COPS: An Arresting Look at NEC Article 708

An Arresting Look at

NEC Article 708

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

Takeaway #3:

Public acceptance of Article 708

Takeaway #2:

Article 708 and other “similar” NEC articles

Takeaway #1:

Operational (“nameplate”) availability

Learning Objectives

Michael A. Anthony, PE – University of Michigan

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.

ADAPTATION OF IEEE 493 “GOLD BOOK” PROBLEM

Takeaway #2: Article 708 and other “similar” NEC articles

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

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.

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.

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

• 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?

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

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.

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.

17Michael A. Anthony, PE – University of Michigan

“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

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

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?

Thanks!

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

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?

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.

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)

Architects will not be initially knowledgeable about

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.

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.

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.

Summary

Take-away 4 There’s Not Much New Under The Sun

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

Learning Objectives

When and Where Does Article 708 Apply

Code Requirements That Add Cost

Impacts on Other Trades

Referenced Documents

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.

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

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

Critical Operations Power Systems (COPS) for DCOA Include but are not limited to:

– Power System

– HVAC

– Fire Alarm

– Security

– Communications

– Signaling

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

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

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

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

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)

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)

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

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

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

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

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

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

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

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.

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

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)

– 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

– 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?)

– 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

– Transfer switch May be Bypass-Isolation but this

is not Required (Why not?)

– Transfer Switch (Equipment) May Supply Only

COPS Branch Circuits

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

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)

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)

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

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

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

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)

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

Thank you for attending!

Please take our exit survey at the end of the Q&A session.

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