Surge Protection 230.67 - Existing Service

[Tank11]

I'm working on an existing hotel that is being converted to individual apartments. The overall service size is not changing and the main distribution is not changing, only adding breakers and branch circuits for kitchenettes throughout the building.

Does this trigger a requirement for new surge protection per NEC 230.67?

 

[infinity]

IMO no it's not required because of (D).

230.67(D) Replacement.
Where service equipment is replaced, all of the requirements of this section shall apply.

 

[petersonra]

It seems to me there is a requirement to have surge protection if there are any safety circuits involved. Are there are safety circuits in the new building that you will be adding?