scotteng
Member
- Location
- Apollo Beach, FL
- Occupation
- Professional Engineer
Please forgive the length in advance, but the issue deserves it to fully explain my dilemma...
I have designed a 14,300 sq. ft. grocery store which is one tenant within a larger retail building. This is phase I of the project. In phase III, the store will take over an adjacent tenant and become closer to 40,000 sq. ft. A generator was initially planned to be part of phase III. Thus, without a generator in phase I, our design used battery packs (unit equipment) for the emergency lighting. The batteries are in the fixtures, not wall mounted emergency lights.
A couple of days before the permit for phase I is due, the owner decides he would like the generator in phase I.
Because the store was designed with battery packs, it was agreed that we would leave the wiring and batteries as-is and treat the generator as optional stand-by. The owner wanted their lights to continue to run as the primary function of the generator, so we installed the transfer switch ahead of the lighting panel. Thus, if utility drops out, the unit equipment powers the emergency lights for 10 seconds until the stand-by generator kicks in and all lights come on. The store would then still have 90 minutes of emergency lighting in the event the generator failed as well.
During plan review, the reviewer states that in the City of Los Angeles, you cannot connect an optional stand-by generator to the normal power system and it subsequently feed fixtures with unit equipment. There is no requirement stating such that I can find in the Los Angeles Municipal Code (a.k.a. local amendment), California Electrical Code (derivation of the NEC), or the California Building Code (derivation of the IBC).
Some of his statements are:
? The wiring design is acceptable if we remove the generator (and thus don't have a second normal source powering emergency fixtures).
? That design is acceptable if we re-circuit the emergency fixtures to a panel that is not fed from the generator.
? His interpretation is that 700.12, unit equipment normal source means "utility source".
I asked to speak to the head electrical plans reviewer for LADBS, and to my amazement, his response was the same. "You can't do that here". He said "once you put in a generator and connect it to your emergency lights, that generator is an emergency generator and all wiring will be considered emergency wiring if they power emergency lights". Neither understood that our emergency wiring in the store is only the leads coming out of the battery ballast. Neither would take the time to clearly state a code section that backs their "interpretation" other than to state that the portion of 700.12 for unit equipment that talks about the "normal" source, they define that as being the utility company.
Admittedly, I am hard headed, but I've designed literally hundreds of stand-by and emergency generator systems and feel I have a rock solid understanding of each. If there is anyone who can help with a convincing argument I could use, I would greatly appreciate it.
I have designed a 14,300 sq. ft. grocery store which is one tenant within a larger retail building. This is phase I of the project. In phase III, the store will take over an adjacent tenant and become closer to 40,000 sq. ft. A generator was initially planned to be part of phase III. Thus, without a generator in phase I, our design used battery packs (unit equipment) for the emergency lighting. The batteries are in the fixtures, not wall mounted emergency lights.
A couple of days before the permit for phase I is due, the owner decides he would like the generator in phase I.
Because the store was designed with battery packs, it was agreed that we would leave the wiring and batteries as-is and treat the generator as optional stand-by. The owner wanted their lights to continue to run as the primary function of the generator, so we installed the transfer switch ahead of the lighting panel. Thus, if utility drops out, the unit equipment powers the emergency lights for 10 seconds until the stand-by generator kicks in and all lights come on. The store would then still have 90 minutes of emergency lighting in the event the generator failed as well.
During plan review, the reviewer states that in the City of Los Angeles, you cannot connect an optional stand-by generator to the normal power system and it subsequently feed fixtures with unit equipment. There is no requirement stating such that I can find in the Los Angeles Municipal Code (a.k.a. local amendment), California Electrical Code (derivation of the NEC), or the California Building Code (derivation of the IBC).
Some of his statements are:
? The wiring design is acceptable if we remove the generator (and thus don't have a second normal source powering emergency fixtures).
? That design is acceptable if we re-circuit the emergency fixtures to a panel that is not fed from the generator.
? His interpretation is that 700.12, unit equipment normal source means "utility source".
I asked to speak to the head electrical plans reviewer for LADBS, and to my amazement, his response was the same. "You can't do that here". He said "once you put in a generator and connect it to your emergency lights, that generator is an emergency generator and all wiring will be considered emergency wiring if they power emergency lights". Neither understood that our emergency wiring in the store is only the leads coming out of the battery ballast. Neither would take the time to clearly state a code section that backs their "interpretation" other than to state that the portion of 700.12 for unit equipment that talks about the "normal" source, they define that as being the utility company.
Admittedly, I am hard headed, but I've designed literally hundreds of stand-by and emergency generator systems and feel I have a rock solid understanding of each. If there is anyone who can help with a convincing argument I could use, I would greatly appreciate it.
