BS excuse or legitimate gripe? (WV marina refusing to add GFCIs to boat slips)

[htroberts]

This:

http://www.theet.com/news/local/boa...cle_8ce8b12e-1ce9-11e4-8580-0019bb2963f4.html

popped up in an EC&M newsletter, in which a marina owner is going to turn off electrical service to 92 boat slips because they "can't afford" the $600K price tag to retrofit GFCIs to comply with a West Virginia law passed after a teenager was shocked and subsequently drowned.

Obviously I've not seen the proposal or jobsite, and maybe a simple retrofit isn't possible, or there are other pending non-compliances that an upgrade would trigger addressing, but $6521 per boat pedestal sounds a little high to me to add GFCIs.

Is this a BS move covering for a political protest? Or does this seem reasonable? Other than replacing the entire distribution system, what could drive the cost so high?

 

[greenspark1]

Well it's really hard to say what drove the cost so high. There could by a host of other issues that need to be remedied to bring the docks up to Code. I assume installing GFCI on the feeder to the docks would solve the GFCI problem, no reason to install one for each slip.

Considering this is the same marina where the teenager was killed, I find it disrespectful that they won't install the safety equipment.

 

[petersonra]

I find it disrespectful that they won't install the safety equipment.

It is a moot point if they do not have $600k laying around.

I have never been involved in a marina project but I have run across a number of projects where the cost just seems insane for what was being done, but as I looked at what they ended up doing most of it made sense.

Some times things just cannot be fixed and have to be ripped out.

At least they have decided to shut off the electricity so it won't happen again.

 

[Jon456]

A couple of thoughts...

1. Yachts require 240VAC 3-pole/4-wire hook-ups up to 50A. So not quite as simple as adding a standard household GFCI.

2. Unless the yachts are configured with isolation transformers (you'd think it would be a mandated requirement, but it's not and very few boats have them), the GFCI's will be tripped constantly. So the net effect will be no power at the marina.

 

[starbolin]

...

Is this a BS move covering for a political protest? Or does this seem reasonable? Other than replacing the entire distribution system, what could drive the cost so high?

Kid died on the docks and now the powers have a political problem. The powers make it a code enforcement problem. Code enforcement makes it the business owners problem. Gray-water flows downhill:happysad:

 

[augie47]

Kid died on the docks and now the powers have a political problem. The powers make it a code enforcement problem. Code enforcement makes it the business owners problem. Gray-water flows downhill:happysad:

After some recent deaths at marinas in Tennessee there is similar legislation working its way through the system in our State. Mandatory periodic inspections, GF (100 ma or less) protection on all marina circuits, and efforts to ban swimming are included in the new rules.
I think Mike has some interesting articles on the subject at the main website.
Nationwide deaths have prompted stringent regulations in the '14 Code and these retroactive measures seem well founded.

 

[fmtjfw]

What I know:

What I know:

The marina in question is part of a state facility. Their current budget does not have an extra $600K. The kid the bill is named for died there. You think they don't have any pressure on them not to have a re-occurrence?

They have about 5 houseboats with "large" services, the kid was killed by a miswired houseboat. Not many "yachts". Plenty of small boat slips.

The bill was put in the "natural Resources" part of the state code, not under the Fire Marshal. The Game wardens just ignored it, since they didn't know how to enforce it. The Fire Marshal just recently got it dumped in his/their lap. The bill came into full force 1 Aug 2014. The state legislature passed an extension to 1Jan2015, but the Governor refused to sign it. The Fire Marshall expected the extension to pass. They are having us (a group I work with: IAEI and an engineering firm) organize and put on multi-day training sessions for the Fire Marshals, Owners, inspectors, and licensed electricians, but they are not scheduled until the fall.

Everybody is scrambling to do something. US Corps of Engineers believes there are about 500 marinas in the state. There are currently less than 20 licensed electrical inspectors at the "commercial" level, which is the minimum to inspect these electrical installations (how every many there may be). Imagine what it costs to inspect each and every element of an installation. Imagine what uninspected (or inspected by Joe "lick'em" Stickup) existing installations look like.

All the wiring must be installed by WV licensed Journeyman or Master. Apprentices can not touch it.

There is no grandfathering. The wiring must meet NEC2011, NFPA 303-2006?, several ABYC standards, and requirements of the bill to pass.

Even with the law known to them, owners are still building stuff that will not pass, hoping to worm out of the requirements somehow.(IMHO)

The boat circuits must be protected by GFE (30--100mA) not GFCI(6mA). Most non-boat circuits must be protected by GFCI(6mA).

[I may just go take the commercial inspectors' test and start my apprenticeship.]

 

[fmtjfw]

The marina in question is part of a state facility. Their current budget does not have an extra $600K. The kid the bill is named for died there. You think they don't have any pressure on them not to have a re-occurrence?

They have about 5 houseboats with "large" services, the kid was killed by a miswired houseboat. Not many "yachts". Plenty of small boat slips.

The bill was put in the "natural Resources" part of the state code, not under the Fire Marshal. The Game wardens just ignored it, since they didn't know how to enforce it. The Fire Marshal just recently got it dumped in his/their lap. The bill came into full force 1 Aug 2014. The state legislature passed an extension to 1Jan2015, but the Governor refused to sign it. The Fire Marshall expected the extension to pass. They are having us (a group I work with: IAEI and an engineering firm) organize and put on multi-day training sessions for the Fire Marshals, Owners, inspectors, and licensed electricians, but they are not scheduled until the fall.

Everybody is scrambling to do something. US Corps of Engineers believes there are about 500 marinas in the state. There are currently less than 20 licensed electrical inspectors at the "commercial" level, which is the minimum to inspect these electrical installations (how every many there may be). Imagine what it costs to inspect each and every element of an installation. Imagine what uninspected (or inspected by Joe "lick'em" Stickup) existing installations look like.

All the wiring must be installed by WV licensed Journeyman or Master. Apprentices can not touch it.

There is no grandfathering. The wiring must meet NEC2011, NFPA 303-2006?, several ABYC standards, and requirements of the bill to pass.

Even with the law known to them, owners are still building stuff that will not pass, hoping to worm out of the requirements somehow.(IMHO)

The boat circuits must be protected by GFE (30--100mA) not GFCI(6mA). Most non-boat circuits must be protected by GFCI(6mA).

[I may just go take the commercial inspectors' test and start my apprenticeship.]

Or maybe the Gov. did sign it? Confusion reigns! (1 Dec 2014?)

Failure to comply with the law is a misdemeanor. $100 per day fine

Injury -- $500-$1000 / up to 6 month sentence

Death -- $1000 / up to 1 year sentence.

 

[kwired]

Or maybe the Gov. did sign it? Confusion reigns! (1 Dec 2014?)

Failure to comply with the law is a misdemeanor. $100 per day fine

Injury -- $500-$1000 / up to 6 month sentence

Death -- $1000 / up to 1 year sentence.

Those are are small fines compared to what civil suits may be if someone is killed.

Someone needs to put on some kind of demonstrations for these owners of what can go wrong and why following NEC is cheap insurance, even though it doesn't appear that way upfront.

 

[fmtjfw]

Those are are small fines compared to what civil suits may be if someone is killed.

Someone needs to put on some kind of demonstrations for these owners of what can go wrong and why following NEC is cheap insurance, even though it doesn't appear that way upfront.

A conviction makes the work of the civil suit attorney much easier.

Also just for operation without passing inspection is $100 per day, which adds up.

I'm sure there will be a part of the training that will address what can go wrong.

Also an owners' liability insurance carrier is likely to cancel non-compliant docks.
And the Fire Marshal is likely to red tag it. There are probably more penalties for violating a red tag.

 

[StarCat]

Spot on

Spot on

Kid died on the docks and now the powers have a political problem. The powers make it a code enforcement problem. Code enforcement makes it the business owners problem. Gray-water flows downhill:happysad:

Spot on Starbolin
I also find it interesting that the politicians are attempting to micromanage the lack of common sense and lack of simple education about electricity that once existed but is no longer with electrical code manipulations which attempt to force more technology into an equation where personal responsibility has gone out the window.

 

[texie]

The marina in question is part of a state facility. Their current budget does not have an extra $600K. The kid the bill is named for died there. You think they don't have any pressure on them not to have a re-occurrence?

They have about 5 houseboats with "large" services, the kid was killed by a miswired houseboat. Not many "yachts". Plenty of small boat slips.

The bill was put in the "natural Resources" part of the state code, not under the Fire Marshal. The Game wardens just ignored it, since they didn't know how to enforce it. The Fire Marshal just recently got it dumped in his/their lap. The bill came into full force 1 Aug 2014. The state legislature passed an extension to 1Jan2015, but the Governor refused to sign it. The Fire Marshall expected the extension to pass. They are having us (a group I work with: IAEI and an engineering firm) organize and put on multi-day training sessions for the Fire Marshals, Owners, inspectors, and licensed electricians, but they are not scheduled until the fall.

Everybody is scrambling to do something. US Corps of Engineers believes there are about 500 marinas in the state. There are currently less than 20 licensed electrical inspectors at the "commercial" level, which is the minimum to inspect these electrical installations (how every many there may be). Imagine what it costs to inspect each and every element of an installation. Imagine what uninspected (or inspected by Joe "lick'em" Stickup) existing installations look like.

All the wiring must be installed by WV licensed Journeyman or Master. Apprentices can not touch it.

There is no grandfathering. The wiring must meet NEC2011, NFPA 303-2006?, several ABYC standards, and requirements of the bill to pass.

Even with the law known to them, owners are still building stuff that will not pass, hoping to worm out of the requirements somehow.(IMHO)

The boat circuits must be protected by GFE (30--100mA) not GFCI(6mA). Most non-boat circuits must be protected by GFCI(6mA).

[I may just go take the commercial inspectors' test and start my apprenticeship.]

Since this is such a hot button issue, I'm wondering how you and the group(s) conducting the training for these inspections interpret 555.3. Does the GF protection have to cover all the wiring on the dock or can it just be installed to protect the shore power outlet?

 

[htroberts]

It is a moot point if they do not have $600k laying around.

My question was more around understanding whether $600K was reasonable for what seems like a fairly simple project, and if it is, what are the likely components of the cost.

I've never done a marina, and I'm sure there are issues I don't appreciate, but this seemed to me like a ridiculously high cost for adding some sort of ground fault protection (I called it GFCI, although a device that trips at 100mA is obviously not a typical GFCI breaker) to 92 pedestals with marine outlets.

 

[GoldDigger]

Maybe you have to factor in replacing all the wiring so that the new GF devices don't trip?
The law may also eliminate all sorts of other grandfathered wiring methods.

 

[augie47]

Maybe you have to factor in replacing all the wiring so that the new GF devices don't trip?
The law may also eliminate all sorts of other grandfathered wiring methods.

From some of the marinas in this area the correcting might be the larger expense but seems to only substantiate the need.
It was discussed in early thread about the wisdom of having GF protection on individual feeders vs the entire circuit which would obviously effect the cost.
I have found it interesting that a few of the marinas in this area have been upgraded to GF service protection and the detection system in each case has had a dip-switch adjustable range taking it into the amperage (no ma) range.
I'm sure no one will ever increase the setting.

 

[htroberts]

Maybe you have to factor in replacing all the wiring so that the new GF devices don't trip?
The law may also eliminate all sorts of other grandfathered wiring methods.

I found the bill http://www.mileyinthehouse.com/wp-content/uploads/2013/03/Michael-Cunningham-Bill.pdf

The portion dealing with Marina wiring seems straightforward:

?20-7-26. Boat Dock and Marina Safety Requirements-Electrical Shock and Electrocution.

(a) All boat dock or marina owners or operators shall comply with the following requirements to prevent electrical shock, electrocution, or injury to users of their facilities and the surrounding areas:

(1) All electrical wiring shall be installed by and maintained by a holder of a valid West Virginia electrician license or master electrician license in accordance with the most recently adopted versions of the National Fire Protection Association's Standards for Marinas and Boatyards (NFPA) 303 and the National Electric Code (NFPA 70);

(2) Install ground fault circuit interrupters on all boat dock and marina electrical wiring circuits;

(3) Cause annual inspection by a West Virginia certified electrical inspector or master electrician of all sources of electrical supply, including ship-to-shore power pedestals, submergible pumps, and sewage pump-out facilities, that could result in unsafe electrical current in the water.​

[sic--not sure what happened to (b)]
(c) All work performed on rental motor boats or vessels shall be performed by electricians licensed in West Virginia who are familiar with ABYC standards or by an ABYC certified electrical technician.​

I thought this was interesting as well, although it's on the 'vessel' side.

?20-7-27. Boat and Vessel Safety Requirements-Electrical Shock and Electrocution.

(a) Every vessel shall have aboard all equipment meeting the ABYC standards necessary to ensure the safety of the passengers and the public from electric shock, electrocution, and electric shock drowning.

(b) Electrical wiring on a motorboat shall be performed by electricians licensed in West Virginia who are familiar with ABYC standards or by an ABYC certified electrical technician.​

I'd like to know what's in the ABYC standard.

So must comply with latest adopted code in WV; no grandfathering. I'd like to see the condition of the existing wiring that necessitates replacing the whole ball of wax. And as the law is written, I assume that future code versions will apply immediately as they're adopted as well...

 

[fmtjfw]

Spot on Starbolin
I also find it interesting that the politicians are attempting to micromanage the lack of common sense and lack of simple education about electricity that once existed but is no longer with electrical code manipulations which attempt to force more technology into an equation where personal responsibility has gone out the window.

Confused by your remark. It seems to me that the politicians are directing owners to follow the NEC and the NFPA 303 requirements, That all must be inspected this year and must pass the NEC2011 and NFPA303-2006 requirements. Further that you must be reinspected every 3 years. That you can't use apprentices to do the wiring -- is that the micromanagement? The inspections are going to be trouble enough, imagine what it would take to research when each part was installed when and dredge up NEC versions since the 50's. This in a state without building permits except in some municipalities. So, just start out at current requirements -- also an abundance of caution since more than one death has occurred.

The bill (At least the version the Fire Marshal has posted) states:
?20-9-2 You gotta put up a sign prohibiting swimming within 100 feet of the facility (which can be read at 80 feet away -- go figure?)

?20-9-3(1) 110 or 220 AC must be installed and maintained by a licensed journeyman or master. It must meet the most recently adopted NFPA 303 (stds for marinas and boatyards) [2006 version] and NEC2011. [Newer codes apply as they are adopted]

?20-9-3(2) Install ground fault circuit interrupters on all boat dock and marina electrical wiring circuits
?20-9-3(3) inspection before 1-aug-14 1-dec-2014 and once every 3 years thereafter. Inspect:
all sources of electrical supply
ship-to-shore power pedestals
submergible pumps
sewage pump-out facilities.
[also fueling facilities under electrical and fuel code requirements]


There are quotes from another version of the bill, but I am not sure it is the official one. The state site many contain the whole history of the drafting of the bill.

 

[GoldDigger]

It must meet the most recently adopted NFPA 303 (stds for marinas and boatyards) [2006 version] and NEC2011. [Newer codes apply as they are adopted]

Also retroactively? Should keep a lot of electricians and inspectors very busy....
I can sympathize with throwing at all grandfathering as a one time event, given how far back a lot of the installed systems go, but eliminating grandfathering into the indefinite future seems pointless.

 

[fmtjfw]

Since this is such a hot button issue, I'm wondering how you and the group(s) conducting the training for these inspections interpret 555.3. Does the GF protection have to cover all the wiring on the dock or can it just be installed to protect the shore power outlet?

Here is my tentative position.

You are required to have a 100mA or better GFE on:

1) Service entrance OCPD
or

2) All feeder OCPDs serving offshore wiring
or

3) All Branch circuit OCPDs serving offshore wiring.

You can use a combination as long as all offshore wiring is GFE protected.

I hang my hat on:

555.3 Ground-Fault Protection. The main overcurrent
protective device that feeds the marina shall have ground
fault protection not exceeding 100 mA. Ground-fault protection
of each individual branch or feeder circuit shall be
permitted as a suitable alternative.

If you GFE the service you are covering all offshore wiring. The phrase "branch or feeder circuit" leads me to include the circuit wires and not just the receptacle. Also note that at this part of the article we have not even mentioned "shore-power" receptacles. So I also read this to cover all feeders and branch circuits that supply any other wiring offshore. I believe common sense would lead one to include protection of the feeder and branch circuit conductors as they are often subjected to strain and movement.

Offshore receptacles 125V 15/20A not for powering boats are required to have GFCI (5mA) protection

Other GFCI requirements as stated elsewhere in the NEC and in 555.

I'd be interested in other interpretations -- with their rationale explained.

 

[fmtjfw]

Also retroactively? Should keep a lot of electricians and inspectors very busy....
I can sympathize with throwing at all grandfathering as a one time event, given how far back a lot of the installed systems go, but eliminating grandfathering into the indefinite future seems pointless.

Good point.

It is not pointless -- if one presumes the Codes require safer installations as they go forward.

But once they are brought up to a known level, maybe grandfathering can be reintroduced.

[You know of course that there have been fights about just 5mA GFICing everything and let the electricians and shipwrights figure it out]