 boiler plant operators apply a comprehensive knowledge of all operational phases of power boiler plant operations, (e.g., water treatment, fuel systems, steam generation, and pollution control) and their interrelationships for efficient and economical generation of steam or high temperature hot water (HTHW).  They apply knowledge of the principles and theories pertaining to combustion, heat transfer, and steam or HTHW generation in the operation of power boiler plants.  Grade 10 employees also apply a thorough knowledge of the structural and operating characteristics of single and multiple fuel power boilers and associated auxiliary and pollution control equipment or systems (e.g., computerized or microprocessor control systems, fuel handling and distribution equipment and systems, fuel firing mechanisms, feed water and boiler water treatment systems, steam and electrical pumps, pressurization systems, compressors, electrostatic precipitators, and flue-gas desulfurization systems) to properly operate, adjust, troubleshoot, and maintain the equipment and systems.  They apply a thorough knowledge of water treatment procedures and water analysis, using standard chemical tests.  They have a thorough knowledge of water treatment equipment and systems, e.g., cation/anion exchange units for demineralization of feed water.  Grade 10 operators have a thorough knowledge of chemical and physical aspects of sulfur-containing fuels (e.g., oil, coal, lignite), the chemical reactions involved in combustion, and the relationship between fuel quality and combustion efficiency.  They have: (1) a practical knowledge of environmental law and a thorough knowledge of procedures or adjustments during combustion to control pollutants in flue emissions (e.g., control combustion time, stack temperature, and excess air flow); and, (2) a thorough knowledge of the steam or HTHW distribution systems, user requirements, casualty control procedures, and how to bypass a section of the system to maintain service.  They are knowledgeable of maintenance requirements (e.g., cleaning fuel guns, lubricating equipment, and power cleaning water tubes) and procedures necessary to perform operational repairs of limited to moderate complexity, e.g., repair or replace valves, gauges, water pipes, and refractory linings.  In some work situations, operators at this level may have basic knowledge of electricity to test and replace wires, switches, and other basic electrical components.

Grade 10 operators have skill in:(1) procedures and adjustments necessary to start, operate, and maintain a power boiler facility (i.e., power boilers and auxiliary and pollution control equipment) to meet load demands and maintain efficient levels of combustion and compliance with pollution laws; (2) operating power boilers from cold starts through normal operation and hot or emergency shut downs; (3) operating and adjusting associated auxiliary and pollution control equipment; (4) reading and analyzing information from gauges, meters, recorders, analog displays, and computer generated data to determine the operational status of the facility and necessary adjustments; (5) specialized combustion techniques and adjustments to firebox variables such as fuel flow or feed, fuel/air ratio, temperature, combustion time, and over air or under air feeds to control chemical pollutants in flue gas emissions and maintain combustion efficiency; (6) setting and adjusting flame patterns in power boilers with single or multiple burners to ensure safe and efficient combustion; and, (7) adjusting various combustion settings to compensate for varying qualities or conditions of fuels.  Grade 10 operators can:  (1) stabilize boilers in a closed system when one boiler starts to go down while maintaining safe levels and efficient combustion; and, (2) make individual and sequential adjustments to a variety of controls and equipment to achieve and maintain maximum efficiency of equipment and systems being operated.

The appellant’s knowledge and skill substantially exceeds the grade 8 level but does not fully meet the grade 10 level.  Unlike the grade 8 level and similar to the grade 10 level, the appellant applies a comprehensive knowledge of many of the operational phases of power boiler plants.  He is knowledgeable of water treatment procedures and analysis, steam generation including production and distribution of HTHW and fuel systems for multiple fuel boilers including some of their auxiliary equipment, e.g., steam and electrical pumps, and performs required maintenance and operational repairs, e.g., repairing damaged cement inside the back door of boilers and replacing valves and gauges.  He is skilled in the procedures and adjustments needed to start, efficiently operate, and maintain power boilers to meet load demands, including reading gauges and making changes in combustion.  However, in contrast to the grade 10 level the appellant is not required to have knowledge of a variety of pollution control tasks and equipment associated with the operation of power boilers.  Because the primary fuel used to run the boilers is clean burning natural gas, his duties do not include operating complex pollution control equipment and applying knowledge of the procedures and adjustments needed to control pollutants generated by continually burning sulfur-containing fossil fuels, e.g., oil, coal, and lignite.  Because of the clean nature of gas, the appellant does not have to use or be knowledgeable of auxiliary equipment such as electrostatic precipitators and flue-gas desulfurization systems.  Once a month, each boiler operates for an hour using highly refined fuel oil on a test basis.  In addition, because the automated master boiler control system automatically controls operating temperature, oxygen, and boiler steam and water pressure, unlike the grade 10 level the appellant does not need to possess a thorough knowledge of the procedures or adjustments during combustion to control pollutants in flue emissions.  The appellant also does not deal with smoke or other pollutants since he operates clean burning boilers.  Because this factor substantially exceeds the grade 8 level, but does not fully meet the grade 10 level, it is properly credited at the grade 9 level.

Responsibility

Grade 8 boiler plant workers receive work assignments from a supervisor or a higher grade worker in the form of written or oral instructions.  The instructions outline the work to be performed and the methods and materials to be used.  Workers at this level are responsible for observing meters and gauges to insure proper combustion and prescribed temperatures, pressures, and emissions and for performing routine operator maintenance of equipment.  They are responsible for understanding and responding to a variety of conditions indicated by meters and gauges.  Workers are alert and recognize dangerous conditions in boilers, controls, valves, piping and other equipment inherent to boiler operations to prevent equipment damage or explosion.  They perform work in accordance with local, state, and Federal pollution control requirements.  Problems are reported to a higher grade worker or supervisor.  Work at this level is checked through observation of work methods and procedures.  A higher grade worker or supervisor is available for advice and assistance on any work problem encountered and checks to see that assignments are completed according to instructions and established practices. 

Grade 10 boiler plant operators receive work assignments from a supervisor or a higher grade operator who is in charge of the facility or work shift.  They provide written or oral instructions which may be accompanied by diagrams, drawings, operating manuals, or special facility procedures to be followed during emergencies, equipment failure, or system malfunction.  They are familiar with the total plant layout including drawings and circuit diagrams of the boilers and auxiliary and pollution control equipment, in order to locate problems and determine appropriate action necessary to maintain adequate steam or HTHW production.  As compared to the predetermined methods and procedures at the grade 8 level, grade 10 boiler plant operators make more independent decisions and judgments regarding boiler plan operations (e.g., combustion and pollution control adjustments, troubleshooting techniques, and equipment maintenance and repair procedures).  In maintenance and repair operations, they complete all work in accordance with required specifications and use a variety of standard mechanical and basic electrical processes.  Boiler plant operators at this level typically have primary responsibility for checking boilers and auxiliary and pollution control equipment to insure the operational efficiency of equipment and safety of personnel.  They take immediate action to prevent interruptions to plant operations and report all emergencies or dangerous conditions.  The supervisor or higher grade operator with shift level responsibility is usually available to provide technical assistance on difficult or unusual problems.  Work is checked through occasional observation of operational efficiency, production reports, and adherence to established operating techniques and procedures. 

The appellant’s responsibility substantially exceeds the grade 8 level but does not fully meet the grade 10 level.  Unlike the grade 8 level, he fully operates the boiler plant in accordance with accepted methods and procedures on shifts and days the supervisor is not present.  Similar to the grade 10 level, the supervisor provides oral or written instructions which sometimes include diagrams and maintenance checklists.  Like the grade 10 level, the appellant is familiar with the entire layout of the boiler plant including diagrams of the boilers and auxiliary equipment in order to locate problems and take necessary actions to maintain steam and HTHW production.  In contrast to the grade 8 level, he makes independent decisions on boiler operating adjustments, maintenance, and equipment repair in accordance with required specifications.  The supervisor checks work through observation and completion of logs describing the work done and how any abnormal conditions encountered were handled during the shift.  Although the appellant checks boilers and auxiliary equipment to insure the operational efficiency of equipment and safety of personnel, he does not check pollution control equipment.  Therefore, because the appellant’s job exceeds the grade 8 level but does not fully meet the grade 10 level, this factor is credited at the grade 9 level.

Physical Effort and Working Conditions

Since the description of these factors in the JGS is the same at both defined grade levels, these factors do not have an impact on the grade of the job and will not be addressed further.

Special Additional Responsibilities

In order to receive an additional grade for “operator in charge” responsibilities, the boiler plant operator must be working at the full performance level and must be assigned shift responsibility on a regular and recurring basis and only one operator on a shift can be assigned this responsibility.  The 5402 JGS describes special circumstances which warrant crediting one additional grade to full performance level plant operator jobs when functioning as the “operator in charge” on second and third shifts and on weekends, whether they work alone or with a small group of plant operating employees.  One operator is typically designated as the “operator in charge” of the complete plant including ancillary facilities, stand-alone, and satellite boilers which may be geographically dispersed.  The following conditions must be clearly met to warrant the crediting of an additional grade.  The “operator in charge”: (1) follows written instructions from a supervisor or the “operator in charge” on the previous shift; (2) performs additional duties that are more responsible and require a slightly higher level of skill and knowledge than full performance level operators who have a supervisor available for technical advice and guidance; (3) must have a thorough knowledge of the entire steam or hot water system and user requirements in order to locate problems and initiate immediate corrective action to maintain adequate steam or hot water production; (4) in the absence of written contingency procedures, has the responsibility to decide whether to shut down a boiler and, if so, whether equipment still in operation can handle the load or whether to fire up another boiler and attempt to bypass the trouble until corrective action has been completed; (5) determines what work must be done and has authority to approve overtime or call in “off-duty” maintenance personnel; and, (6) relays instructions to the next shift operator, including problems encountered and action taken. 

Before we proceed with evaluating the conditions above, we need to clarify the full performance level for the plant operator job because the organizational chart for the boiler plant includes Boiler Plant Operator jobs at grades 9 and 11 and shows grade 9 is the full performance level.  In 2013, the agency reviewed a vacant plant operator job and graded it at the 9 level and cancelled the grade 11 JD.  However, the remaining encumbered plant operator jobs at the grade 11 have not been downgraded because the agency is under a moratorium on implementing “involuntary change to lower grade actions related to classification issues” and we do not know when the downgrade actions will be effective.

The appellant’s job does not meet all the conditions for crediting responsibility for “operator in charge.”  The appellant is regularly assigned to a fixed shift covering daytime hours and weekends and he is at the full performance level.  The supervisor does not actually officially assign or prepare a written roster identifying the “operator in charge” nor does he verbally assign that responsibility to a particular shift worker.  Our findings disclosed the “operator in charge” is the one plant operator assigned to the shift and the operator completes the shifts’ assigned tasks.  Therefore, condition #1 is not met because it states the “operator in charge” follows written instructions from a supervisor or the “operator in charge” on the previous shift. 

Our findings indicate the appellant possesses a thorough knowledge of the steam and hot water systems at the installation to locate problems and initiate corrective action, but his “operator in charge” duties regarding those systems do not require a slightly higher level of skill and knowledge than the operators who work on other shifts.  Both the appellant and his coworkers are at the same knowledge and skill level even when acting as “operator in charge.”  Thus condition #2 is not fully met.

Our findings indicate the appellant possesses a thorough knowledge of the entire steam and hot water system at the VAMC to locate problems and initiate corrective action to maintain adequate steam and hot water production.  Thus, condition #3 is met.

Our findings indicate no written contingency procedures were developed and the appellant can shut down a boiler, respond to steam failures, and start another boiler.  However, unlike condition #4 there is a standard operating procedure (SOP) in place which he follows if needed governing actions to be taken in the event of boiler and/or equipment failures, e.g., requesting assistance from the Utility Systems Repairer Operator on shift with placing the boiler plant back into operation and contacting his immediate or second level supervisor or Chief of Engineering day or night for instructions in the event of some type of disruption taking a boiler off line.  Our findings disclosed all boiler operators in Massachusetts are required to obtain a license and keep it current in order to work in the state.  Before a license is issued, an applicant completes a training course and passes an examination.  The training course covers instruction in such topics as boiler safety, maintenance, and emergency procedures.  License renewal is every five years and the operator has to show that 30 hours of continuing education in boilers has been completed.  The appellant brings his knowledge of boilers to his job but the SOP shows he does not have to rely only on his own judgment when responding to equipment failures.  Thus condition #4 is not fully met.

As previously discussed, under condition #5 the “operator in charge” determines what work must be done on the shift and is authorized to approve overtime or call in necessary maintenance personnel.  The appellant is thoroughly knowledgeable of the steam and hot water systems and is authorized to determine the scope of work to be done to those systems in the event of failures.  He is also authorized to approve overtime in emergency situations for personnel already on site or recall personnel to perform work without obtaining supervisory approval or any other administrative clearances from installation staff.  Therefore, his job meets condition #5.

Condition #6 is met because the appellant relays instructions to the next shift operator including problems encountered and action taken.

In summary, we find that because all the conditions are not clearly met the appellant’s job cannot be granted additional credit for shift responsibility.

Summary

By application of the job grading criteria in the 5402 JGS we find the appellant’s job is properly graded at the grade 9 level.

Decision

The appellant’s job is properly graded as Boiler Plant Operator, WG-5402-9.

 

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