695.4(B)(3)

[roger]

For sake of conversation, can anyone read anything into 695.4(B)(3)(a) or 695.4(B)(3)(b) (which will take you to 700.10(B)(5)) that will allow OCPD's for Fire Pumps to be in enclosures that are feeding other loads?
For example, can the OCPD for the normal supply to a Fire Pump be in the same vertical section as other distribution panel feeders and, can the OCPD from a generator be in the same vertical section as the Critical Branch feeder, the Life Safety Branch feeder and the Equipment System Feeder.

Yeah, I know the Critical Branch, Life Safety Branch, and Equipment branches are an issue but that's another story.

Roger

 

[Smart $]

For sake of conversation, can anyone read anything into 695.4(3)(a) or 695.4(3)(b) (which will take you to 700.10(B)(5)) that will allow OCPD's for Fire Pumps to be in enclosures that are feeding other loads? ...

Please clarify... there are no sections as referenced. Are you referencing 695.4(B)(1)(3)(a) and (b)? If so, nothing points to 700.10(B)(5)...???

Ooops... just saw title... so you're referencing 695.4(B)(3)(a) and (b).

 

[roger]

Please clarify... there are no sections as referenced. Are you referencing 695.4(B)(1)(3)(a) and (b)? If so, nothing points to 700.10(B)(5)...???

Ooops... just saw title... so you're referencing 695.4(B)(3)(a) and (b).

No problem, I could have made it a little clearer and I am editing the sentence you quoted.

Roger

 

[Smart $]

Regarding fire pump ocpd, I think 695.4(B)(3)(a)(3) is all the further you need to go... must be located in equipment solely for the fire pump.

 

[roger]

Regarding fire pump ocpd, I think 695.4(B)(3)(a)(3) is all the further you need to go... must be located in equipment solely for the fire pump.

You and I are in agreement but, I have some engineers and inspectors that are somehow reading it differently than we are.

Roger

 

[Smart $]

You and I are in agreement but, I have some engineers and inspectors that are somehow reading it differently than we are.

Roger

Their explanation???

 

[roger]

Their explanation???

None really. When it was brought to their attention there was a conference call with designers, inspectors, GC, and myself. The designers lead the show by talking in circles of article 517 and 695.3, I finally stepped in and pointed all to 695.4(B)(3), the inspectors asked to be excused from the call to discuss things in private and when they returned they said "based on 695.4(B)(3) they would allow it", this is the reason for my question, I am wondering what they are reading.

Roger

 

[ceb58]

None really. When it was brought to their attention there was a conference call with designers, inspectors, GC, and myself. The designers lead the show by talking in circles of article 517 and 695.3, I finally stepped in and pointed all to 695.4(B)(3), the inspectors asked to be excused from the call to discuss things in private and when they returned they said "based on 695.4(B)(3) they would allow it", this is the reason for my question, I am wondering what they are reading.

Roger

Could they be looking at 695.4(B)(3)(b) which takes them to 700.10(B)(5)(a)? This was done utilizing the SWAG method of reasoning

 

[roger]

Could they be looking at 695.4(B)(3)(b) which takes them to 700.10(B)(5)(a)? This was done utilizing the SWAG method of reasoning

Hey Curtis, that is one of the things they are not seeing, 700.10(B)(5)(a) still calls for the OCPD to be in a separate enclosure or separate vertical section of the switchboard.

Roger

 

[ceb58]

Hey Curtis, that is one of the things they are not seeing, 700.10(B)(5)(a) still calls for the OCPD to be in a separate enclosure or separate vertical section of the switchboard.

Roger

Then I have no clue :dunce: Can the inspectors not explain their reasoning?

 

[VUGear]

For example, can the OCPD for the normal supply to a Fire Pump be in the same vertical section as other distribution panel feeders

From 695.4(B)(3)(a), apparently not, and not even within the same distribution panel. In the old days we used to feed the normal side of fire pump transfer switches from a separate compartment or vertical section in the main switchboard, but nowadays usually try to run a separate service lateral from the utility directly to the controller/ATS.

and, can the OCPD from a generator be in the same vertical section as the Critical Branch feeder, the Life Safety Branch feeder and the Equipment System Feeder.

From 695.4(B)(3)(b), apparently yes. The fire pump may be considered an Article 700 load and does not have to be treated as an Article 701 or 702 load (going by the informational note under 700.2).

On a related note, a number of folks are designing or requiring equipment branch loads to be fed from separate vertical sections from life safety and critical feeds, but NFPA 70 and 99 code panel members have told me that the equipment branch is always intended to be an Art. 700 load and not required to be separate from the other two.

 

[roger]

From 695.4(B)(3)(b), apparently yes. The fire pump may be considered an Article 700 load and does not have to be treated as an Article 701 or 702 load (going by the informational note under 700.2).

I not sure I understand your point, article 695.4(B)(3)(B) already takes us to 700.10(B)(5)(a) and it is specific in it's requirment of separate vertical switchboard sections or separate disconects.

On a related note, a number of folks are designing or requiring equipment branch loads to be fed from separate vertical sections from life safety and critical feeds, but NFPA 70 and 99 code panel members have told me that the equipment branch is always intended to be an Art. 700 load and not required to be separate from the other two.

Who ever is saying this needs to spend some time in 517.30(B) and take note of the difference between the "Emergency System" 517.30(B)(2) and the "Equipment System" 517.30(B)(3) then they need to read 517.30(B)(B)(5)


There is also 517.30(C)

(C) Wiring Requirements.
(1) Separation from Other Circuits. The life safety branch and critical branch of the emergency system shall be kept entirely independent of all other wiring and equipment and shall not enter the same raceways, boxes, or cabinets with each other or other wiring.

Wiring of the life safety branch and the critical branch shall be permitted to occupy the same raceways, boxes, or cabinets of other circuits not part of the branch where such wiring complies with one of the following:
(1) Is in transfer equipment enclosures
(2) Is in exit or emergency luminaires supplied from two sources
(3) Is in a common junction box attached to exit or emergency luminaires supplied from two sources
(4) Is for two or more emergency circuits supplied from the same branch

There is no provision to allow them to be in the same section of switchgear

The wiring of the equipment system shall be permitted to occupy the same raceways, boxes, or cabinets of other circuits that are not part of the emergency system.

The Equipment System is basically treated the same as a 702 installation.

Roger

 

[RB1]

Roger,

This is why I hate the use of the term "normal" as used in the context of Article 695. There are two separate issues as I see it. One is the utility supply, the other is the utility supply disconnecting means. The utility supply must be a separate service or a tap ahead of the service disconnecting means per 695.3. The tap is actually ahead of the "normal" service disconnecting means. These conductors, whether a service tap or service lateral, are then are permitted to supply the single disconnecting means described in 695.4(B). It would be impossible for the utility supply to meet the requirements of 230.72(B), as referenced in 695.3(A), and be within the same switchboard. The disconnecting means for the on-site standby power source must be in a separate enclosure or separate vertical switchboard section from legally required or optional standby. I am not sure I understand your reference to Article 517. According to NFPA 99 the separate branches do not exist ahead of the transfer switch.

 

[VUGear]

I not sure I understand your point, article 695.4(B)(3)(B) already takes us to 700.10(B)(5)(a) and it is specific in it's requirement of separate vertical switchboard sections or separate disconects.

Right, it does take us to 700.10(B)(5), not specifically to subpart (a), but then there's nothing in 700.10(B)(5) that says a fire pump is anything but an emergency load. 700.10(B)(5) merely says that Art. 700 wiring is to be separate from Art. 701 and 702 wiring. 695.4(B)(3)(b) says, "in accordance with 700.10(B)(5) for emergency circuits". Why did they specifically say emergency circuits and not legally required or optional standby circuits? The Handbook commentary after 695.4(B)(3)(b) also reinforces that fire pumps are considered emergency and not legally required or optional standby.

Who ever is saying this needs to spend some time in 517.30(B) and take note of the difference between the "Emergency System" 517.30(B)(2) and the "Equipment System" 517.30(B)(3) then they need to read 517.30(B)(B)(5)

There is also 517.30(C)

There is no provision to allow them to be in the same section of switchgear

The Equipment System is basically treated the same as a 702 installation.

Yes, and the language in 517.30 is exactly what has led to the misinterpretation of the equipment system being something other than an Art. 700 load. My understanding is that upcoming editions will drop the "emergency system" designation in Art. 517 precisely to eliminate confusion on this; the essential electrical system for hospitals will then be made up of the three branches with no more reference to an "emergency system" being distinct from the equipment branch. This is moving the NEC to be in line with what has already been done in the 2012 NFPA 99.

I am not sure I understand your reference to Article 517. According to NFPA 99 the separate branches do not exist ahead of the transfer switch.

Right, the branches within the essential electrical system are actually not defined until you get to the transfer switch level. That's why the devices feeding life safety, critical and equipment transfer switches can be in the same vertical sections. Even though a device or feeder may be upstream of say, a life safety transfer switch, the device or feeder is itself not technically part of the life safety branch, but rather just part of the essential system in general.

 

[roger]

Right, it does take us to 700.10(B)(5), not specifically to subpart (a), but then there's nothing in 700.10(B)(5) that says a fire pump is anything but an emergency load. 700.10(B)(5) merely says that Art. 700 wiring is to be separate from Art. 701 and 702 wiring. 695.4(B)(3)(b) says, "in accordance with 700.10(B)(5) for emergency circuits". Why did they specifically say emergency circuits and not legally required or optional standby circuits?

Because it is an Emergency circuit, that is not being debated, but it also says; "From separate vertical switchboard sections, with or without a common bus or from individual disconnects mounted in separate enclosures."

The Handbook commentary after 695.4(B)(3)(b) also reinforces that fire pumps are considered emergency and not legally required or optional standby.

And once again, that is not being debated.

Yes, and the language in 517.30 is exactly what has led to the misinterpretation of the equipment system being something other than an Art. 700 load. My understanding is that upcoming editions will drop the "emergency system" designation in Art. 517 precisely to eliminate confusion on this;

And until something changes or the NFPA wants to issue an FI, it is what is and the wording is what it is.

the essential electrical system for hospitals will then be made up of the three branches with no more reference to an "emergency system" being distinct from the equipment branch. This is moving the NEC to be in line with what has already been done in the 2012 NFPA 99.

And when that takes place we can live by it, until then we will not be able to tell AHJ's that the words in 517 don't really mean anything.

Right, the branches within the essential electrical system are actually not defined until you get to the transfer switch level. That's why the devices feeding life safety, critical and equipment transfer switches can be in the same vertical sections. Even though a device or feeder may be upstream of say, a life safety transfer switch, the device or feeder is itself not technically part of the life safety branch, but rather just part of the essential system in general.

I can almost agree with this concerning the Emergency System verses the Equipment System unless someone wanted to compare figure 517.30 No 1 to Exhibits, 700.3, 700.4, and 700.5, of the handbook (you brought the handbook into the discussion ) where does the 700, 701, and 702 systems start?

Roger

 

[VUGear]

Because it is an Emergency circuit, that is not being debated, but it also says; "From separate vertical switchboard sections, with or without a common bus or from individual disconnects mounted in separate enclosures."

Okay, so are you saying that 700.10(B)(5)(a) not only requires wiring for legally required and optional loads to be separate from that for emergency, but also requires that wiring for emergency loads (or at least fire pumps in particular) be separate from other emergency loads?

Even though 695.4(B)(3)(b) refers to 700.10(B)(5), I'm not sure I see where it follows that either (i) fire pump conductors are to be separate from those serving other emergency loads or (ii) fire pumps are anything but an emergency load. Particularly in light of the admittedly non-canonical Handbook commentary after 695.4(B)(3)(b) as well as the informational note under 700.2. All I see is that fire pumps are to be treated like any other emergency system load and thus kept separate from legally required and optional standby loads. The wording in 700.10(B)(5) ahead of subpart (a) is not addressing one particular system or branch that has to be separate per subpart (a), but rather wiring for a combination of Art. 700, 701 and 702 loads. I don't see that it says there also has to be separation among Art. 700 loads.

If the intent of 695.4(B)(3)(b) was to keep fire pump emergency-side disconnecting means separate from ALL other loads, then why not explicitly say so or reference 700.10(B)(5)(a) in particular instead of the entirety of 700.10(B)(5)? Or do you feel the commentary under 695.4(B)(3)(b) is incomplete?

And until something changes or the NFPA wants to issue an FI, it is what is and the wording is what it is. And when that takes place we can live by it, until then we will not be able to tell AHJ's that the words in 517 don't really mean anything.

I've found that AHJs are often amenable to recognizing newer editions of code that are not yet adopted in their jurisdiction if they are shown how and why the change was made and they don't have a problem with the newer language.

I can almost agree with this concerning the Emergency System verses the Equipment System unless someone wanted to compare figure 517.30 No 1 to Exhibits, 700.3, 700.4, and 700.5, of the handbook (you brought the handbook into the discussion ) where does the 700, 701, and 702 systems start?

Based on the three Exhibits in 700, where each seems to be compliant, as well as 700.10(B)(5)(d), it appears that the delineation of emergency, legally required and optional standby feeders can occur upstream of possible system transfer switches, at the point of overcurrent protection. The commentary after 700.10(B)(5)(d) is helpful here. Article 517 would appear to address (at least for now) the particular case of an emergency system that is used in hospitals, and which is further delineated into three branches of that system.

 

[roger]

Okay, so are you saying that 700.10(B)(5)(a) not only requires wiring for legally required and optional loads to be separate from that for emergency, but also requires that wiring for emergency loads (or at least fire pumps in particular) be separate from other emergency loads?

Yes that is what I'm saying, I am not so sure this is the intent but it is what it says or at least the way I read it.

Even though 695.4(B)(3)(b) refers to 700.10(B)(5), I'm not sure I see where it follows that either (i) fire pump conductors are to be separate from those serving other emergency loads or (ii) fire pumps are anything but an emergency load.

I see the flip side.

Particularly in light of the admittedly non-canonical Handbook commentary after 695.4(B)(3)(b) as well as the informational note under 700.2. All I see is that fire pumps are to be treated like any other emergency system load and thus kept separate from legally required and optional standby loads.

And I see it as requiring Fire Pumps to be kept separated from other Emergency loads.

The wording in 700.10(B)(5) ahead of subpart (a) is not addressing one particular system or branch that has to be separate per subpart (a), but rather wiring for a combination of Art. 700, 701 and 702 loads.

And to that statement I will say that the section is poorly written.

I don't see that it says there also has to be separation among Art. 700 loads.

And I don't see clear enough wording that says it doesn't.

If the intent of 695.4(B)(3)(b) was to keep fire pump emergency-side disconnecting means separate from ALL other loads, then why not explicitly say so or reference 700.10(B)(5)(a) in particular instead of the entirety of 700.10(B)(5)? Or do you feel the commentary under 695.4(B)(3)(b) is incomplete?

I feel the the actual code wording is lacking in clarrity which leaves us at our differences of what is being said

I've found that AHJs are often amenable to recognizing newer editions of code that are not yet adopted in their jurisdiction if they are shown how and why the change was made and they don't have a problem with the newer language.

And when the 2014 is actually in print I could see that some might recognize a future change but, it isn't released in print yet.

Based on the three Exhibits in 700, where each seems to be compliant, as well as 700.10(B)(5)(d), it appears that the delineation of emergency, legally required and optional standby feeders can occur upstream of possible system transfer switches, at the point of overcurrent protection. The commentary after 700.10(B)(5)(d) is helpful here. Article 517 would appear to address (at least for now) the particular case of an emergency system that is used in hospitals, and which is further delineated into three branches of that system.

Agreed.

Roger

 

[RB1]

VUgear,

Fire pumps are actually rarely considered to be an emergency load. The IBC requires fire pumps to be considered a standby load for high-rise buildings. Additionally, where the service is considered to be reliable, a connection ahead of the "normal" service disconnecting means is all that is required for a fire pump.

 

[VUGear]

VUgear,

Fire pumps are actually rarely considered to be an emergency load.

Right, but I was responding to the OP's question which was regarding the specific case of separation from life safety, critical and equipment branches.

However as a side note, it seems noteworthy that 695.4(B)(3)(b) points to Art. 700 and not Art. 701 or 702; so even though in a non-hospital situation such as a high rise, which has both "emergency" and "standby" loads, you may have a fire pump that is considered a standby load, but you still have to apply an emergency load standard to it with respect to the emergency-side feed.

 

[roger]

Right, but I was responding to the OP's question which was regarding the specific case of separation from life safety, critical and equipment branches.

So, do you agree that a Fire Pump must have separation from the Life Safety Branch, Critical Branch, and the Equipment System?

However as a side note, it seems noteworthy that 695.4(B)(3)(b) points to Art. 700 and not Art. 701 or 702;

I agree.

so even though in a non-hospital situation such as a high rise, which has both "emergency" and "standby" loads, you may have a fire pump that is considered a standby load, but you still have to apply an emergency load standard to it with respect to the emergency-side feed.

I agree here as well.

Roger