cops: an arresting look at nec article 708
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COPS:
An Arresting Look at
NEC Article 708
ASCO
COPS:
An Arresting Look at NEC Article 708
Speakers:
Michael A. Anthony, PE
Member, Panel 1 of the NEC,
representing the Association of
Education Facilities Officers
(APPA)
Christopher M. Johnston, PE
Senior Vice President,
Chief Engineer – Critical Facilities
Syska Hennessy Group
Rudy Bergthold
Senior Vice President/Chief
Technology Officer
Cupertino Electric, Inc.
Michael Ivanovich
Editor-in-Chief and Moderator
Consulting-Specifying Engineer
ASCO®
Michael A. Anthony, PE
University of Michigan
2008 NEC Article 708
Critical Operations Power Systems
Consulting-Specifying Engineer
Webcast May 21, 2008
For source information, disclaimer and biography of Michael Anthony, go to
http://first-team-usa.com/MA_Anthony.pdf
4
Takeaway #3:
Public acceptance of Article 708
Takeaway #2:
Article 708 and other “similar” NEC articles
Takeaway #1:
Operational (“nameplate”) availability
Learning Objectives
z
y
x
Michael A. Anthony, PE – University of Michigan
5
Take Away #1: Operational (“nameplate”) availability
Annex F: Availability and Reliability for Critical Operations Power Systems; and Development and Implementation of Functional Performance
Tests (FPTs) for Critical Operations Power Systems
I. Availability and Reliability for Critical Operations Power Systems.
Critical operations power systems may support facilities with a variety of objectives that are vital to public safety. Often these objectives are of
such critical importance that system downtime is costly in terms of economic losses, loss of security, or loss of mission. For those reasons,
the availability of the critical operations power system, the percentage of time that the system is in service, is important to those
facilities. Given a specified level of availability, the reliability and maintainability requirements are then derived based on that availability
requirement.
Availability. Availability is defined as the percentage of time that a system is available to perform its function(s). Availability is measured in a
variety of ways, including the following:
Availability = MTBF/(MTTF+MTTR)
where:
MTBF= mean time between failures
MTTF= mean time to failure
MTTR= mean time to repair
Availability Hours of Downtime*
0.9 876
0.99 87.6
0.999 8.76
0.9999 0.876
0.99999 0.0876
0.999999 0.00876
0.9999999 0.000876
*Based on a year of 8760 hours.
Michael A. Anthony, PE – University of Michigan
6
ADAPTATION OF IEEE 493 “GOLD BOOK” PROBLEM
Michael A. Anthony, PE – University of Michigan
7
ADAPTATION OF IEEE 493 “GOLD BOOK” PROBLEM
Michael A. Anthony, PE – University of Michigan
8
Takeaway #2: Article 708 and other “similar” NEC articles
Michael A. Anthony, PE – University of Michigan
9
Critical Branch.A subsystem of
the emergency system consisting
of feeders and branch circuits
supplying energy to task
illumination, special power
circuits, and selected receptacles
serving areas and functions
related to patient care and that
are connected to alternate power
sources by one or more transfer
switches during interruption of
normal power source.
-- Article 517
Michael A. Anthony, PE – University of Michigan
10
708.20 (F)(3) Dual Supplies. Prime movers shall
not be solely dependent on a public utility gas system
for their fuel supply or municipal water supply for their
cooling systems. Means shall be provided for
automatically transferring from one fuel supply to
another where dual fuel supplies are used.
Michael A. Anthony, PE – University of Michigan
11
Mobile natural gas generator
HISPANO SUIZA MOBILE 8MW Plymouth County, Massachusetts Mobile Command Unit
708.20 (F)(6) Mean[s] for Connecting
Portable or Vehicle-Mounted Generator.Where the COPS is supplied by a single generator,
a means to connect a portable or vehicle-mounted
generator shall be provided.
Michael A. Anthony, PE – University of Michigan
12
Q1. Do you have suf f icient storage facilities for running generators for 96 continuous hours?
Yes 47.5% No 52.5%
Q2. Can you simultaneously operate diesel f ired boilers and generators f rom the same fuel supply, for a 96 hour period if load shedding is implemented?
Yes 57.9% No 42.1%
Q3. Are additional tanks required on site if the hospital’s mission is to provide care for 96 hours or longer, and the Joint Commission demands “on site” storage?
Yes 68.2% No 31.8%
Q4. What would you estimate the cost of acquiring and installing these tanks?
Estimates ranged from $25,000-200,000
Q6. Do you think of f -site fuel storage, on dealer properties, should suf fice?
Yes 55.9% No 44.1%
Q7. How should loads be calculated to determine the amount of fuel needed for a 96 hour continuous run?
Full nameplate rating of all generators
37.1% Connected load 45.7% Calculated load 20.0%
Q11. What is your interpretation of EC.4.12, B-6, regarding the 96 hour issue?
Some replies couldn’t be printed, but the preponderance of replies included that the Joint was “legislating f rom the bench”.
Excerpts from Fuel Supply Survey from Healthcare Engineering Network that posed the question: Do you need 96 hours of fuel to
comply with JCAHO EC.4.12. B-6?
Article 517 and Article 708 “critical” systems may compete for fuel
Michael A. Anthony, PE – University of Michigan
13
• Risk assessment for critical operations power systems shall be documented and shall be conducted in accordance with 708.4(A) through (C).
• FPN: Chapter 5 of NFPA 1600-2007, Standard on Disaster/Emergency Management and Business Continuity Programs, provides additional guidance concerning risk assessment and hazard analysis.
• (A) Conducting Risk Assessment. In critical operations power systems, risk assessment shall be performed to identify hazards, the likelihood of their occurrence, and the vulnerability of the electrical system to those hazards.
• (B) Identification of Hazards. Hazards to be considered at a minimum shall include, but shall not be limited to, the following:
• (1) Naturally occurring hazards (geological, meteorological, and biological)
• (2) Human-caused events (accidental and intentional) [1600:5.3.2]
• (C) Developing Mitigation Strategy. Based on the results of the risk assessment, a strategy shall be developed and implemented to mitigate the hazards that have not been sufficiently mitigated by the prescriptive requirements of this Code.
708.4 Risk Assessment
Take Away #3: Public Acceptance of Article 708
Should a
tabulation like
this show up in
the facility
engineering
documentation,
in the bidding
documents, or
in both?
Michael A. Anthony, PE – University of Michigan
14
Hazard Mitigation Grant Program Responsibilities:
Within locally declared areas, the affected jurisdictions are
responsible for identifying projects that will substantially
reduce the risk of future damage, hardship, loss, or
suffering from a disaster. These agencies must ensure that
each identified project is cost effective and meets basic
project eligibility. These agencies will be the primary contact
and coordinator for each funded project until completion. –
from “Marin County Operational Area Emergency
Operations Plan” (1999)
SAMPLE CHALLENGES OBSERVED
Michael A. Anthony, PE – University of Michigan
15
708.5 Physical Security.
Physical security shall be provided for critical operations power systems in accordance with
708.5(A) and (B).
(A) Risk Assessment. Based on the results of the risk assessment, a strategy for
providing physical security for critical operations power systems shall be developed,
documented, and implemented.
(B) Restricted Access. Electrical circuits and equipment for critical operations power
systems shall be accessible to qualified personnel only.
SAMPLE CHALLENGES OBSERVED
Michael A. Anthony, PE – University of Michigan
16
Ventura County Fire Protection District: Replacement of their
existing f ire command center with a new 16,000 sf dispatch center,
housing administration, dispatching, and living functions. Design
features for this 24 hour facility include equipment rooms holding the
latest in technology, a dispatch f loor to accommodate future growth, a
training room that doubles as an expanded dispatch, and living
accommodations for 11 dispatchers. Because the project is located
on airport property, the A/E coordinated with the FAA to incorporate
high security features to ensure continuous protection for occupants
and equipment and continuous public safety services to the County of
Ventura.
A congressional report states the Baghdad Embassy is a a self -
suf f icient and "hardened" domain, to function in the midst of
Baghdad power outages, water shortages and continuing
turmoil. It has its own water wells, electricity plant and
wastewater-treatment facility to allow 100 percent independence
f rom city utilities.
SAMPLE CHALLENGES OBSERVED
Michael A. Anthony, PE – University of Michigan
17Michael A. Anthony, PE – University of Michigan
18
“The earthquake occurring on 4/18/2008 illustrates that significant
seismic events do occur east of the Rockies. Earthquakes of
comparable size are felt over greater distances and are potentially
more dangerous in the Eastern U.S. than those occurring in the West
due to differences in ground conditions. Direct damage to electric power infrastructure could cause a blackout affecting much of the
entire Eastern Interconnection. The blackout would be short-lived
(perhaps a week in duration) in the regions that are far enough from
the earthquake center to experience only mild ground shaking.
However, restoring the power grid in regions of highest ground-shaking intensity would take months.”
-- Midwest Independent Systems Operators Conference, May 2008
Proposal: A 30-day outage benchmark
Michael A. Anthony, PE – University of Michigan
19
Innovation: Community Backup Power – Microgrids
Pharmacy
Fuel StationsGrocery Stores
Banks, etc
FPN No. 1: Critical operations
power systems are generally installed in vital infrastructure facilities that, if destroyed or
incapacitated, would disrupt national security, the economy,
public health or safety; and where enhanced electrical infrastructure for continuity of
operation has been deemed necessary by governmental
authority.
National Electric Safety Code ANSI/IEEE C.2 “Last Mile” of wiring
NEC Wiring
Transfer
Switch
Michael A. Anthony, PE – University of Michigan
20
CEU Questions
A. Which Annex provides model language for adopting jurisdictions to determine the degree to which an existing emergency management facility can be modified to meet the requirements for a 708-compliant designated critical operations area (DCOA)?
B. Which Annex recommends a 72 hour capacity for the signaling systems between widely separated DCOA’s?
C. What two methods are recommended in Annex F for improving availability in existing DCOA’s?
Michael A. Anthony, PE – University of Michigan
21
Thanks!
Michael A. Anthony, PE – University of Michigan
For source information, disclaimer and biography of Michael
Anthony, go to http://first-team-usa.com/MA_Anthony.pdf
COPS From The Consulting Engineer’s Crystal Ball
Christopher M. Johnston, P.E.National Critical Facilities Chief Engineer
Syska Hennessy GroupTel. (770) 563-1567E-Mail cjohnston@syska.com
For COPS: An Arresting Look at NEC Article 708, hosted by Consulting-Specifying
Engineer, Webcast on May 21, 2008, at www.csemag.com
23
Learning Objectives
Take-away 1 Much Initial Confusion
Take-away 2 Old Dogs Must Learn New Tricks
Take-away 3 Engineers Must Guide The Architects
Take-Away 4 There’s Not Much New Under The Sun
Take-away 5 What’s To Gain?
24
Take-away 1 Much Initial Confusion
There will be much initial confusion about which Authorities Have Jurisdiction (708.1)
– Municipal, state, Federal or other Codes by any governmental agency having jurisdiction or
– Facility engineering documentation establishing necessity.
There will be turf battles and overlaps between agencies.
There will be conflicts with other NEC Articles.
There will be courts and lawyers involved.
There will be some projects and engineers caught in the cross-fire.
25
Take-away 2 Old Dogs Must Learn New Tricks
COPS correctly done will require additional
effort and fee. Some notable examples:
– Documented Risk Assessment (708.4)
– Physical Security Provisions (708.5)
– Commissioning to a higher standard (708.8)
– Fire protection for feeders (708.10)(C)(2)
– Selective overcurrent device coordination
(708.54)
26
Take-away 3 Engineers Must Guide The Architects
Architects will not be initially knowledgeable about
COPS.
Engineers should be involved with the project from
the programming stage (Risk Assessment).
Authorities Having Jurisdiction may require a
preventive maintenance program as part of design
(708.6(C))
Authorities Having Jurisdiction may require
commissioning and witness testing as part of design.
27
Take-away 4 There’s Not Much New Under The Sun
Many of the COPS requirements are long-
established practices for knowledgeable
clients with critical facilities (banks,
investment banks, insurance companies,
telecom providers, etc.)
A few consulting engineers are
knowledgeable about these practices and
are regularly involved in such design.
28
Take-away 5 What’s To Gain?
708.1 alludes to “…systems …classed by facility
engineering documentation establishing the
necessity…”
No knowledgeable non-governmental user has
anything to gain by complying with Article 708. No
leniencies that would increase availability at a
reasonable cost are apparent.
Many governmental users can provide better service
by complying with all of the provisions of Article 708.
29
Summary
Take-away 1 Much Initial Confusion
Take-away 2 Old Dogs Must Learn New Tricks
Take-away 3 Engineers Must Guide The Architects
Take-away 4 There’s Not Much New Under The Sun
Take-away 5 What’s To Gain?
Electrical Contractors and NEC Article 708
Rudy Bergthold, P.E.,
Sr. Vice President & CTO
Cupertino Electric, Inc.
1132 N. 7th Street
San Jose, CA. 95112
Rudy_Bergthold@CEI.com
For COPS: An Arresting Look at NEC Article 708, hosted by Consulting-Specifying
Engineer, Webcast on May 21, 2008, at www.csemag.com
31
Learning Objectives
When and Where Does Article 708 Apply
Code Requirements That Add Cost
Impacts on Other Trades
Referenced Documents
32
When and Where does Article 708 Apply
Scope:
Installation, Operation, Monitoring, Control
and Maintenance of portions of premises
wiring system intended to supply, distribute
and control electricity in Designated Critical
Operations Areas (DCOA) in the event of
disruption to elements of the normal system.
33
When and Where does Article 708 Apply
Critical Operations Power System (COPS)
are those systems so classed by:
– Municipal Governments or Codes
– State Governments or Codes
– Federal Government or Codes
– Other Governmental Agency or Code Having
Jurisdiction
– Facility Engineering Documentation Establishing
Necessity
34
When and Where does Article 708 Apply
Definition: Critical Operations Power System
(COPS):
– Power System for Facilities or Parts of Facilities
that Require Continuous Operation for Reasons
of Public Safety, Emergency Management,
National Security or Business Continuity
35
When and Where does Article 708 Apply
Critical Operations Power Systems (COPS) for DCOA Include but are not limited to:
– Power System
– HVAC
– Fire Alarm
– Security
– Communications
– Signaling
36
When and Where does Article 708 Apply
Where Might We Find COPS
– Government Command and Control Buildings
– Buildings Housing First Responders Such as
Police & Fire
– Critical Communications - 911 Operators
– Emergency Medical Facilities
37
Code Requirements that Add Cost
Risk Assessment – Who Prepares this
Document and What Impacts Could This
Present to the Contractors?
– Type of Construction
– Anchoring and/or Support of Equipment
– Redundancy of Components
– Concurrent Maintainability of Equipment
38
Code Requirements That Add Cost
Physical Security – Impediments to the
Movement of Men and Material
– Restrictions on Access to Work Space
– Extra Time to Move Men and Material Through
Security
– Extra Time Required for Special Training
– Lockdowns and Stop Work Instructions
39
Code Requirements That Add Cost
Commissioning, Testing & Maintenance –
– The AHJ Shall Conduct or Witness a Test of the
Complete System Upon Installation and
Periodically Afterward
– Documented Results for Future Reference
– Can Take Days or Weeks with Rented
Equipment, Vendor Support, Fuel Expense and
Manpower
40
Code Requirements That Add Cost
Wiring of COPS
– Wiring of COPS Circuits to be Separated and Independent of All Other Wiring
– Receptacles or Cover Plates of COPS Circuits to have Distinctive Color
– Special Readily Identifiable Marking of all Boxes, Enclosures, Transfer Switches, Generators, etc for COPS (could extend to conduits)
41
Code Requirements That Add Cost
Wiring of COPS
– All feeders, if exposed, shall be GRS, IMC or MI
Cable (does not allow bus duct or EMT conduit)
– PVC40, PVC80, EMT may be used if encased in
2 inches of concrete
– Feeders below 100 year flood plain shall be
installed as wet location – back straps on surface
conduits and spacers behind boxes, etc.
(Added Labor)
42
Code Requirements That Add Cost
Wiring of COPS– Fire Protection for Feeders
1 Hour Listed Assembly
Protected with 1 Hour Fire Rated Assembly Construction
Embedded in 2 inches of Concrete
Listed 1 Hour Rated Cable Assembly
– COPS Branch Circuits outside DOCA wired same as Feeders – GRS, IMC or MI Cable
43
Code Requirements That Add Cost
Wiring of COPS
– COPS Branch Circuits Inside DOCA may be
wired with any methods listed in Article 300
– COPS Feeders and Branch Circuits shall only
Supply Equipment Required for Critical
Operations Use. General Maintenance Circuits or
Other Circuits (Example: Vending Machines)
would not be Critical Operations
44
Code Requirements That Add Cost
COPS Equipment
– Branch Circuit Distribution Equipment Located
within Same DOCA as Circuit Supplied. Could
need Multiple COPS Distribution Rooms
– Distribution Equipment (Switchboards, Transfer
Equipment, Transformers, Panelboards, etc.)
Must be Located in Spaces with 2 Hour Rating
and be Above 100 year Flood Plain
45
Code Requirements That Add Cost
Special Wiring for HVAC, Fire Alarm, Security, Emergency Communications and Signaling
– Wired in GRS, IMC or MI Cable ONLY
– Control, Monitoring and Power to HVAC Systems shall be 2 Hour Fire Resistive Cable or a Listed 2 Hour Electrical Circuit Protective System
46
Code Requirements That Add Cost
Special Wiring for HVAC, Fire Alarm, Security, Emergency Communications and Signaling
– Signal and Communications wires shall use Shielded, Twisted Pairs and the Shield shall be Continuous
– Fiber Optic Cables shall be used for Connections between Buildings Under the Same Management
– Control Circuits over 50 volts shall use 600 volt rated wire
47
Code Requirements That Add Cost
Special Wiring for HVAC, Fire Alarm,
Security, Emergency Communications and
Signaling
– Communications Riser Cables shall be 2 Hour
Fire Resistive Cable or a Listed 2 Hour Electrical
Circuit Protective System.
– Relays used must have Contacts that Exceed the
Circuit Voltage and Current Ratings in Controlled
Circuit
48
Code Requirements That Add Cost
Sources of Power
– In Addition to Normal Source, COPS shall also
have Alternate Source of Storage Battery,
Generator, UPS with Generator, or Fuel Cell.
– Normal and Alternate Sources shall be installed in
spaces Fully Protected by Sprinklers or be
installed in spaces with 1 Hour Rating
– Shall have TVSS at Each Bus Level in the
System
49
Code Requirements That Add Cost
Sources of Power
– Normal and Alternate Sources Shall be Grounded
as Separately Derived Sources
– System Shall Transfer between normal and
Alternate within the time Required for Operation
of the System – No Specific Transfer Time
Specified in the Code.
50
Code Requirements That Add Cost
Storage Batteries– Automatic charging required using Charger
Designed to work with the Battery
– Sealed VRLA Batteries May be in Opaque Jars
– Flooded Cells Must be in Transparent Jars
– No Automotive-type Batteries
– Operation of COPS for 72 Hours at +/- 10% Voltage
– Ventilation Required for Continuous Operation under Maximum Anticipated Ambient Temp
51
Code Requirements That Add Cost
Generator Set & Transfer Equipment
– Automatic Start and Transfer by Electrically
Operated, Mechanically Held ATS Identified for
Emergency Use (UL1008 or Equal)
– Minimum 15 Minute Adjustable Re-transfer to
Normal Source – may go longer time.
– On Site Fuel Supply for 72 Hours (6500 to 7000
gallons of diesel per 1000KW COPS Load)
52
Code Requirements That Add Cost
Generator Set & Transfer Equipment
– Fuel Supply Must be Secured and Protected
– Cannot be Solely Dependant on Utility Supply of
Fuel or Cooling Water. Must Automatically
Transfer to Alternate Source
– Power for Battery Chargers, Fuel Pumps, and
Driven Dampers must come from Protected
COPS. If outside DOCA then wire with GRS, IMC
or MI Cable
53
Code Requirements That Add Cost
Generator Set & Transfer Equipment
– Generator Must Have Rating Allowing Operation
for Unlimited Hours with Varying Load. This
description is for a Prime Rated Generator Set as
opposed to Stand-By Rated Unit.
Reference ISO8528 and ISO3046
– A Portable or Redundant Generator is Required
whenever the COPS Alternate Source is Out of
Service (Oil Change?)
54
Code Requirements That Add Cost
Generator Set & Transfer Equipment
– Portable Source Connection Shall be Supplied
where the System contains Only One Alternate
Source Generator
– Selective Load Pick-up, Load Shedding, and
Peak Sharing is Allowed Provided COPS and
Emergency Loads Receive the Highest Priority
55
Code Requirements That Add Cost
Generator Set & Transfer Equipment
– Transfer switch May be Bypass-Isolation but this
is not Required (Why not?)
– Transfer Switch (Equipment) May Supply Only
COPS Branch Circuits
56
Code Requirements That Add Cost
Uninterruptible Power Supply (UPS)
– UPS May be Used but Must have Storage Battery
and Generator as described above
Fuel Cell
– Fuel cell May be Used As Alternate Source.
Refer to NFPA 70-2008, Article 692 Parts II
through VIII
57
Code Requirements That Add Cost
Overcurrent Protection
– Where Ground Fault protection is Required on the
Normal Source Main, Another Level of Ground
Fault Protection is Required on the COPS
Feeders
– All Ground Fault Protection Must Be Tested
– Downstream (Feeder) GFP Shall be Separated
from Upstream (Main) GFP by a Minimum of
6 cycles (0.1 seconds)
58
Code Requirements That Add Cost
Overcurrent Protection
– All COPS Overcurrent Devices Shall be
Selectively Coordinated with all Supply Side
Overcurrent Devices
Must Have Fully Rated System
No Series Ratings Allowed
Size Ratio of Devices Critical to Achieve Coordination
(Minimum 1:2 or 1:4)
59
Impacts On Other Trades
Necessary Structural and Architectural
Elements
– Structural Attachment and/or Equipment Support
– 1 Hour Rated Assemblies for Fire Protection for
Feeders
– 2 Hour COPS Equipment Enclosures/Rooms
Above 100 Year Flood Plain
– Ventilation for Storage Batteries
60
Impacts On Other Trades
Necessary Structural and Architectural
Elements
– Physical Security for COPS
– Protection for Fuel Storage
– Capacity (72 Hours) of on Site Fuel Storage
61
Referenced Documents
NFPA 1600-2007, Standard on Disaster/Emergency
Management and Business Continuity Programs
NFPA 110-2005, Standard for Emergency and
Standby Power Systems
NFPA 99-2005, Standard for Health Care Facilities
NFPA 101-2006, Life Safety Code
62
Referenced Documents
NFPA 730-2006, Guide for Premises Security
NFPA 70-2008, National Electrical Code, Annex F,
Availability and Reliability for Critical Operations
Power Systems; and Development and
Implementation of Functional Performance Tests
(FPTs) for Critical Operations Power Systems
NFPA 70-2008, National Electrical Code, Annex G,
Supervisory Control and Data Acquisition (SCADA)
63
Summary
Before You Pull Together A Final Price Estimate You
Need to Know if Article 708 Applies to the Scope of
the Work
Understand the Article 708 Requirements That Will
Impact the Cost of the Installation
Communicate the Impacts of Article 708 on Other
Trades to Avoid Potential Costly Changes
Become Familiar with Referenced Documents
64
Thank you for attending!
Q&A
Please take our exit survey at the end of the Q&A session.
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