Gus -
I picked out pieces of your comment. I'm not trying to mis-quote you, just gather up the parts that matter to me. So if you see anything that looks like a mis-quote, I'll back right off.
...No inspector has the knowledge, time, or testing facilities to recognize the hazards that might be present with a piece of pre-wired equipment. ...
...The governing body and the customer look to the inspector for that assurance ...
I think a lot of my issues start right here. These two are mutually exclusive. With having the knowledge, time, testing facilities, the AHJ/Inspection agency can not supply assurance. In most of the stuff i work on, that NRTL label won't help a bit (I'll show why later)
...The governing body and the customer look to the inspector for that assurance, and I don't know of a practical way to attain that without a "NRTL" label. ...
Let's look at an installation, perhaps similar in complexity to the OP.
Say the installation is:
Service point is on the primary, 69kv
Two 10mva xfm
Plant distribution is HRG 13.8kv
5 Parallel feeders to double ended 100kva, 480V NGR substations
Two black start, 1750kva, HRG, 13.8kv DGs tied in at the main 13.8kv distribution.
Several 120V UPS, one 480V, 3ph UPS
We are bringing this thing up in pieces. As each section gets done, the inspection/commissioning gets completed and it gets turned on.
So the 69kv is completed, transformers are completed, 13.8kv substation is in, DGs are in, we are commecting the 13.8kv feeders. We are ready to commission/energize right up to the 13.8kv main.
AHJ/Inspector walks in and says:
"I don't see a label on the:
69/13.8 transformers
13.8Kv airbreaks on the transformer secondaries;
13.8kv circuit breakers;
Diesel Generators;
480V battery charger"
Engineer:
The transformers are ansi rated not UL. I don't think I have ever seen a 69kv xfm with a UL sticker.
The 13.8kv equipment is generally used by utilities. Listings are not available cause the utilities don't need it or want to pay for it.
The UL listing for generators, UL2200, stops at 600V.
The UL listing for battery chargers stops at 150V.
There is nothing in the NEC that requires any of this equipment to be listed.
AHJ/Inspector:
The State of Tennessee requires it.
Engineer:
We can certainly spend $200K and get a UL field evaluation - except for the 69kv gear and the transformer. Those two I don't know about. For the generators, the only part we can get listed is the control equipment. There won't be a field evaluation for the generator itself.
However I am curious as to your opinion:
1. After we spend this money, just how much safer do you think the installation will be?
2. If the 69kv CB, transformers, 13.8kv cbs (the substation) belonged to the utility, none of it would have a UL sticker. Would it be less safe then?
3. Say we have an agreement with the utility: After the substation is completed, commissioned, operational, we are going to give it to them. They will own it and maintain it. Our service point will be on the load side of the 13.8kv feeder CBs. Metering is still primary - the utility is not going to eat the cost of heating the transformers. Does the equipment still require a sticker? If not, is it still safe?
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...What other choices does an inspection program have ? ...
Two options I can see:
1. Take some of the money charged for the permit and hire out for a
competent plans review. Take the rest of the permit money and inspect that the installation is per plan. Keep 10% of the money to pay for the overhead. Of course that would mean that the city/state doesn't get all the money to bloat the bureaucracy.
2. For the cookie-cutter NEC designed parts, inspect to the NEC, require all NRTL listed equipment if the state wishes. For the non-cookie-cutter designed parts, the ones where the inspector does not have the knowledge, time, facilities, keep the money and believe the stamped drawings. Require listed equipment where the NEC has specific requirements.
Where would I draw the line?
If there are no stamped drawings, require all NRTL listed equipment. This relieves the inspector for the time, knowledge, facilities part.
If there are stamped drawings then require listed equipment where the NEC has requirements. And if the NEC requires a listing, then a letter from a PE does not change that.
Just an opinion
cf