SECOND DRAFT MEETING AGENDA - NFPA DRAFT MEETING AGENDA . NFPA Technical Committee on Emergency Power Supplies (EPS-AAA) Second Draft Meeting for …

SECOND DRAFT MEETING AGENDA

NFPA Technical Committee on Emergency Power Supplies (EPS-AAA)

Second Draft Meeting for 2019 Edition of NFPA 110 and NFPA 111

July 19, 2017

Teleconference / Web Meeting

Item No. Subject

17-7-1 Call to Order

17-7-2 Introduction of Members and Guests (Attachment A)

17-7-3 Approval of Previous Meeting Minutes (Attachment B)

17-7-4 Review of Regs and Committee Actions

17-7-5 Task Group Reports

17-7-6 Processing of Public Comments (Attachment C)

17-7-7 Old Business

17-7-8 New Business

17-7-9 Adjournment

NFPA 110 & 111 Second Draft Technical Committee Meeting Agenda Teleconference - July 19, 2017

Page 1 of 30

Attachment A: Technical Committee Roster


Page 2 of 30

Address List No PhoneEmergency Power Supplies EPS-AAA

National Electrical Code®

Christopher Coache07/06/2017

EPS-AAA

Dan Chisholm, Sr.

ChairMGI Systems, Inc.PO Box 2474Winter Park, FL 32790-2474Alternate: Dan Chisholm, Jr.

IM 10/1/1993EPS-AAA

Ernest E. Allen

PrincipalThe Doctors Company5001 Mayfield Road, Suite L55Lyndhurst, OH 44124NFPA Health Care Section

I 7/1/1990

EPS-AAA

Kenneth A. Cotton

PrincipalUS Energy/Donlee CropNetwork Operation Center140 East Stetson AveSuite 309Hemet, CA 92543Alternate: Joshua Dugger

M 10/1/1999EPS-AAA

Jason D'Antona

PrincipalThompson Consultants, Inc.525 Mill StreetMarion, MA 02738

SE 03/07/2013

EPS-AAA

David A. Dagenais

PrincipalPartners/Wentworth-Douglass Hospital789 Central AvenueDover, NH 03820

U 08/09/2012EPS-AAA

Richard L. Day

PrincipalMichigan State Fire Marshal's Office207 Jackson StreetAllegan, MI 49010-9156

E 03/03/2014

EPS-AAA

Dennis DeMoss

PrincipalSargent & Lundy55 East Monroe StreetChicago, IL 60603Alternate: David C. Skiba

SE 1/1/1990EPS-AAA

William H. Everard

PrincipalEverard Mid Atlantic Inc.8743 Center RoadSpringfield, VA 22152-2234

SE 1/1/1979

EPS-AAA

Louis J. Feller

PrincipalUS Army Corps of Engineers8212 126th Place SENewcastle, WA 98056-9132

U 03/03/2014EPS-AAA

James R. (Skip) Gregory

PrincipalHealth Facility Consulting4128 Zermatt DriveTallahassee, FL 32303-2252Florida Agency for Health Care Administration

E 3/21/2006

EPS-AAA

Ross M. Hardy

PrincipalThe University of Michigan Medical CenterPlant Hospital Maintenance1500 East Medical Center DriveAnn Arbor, MI 48073-6712

U 7/14/2004EPS-AAA

Jonathan Hartsell

PrincipalRodgers5701 North Sharon Amity RoadCharlotte, NC 28215

IM 07/29/2013


Page 3 of 30




EPS-AAA

Oleh Kowalskyj

PrincipalU.S. Department of Veterans AffairsVeterans Health Administration (10NAS)810 Vermont Avenue, NWWashingston, DC 20420US Department of Veterans AffairsAlternate: Gary Krauch

U 04/04/2017EPS-AAA

Pouyan Layegh

PrincipalUniversity of Texas MD Anderson Cancer Center3126 Barrons WaySugar Land, TX 77479

U 11/30/2016

EPS-AAA

Chad E. Loomis

PrincipalCornell University2336 South Balch HallIthaca, NY 14853

U 3/2/2010EPS-AAA

Alan Manche

PrincipalSchneider Electric1601 Mercer RoadLexington, KY 40511-1025

M 10/23/2003

EPS-AAA

George Mills

PrincipalThe Joint CommissionDepartment of EngineeringOne Renaissance BoulevardOakbrook Terrace, IL 60181Joint Commission on Accreditation HealthcareOrganizations

E 3/15/2007EPS-AAA

Dermott Murphy

PrincipalWashington State Patrol - Fire Prevention BureauPO Box 42642Olympia, WA 98504

E 11/30/2016

EPS-AAA

Hugh O. Nash, Jr.

PrincipalNash-Consult964 General George Patton RoadNashville, TN 37221Alternate: Bogue M. Waller

SE 10/3/2002EPS-AAA

Daniel J. O'Connor

PrincipalJENSEN HUGHES/AON Fire Protection Engineering4 Overlook PointLincolnshire, IL 60069-4302Alternate: Raymond J. Battalora

I 1/1/1984

EPS-AAA

Gary L. Olson

PrincipalkW Rx, LLC12979 Killdeer Street NWMinneapolis, MN 55448-7018

SE 08/09/2011EPS-AAA

Steve R. Sappington

PrincipalCaterpillar Inc.175 Cutstone CourtFayetteville, GA 30215-6206

M 08/11/2014

EPS-AAA

Ronald A. Schroeder

PrincipalASCO Power Technologies, LP160 Park AvenueFlorham Park, NJ 07932Alternate: Brian J. Escott

M 1/10/2008EPS-AAA

Randy H. Schubert

PrincipalEricsson444 Hoes LanePiscataway, NJ 08854-4104Alliance for Telecommunications Industry SolutionsAlternate: Richard G. Kluge

U 12/08/2015


Page 4 of 30




EPS-AAA

Ronald M. Smidt

PrincipalCarolinas HealthCare SystemPO Box 901Troutman, NC 28166American Society for Healthcare Engineering

U 7/24/1997EPS-AAA

Raymond J. Stanko

PrincipalUL LLC333 Pfingsten RoadNorthbrook, IL 60062-2096

RT 8/9/2011

EPS-AAA

David Stymiest

PrincipalSmith Seckman Reid, Inc.2995 Sidco DriveNashville, TN 37204

SE 1/12/2000EPS-AAA

Herbert V. Whittall

PrincipalElectrical Generating Systems Association19 Park AvenueVero Beach, FL 32960Alternate: James Hunt

M 11/30/2016

EPS-AAA

Timothy P. Windey

PrincipalCummins Power Generation1400 73rd Avenue NEMinneapolis, MN 55432-3702

M 08/03/2016EPS-AAA

Michael J. Lang

Voting AlternateMersen1135 Arva DriveRoswell, GA 30076National Electric Fuse Association

M 10/29/2012

EPS-AAA

Rich Scroggins

Voting AlternateCummins Power Generation3850 North Victoria StreetShoreview, MN 55126-2907

M 10/28/2014EPS-AAA

Raymond J. Battalora

AlternateJensen Hughes/AON Fire Protection EngineeringProject Director1701 North Collins Boulevard, Suite 235Richardson, TX 75080-3553Principal: Daniel J. O'Connor

I 4/3/2003

EPS-AAA

Dan Chisholm, Jr.

AlternateMGI Systems, Inc.412 Page StreetOrlando, FL 32806Principal: Dan Chisholm, Sr.

IM 7/14/2004EPS-AAA

Joshua Dugger

AlternateFacility Shield International14419 Veterans WayMoreno Valley, CA 92553-9059Principal: Kenneth A. Cotton

M 10/29/2012

EPS-AAA

Brian J. Escott

AlternateASCO Power TechnologiesVice President, Power Control Systems160 Park AvenueFlorham Park, NJ 07932-1419Principal: Ronald A. Schroeder

M 07/29/2013EPS-AAA

James Hunt

AlternateHostrat Inc.5723 East AlkiSpokane, WA 99212Electrical Generating Systems AssociationPrincipal: Herbert V. Whittall

M 08/03/2016


Page 5 of 30




EPS-AAA

Richard G. Kluge

AlternateEricsson1 Ericsson DrivePiscataway, NJ 08854Alliance for Telecommunications Industry SolutionsPrincipal: Randy H. Schubert

U 12/08/2015EPS-AAA

Gary Krauch

AlternateVirginia New England Healthcare System2000 Springs RoadBuilding 61Bedford, MA 01730US Department of Veterans AffairsPrincipal: Oleh Kowalskyj

U 04/04/2017

EPS-AAA

David C. Skiba

AlternateSargent & Lundy LLC55 East Monroe StreetSuite 2710Chicago, IL 60603-5821Principal: Dennis DeMoss

SE 10/28/2014EPS-AAA

Bogue M. Waller

AlternateGresham Smith & Partners1400 Nashville City Center511 Union Street, Suite 1400Nashville, TN 37219Principal: Hugh O. Nash, Jr.

SE 10/23/2013

EPS-AAA

Christopher Coache

Staff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy, MA 02169-7471

8/7/2011


Page 6 of 30

Attachment B: Previous Meeting Minutes


Page 7 of 30

National Fire Protection Association

1 Batterymarch Park, Quincy, MA 02169-7471

Phone: 617-770-3000 • Fax: 617-770-0700 • www.nfpa.org

TO: Technical Committee on Emergency Power Supplies DATE: September 7, 2016 SUBJECT: Minutes of NFPA 110 and 111 First Draft Teleconference/Web Meeting Meeting Location: Teleconference/Web Agenda Item 16-9-1 – Call to Order The teleconference/web meeting was called to order by Chair Dan Chisholm, Sr at 10 am (Eastern Time). Agenda Item 16-9-2 – Introduction of Members and Guests Attendees participating in the teleconference/web meeting were as follows: TECHNICAL COMMITTEE MEMBERS PRESENT

NAME COMPANY

Dan Chisholm, Sr., Chair MGI Systems, Inc.

Herbert Daugherty, Secretary Electric Generating Systems Association

Kenneth A. Cotton, Principal US Energy/Donlee Crop

Jason D’Antona, Principal Thompson Consultants, Inc.

Dennis DeMoss, Principal Sargent & Lundy

Louis Feller, Principal US Army Corps of Engineers

James Gregory, Principal Health Facility Consulting

Jonathan Hartsell, Principal Rodgers

James Hunt, Principal HOTSTART Inc.

Chad Loomis, Principal Cornell University

Hugh Nash, Jr., Principal Nash-Consult

Gary Olson, Principal kW Rx, LLC

Steve Sappington, Principal Caterpillar Inc.

Ronald Schroeder, Principal ASCO Power Technologies, LP

Ronald Smidt, Principal Carolinas HealthCare System Rep.: American Society for Healthcare Engineering

David Stymiest, Principal Smith Seckman Reid, Inc.

Hebert Whittall, Principal Electrical Generating Systems Association

Timothy Windey, Principal Cummins Power Generation

Michael Lang, Voting Alternate Mersen Rep.: National Electric Fuse Association

Joshua Dugger, Alternate to K. Cotton Facility Shield International


Page 8 of 30




TECHNICAL COMMITTEE MEMBERS NOT PRESENT

NAME COMPANY

Ernest Allen, Principal The Doctors Company Rep.: NFPA Health Care Section

David Dagenais, Principal Wentworth-Douglass Hospital

Richard Day, Principal Michigan State Fire Marshal’s Office

William Everard, Principal Everard Mid Atlantic Inc.

Ross Hardy, Principal The University of Michigan Medical Center Plant Hospital Maintenance

Alan Manche, Principal Schneider Electric

Daniel O’Connor, Principal JENSEN HUGHES/AON Fire Protection Engineering

Ralph Patterson, Principal Power Products & Solutions Inc. Rep.: InterNational Electrical Testing Association

Raymond Stanko, Principal UL LLC

Larry Lau, Voting Alternate US Department of Veterans Affairs

Rich Scroggins, Voting Alternate Cummins Power Generation

Raymond Battalora, Alternate AENSEN HUGHES/AON Fire Protection Engineering

GUESTS

NAME

Sarah English

Vicky Giroux

Alisha Younts

Agenda Item 16-9-3 – Approval of Previous Meeting Minutes Minutes of the Second Draft meeting of the 2016 edition were approved. Agenda Item 16-9-4 – Review of NFPA Regulations and Committee Actions NFPA Staff Liaison Christopher Coache gave a presentation on the NFPA Standards Development Process for First Draft meetings.

Richard Kluge, Alternate to R. Schubert Telcordia Technologies (Ericsson) Rep.: Alliance for Telecommunications Industry Solutions

David Skiba, Alternate to D. DeMoss Sargent & Lundy LLC

Bogue Waller, Alternate to H. Nash, Jr. Gresham Smith & Partners

Christopher Coache, Staff Liaison National Fire Protection Association


Page 9 of 30




Agenda Item 16-9-5 – Task Group Reports There were no active task groups in effect prior to the commencement of this meeting. Agenda Item 16-9-6 – Processing of Public Inputs NFPA 110 public inputs were processed. NFPA 111 public inputs were processed. Agenda Item 16-9-7 – Old Business No old business was brought up. Agenda Item 16-9-8 – New Business A task group (Dan Chisholm, Sr, Skip Gregory and Gary Olson) was formed to reword 5.6.5.6. Agenda Item 16-9-9 – Adjournment The teleconference/web meeting was adjourned at 7 PM (Eastern Time). (Meeting minutes prepared by C. Coache.)


Page 10 of 30

Attachment C: Public Comment Report


Page 11 of 30

Public Comment No. 11-NFPA 110-2017 [ Section No. 4.4 ]

4.4* Level.

This standard recognizes two levels for equipment installation, performance, and maintenancerequirements.

4.4.1*

Level 1 systems shall be installed where failure of the equipment to perform could result in loss of humanlife or serious injuries.

4.4.2*

Level 2 systems shall be installed where failure of the EPSS to perform is less critical to human life andsafety.

4.4.3*

All equipment shall be permanently installed.

4.4.4*

Level 1 and Level 2 systems shall ensure that all loads served by the EPSS are supplied with alternatepower that meets all the following criteria:

(1) Of a quality within the operating limits of the load

(2) For a duration specified for the class as defined in Table 4.1(a)

(3) Within the time specified for the type as defined in Table 4.1(b)

Additional Proposed Changes

File Name Description Approved

Correlating_Committee_Note_No_1.pdf 110_CCN1

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 1 in the First Draft Report on First Revision No. 2 and is also related to Public Input No. 51.

Substantiation: This section recognizes the two levels of systems that are used throughout the document. The correlating committee directs the technical committee to review 7.2.1 and 7.11.1, as well as the remainder of the document, for correlation and consistency in the application of these two levels. This will be considered as a public comment.

Related Item

FR 2

PI 51

Submitter Information Verification

Submitter FullName:

CC on NEC-AAC

Organization:NFPA NATIONAL ELECTRICAL CODE CORRELATINGCOMMITTEE

Street Address:

City:

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...


Page 12 of 30

State:

Zip:

Submittal Date: Tue May 09 16:43:46 EDT 2017



Page 13 of 30

Correlating Committee Note No. 1-NFPA 110-2017 [ Section No. 4.4 [Excluding any Sub-Sections] ]


Submitter Full Name: Mark Earley

Organization: National Fire Protection Assoc

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jan 20 13:18:14 EST 2017

Committee Statement and Meeting Notes

Committee Statement:

This section recognizes the two levels of systems that are used throughout the document. The correlating committee directs the technical committee to review 7.2.1 and 7.11.1, as well as the remainder of the document, for correlation and consistency in the application of these two levels. This will be considered as a public comment.

Ballot Results

This item has passed ballot

12 Eligible Voters

0 Not Returned

12 Affirmative All

0 Affirmative with Comments

0 Negative with Comments

0 Abstention

Affirmative All

Brunssen, James E. Deike, Jr., Roland E. Dressman, Kevin L. Hickman, Palmer L. Hittinger, David L. Holub, Richard A. Johnston, Michael J. Kovacik, John R. Manche, Alan McCullough, Robert A. Pierce, James F. Saporita, Vincent J.


Page 14 of 30

Public Comment No. 3-NFPA 110-2017 [ Section No. 5.2.1 [Excluding any Sub-Sections]

]

Energy converters shall consist only of rotating equipment as indicated in 5.2.4, or fuel cells as described inNFPA 852, Standard for Installation of Stationary Fuel Cell Power Systems .


Summary: To address the coordination of NFPA-70, NFPA-99 and NFPA-110, NFPA-110 should be changed to permit fuel cells as source of emergency power provided specific conditions are met.

Originally Proposed Changes to the Code:The following proposed changes were submitted by Walt Vernon during the public comment period on NFPA-110 as one way to permit fuel cells as a source of emergency power in NFPA-110 (Public Input #62 and Public Input #61 respectively):1. Change 5.2.1 to read: “Energy converters shall consist only of rotating equipment as indicated in 5.2.4, or fuel cells as described in NFPA 852, Standard for Installation of Stationary Fuel Cell Power Systems.

2. Additions to section 5.4 as follows: 5.4.1 Because Fuel Cells cannot come up to rated load within a reasonable time,

5.4.1.1. Fuel cell installations must consist of N+1 units operating in parallel, and continuously supplying power to the Emergency System.

5.4.1.2 Fuel cell installations shall have a normal utility supply available in case of total system failure. And

5.4.1.3 Fuel cell installations shall include a connection for portable diesel generator to supply the legally required life safety loads.

These changes were submitted to ensure coordination with NFPA-99 and NFPA-70 both of which permit the use of fuel cells for emergency power.

Committees initial Response:

The NFPA110 committee rejected these changes indicating that “currently fuel cells do not meet all of the performance requirements of NFPA 110.”

New Comment:The committee response in resolving PI 61 was that “fuel cells do not meet the requirements of Section 5.4.” The response to PI 62 was that “currently fuel cells do not meet all of the performance requirements of NFPA 110.” That is exactly what these proposals are trying to address and that resolution statement given by the committee on PI 61 and PI 62 do not address why the committee decided to reject this submittal.

We therefore suggest that the following be added to the text as section 5.4.1:5.4.1 Fuel cells shall be considered to meet the requirement of 5.4 where all of the following conditions are met: (1) Fuel cell installations consist of N+1 units operating in parallel, and continuously supplying power to the Emergency System. (2) Fuel cell installations have a normal utility supply available in case of total system failure. (3) Fuel cell installations include a connection for portable diesel generator to supply the legally required life safety loads.Additionally, section 5.2.1 should be modified as originally suggested, namely: Energy converters shall consist only of rotating equipment as indicated in 5.2.4 or fuel cells as described in NFPA 853, Standard for Installation of Stationary Fuel Cell Power Systems.

Additional Background Information



Page 15 of 30

It does not appear the committee addressed the fact that fuel cells are already permitted as emergency power sources in other NFPA documents. The committee should further consider the change to ensure proper coordination between all NFPA codes.

Walt Vernon chaired the electrical systems committee for NFPA-99 at the time fuel cells were introduced for inclusion as a source of emergency power for health care facilities. He has indicated he would be happy to work with the NFPA-110 committee to ensure the NFPA-110 is appropriately changed to include fuel cells.

NFPA-99 has jurisdiction over healthcare:NFPA-99 was intended to have jurisdiction over healthcare facilities. Section 1.3.1 indicates that “This code shall apply to all health care facilities other than home care and veterinary care.” Section 1.2 states that “the purpose of this code is to provide minimum requirements for the installation, inspection, testing, maintenance, performance, and safe practices for facilities, material, equipment, and appliances, including other hazards associated with the primary hazards.”Furthermore, section 2.1 (2) notes “where the requirements of a referenced code or standard differ from the requirements of this code, the requirements of this code shall govern.” NFPA-110 is a referenced standard.

NFPA 99 explicitly recognizes use of fuel cells for emergency powerSection 6.4.1.1.7 permits fuel cell systems to serve as the alternate source for all or part of an essential electrical system under certain conditions. The National Electrical Code (NFPA-70) explicitly recognizes the use of fuel cells for emergency powerNFPA70 Already recognizes Fuel Cells as a source of power for emergency systems. Sections 700.12E speaks to this specifically: 700.12E“(E) Fuel Cell System. Fuel cell systems used as a source of power for emergency systems shall be of suitable rating and capacity to supply and maintain the total load for not less than 2 hours of full-demand operation.Installation of a fuel cell system shall meet the requirements of Parts II through VIII of Article 692.Where a single fuel cell system serves as the normal supply for the building or group of buildings concerned, it shall not serve as the sole source of power for the emergency standby system.”

As well, NFPA-70 section 701.12F speak specifically to fuel cell use for legally required standby systems:701.12F:“(F) Fuel Cell System. Fuel cell systems used as a source of power for legally required standby systems shall be of suitable rating and capacity to supply and maintain the total load for not less than 2 hours of full-demand operation.Installation of a fuel cell system shall meet the requirements of Parts II through VIII of Article 692.Where a single fuel cell system serves as the normal supply for the building or group of buildings concerned, it shall not serve as the sole source of power for the legally required standby system.”

Therefore, for coordination, changes should be made to NFPA-110:To ensure coordination of the NFPA documents, NFPA-110 should be changed to permit fuel cells as source of emergency power.The technical details of such a change can be deliberated to address concerns. However, NFPA-110 should recognize fuel cells as a source of emergency power, given that they are already explicitly permitted as a source of emergency power for healthcare facilities under the jurisdiction of NFPA-99 and are explicitly permitted more generally under NFPA-70.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 4-NFPA 110-2017 [Section No. 5.4]

Related Item

Public Input#62

Public Input#61


Submitter Full Name: Walter Vernon



Page 16 of 30

Organization: Mazzetti

Street Address:

City:

State:

Zip:

Submittal Date: Thu Apr 20 09:47:10 EDT 2017



Page 17 of 30

Public Comment No. 4-NFPA 110-2017 [ Section No. 5.4 ]

5.4* Energy Converters — Capacity.

The energy converters shall have the required capacity and response to pick up and carry the load withinthe time specified in Table 4.1(b) after loss of primary power.

5.4.1 Fuel cells shall be considered to meet the requirement of 5.4 where all of the followingconditions are met:

(1) Fuel cell installations consist of N+1 units operating in parallel, and continuouslysupplying power to the Emergency System.

(2) Fuel cell installations have a normal utility supply available in case of total systemfailure.

(3) Fuel cell installations include a connection for portable diesel generator to supply thelegally required life safety loads.


Summary: To address the coordination of NFPA-70, NFPA-99 and NFPA-110, NFPA-110 should be changed to permit fuel cells as source of emergency power provided specific conditions are met.

Originally Proposed Changes to the Code:The following proposed changes were submitted by Walt Vernon during the public comment period on NFPA-110 as one way to permit fuel cells as a source of emergency power in NFPA-110 (Public Input #62 and Public Input #61 respectively):1. Change 5.2.1 to read: “Energy converters shall consist only of rotating equipment as indicated in 5.2.4, or fuel cells as described in NFPA 852, Standard for Installation of Stationary Fuel Cell Power Systems.

2. Additions to section 5.4 as follows: 5.4.1 Because Fuel Cells cannot come up to rated load within a reasonable time,

5.4.1.1. Fuel cell installations must consist of N+1 units operating in parallel, and continuously supplying power to the Emergency System.

5.4.1.2 Fuel cell installations shall have a normal utility supply available in case of total system failure. And

5.4.1.3 Fuel cell installations shall include a connection for portable diesel generator to supply the legally required life safety loads.

These changes were submitted to ensure coordination with NFPA-99 and NFPA-70 both of which permit the use of fuel cells for emergency power.

Committees initial Response:The NFPA110 committee rejected these changes indicating that “currently fuel cells do not meet all of the performance requirements of NFPA 110.”

New CommentThe committee response in resolving PI 61 was that “fuel cells do not meet the requirements of Section 5.4.” The response to PI 62 was that “currently fuel cells do not meet all of the performance requirements of NFPA 110.” That is exactly what these proposals are trying to address and that resolution statement given by the committee on PI 61 and PI 62 do not address why the committee decided to reject this submittal.

We therefore suggest that the following be added to the text as section 5.4.1:5.4.1 Fuel cells shall be considered to meet the requirement of 5.4 where all of the following conditions are met: (1) Fuel cell installations consist of N+1 units operating in parallel, and continuously supplying power to the



Page 18 of 30

Emergency System. (2) Fuel cell installations have a normal utility supply available in case of total system failure. (3) Fuel cell installations include a connection for portable diesel generator to supply the legally required life safety loads.Additionally, section 5.2.1 should be modified as originally suggested, namely: Energy converters shall consist only of rotating equipment as indicated in 5.2.4 or fuel cells as described in NFPA 853, Standard for Installation of Stationary Fuel Cell Power Systems.

Additional Background Information:It does not appear the committee addressed the fact that fuel cells are already permitted as emergency power sources in other NFPA documents. The committee should further consider the change to ensure proper coordination between all NFPA codes.

Walt Vernon chaired the electrical systems committee for NFPA-99 at the time fuel cells were introduced for inclusion as a source of emergency power for health care facilities. He has indicated he would be happy to work with the NFPA-110 committee to ensure the NFPA-110 is appropriately changed to include fuel cells.

NFPA-99 has jurisdiction over healthcare:NFPA-99 was intended to have jurisdiction over healthcare facilities. Section 1.3.1 indicates that “This code shall apply to all health care facilities other than home care and veterinary care.” Section 1.2 states that “the purpose of this code is to provide minimum requirements for the installation, inspection, testing, maintenance, performance, and safe practices for facilities, material, equipment, and appliances, including other hazards associated with the primary hazards.”Furthermore, section 2.1 (2) notes “where the requirements of a referenced code or standard differ from the requirements of this code, the requirements of this code shall govern.” NFPA-110 is a referenced standard.

NFPA 99 explicitly recognizes use of fuel cells for emergency power:Section 6.4.1.1.7 permits fuel cell systems to serve as the alternate source for all or part of an essential electrical system under certain conditions.

The National Electrical Code (NFPA-70) explicitly recognizes the use of fuel cells for emergency powerNFPA70 Already recognizes Fuel Cells as a source of power for emergency systems. Sections 700.12E speaks to this specifically:

700.12E:“(E) Fuel Cell System. Fuel cell systems used as a source of power for emergency systems shall be of suitable rating and capacity to supply and maintain the total load for not less than 2 hours of full-demand operation.Installation of a fuel cell system shall meet the requirements of Parts II through VIII of Article 692.Where a single fuel cell system serves as the normal supply for the building or group of buildings concerned, it shall not serve as the sole source of power for the emergency standby system.”

As well, NFPA-70 section 701.12F speak specifically to fuel cell use for legally required standby systems:701.12F:“(F) Fuel Cell System. Fuel cell systems used as a source of power for legally required standby systems shall be of suitable rating and capacity to supply and maintain the total load for not less than 2 hours of full-demand operation.Installation of a fuel cell system shall meet the requirements of Parts II through VIII of Article 692.Where a single fuel cell system serves as the normal supply for the building or group of buildings concerned, it shall not serve as the sole source of power for the legally required standby system.”

Therefore, for coordination, changes should be made to NFPA-110To ensure coordination of the NFPA documents, NFPA-110 should be changed to permit fuel cells as source of emergency power.The technical details of such a change can be deliberated to address concerns. However, NFPA-110 should recognize fuel cells as a source of emergency power, given that they are already explicitly permitted as a source of emergency power for healthcare facilities under the jurisdiction of NFPA-99 and are explicitly permitted more generally under NFPA-70.

Related Public Comments for This Document



Page 19 of 30

Related Comment Relationship

Public Comment No. 3-NFPA 110-2017 [Section No. 5.2.1[Excluding any Sub-Sections]]

Both related to use of fuel cells foremergency power

Related Item

PI-61


Submitter Full Name: Walter Vernon

Organization: Mazzetti

Street Address:

City:

State:

Zip:

Submittal Date: Thu Apr 20 10:10:01 EDT 2017



Page 20 of 30

Public Comment No. 8-NFPA 110-2017 [ Section No. 5.6.4.7 ]

5.6.4.7

All chargers shall include the following characteristics, which are to be accomplished without manualintervention (i.e., manual switch or manual tap changing):

(1) At its rated voltage, the charger shall be capable of delivering energy into a fully discharged battery unitwithout damaging the battery.

(2) The charger shall be capable of returning the fully discharged battery to 100 percent of its ampere-hourrating within the time specified in Table 5.6.4.2, item (f).

(3) As specified in Table 5.6.4.2, item (e), meters with an accuracy within 5 percent of range shall befurnished.

(4) The generator set or charger The charger shall be permanently marked with the following:

(5) Allowable range of battery unit capacity that can be recharged within the time requirements ofTable 5.6.4.2

(6) Nominal output current and voltage

(7) Sufficient battery-type data to allow replacement batteries to be obtained

(8) The battery charger output and performance shall be compatible with the batteries furnished.

(9) Battery chargers used in Level 1 systems shall include temperature compensation for charge rate.


Article 5.6.4.7 is speaking to static automatic battery chargers (not prime mover driven chargers), as prefaced in 5.6.4.6. So, we should strike "generator set or" from (4), as it doesn't make sense.

Related Item

27-NFPA 110-2016


Submitter Full Name: Timothy Windey

Organization: Cummins Power Systems

Street Address:

City:

State:

Zip:

Submittal Date: Fri May 05 14:55:16 EDT 2017



Page 21 of 30


5.6.5.1

A control panel shall be provided and shall contain the following:

(1) Automatic remote start capability

(2) “Run-off-automatic” mechanical switch automatic” switch function

(3) Shutdowns as required by 5.6.5.2(3)

(4) Alarms as required by 5.6.5.2(4)

(5) Controls as required by 5.6.5.2(5)


The intent of the submitters PI was to make this more flexible, as many modern digital generator controls have HMI membrane panels that include the switch function. The intent was not to insert the word "mechanical" ahead of the word "switch". Don't think we should require a step backwards with technology.

Related Item

28-NFPA 110-2016




Street Address:

City:

State:

Zip:




Page 22 of 30


5.6.5.5

The cranking cycle shall be capable of being initiated by any of the following:

(1) Manual start initiation as specified in 5.6.5.2(2)(a).

(2) Loss of normal power at any automatic transfer switch (ATS) considered a part of the EPSS. Primemover shall start (or stop) after appropriate time delays, upon operation of a remote switch or set ofcontacts.

(3) Clock exerciser located in an ATS or in the control panel.

(4) Manually operated (test) switch located in each ATS that simulates a loss of power and causesautomatic starting and operation until this switch is reset, to cause the engine circuit to duplicate itsfunctions in the same manner commercial power is restored after a true commercial power failure.


I am the submitter of the original PI (49-NFPA 110-2016). The PI was passed in the first draft meeting, using my exact wording and substantiation. Unfortunately there was an error made with the wording of this article in the first draft report (and subsequent reports). Please restore wording per this PC (and my original PI 49).

Related Item

PI 49-NFPA-2016




Street Address:

City:

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5.6.5.6 *

All installations shall be provided with at least one remote tamperproof emergency stop switch locatedoutside the room housing the prime mover, where so installed, or elsewhere on the premises where theprime mover is located outside the building.

5.6.5.6.1

The remote manual stop station shall be labeled.

The remote stop should be an option not a mandatory component. I suggest the language in 5.6.5.6 bechanged from "All installations shall be provided with at least one remote tamperproof emergency stopswitch" to "All installation should be proided with at least one remote tamperproof emergenc stop switch"

I don't think it is imperitive in Level 1 applications to have this device installed. The specific operatingprocedure for each facility should dictate the need to incorporate the use of the remote switch. I have 30+years of oerational experience working for hospitals in the Engineering Department, I have yet to see aprocedure in place and staff training on the use of the remote stop switch. I have reached out to numerousmembers of the NFPA 110 committee for feedback on policies or procedures in place at other facilities, Ihave yet to receive any correspondance back with an active procedure that has been implemented. We takethe generation of emergency power very seriously here in NYC area, which is why we commit continuousmanpower for the observation and data collection of the emergency generator while in operation.

I would have difficult time putting together an operational procedure for staff to follow for the implementationof the remote stop switch. We all strive to provide our staff the proper training, tools, education andoperatonal strategy for all of our equipment and systems, yet all my peers I've spoken to have yet to addressthe operational strategy for the remote stop switch for Level 1 applcations.

I would be happy to expound further on the topic and entertain any thought processess to safely implementthe use of the switch that would never jeopardize LIFE SAFETY in our hospital.

Please feel free to contact me if you would like to have further dialogue on the topic.

Best Regards,

Kenny Brengel

516-592-3692

[email protected]


The undue burden on the hospital to implement a strategic policy and procedure for the operation and training of staff on how, when and why they would use the remote manual stop station for the emergency generator for Level 1 facility.

The remote stop should be an option not a mandatory component. I suggest the language in 5.6.5.6to be changed from "All installations SHALL be provided with at least one remote tamperproof emergency stop switch" to"All installations SHOULD be provided with at least one remote tamperproof emergency stop switch"

I don't think it is imperative in Level 1 applications to have this device installed. The specific operating procedure for each facility should dictate the need to incorporate the use of the remote switch. I have 30+ years of hospital operational experience in the Engineering Department. I have yet to see a policy, procedure and staff training in place on the use of the remote stop switch. I have reached out to numerous members of the NFPA 110 committee for feedback on current policies and procedures in place at other facilities. I have yet to receive any correspondence back with an active program that has been implemented. We take the generation of emergency power very seriously here in the NYC area, which is why we commit resources and continuos manpower for the observation and data collection of the emergency generator while in operation.

I would have a difficult time putting together an operational procedure for staff to follow for the implementation of



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the remote stop switch. We all strive to provide staff the proper training, tools, education and systems, yet all my peers I've spoken to have yet to address the operational strategy for the remote stop switch for Level 1 applications.

I would be happy to expound further on my concerns on this topic and entertain any thought process to safely implement the use of the switch that would NEVER jeopardize LIFE SAFETY in any hospital.

Please feel free to contact me if you would like to have further dialogue on this topic.

Best regards,Kenny [email protected]

Related Item

5.6.5.6


Submitter Full Name: Ken Brengel

Organization: KJB Facility Consulting Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Thu Mar 30 09:34:38 EDT 2017



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5.6.9.9

The generator instrument panel for Level 1 applications shall contain the following:

(1) An ac voltmeter(s) for each phase or a phase selector switch

(2) An ac ammeter(s) for each phase or a phase selector switch

(3) A frequency meter

(4) A voltage-adjusting feature to allow ± 5 percent voltage adjustment

(5) An ac kW meter indicating total load on or kVA meter to show total power for the generator set


Need some flexibility for this new requirement, as some more basic generator control HMI's have kVA meters.

Related Item

29-NFPA 110-2016




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Public Comment No. 10-NFPA 110-2017 [ Section No. 7.9.13 ]

7.9.13

Automatically actuated valves shall not be permitted in the fuel oil supply or fuel oil return lines for Level 1emergency power supply systems when the fuel supply is directly connected to the prime mover .

7.9.13.1*

Automatically actuated valves shall be permitted in the fuel oil supply or fuel oil return lines between a dayfuel tank and the main fuel tank for Level 1 emergency power supply systems.

A.7.9.13.1

The fuel supply is also a fire risk to the building and the occupants of that building. The main fuel tankprovides fuel for extended use of the emergency power system or to multiple emergency generators. Ifthere is an issue with the fuel delivery system to the day fuel tank, a large quantity of fuel can be fed intothe generator room. This fuel will feed a growing fire in the generator room and can escape the roomcreating a liquid fire hazard in an occupancy not designed for that type of fire hazard.


The reliability and availability of the direct fuel supply to a Level 1 emergency power supply system is critical. A properly sized day fuel tank will ensure the emergency power is available when needed.

A properly designed fuel/fire detection system interlocked to an automatically actuated valve between the main fuel tank and day fuel tank will help keep any potential spill and/or fire in the emergency generator room and limit the exposure to the main occupancy of the building. With an alarm system, personnel at the facility could respond to any potential false alarm and restore the main fuel supply to the day fuel tank long before the day fuel tank is exhausted. The provision of an automatic shut-off valve in the fuel supply lines between the main fuel tank and day fuel tank will not negatively impact the availability or reliability of the fuel supply to the generator.

The concern of a fuel exposure to the main occupancy of a building is real. There are upsets in the generator room that can lead to fuel from the main tank being pumped into the generator room and also escape the room. To date FM Global has had a couple of incident reported that involved fuel escaping the generator room. In one case the fuel entered a hospital. These events have not resulted in a fire but a liquid fuel fire in any occupancy that is not specifically designed for that exposure can be devastating to the occupancy.

Related Item

PI 57


Submitter Full Name: John LeBlanc

Organization: FM Global

Street Address:

City:

State:

Zip:

Submittal Date: Tue May 09 15:05:17 EDT 2017



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7.11.6 *

For systems in seismic risk areas, the EPS, transfer switches, distribution panels, circuit breakers, andassociated controls shall be capable of performing their intended function during and after being subjectedto the anticipated seismic shock.


Rolling this back to the original wording after discussing with OSHPD. The California Electrical Code, 2016 (NFPA National Electrical Code, 2014) Section 517.31 requires that Life Safety and Critical Branch of Essential Electrical System (Alternative Power Source) be restored within 10 seconds after interruption of normal source, irrespective of the cause.

Related Item

46-NFPA 110 2016




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8.3.7*

A fuel quality test shall be performed at least annually using appropriate ASTM standards.

Please see my additions and changes to the current 8.3.7* below as there is much confusion in theindustry due to the broadness of the testing recommendations and information. It would be my privilege toassist in the upcoming editions pertaining to this Chapter and Section.

8.3.7***

A fuel quality test shall be performed no less than annually using appropriate test methods approved underASTM D 975, Standard Specifications for Diesel Fuel Oils, to indicate fuel can be stored for a minimum of1 year without degradation. Not all approved testing under D 975 specifications shall be required, but aminimum testing of Bacteria/Fungi ASTM D6469, Water & Sediment ASTM D2709 and other foreignmaterials shall be performed as where there is a separation of water from the diesel fuel, microbialcontamination can occur. For fuels being stored for periods longer than 12 months, the diesel fuel shallalso be tested for ignition quality and performance by testing for a minimum of Cetane Index ASTMD4737 approved under ASTM D 975 standards.

Additional tests chosen should be recommended on several factors including but not limited to thefollowing:

1) Geographical location and climate in which diesel fuel is being stored. Climates where thetemperature does not get below freezing should not require the testing of the diesel fuels cold weatherproperties such as cloud point, pour point, and cold filter plug point.

2) The environment in which the fuel stored. See points referenced in Annex A 7.9.1.2 which suggestthat fuel degradation accelerates in tanks subjected to temperature variations as it can lead to thepresence of water and where there is a separation of diesel fuel and water microorganisms and fungi cangrow and contaminate the fuel supply which can lead to general or pitting corrosion of steel tanks andcomponents, possibly resulting in filter plugging, operational issues or a hydrocarbon release to theenvironment.

3) The material of the tank in which the fuel stored. See points referenced in Annex A 7.9.3.1 that states"Copper can promote fuel degradation and can produce mercaptide gels. Zinc coatings can react withwater or organic acids in the fuel to form gels that rapidly plug filters.” Tanks with copper and zinc materialcould recommend having Copper Corrosion testing performed by methods approved under ASTM D 975specifications.

4) ASTM D 975 specification allows biodiesel concentrations up to 5% (B5) in diesel fuel with noseparate labeling required at the pump. It is recommended to test for % Biodiesel Concentration ASTMD7371 in a fuel supply being stored for a minimum of 6 months as biodiesel blends are comprised oforganic substances which accelerate the degradation of fuel if not properly treated. Acceleration is greaterwith any presence of microbiological growth and could possibly lead to sludge like substances within thefuel supply leading to clogged filters and operational issues.

5) All diesel fuel tanks filled after 2014, when the ULSD diesel fuel was made required for all NRLMengines and equipment, it is recommended to test for the Sulfur Content ASTM D2622 to ensure allstored fuels meet the current USLD requirement which reduced Sulfur Content to 15ppm.

Additional documentation suggested to be added from the NFPA 25 - Standard for the Inspection, Testing,and Maintenance of Water-Based Fire Protection Systems—2017 Edition is as follows:

1) If diesel fuel is found to be deficient in the testing required in 8.3.7, the fuel shall be reconditioned orreplaced, the supply tank shall be cleaned internally, and the engine fuel filter(s) shall be changed.

2) After the restoration of the fuel and tank, the fuel shall be retested every 6 months until experienceindicates the fuel can be stored for a minimum of 1 year without degradation beyond that allowed in abovechapters.




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As a provider of diesel fuel testing predominately within the power generation industry, I believe the clarification and guidelines within the fuel quality testing requirements would eliminate much confusion and inconsistency nationwide, particularly when it comes to critical and emergency power operations. As a member of several associations and hundreds of customers, I have experienced that lack of guidance and education is largest and most consistent challenge in the field not only at the service level but especially at the end user level. In addition, it would certainly assist other regulatory firms that reference the NFPA110 regulations in understanding what to look for when enforcing the requirements within their jurisdiction.

Related Item

Professional within Diesel Fuel Testing Laboratory

Member of the EGSA (Electrical Generator Systems Association

Member of the EGSA Dealer / Distributor Committee

Provider of Diesel Fuel Testing for Service Companies / Dealers / Distributors / End Users who arerequired to follow NFPA110 Guidelines


Submitter FullName:

Michelle Hilger

Organization:Titan Laboratories, Member of E.G.S.A (Electrical Generator SystemsAssociation), Member of the Dealer / Distributor Committee within theE.G.S.A

Street Address:

City:

State:

Zip:

Submittal Date: Wed May 10 08:31:27 EDT 2017



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Documents

SECOND DRAFT MEETING AGENDA - NFPA DRAFT MEETING AGENDA . NFPA Technical Committee on Emergency Power Supplies (EPS-AAA) Second Draft Meeting for …