NFPA 110 & 111 – 2013 Editions

NFPA 110/111 Update - 2013 EditionsREJECTWater mist fire protectionLog #26, #27, #28, #297.11.2.1 Where water based fire suppression systems are installed in EPSequipment rooms or separate buildings, and the manufacturers of the EPScertify that such water based fire suppression systems cannot damage the EPSsystem hinder its operation or reduce its outputsystem,output, the water based firesuppression systems shall be designed and installed per NFPA 13, StandardFor the Installation of Sprinkler Systems or NFPA 750, Standard on Water MistFire Protection Systems.Substantiation: Because water based fire suppression systems are notexcluded as an optional method of suppression in Section 7.11.2paragraphs 1 & 2, and NFPA 13 and 750 are the primary standardsoutlining the requirements for water based fire suppression systems, theyshould be referenced to provide guidelines to the end user, AHJ anddesign firm. Water Mist has been approved and installed in a wide rangepower systemyapplicationsppgloballygy and for clarityy NFPA 750 Standardof pon Water Mist Fire Protection Systems should be included in NFPA 110 asa Referenced Publication.TC Statement: It is not plausible to expect an EPS manufacturer to certifythat a water-based fire protection system will not damage the EPS, hinderits operation, or reduce its output. NFPA 110 does not prohibit the use ofwater-based fire protection systems for fire suppression within the EPSequipment room and determination of the applicable standard to use isthe purview of the authority having jurisdiction.REJECTLog # 36Battery lighting for EPSS7.3.1 The Level 1 or Level 2 EPS and EPSS equipment location(s) shall be provided with batterypowered emergency lighting. This requirement shall not apply to units located outdoors inenclosures that do not include walk-in access.Substantiation: Many enlightened designersdesigners, so to saysay, are already doing this but the practiceshould be mandatory. This relatively slight change in wording of this passage will placeemphasis upon illumination for the actual system of disconnecting means, related protectivedevices, transfer switches, and all control, supervisory, and support devices up to andincluding the load terminals of the transfer equipment needed for the system to operate as asafe and reliable source of electric power.For the convenience of the committee, the transactions of rejections by other NFPA technicalcommittees is submitted with this proposal to supplement this substantiation and is attachedherewith Finally, this link to a video clip showing how a switchgear room goes dark after aswitchgeargexplosionpshould be evidence enough:g http://www.youtube.com/watch?v P00WE7z9tu4pyNote that the area of the explosion instantly goes dark. Without emergency lighting around theEPSS, how would rescue professionals be able to help? Note: Supporting material is availablefor review at NFPA Headquarters.TC Statement: As cited in the submitter's substantiation, providing battery-powered emergencylighting units at locations other than as currently required is a design consideration. Thesubstantiation does not support such a broad expansion of a mandatory requirement for thistype of equipment. Response to outages is part of standard operating procedures establishedby facilities and this includes provision to illuminate areas that have been put into darkness.David Stymiest, PE CHFM FASHE, 504.232.1113,DStymiest@ssr-inc.com, See NFPA Disclaimer; Copyright (c)2012 SSR, Inc.REJECTWater mist fire protectionLog #26, #27, #28, #29A.7.11.2 If a fire suppression system is used in EPS rooms orseparate buildings housing EPS equipment, consideration shouldbe ggiven to ppreaction-typeyp suppressionppsystemsypper NFPA 13Standard For The Installation of Sprinkler Systems or NFPA 750Standard on Water Mist Fire Protection Systems.Substantiation: Because NFPA 13 and 750 are standards outliningthe requirements for pre-action systems, they should bereferenced in this section to provide a standard for design andinstallation. Water Mist has been approved (FM – CombustionTurbines & Machinery Spaces) and installed in a wide range ofpower supply applications globally. NFPA 750 Standard onWater Mist Fire Protection Systems should also be included as apreaction system option.TC Statement: There are preaction-type suppression systems otherthan wet. The recommendation implies that only wet-typesystems are acceptable.REJECTCampus feeder as EPSLog # 39Under 5.1 Energy Sources5.1.5.x A dedicated feeder in a multi-building, campus-style electrical powerdistribution network shall be permitted to be used as the EPS where thenormal and emergency feeder independence and reliability is acceptable tothe AHJ.Substantiation: Many appa.org colleges and universities have large mediumvoltage distribution systems on the order of 10-100 MW – often backed up bydistrict energy systems – that can be configured to present EPS availability thatexceeds the availability of the best maintained building-level on-site generator.This resource can be used to meet life safety, business continuity andsustainability objectives the possibility of using two sufficiently independentsources is tracking in this document. Refer to related proposal on theapplication of quantitative methods for assessing power system reliability.TC Statement: Vulnerability of outside utility sources to outages due toenvironmental factors (major natural disasters) is greater than the vulnerabilityof an on-site source of alternate power installed in accordance with thisstandard. Without on-site alternate power sources, critical operation of vitalfacilities could be compromised.6

NFPA 110/111 Update - 2013 EditionsREJECTLog #43Expand NFPA 110 scopePermit this document to grow beyond its present focus as an installationdocument for the on-site generation manufacturing, installation andmaintenance industryy byy permittingpgpproposalspfor use of utilityy sourcesfor EPS in future revision cycles. [by deleting (4) from 110 exclusions DLS]1.1.3 This standard does not cover the following: (4)Utility service when suchservice is permitted as the EPSSSubstantiation: NFPA 110 needs to morph into a kind of “landing page” for allpower system reliability issues at the building premises level and quite possiblyone step up above the service point into the last mile of power distribution.State public utility regulatory authorities and the state building department andstate emergency management agencies need a vast void filled by what thisdocument could be. What other document in the NFPA universe would havegrowth potential to meet the demand for more granular power system reliabilityleading practice among these agencies? As a veteran of the scope discussionson NEC CMP-1 for the past 10 years I fully grasp how scope issues like thisopen onto a minefield of sensitivities among each of the interest groups.[CONTINUED]APRNew proposed Annex “X”Log # 34Add new Annex X: Availability and Reliability of Emergency and StandbyPower Systems[about 2 pages ]Substantiation: This material has been derived from Annex F of the 2011National Electrical Code and has been modified for application to themore common emergency and standby power systems and to moveclosely align with the IEEE Standard 493 – Design of Reliable Industrialand Commercial Power Systems, the so-called “Gold Book” - . It is verygeneral information that ought to be available to users of this documentwho deal with the far more common building emergency and standbypower systemssystems.TC Action: Add a new last sentence to A.8.1 to read: “For more detailedinformation on electrical equipment maintenance refer to NFPA 70B,Recommended Practice on Electrical Equipment Maintenance.”TC Statement: NFPA 70B-2010 contains the information provided in therecommendation and it is not necessary to repeat this information in NFPA110.David Stymiest, PE CHFM FASHE, 504.232.1113,DStymiest@ssr-inc.com, See NFPA Disclaimer; Copyright (c)2012 SSR, Inc.REJECTLog #43Expand NFPA 110 scope[CONTINUATION OF SUBSTANTIATION]My hope at this stage of the revision process is to hope for informed discussion bythe committee on thisthis. It would not be expected that this could be done by thiscommittee in a single cycle, in isolation from, say the NFPA Standards Council.But as surely as the present NFPA 110 once used to be NFPA 76A, thisdocument needs to rise to a market for it that is already there. Either thiscommittee or the NFPA Standards Council needs to approach this documentand make it ready to receive smart grid and sustainability concepts, amongothers. Interactive sources and electric vehicles with bi-directional power flowcapability that can be used for non-automatic, isolated sources of backup poweris not too far ahead of us with great potential for changing the mix of EPSsources and the configuration of the last mile of municipal power infrastructure.Accordingly, the last mile of power infrastructure will inform leading practice inbuilding premises power security.TC Statement: The committee disagrees with the recommendation andsubstantiation. A utility may choose to use this document as a reference for theirdistributed power generation facility, but it is not the intent of this committee toexpand the scope of this document to address other than on-site generation.APRNew proposed Annex “Y”Log # 35Add new Annex Y: Risk Assessment and Commissioning Based on the Criticality of theFacility or Regional Network of Facilities [about 2 pages - DLS]Substantiation: NFPA 110 needs to evolve to meet demand for more formal engineeringmodeling of power systems that backup normal power systems. This proposal,d i d fromderivedfmaterialt i l presentedt d tto ththe NFPA 7070-20112011 technicalt h i l committeesittanddrelated proposal for a new Annex X, is intended to into provide the broad contours ofa “landing page” for the design of all types of backup power systems. The classifyinggovernmental agency having jurisdiction would benefit from a gradient level ofcriticality for the facilities that has specific operation guidelines. It provides theframework by which the jurisdiction can evaluate the criticality of all of their facilitiesrelative to each other and thus provides a means to ensure the most critical systemsare recognized as such and have the resources allocated to them so that they areavailable when needed to deliver emergency services and provide for disasterrecovery. Without a gradient scale, fewer resources would be available to the mostcritical systems because all of the critical facilities would require the same amount ofresources. The requirement for the various types of critical systems needs to alignwith the importance of the system to the protection of life and property. A set ofspecific operational requirements for the various levels of criticality is needed toprovide design criteria and for consistent application. A gradient level of riskassessment with probabilistic modeling provides a quantitative method to ensure themost critical systems have been designed sufficiently robust so that they areavailable when needed to deliver emergency services and provide for disasterrecovery.TC Statement: The committee action on Proposal 110-49 (Log #34) meets the intent of therecommendation.7

NFPA 110/111 Update - 2013 EditionsAPReliability calcs & IEEE 493ROP Log #41, then ROC Log # 6Add new Annex material as follows:A.1.4.1 Assignment of degree of reliability of therecogni ed EPSSrecognizedEPSS, or equivalencyeq i alenc of othermethods, depends on the careful evaluation ofthe variables at each particular installation. Onesource of information on quantitative methods forassessing power system reliability is ANSI/IEEE493-2007, Recommended Practice for the Designof Reliable Industrial and Commercial PowerSystems.Substantiation: This is an adaptation of a new provision in Article 701 of the 2011 NEC. Members of thatcommittee agreed that this resource offered a way to convey opinions about power security into the realm ofscience. Very often, the AHJ is put in the position of having to assess the equivalency of an ArchitectEngineer’s EPSS design. It would be reasonable for the AHJ to ask for reliability calculations, much as heor she might ask for short circuit or ampere demand calculations. Unfortunately, the training of manyelectrical engineers does not include formal, reliability analysis so reference to this document will provide astarting point for establishing equivalencies.TC Statement: There are documents other than the recommended IEEE standard that address the reliability ofpower systems. The recommendation implies that this is the only relevant reference document.REJECTLog #37AHJ okay for EPSS w/NPCONTINUATION OF SUBSTANTIATIONNot only is the existing language costly (and, in the parlance of the currentg– “unsustainable” --there are manyy reasons to have the normal powerpzeitgeistswitchgear and the EPSS at least within eyeshot of one another; not the least ofwhich is the ability for electricians to verify the energization status of the normalpower switchgear while performing maintenance or operating EPSS. In otherwords, some jurisdictions recognize that there are safety concerns about havingthe two separated.The 1000 ampere threshold asserted here seems to be derived from flashboundaries that appear in other NFPA documents. While I have no data to proveit, it seems plausible that there is the risk in the likelihood of arc-fault damage tobe weighed against the likelihood of human error in not being able to verify theoperating conditions of both power sources simultaneously even when statusappears on transfer switch controls .TC Statement: This requirement is focused on protecting the EPSS equipment fromexposures. Section 1.4.1 provides the AHJ with discretion to accept designs thatprovide equivalency.David Stymiest, PE CHFM FASHE, 504.232.1113,DStymiest@ssr-inc.com, See NFPA Disclaimer; Copyright (c)2012 SSR, Inc.REJECTLog #37AHJ okay for EPSS w/NPUnless otherwise permitted by the AHJ, based upon site specificfactors such as architectural configuration, relative distancebetween equipment,q p, occupancy,py, typeyp or conditions of maintenanceand supervision, Level 1 EPSS equipment shall not be installed in thesame room with the normal service equipment, where the serviceequipment is rated over 150 volts to ground and equal to or greater than1000 amperes.Substantiation: While the committee’s intention to assert isolation between normalpower and emergency power switchgear has merit as good design practice, itmust also be aware that many jurisdictions simply ignore this requirementbecause it drives up architectural costs when,when for exampleexample, separate rooms mustbe built for, 750 kVA service switchgear and 150 kVA Level 1 switchgear. At480V, 1000 amperes is less than 1000 kVA – meaning that this requirementaffects a significant installed base in commercial and institutional buildings whichusually meet the Level 1 criterion.REJECTLog #38Permit EPSS with NPAfter7.2.2 Level 1 EPSS equipment shall not be installed in the same room with thenormal service equipment, where the service equipment is rated over 150volts to ground and equal to or greater than 1000 amperesamperes.Add text to read as follows:7.2.2.x (NEW) EPSS distribution equipment and transfer equipment shallbe permitted in the same room as the normal service disconnect whenthe conductors for each system are not located within the samecabinet, enclosure or vertical switchboard section as the servicedisconnecting means or normal source feeder disconnecting means.Substantiation: This proposal is derived from Mr. Manche’s comment on theaffirmative in the last revision cycleyand strikes me as a well-reasonedstatement. I could not track it any further in the development process so I amputting it out there for more discussion For context, the entire proposal isduplicated here for the convenience of the committee:TC Statement: Regardless of the equipment orientation, it is the intent of thisrequirement to separate the Level 1 EPSS equipment from the normalservice equipment to achieve a higher degree of reliability and protectionfrom fire hazards.8

NFPA 110/111 Update - 2013 EditionsREJECTLog #1Engine fluid lab analysis(no wording provided)Recommendation: Similarly to diesel fuel, lubricating engineoil and coolants in power trains, such as diesel engines inemergency generators that are infrequently operated, aresubject to contamination other than normal usage. It isrecommended that a laboratory analysis schedule of allfluids be established with periodic sampling and testing todocument and establish engine wear patterns for life cyclepredictions and also as an aid in prediction of pendingfailures.failuresSubstantiation: [See next slide]APPFuel maintenance programLog #3Recommendation:7.9.1.2 Fuel system design shall provide for a supply of clean fuel toprime mover by documentation of a fuel maintenance program thatincorporates periodic centrifuge cleaning/polishing with highpressure tank agitation and or mechanical tank cleaning withauxiliary filtration, in addition to sampling by qualified personnel forlaboratory analysis of diesel fuel.7.9.1.3 Tanks shall be sized so that the fuel is consumed with in thestorage life, or provisions shall be made to centrifuge clean/polish andlaboratory test,test or replace stale fuel with clean fuelfuel.A.7.9.1.3 Fuel maintenance Filtration and water separators can removecontaminates and water returning fuel to conditions where it will providereliability and efficiency for standby generators to protect primemovers' injection equipment when called upon in emergencyconditionsDavid Stymiest, PE CHFM FASHE, 504.232.1113,DStymiest@ssr-inc.com, See NFPA Disclaimer; Copyright (c)2012 SSR, Inc.REJECTLog #1Engine fluid lab analysis(no wording provided)Substantiation: Scientific data should be used in today's progressivemaintenance programs for critical emergency generators. Pendingfailures wear patternsfailures,patterns, and replacement of units can and should bedetermined by scientific laboratory analysis of fluids used in dieselgenerators. Oil and coolant laboratory analysis can predict pendingfailures and repla

List major NFPA 111-2013 proposals Describe NFPA 110 proposers’ rationales for selected major proposals Describe NFPA 111 proposers’ rationales fltdj lfor selected major proposals Note: We will discuss topics and rationales, we will not read the slides. NFPA Disclaimer Alth