230.85 Question

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Jimmy7

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Electrician
I have an elderly couple on a limited budget that want to change their rotted 100 amp service from fuses to breakers in their home. The dryer and range have three wire cables that are installed above the Sheetrock ceiling in the basement..

Due to the three wires, I was thinking I could use a 100 amp meter main with a piece of SEU in between the meter main and the main breaker of the panel. I was thinking this until I thought I heard there was some issue with the listing of a Milbank Meter Main being used in this situation. I reached out to Milbank and they said in part “You run into some labeling issues with the rating on standard meter mains that are listed as "suitable ONLY for use as service equipment". The emergency disconnect label on the outside of meter mains listed that way will have the label that says "emergency disconnect, service disconnect". For UL listing in order to remove the word only from the service equipment rating the neutral must be isolated from ground when it leaves the factory. Our standard meter mains don't have the ability to isolate the neutral.”.

What is the best way to change the 100 amp service without having to replace the three wire range and dryer cables?
 
What do they have now - separate meter and main panel? Where is the main panel, outside or inside? If you use a meter enclosure outside, followed by an emergency disconnect that is NOT labeled as a service disconnect, you can continue with 3 wire service conductors to the original main panel (whether reusing or installing a new one). This may be your only option unless the original main panel is outside and its main can serve as the emergency disconnect. Not sure if you are allowed to extend a 3 wire range or dryer circuit should the new main panel end up outside and is currently inside. That may give you some options if its allowed.
 
The meter socket is outside, and the panel is inside in the basement. The existing meter socket is rotted, and the panel has fuses
 
FWIW, the conflict described in the OP is only a labeling conflict, not a substantive conflict.

That is, "Suitable for Use Only as Service Equipment" should really be "Suitable only for Use as Service Equipment or on the Utility Side of the Service Equipment". Because SUOSE just means the neutral is permanently bonded to the case, which is what is required for the Service Equipment or anywhere on the utility side thereof, like a 230.85 Emergency Disconnect.

Prior to the 2020 NEC addition of 230.85, this distinction was immaterial. Now that it is material, the UL standard for the labeling hasn't caught up.

My point is that while the letter of the code is that it would be a violation, it's only a regulatory mixup, and a sufficiently reasonable AHJ should always approve it.

Cheers, Wayne
 
We’re in the 2023 code cycle here in MA. I think what I‘m looking for is in 230.85(B)(3) -

Other listed disconnect switch or circuit breaker that is marked suitable for use as service equipment, but not marked as suitable only for use as service equipment, installed on the supply side of each service disconnect.

If I can find a disconnect that fulfills this requirement, can I then run a three wire from the meter socket to the Nema 3R disconnect and then to the main breaker panel in the basement?
 
wwhitney said:
FWIW, the conflict described in the OP is only a labeling conflict, not a substantive conflict.

That is, "Suitable for Use Only as Service Equipment" should really be "Suitable only for Use as Service Equipment or on the Utility Side of the Service Equipment". Because SUOSE just means the neutral is permanently bonded to the case, which is what is required for the Service Equipment or anywhere on the utility side thereof, like a 230.85 Emergency Disconnect.

Prior to the 2020 NEC addition of 230.85, this distinction was immaterial. Now that it is material, the UL standard for the labeling hasn't caught up.

My point is that while the letter of the code is that it would be a violation, it's only a regulatory mixup, and a sufficiently reasonable AHJ should always approve it.

Cheers, Wayne
Click to expand...
SOUSE has factory label "Service Disconnect" and the metal on some SOUSE equipment is stamped "Service Disconnect"

UL 231 does make distinction between SUSE and SOUSE in the standard. The 2023 language change was due to the SOUSE listing.
 
shortcircuit2 said:
SOUSE has factory label "Service Disconnect" and the metal on some SOUSE equipment is stamped "Service Disconnect"
Click to expand...
Ok, the label would obviously need changing, and if the metal is stamped, that would be trouble. But still, this is a labeling issue, not a physics issue. Just slap your 230.85 "Emergency Disconnect -- Not Service Equipment" over the factory "Service Disconnect" label. [Not saying that complies with 2023 230.85, just that there is no good reason that isn't allowed.]

Cheers, Wayne
 
It is a 110.3(B) issue. Your suggestion (factory label change/removal) would be a field modification of listed equipment. This is (field modification) not accepted for any other equipment in the Code to my knowledge? If we cross the line here does that open the door to allow other 110.3(B) changes in the field or misuse of listed equipment?

Can I use a 4"-round plastic old work box to hang a 2-pound luminaire at a ceiling outlet? It is not a physics issue?

I did hear of 1 meter-main manufacturer working towards development and listing of a meter-main with a floating neutral. Have not seen one yet.
 
shortcircuit2 said:
It is a 110.3(B) issue. Your suggestion (factory label change/removal) would be a field modification of listed equipment. This is (field modification) not accepted for any other equipment in the Code to my knowledge?
Click to expand...
Equipment gets modified during field installation all the time. It's up to the AHJ to determine if the modification is a problem.

The issue is that UL and the NFPA have not acted in concert to reconcile UL 67 and NEC 230.85. A meter/main breaker with the neutral bar bonded to the case is perfectly suited in its design to be a 230.85 Emergency Disconnect. The problem is that UL 67 never envisioned this possibility, and any panelboard with the neutral bar not insulated from the case (11.2.2) is required to be marked SOUSE, and any equipment marked SOUSE (34.9.7) is required to mark its main breaker as "Service Disconnect." Delete those markings and you have a great meter/emergency disconnect product.

IMO the NFPA erred in the 2023 NEC in drafting 230.85(B)(2) and (3). Rather than prohibit the use of SUOSE equipment, it should have required that if used, any "Service Disconnect" marking be covered with an "Emergency Disconnect" label. Labeling problem solved. But I guess they want UL to change UL 67 and don't mind inconveniencing electricians in the meantime.

UL did recently update UL 67 (August 22, 2023) and changed 34.9.7. It now says:

UL 67 said:
34.9.7 If a panelboard is marked "Suitable only for use as service equipment," each service disconnection means for ungrounded conductors shall be marked "Service Disconnect." The panelboard may also be marked "Emergency Disconnect".

Note: An "Emergency Disconnect" marking is intended to provide a disconnect marking in accordance with Section 230.85 of the National Electrical Code, NFPA 70.
Click to expand...

Apparently UL doesn't want to play along--marking the panelboard "Emergency Disconnect" doesn't do anything to help, as it still is required to be marked "SOUSE," with the mains still required to be marked "Service Disconnect." To avoid useless labeling disputes with NEC 230.85, UL would have needed to allow the marking of "Emergency Disconnect" in lieu of "Service Disconnect," ideally as field installable labels. And they would need to change the wording of SOUSE to something like "Line Side Suitable Only for Use with Service Conductors."

The upshot is still that this is a labeling dispute only. To strictly comply with NEC 230.85, right now you would need to find a meter/main breaker that has a factory insulated neutral bar, even though you need to bond the neutral bar to the case anyway. I.e. it's a pointless exercise just to get the right labels from the factory.

Cheers, Wayne
 
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