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
1 13-1 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 Entire Document (Log # 1170l ) 13-2 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 Entire Document (Log # 921l ) 13-3 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 100.Battery System (New) and 480.2 (Log # 1606 ) 13-4 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 100.Emergency Systems (New) and 700.2 (Log # 1613 ) 13-5 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 100.Nominal Battery Voltage (New) and 480.2 (Log # 1605 ) 13-6 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 100.Phase Converter (New) and 455.2 (Log # 1604 ) 13-7 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 100.Sealed Cell or Battery (New) and 480.2 (Log # 1608 ) 13-9 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 100. Storage Battery (New) and 480.2 (Log # 1607 ) 13-10 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 445.11 (Log # 2682 ) Degnan, J. Field marking of generators for permanent installations is not necessary, but does no harm. Field marking of rental units or portable generators that are used in multiple applications may or may not be accurate. If the NEC is going to require field marking it should also require 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 Panel Statement as follows: "CMP-13 does not accept the proposed requirement for marking the location of the generator bonding which may be inaccessbile in some cases." since it is not part of the actual text to be inserted as text into the NEC. 13-11 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 445.11 (Log # 2932 )
2 13-12 Eligible To Vote:18 Affirmative: 16 : 2 Abstain: 0 Not Returned: 0 445.12 (Log # 2643 ) Brown, J. The panel's action does not meet the submitter's intent and this proposal should have been rejected. The inclusion of overload in the section title does not address his concerns for short-circuit protection. The term Overload does not need to be included in the title since the present 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 defined in Article 100 and clearly includes "overload." Adding the term "overload" to the section title does not add clarity since the existing title is "overcurrent." Combining these two terms for a new section title "Overcurrent and 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 the term "overload" into the section title meet the intent of the submitter? 13-13 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 445.16 (Log # 1158 ) 13-14 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 445.17 (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 "1000 volts." 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 the last sentence, the word "and" should be changed to "through" read as follows: The higher horsepower rating of Table 430.247 through Table 430.250 shall be used whenever the generator selection is between two ratings. 13-15 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 445.17 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 "1000 volts." Ode, M. See my comment on Proposal 13-14. 13-16 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 445.18 (Log # 480 )
3 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 protective devices and control apparatus are able to be disconnected entirely from the circuits supplied by the 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 Generator Assemblies. The action to accept in principle proposal 13-111 will permit the installation of a standby generator without a disconnecting means installed at any point from the generator terminals to the 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 13-111 is based partially on UL 2200 which mandates a means to stop the driving means, prevent restarting and requires this means to be lockable in the OFF position. Not all generators are listed. The above modifications are needed for the safety of all installer/maintainers. It should be noted that OSHA does not permit an emergency stop button to be used to lockout electrical equipment. 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 an acceptable 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 : 0 Abstain: 0 Not Returned: 0 445.19 (Log # CP1304 ) 13-17 Eligible To Vote:18 Affirmative: 17 : 1 Abstain: 0 Not Returned: 0 445.19 (Log # 501 ) Ode, M. This proposal should have been a reject instead of an accept in principle since Proposal 13-16a deleted Section 445.19. Little, L. We agree with the affirmative comment by Mr. Ode. 13-18 Eligible To Vote:18 Affirmative: 17 : 1 Abstain: 0 Not Returned: 0 445.20 (New) (Log # 2461 )
4 Caron, D. The panel statement does not address the submitter's substantiation. Large generators, arranged to operate 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 breakers and the common bus in the paralleling switchgear, should be defined or recognized in some way in Article 445 as a system. Rules for applying ground fault protection (700.6(D)) and selective coordination (700.27) are often misapplied, or as the submitter has indicated, cannot be applied. 13-19 Eligible To Vote:18 Affirmative: 16 : 2 Abstain: 0 Not Returned: 0 445.20 (New) (Log # 3364 ) Czarnecki, N. This proposal seeks to add GFCI protection to all 125V generator outlets without any substantiation that an issue exists at all levels. In order to establish a functional GFCI configuration on the generator, the generator is forced to be of the bonded neutral 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 will not enhance safety, but obsolete safe infrastructure already in place. Enhanced safety has not been accomplished and potentially compromised 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 generator grounding that wasn't available in 2008, when this same proposal failed to gain the required acceptance of the panel.
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 the bonded neutral type. There are many presently in production. The sketch provided by Mr. Czarnecki with the negative ballot comment clearly reveals his concern, which is the viability of 15/20 ampere, 125-volt, single pole transfer switches. They will not work through a GFCI. A two pole transfer switch would be required because a portion of the neutral current would flow over the equipment grounding conductor where a single pole transfer 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 and indisputable NEC violations. The issue at the core of this proposal is the use of portable generators to supply power to a dwelling unit when there is a loss of power. This occurs regularly 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, wet vacuums, refrigerators, freezers and other appliances during weather related events. There are 15/20 ampere, 125-volt, single pole transfer switches on the market and their use allows the homeowner to supply power to the selected branch circuit by plugging the male end of an extension cord into a receptacle outlet on the generator and by plugging the female end of the extension 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 a grounded system through the solid connection to the service supplied neutral conductor. This means that all other receptacle outlets on the generator now have potential to ground without GFCI protection. The homeowner will utilize every receptacle outlet in these weather related events, and without GFCI protection, serious safety concerns exist. Where a generator is used in 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 wiring devices, both permanently and temporarily installed. This includes (a) wiring from the service point or power source to the outlets or (b) wiring from and including the power source to the 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 part of 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 take action to prevent exposure to shock hazards. We cannot look the other way because of the impact on a particular product when it comes to safety. The claim that this revision will drive homeowners/users to defeat the system by removing grounding connections is without merit because we presently have both types of generators readily available. When a homeowner/ user decides to buy a new portable generator, they will go online or to a local home improvement 5
6 store. A simple trip to Lowes or Home Depot reveals that many of the portable generators available already have GFCI type receptacles. The Purpose of the NEC is the practical safeguarding of persons and property from hazards arising from the use of electricity. That is the 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 a product standards issue. The standard for generators should be updated to include this requirement. When I read the proposed Rule it could imply to add ground-fault circuit interrupter protection to existing generators as well. This could result in certified generators being modified in the field and thus voiding the existing certification. 13-20 Eligible To Vote:18 Affirmative: 16 : 2 Abstain: 0 Not Returned: 0 455 (Log # 3302a ) Rodriguez, A. The primary function of the conductor presently defined as an "equipment grounding conductor" is actually a bonding function. The grounding electrode conductor grounds systems and equipment. Accepting this change will help increase usability and understanding of the associated requirements. The existing term and the associated terms grounded and bonded are frequently 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 and documentation changes should never be an argument where safety is concerned. Further, not all electrical practitioners are knowledgeable in the main intent of this conductor. There is no justification for retaining an incorrect and potentially hazardous electrical 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 much misunderstanding with possible hazardous operating conditions in electrical installations. The use of the term grounding implies that 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 low impedance 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, provides its primary function whether or not it is grounded. For a grounded system, it is grounded because the system is grounded. For an ungrounded 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 all of the way back to the source. 13-21 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.xx (New) (Log # 2996 )
7 13-22 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.xx (New) (Log # 3007 ) 13-23 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.xx (New) (Log # 3008 ) 13-24 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.1, Informational Note (New) (Log # 3009 ) 13-25 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.2 (Log # 2241 ) 13-26 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.2.Cell (New) (Log # 2989 ) 13-27 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.2.Container (New) (Log # 2990 ) 13-28 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.2.Electrolyte (New) (Log # 2991 ) 13-29 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.2.Intercell Connector (New) (Log # 2992 ) 13-30 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.2.Intertier Connector (Log # 2993 ) 13-31 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.2.Nominal Battery Voltage (Log # 2994 ) 13-32 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.2.Terminal (New) (Log # 2995 ) 13-33 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.4 and 480.5 (Log # 2997 )
8 Little, L. Further modifications to this section should be considered. The following proposed revisions were in a proposal not received by NFPA staff that was developed by a joint effort of the NEC Task Force of the Technical 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 readily accessible 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 open position 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 available short circuit current. The label shall be placed in a conspicuous location near the battery if a disconnect is not provided. Informational Note: Battery equipment suppliers can provide information about short circuit current on any particular battery model. 645.10(A) requires remote activation for disconnects serving ITE rooms. The disconnect serving the ITE room must be capable of being locked open to prevent the remote actuation from occurring when it will jeopardize safety of personnel. DC busway is common in large UPS installations in which there are multiple strings of batteries. Each string is connected in series to create the necessary dc voltage and each string has a disconnecting means &/or overcurrent protective device. The strings are connected in parallel to a common dc bus which may also have a disconnecting means. The individual string disconnects allow manual disconnecting so that maintenance can be performed on a redundant battery string while the remaining battery strings support the load. It also functions 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 labeling requirement attests this hazard and aids in determining the arc-flash protection boundary and required PPE. 13-34 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.5 (Log # 52 ) Ode, M. In the last sentence in the Panel Statement, change the word "in" to "with" for clarity. 13-35 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.5 (Log # 620 ) 13-36 Eligible To Vote:18 Affirmative: 16 : 2 Abstain: 0 Not Returned: 0 480.5(A) and (B) (New) (Log # 1076 )
9 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 been enforced by AHJs for decades. This proposed revision mirrors the present requirement in 240.21(H), which requires 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 and Insulated and Insulating Hand Tools Direct Current Equipment requires determining the available arcing current to select PPE necessary 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. 13-37 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.7 (Log # 2998 ) 13-38 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.8(C) (Log # 2999 ) 13-39 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.9(A), Informational Note (New) (Log # 53 ) 13-40 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.9(C) (Log # 119 ) 13-41 Eligible To Vote:18 Affirmative: 16 : 2 Abstain: 0 Not Returned: 0 480.9(C), Informational Note (New) (Log # 3001 ) Degnan, J. The note provides valuable information and should be left in. While the panel statement is true, applying it universally to the NEC would result in the removal of many informational notes. Little, L. The panel statement is incorrect. The proposed informational note is designed to inform the code user 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. 13-42 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.9(C)(1) and (2) (New) (Log # 3000 )
10 13-43 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.9(D) (New) (Log # 3002 ) 13-44 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.9(D) (Log # 3003 ) 13-45 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.9(E) (Log # 3004 ) 13-46 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.9(F) (New) (Log # 3005 ) 13-47 Eligible To Vote:18 Affirmative: 17 : 1 Abstain: 0 Not Returned: 0 480.9(X) (New) (Log # 3006 ) Little, L. This proposal should have been accepted. The panel statement to reject agrees with the proposed text. The panel states that a requirement for illumination of batteries belongs in Article 480. The panel also agrees that luminaires should not be located directly above batteries. 13-48 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 480.11 (New) (Log # 2242 ) 13-48a Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.1(B) (Log # CP1300 ) Caron, D. See my comment on Proposal 13-55. 13-49 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.1(C) (New) (Log # 3366 ) 13-50 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.2 (Log # 1660 ) 13-51 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.2.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 the NFPA Regulations Governing Committee Projects. NFPA rules require the wording to be added or revised and how the text in the NEC should be revised. Residential fire pumps are already covered by Article 695 in the NEC.
11 13-52 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.2.On-Site Standby Generator (Log # 1271 ) 13-53 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.3(A)(1) (Log # 497 ) 13-54 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.3(A)(1) (Log # 611 ) 13-55 Eligible To Vote:18 Affirmative: 17 : 1 Abstain: 0 Not Returned: 0 695.3(C)(1) (Log # 549 ) Caron, D. The panel action, the new text in 13-48a (695.1(B)) and new text in 13-55a, partially meets the intent of Proposal 13-55. Transfer equipment in the main electric room of a building that is part of a multibuilding campus-style complex, can manually or automatically switch from a feeder supplying the building, to a back-up feeder within the main electric room. A single feeder to the pump room would be considered a reliable source because of the back-up feeder by NFPA 20 9.2.2(4). The panel statement is not consistent with NFPA 20 language in that NFPA 20 would not require an additional alternate source to the pump room, as required 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 13-48a deals with a clarification of Article 695 coverage of the installation of pressure maintenance pumps and transfer equipment upstream of the fire pump transfer switch. Proposal 13-55 deals with feeder sources for multi-building campus-style complexes. 13-55a Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.3(F) and 695.3(G) (Log # 3532 ) Caron, D. See my comment on Proposal 13-55.
12 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 very well to the overcurrent protection permitted between the fire pump power source and the fire pump controller or the fire pump transfer switch. Such overcurrent protection is sized to provide only ground fault and short circuit protection for the fire pump motor circuit. It does not provide motor overload protection. Overload protection for the fire pump motor is provided by the circuit breaker in the fire pump controller. This arrangement prevents opening of the overcurrent protective device permitted between the fire pump power source and the fire pump controller or the fire pump transfer switch in the event of a motor overload. If this overcurrent protective device were to open, it may not accessible for immediate resetting and thus, render the fire pump motor inoperable. If the fire pump motor experiences an overload condition causing breaker tripping, it is desirable to have the fire pump breaker trip because it is easily located and reclosed to allow attempts to restart the fire pump motor during a fire event. Fire pumps can be temporarily distressed and one or more attempts at restarting can result in continuous running of the pump motor if the overload condition no longer exists. Instantaneous trip circuit breakers do not provide overload protection which is the required performance for the overcurrent 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 for overcurrent devices as specified in 695.4(B)(2). More importantly, an instantaneous trip circuit breaker does not need to be sized as large in amperes as other protective devices already permitted. Such oversizing is necessary to prevent their overload tripping characteristics from overlapping those of the fire pump circuit breaker. It is recognized that an instantaneous trip circuit breaker is intended to be a factory installed product. This is ensured by including the requirement that it shall be provided as part of a transfer switch assembly listed for fire pump service. 13-56 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.4(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) but provides new text based on the NFPA 20 document as an alternative to the existing text in the NEC. 13-57 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.4(B)(2) (Log # 2639 ) 13-58 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.4(B)(2) (Log # 2640 ) 13-59 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.4(B)(2)(a) (Log # 2738 ) Ode, M. See the affirmative statement in Proposal 13-56. 13-60 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.4(B)(3)(a) (Log # 321 ) 13-61 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.4(B)(3)(b) (Log # 326 )
13 13-62 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.4(B)(3) (Log # 844 ) 13-63 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.5 (New) (Log # 1496 ) 13-64 Eligible To Vote:18 Affirmative: 17 : 1 Abstain: 0 Not Returned: 0 695.5(B) (Log # 1531 ) Czarnecki, N. The assertion that NFPA20 does not allow for the alternate method of overcurrent protection for transformers, simply because it does not specifically address the issue, is unsupportable. 13-65 Eligible To Vote:18 Affirmative: 17 : 1 Abstain: 0 Not Returned: 0 695.5(C)(2) (Log # 1532 ) Czarnecki, N. The assertion that NFPA20 does not allow for the alternate method of overcurrent protection for transformers, simply because it does not specifically address the issue, is unsupportable. 13-66 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.5(C)(2) (Log # 1673 ) 13-67 Eligible To Vote:18 Affirmative: 17 : 1 Abstain: 0 Not Returned: 0 695.6(A)(2)(d)(1) (Log # 1118 ) Ode, M. The Proposal did not provide any technical substantiation for the change from 2 inches of concrete in the existing NEC text to 4 inches of concrete. UL does not list concrete by itself for a fire rating so any UL fire rated assembly would involve a complete assembly of building materials, often including concrete and other materials. There are many different factors that can affect heat transfer, other than the thickness of concrete. Pre-stressed concrete has a different heat transfer ratio than lightweight concrete, steel reinforcement within concrete will affect heat transfer, and the type of aggregate used within the concrete will also affect heat transfer. The NFPA Fire Protection Handbook states the following: Reinforcing steel can also affect the amount of heat transfer that can occur within the concrete floor or wall." Concrete has a low thermal conductivity and a low thermal capacity. One of the more significant factors in determining the thermal characteristics of reinforced concrete is the type of aggregate used in the concrete and can vary throughout the United States. Concrete in direct contact with earth will have a different heat transfer than concrete installed as a wall or floor ceiling installation for multiple floor locations. Moisture content of the concrete will affect heat transfer. Furthermore, lightweight concrete has much different heat transfer rates than regular, reinforced, or prestressed concrete. The submitter could have provided a Fact Finding Study on the different types of concrete that could be used, the recommended thickness, and addressed the variables with the amount of heat transfer for each application so the Panel could act on the technical merits for this change, rather than just guessing at a depth of concrete. The 2-inch concrete thickness has been used for many NEC cycles to provide physical protection with some limited protection from heat transfer and should not be changed without proper technical substantiation for this change.
14 13-68 Eligible To Vote:18 Affirmative: 16 : 2 Abstain: 0 Not Returned: 0 695.6(B) (Log # 10 ) 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. In some egress scenarios, concrete encasement may offer physical protection that would prove more valuable than a system only designed for 2 hours fire. Ode, M. See the Statement in Proposal 13-67. 13-69 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.6(D) (Log # 141 ) Little, L. Electrical metallic tubing (EMT) has been proven as an effective ground fault path. See the GEMI research study or the data in the Soares grounding book. 13-70 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.6(D) (Log # 702 ) 13-71 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.6(D) (Log # 1529 ) 13-72 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.6(D) (Log # 1828 ) 13-73 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.6(D) and 695.14(E) (Log # 2419 ) 13-74 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.6(D) and 695.14(E) (Log # 2445 ) 13-75 Eligible To Vote:18 Affirmative: 17 : 1 Abstain: 0 Not Returned: 0 695.6(D) (Log # 2641 ) Savage, Sr., M. The submitter s substantiation states that EMT with set screw connectors would not be an acceptable method of providing a GF return path and would require a separate EGC. However, under 250.118 EMT is judged to be an acceptable (FMC is required to have listed fittings per this section, no mention of EMT) EGC and no material was presented to show the inadequacy of EMT as a GF return path.
15 Czarnecki, N. The substantiation contains an incorrect reference to electrical metallic tubing (EMT) with set-screw fittings as an example of a raceway that is not capable of conducting sufficient ground-fault to open the overcurrent protective device. The Georgia Tech research study on grounding referred to in the Soares Book on Grounding validates that EMT with set-screw fittings and installed 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 be subjected to a current test to determine if the EMT and the interface between the EMT and the fitting can effectively carry fault current, in order to permit operation of the overcurrent device and terminate fault current flow. In order to carry a UL listing, EMT fittings 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 fault occurs, its possible to energize the motor frame. Other than this limited scenario, the entire ground return path would need to be examined, not just the portion between the controller and the motor. Little, L. Electrical metallic tubing (EMT) has been proven as an effective ground fault path. See the GEMI research study or the data in the Soares grounding book. 13-76 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.6(D) and 695.14(E) (Log # 2843 ) 13-77 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.6(D) (Log # 2913 ) 13-78 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.6(E) (Log # 2669 ) Little, L. Electrical metallic tubing (EMT) has been proven as an effective ground fault path. See the GEMI research study or the data in the Soares grounding book. 13-79 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.6(I) (Log # 142 ) 13-80 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.6(J)(5) (New) (Log # 1350 ) 13-81 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.7(A) (Log # 3020 ) 13-82 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.7(B) (Log # 703 ) 13-83 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.12(G) (Log # 143 )
13-84 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.14(E) (Log # 2808 ) 13-85 Eligible To Vote:18 Affirmative: 17 : 1 Abstain: 0 Not Returned: 0 695.14(F) (Log # 11 ) Ode, M. See the Statement in Proposal 13-67. 13-86 Eligible To Vote:18 Affirmative: 17 : 1 Abstain: 0 Not Returned: 0 695.14(F)(1) (Log # 1119 ) Ode, M. See the Statement in Proposal 13-67. 13-87 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 695.14(G) (Log # 144 ) 13-88 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.1 (Log # 1469 ) 13-88a Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.2 (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 and critical branches of the essential electrical system. 13-89 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.2 Luminaire, Directly Controlled (New) (Log # 1395 ) 13-90 Eligible To Vote:18 Affirmative: 17 : 1 Abstain: 0 Not Returned: 0 700.2 and 700.10(B) (Log # 3312 ) Degnan, J. Reasoning for the negative vote is in the text of the proposal. 13-91 Eligible To Vote:18 Affirmative: 17 : 1 Abstain: 0 Not Returned: 0 700.2.Emergency Systems (Log # 747 ) Degnan, J. The figure is not clear where the delineation is betwen normal and emergency. 16
17 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, the figure (13-91 Attachment 2 Figure 695-3(D)) should be added to 695.3(D) for fire pumps when an on-site standby 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 stage could explain the intent of the figures, the meaning of the symbology, and any requirements the figures were not intended to define. 13-92 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.2.Emergency Systems (Log # 1272 ) 13-92a Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.2, 700.3(E), 700.12, Informational Note (Log # CP1302 ) 13-93 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.3(F) (Log # 2526 ) 13-94 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.4(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 yearly or every other year, as determined by the AHJ. 13-95 Eligible To Vote:18 Affirmative: 17 : 1 Abstain: 0 Not Returned: 0 700.5(C) (Log # 1011 ) Brown, J. It is recognized that increasing voltage from 600 volts to 1000 volts may be applicable to specific installations. However, adequate technical substantiation has not been provided to support the change in this Article. 13-96 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.5(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 be marked with the types of overcurrent protective devices that are required for protecting the transfer switches and with the short circuit current rating of the transfer switch. The term withstand rating is not used in the requirements in UL 1008 but the rating in available rms symmetrical short circuit current is used in the Standard.
18 13-97 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.7(B) (Log # 906 ) 13-98 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.8 (New) (Log # 3330 ) Little, L. Surge protective devices have proven to provide benefits for components and systems against the damages of voltage surges, but the substantiation for this proposal does not document that such protection would specifically benefit emergency systems. 13-99 Eligible To Vote:18 Affirmative: 17 : 1 Abstain: 0 Not Returned: 0 700.9(B)(5) (Log # 63 ) Degnan, J. Reasoning for the negative vote is in the text of proposal 13-90, which was updated for this code cycle. 13-100 Eligible To Vote:18 Affirmative: 17 : 1 Abstain: 0 Not Returned: 0 700.9(B)(5)(b) (Log # 64 ) 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. The paragraph states that it shall be permitted to not have overcurrent protection, the exception states that it shall be permitted to have it. I intend to submit a comment suggesting that the proposal be accepted in principle by changing the text to "...multiple feeders with or without overcurrent protection at the source." and eliminating the Exception. 13-101 Eligible To Vote:18 Affirmative: 17 : 1 Abstain: 0 Not Returned: 0 700.9(D)(1) (Log # 12 ) Ode, M. See the Statement in Proposal 13-67. 13-102 Eligible To Vote:18 Affirmative: 17 : 1 Abstain: 0 Not Returned: 0 700.10(B) (Log # 3313 ) Degnan, J. The reason for the no vote is in the text of the proposal. 13-103 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.10(B)(5) (Log # 496 ) 13-104 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.10(B)(5) (Log # 2131 )
19 Degnan, J. If the panel doesn't support removing the paragraph as in proposal 13-90, improving the paragraph's language and clarity is appropriate. 13-105 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.10(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. 13-106 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.10(D) (Log # 1564 ) Caron, D. See my comment on Proposal 13-105. 13-107 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.10(D) (Log # 2087 ) Caron, D. See my comment on Proposal 13-105. 13-108 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.10(D) Exception (New) (Log # 1143 ) 13-109 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.10(D)(1) (Log # 1117 ) 13-110 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.12(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. 13-111 Eligible To Vote:18 Affirmative: 16 : 2 Abstain: 0 Not Returned: 0 700.12(B)(6), 701.12(B)(5) and 702.12 (Log # 550a )
20 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 is required. There is no requirement that the generator be rendered incapable of restarting. There is no requirement that the device used to stop the driving means and to prevent restarting be capable of being locked in the open position. 445.18 must be modified before this action is acceptable 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 would eliminate 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 and located 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 an additional disconnecting means, in accordance with 225.36 located where ungrounded conductors serve or pass through the building or structure supplied. Exception: For installations under single management, where conditions of maintenance and supervision ensure that only qualified persons will monitor and service the installation and where documented safe switching procedures are established and maintained for disconnection, the generator set disconnecting means shall not be required to be located within sight of the building or structure served and an additional disconnecting means, in accordance with 225.36 located where ungrounded conductors serve or pass through the 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 and supplied with listed branch circuit or feeder circuit breakers shall not be required to comply with 225.36." Adding this text will ensure that circuit breakers supplied as part of the generator does not have to be service rated. 13-112 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.12(D) (Log # 2153 ) 13-113 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.12(D)(1) (Log # 3125 ) 13-114 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.12(F) (Log # 428 ) 13-115 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.12(F) (Log # 1565 )
21 13-116 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.12(F) Exception No. 1 (Log # 838 ) 13-117 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.12(F)(4) Exception No. 3 (Log # 2024 ) 13-118 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.19 (New) (Log # 3367 ) 13-119 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.20 (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 single circuit, 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 disconnect them 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 emergency lighting upon loss of normal power. (4) Motion sensors shall not have a manual-off position. 13-120 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.23 (Log # 1398 ) 13-121 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.24 (New) (Log # 1397 ) 13-122 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.26 (Log # 1470 )
22 13-123 Eligible To Vote:18 Affirmative: 18 : 0 Abstain: 0 Not Returned: 0 700.26 (Log # 2255 ) Caron, D. Proponents of selective coordination do not seem to have any concern about coordination of low level ground faults. Ground faults are the most prevalent fault in the field; exponentially more prevalent than high 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 of equipment for services/feeders over 150 volts and 1,000 amperes. Article 517.17 requires a second level of ground fault protection as well as selectivity with the upstream ground fault device. There are many requirements in the Code for ground fault circuit interrupters. The majority of the ground fault protection requirements apply to the normal power system. Due to these requirements, over the years, manufacturers have developed the technology to design a complete system that coordinates low level ground faults from service entrance equipment to lighting branch circuits, yet Article 700 explicitly does not require selectivity for these common faults at all, just indication. 13-124 Eligible To Vote:18 Affirmative: 17 : 1 Abstain: 0 Not Returned: 0 700.27 (Log # 765 ) Caron, D. The Panel agreed in the 2010 ROP that devices in the normal system are outside the scope of Article 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 electrical safety of the installation, operation, and maintenance of emergency systems when the normal electrical supply or system is interrupted. The additional text is accurate and necessary and it provides clarity to help alleviate misinterpretation.