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    210.12(B) Exception: AFCI 6ft rule

    Recently AHJ wrote report saying the 4 ft conduit containing circuits does not meet exception since the Hot+Grounded conductor's length would be 8ft in total. Unfortunately interpreting idioms is long and I will paste the email that won the exception back from the AHJ (after Lead Electrical Inspector -> Her Sup -> Technical review committee) however I wish to summarize:

    TL/DR: 210.12(B) should deal with length of cable from termination to termination or length of conduit or distance of enclosures as saying "extension of existing conductors is not more than 1.8m (6 ft)" is open to some wild interpretation that would be completely outside of the electrical panel's meaning.

    From: Field Inspector (LNI)
    Sent: Wednesday, July 20, 2016 8:52 AM
    To: Lead Inspector (LNI)
    Subject: 210.12 B exception

    Yesterday you forwarded me a voice message about a panel change that relocated the panel.

    The panel location is approximately 4-5 feet away from the original location. The circuits are running through several liquid tight flexes out of the bottom of the panel, through the wall into the old panel can (Zinsco above a stair landing)

    The way I read the exception, “less than 6’ of conductor” I see that there is now 8-10’ of new conductor for each 120V circuit (hot and neutral)

    What say you?
    From: Lead Inspector
    Sent: Wednesday, July 20, 2016 8:55 AM
    To: Field Inspector
    Subject: RE: 210.12 B exception

    I say that the panel should be relocated from the stairs so it will have to be ARC-faulted because it is lengthy in relocation
    From: Chad Ferguson
    Sent: Wednesday, July 20, 2016 10:27 AM
    To: Field Inspector
    Subject: RE: 210.12 B exception

    While I do not have [Lead Inspector]’s email this plan was brought up to her on 7/12 she will have record of me trying to get ahold of her through the chief’s office and an email was sent to her saying to call me back.

    I expressed the following: Existing 14” wide Sylvania-Zinsco panel located on non-conforming location on stairwell, asking if a new panel can be installed on the stairwell if a landing is put in. Expressed we did not want to move the panel under the stairs as it would be more than 6ft of move and did not want to do AFCI. She confirmed stairwell would not be acceptable for panel and that my proposed idea of putting the panel 4 ft away on the outside of the house would not require AFCI and would be in a conforming location and that conveyances are never issued for panels on stairwells.

    Now I know that a phone call is not plan review there is a huge disparity here as all other jurisdictions in this state have the panel located no more than 6 ft away not requiring AFCI. By the same logic take the following must be true for all of your correction action to be true:

    A circuit is comprised of only 2 wires, the EGC is not considered a “Conductor” else:
    3 wire circuit: Hot+grounded+egc = 2 ft extension before AFCI REQUIRED
    4 wire circuit: Hot+hot+grounded+egc = 1.5 ft extension before AFCI REQUIRED

    Transversely what you’re claiming:
    3 wire circuit: Hot+grounded = 3 ft extension before AFCI REQUIRED
    4 wire circuit: hot+hot+grounded = 2 ft extension before AFCI REQUIRED

    GIVEN the code says 210.12(B) Exception: AFCI protection shall not be required where the extension of the existing conductors is not more than 1.8 m (6 ft) and does not include any additional outlets or devices.

    GIVEN the aforementioned section paraphrases: 210.12(B): In any of the areas specified in 210.12(A), where branch-circuit wiring is modified, replaced, or extended, the branch circuit shall be protected by one of the following

    The question is: is the phrase “extension of the existing conductors” referring to a branch circuit’s length given the individual conductors (Which I present before is fallacious GIVEN the examples of EGC and multiwire circuits above) or is it referring to the conductors indirectly as a group contained in a set (cable) where that group’s length must not exceed 6 feet. I see this as the more logical and correct interpretation of code as the code does say 6 feet after all and not 1.5, 2 or 3 feet.

    PURPOSE

    I think Jade Learning provides insight into the panel’s purpose when it states the following:

    [ATTACH=CONFIG]15345[/ATTACH]

    Since the image might not come through on some cell phones I will type:

    This exception was added to cover cases where the dwelling unit panelboard is replaced or upgraded, and the original branch-circuit wiring has to be extended to reach the new location. The Code panels felt 6 ft. was a long enough distance to cover this type of circuit modification.

    This is referring to branch-circuit wiring and its idiom is that of the conductors are a set contained inside of that branch-circuit and that set’s length must not be more than 6ft.

    CONCLUSION:

    I agree the code should focus more on enclosure mounting distance which is its intent in the first place. Given the circumstances I beg you to reconsider the corrections wrote on Permit #XXXXXXXE, even if the content of the email does not sway your interpretation in the future given the communication I’ve had with [Lead Inspector].

    I look forward to your response, Have a good day.

    References:

    Electrical Currents 2014 Issue 07

    NFPA 70 NEC 2014

    http://www.jade1.com/jadecc/registra...Date=6/30/2014


    Thank you,
    Chadwick Ferguson
    Attached Files

    #2
    [COLOR=#333333]Section/Paragraph: 210.12(B) Exception.[/COLOR]

    [COLOR=#333333]Added Text[/COLOR]

    210.12(B) Branch Circuit Extensions or Modifications -- Dwelling Units.
    In any of the areas specified in 210.12(A), where branch-circuit wiring is modified, replaced, or extended, the branch circuit shall be protected by one of the following:
    (1) A listed combination-type AFCI located at the origin of the branch circuit
    (2) A listed outlet branch-circuit type AFCI located at the first receptacle outlet of the existing branch circuit

    Exception: AFCI protection shall not be required where the [COLOR=#ff0000]raceway length the branch circuit extension is traveling in [/COLOR]is not more than 1.8 m (6 ft) and does not include any additional outlets or devices.[COLOR=#FF0000]
    [/COLOR]

    Substantiation

    See Above

    Comment


      #3
      Doesnt WAC 296-46B-240 024F allow the panelboard to be over the steps? Or were they citing a working space violation?

      024(F) Not located over steps.
      If the overcurrent device is a part of a panelboard that is being repaired or replaced in an existing location, the installation is allowed to be made above the steps.
      Ethan Brush - East West Electric. NY, WA. MA

      "You can't generalize"

      Comment


        #4
        Yes, there were a few words had about that also. in the Field Inspectors words "It pays to know the WAC." Unfortunately this specific rule did not come to my, the other PM, the Journeyman, or the Lead Inspector's mind when laying the project out. I believe the main factor is we are primarily a Seattle contractor and when DPD is the AHJ they will not allow the panel to exist on the stairs and are even known to write home owner corrections about this issue if it is persisting.

        Comment


          #5
          Over stairwell panel

          Originally posted by electrofelon View Post
          Doesnt WAC 296-46B-240 024F allow the panelboard to be over the steps? Or were they citing a working space violation?
          WAC does not permit new construction panels over stairwells since 2014 NEC adoption but that may not affect the project if this is a Seattle City permit that was probably pulled prior to JUL 2015 last year. Those projects would have been under the Seattle 2008 codes that lag behind LNI requirements. The last mid-rise dwelling project I was brought on to consult was the case for the NM install methods upgraded to save time on the project. I am retired but very active publishing on the latest installation methods. (I.e. Dual Function OCPD methods.) RBJ, aka gndrod
          rbj, Seattle...Safety is a Professional Courtesy.

          Comment


            #6
            Originally posted by lavacano View Post
            [COLOR=#333333]Section/Paragraph: 210.12(B) Exception.[/COLOR]

            [COLOR=#333333]Added Text[/COLOR]

            210.12(B) Branch Circuit Extensions or Modifications -- Dwelling Units.
            In any of the areas specified in 210.12(A), where branch-circuit wiring is modified, replaced, or extended, the branch circuit shall be protected by one of the following:
            (1) A listed combination-type AFCI located at the origin of the branch circuit
            (2) A listed outlet branch-circuit type AFCI located at the first receptacle outlet of the existing branch circuit

            Exception: AFCI protection shall not be required where the [COLOR=#ff0000]raceway length the branch circuit extension is traveling in [/COLOR]is not more than 1.8 m (6 ft) and does not include any additional outlets or devices.[COLOR=#FF0000]
            [/COLOR]

            Substantiation

            See Above
            The current wording allows an extension of up to 6' of conductor if you change that to 6' of raceway then the conductors could be of any length.
            Rob

            Moderator

            All responses based on the 2017 NEC unless otherwise noted

            Comment


              #7
              Iirc, 210.12(B) was an rop accepted to accommodate service upgrades , written by a mod on the site (whom i'll let himself reveal) , so we may have a real 'insider' ...


              ~RJ~

              Comment


                #8
                Originally posted by romex jockey View Post
                Iirc, 210.12(B) was an rop accepted to accommodate service upgrades , written by a mod on the site (whom i'll let himself reveal) , so we may have a real 'insider' ...


                ~RJ~
                The heck with waiting, I'll out the feller.

                The 2014 ROP:

                2-115 Log #536 NEC-P02
                Final Action:
                Accept in Principle
                (210.12(B))
                __________________________________________________ ______________
                Submitter:
                Dennis Alwon, Alwon Electric Inc.

                Recommendation: Add new text to read as follows:
                Exception: Where extension of the branch circuit does not include any added
                outlets or devices.

                Substantiation:
                Often times when changing a service in an older home the
                branch circuit conductors do not reach the new location of the panel. The wire
                is sometimes just spliced inside the panel to reach the termination points while
                other times the circuit may need to be extended a short distance to reach the
                new location. Since many areas are inspecting this differently throughout the
                country this exception would clarify this section and bring uniformity
                throughout.

                Panel Meeting Action: Accept in Principle

                Revise the proposed wording to read as follows:
                “Exception: AFCI protection shall not be required where the extension of the
                existing conductors is not more than 1.8 m (6 ft.) and does not include any
                additional outlets or devices.”

                Panel Statement:
                The revised wording provides clarity and satisfies the intent
                of the submitter.

                Number Eligible to Vote: 11
                Ballot Results:
                Affirmative: 9 Negative: 1 Abstain: 1

                Explanation of Negative:
                KING, D.: This Proposal should be rejected. It is the intent of Section
                210.12(B) to provide AFCI protection where circuits that are covered by
                210.12(A) are “modified.” The submitter has not provided any substantiation to
                allow for an exception for AFCI Protection in the branch circuit modification
                described in his substantiation. Accepting the proposed exception would greatly
                dimish the level of safety currently provided by the requirements of 210.12(B).

                Explanation of Abstention:
                ORLOWSKI,
                S.: See my Explanation of Vote on Proposal 2-92.

                Comment on Affirmative:
                HILBERT, M.: Continue to accept in principle. The issues noted in the
                substantiation for this proposal and Proposal 2-11 are often topics of discussion
                at IAEI meetings as well as other educational meetings and do need
                clarification.

                The proposed language as revised by the panel’s accept in principle action
                will go a long way in promoting uniform interpretations. It will clarify that
                extending branch circuit conductors within an enclosure for the purposes of
                replacing a device or utilization equipment or for extending a branch circuit to
                a panelboard being replaced or upgraded does not require an AFCI protective
                device to be installed.

                Six feet was chosen for branch circuit extensions as it should provide a
                sufficient length for most applications where an existing panel is being
                relocated out of a clothes closet or to comply with readily accessible
                requirements, etc.
                Last edited by jumper; 11-05-16, 11:21 AM.
                [COLOR="blue"]"Electricity is really just organized lightning." George Carlin


                Derek[/COLOR]

                Comment


                  #9
                  You outted me

                  Yea, I didn't like that they added the 6' rule as one could argue that the distance is from termination to termination rather than between enclosures. IMO, the 6' distance can be very tight in many instances even between enclosures.

                  FWIW one cmp member stated the distance is from terminations... not between enclosures.
                  They say I shot a man named Gray and took his wife to Italy
                  She inherited a million bucks and when she died it came to me
                  I can't help it if I'm lucky

                  Comment


                    #10
                    Though I see the point of bringing up the fact the rule concerns the conductor length and not the length of a raceway, the inspector in OP is halving the rule by wanting to measure both conductors of the circuit. I think the rule intended to include just the one way length of conductor involved but include all conductors of the circuit in that length.
                    I live for today, I'm just a day behind.

                    Comment


                      #11
                      I can't imagine why the inspector is using the conductor length both ways.... Assuming nm cable then how would 3' of nm being of any help at all... the inspector is in error.

                      Ask the inspector how he would calculate a multiwire branch circuit--- 2' of cable???? Makes no sense
                      They say I shot a man named Gray and took his wife to Italy
                      She inherited a million bucks and when she died it came to me
                      I can't help it if I'm lucky

                      Comment


                        #12
                        Originally posted by Dennis Alwon View Post
                        I can't imagine why the inspector is using the conductor length both ways.... Assuming nm cable then how would 3' of nm being of any help at all... the inspector is in error.

                        Ask the inspector how he would calculate a multiwire branch circuit--- 2' of cable???? Makes no sense
                        Make it a three phase MWBC and you only get 18".

                        Extend two of them as part of the same panel move and get 9"?

                        Comment


                          #13
                          Originally posted by GoldDigger View Post
                          Make it a three phase MWBC and you only get 18".

                          Extend two of them as part of the same panel move and get 9"?
                          Yep, gets absurd doesn't it. Not sure if the inspector is just being difficult or if he really thought it was meant to be that way. I can assure him he is ioncorrect
                          They say I shot a man named Gray and took his wife to Italy
                          She inherited a million bucks and when she died it came to me
                          I can't help it if I'm lucky

                          Comment


                            #14
                            Originally posted by Dennis Alwon View Post
                            IMO, the 6' distance can be very tight in many instances even between enclosures.
                            No doubt, even the 10' tap rule can be tough to comply with.

                            Comment


                              #15
                              Originally posted by Dennis Alwon View Post
                              Yep, gets absurd doesn't it. Not sure if the inspector is just being difficult or if he really thought it was meant to be that way. I can assure him he is incorrect
                              I agree and really would 3' or 6' make any difference? Your proposal was great because it adds direct language as to how the distance is measured and takes care of an extremely common installation.
                              Rob

                              Moderator

                              All responses based on the 2017 NEC unless otherwise noted

                              Comment

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