m e m o r a n d u m€¦ · for correlation with the actions taken on proposals throughout the nec,...

National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 • Fax: 617-770-0700 • www.nfpa.org

M E M O R A N D U M TO: Members of the NEC-Code Making Panel 13 FROM: Jean O’Connor DATE: March 9, 2012 SUBJECT: NFPA 70 ROP Final Ballot Results (A2013 Cycle) The March 8, 2012 date for circulation changes and final receipt of letter ballots has passed. In accordance with the NFPA Regulations Governing Committee Projects, the attached report contains the number of members eligible to vote, the names of principals whose ballots were not returned, and the reasons for negative, affirmative and abstaining comments. Attachment: Final Ballot Results Report

Thursday, March 8, 2012Document # 70

Final Ballot Results Report for NEC-P13 Proposals

13-1 Eligible To Vote:18 Affirmative: 18 Negative: 0 Abstain: 0 Not Returned: 0

Entire Document (Log # 1170l )


Entire Document (Log # 921l )


100.Battery System (New) and 480.2 (Log # 1606 )


100.Emergency Systems (New) and 700.2 (Log # 1613 )


100.Nominal Battery Voltage (New) and 480.2 (Log # 1605 )


100.Phase Converter (New) and 455.2 (Log # 1604 )


100.Sealed Cell or Battery (New) and 480.2 (Log # 1608 )


100. Storage Battery (New) and 480.2 (Log # 1607 )


445.11 (Log # 2682 )

Affirmative with Comment

Degnan, J. Field marking of generators for permanent installations is not necessary, but does no harm. Field marking of rental units orportable generators that are used in multiple applications may or may not be accurate. If the NEC is going to require field marking it should alsorequire verification of the indicated marking prior to application.

Little, L. We agree with the affirmative comments by Mr. Degnan and Mr. Ode.

Ode, M. The last sentence in the Panel Action text should be moved to the last sentence of the PanelStatement as follows: "CMP-13 does not accept the proposed requirement for marking the location of thegenerator bonding which may be inaccessbile in some cases." since it is not part of the actual text to beinserted as text into the NEC.


445.11 (Log # 2932 )

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445.12 (Log # 2643 )

Negative

Brown, J. The panel's action does not meet the submitter's intent and this proposal should have been rejected. The inclusion of “overload” inthe section title does not address his concerns for short-circuit protection. The term “Overload” does not need to be included in the title since thepresent title “Overcurrent Protection” already encompasses overload protection, as the submitter of this proposal has stated.

Little, L. This action is not necessary and is confusing a well defined term. The term "overcurrent" is definedin Article 100 and clearly includes "overload." Adding the term "overload" to the section title does not addclarity since the existing title is "overcurrent." Combining these two terms for a new section title "Overcurrentand Overload Protection" infers that overcurrent protection is not overload protection.The submitters proposed revision was directed at adding "short circuit" into 445.12(A). How does adding theterm "overload" into the section title meet the intent of the submitter?


445.16 (Log # 1158 )


445.17 (New) (Log # 425 )


Little, L. For correlation with the actions taken on proposals throughout the NEC, the reference to "600 volts" should be revised to "1000volts."

Ode, M. While I agree with the Panel Action, the existing text has an errata that should be fixed as part of the revision in the proposal. In thelast sentence, the word "and" should be changed to "through" read as follows: The higher horsepower rating of Table 430.247 through Table430.250 shall be used whenever the generator selection is between two ratings.


445.17 Exception (New) (Log # 502 )


Little, L. For correlation with the actions taken on proposals throughout the NEC, the reference to "600 volts" should be revised to "1000volts."

Ode, M. See my comment on Proposal 13-14.


445.18 (Log # 480 )


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Little, L. The action to accept in principle should be modified as follows:445.18 Disconnecting Means Required for Generators. Generators shall be equipped with

disconnect(s), lockable in the open position, by means of which the generator and all protectivedevices and control apparatus are able to be disconnected entirely from the circuits supplied bythe generator except where all of the following conditions apply:

(1) The generator is listed.(2) The driving means for the generator can be readily shut down, rendered incapable of

restarting and is lockable in the OFF position in accordance with 110.25.(3) The generator is not arranged to operate in parallel with another generator or other source

of voltage.Informational Note: See UL 2200 Standard for Safety of Stationary Engine GeneratorAssemblies.

The action to accept in principle proposal 13-111 will permit the installation of a standbygenerator without a disconnecting means installed at any point from the generator terminals tothe equipment supplied. A means to simply shut down the driving means for the generator,such as a diesel engine, is all that will be required. The panel action to accept proposal 13-111is based partially on UL 2200 which mandates a means to stop the driving means, preventrestarting and requires this means to be lockable in the OFF position. Not all generators arelisted. The above modifications are needed for the safety of all installer/maintainers. It shouldbe noted that OSHA does not permit an emergency stop button to be used to lockout electricalequipment. See CFR 29 1910.333(b)(2)(ii)(B). If a Nationally Recognized Testing Laboratory(NRTL) has listed such a device for lockout/tagout, it may be considered by OSHA as anacceptable means of lockout/tagout.

The reference to 110.25 correlates with the action on proposal 1-130.

13-16a Eligible To Vote:18 Affirmative: 18 Negative: 0 Abstain: 0 Not Returned: 0

445.19 (Log # CP1304 )


445.19 (Log # 501 )

Negative

Ode, M. This proposal should have been a reject instead of an accept in principle since Proposal13-16a deleted Section 445.19.


Little, L. We agree with the affirmative comment by Mr. Ode.


445.20 (New) (Log # 2461 )

Negative

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Caron, D. The panel statement does not address the submitter's substantiation. Large generators, arranged tooperate in parallel to serve loads in hospitals and other occupancies, are very common. The conductors,controls and equipment required to parallel the generators, including the electrically operated circuit breakersand the common bus in the paralleling switchgear, should be defined or recognized in some way in Article 445as a system. Rules for applying ground fault protection (700.6(D)) and selective coordination (700.27) areoften misapplied, or as the submitter has indicated, cannot be applied.


445.20 (New) (Log # 3364 )

Negative

Czarnecki, N. This proposal seeks to add GFCI protection to all 125V generator outlets without any substantiation that an issueexists at all levels. In order to establish a functional GFCI configuration on the generator, the generator is forced to be of the bondedneutral variety. Therefore, this proposal would have the effect of eliminating floating neutral generators used to power structures,non-separately derived standby systems, and transfer switches for non-separately derived systems. Eliminating such equipment willnot enhance safety, but obsolete safe infrastructure already in place. Enhanced safety has not been accomplished and potentiallycompromised with users defeating the system by removing grounding connections to find a means to get power on in their home.Note: Supporting Material is available for review at NFPA Headquarters.

Degnan, J. The submitter did not present any new information regarding the different safety issues associated with portable generatorgrounding that wasn't available in 2008, when this same proposal failed to gain the required acceptance of the panel.


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Little, L. The following comment is written to address the negative comment by Mr.Czarnecki:

We agree that acceptance of this proposal will require all portable generators to be of thebonded neutral type. There are many presently in production.The sketch provided by Mr. Czarnecki with the negative ballot comment clearly reveals hisconcern, which is the viability of 15/20 ampere, 125-volt, single pole transfer switches. Theywill not work through a GFCI. A two pole transfer switch would be required because a portionof the neutral current would flow over the equipment grounding conductor where a single poletransfer switch is used causing the GFCI to open.

We strongly disagree that the elimination of the floating neutral type generator will remove“safe infrastructure already in place.”The infrastructure already in place represents serious safety concerns along with clear andindisputable NEC violations. The issue at the core of this proposal is the use of portablegenerators to supply power to a dwelling unit when there is a loss of power. This occursregularly across the country when there is a weather related event that causes a loss of power.Homeowners use portable generators to supply power to sump pumps, heaters, lighting, wetvacuums, refrigerators, freezers and other appliances during weather related events. There are15/20 ampere, 125-volt, single pole transfer switches on the market and their use allows thehomeowner to supply power to the selected branch circuit by plugging the male end of anextension cord into a receptacle outlet on the generator and by plugging the female end of theextension cord into a flanged outlet on the 15/20 ampere, 125-volt, single pole transfer switch.Once this connection is made, we no longer have a floating neutral generator. We now have agrounded system through the solid connection to the service supplied neutral conductor. Thismeans that all other receptacle outlets on the generator now have potential to ground withoutGFCI protection. The homeowner will utilize every receptacle outlet in these weather relatedevents, and without GFCI protection, serious safety concerns exist. Where a generator is usedin this manner it is covered by the NEC, it is part of the “premises wiring” as defined below:

Premises Wiring (System). Interior and exterior wiring, including power, lighting, control,and signal circuit wiring together with all their associated hardware, fittings, and wiringdevices, both permanently and temporarily installed. This includes (a) wiring from the servicepoint or power source to the outlets or (b) wiring from and including the power source tothe outlets where there is no service point.

Such wiring does not include wiring internal to appliances, luminaires, motors, controllers,motor control centers, and similar equipment.

A portable generator supplying a dwelling unit through a transfer switch is indisputably partof the premises wiring and is covered by the NEC. The requirements in 210.8 and 250.20(B)apply.

We understand and are sympathetic to the concerns of Mr. Czarnecki. However, we must takeaction to prevent exposure to shock hazards. We cannot look the other way because of theimpact on a particular product when it comes to safety. The claim that this revision will drivehomeowners/users to “defeat the system by removing grounding connections” is without meritbecause we presently have both types of generators readily available. When a homeowner/ userdecides to buy a new portable generator, they will go online or to a local home improvement

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store. A simple trip to Lowes or Home Depot reveals that many of the portable generatorsavailable already have GFCI type receptacles. The Purpose of the NEC is the “practicalsafeguarding of persons and property from hazards arising from the use of electricity.” That isthe intent of this proposal.

We need to get it right.

Paulsen, S. While I agree with the intent to provide additional personal protection I also feel that this now aproduct standards issue. The standard for generators should be updated to include this requirement. When Iread the proposed Rule it could imply to add ground-fault circuit interrupter protection to existing generatorsas well. This could result in certified generators being modified in the field and thus voiding the existingcertification.


455 (Log # 3302a )

Negative

Rodriguez, A. The primary function of the conductor presently defined as an "equipment grounding conductor" is actually abonding function. The grounding electrode conductor grounds systems and equipment. Accepting this change will help increaseusability and understanding of the associated requirements. The existing term and the associated terms grounded and bonded arefrequently misunderstood and misused by both new and experienced NEC users.

Spina, M. Similar proposals have been presented in the past and have been rejected. Reasons given often relate to cost,significant changes in documentation required, or the fact that knowledgeable people know what this conductor is used for. Cost anddocumentation changes should never be an argument where safety is concerned. Further, not all electrical practitioners areknowledgeable in the main intent of this conductor. There is no justification for retaining an incorrect and potentially hazardouselectrical installation just because we have used this definition for many years.The intent of the proposed change is to provide a descriptive name to a construction element that has resulted in muchmisunderstanding with possible hazardous operating conditions in electrical installations. The use of the term ”grounding” impliesthat grounding is its principal function. Although grounding may be desirable, providing an effective fault current path (i.e. bonding)is and should be the emphasis. There are many who feel that a connection to a water pipe (which may or may not be a good ground)meets the needs of equipment grounding.There are two conductors described in the Code performing the same function but named differently. The “bonding jumper” is a

short conductor that insures the electrical integrity of enclosure to raceway. The longer conductor, intended to provide a lowimpedance path to the source, is named a “grounding” conductor instead of its real function as a “bonding” conductor.Technically, the definition in Article 100 may be adequate for Panel members and those that teach. Practically, the definition is

confusing if the terminology does not fit the function performed. The equipment bonding conductor, as it should be called, providesits primary function whether or not it is grounded. For a grounded system, it is grounded because the system is grounded. For anungrounded system, it is grounded to limit the voltage due to a lightning strike or contact with a higher voltage system.Changing the name will assist in educating electricians into the “why” they are installing a conductor that needs to be continuous allof the way back to the source.


480.xx (New) (Log # 2996 )

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480.xx (New) (Log # 3007 )


480.xx (New) (Log # 3008 )


480.1, Informational Note (New) (Log # 3009 )


480.2 (Log # 2241 )


480.2.Cell (New) (Log # 2989 )


480.2.Container (New) (Log # 2990 )


480.2.Electrolyte (New) (Log # 2991 )


480.2.Intercell Connector (New) (Log # 2992 )


480.2.Intertier Connector (Log # 2993 )


480.2.Nominal Battery Voltage (Log # 2994 )


480.2.Terminal (New) (Log # 2995 )


480.4 and 480.5 (Log # 2997 )


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Little, L. Further modifications to this section should be considered. The following proposed revisions werein a proposal not received by NFPA staff that was developed by a joint effort of the NEC Task Force of theTechnical Correlating Committee and the IEEE Stationary Battery Committee.The section is retitled and subdivided as follows:

480.5 DC Disconnect Methods(A) Disconnecting Means. A disconnecting means shall be provided for all ungrounded conductors derived

from a stationary battery system with a nominal voltage over 50 volts. A disconnecting means shall be readilyaccessible and located within sight of the battery system.(B) Remote Actuation. Where controls to activate the disconnecting means of a battery are not located within

sight of a stationary battery system, the disconnecting means shall be capable of being locked in the openposition in accordance with Section 110.25.(C) Busway. Where a DC Busway system is installed, the disconnecting means shall be permitted to be

incorporated into the busway.(D) Notification. A label shall be installed on or adjacent to the disconnect containing the maximum availableshort circuit current. The label shall be placed in a conspicuous location near the battery if a disconnect is notprovided.Informational Note: Battery equipment suppliers can provide information about short circuit current on anyparticular battery model.

645.10(A) requires remote activation for disconnects serving ITE rooms. The disconnect serving the ITEroom must be capable of being locked open to prevent the remote actuation from occurring when it willjeopardize safety of personnel.

DC busway is common in large UPS installations in which there are multiple strings of batteries. Each stringis connected in series to create the necessary dc voltage and each string has a disconnecting means &/orovercurrent protective device. The strings are connected in parallel to a common dc bus which may also havea disconnecting means. The individual string disconnects allow manual disconnecting so that maintenance canbe performed on a redundant battery string while the remaining battery strings support the load. It alsofunctions as an OCPD to prevent the energy from other strings from feeding into a faulted cell in one string.The disconnect on a DC busway system allows for a single point of shutdown for the entire dc supply.

The stored energy in a battery system is a potential hazard to personnel maintaining the system. The labelingrequirement attests this hazard and aids in determining the arc-flash protection boundary and required PPE.


480.5 (Log # 52 )


Ode, M. In the last sentence in the Panel Statement, change the word "in" to "with" for clarity.


480.5 (Log # 620 )


480.5(A) and (B) (New) (Log # 1076 )

Negative

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Little, L. The proposed revision to require that the disconnecting means be installed "as close as practicable"is enforceable. The term "practicable" with reference to distance is used throughout the NEC and has beenenforced by AHJs for decades. This proposed revision mirrors the present requirement in 240.21(H), whichrequires overcurrent protection to be installed as "close as practicable" to the battery terminals.

Spina, M. A) 240.21(H) permits overcurrent protection for battery conductors to be installed as close as practicable.Inclusion of a similar statement here would harmonize the requirements.B) NFPA 70E-2012 “Table 130.7(C)(15)(b) Hazard/Risk Category Classifications and Use of Rubber Insulating Gloves andInsulated and Insulating Hand Tools — Direct Current Equipment” requires determining the available arcing current to select PPEnecessary for protection of employees.

he arcing current depends on the maximum short circuit from battery system. Without knowing what the available short current is,employees have no way of selecting required PPE for protection from the arc flash hazard.The only way to determine the maximum short circuit available from the battery is from the manufacturer. The optimum time to

obtain this value is during the initial installation. Without this information, proper sizing of disconnect switch may not be feasible.This requirement for posting of short circuit current for batteries is similar to the requirements in 110.24 for service equipment to

comply with 110.9 and 110.10.


480.7 (Log # 2998 )


480.8(C) (Log # 2999 )


480.9(A), Informational Note (New) (Log # 53 )


480.9(C) (Log # 119 )


480.9(C), Informational Note (New) (Log # 3001 )

Negative

Degnan, J. The note provides valuable information and should be left in. While the panel statement is true, applying it universally to the NECwould result in the removal of many informational notes.

Little, L. The panel statement is incorrect. The proposed informational note is designed to inform the codeuser that additional space may be required. Where adequate space is not provided to permit the hoisting,removal or replacement of batteries, serious safety concerns exist.


480.9(C)(1) and (2) (New) (Log # 3000 )

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480.9(D) (New) (Log # 3002 )


480.9(D) (Log # 3003 )


480.9(E) (Log # 3004 )


480.9(F) (New) (Log # 3005 )


480.9(X) (New) (Log # 3006 )

Negative

Little, L. This proposal should have been accepted. The panel statement to reject agrees with the proposedtext. The panel states that a requirement for illumination of batteries belongs in Article 480. The panel alsoagrees that luminaires should not be located directly above batteries.


480.11 (New) (Log # 2242 )


695.1(B) (Log # CP1300 )


Caron, D. See my comment on Proposal 13-55.


695.1(C) (New) (Log # 3366 )


695.2 (Log # 1660 )


695.2.Fire Pump - Sprinkler Pumps for Residential Homes (New) (Log # 401 )


Ode, M. The submitter did not provide the proposed text or wording in the recommendation in this proposal in accordance with 4.3.3(c) of theNFPA Regulations Governing Committee Projects. NFPA rules require the wording to be added or revised and how the text in the NEC should berevised. Residential fire pumps are already covered by Article 695 in the NEC.

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695.2.On-Site Standby Generator (Log # 1271 )


695.3(A)(1) (Log # 497 )


695.3(A)(1) (Log # 611 )


695.3(C)(1) (Log # 549 )

Negative

Caron, D. The panel action, the new text in 13-48a (695.1(B)) and new text in 13-55a, partially meets theintent of Proposal 13-55. Transfer equipment in the main electric room of a building that is part of a multi-building campus-style complex, can manually or automatically switch from a feeder supplying the building, toa back-up feeder within the main electric room. A single feeder to the pump room would be considered areliable source because of the back-up feeder by NFPA 20 9.2.2(4). The panel statement is not consistent withNFPA 20 language in that NFPA 20 would not require an additional alternate source to the pump room, asrequired by 695.3(C)(2).


Ode, M. The last sentence in the Panel Statement (The Panel Action on 13-48a meets the intent of the submitter) is incorrect. Proposal 13-48adeals with a clarification of Article 695 coverage of the installation of pressure maintenance pumps and transfer equipment upstream of the firepump transfer switch. Proposal 13-55 deals with feeder sources for multi-building campus-style complexes.


695.3(F) and 695.3(G) (Log # 3532 )



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Czarnecki, N. Add the following to 695.3(F):

Overcurrent Device Selection. An instantaneous trip circuit breaker shall be permitted in lieu of the overcurrent devices specified

in 695.4(B)(2) provided it is part of a transfer switch assembly listed for fire pump service.

Currently, the NEC only permits the use of an instantaneous trip circuit breaker if provided as part of a listed combination motor

controller as specified in 430.52(C)(3). The operating characteristics of an instantaneous trip circuit breaker lend themselves verywell to the overcurrent protection permitted between the fire pump power source and the fire pump controller or the fire pumptransfer switch. Such overcurrent protection is sized to provide only ground fault and short circuit protection for the fire pump motorcircuit. It does not provide motor overload protection. Overload protection for the fire pump motor is provided by the circuit breakerin the fire pump controller. This arrangement prevents opening of the overcurrent protective device permitted between the fire pumppower source and the fire pump controller or the fire pump transfer switch in the event of a motor overload. If this overcurrentprotective device were to open, it may not accessible for immediate resetting and thus, render the fire pump motor inoperable. If thefire pump motor experiences an overload condition causing breaker tripping, it is desirable to have the fire pump breaker trip becauseit is easily located and reclosed to allow attempts to restart the fire pump motor during a fire event. Fire pumps can be temporarilydistressed and one or more attempts at restarting can result in continuous running of the pump motor if the overload condition nolonger exists. Instantaneous trip circuit breakers do not provide overload protection which is the required performance for theovercurrent protection permitted between the fire pump power source and the fire pump controller or the fire pump transfer switch.The magnetic trip setting of an instantaneous trip circuit breaker can easily be adjusted to provide the operating characteristics forovercurrent devices as specified in 695.4(B)(2). More importantly, an instantaneous trip circuit breaker does not need to be sized aslarge in amperes as other protective devices already permitted. Such oversizing is necessary to prevent their overload trippingcharacteristics from overlapping those of the fire pump circuit breaker. It is recognized that an instantaneous trip circuit breaker isintended to be a factory installed product. This is ensured by including the requirement that it shall be provided as part of a transferswitch assembly listed for fire pump service.


695.4(B)(2)(a) (Log # 1530 )


Ode, M. The Panel Statement should be revised as follows: CMP-13 notes that Proposal 13-58 does not strike the original text in (1) butprovides new text based on the NFPA 20 document as an alternative to the existing text in the NEC.


695.4(B)(2) (Log # 2639 )


695.4(B)(2) (Log # 2640 )


695.4(B)(2)(a) (Log # 2738 )


Ode, M. See the affirmative statement in Proposal 13-56.


695.4(B)(3)(a) (Log # 321 )


695.4(B)(3)(b) (Log # 326 )

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695.4(B)(3) (Log # 844 )


695.5 (New) (Log # 1496 )


695.5(B) (Log # 1531 )

Negative

Czarnecki, N. The assertion that NFPA20 does not allow for the alternate method of overcurrent protection for transformers, simply because itdoes not specifically address the issue, is unsupportable.


695.5(C)(2) (Log # 1532 )

Negative

Czarnecki, N. The assertion that NFPA20 does not allow for the alternate method of overcurrent protection for transformers, simply because itdoes not specifically address the issue, is unsupportable.


695.5(C)(2) (Log # 1673 )


695.6(A)(2)(d)(1) (Log # 1118 )

Negative

Ode, M. The Proposal did not provide any technical substantiation for the change from 2 inches of concrete in theexisting NEC text to 4 inches of concrete. UL does not list concrete by itself for a fire rating so any UL fire ratedassembly would involve a complete assembly of building materials, often including concrete and other materials. Thereare many different factors that can affect heat transfer, other than the thickness of concrete. Pre-stressed concrete has adifferent heat transfer ratio than lightweight concrete, steel reinforcement within concrete will affect heat transfer, andthe type of aggregate used within the concrete will also affect heat transfer. The NFPA Fire Protection Handbook statesthe following: “Reinforcing steel can also affect the amount of heat transfer that can occur within the concrete floor orwall." Concrete has a low thermal conductivity and a low thermal capacity. One of the more significant factors indetermining the thermal characteristics of reinforced concrete is the type of aggregate used in the concrete and can varythroughout the United States. Concrete in direct contact with earth will have a different heat transfer than concreteinstalled as a wall or floor ceiling installation for multiple floor locations. Moisture content of the concrete will affectheat transfer. Furthermore, lightweight concrete has much different heat transfer rates than regular, reinforced, or pre-stressed concrete. The submitter could have provided a Fact Finding Study on the different types of concrete that couldbe used, the recommended thickness, and addressed the variables with the amount of heat transfer for each application sothe Panel could act on the technical merits for this change, rather than just guessing at a depth of concrete. The 2-inchconcrete thickness has been used for many NEC cycles to provide physical protection with some limited protection fromheat transfer and should not be changed without proper technical substantiation for this change.

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695.6(B) (Log # 10 )

Negative

Degnan, J. While test data shows that 2" of concrete fails to protect when subjected to a fire for 2 hours, fire isn't the only consideration. Insome egress scenarios, concrete encasement may offer physical protection that would prove more valuable than a system only designed for 2 hoursfire.

Ode, M. See the Negative Statement in Proposal 13-67.


695.6(D) (Log # 141 )


Little, L. Electrical metallic tubing (EMT) has been proven as an effective ground fault path. See the GEMIresearch study or the data in the Soares grounding book.


695.6(D) (Log # 702 )


695.6(D) (Log # 1529 )


695.6(D) (Log # 1828 )


695.6(D) and 695.14(E) (Log # 2419 )


695.6(D) and 695.14(E) (Log # 2445 )


695.6(D) (Log # 2641 )

Negative

Savage, Sr., M. The submitter’s substantiation states that EMT with set screw connectors would not be an acceptable method of providing aGF return path and would require a separate EGC. However, under 250.118 EMT is judged to be an acceptable (FMC is required to have listedfittings per this section, no mention of EMT) EGC and no material was presented to show the inadequacy of EMT as a GF return path.


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Czarnecki, N. The substantiation contains an incorrect reference to electrical metallic tubing (EMT) with set-screw fittings as anexample of a raceway that is not capable of conducting sufficient ground-fault to open the overcurrent protective device. The GeorgiaTech research study on grounding referred to in the Soares Book on Grounding validates that EMT with set-screw fittings andinstalled in accordance with the NEC is a proven equipment grounding conductor in accordance with the requirements of Article 250.Effective February 1996, UL 514B, the Standard for Safety for Conduit, Tubing and Cable Fittings required that all EMT fittings besubjected to a current test to determine if the EMT and the interface between the EMT and the fitting can effectively carry faultcurrent, in order to permit operation of the overcurrent device and terminate fault current flow. In order to carry a UL listing, EMTfittings must pass this test. Article 358 (Electrical Metallic Tubing) requires the use of listed fittings.

Degnan, J. If vibration from the pump compromises the ground path offered by the raceway, and a subsequent pump motor ground faultoccurs, its possible to energize the motor frame. Other than this limited scenario, the entire ground return path would need to be examined, not justthe portion between the controller and the motor.



695.6(D) and 695.14(E) (Log # 2843 )


695.6(D) (Log # 2913 )


695.6(E) (Log # 2669 )




695.6(I) (Log # 142 )


695.6(J)(5) (New) (Log # 1350 )


695.7(A) (Log # 3020 )


695.7(B) (Log # 703 )


695.12(G) (Log # 143 )

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695.14(E) (Log # 2808 )


695.14(F) (Log # 11 )

Negative



695.14(F)(1) (Log # 1119 )

Negative



695.14(G) (Log # 144 )


700.1 (Log # 1469 )


700.2 (Log # 3533 )


Degnan, J. It would be helpful to clarify in the Informational Note that NFPA 99 no longer uses the term "emergency for the life safety andcritical branches of the essential electrical system.


700.2 Luminaire, Directly Controlled (New) (Log # 1395 )


700.2 and 700.10(B) (Log # 3312 )

Negative

Degnan, J. Reasoning for the negative vote is in the text of the proposal.


700.2.Emergency Systems (Log # 747 )

Negative

Degnan, J. The figure is not clear where the delineation is betwen normal and emergency.


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Caron, D. The figure for this Proposal (13-91) should be modified per figure (13-91 Attachment 1 Figure 700-2) and the figures for Proposal 13-130, 13-141 and 13-156 should be similar for consistency. In addition, thefigure (13-91 Attachment 2 Figure 695-3(D)) should be added to 695.3(D) for fire pumps when an on-sitestandby generator is used for the alternate source.

****Insert Two Figures Here***

Czarnecki, N. The changes the Panel suggested could create some level of confusion. Perhaps some additional detail in the comment stagecould explain the intent of the figures, the meaning of the symbology, and any requirements the figures were not intended to define.


700.2.Emergency Systems (Log # 1272 )


700.2, 700.3(E), 700.12, Informational Note (Log # CP1302 )


700.3(F) (Log # 2526 )


700.4(A) and (B) (Log # 1448 )


Ode, M. Revise the last sentence in the Panel Statement to read as follows: The entire system, based on Section 700.3(A), may be done yearlyor every other year, as determined by the AHJ.


700.5(C) (Log # 1011 )

Negative

Brown, J. It is recognized that increasing voltage from 600 volts to 1000 volts may be applicable to specific installations. However, adequatetechnical substantiation has not been provided to support the change in this Article.


700.5(E), 701.5(D), and 708.24(E) (Log # 2263 )


Ode, M. Listed and identified emergency automatic transfer switches, as required by 700.5(A) and (C), are already required by UL 1008 to bemarked with the types of overcurrent protective devices that are required for protecting the transfer switches and with the short circuit current ratingof the transfer switch. The term “withstand rating” is not used in the requirements in UL 1008 but the rating in “available rms symmetrical shortcircuit current” is used in the Standard.

17




700.7(B) (Log # 906 )


700.8 (New) (Log # 3330 )


Little, L. Surge protective devices have proven to provide benefits for components and systems against thedamages of voltage surges, but the substantiation for this proposal does not document that such protectionwould specifically benefit emergency systems.


700.9(B)(5) (Log # 63 )

Negative

Degnan, J. Reasoning for the negative vote is in the text of proposal 13-90, which was updated for this code cycle.


700.9(B)(5)(b) (Log # 64 )

Negative

Degnan, J. Further examination of that paragraph the 2011 NEC 700.10(B)(5)(b) reveals that it should be rewritten to clarify its intent. Theparagraph states that it shall be permitted to not have overcurrent protection, the exception states that it shall be permitted to have it. I intend tosubmit a comment suggesting that the proposal be accepted in principle by changing the text to "...multiple feeders with or without overcurrentprotection at the source." and eliminating the Exception.


700.9(D)(1) (Log # 12 )

Negative



700.10(B) (Log # 3313 )

Negative

Degnan, J. The reason for the no vote is in the text of the proposal.


700.10(B)(5) (Log # 496 )


700.10(B)(5) (Log # 2131 )


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Degnan, J. If the panel doesn't support removing the paragraph as in proposal 13-90, improving the paragraph's language and clarity isappropriate.


700.10(D) (Log # 1116 )


Caron, D. The first level subdivision should be further revised as follows:(D) Fire Protection. Emergency systems shall meet the additional requirements in (D)(1) through (D)(3). in

assembly occupancies for not less than 1000 persons or in buildings above 23 m (75 ft) in height.


700.10(D) (Log # 1564 )




700.10(D) (Log # 2087 )




700.10(D) Exception (New) (Log # 1143 )


700.10(D)(1) (Log # 1117 )


700.12(B)(6), 701.11(B)(5), 702.11, 225.36, and 225.38 (Log # 65 )


Ode, M. See the Affirmative Statement in Proposal 13-111.


700.12(B)(6), 701.12(B)(5) and 702.12 (Log # 550a )

Negative

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Little, L. This action will now permit a generator installation without a disconnecting means.There will only be a control device to stop the generator driving means. Nothing more isrequired. There is no requirement that the generator be rendered incapable of restarting. Thereis no requirement that the device used to stop the driving means and to prevent restarting becapable of being locked in the open position. 445.18 must be modified before this action isacceptable in any form. See our proposed solution and statement on Proposal 13-16.

Savage, Sr., M. The submitter's concerns are adequately covered throughout the NEC in various Articles, and this requirement wouldeliminate the ability to provide Lock Out/Tag Out protection for servicing the system.


Caron, D. For clarity, the article should be rewritten as follows:(6) Outdoor Generator Sets. An outdoor housed generator set shall be equipped with a disconnecting

means in accordance with (6)(a) or (6)(b):(a) A disconnecting means, in accordance with 445.18, mounted on or within the generator enclosure andlocated within sight of the building or structure supplied.(b) A disconnecting means, in accordance with 445.18, mounted on or within the generator enclosure and anadditional disconnecting means, in accordance with 225.36 located where ungrounded conductors serve or passthrough the building or structure supplied.Exception: For installations under single management, where conditions of maintenance and supervisionensure that only qualified persons will monitor and service the installation and where documented safeswitching procedures are established and maintained for disconnection, the generator set disconnectingmeans shall not be required to be located within sight of the building or structure served and an additionaldisconnecting means, in accordance with 225.36 located where ungrounded conductors serve or pass throughthe building or structure supplied shall not be required.

Ode, M. A new second to last sentence in the revised text should be added as follows: "A listed generator complying with this section andsupplied with listed branch circuit or feeder circuit breakers shall not be required to comply with 225.36." Adding this text will ensure that circuitbreakers supplied as part of the generator does not have to be service rated.


700.12(D) (Log # 2153 )


700.12(D)(1) (Log # 3125 )


700.12(F) (Log # 428 )


700.12(F) (Log # 1565 )

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700.12(F) Exception No. 1 (Log # 838 )


700.12(F)(4) Exception No. 3 (Log # 2024 )


700.19 (New) (Log # 3367 )


700.20 (Log # 764 )


Caron, D. Revise as follows:700.20 Switch Requirements.(A) Arrangement. The switch or switches installed in emergency lighting circuits shall be arranged so that

only authorized persons have control of emergency lighting.Exception No. 1: Where two or more single-throw switches are connected in parallel to control a singlecircuit, at least one of these switches shall be accessible only to authorized persons.Exception No. 2: Additional switches that act only to put emergency lights into operation but not disconnectthem shall be permissible.(B) Series Connected or Three Way and Four Way Switches. Switches connected in series or 3- and 4-

way switches shall not be used.(C) Motion Sensors. Emergency lighting circuits shall be permitted to be switched by motion sensors, where

all of the following conditions are met:(1) Spacing between motion sensors is in accordance with manufacturer's instructions.(2) Manual activation is not required to reenergize emergency lighting when the area is occupied.(3) A non-adjustable time delay of 30 15 minutes shall be required after the area is vacated prior to

extinguishing of lighting for the area.Exception No. (C)(3): Motion sensors with time delays shall be permitted provided it is used in conjunction

with an automatic load control relay that will automatically bypass the motion sensor and energize emergencylighting upon loss of normal power.(4) Motion sensors shall not have a manual-OFF position.


700.23 (Log # 1398 )


700.24 (New) (Log # 1397 )


700.26 (Log # 1470 )

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700.26 (Log # 2255 )


Caron, D. Proponents of selective coordination do not seem to have any concern about coordination of lowlevel ground faults. Ground faults are the most prevalent fault in the field; exponentially more prevalent thanhigh value short circuits. This fact is documented in IEEE literature.

Because of the pervasiveness of ground faults, Article 215.10 and 239.95 require ground fault protection ofequipment for services/feeders over 150 volts and 1,000 amperes. Article 517.17 requires a second level ofground fault protection as well as selectivity with the upstream ground fault device. There are manyrequirements in the Code for ground fault circuit interrupters.

The majority of the ground fault protection requirements apply to the normal power system. Due to theserequirements, over the years, manufacturers have developed the technology to design a complete system thatcoordinates low level ground faults from service entrance equipment to lighting branch circuits, yet Article 700explicitly does not require selectivity for these common faults at all, just indication.


700.27 (Log # 765 )

Negative

Caron, D. The Panel agreed in the 2010 ROP that devices in the normal system are outside the scope ofArticle 700 and reaffirmed this position in this Panel Statement.

The scope of Article 700 is clearly defined in 700.1: “The provisions of this article apply to the electricalsafety of the installation, operation, and maintenance of emergency systems ……… when the normal electricalsupply or system is interrupted.”

The additional text is accurate and necessary and it provides clarity to help alleviate misinterpretation.


22



Little, L. The following comment is written to address the negative comment by Mr. Caron:The scope of all Articles in the NEC is under the purview of the Technical CorrelatingCommittee (TCC). This Code Making Panel did not reaffirm any statement made in the 2011revision cycle, they simply reaffirmed the action to reject this proposal.

The scope of Article 700 is clear and undisputable. It should be noted that this is Chapterseven in the NEC and as per 90.3, Article 700 may supplement and or modify the requirementsfound in Chapters one through four. Emergency systems are not utilized in only situationswhere there is a loss of power. These systems will be supplied with a normal source for thevast majority of time and when a loss of normal power occurs, another source in compliancewith 700.12 will be utilized. This scope statement simply identifies that portion of the system.Article 700 has purview over the installation of emergency systems, including all sources ofpower.

In the 2011 NEC cycle, Proposal 13-197 clearly requests that two devices, on the normal sideof the transfer switch, not be required to selectively coordinate with each other. The panelagreed with the concept, but felt that the additional text was unnecessary.

The figure from the 2011 ROP is useful to explain what the CMP clearly understood. Anovercurrent condition on the load-side of “1” or “2” must not open any upstream device, andan overcurrent on the load side of “3” must not open “4”. While it might be good designpractice, there is no requirement in the NEC that would require “5” to selectively coordinatewith “6”.

Proposal 13-124 for the 2014 NEC is completely different than Proposal 13-197 in the 2011NEC. Proposal 13-124 would remove the requirement that “1” or “2” selectively coordinatewith “5” and/or “6”. This would allow “5” or “6” to open for an overcurrent on the load sideof “1” or “2”, subjecting the distribution system to unnecessary risk and allowing numerousnormal-side loads to be lost, without being picked up by the alternate source.


700.27 (Log # 1062 )

Negative

Caron, D. The language in Proposal 13-125 is consistent with the 2012 NFPA 99 document for hospitals. The NFPA 99 committee deliberatedthis issue thru two 3 year code cycles. As many are aware, at the end of the first code cycle, the entire document was rejected and sent back tocommittee. There were many items in the 2009 version of NFPA 99 that caused the document to be rejected, not just the selective coordinationissue. In the final document, accepted in 2012, there were many changes made in order to get consensus from the community. However, there wasoverwhelming consensus within the committee to keep the intent of selective coordination as originally written in 2009. This is one of the few itemsthat did not change from the rejected 2009 version to the accepted 2012 version now in publication.

Part of the reason the performance criteria was added to NFPA 99 is Panel 13's refusal to offer any relief from the extreme interpretation of theselective coordination requirement. There are many instances where relief to the strict interpretation is necessary, such as extensions to existingsystems, large systems with multiple generators, etc. NFPA 99 took matters into its own hands and provided their own relief. Who will be next??What other special interest group will seek relief from the NEC requirements for this, or any other issue??To avoid the many special interest groups from providing their own relief from this requirement, Panel 13 should craft language in Article 700.27,

701.27 and 708.54 to make it clear that relief is available for special installations.


23



Little, L. The following comment is written to address the negative comment by Mr. Caron:Mr. Caron makes an extremely astute observation. He is correct in that, NFPA 99 has modified the selective coordination requirements for health

care facilities. NFPA 99 allows overcurrent protective devices serving emergency electrical systems in hospitals etc. to coordinate for the period oftime that a fault's duration extends beyond .1 seconds. Note that we did not use the term “selective” in the previous sentence. Allowing overlap outto .1 seconds is not isolating a fault, it is protection against overloads and very low level short circuits or ground faults only.Mr. Caron astutely asks: “Who will be next? What other special interest group will seek relief from the NEC requirements for this, or any other

issue?”The Standards Council Decision D#11-7 gives purview over this issue to NFPA 99. This was not without controversy. There were NITMAM’s andan appeal. However, the Standards Council gave purview over this issue to NFPA 99. We respect and abide by the decision of Council. We dobelieve however, that this action is precedent setting and will lead to multiple special occupancies developing their own standard. These specialoccupancies will then approach Standards Council to seek purview over electrical requirements and Council will be bound to give purview due tothe precedent set with NFPA 99.The American Society for Healthcare Engineering has an avenue by which they can appeal to Standards Council and get purview if they cannot getwhat they want in the NEC process, it is NFPA 99. New technical committees may be developed in accordance with 3.1 of the RegulationsGoverning Committee Projects. If a project is rejected by Standards Council, the entity seeking a code/standard may simply go to another standardsorganization.Organizations considering such action to develop their own standard, allowing them to then modify all/any NEC requirements may include thefollowing:• The National Association of Home Builders. This would allow them to delete all AFCI and other requirements.• The American Chemistry Council. This would allow them to modify all NEC requirements in their industrial installations.• Multiple Telecommunications Industries. This would allow them to modify all/any NEC requirements.• Association of Higher Education Facilities Officers. This would allow colleges and universities to write their own rules for demand factors.

There are dozens of other examples. Any industry organization may seek to develop their own standard in order to modify requirements in otherNFPA codes or standards.The NEC may one day simply be a compilation of electrical requirements that exist in other standards.

Ode, M. The submitter did not provide any data on the results of a longer fault delay. The effect on the electrical equipment of a longerduration arc fault is a major concern for emergency systems and no technical substantiation has been provided in this proposal with this critical data.The submitter did not show any data on the fault current level below the 0.1 second limit where the circuit breakers or fuses may not be in theselective area. This proposal would reduce the level of safety by limiting the types of overcurrent that would need to be isolated to the nearestupstream device. Requiring selective coordination down to only 0.1 seconds will cover only overloads and a few minor phase-to-phase and someground faults. It will not cover many arcing faults, the most prevalent type of short-circuit, as might be caused by dropping a screwdriver, and, ofcourse, it won't cover heavier bolted faults. Faster-acting, current limiting devices, either circuit breakers or fuses or a combination of both can beused to effectively create selective coordination.


700.27 (Log # 1566 )

Negative

Caron, D. See comment on Proposal 13-125.

Olney, P. With respect to the panel action, I disagree with the panel action. There are many jurisdictionswhere there is no plan review process for electrical installation. The installation of selective coordination by aqualified person only may leave some installations in jeopardy of failure by the AHJ. Does the nature of amaster electrician make you a qualified person? There are many times the design is completed with the help ofequipment manufacturer's for there equipment and may not know the whole layout of the electrical system oralternate power sources. Having a licensed professional engineer lay out the system helps AHJ ensure it hasbeen done properly.

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700.27 (Log # 2256 )


700.100(D)(1)(5) (Log # 1114 )

Negative



701.1 (Log # 1471 )


701.2.Legally Required Standby Systems (Log # 746 )

Negative

Degnan, J. The figure does not clearly define normal and legally required standby systems.


Caron, D. See figure (13-130 Attachment Figure 701-2) and comment on Proposal 13-91.

****Insert Figure Here***



701.2.Legally Required Standby Systems (Log # 1273 )


701.3(E), 701.12, Informational Note (Log # CP1303 )


701.5(C) (Log # 1012 )

Negative



701.7(B) (Log # 907 )

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701.7(C) (New) (Log # 1986 )


701.10 (Log # 1985 )


701.12(D) (Log # 3126 )


701.12(E) (Log # 495 )


701.26 (Log # 1472 )


701.27 (Log # 1567 )

Negative


Olney, P. See my Explanation of Negative Vote on Proposal 13-126.


701.28, Part V (New) (Log # 2344 )


Ode, M. There is no definition provided for a supervisory station within the NEC with no substantiation for the source of this supervisorystation.


702.2.Optional Standby Systems (Log # 745 )

Negative

Degnan, J. Is a figure necessary for optional standby? What information does it convey?



***Insert Figure Here***.


26




702.2.Optional Standby Systems (Log # 1274 )


702.4(B) (Log # 3244 )


Ode, M. The submitter's concern is already addressed in 220.87 to calculate actual peak demand load. Anytime a new load is applied to apanelboard or a new feeder is established, calculations must be done based on Article 220. This applies to single family dwellings and all otherfacilities. The purpose of creating (B)(1) for manual transfer is to permit the customer to select the load to connect to the generator. Power lossduring the winter, for example, would require connection of different loads than a power outage in the summer or spring. This only applies tomanual transfer since there are too many loads that can be inadvertently left on with possible overload for the feeder with an automatic transferdevice. Anticipating the load on an automatic transfer system would really have the inspector guessing. This would be an unenforceable situation.


702.4(B)(2)(a) (Log # 174 )


702.7(B) (Log # 897 )


702.7(C) (New) (Log # 3488 )


702.9 (Log # 3419 )


702.11(A) and (B) (Log # 3254 )


702.11(C) (New) (Log # 3127 )


702.12 (Log # 3376 )


702.13 (New) (Log # 2525 )


707 (New) (Log # 2918 )

27




Ode, M. Chapter 6 in the NEC covers special equipment, such as photovoltaic systems, fuel cell systems, and small wind electric systems allcovered by Panel 4. Chapter 7 covers special conditions such as emergency conditions, legally required, and optional power conditions. None ofthese conditions are compatible with the Chapter 6 equipment coverage provided in Article 690, 692, and 694 for the equipment mentioned in thefirst sentence of this statement. Leaving the inverter requirements and other common sections in each of these three articles in Chapter 6 are moreuser-friendly than moving them into a new article in Chapter 7 and none of the suggested common sections could be considered conditions ascovered by Chapter 7.


708 (Log # 406 )


Ode, M. Article 708 is the electrical installation part of a larger standard on disasterand emergency management, such as NFPA 1600-2010, Standard on Disaster/Emergency Management and BusinessContinuity Program. The NEC Technical Correlating Committee and the NFPA Standards Council decided that theelectrical requirements for disaster and emergency management was better served by the National Electrical Codeprocess than by a separate and different committee so Article 708 was developed. There was no technical substantiationprovided to delete this article. This article is used within the Home Land Security process to ensure natural and humancaused disasters have less chance of disrupting electrical power for critical facilities such as hospitals, fire and policefacilities, as well as critical financial facilities and the protection of life and property.


708.1 (Log # 1473 )


708.1, 708.6(C), (E), 708.52(C), Informational Note (Log # CP1305 )


708.2.Category I COPS,Category II COPS,Category III COPS,Category IV COPS (Log # 1452 )


708.2.Critical Operations Power Systems (COPS) (Log # 744 )



**** Insert Figure Here***



708.2.Supervisory Control and Data Acquisition (SCADA) (Log # 1277 )

28




708.4(A) (Log # 1454 )


708.10(A)(1) (Log # 3442 )


708.10(C) (Log # 814 )


708.10(C)(1) (Log # 801 )


708.10(C)(1) (Log # 815 )


708.10(C)(1) (Log # 2420 )


708.10(C)(1) (Log # 2446 )


708.10(C)(1)(3) (Log # 2809 )


708.10(C)(1)(3) (Log # 2844 )


708.10(C)(2) (Log # 13 )

Negative



708.10(C)(2)(3) (Log # 1115 )

Negative


29




708.12(A) (Log # 1351 )


708.14 (Log # 1528 )


708.14(7) (Log # 1624 )


708.20 (Log # 1453 )


708.20(F)(5) (Log # CP1301 )

Negative

Little, L. See our statement on 13-111.The panel statement is incorrect. The action to include the new first level subdivision (B) did not occur in Articles 700 and 701.


Caron, D. See comment on Proposal 111.

Ode, M. A new second to last sentence in the revised text in (A) should be added as follows: "A listed generator complying with this sectionand supplied with listed branch circuit or feeder circuit breakers shall not be required to comply with 225.36." Adding this text will ensure thatcircuit breakers supplied as part of the generator does not have to be service rated.


708.20(F)(5) (Log # 2271 )


Ode, M. See the Affirmative Statement in Proposal 13-172a.


708.52(B) (Log # 1013 )

Negative



708.52(D) (Log # 743 )


708.54 (Log # 1569 )

Negative

30




Olney, P. See my Explanation of Negative Vote on Proposal 13-126.






Article 710 (New) (Log # 2916 )


750 (New) (Log # 3480 )

Negative

Savage, Sr., M. The requirements of this proposal belongs in documents other than the NEC. The NEC is notan energy management document, the proposal is outside the scope of 90.1 and 90.2. Perhaps the submittershould send this proposal to the IECC or other energy code documents, i.e. ASHRAE.


Annex F (Log # 2908 )


Annex J (New) (Log # 3348 )


Annex J (New) (Log # 3349 )

31

m e m o r a n d u m€¦ · for correlation with the actions taken on proposals throughout the nec,...

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