250.184 is not and can not be made applicable to your 'existing' step-up transformer. Your 12kV system does not have a neutral point.
If the AHJ wants the 12kV system (not just the 'metal' parts) grounded, your only choice is to purchase and install an artificial neutral under 250.182. Only then, can you begin to apply any of the requirements of 250.180. You will also need to pull new cables per 250.184(A)(2) and (B)(8)
I don't have much to add. Most all has been said by others. The wrong transformer was ordered. Xfm1 should have a 480D/12460Y. It might be worth checking if the right one was ordered and the wrong one shipped. Be nice if someone would pay for a new xfm, provided the customer didn't mind waiting. I also don't have a clue why there wasn't an EGC speced for the 12460V raceway.
Jim pretty well has the reasonable responses nailed. Grounding transformer and pull an EGC. I had delusions of digging up the PVC and laying a DB conductor along side of the MV conduit. Then reality struck: The cost of digging up the conduit, without breaking it, is likely a lot more than pulling the conductors out and pulling back in with an EGC. If you are careful (and lucky), you could re-use the existing conductors
As Jim pointed out, the minimum size (ampacity) of the EGC is specified by code. I don't see any way the shields could provide the required size.
--- There is no easy fix for the discrepancies (except to run the 12kV system ungrounded).
For some reason ungrounded really bugs me. It's not code issues, it's design issues. I really would not want to put in an ungrounded system without ground detectors, and ground detectors require someone to look at them occasionally and know what to do, and from your posts, this would not be considered a supervised installation.
Jim -
Have you ever worked with un-grounded MV systems? I don't recall any. Lots of impedance grounded - mostly high impedance, some solidly grounded, but no un-grounded. Where/why would one use one?
What to do?
It appears the suituation has gone adversarial - which generally means everybody is screwed, even if the job finishes okay. Bummer
1. Start with the GC:
You are not going to "interpret" the engineers rfi responses. They don't provide a detail and there is no industry standard method - you are not putting it in. There is no upside for you to follow the GC saying you have enough information. If any thing goes wrong the engineer says, "We didn't say to do that."
A. There is no way to ground the 12460V as proposed by engineering. 12460D does not have a "centertap". Suggest engineering provide a spec and detail for a grounding transformer. This falls under the, "We're trying to help out" part - not the, "We're trying to tell you your job" part.
If they don't like that, then engineering provide a detail on how to ground the 12460D - using the three available terminals, H1, H2, H3 There is no industry standard method to do this.
B. If engineering/GC expect you to size the EGC, as Jim noted, point out 250.184.B.c. You consider this an engineering task to provide EGC sizing.
However, if they insist, you will size per 250.66, #8CU. And the three shields don't look like they meet that. And that means a re-pull - on their dime.
2. Enlist the support of the AHJ:
As smart $ suggested, get the AHJ to buy-in on the solutions.
A. Use the shields as the EGC conductors. Or re-pull with an EGC.
B. Any engineering specified screwy grounding method ("Screwy" defined as other than a grounding transformer or a new 480D/12460Y xfm1)
3. Put in what ever they tell you to, exactly the way they tell you to do it. The job has gone south. Document it all you can, get insulated from it.
4. Make sure you keep your short sword close at hand. It may be the only way to get completely free from this job
Gary -
I normally don't provide free advice. I don't mind helping out, it's just that I figure advise is worth what you pay for it. Keep that in mind when you are reading this.
So what do you suggest Gary do? :wink:
smart $ - I hope this meets your expectation. I don't expect to go any farther with the information at hand.
cf