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NATIONAL ELECTRICAL CODE ® CODE-MAKING PANEL 10 NFPA 70 Second Draft Meeting Agenda October 29 – November 3, 2018 San Diego, CA 1. Call to Order – Julian Burns, Chair 2. Introductions 3. Approval of Previous Meeting Minutes (Attachment A) 4. Staff Updates - NFPA Staff Overview of NFPA Process 5. Review of Public Comments (Attachment B) 6. Old Business 7. New Business 8. Adjourn Code-Making Panel 10 Second Draft Meeting Agenda October 29 - November 3, 2018 Page 1 of 266

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Page 1: NATIONAL ELECTRICAL CODE CODE-MAKING PANEL 10 ......NATIONAL ELECTRICAL CODE® CODE-MAKING PANEL 10 NFPA 70 Second Draft Meeting Agenda October 29 – November 3, 2018 San Diego, CA

NATIONAL ELECTRICAL CODE® CODE-MAKING PANEL 10

NFPA 70 Second Draft Meeting Agenda

October 29 – November 3, 2018 San Diego, CA

1. Call to Order – Julian Burns, Chair

2. Introductions

3. Approval of Previous Meeting Minutes (Attachment A)

4. Staff Updates - NFPA Staff

• Overview of NFPA Process

5. Review of Public Comments (Attachment B)

6. Old Business

7. New Business

8. Adjourn

Code-Making Panel 10 Second Draft Meeting Agenda October 29 - November 3, 2018

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Attachment A: Previous Meeting Minutes

Code-Making Panel 10 Second Draft Meeting Agenda October 29 - November 3, 2018

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Code-Making Panel 10 Attendance

NEC® First Draft Meeting A2019

Principal Members in Attendance

J. Burns, Chair P. Barnhart S. Blizard C. Carter J. Dollard C. Fredericks E. Koepke K. Rempe V. Saporita S. Townsend C. Vance D. Williams

Alternate Members in Attendance

A. Dawes J. Dorsey K. Lippert R. Lofton A. Manche D. Morrissey N. Philips R. Sparks S. Struble D. Zia

Staff Liaison

R. Roux, NFPA S. Mahoney, NFPA M. Earley, NFPA

Guests in Attendance

D. Buuck, National Association of House Builders

P. Walsh, IEEE T. Domitrovich, Eaton

D. Crawford, Steel Tub Institute D. Clements, IAEI C. Hunter, Cerro Wire D. Vigstol, NFPA K. Waters, Schneider Electric J. McDonald, NECA L. Grahor, Eaton M. Holt, Mike Holt Enterprises E. Hohengasser, NFPA C. Dubay, NFPA M. Johnston, NECA V. Della Croce, Siemens C. Jensen, UL LLC T. Papallo, Siemens T. McClintock, NFPA M. Paiss, IAFF J. Burris, STI J. Andre, STI J. Conrad, Marmon R. Horner, STI C. Jensen, UL LLC C. Roecks, Southwest Gas Corp, Member of American Gas Assoc

C. Palmieri, IAEI T. McClintock, IAEI

C. Hunter, Cerro Wire T. Lottmann, Eaton R. Dollar, Siemens T. O’Brien, Cisco

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Attachment B: Public Comment Report

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Public Comment No. 683-NFPA 70-2018 [ Global Input ]

Type your content here ...{strikethrough}physical{/strikethrough} damage

Statement of Problem and Substantiation for Public Comment

I have to respectfully disagree with the concept that the term, "Physical damage" is well understood. My basis for this is the fact that there have been many, many attempts to define the term based on the various understandings that experienced electricians and inspectors have. Based on the committee's response to PI 1781, it appears that removing the adjective will increase the consistency of interpretation of the rules that pertain to damage, while entailing no loss.

Related Item

• Based to committee statement in reponse to PI 1781

Submitter Information Verification

Submitter Full Name: David Shapiro

Organization: Safety First Electrical

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 15 12:34:48 EDT 2018

Committee: NEC-AAC

Copyright Assignment

I, David Shapiro, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am David Shapiro, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 979-NFPA 70-2018 [ Global Input ]

This Global Public Comment requests that each CMP review all products under their purview anddetermine whether reconditioning should be permitted. This public comment is submitted by a taskgroup assigned by the NEC Correlating Committee. This task group was charged with reviewing PublicInput 2935 which was resolved by CMP-1 during the first draft stage. This PI would have required that“Reconditioned Equipment” be “listed as “reconditioned” and the “original listing marks removed”. This PIhas ramifications that are global in nature and impacts all products referenced in the NEC under thepurview of every CMP.

Additional Proposed Changes

File Name Description Approved

NEMA-Position_Refubishing_on_ElecEquip.pdf

Statement of Problem and Substantiation for Public Comment

This Public Comment is submitted on behalf of a task group appointed by the NEC® Correlating Committee. This Task Group was appointed to review the use of refurbished equipment throughout the NEC®. Task Group members are Jim Dollard, Robert Osborne, Jim Pierce, and David Williams. This task group has been charged with reviewing Public Input (PI) 2935 which was resolved by CMP-1 during the first draft stage. This PI would have required that “Reconditioned Equipment” be “listed as “reconditioned” and the “original listing marks removed”. This PI has ramifications that are global in nature and impacts all products referenced in the NEC under the purview of every CMP.

Task group members noted that some types of equipment are capable of being reconditioned, then re-evaluated to ensure compliance with the applicable product standards. Other types of equipment do not lend themselves to reconditioning due to the complexity of the product, the manufacturing process, or the level of knowledge the company performing the reconditioning may need, etc.

The “NEMA Policy on Reconditioned Electrical Equipment” details the following aspects of Reconditioning of Electrical Equipment:

ꞏ Fundamental Tenets for Reconditioning Electrical Equipment

ꞏ Electrical Infrastructure and Worker Safety

ꞏ Integrity of Reconditioned Equipment

ꞏ Listing or Certification Marks

ꞏ UL Guidance on the UL Mark

ꞏ Components or Assemblies Not Suitable For Reconditioning (Appendix A)

ꞏ Components or Assemblies Which May Be Reconditioned (Appendix B)

A PDF copy of this NEMA policy is attached and may also be found on the internet at the following URL:

https://www.nema.org/Policy/Documents/NEMA-Position_Refubishing%20on%20ElecEquip.pdf

NEC® section 110.21(A)(2), which was new for the 2017 Edition of the NEC®, included marking requirements for “Reconditioned Equipment”. PI 2935 would have required that “Reconditioned Equipment” be “listed as “reconditioned” and the “original listing marks removed”. CMP 1 resolved this PI. Due to the global nature of PI 2935 this Task Group, appointed by the NEC® Correlating Committee, has developed a number of Public Comments, based on the products identified in the referenced NEMA document, to determine whether or not equipment can be reconditioned, and if reconditioned, what additional requirements apply.

While several Public Comments were developed for specific equipment by this task group, not all equipment was addressed (neither was all the equipment noted in the NEMA Policy document addressed). This Global Public

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Comment requests each CMP to review the products required to be listed under their purview and determine whether reconditioning should be permitted. It is recommended that the NEMA Policy document be used as one of the guidelines in making this determination. It is also recommended that one of the following options/examples be chosen for listed equipment:

Option 1 - Equipment NOT suitable for Reconditioning (EXAMPLE):

695.10 Listed Equipment. Diesel engine fire pump controllers, electric fire pump controllers, electric motors, fire pump power transfer switches, foam pump controllers, and limited service controllers shall be listed for fire pump service. [20:9.5.1.1, 10.1.2.1, 12.1.3.1]

Fire pump controllers and transfer switches shall not be permitted to be reconditioned.

Option 2 - Equipment which MAY BE suitable for Reconditioning (EXAMPLE):

408.8 Reconditioned Equipment.

(A) Panelboards. The use of reconditioned panelboards shall comply with (1) and (2):

(1) Industrial and commercial panelboards shall be permitted to be reconditioned. Reconditioned equipment shall be listed as “reconditioned” and the original listing mark removed.

(2) Panelboards installed in dwelling units shall not be permitted to be reconditioned.

(B) Switchboards and Switchgear. Low voltage switchgear, medium voltage switchgear and switchboards shall be permitted to be reconditioned. Reconditioned equipment shall be listed as “reconditioned” and the original listing mark removed.

Note that equipment where no specific guidance is provided would be permitted to be reconditioned and would only be required to meet the marking requirements in 110.21(A)(2).

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 980-NFPA 70-2018 [New Section after 240.87(B)]

Public Comment No. 981-NFPA 70-2018 [New Section after 240.61]

Public Comment No. 982-NFPA 70-2018 [New Section after 240.101(B)]

Public Comment No. 983-NFPA 70-2018 [Section No. 695.10]

Public Comment No. 984-NFPA 70-2018 [Section No. 700.5(C)]

Public Comment No. 985-NFPA 70-2018 [Section No. 701.5(C)]

Public Comment No. 986-NFPA 70-2018 [Section No. 702.5]

Public Comment No. 987-NFPA 70-2018 [New Section after 408.7]

Related Item

• PI 2935

Submitter Information Verification

Submitter Full Name: James Dollard

Organization: IBEW Local Union 98

Street Address:

City:

State:

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Zip:

Submittal Date: Tue Aug 21 08:08:39 EDT 2018

Committee: NEC-AAC

Copyright Assignment

I, James Dollard, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am James Dollard, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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NEMA Policy on Reconditioned Electrical Equipment Executive Summary: The option of reconditioning existing equipment (instead of purchasing new equipment) exists today. Proper electrical equipment reconditioning provides a means to extend the life of electrical products as well as an opportunity in some cases to update installed equipment with the latest performance and safety features. However, not all components of the electrical infrastructure are candidates for reconditioning. There are a number of precautions that must be adhered to when reconditioning electrical equipment if that equipment is to operate safely and with acceptable performance. Those precautions are discussed below and include the use of design qualified parts, testing to industry-recognized safety standards, original manufacturer specification and/or recommendations, when possible, and reconditioning performed by qualified personnel. The integrity of reconditioned electrical equipment must be established by documenting and demonstrating that component replacement has not compromised the manufacturer’s original specifications and accepted industry standards. The third party certification mark must be removed or obliterated from reconditioned electrical products to indicate that an evaluation of the reconditioning process or reconditioned product has not been conducted by the original third party. As guidance, Appendix B provides a list of electrical products and components that are considered by NEMA suitable for reconditioning and Appendix A provides a list of electrical products considered not suitable for reconditioning. Medical Imaging Equipment is specifically not addressed by this policy (reference MITA 1, Good Refurbishment Practices for Medical Imaging Equipment). Introduction: The U.S. electrical industry includes discussions on implementing new technologies to enhance existing electrical infrastructure. Further, sustainability and safeguarding the environment are growing in importance. In the midst of this is the option for reconditioning existing equipment. Paramount in all this is the fundamental priority that all electrical systems operate while safe-guarding personnel and infrastructure from potential hazards (electrical, mechanical, fire, etc.). This forms the basis for the NEMA position on reconditioning electrical products. Given that electrical systems are diverse in design, function, and application, not all components of the electrical infrastructure are candidates for reconditioning. Definition:

Reconditioning: the process of restoring electromechanical systems, equipment, apparatus or components to operating conditions as recommended by the

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manufacturer’s instructions, using only design qualified parts. Reverse engineered parts (designs copied from existing parts by other manufacturers) are not considered to be “design qualified parts” unless specifically design verified under applicable Standards. Electrical industry practitioners and other organizations may also use the following terms/words to describe the process of reconditioning: remanufacturing, refurbishing, recycling, repairing, restoring, rebuilding, reengineering, and reusing.

In addition to design considerations, it is often impossible to obtain the service records, application environment, and operation parameters of all electrical components. Not having access to such information could have an adverse impact on the final safety and reliability of refurbished or reconditioned equipment. While NEMA supports the reconditioning of some electrical equipment, the components listed in Appendix A are not recommended for reconditioning, unless otherwise indicated by the original manufacturer. Normal servicing of equipment that remains within a facility should not be considered reconditioning or refurbishing. For electrical components suitable for reconditioning listed in Appendix B, the following fundamental tenets have been established. Fundamental Tenets for Reconditioning Electrical Equipment

Reconditioning electrical equipment may be a viable option for extending operational lifetime of equipment and enhancing equipment with additional features.

Electrical equipment reconditioning activity must be based on available guidance documentation from the Original Equipment Manufacturer, or industry-developed standards. Where any conflict in guidance is noted between the OEM and industry standards, the OEM guidance should take precedence. 

Electrical equipment must be reconditioned and qualified to an industry-developed standard that ensures equipment is in a usable and safe operating condition. An industry-developed standard is a widely agreed upon rule, set of rules, procedures or requirements for a product, assembly or process which are developed by members or organizations of an aggregate of manufacturing and technically productive enterprises in a particular field. Products deemed to be candidates for reconditioning must be reconditioned and qualified to industry standards containing the most relevant and critical design aspects, testing criteria and manufacturing specifications when the item was built.

Reconditioning work must be performed by qualified personnel. Electrical equipment that has been exposed to adverse conditions, such as fire,

water damage, etc., may not be suitable for reconditioning. A comprehensive assessment of the electrical equipment being considered for

reconditioning with service records, application, environment, service life, and operating parameters is critical before deciding to pursue reconditioning of the electrical equipment and system. Trained, skilled technicians should be able to assess whether a device or system is suitable for reconditioning through physical inspection and test.

Appendix A provides guidance on which components or assemblies of the electrical system are not suitable for reconditioning because they may pose a

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hazard. Appendix B provides guidance on the components or assemblies are suitable for reconditioning.

Reconditioning electrical equipment must utilize electrical product safety standards as they contain design aspects, testing criteria and manufacturing specifications to ensure a given product will function as intended. These requirements are established to deliver a usable and safe operating condition as a key component of intended product functionality.

Electrical Infrastructure and Worker Safety

Electrical equipment that is properly installed, tested, maintained, and operated will provide reliable power as well as protect the electrical infrastructure. The reconditioning of electrical equipment requires the electrical industry, in collaboration with manufacturers, to establish performance specifications and accepted industry standards to help ensure safe and reliable equipment that help protect our electrical infrastructure so workers and users can continue to benefit from a safe and effective electrical system. Reconditioning standards must include prescriptive actions and performance requirements that result in equipment that complies with standards that include but are not limited to CSA, IEC, IEEE, NEC, OSHA, NFPA 70E, NFPA 70B, NETA ATS, NETA MTS, and EASA AR100 for example. Qualified personnel must possess the knowledge of how to assess equipment condition, potential hazards, and specifications to accurately determine the suitability for reconditioning. A safe and reliable electrical infrastructure that can be safely maintained is dependent on compliance with manufacturers’ instructions, qualified workers, proper maintenance, and accepted industry standards for reconditioning activities. Electrical Equipment Reliability, Performance and Safety

Proper electrical equipment reconditioning provides a means to extend the life of electrical products as well as an opportunity to update installed equipment with the latest performance and safety features. Establishing well defined guidelines for those performing the reconditioning activity, based on original manufacturer’s requirements, creates a solid foundation for the electrical industry and users. It is paramount that reconditioned electrical equipment be reliable in not only providing power, but also in safely performing its intended function as part of a safe operating electrical system. Understanding the environment, electrical load characteristics and historical maintenance performed on equipment being considered for reconditioning are all important parts of an assessment for reconditioning that can have a significant bearing on reliability, performance and safety. The electrical equipment manufacturer is the foremost authority on the design, performance and intended safe application of their product. Reconditioned electrical equipment must not compromise the reliability, performance, safe operation, or maintenance of the electrical system. Integrity of Reconditioned Equipment

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Reconditioned electrical equipment must comply with all applicable standards at the time the equipment was initially built as a minimum as well as the original manufacturer’s performance requirements in accordance with the nameplate markings and ratings. Replacement parts shall meet the design criteria (form, fit, and function) for the device to perform its intended function and provide safe operation. Replacement parts shall not include counterfeit parts (i.e., parts that have been misrepresented to be an authorized item of the legally authorized source.) Equipment shall operate safely in its intended application after reconditioning occurs. Care must be taken to ensure specific operations such as timing, sequencing, control, transfer, etc. continue to function in the manner originally intended, unless changes are specified during the reconditioning process. The integrity of reconditioned electrical equipment must be established by documenting and demonstrating that component replacement and performance changes have not compromised the manufacturer’s specifications and accepted industry standards. Listing or Certification Marks

NEMA members manufacture products that are more than likely to be evaluated as part of a third party certification program to nationally recognized safety standards. These products can be marked with a listing or certification mark when the products are manufactured and shipped from the factory. The organization that reconditions the product is responsible for adhering to the guidelines from the issuing agency authorizing the mark to determine if the mark can remain on the product after reconditioning. The organization that reconditions is responsible for any actions necessary for the mark to remain on the product (analysis, testing, etc.). Otherwise, reconditioned electrical products must have their mark removed or obliterated to indicate that an evaluation of the reconditioning process has not been conducted by the original third party. The organization that reconditions the product is additionally responsible for applying a mark or seal that indicates that the equipment has been reconditioned. This mark must provide traceability to the reconditioning organization in the event that it is necessary to determine the details of who reconditioned the equipment and the report on what was completed during this process. There are a number of NEMA products that are not allowed to be reconditioned due to the inherent safety characteristics and requirements for those products to be evaluated according to a regular follow up program to evaluate the safety performance requirements as a condition of maintaining the listing or certification mark. This process cannot be applied to reconditioned electrical products since these are normally destructive tests and sample sets of reconditioned products are not possible due to limited quantities or ratings of specific devices. UL Guidance on the UL Mark When the manufacturer places the UL Mark on the product at the factory, it is their attestation that the product complies with the applicable requirements. Unless there is further oversight or review/inspection (field inspection) UL cannot ascertain that the

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product continues to comply with all requirements should field repairs, modifications or component replacements be made to the product. Obviously there is little control over what manufacturers will or can do to equipment which left the factory with a certification mark. UL has created rebuilt categories where the reconditioning of product is done in an organized consistent manner under the supervision of UL’s FUS (Follow-Up Services) field representatives. In these cases the first action conducted with equipment being rebuilt is the removal of the initial certification mark (if provided). Upon completion of the reconditioning, in accordance with the surveillance document, the manufacturer is permitted to affix a mark which clearly identifies the product as reconditioned.

Cases where a reconditioner is instructed to NOT remove any certification mark will result in confusion. Clearly such equipment in the field, which has undergone modification or reconditioning, is ineligible to bear a mark which designates a compliance with a certification standard.

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APPENDIX A

COMPONENTS OR ASSEMBLIES NOT SUITABLE FOR RECONDITIONING* Adjustable speed drives Arc fault circuit breakers Ballasts Busway (mylar wrapped) Busway (powder coated) Cable tray Cast resin transformers Components containing semiconductors and transistors Control transformers Dry type transformers Electrical Connectors Electrical submetering equipment Electrical vehicle supply equipment Enclosed switches Fire detectors, smoke alarms, co detectors Fire pump controllers Flexible and extension cords Flexible conduit Ground fault circuit breakers High performance wire and cable Lighting controls Liquid filled transformers Low and medium voltage fuse holders Low and medium voltage non-renewable fuses Low voltage power circuit breaker electronic trip units Luminaires Meters (electromechanical, electronic or digital) Meter sockets Molded case circuit breakers Non-Metallic conduit, tubing, raceways and fittings Non-metallic surface raceways and fittings Outlet and junction boxes Overload relays Pin and sleeve plugs receptacles and connectors Power and control cable Protective relays (electronic or digital) Residential panel boards Solid state contactors and starters Solid state drives Strut type channel raceway Surface metal raceways and fittings Surge protective devices Transfer switches Wire or cable Wireway Wiring devices

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*The components or products listed above are not recommended for reconditioning, unless otherwise indicated by the original manufacturer.

APPENDIX B

COMPONENTS OR ASSEMBLIES WHICH MAY BE RECONDITIONED Electromechanical protective relays, and current transformers High voltage circuit breakers Industrial and commercial panel boards Low and medium voltage power circuit breakers Low and medium voltage replaceable link fuses Low voltage switchgear Manual and magnetic controllers Medium voltage switchgear Metallic conduit, tubing, raceways and fittings Motor control centers Motors Switchboards Uninterruptible Power Supply Equipment

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Public Comment No. 2215-NFPA 70-2018 [ Global Input ]

The Correlating Committee directs Panel 10 to review all references to Article 310 under their purview.Article 310 has been divided into Article 310,

Conductors for General Wiring, and Article 311, Medium Voltage Conductors and Cables for usability andclarity. Panel 10 shall appoint a task group

to review all necessary references to verify their accuracy and submit Public Comments where necessary.This action instructs Panel 10 to

submit a Public Comment(s) within the time frame required in the NEC schedule.

This action shall be considered as a public comment.

Additional Proposed Changes

File Name Description Approved

CN_270.pdf CN_270

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 270 in the First Draft Report.

The Correlating Committee directs Panel 10 to review all references to Article 310 under their purview. Article 310 has been divided into Article 310,

Conductors for General Wiring, and Article 311, Medium Voltage Conductors and Cables for usability and clarity. Panel 10 shall appoint a task group

to review all necessary references to verify their accuracy and submit Public Comments where necessary. This action instructs Panel 10 to

submit a Public Comment(s) within the time frame required in the NEC schedule.

This action shall be considered as a public comment.

Related Item

• Correlating Committee Note No. 270

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Sep 07 14:00:33 EDT 2018

Committee: NEC-P10

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Copyright Assignment

I, CC on NEC-AAC, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am CC on NEC-AAC, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Correlating Committee Note No. 270-NFPA 70-2018 [ Global Input ]

Submitter Information Verification

Submitter Full Name: Sarah CaldwellCommittee: Submittal Date: Fri May 11 17:54:55 EDT 2018

Committee Statement and Meeting Notes

Committee Statement:

The Correlating Committee directs all panels to review all references to Article 310 under their purview. Article 310 has been divided into Article 310, Conductors for General Wiring, and Article 311, Medium Voltage Conductors and Cables for usability and clarity. Each panel shall appoint a task group to review all necessary references to verify their accuracy and submit Public Comments where necessary. This action instructs the referenced panels to submit a Public Comment(s) within the time frame required in the NEC schedule.

This action shall be considered as a public comment.

Ballot Results

This item has passed ballot

12 Eligible Voters0 Not Returned

12 Affirmative All0 Affirmative with Comments0 Negative with Comments0 Abstention

Affirmative AllBrunssen, James E.

Dressman, Kevin L.

Hickman, Palmer L.

Hittinger, David L.

Holub, Richard A.

Johnston, Michael J.

Kovacik, John R.

Manche, Alan

McDaniel, Roger D.

Pierce, James F.

Saporita, Vincent J.

Williams, David A.

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Public Comment No. 2232-NFPA 70-2018 [ Global Input ]

The Correlating Committee directs Panel 10 to review all Articles, within their purview, that supplement ormodify (90.3) GFCI requirements in 210.8 for correlation, clarity, usability and standardized format. ACorrelating Committee Task Group will be appointed and will submit comments where necessary.

This action shall be considered as a public comment.

Additional Proposed Changes

File Name Description Approved

CN_152.pdf CN_152

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 152 in the First Draft Report.

The Correlating Committee directs Panel 10 to review all Articles, within their purview, that supplement or modify (90.3) GFCI requirements in 210.8 for correlation, clarity, usability and standardized format. A Correlating Committee Task Group will be appointed and will submit comments where necessary.

This action shall be considered as a public comment.

Related Item

• Correlating Committee Note No. 152

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Sep 07 14:53:53 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, CC on NEC-AAC, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am CC on NEC-AAC, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Correlating Committee Note No. 152-NFPA 70-2018 [ Global Input ]

Submitter Information Verification

Submitter Full Name: Erik Hohengasser

Committee:

Submittal Date: Thu May 10 18:00:52 EDT 2018

Committee Statement

CommitteeStatement:

The Correlating Committee directs each panel to review all Articles, within their purview, thatsupplement or modify (90.3) GFCI requirements in 210.8 for correlation, clarity, usability andstandardized format. A Correlating Committee Task Group will be appointed and will submit commentswhere necessary.

This action shall 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.

Dressman, Kevin L.

Hickman, Palmer L.

Hittinger, David L.

Holub, Richard A.

Johnston, Michael J.

Kovacik, John R.

Manche, Alan

McDaniel, Roger D.

Pierce, James F.

Saporita, Vincent J.

Williams, David A.

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Public Comment No. 796-NFPA 70-2018 [ Global Input ]

It was the action of the Correlating Committee that this first revision be referred to Code-Making Panel 10for correlation of permitted wiring methods in Article 230.

This action will be considered as a public comment.

Additional Proposed Changes

File Name Description Approved

CCN_1_-_Global.pdf 70_CN 1

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. 8036, and is also related to Public Input No. 4309.

It was the action of the Correlating Committee that this first revision be referred to Code-Making Panel 10 for correlation of permitted wiring methods in Article 230.

This action will be considered as a public comment.

Related Item

• FR 8036

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 17 15:40:41 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, CC on NEC-AAC, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am CC on NEC-AAC, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Correlating Committee Note No. 1-NFPA 70-2018 [ Global Input ]

Submitter Information Verification

Submitter Full Name: Sarah Caldwell

Committee:

Submittal Date: Wed May 09 11:01:37 EDT 2018

Committee Statement and Meeting Notes

CommitteeStatement:

The Correlating Committee advises that article scope statements and article titles are the responsibilityof the correlating committee. The correlating committee accepts the scope statement and directs thatthe Article title be changed to “Type P Cable”.

This action will be considered as a Public Comment.

The Correlating Committee directs the panel to reconsider the use of first level subdivisions in 337.24this section. Consider using two list item type format to meet the requirements of the NEC® StyleManual 2.1.5.1.

This action will be considered as a Public Comment.

The Correlating Committee notes that the hazardous (classified) location uses or permissions to useType P cable are under the purview of CMP14 and are better located in Chapter 5 for usability. TheCorrelating Committee directs CMP 6 to correlate uses permitted, as done in other cable assemblyarticles, for Type P Cable in Chapter 5 locations.

This action will be considered as a Public Comment.

It was the action of the Correlating Committee that this first revision be referred to Code-Making Panel10 for correlation of permitted wiring methods in Article 230.

This action will be considered as a public comment.

First Revision No. 8036-NFPA 70-2018 [Global Input]

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.

Dressman, Kevin L.

Hickman, Palmer L.

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Hittinger, David L.

Holub, Richard A.

Johnston, Michael J.

Kovacik, John R.

Manche, Alan

McDaniel, Roger D.

Pierce, James F.

Saporita, Vincent J.

Williams, David A.

National Fire Protection Association Report https://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/...

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Public Comment No. 836-NFPA 70-2018 [ Global Input ]

The Correlating Committee advises that new articles and their scope statements are theresponsibility of the Correlating Committee and accepts the panel action.

The Correlating Committee directs that an Informational note be considered for 242.1 toprovide a transition between the previous Article 280 and 285 to this new Article.

This action will be considered a public comment.

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Additional Proposed Changes

File Name Description Approved

CN_69_-_Global.pdf 70_CN 69

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 69 in the First Draft Report on First Revision No. 8221.

The Correlating Committee advises that new articles and their scope statements are the responsibility of the Correlating Committee and acceptsthe panel action.

The Correlating Committee directs that an Informational note be considered for 242.1 to provide a transition between the previous Article 280and 285 to this new Article.

This action will be considered a public comment.

Related Item

• FR 8221

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 11:25:14 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, CC on NEC-AAC, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am CC on NEC-AAC, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Correlating Committee Note No. 69-NFPA 70-2018 [ Global Input ]

Submitter Information Verification

Submitter Full Name: Sarah CaldwellCommittee: Submittal Date: Wed May 09 17:47:27 EDT 2018

Committee Statement and Meeting Notes

Committee Statement:

The Correlating Committee advises that new articles and their scope statements are the responsibility of the Correlating Committee and accepts the panel action.

The Correlating Committee directs that an Informational note be considered for 242.1 to provide a transition between the previous Article 280 and 285 to this new Article.

This action will be considered a public comment.

First Revision No. 8221-NFPA 70-2018 [Global Input]

Ballot Results

This item has passed ballot

12 Eligible Voters0 Not Returned

12 Affirmative All0 Affirmative with Comments0 Negative with Comments0 Abstention

Affirmative AllBrunssen, James E.

Dressman, Kevin L.

Hickman, Palmer L.

Hittinger, David L.

Holub, Richard A.

Johnston, Michael J.

Kovacik, John R.

Manche, Alan

McDaniel, Roger D.

Pierce, James F.

Saporita, Vincent J.

Williams, David A.

Page 1 of 1National Fire Protection Association Report

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Public Comment No. 511-NFPA 70-2018 [ Definition: Fault Current, Available (Available

Fault Curre... ]

Fault Current, Available (Available Fault Current).

The largest amount of current capable of being delivered at a point on the system during a short-circuit

condition based on (1) t he system voltage and (2) the connected total impedance of the current flow path

from the source to the point of the fault . (CMP-10)

Informational Note: A short-circuit can occur during abnormal conditions such as a fault betweencircuit conductors or a ground fault. See Informational Note Figure 100.1.

Figure Informational Note Figure 100.1 Available Fault Current.

Statement of Problem and Substantiation for Public Comment

1. Delete 'maximum' since there is no maximum, minimum, average, or anything else. It is what it is.2. Delete figure since this includes 110.9, 110.10, and have too many references to Available Fault Current, that only confuses the issue.3. Delete Informational note. Available fault current is calculated phase-to-neutral/ground. This note just adds confusion.

Related Item

• FR-8191

Submitter Information Verification

Submitter Full Name: Mike Holt

Organization: Mike Holt Enterprises Inc

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 09 17:55:02 EDT 2018

Committee: NEC-P10

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Copyright Assignment

I, Mike Holt, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Mike Holt, and I agree to be legally bound by the above Copyright Assignment and the terms andconditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon mysubmission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 595-NFPA 70-2018 [ Definition: Fault Current, Available (Available

Fault Curre... ]

Fault Current, Available (Available Fault Current).

The largest amount of current capable of being delivered at a point on the system during a short-circuitcondition. (CMP-10)

Informational Note: A short-circuit can occur during abnormal conditions such as a fault betweencircuit conductors or a ground fault . See Informational Note Figure 100.1.

Figure Informational Note Figure 100.1 Available Fault Current.

Statement of Problem and Substantiation for Public Comment

The Informational Note should not include a reference to a ground fault as a type of a short-circuit. The term "Ground Fault" is defined in Article 100 and is not considered by that definition as a type of a short circuit.Note also that 110.7 differentiates between a short-circuit and a ground-fault. The Figure should be deleted as it will cause confusion. It can be concluded that the only points the fault current needs to be considered is at the points shown. There can be many other points where a the available fault current must be considered such as distribution centers, motor control centers, motor controllers and control panels. to name a few.

Related Item

• FR-8171

Submitter Information Verification

Submitter Full Name: Phil Simmons

Organization: Simmons Electrical Services

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 13 15:20:47 EDT 2018

Committee: NEC-P10

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Copyright Assignment

I, Phil Simmons, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Phil Simmons, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1303-NFPA 70-2018 [ Definition: Fault Current. ]

Fault Current.

An objectionable A current that flows due to an abnormal circuit condition such as a short-circuit or groundfault . (CMP-10)

Statement of Problem and Substantiation for Public Comment

Whereas "objectionable current" is not defined in the NEC, it is used in 250.6 to describe neutral currents flowing on the grounding system due to multiple bonding jumpers. Defining fault current as "objectionable" creates an ambiguous definition for the word objectionable. And why is fault current objectionable? We take a great deal of care to create effective ground fault current paths, in the design and installation of system, to ensure that there is a path such that fault current will flow and ocp devices will trip. I would say that "objectionable" should be reserved for something that is not supposed to happen. Fault current, on the other hand, is definitely supposed to happen during a fault condition.

Related Item

• 1247-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: Eric Stromberg

Organization: Los Alamos National Laboratory

Affiliation: Self

Street Address:

City:

State:

Zip:

Submittal Date: Sun Aug 26 13:09:59 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Eric Stromberg, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Eric Stromberg, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1993-NFPA 70-2018 [ Definition: Fault Current. ]

Fault Current.

An objectionable current that flows due to an abnormal The amount of current delivered at a point on the

system during a short- circuit condition. (CMP-10)

Statement of Problem and Substantiation for Public Comment

Revise the definition to match that which is presently in NFPA 70E. Fault Current. The amount of current delivered at a point on the system during a short-circuit condition.

The proposed definition to the NEC can be confusing by using the word "objectionable". Objectionable current is covered in 250.6 and typically seems to be a different condition than what CMP10 is trying to address. Abnormal circuit conditions can occur without resulting in what is usually thought of as fault current.

This revised definition could be used with the term "maximum" or another word in a specific rule possibly eliminating the need for a definition of "Available Fault Current".

Possibly a definition of Short Circuit should also be added as an "unintentional connection between circuit conductors due to a fault". The term "short circuit" is commonly misused and misunderstood.

Related Item

• FR 8190

Submitter Information Verification

Submitter Full Name: Paul Dobrowsky

Organization: Innovative Technology Services

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 14:01:06 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Paul Dobrowsky, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Paul Dobrowsky, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 2140-NFPA 70-2018 [ Definition: Fault Current. ]

Fault Current.

An objectionable current that flows due to an abnormal The amount of current delivered at a point on the

system during a short- circuit condition. (CMP-10)

Statement of Problem and Substantiation for Public Comment

Using the phrase "current that flows" does not improve usability. Current is often defined as the movement of electrons, the words flow or flows is redundant. Using the phrase "objectionable current" in this new definition creates a conflict with 250.6(C). Objectionable current can exist without a fault condition.

Related Item

• FR 8190

Submitter Information Verification

Submitter Full Name: Paul Dobrowsky

Organization: Innovative Technology Services

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 20:14:15 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Paul Dobrowsky, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Paul Dobrowsky, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 509-NFPA 70-2018 [ Definition: Fault Current. ]

Fault Current.

An objectionable current that flows due to an abnormal circuit condition

An unintentional, electrically conductive connection between an ungrounded conductor of anelectrical circuit and (1) another ungrounded conductor, (2) a grounded conductor, (3) the normally non–current-carrying conductors, metallic enclosures, metallic raceways, metallic equipment, or (4) the earth .(CMP-10)

Information Note: See the definition of ground fault.

Statement of Problem and Substantiation for Public Comment

Revise the definitinon to be similar to the term Ground Fault. For sure the word 'objectional' should not be in the term.

Related Item

• FR-8190

Submitter Information Verification

Submitter Full Name: Mike Holt

Organization: Mike Holt Enterprises Inc

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 09 17:45:22 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Mike Holt, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Mike Holt, and I agree to be legally bound by the above Copyright Assignment and the terms andconditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon mysubmission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1302-NFPA 70-2018 [ Definition: Feeder. ]

Feeder.

All circuit conductors between the service equipment, the source of a separately derived system, orother power supply source and the final branch-circuit overcurrent device. (CMP-2)

Statement of Problem and Substantiation for Public Comment

The article 100 definition of "separately derived system" states that it is "An electrical source..."Since the definition already states that it is a source; to say "the source of a separately derived system" is to say "the source of the source..." This, in turn, would indicate the system feeding the separately derived system.

Related Item

• 2145-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: Eric Stromberg

Organization: Los Alamos National Laboratory

Affiliation: Self

Street Address:

City:

State:

Zip:

Submittal Date: Sun Aug 26 13:03:36 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Eric Stromberg, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). Iunderstand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Commentand that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Eric Stromberg, and I agree to be legally bound by the above Copyright Assignment andthe terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronicsignature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1892-NFPA 70-2018 [ Definition: Service Drop. ]

Service Drop, Utility .

The overhead conductors between the utility electric system and the service point. (CMP-10)

Statement of Problem and Substantiation for Public Comment

There are currently eleven definitions in the Code that begin with the word "Service." Nine of these are customer owned and are inside the scope of the Code. Two of them, "service-drop," and "service-lateral" are not customer owned and are outside the scope of the Code. Because of this, the word "service" is ambiguous in the Code. Also, a "service drop" is not a "service conductor." Not very intuitive.

"Service Drop" occurs 33 times in the Code. It could easily be replaced Globally. Defining it as "Service Drop, Utility" keeps it within the block of definitions in Art. 100. On the other hand, the definition could simply become "Utility Drop." This would bring more clarity in that there would be no ambiguity as to the use of the word "service."

Related Item

• 2161-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: Eric Stromberg

Organization: Los Alamos National Laboratory

Affiliation: Self

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 11:20:16 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Eric Stromberg, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Eric Stromberg, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 311-NFPA 70-2018 [ Definition: Service. ]

Service.

The conductors and equipment connecting the serving utility to the wiring system of the premises served.(CMP-10)

Statement of Problem and Substantiation for Public Comment

The information provided by Mr. Vance in his negative ballot statement is completely correct. However, with the advent of distributed energy resources providing energy from the premises wiring system to the utility is becoming common. Updating the definition of service is essential to proper application of the NEC. Please keep the revised definition as it appears in FR 8195.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 315-NFPA 70-2018 [Section No. 705.11(F)]

Related Item

• FR-8195

Submitter Information Verification

Submitter Full Name: Timothy Croushore

Organization: FirstEnergy

Affiliation: FirstEnergy

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 27 12:57:46 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Timothy Croushore, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyrightin this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intendthat I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or anothersimilar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority toenter into this copyright assignment.

By checking this box I affirm that I am Timothy Croushore, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 600-NFPA 70-2018 [ Definition: Service. ]

Service.

The conductors and equipment connecting the serving utility to the service equipment for the wiring systemof the premises served. (CMP-10)

Statement of Problem and Substantiation for Public Comment

The words "service equipment" are proposed to add clarity to the definition. The "service equipment" is (are) a vitally important part of the "Service". The service begins at the serving utility and ends at the service disconnecting means.

Related Item

• FR-8195

Submitter Information Verification

Submitter Full Name: Phil Simmons

Organization: Simmons Electrical Services

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 13 16:28:31 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Phil Simmons, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Phil Simmons, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1895-NFPA 70-2018 [ Definition: Service Lateral. ]

Service Lateral, Utility .

The underground conductors between the utility electric supply system and the service point.(CMP-4)

Statement of Problem and Substantiation for Public Comment

There are currently eleven definitions in the Code that begin with the word "Service." Nine of these are customer owned and are inside the scope of the Code. Two of them, "service-drop," and "service-lateral" are not customer owned and are outside the scope of the Code. Because of this, the word "service" is ambiguous in the Code. Also, a "service lateral" is not a "service conductor." Not very intuitive.

"Service Lateral" occurs 14 times in the Code. It could easily be replaced Globally. Defining it as "Service Lateral, Utility" keeps it within the block of definitions in Art. 100. On the other hand, the definition could simply become "Utility Lateral." This would bring more clarity in that there would be no ambiguity as to the use of the word "service."

Related Item

• 2162-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: Eric Stromberg

Organization: Los Alamos National Laboratory

Affiliation: Self

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 11:28:50 EDT 2018

Committee: NEC-P04

Copyright Assignment

I, Eric Stromberg, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). Iunderstand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Commentand that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Eric Stromberg, and I agree to be legally bound by the above Copyright Assignment andthe terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronicsignature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 850-NFPA 70-2018 [ Section No. 215.2(A) ]

(A) Feeders Not More Than 1000 Volts.

(1) General.

Feeder conductors shall have an ampacity not less than the larger of 215.2(A)(1)(a) or (A)(1)(b) and shallcomply with 110.14(C).

(a) Where a feeder supplies continuous loads or any combination of continuous and noncontinuousloads, the minimum feeder conductor size shall have an ampacity not less than the noncontinuous loadplus 125 percent of the continuous load.

Exception No. 1: If the assembly, including the overcurrent devices protecting the feeder(s), is listedfor operation at 100 percent of its rating, the ampacity of the feeder conductors shall be permitted to benot less than the sum of the continuous load plus the noncontinuous load.

Exception No. 2: Where a portion of a feeder is connected at both its supply and load ends toseparately installed pressure connections as covered in 110.14(C)(2), it shall be permitted to have anampacity not less than the sum of the continuous load plus the noncontinuous load. No portion of afeeder installed under this exception shall extend into an enclosure containing either the feeder supply orthe feeder load terminations, as covered in 110.14(C)(1).

Exception No. 3: Grounded conductors that are not connected to an overcurrent device shall bepermitted to be sized at 100 percent of the continuous and noncontinuous load.

(b) The minimum feeder conductor size shall have an ampacity not less than the maximum load to beserved after the application of any adjustment or correction factors in accordance with 310.14.

Informational Note No. 1: See Examples D1 through D11 in Informative Annex D.

Informational Note No. 2: Conductors for feeders, as defined in Article 100, sized to prevent avoltage drop exceeding 3 percent at the farthest outlet of power, heating, and lighting loads, orcombinations of such loads, and where the maximum total voltage drop on both feeders and branchcircuits to the farthest outlet does not exceed 5 percent, will provide reasonable efficiency ofoperation.

Informational Note No. 3: See 210.19(A), Informational Note No. 4, for voltage drop for branchcircuits.

(2) Grounded Conductor.

The size of the feeder circuit grounded conductor shall not be smaller than that required by 250.122,except that 250.122(E) shall not apply where grounded conductors are run in parallel.

Additional minimum sizes shall be as specified in 215.2(A)(3) under the conditions stipulated.

(3) Ampacity Relative to Service Conductors.

The feeder conductor ampacity shall not be less than that of the service conductors where the feederconductors carry the total load supplied by service conductors with an ampacity of 55 amperes or less.

Additional Proposed Changes

File Name Description Approved

CN_57.pdf 70_CN 57

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 57 in the First Draft Report on First Revision No. 8269.

The Correlating Committee directs that this First Revision be correlated with FR-7981. The reference to 310.14 may be inaccurate.

This action will be considered as a public comment.

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Related Item

• FR 8269

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 11:58:13 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, CC on NEC-AAC, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am CC on NEC-AAC, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 892-NFPA 70-2018 [ Section No. 215.2(A) ]

(A) Feeders Not More Than 1000 Volts.

(1) General.

Feeder conductors shall have an ampacity not less than the larger of 215.2(A)(1)(a) or (A)(1)(b) and shallcomply with 110.14(C).

(a) Where a feeder supplies continuous loads or any combination of continuous and noncontinuousloads, the minimum feeder conductor size shall have an ampacity not less than the noncontinuous loadplus 125 percent of the continuous load.

Exception No. 1: If the assembly, including the overcurrent devices protecting the feeder(s), is listedfor operation at 100 percent of its rating, the ampacity of the feeder conductors shall be permitted to benot less than the sum of the continuous load plus the noncontinuous load.

Exception No. 2: Where a portion of a feeder is connected at both its supply and load ends toseparately installed pressure connections as covered in 110.14(C)(2), it shall be permitted to have anampacity not less than the sum of the continuous load plus the noncontinuous load. No portion of afeeder installed under this exception shall extend into an enclosure containing either the feeder supply orthe feeder load terminations, as covered in 110.14(C)(1).

Exception No. 3: Grounded conductors that are not connected to an overcurrent device shall bepermitted to be sized at 100 percent of the continuous and noncontinuous load.

(b) The minimum feeder conductor size shall have an ampacity not less than the maximum load to beserved after the application of any adjustment or correction factors in accordance with 310.14.

Informational Note No. 1: See Examples D1 through D11 in Informative Annex D.

Informational Note No. 2: Conductors for feeders, as defined in Article 100, sized to prevent avoltage drop exceeding 3 percent at the farthest outlet of power, heating, and lighting loads, orcombinations of such loads, and where the maximum total voltage drop on both feeders and branchcircuits to the farthest outlet does not exceed 5 percent, will provide reasonable efficiency ofoperation.

Informational Note No. 3: See 210.19(A), Informational Note No. 4, for voltage drop for branchcircuits.

(2) Grounded Conductor.

The size of the feeder circuit grounded conductor shall not be smaller than that required by 250.122,except that 250.122(E) shall not apply where grounded conductors are run in parallel.

Additional minimum sizes shall be as specified in 215.2(A)(3) under the conditions stipulated.

(3) Ampacity Relative to Service Conductors.

The feeder conductor ampacity shall not be less than that of the service conductors where the feederconductors carry the total load supplied by service conductors with an ampacity of 55 amperes or less.

Additional Proposed Changes

File Name Description Approved

CN_242.pdf 70_CN 242

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 242 in the First Draft Report on First Revision No. 8114.

The Correlating Committee directs Code-Making Panel 5 to correlate FR 8114 with 250.102(D), 250.104(B), and 250.190(C)(3).

The Correlating Committee directs that FR 8114 be referred to Code-Making Panel 2 for correlation with Annex D

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Example D3(a).

The Correlating Committee directs that FR 8114 be referred to Code-Making Panel 4 for correlation with 690.45.

The Correlating Committee directs that FR 8114 be referred to Code-Making Panel 10 for correlation with 215.2(A)(2)(b)(2) and 215.2(B).

The Correlating Committee directs that FR 8114 be referred to Code-Making Panel 15 for correlation with 525.11.

The Correlating Committee directs that FR 8114 be referred to Code-Making Panel 18 for correlation with 600.7(A)(2).

These actions will be considered as public comments.

The Correlating Committee directs that FR 8114 be sent to all panels for information.

Related Item

• FR 8114

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 15:00:46 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, CC on NEC-AAC, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am CC on NEC-AAC, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Code-Making Panel 10 Second Draft Meeting Agenda October 29 - November 3, 2018

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Public Comment No. 648-NFPA 70-2018 [ Section No. 215.2(A)(1) ]

(1) General.

Feeder conductors shall have an ampacity not less than the larger of 215.2(A)(1)(a) or (A)(1)(b) and shallcomply with 110.14(C).

(a) Where a feeder supplies continuous loads or any combination of continuous and noncontinuousloads, the minimum feeder conductor size shall have an a table ampacity not less than the noncontinuousload plus 125 percent of the continuous load.

Exception No. 1: If the assembly, including the overcurrent devices protecting the feeder(s), is listedfor operation at 100 percent of its rating, the ampacity of the feeder conductors shall be permitted to be notless than the sum of the continuous load plus the noncontinuous load.

Exception No. 2: Where a portion of a feeder is connected at both its supply and load ends toseparately installed pressure connections as covered in 110.14(C)(2), it shall be permitted to have anampacity not less than the sum of the continuous load plus the noncontinuous load. No portion of a feederinstalled under this exception shall extend into an enclosure containing either the feeder supply or thefeeder load terminations, as covered in 110.14(C)(1).

Exception No. 3: Grounded conductors that are not connected to an overcurrent device shall bepermitted to be sized at 100 percent of the continuous and noncontinuous load.

(b) The minimum feeder conductor size shall have an ampacity not less than the maximum load to beserved after the application of any adjustment or correction factors in accordance with 310 . 14.

Informational Note No. 1: See Examples D1 through D11 in Informative Annex D.

Informational Note No. 2: Conductors for feeders, as defined in Article 100, sized to prevent avoltage drop exceeding 3 percent at the farthest outlet of power, heating, and lighting loads, orcombinations of such loads, and where the maximum total voltage drop on both feeders and branchcircuits to the farthest outlet does not exceed 5 percent, will provide reasonable efficiency ofoperation.

Informational Note No. 3: See 210.19(A), Informational Note No. 4, for voltage drop for branchcircuits.

Statement of Problem and Substantiation for Public Comment

The section appears to be requiring that the ampacity found in the ampacity tables be used for rule in (a) and the actual ampacity under the conditions of use for (b). The issue is that the definition of ampacity in Article 100 is under the conditions of use, that is after the application of any required ampacity adjustment and/or correction factors. Using the current wording, if you have an 80 amp continuous load, with those conductors being in a raceway having 8 current carrying conductors and equipment terminations rated at 75°C, the rule in (a) would require a 1 AWG copper THHN conductor (the 90°C ampacity of 145 amps adjusted by a factor of 70%). The rule in (b) would require a 3 AWG copper THHN conductor (again with the 90°C ampacity of 115 amps adjusted by a factor of 70%). I believe that the intent of the rule is to use a conductor directly sized from the ampacity table for the rule in (a) with that size based on a 100% of the non-continuous load plus a 125% of the continuous load, and that in (b) the intent is for the conductor to have an "ampacity" of 80 amps after the application of any adjustment and/or correction factors.

I don't believe that is the intent of the rule. I believe the intent of the rule is to require the conductor to have a "table" ampacity of 100 amps per (a), and a conductor with an ampacity of 80 amps under the conditions of use per (b). There needs to be a way to differentiate between the "ampacity" required in (a) from the one required in (b). This requires the application of some qualifying term to the "ampacity" in (a). This section needs to be coordinated with the definition of ampacity as found in Article 100. It is not currently so coordinated.

Related Item

• First Revision No. 8269-NFPA 70-2018 • Public Comment No. 652-NFPA 70-2018

Submitter Information Verification

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Submitter Full Name: Don Ganiere

Organization: [ Not Specified ]

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 14 14:50:43 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Don Ganiere, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Don Ganiere, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 894-NFPA 70-2018 [ Section No. 215.2(B) ]

(B) Feeders over 1000 Volts.

The ampacity of conductors shall be in accordance with 310.14 and 311.60 as applicable. Where installed,the size of the feeder-circuit grounded conductor shall not be smaller than that required by 250.122,except that 250.122(E) shall not apply where grounded conductors are run in parallel. Feeder conductorsover 1000 volts shall be sized in accordance with 215.2(B)(1), (B)(2), or (B)(3).

(1) Feeders Supplying Transformers.

The ampacity of feeder conductors shall not be less than the sum of the nameplate ratings of thetransformers supplied when only transformers are supplied.

(2) Feeders Supplying Transformers and Utilization Equipment.

The ampacity of feeders supplying a combination of transformers and utilization equipment shall not beless than the sum of the nameplate ratings of the transformers and 125 percent of the designed potentialload of the utilization equipment that will be operated simultaneously.

(3) Supervised Installations.

For supervised installations, feeder conductor sizing shall be permitted to be determined by qualifiedpersons under engineering supervision in accordance with 310.14(B) or 311.60(B). Supervisedinstallations are defined as those portions of a facility where all of the following conditions are met:

(1) Conditions of design and installation are provided under engineering supervision.

(2) Qualified persons with documented training and experience in over 1000-volt systems providemaintenance, monitoring, and servicing of the system.

Additional Proposed Changes

File Name Description Approved

CN_242.pdf 70_CN 242

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 242 in the First Draft Report on First Revision No. 8114.

The Correlating Committee directs Code-Making Panel 5 to correlate FR 8114 with 250.102(D), 250.104(B), and 250.190(C)(3).

The Correlating Committee directs that FR 8114 be referred to Code-Making Panel 2 for correlation with Annex D Example D3(a).

The Correlating Committee directs that FR 8114 be referred to Code-Making Panel 4 for correlation with 690.45.

The Correlating Committee directs that FR 8114 be referred to Code-Making Panel 10 for correlation with 215.2(A)(2)(b)(2) and 215.2(B).

The Correlating Committee directs that FR 8114 be referred to Code-Making Panel 15 for correlation with 525.11.

The Correlating Committee directs that FR 8114 be referred to Code-Making Panel 18 for correlation with 600.7(A)(2).

These actions will be considered as public comments.

The Correlating Committee directs that FR 8114 be sent to all panels for information.

Related Item

• FR 8114

Submitter Information Verification

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Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 15:02:11 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, CC on NEC-AAC, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am CC on NEC-AAC, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Code-Making Panel 10 Second Draft Meeting Agenda October 29 - November 3, 2018

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Public Comment No. 853-NFPA 70-2018 [ Section No. 215.10 ]

215.10 Ground-Fault Protection of Equipment.

Each feeder disconnect rated 1000 amperes or more and installed on solidly grounded wye electricalsystems of more than 150 volts to ground, but not exceeding 600 volts phase-to-phase, shall be providedwith ground-fault protection of equipment in accordance with 230.95.

Informational Note: For buildings that contain health care occupancies, see the requirements of517.17.

Exception No. 1: This section shall not apply to a disconnecting means for a continuous industrialprocess where a nonorderly shutdown will introduce additional or increased hazards.

Exception No. 2: This section shall not apply if ground-fault protection of equipment is provided on thesupply side of the feeder and on the load side of any transformer supplying the feeder.

Exception No. 3: If temporary feeder conductors are used to connect a generator to a facility for repair,maintenance, or emergencies, ground-fault protection of equipment shall not be required. Temporaryfeeders without ground-fault protection shall be permitted for the time period necessary but shall notexceed 90 days.

Additional Proposed Changes

File Name Description Approved

CN_164.pdf 70_CN 164

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 164 in the First Draft Report on First Revision No. 8361.

The Correlating Committee directs that the Informational Note be reviewed for compliance with the NEC Style Manual with regard to mandatory requirements.

This action will be considered as a public comment.

Related Item

• FR 8361

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 12:00:29 EDT 2018

Committee: NEC-P10

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Copyright Assignment

I, CC on NEC-AAC, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am CC on NEC-AAC, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 932-NFPA 70-2018 [ Section No. 215.12(C)(1) ]

(1) Feeders Supplied from More Than One Nominal Voltage System.

Where the premises wiring system has feeders supplied from more than one nominal voltage system, eachungrounded conductor of a feeder shall be identified by phase or line and system at all termination,connection, and splice points in compliance with 215.12(C)(1)(a) and (b).

(a) Means of Identification. The means of identification shall be permitted to be by separate colorcoding, marking tape, tagging, or other approved means.

(b) Posting of Identification Means. The method utilized for conductors originating within each feederpanelboard or similar feeder distribution equipment shall be documented in a manner that is readilyavailable or shall be permanently posted at each feeder panelboard or similar feeder distribution equipment.

Exception: The requirements of 210. 5(C)(1) for posting of identification means for ungrounded conductorsshall not be required at industrial installations where conditions of maintenance and supervision ensurethat only qualified persons service the equipment.

Statement of Problem and Substantiation for Public Comment

This is similar to 110.24 and 392.18 Exception. These environments are most likely to have qualified persons present to service the electric equipment. Note: I prefer 'at' rather than 'in' as we see in 392.18 Exception.

Related Item

• 215.12(C)(1)

Submitter Information Verification

Submitter Full Name: Norman Feck

Organization: State of Colorado

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 16:37:54 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Norman Feck, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Norman Feck, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 124-NFPA 70-2018 [ Section No. 225.3 ]

225.3 Other Articles.

Application of other articles, including additional requirements to specific cases of equipment andconductors, is shown in Table 225.3.

Table 225.3 Other Articles

Equipment/Conductors Article

Branch circuits 210

Class 1, Class 2, and Class 3 remote-control, signaling, and power-limited circuits 725

Communications circuits 800 805

Community antenna television and radio distribution systems 820

Conductors for general wiring 310

Electrically driven or controlled irrigation machines 675

Electric signs and outline lighting 600

Feeders 215

Fire alarm systems 760

Fixed outdoor electric deicing and snow-melting equipment 426

Floating buildings 553

Grounding and bonding 250

Hazardous (classified) locations 500

Hazardous (classified) locations — specific 510

Marinas and boatyards 555

Messenger-supported wiring 396

Mobile homes, manufactured homes, and mobile home parks 550

Open wiring on insulators 398

Over 1000 volts, general 490

Overcurrent protection 240

Radio and television equipment 810

Services 230

Solar photovoltaic systems 690

Swimming pools, fountains, and similar installations 680

Use and identification of grounded conductors 200

Statement of Problem and Substantiation for Public Comment

FR 7512 created a new general article, Article 800, for Chapter 8. The old Article 800 was renumbered to Article 805.

Related Item

• FR 7512

Submitter Information Verification

Submitter Full Name: Terry Peters

Organization: PLASTICS Industry Association

Affiliation: PLASTICS Industry Association

Street Address:

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City:

State:

Zip:

Submittal Date: Sun Jul 01 09:11:29 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Terry Peters, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Terry Peters, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1715-NFPA 70-2018 [ Section No. 225.10 ]

225.10 Wiring on Buildings (or Other Structures).

The installation of outside wiring on surfaces of buildings (or other structures) shall be permitted for circuitsnot exceeding 1000 volts, nominal, as the following:

(1) Auxiliary gutters

(2) Busways

(3) Cable trays

(4) Cablebus

(5) Electrical metallic tubing (EMT)

(6) Flexible metal conduit (FMC)

(7) Intermediate metal conduit (IMC)

(8) Liquidtight flexible metal conduit (LFMC)

(9) Liquidtight flexible nonmetallic conduit (LFNC)

(10) Messenger-supported wiring

(11) Open wiring on insulators

(12) Reinforced thermosetting resin conduit (RTRC)

(13) Rigid metal conduit (RMC)

(14) Rigid polyvinyl chloride conduit (PVC)

(15) Type MC cable

(16) Type MI cable

(17) Type TC cable

(18) Type UF cable

(19) Type SE cable

(20) Wireways

Circuits of over 1000 volts, nominal, shall be installed as provided in 300.37.

Statement of Problem and Substantiation for Public Comment

The change made in the First Revision resulted in the inadvertent omission of Type SE cable, a wiring method that is very commonly used for this application and is suitable for the use.

Related Item

• PI 4284

Submitter Information Verification

Submitter Full Name: Christel Hunter

Organization: Cerro Wire

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 17:35:30 EDT 2018

Committee: NEC-P10

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Copyright Assignment

I, Christel Hunter, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Christel Hunter, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 856-NFPA 70-2018 [ Section No. 225.10 ]

225.10 Wiring on Buildings (or Other Structures).

The installation of outside wiring on surfaces of buildings (or other structures) shall be permitted for circuitsnot exceeding 1000 volts, nominal, as the following:

(1) Auxiliary gutters

(2) Busways

(3) Cable trays

(4) Cablebus

(5) Electrical metallic tubing (EMT)

(6) Flexible metal conduit (FMC)

(7) Intermediate metal conduit (IMC)

(8) Liquidtight flexible metal conduit (LFMC)

(9) Liquidtight flexible nonmetallic conduit (LFNC)

(10) Messenger-supported wiring

(11) Open wiring on insulators

(12) Reinforced thermosetting resin conduit (RTRC)

(13) Rigid metal conduit (RMC)

(14) Rigid polyvinyl chloride conduit (PVC)

(15) Type MC cable

(16) Type MI cable

(17) Type TC cable

(18) Type UF cable

(19) Wireways

Circuits of over 1000 volts, nominal, shall be installed as provided in 300.37.

Additional Proposed Changes

File Name Description Approved

CN_59.pdf 70_CN 59

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 59 in the First Draft Report on First Revision No. 8274.

The Correlating Committee directs that this First Revision be correlated with the actions taken on FR-8457 with regard to section 230.43, list item (20). It is unclear if Type TC, Type TC-ER or both types are permitted to be used for outside feeders and service conductors.

This action will be considered as a public comment.

Related Item

• FR 8274

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

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Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 12:08:19 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, CC on NEC-AAC, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am CC on NEC-AAC, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 863-NFPA 70-2018 [ Section No. 225.21 ]

225.21 Multiconductor Cables on Exterior Surfaces of Buildings (or Other Structures).

Supports for multiconductor cables on exterior surfaces of buildings (or other structures) shall be asprovided in 230.51.

Additional Proposed Changes

File Name Description Approved

CN_60.pdf 70_CN 60

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 60 in the First Draft Report on First Revision No. 8278.

The Correlating Committee directs that this First Revision be reconsidered and correlated with the actions taken on Public Input 1380. CMP-3 did not accept the relocation of this section into Article 300.

This action will be considered as a public comment.

Related Item

• FR 8278

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 13:20:09 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, CC on NEC-AAC, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am CC on NEC-AAC, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1300-NFPA 70-2018 [ Section No. 225.30(A) ]

(A) Special Conditions.

Additional feeders or branch circuits shall be permitted to supply the following:

(1) Fire pumps

(2) Emergency systems

(3) Legally required standby systems

(4) Optional standby systems

(5) Parallel power production systems

(6) Systems designed for connection to multiple sources of supply for the purpose of enhanced reliability

(7) Electric vehicle charging systems listed, labeled, and identified for more than a single branch circuit orfeeder

(8) Docking facilities and piers

(9) Buildings where a single feeder would result in incident energies too large to work on with availablepersonal protective equipment

Statement of Problem and Substantiation for Public Comment

This was PI number 2518. The committee statement was as follows "Additionally, this revision will permit multiple smaller feeders, with smaller conductors and lower rated OCPD's to allow the designer to reduce the level of arc energy."

I don't see this wording, or something similar to it, in the first draft.

Related Item

• 2581-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: Eric Stromberg

Organization: Los Alamos National Laboratory

Affiliation: Self

Street Address:

City:

State:

Zip:

Submittal Date: Sun Aug 26 12:32:16 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Eric Stromberg, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Eric Stromberg, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 380-NFPA 70-2018 [ Section No. 225.30(B) ]

(B) Common Supply Equipment.

Where Up to six sets of feeder conductors shall be permitted to supply a building or structure where theyoriginate in the same panelboard, switchboard, or other distribution equipment, and each feeder terminatesin a single disconnecting means, not more than six feeders shall be permitted . Where more than onefeeder is installed in accordance with this section, all feeder disconnects in the building or structuresupplied shall be grouped in the same location , and the requirements of permitting up to six disconnectsper feeder in 225.33 shall not apply. Each disconnect shall be marked to indicate the load served.

Statement of Problem and Substantiation for Public Comment

My edits are an attempt to make it clear that up to six feeders can be supplied to a building or structure.

Related Item

• FR-8280

Submitter Information Verification

Submitter Full Name: Mike Holt

Organization: Mike Holt Enterprises Inc

Street Address:

City:

State:

Zip:

Submittal Date: Sat Aug 04 12:06:49 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Mike Holt, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Mike Holt, and I agree to be legally bound by the above Copyright Assignment and the terms andconditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon mysubmission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 638-NFPA 70-2018 [ Section No. 225.30(B) ]

(B) Common Supply Equipment.

Where feeder conductors originate in the same panelboard, switchboard, or other distribution equipment,and each feeder terminates in a single disconnecting means, not more than six feeders shall be permitted.Where more than one feeder is installed in accordance with this section, all feeder disconnects in inside oroutside the building or structure supplied structure supplied shall be grouped in the same location , andthe requirements of 225.33 shall not apply. Each disconnect shall be marked to indicate the load served.

Statement of Problem and Substantiation for Public Comment

It is possible to have the feeder disconnects located outside of the building as permitted in 225.32. With this change it is clear that the disconnects must be grouped whether located inside or outside of the building being supplied.

Related Item

• FR 8280

Submitter Information Verification

Submitter Full Name: David Hittinger

Organization: IEC

Affiliation: Independent Electrical Contractors, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 14 12:36:18 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, David Hittinger, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am David Hittinger, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 935-NFPA 70-2018 [ New Section after 225.32 ]

TITLE OF NEW CONTENT

225.32A Marking

Each main disconnecting means shall be permanently marked to identify it as a main disconnect.

Statement of Problem and Substantiation for Public Comment

This is similar to 230.70(B). It is a requirement to label each of the one through six service disconnecting means as a service disconnect. At a detached building or structure, up to six disconnecting means are also allowed for the feeder. Each of these disconnecting means shall be labeled ‘MAIN’ so the user would know that’s what it takes to shut off all power for that detached building or structure.

Related Item

• 225.32A

Submitter Information Verification

Submitter Full Name: Norman Feck

Organization: State of Colorado

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 16:52:17 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Norman Feck, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Norman Feck, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 937-NFPA 70-2018 [ New Section after 225.37 ]

TITLE OF NEW CONTENT

225.37B Identification of Remote Branch Circuits and Feeders

Where the physical location source for a branch circuit or feeder is unclear, while at the load end of abranch circuit or feeder, a permanent label at the load served shall be required stating a physical descriptionof where the source is derived.”

Informational Note: Examples: Motorized gate, premises with multiple outbuildings, pole based luminaire.

Statement of Problem and Substantiation for Public Comment

This new 225.37B code entry is similar to current 408.4B, just the other end of the circuit.

The new 225.37B is a good idea just like 408.4B is a good idea. Once the original electrician leaves the job, service electricians, maintenance personnel, and homeowners, may have a hard time locating the source of a circuit at a remote location.

Related Item

• 225.37B

Submitter Information Verification

Submitter Full Name: Norman Feck

Organization: State of Colorado

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 17:05:38 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Norman Feck, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Norman Feck, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 936-NFPA 70-2018 [ Section No. 225.37 ]

225.37 37(A) Multiple Circuits Identification .

Where a building or structure has any combination of feeders, branch circuits, or services passing through itor supplying it, a permanent plaque or directory shall be installed at each feeder and branch-circuitdisconnect location denoting all other services, feeders, or branch circuits supplying that building orstructure or passing through that building or structure and the area served by each.

Exception No. 1: A plaque or directory shall not be required for large-capacity multibuilding industrialinstallations under single management, where it is ensured that disconnection can be accomplished byestablishing and maintaining safe switching procedures.

Exception No. 2: This identification shall not be required for branch circuits installed from a dwelling unit toa second building or structure.

Statement of Problem and Substantiation for Public Comment

Multiple Circuits Identification is a more accurate title for the existing to remain text.It also makes room for the newly proposed 225.37(B).

Related Item

• 225.37A

Submitter Information Verification

Submitter Full Name: Norman Feck

Organization: State of Colorado

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 17:00:45 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Norman Feck, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Norman Feck, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 404-NFPA 70-2018 [ Section No. 230.2 [Excluding any Sub-

Sections] ]

A building or other structure served shall be supplied by only one service unless permitted in 230.2(A)through (D). For the purpose of E).

(F) Common Supply Equipment. Where service conductors supply two to six service disconnects aspermitted in 230.40, Exception No. 2 only , underground sets of conductors, 1/0 AWG and larger, running tothe same location and connected together at their supply end but not connected together at their load endshall be considered to be supplying one service permitted .

Statement of Problem and Substantiation for Public Comment

Relocate some text from 230.2(A) to a new 230.2(F) so that it's easier to apply this requirement and easier to find and apply, and to comply with the similar new requirements of 225.30(B).

Related Item

• PI-2517

Submitter Information Verification

Submitter Full Name: Mike Holt

Organization: Mike Holt Enterprises Inc

Street Address:

City:

State:

Zip:

Submittal Date: Sun Aug 05 07:48:56 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Mike Holt, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Mike Holt, and I agree to be legally bound by the above Copyright Assignment and the terms andconditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon mysubmission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 864-NFPA 70-2018 [ Section No. 230.10 ]

230.10 Vegetation as Support.

Vegetation such as trees shall not be used for support of overhead service conductors or serviceequipment.

Additional Proposed Changes

File Name Description Approved

CN_62.pdf 70_CN 62

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 62 in the First Draft Report on First Revision No. 8454.

The Correlating Committee directs that this First Revision be reviewed and correlated with FR-8624. The term “Taps” has been deleted in FR-8624.

This action will be considered as a public comment.

Related Item

• FR 8454

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 13:23:20 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, CC on NEC-AAC, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am CC on NEC-AAC, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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������������������������������� �!"��� �!�������#��$%&'�(���'�%�����)��&�����)%����&���� ���

*+,,-./0123 *+44100-- 5+0- 5+6 7895:;< =>98>?@ A 5-B C-D01+2 /E0-, 8F>6?> GCHI4100-, J2E+,4/01+2 K-,1E1D/01+2CHI4100-, :H.. 5/4-LM���� N��%!���*+44100--LCHI4100/. O/0-L "�% P�Q �R �'��S�T� UV� ����*+44100-- C0/0-4-20 /2W X--0123 5+0-Y*+44100--C0/0-4-20L ��� N�������� N������ %����� ���� ��� ���� ��Z�� �� ��Z�!�% ��% ��������% !����(�[�S� ��� ���� \����] ��� ���� %�����% � ��(�[�S� ��� ���� !�� �� ���%���% �� � ����� ������� ���� ��Z�� �� �STS(���� '�(���� ��! M���� ����� �_����a/..+0 b-YH.0Y cd1Y 10-4 d/Y e/YY-W I/..+0�� U����� ����� �� �������%�� �������Z� ���� �������Z� !�� N������� �����Z� !�� N������� ��������<EE1,4/01f- <..g�������h i���� U�V�������h j�Z� k�l�m���h ������ k�l������h V�Z% k�l���h �����% ��i�����h P����� i�jZ��mh i�� ��P�����h ����P�V����h ���� V������h i���� ��M�����h ����� i�"�����h V�Z% ��Code-Making Panel 10 Second Draft Meeting Agenda

October 29 - November 3, 2018 Page 77 of 266

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Public Comment No. 191-NFPA 70-2018 [ Section No. 230.11 ]

230.11 Splices and Taps.

Splices and taps shall be permitted. Power distribution blocks, pressure connectors, and devices forsplices and taps shall be listed. Power distribution blocks, pressure connectors, and devices for splices andtaps, installed on service conductors, shall be marked “suitable for use on the line side of the serviceequipment” or equivalent.

Statement of Problem and Substantiation for Public Comment

This requirement should be located in the existing Section 230.46. A public comment to revise that Section is also submitted (PC No. 192) which relocates and revises the requirements included in this new Section.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 192-NFPA 70-2018 [Section No.230.46]

Relocate requirements from 230.11 to230.46.

Public Comment No. 192-NFPA 70-2018 [Section No.230.46]

Related Item

• FR 8454

Submitter Information Verification

Submitter Full Name: Robert Osborne

Organization: UL LLC

Street Address:

City:

State:

Zip:

Submittal Date: Tue Jul 10 10:46:49 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Robert Osborne, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Robert Osborne, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 381-NFPA 70-2018 [ Section No. 230.11 ]

230.11 Splices and Taps.

Splices and taps Service conductors shall be permitted to be spliced and tapped . Power distributionblocks, pressure connectors, and devices for splices and taps shall be listed. Power distribution blocks,pressure connectors, and devices for splices and taps, installed on service conductors , shall be marked“suitable for use on the line side of the service equipment” or equivalent.

Statement of Problem and Substantiation for Public Comment

My revisions is to make it clear that we are only addressing service conductors (scope of Article 230). There for no need to have one sentence about lising, then another about listing for service conductors, when this rule only address service conductors.

Related Item

• FR-8454

Submitter Information Verification

Submitter Full Name: Mike Holt

Organization: Mike Holt Enterprises Inc

Street Address:

City:

State:

Zip:

Submittal Date: Sat Aug 04 12:16:27 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Mike Holt, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Mike Holt, and I agree to be legally bound by the above Copyright Assignment and the terms andconditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon mysubmission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1369-NFPA 70-2018 [ Section No. 230.23 ]

230.23 Size and Rating Ampacity .

(A) General.

Conductors shall have sufficient ampacity to carry the current for the load as calculated in accordance withArticle 220 and shall have adequate mechanical strength.

(B) Minimum Size.

The conductors shall not be smaller than 8 AWG copper

or

or 6 AWG aluminum

or

or copper-

clad

clad Aluminum or 6 AWG aluminum .

Exception:

Conductors

Conductors supplying only limited loads of a single branch circuit — such as small polyphase power,controlled water heaters, and similar loads — shall not be smaller than 12 AWG hard-drawn copper ,copper-clad aluminum or equivalent.

(C) Grounded Conductors.

The grounded conductor shall not be less than the minimum size as required

by 250

by 250 .24(

A

C )

(1)

.

Additional Proposed Changes

File Name Description Approved

Notice_of_Authorization-2017-10-06-4788086098.pdf

UL Listing Notification for 12 - 2 AWG NM Cables. 8 AWG CCA Is Used Every Day in Branch Circuits

Prop_Table_310.16_310.15_B_16_.pdfProposed Table 310.16: 8 AWG CCA is already permitted for Use in Current 310.15(B)16 Table

UL_Spec_NM_Allows_8_AWG_Cu-Clad.JPGUL Standard Permitting 8 AWG Copper Clad Aluminum for Use In NM Cable

Statement of Problem and Substantiation for Public Comment

PUBLIC COMMENT RESPONSE:• The Diameter of Copper-Clad Aluminum Wire (the metallic conductive component of a conductor) works as part of a system where the wire insulation has the greatest influence over product safety. 8 AWG copper-clad aluminum is already "listed" and currently safely used with insulation types THHN/THWN, THW, XHHW, and cable types SE, SER, among other types of conductors. Further, 8 AWG CCA is 2.7 times lighter than single-metal copper 8 AWG, making CCA well suited for aerial applications. There’s no technical reason that copper-clad aluminum can’t be safely used in service conductors in 8 AWG size, provided that the insulation and termination methods are applied in conformance to the NEC for the application. This Code provides for both. For example, in the form of THHN, 8 AWG Copper Clad Aluminum is used on a daily basis with residential water heaters, AC's and

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clothes dryers. Given the proper insulation, there's no reason that it could not be used as a feeder.There could be a good technical reason to limit the size of single-metal aluminum to 6 AWG, but to limit Copper Clad Aluminum without technical substantiation denies industry a valid product.

From the 2017 NEC, 310.15(B)(16), 8 AWG copper-clad aluminum has an ampacity of 35 Amps at 60C and 40 Amps at 75C. Where terminals at both ends are suitable for 60C, the use of 8 AWG copper-clad aluminum would be suitable for a 35 Amp service. Where terminals at both ends are suitable for 75C, which is common on service equipment, the use of 8 AWG copper-clad aluminum would be suitable for a 40 Amp service the same as 8 AWG copper.• Rather than Wire Size, The Insulation Type and The Temperature Rating Columns of 310.15(B)16 are Relevant to SERVICE conductors. The ampacity of a conductor is a function of the type of insulation of the conductor and the temperature column in 310.15(B)16 for a specific application. Modern insulation can manage higher heat more safely than the types of insulation applied by the industry when 8 AWG was first conceived as the minimum size for service. Insulation is designed to safely manage the heat generated by conduction, each insulation with its own rating. “Ratings” have little to do with wire diameter. If 8 AWG is the smallest size that the CMP believes to be safe for a service, it should pertain to each metal allowed in the Code. The insulation type should be regulated rather than the size of the wire. If the exception permits 12 AWG single-metal copper for limited loads, it should permit ASTM B566 copper-clad aluminum and AA 8000 series Al wire as well, as all three metals with the adequate insulation and temperature rating have been already proven Code worthy. • Mechanical Strength and Elongation. When meeting “listing” requirements for an electrical conductor in terms of mechanical strength, copper-clad aluminum as a material is held to the same standard as single-metal ETP copper. All copper-clad aluminum conductors are UL Listed that meet the same mechanical and elongation requirements. • Conductor Metals Permitted for Service: Copper conductors are grade ETP. Aluminum is grade AA 8000. copper-clad aluminum Wire is ASTM B566. ASTM B566 is neither Aluminum nor Copper, but is classified in metallurgical terms as a single metal. ASTM B566 bimetal is composed of 27% O2 Free Copper (10% cross-sectional area of the surface), and 73% AA 8000 series aluminum (the core). Due to the metallurgical bond within ASTM B566, the less noble component of the bimetal (8000 Aluminum) is not sacrificial to the more-noble component (0₂ Free Copper). The corrosion resistance of ASTM B566 is equivalent to single-metal copper, if not more so due to the high purity of 0₂ Free Copper residing at its surface.

Related Item

• 2113

Submitter Information Verification

Submitter Full Name: Peter Graser

Organization: Copperweld

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 27 14:44:23 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Peter Graser, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Peter Graser, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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NOTICE OF COMPLETION AND

AUTHORIZATION TO APPLY THE UL MARK

This is an electronically generated letter. Signatures are not required for this document to be valid. Page 1 of 1

2017.10.06 Peter Graser Copperweld Bimetallics LLC 254 Cotton Mill Rd Fayetteville, TN, 37334, US Our Reference: File E492024, Vol 1 Order:

Project: 11882073 4788086098

Your Reference: Peter Graser 7/24/2017 Project Scope: Testing to add NM-B wire to NEW Copperweld Nonmetallic Sheathed-Cable File

Construction will employ recognized CCA, and Listed Type THHN & PVC jacket Dear Peter Graser: Congratulations! UL's investigation of your product(s) has been completed under the above Reference Number and the product was determined to comply with the applicable requirements. This letter temporarily supplements the UL Follow-Up Services Procedure and serves as authorization to apply the UL Mark at authorized factories under UL's Follow-Up Service Program. To provide your manufacturer(s) with the intended authorization to use the UL Mark, you must send a copy of this notice to each manufacturing location currently authorized under File e492024, Vol 1. Records in the Follow-Up Services Procedure covering the product are now being prepared and will be sent in the near future. Until then, this letter authorizes application of the UL Mark for 90 days from the date indicated above. Additional requirements related to your responsibilities as the Applicant can be found in the document “Applicant responsibilities related to Early Authorizations” that can be found at the following web-site: http://www.ul.com/EAResponsibilities Any information and documentation provided to you involving UL Mark services are provided on behalf of UL LLC (UL) or any authorized licensee of UL. We are excited you are now able to apply the UL Mark to your products and appreciate your business. Feel free to contact me or any of our Customer Service representatives if you have any questions. Very truly yours, Reviewed by: Brian Cavalli Bruce A. Mahrenholz Engineering Associate CPO Director [email protected] [email protected] d1ee6431-b01c-4fdc-ac75-c9d5fae7e357

Code-Making Panel 10 Second Draft Meeting Agenda October 29 - November 3, 2018

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Public Comment No. 1339-NFPA 70-2018 [ Section No. 230.30(B) ]

(B) Wiring Methods.

Underground service conductors shall be installed in accordance with the applicable requirements of thisCode covering the type of wiring method used and shall be limited to the following methods:

(1) Type RMC conduit

(2) Type IMC conduit

(3) Type NUCC conduit

(4) Type HDPE conduit

(5) Type PVC conduit

(6) Type RTRC conduit

(7) Type IGS cable

(8) Type USE conductors or cables

(9) Type MV or Type MC cable identified for direct burial applications

(10) Type MI cable, where suitably protected against physical damage and corrosive conditions

(11) Type EMT

Statement of Problem and Substantiation for Public Comment

PI 2739 should be accepted. Comments were made by CMP-10 that EMT is not allowed to be used in direct burial applications but there are several places in the NEC that allow its use below grade including in 358.10(A)(1) and 358.10(A)(2) (See definition of Location, Wet). Also ULs product spec allows the use of EMT in direct contact with soil.There was also a question on how deep to bury EMT. Column 3 of Table 300.5 specifies the burial depth for “Other Approved Raceways” which includes EMT.

Related Item

• PI 2739

Submitter Information Verification

Submitter Full Name: Vince Baclawski

Organization: Nema

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 27 11:21:13 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Vince Baclawski, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Vince Baclawski, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1894-NFPA 70-2018 [ Section No. 230.30(B) ]

(B) Wiring Methods.

Underground service conductors shall be installed in accordance with the applicable requirements of thisCode covering the type of wiring method used and shall be limited to the following methods:

(1) Type RMC conduit

(2) Type IMC conduit

(3) Type NUCC conduit

(4) Type HDPE conduit

(5) Type PVC conduit

(6) Type RTRC conduit

(7) Type IGS cable

(8) Type USE conductors or cables

(9) Type MV or Type MC cable identified for direct burial applications

(10) Type MI cable, where suitably protected against physical damage and corrosive conditions

(11) Type TC-ER cable identified for direct burial applications and identified for pulling through structuralmembers

Statement of Problem and Substantiation for Public Comment

Greetings Code Panel Members,

Type TC uses inner conductors that are permitted for use in other underground raceways or type MC. The type TC cable that is rated for direct burial is subject to the same crush and impact testing under UL 1277 as type MC cable is under 1569 as referenced in UL 1277. There is no physical difference in the inner conductors and since type TC is available rated for direct burial it should be permitted for use.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 1887-NFPA 70-2018[Section No. 336.10]

None Directly - This simply relates to important facts aboutthe inner conductors

Public Comment No. 1888-NFPA 70-2018[Section No. 336.10]

None Directly - This simply relates to important facts aboutthe inner conductors

Related Item

• PI 200 • PI 210 • PI 220

Submitter Information Verification

Submitter Full Name: Paul Abernathy

Organization: Encore Wire Corporation

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 11:28:32 EDT 2018

Committee: NEC-P10

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Copyright Assignment

I, Paul Abernathy, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Paul Abernathy, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1374-NFPA 70-2018 [ Section No. 230.31(B) ]

230.31 Size and Rating Ampacity

(B) Minimum Size.

The conductors shall not be smaller than 8 AWG copper

or

or 6 AWG aluminum

or

or copper-clad aluminum and 6 AWG aluminum .

Exception:

Conductors

Conductors supplying only limited loads of a single branch circuit — such as small polyphase power,controlled water heaters, and similar loads — shall not be smaller than 12 AWG copper

or

or 10 AWG aluminum or copper-clad aluminum and 10 AWG aluminum .

Additional Proposed Changes

File Name Description Approved

Notice_of_Authorization-2017-10-06-4788086098.pdf

UL Listing Notification for Copper Clad Aluminum NM Cable, Which includes 8 AWG Diameter Products

Prop_Table_310.16_310.15_B_16_.pdfProposed Amp Table 310.16: Note that Current 2017 310 tables permit 8 AWG CCA for use with insulation for Feeders

UL_Spec_NM_Allows_8_AWG_Cu-Clad.JPG

UL Standard for Cu-Clad NM Permits 8 AWG

Statement of Problem and Substantiation for Public Comment

PUBLIC COMMENT RESPONSE:• The Diameter of Copper-Clad Aluminum Wire (the metallic conductive component of a conductor) works as part of a system where the wire "insulation" has the greatest influence over product safety. 8 AWG copper-clad aluminum is already "listed" and currently safely used with insulation types THHN/THWN, THW, XHHW, and cable types SE, SER, among other types of conductors. Further, 8 AWG CCA is 2.7 times lighter than single-metal copper 8 AWG, making CCA conductors easier to carry and install by hand in service applications. There’s no technical reason that copper-clad aluminum can’t be safely used in service conductors in 8 AWG size, provided that the insulation and termination methods are applied in conformance to the NEC for the application. This Code provides for both. For example, in the form of THHN, 8 AWG Copper Clad Aluminum is used on a daily basis with residential water heaters, AC's and clothes dryers. IN these applications, both the insulation as well as the terminals are rated appropriately. Given the proper insulation and terminals, there's no reason that it could not be used in service. There might be a valid technical reason to limit the size of single-metal aluminum to size 6 AWG, but to limit the size of Copper Clad Aluminum without technical substantiation denies industry a valid product which is currently being employed.

From the 2017 NEC, 310.15(B)(16), 8 AWG copper-clad aluminum has an ampacity of 35 Amps at 60C and 40 Amps at 75C. Where terminals at both ends are suitable for 60C, the use of 8 AWG copper-clad aluminum would be suitable for a 35 Amp service. Where terminals at both ends are suitable for 75C, which is common on service equipment, the use of 8 AWG copper-clad aluminum would be suitable for a 40 Amp service the same as 8 AWG copper• Rather than Wire Size, The Insulation Type and The Temperature Rating Columns of 310.15(B)16 are Relevant to SERVICE conductors. The ampacity of a conductor is a function of the type of insulation of the conductor and the temperature column in 310.15(B)16 for a specific application. Insulation is designed to safely

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manage the heat generated by conduction, each insulation with its own rating. “Ratings” have little to do with wire diameter. If 8 AWG is the smallest size that the CMP believes to be safe for a service, it should pertain to each metal allowed in the Code. The insulation type should be regulated rather than the size of the wire. If the exception permits 12 AWG single-metal copper for limited loads, it should permit ASTM B566 copper-clad aluminum and AA 8000 series Al wire as well, as all three metals with the adequate insulation and temperature rating have been already proven Code worthy. • Mechanical Strength and Elongation. When meeting “listing” requirements for an electrical conductor in terms of mechanical strength, copper-clad aluminum as a material is held to the same standard as single-metal ETP copper. All copper-clad aluminum conductors are UL Listed that meet the same mechanical and elongation requirements. • Conductor Metals Permitted for Service: Copper conductors are grade ETP. Aluminum is grade AA 8000. copper-clad aluminum Wire is ASTM B566. ASTM B566 is neither Aluminum nor Copper, but is classified in metallurgical terms as a single metal. ASTM B566 bimetal is composed of 27% O2 Free Copper (10% cross-sectional area of the surface), and 73% AA 8000 series aluminum (the core). Due to the metallurgical bond within ASTM B566, the less noble component of the bimetal (8000 Aluminum) is not sacrificial to the more-noble component (0₂ Free Copper). The corrosion resistance of ASTM B566 is equivalent to single-metal copper, if not more so due to the high purity of 0₂ Free Copper residing at its surface.

Related Item

• 2120

Submitter Information Verification

Submitter Full Name: Peter Graser

Organization: Copperweld

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 27 14:58:20 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Peter Graser, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Peter Graser, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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NOTICE OF COMPLETION AND

AUTHORIZATION TO APPLY THE UL MARK

This is an electronically generated letter. Signatures are not required for this document to be valid. Page 1 of 1

2017.10.06 Peter Graser Copperweld Bimetallics LLC 254 Cotton Mill Rd Fayetteville, TN, 37334, US Our Reference: File E492024, Vol 1 Order:

Project: 11882073 4788086098

Your Reference: Peter Graser 7/24/2017 Project Scope: Testing to add NM-B wire to NEW Copperweld Nonmetallic Sheathed-Cable File

Construction will employ recognized CCA, and Listed Type THHN & PVC jacket Dear Peter Graser: Congratulations! UL's investigation of your product(s) has been completed under the above Reference Number and the product was determined to comply with the applicable requirements. This letter temporarily supplements the UL Follow-Up Services Procedure and serves as authorization to apply the UL Mark at authorized factories under UL's Follow-Up Service Program. To provide your manufacturer(s) with the intended authorization to use the UL Mark, you must send a copy of this notice to each manufacturing location currently authorized under File e492024, Vol 1. Records in the Follow-Up Services Procedure covering the product are now being prepared and will be sent in the near future. Until then, this letter authorizes application of the UL Mark for 90 days from the date indicated above. Additional requirements related to your responsibilities as the Applicant can be found in the document “Applicant responsibilities related to Early Authorizations” that can be found at the following web-site: http://www.ul.com/EAResponsibilities Any information and documentation provided to you involving UL Mark services are provided on behalf of UL LLC (UL) or any authorized licensee of UL. We are excited you are now able to apply the UL Mark to your products and appreciate your business. Feel free to contact me or any of our Customer Service representatives if you have any questions. Very truly yours, Reviewed by: Brian Cavalli Bruce A. Mahrenholz Engineering Associate CPO Director [email protected] [email protected] d1ee6431-b01c-4fdc-ac75-c9d5fae7e357

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Public Comment No. 865-NFPA 70-2018 [ Section No. 230.42 ]

230.42 Minimum Size and Ampacity.

(A) General.

Service-entrance conductors shall have an ampacity of not less than the maximum load to be served.Conductors shall be sized not less than the largest of 230.42(A)(1)or (A)(2). Loads shall be determined inaccordance with Part III, IV, or V of Article 220, as applicable. Ampacity shall be determined from 310.14and shall comply with 110.14(C). The maximum current of busways shall be that value for which thebusway has been listed or labeled.

Informational Note: For information on busways, see UL 857, Standard for Safety for Busways.

(1) Where the service-entrance conductors supply continuous loads or any combination of noncontinuousand continuous loads, the minimum service-entrance conductor size shall have an ampacity not lessthan the sum of the noncontinuous loads plus 125 percent of continuous loads.

Exception No. 1: Grounded conductors that are not connected to an overcurrent device shall bepermitted to be sized at 100 percent of the sum of the continuous and noncontinuous load.

Exception No. 2: The sum of the noncontinuous load and the continuous load if the service-entranceconductors terminate in an overcurrent device where both the overcurrent device and its assemblyare listed for operation at 100 percent of their rating shall be permitted.

(2) The minimum service-entrance conductor size shall have an ampacity not less than the maximumload to be served after the application of any adjustment or correction factors.

(B) Specific Installations.

In addition to the requirements of 230.42(A), the minimum ampacity for ungrounded conductors for specificinstallations shall not be less than the rating of the service disconnecting means specified in 230.79(A)through (D).

(C) Grounded Conductors.

The grounded conductor shall not be smaller than the minimum size as required by 250.24(A)(1).

Additional Proposed Changes

File Name Description Approved

CN_63.pdf 70_CN 63

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 63 in the First Draft Report on First Revision No. 8456.

The Correlating Committee directs that this First Revision be correlated with FR-8269 (215.2) and FR-7981 (210.19). The changes made in the first sentence of FR-8269 may be necessary here for parallel structure.

This action will be considered as a public comment.

Related Item

• FR 8456

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

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Zip:

Submittal Date: Mon Aug 20 13:26:46 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, CC on NEC-AAC, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am CC on NEC-AAC, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1484-NFPA 70-2018 [ Section No. 230.42(A) ]

(A) General.

Service-entrance conductors shall have an ampacity of not less than the maximum load to be served.Conductors shall be sized not less than the largest of 230.42(A)(1)or (A)(2). Loads shall be determined inaccordance with Part III, IV, or V of Article 220, as applicable. Ampacity shall be determined from 310.14and shall comply with 110.14(C ). The maximum current of busways shall be that value for which thebusway has been listed or labeled.

Informational Note: For information on busways, see UL 857, Standard for Safety for Busways.

(1) Where the service-entrance conductors supply continuous loads or any combination of noncontinuousand continuous loads, the minimum service-entrance conductor size shall have an ampacity not lessthan the sum of the noncontinuous loads plus 125 percent of continuous loads.

Exception No. 1: Grounded conductors that are not connected to an overcurrent device shall bepermitted to be sized at 100 percent of the sum of the continuous and noncontinuous load.

Exception No. 2: The sum of the noncontinuous load and the continuous load if the service-entranceconductors terminate in an overcurrent device where both the overcurrent device and its assemblyare listed for operation at 100 percent of their rating shall be permitted.

(2) The minimum service-entrance conductor size shall have an ampacity not less than the maximum loadto be served after the application of any adjustment or correction factors.

Statement of Problem and Substantiation for Public Comment

This added language is unnecessary all installations are required to comply with 110.14(C)

Related Item

• FR8456

Submitter Information Verification

Submitter Full Name: James Rogers

Organization: Towns Of Oak Bluffs, Tisbury,

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 21:51:42 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, James Rogers, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am James Rogers, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1337-NFPA 70-2018 [ Section No. 230.43 ]

230.43 Wiring Methods for 1000 Volts, Nominal, or Less.

Service-entrance conductors shall be installed in accordance with the applicable requirements of this Codecovering the type of wiring method used and shall be limited to the following methods:

(1) Open wiring on insulators

(2) Type IGS cable

(3) Rigid metal conduit (RMC)

(4) Intermediate metal conduit (IMC)

(5) Electrical metallic tubing (EMT)

(6) Electrical nonmetallic tubing

(7) Service-entrance cables

(8) Wireways

(9) Busways

(10) Auxiliary gutters

(11) Rigid polyvinyl chloride conduit (PVC)

(12) Cablebus

(13) Type MC cable

(14) Mineral-insulated, metal-sheathed cable, Type MI

(15) Flexible metal conduit (FMC) not over 1.8 m (6 ft) long or liquidtight flexible metal conduit (LFMC) notover 1.8 m (6 ft) long between a raceway, or between a raceway and service equipment, with asupply-side bonding jumper routed with the flexible metal conduit (FMC) or the liquidtight flexible metalconduit (LFMC) according to 250.102(A) , (B), (C), and (E)

(16) Liquidtight flexible nonmetallic conduit (LFNC)

(17) High density polyethylene conduit (HDPE)

(18) Nonmetallic underground conduit with conductors (NUCC)

(19) Reinforced thermosetting resin conduit (RTRC)

(20) Type TC-ER cable

Statement of Problem and Substantiation for Public Comment

The charging language in 230.43 already requires and states that; “Service-entrance conductors shall be installed in accordance with the applicable requirements of this Code covering the type of wiring method used…”. Section 250.118(5) and (6) covers the applicable requirements where FMC and LFMC are used as an equipment grounding conductor. Inclusion of the 6 ft. grounding requirements for FMC and LFMC in 230.43 is incomplete and misleading. 230.43(15) should list only FMC and LFMC similar to the other wiring methods listed in this this section.

Related Item

• PI 2702

Submitter Information Verification

Submitter Full Name: Vince Baclawski

Organization: Nema

Street Address:

City:

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State:

Zip:

Submittal Date: Mon Aug 27 11:16:59 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Vince Baclawski, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Vince Baclawski, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 192-NFPA 70-2018 [ Section No. 230.46 ]

230.46 Spliced and Tapped Conductors.

Service-entrance conductors shall be permitted to be spliced or tapped in accordance with 110.14,300.5(E), 300.13, and 300.15. Power distribution blocks, pressure connectors, and devices for splices andtaps shall be listed. Power distribution blocks installed on service conductors shall be marked "suitable foruse on the line side of the service equipment" or equivalent.

Statement of Problem and Substantiation for Public Comment

This Public Comment would relocate verbiage added in a new Section 230.11 (FR 8454) to this existing Section. This Public Comment would also make changes to the requirements in FR 8454, as described below:

This First Revision went beyond relocating “Service Requirements” for power distribution blocks and pressure connectors to also requiring both types of devices be rated “suitable for use on the line side of the service equipment”. In the case of power distribution blocks, this designation is based on the application of a Short Circuit Current Rating without the benefit of an upstream overcurrent protective device. This is consistent with 2017 Code language in 314.28(E)(1) and 376.56(B)(1), and consistent with the listing of Power Distribution Blocks, which may be evaluated and marked as being “suitable for use on the line side of the service equipment”. Wire connectors are not, by themselves, listed as being “suitable for use on the line side of the service disconnect”, although a connector may be part of a listed assembly (such as a panelboard) that is rated for “service equipment”. A connector that isn’t part of equipment, such as an insulated splicing wire connector, is used to join conductors of the same polarity or phase. The connectors are insulated to provide dielectric protection for the voltage rating of the connector from short circuiting to another uninsulated conductor or grounded metal. The connectors are not permanently affixed to the enclosure. Instead, they are floating free inside the enclosure, supported by the wires connected to them. As such, these connectors move with any force they may be subjected to, including those experienced under a short circuit condition, so that a conductor is not likely to pull out of the connector. Power distribution blocks are intended to be permanently fixed within an enclosure and may be used to terminate conductors of opposite polarity or phase and ground (similar to a wire connector that is an integral part of a panelboard). They utilize terminals that rely on through air and over surface spacings to maintain the proper distances between conductors based on the voltage rating of the power distribution block. These spacings are intended to prevent arcing and short circuiting between connectors of different voltage potentials. Because power distribution blocks are not free floating in the enclosure, they must have the ability to withstand opposing forces so that conductors do not pull out of the terminals and potentially short circuit to each other or to ground during a short-circuit condition. Power distribution blocks marked as “suitable for use on the line side of the service equipment” are evaluated without an overcurrent protective device and are subjected to the short circuit current for a duration of no less than three electrical cycles.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 191-NFPA 70-2018 [Section No.230.11]

Relocate reqruirements from 230.11 to230.46.

Public Comment No. 191-NFPA 70-2018 [Section No.230.11]

Related Item

• FR 8454

Submitter Information Verification

Submitter Full Name: Robert Osborne

Organization: UL LLC

Street Address:

City:

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State:

Zip:

Submittal Date: Tue Jul 10 10:51:00 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Robert Osborne, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Robert Osborne, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1113-NFPA 70-2018 [ Section No. 230.62(C) ]

(C) Barriers.

Barriers shall be placed in service equipment such that no uninsulated, ungrounded service busbar orservice terminal is exposed to inadvertent contact by persons or maintenance equipment while servicingload terminations.

Exception: This requirement shall not apply to service panelboards with provisions for more than oneservice disconnect within a single enclosure as permitted in 408.36, Exceptions 1, 2, and 3.

Statement of Problem and Substantiation for Public Comment

This public comment seeks correlation with the actions taken in 230.71 through FR 8463, Correlating Committee Note 268 and the related CC public comment to 408.36 for correlation. Due to the actions in FR 8463 on 230.71 exceptions No. 1 and 2 must be deleted in 408.36.

Additionally, none of the exceptions in 408.36 apply due to the actions of FR 8463.

Correlating Committee Note 268 directs CMP-9 as follows:"The Correlating Committee directs the panel to correlate 408.36 exception no. 1 with the action taken in 230.71 by FR 8463. This action will be considered as a public comment."

Related Item

• FR 8463 • CCN 268

Submitter Information Verification

Submitter Full Name: James Dollard

Organization: IBEW Local Union 98

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 23 08:38:14 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, James Dollard, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am James Dollard, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 2175-NFPA 70-2018 [ Section No. 230.66(B) ]

(B) Meter Sockets.

Meter sockets shall not be considered service equipment but shall be listed and rated for the voltage andampacity current rating of the service.

Exception: Meter sockets supplied by and under the exclusive control of an electric utility shall not berequired to be listed.

Statement of Problem and Substantiation for Public Comment

Ampacity only applies to conductors, equipment is classified by current rating.

Related Item

• FR 8460

Submitter Information Verification

Submitter Full Name: Christel Hunter

Organization: Cerro Wire

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 21:50:42 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Christel Hunter, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Christel Hunter, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1029-NFPA 70-2018 [ Section No. 230.67 ]

230.67 Surge Protection.

(A) Surge Protective Device.

All services in dwelling units shall be provided with a surge protective device (SPD).

(B) Location.

The surge protective device shall be an integral part of the service equipment or shall be locatedimmediately adjacent thereto.

Exception: The surge protective device shall not be required to be located in the service equipment asrequired in (B) if located at each next level distribution equipment downstream toward the load.

(C) Type.

The surge protective device shall be a Type 1 or Type 2 SPD.

(D) Replacement.

Where service equipment is replaced, all of the requirements of this section shall apply.

(E) Multi-family dwelling units .

In addition to the SPD required in 230.67(A), an additional listed Type 2 SPD shall be installed in eachnext level dwelling unit distribution equipment downstream of the service equipment.

Exception: Where the service disconnects for the multi-family dwelling units are installed in accordancewith 230.72(A) and the SPD for each multi-family dwelling unit is located in the dwelling unit serviceequipment, the provisions in 230.67(F) shall not apply.

Statement of Problem and Substantiation for Public Comment

This proposed revision is intended to address the recognized need for surge protection to protect the sensitive electronics and systems found in most premise wiring systems, as the hazards from power surges are not limited to dwelling units. The proposed addition of (E) addresses the need for additional SPD protection for the sensitive electronics and systems found in most modern appliances, safety devices (such as AFCI, GFCI and smoke alarms) and equipment used in multi-family dwelling units. The proposed exception would provide a condition of relief where up to 6 disconnects are installed to serve as the service disconnecting means in place of a single disconnect for 3-6 multifamily condo/apartment units.

Related Item

• First Revision No. 8546-NFPA 70-2018 [ New Section after 230.66 ]

Submitter Information Verification

Submitter Full Name: Brian Baughman

Organization: Generac Power Systems Inc

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 22 08:26:06 EDT 2018

Committee: NEC-P10

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Copyright Assignment

I, Brian Baughman, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Brian Baughman, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1199-NFPA 70-2018 [ Section No. 230.67 ]

230.67 Surge Protection.

(A) Surge Protective Device.

All services in dwelling units shall be provided with a surge protective device (SPD).

(B) Location.

The surge protective device shall be an integral part of the service equipment or shall be locatedimmediately adjacent thereto.

Exception: The surge protective device shall not be required to be located in the service equipment asrequired in (B) if located at each next level distribution equipment downstream toward the load.

(C) Type.

The surge protective device shall be a Type 1 or Type 2 SPD.

(D) Replacement.

Where service equipment is replaced, all of the requirements of this section shall apply.

Statement of Problem and Substantiation for Public Comment

There was insufficient data provided with the PI to justify this new section. There should be a cost-benefit analysis prior to requiring SPDs for all residential services.

Related Item

• FR-8546

Submitter Information Verification

Submitter Full Name: Roy Sparks

Organization: Eli Lilly and Company

Affiliation: ACC

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 11:40:56 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Roy Sparks, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Roy Sparks, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 25-NFPA 70-2018 [ Section No. 230.67 ]

230.67 Surge Protection.

(A) Surge Protective Device.

All services in dwelling units shall be provided with a surge protective device (SPD).

(B) Location.

The surge protective device shall be an integral part of the service equipment or shall be locatedimmediately adjacent thereto.

SPDs at grounded service entrances shall be wired between all line-to-ground (L-G) or line-to-neutral (L-N) conductors.

Exception: The surge protective device shall not be required to be located in the service equipment asrequired in (B) if located at each next level distribution equipment downstream toward the load.

(C) Type.

The surge protective device shall be listed in accordance to ANSI/UL1449-2017, Surge Protective Devices,and be a Type 1 or Type 2 SPD.

(D) Replacement.

Where service equipment is replaced, all of the requirements of this section shall apply.

(E) Ratings.

The SPD shall be listed for installation within the appropriate electrical power supply system. The SPD shall have a minimum Short Circuit Current Rating of 22 kA. The SPD shall have aminimum nominal discharge current rating of 10 kA. The SPD shall have an ANSI/UL 1449voltage protection rating (VPR) of less than or equal to 800 Volts for a 120 volt line and lessthan or equal to 1800 volts for a 240 volt line.

Statement of Problem and Substantiation for Public Comment

230.67(B): Adding this statement removes the possibility and even likelihood of installing an SPD to only one phase conductor and either ground or neutral (could happen based on cost only). The proposed language is from Section 4.20.5.4 of NFPA 780-2017.

230.67(C): Adding the word “listed” prevents “recognized components” from being installed. The additional language requires the product selected be validated by a third party as to the safety of the product under a uniform set of conditions. The intent is to control manufacturers from listing their products to other standards without subjecting their products to a complete battery of safety testing.

New 230.67(E): Without some basic ratings, the specifier/purchaser can put in inferior products such as a minimally rated product in a high-lightning area such as FL. In this situation, the likelihood of SPD failure will be high with failure particles possibly being released into and/or out of the load center.

This first sentence seems trivial, but here is a very possible installation – it is possible and safe to install an SPD rated for a 480 or even 600 volt system on a 120 volt system. The SPD can have a SCCR of 22 kA and a nominal discharge current of 10 kA and will not pass the VPR requirement below. Having all three criteria, SCCR, VPR and Nominal Discharge Current gives the overall intent to keep inevitable surge voltages from reaching insulation breakdown levels within the panel bus work and wire insulation levels.

The short circuit current rating should at least be 22 kA as some larger dwelling units will have service equipment with this rating (the majority of Type 1 & 2 SPDs that are listed to the UL 1449 standard will meet this requirement).

The nominal discharge current rating is a measure of durability to numerous surge current events entering the SPD. This is a well-established durability test for both the UL and IEC markets. By putting in this rating requirement, we eliminate the likelihood of a poorly and incorrectly selected SPD. The NFPA 780 for example requires a lightning protection system to have a nominal discharge current of 20 kA (2017: 4.20.3.1.2) for Type 1 and Type 2 SPDs when used to create a NFPA 780 compliant lightning protection system. By making the requirement 10 kA we are at the lowest level for Type 1 SPD and mid-level for a Type 2 SPD = most universal

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point.

The VPR rating comes from the ANSI/UL 1449 standard and is a test that all UL 1449 listed SPDs must endure and receive an assigned value – the listing lab assigns the values from the test protocol results compared to a table within the standard. However, it is important to the end user to understand that they have an adequate protective device. By placing the VPR ratings requirement, we are providing the necessary technical credentials to accomplish the intent of the Article.

Without the above additional technical credentials described above, the NEC will not have accomplished its intent to provide adequate (not the best) protective measures against surge activity for any locations. NFPA 780 has recognized these essential technical requirements, albeit more strict/robust, as they are dealing with a lightning protection system.

Related Item

• FR-8546

Submitter Information Verification

Submitter Full Name: David Kendall

Organization: Thomas &amp; Betts Corporation

Street Address:

City:

State:

Zip:

Submittal Date: Mon Jun 25 16:18:42 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, David Kendall, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am David Kendall, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 678-NFPA 70-2018 [ Section No. 230.67 ]

230.67 Surge Protection.

(A) Surge Protective Device.

All services in dwelling units shall be provided with a surge protective device (SPD).

(B) Location.

The surge protective device shall be an integral part of the service equipment or shall be locatedimmediately adjacent thereto.

Exception: The surge protective device shall not be required to be located in the service equipment asrequired in (B) if located at each next level distribution equipment downstream toward the load.

(C) Type.

The surge protective device shall be a Type 1 or Type 2 SPD.

(D) Replacement.

Where service equipment is replaced, all of the requirements of this section shall apply.

Statement of Problem and Substantiation for Public Comment

Please review the negative comment submitted by Christopher Vance.

"The submitters did not provide adequate substantiation to clearly identify a risk to equipment or safety concern to warrant this new requirement. The primary concern with this FR is that although surge protection can provide a value to the end user, questions arise whether it should be mandated as it is presently a consumer choice in whether someone would find value in protecting their surge sensitive equipment. Also, potential issues exist with applying currently available products concerning clearly quantifying the level of protection provided and whetherthe unit remains in service. Surge Arresters are currently permitted by the Code in NEC 230.209."

The cost of electrical installations is escalating, if a consumer wants to be protected with a cheaper, less expensive alternative, let them decide. Just like life insurance... buy as much as you want at the level (price) you are comfortable. To mandate the protection, just in case a consumer has a transient incident is not good code language.

Related Item

• PI 2696 • PI 4118 • FR 8546

Submitter Information Verification

Submitter Full Name: Dean Hunter

Organization: Minnesota Department of Labor

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 15 11:29:57 EDT 2018

Committee: NEC-P10

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Copyright Assignment

I, Dean Hunter, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Dean Hunter, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 140-NFPA 70-2018 [ Section No. 230.67(A) ]

(A) Surge Protective Device.

All services in dwelling units shall be provided with a surge protective device (SPD).

Statement of Problem and Substantiation for Public Comment

This change increases safety of residential occupants by avoiding loss of protection of smoke detectors, GFCIs, and AFCIs caused by surges.

Related Item

• 230.67(A)

Submitter Information Verification

Submitter Full Name: Peter Walsh

Organization: TTA

Street Address:

City:

State:

Zip:

Submittal Date: Mon Jul 02 08:51:30 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Peter Walsh, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Peter Walsh, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 294-NFPA 70-2018 [ Section No. 230.67(A) ]

(A) Surge Protective Device.

All services in dwelling units Each service at the following shall be provided with a surge protective device(SPD). :

(1) One-family and two-family dwellings, including electrified garages and electrified accessory buildings

(2) Dwelling units and common areas of multi-family dwellings

(3) Dormitory units and common areas of dormitories

(4) Guest rooms and guest suites of hotels and motels

Statement of Problem and Substantiation for Public Comment

Readability of the Code and enforcement.

• "All services ..." should be singularized to "Each service ..." to correlate with the singular "a surge protective device".

• "... in ..." can be interpreted as those services encompassing SOLELY the INTERIORS of dwellings, implying that where services also encompass EXTERIORS of dwellings and to electrified garages and accessory buildings, those services would be exempt from this requirement; for clarity, revise "... in ..." to "... at ...".

• Arrange the affected spaces, occupancies, etc., into a list format for readability of the Code and for ease of future revisions.

• Excessive use of "dwelling unit" instead of "one-family dwelling", "two-family dwelling" and "multi-family dwelling" in Article 210 has caused enforcement confusion and inconsistent interpretations relative to whether or not protection must be provided in common areas (in addition to the individual dwelling units) of multi-family dwellings, and in electrified garages (attached or detached) and electrified accessory buildings of one- and two-family dwellings. Do not perpetuate the enforcement confusion over the term "dwelling unit" in this new Section.

• Explicitly include at this time "dormitory units", as well as associated common areas of a dormitory. This type of dwelling should be equally protected as it is for other protections such as in 2017 NEC® 210.12(B)/2020 NEC® 210.12(D). The definition for "dormitory unit" is being added to NEC® 210.2 by First Revision FR-7688. CORRELATING COMMITTEE: If "dormitory unit" is used here in a second Article, in accordance with NEC® Style Manual 2.2.2.1, that new definition for the 2020 NEC® should be relocated to Article 100. This would preclude having to reference the term to NEC® 210.2.

• Explicitly include at this time "guest rooms and guest suites". This type of dwelling should be equally protected as it is for other protections such as in 2017 NEC® 210.12(C)/2020 NEC® 210.12(B). Inclusion here might avoid the enforcement dilemma of bed-and-breakfast-type short-term rentals of what otherwise would be considered a dwelling unit.

Related Item

• First Revision No. 8546-NFPA 70-2018 [ New Sectionafter 230.66 ]

• First Revision No. 7688-NFPA 70-2018 [ New Sectionafter 210.1 ]

Submitter Information Verification

Submitter Full Name: Brian Rock

Organization: Hubbell Incorporated

Street Address:

City:

State:

Zip:

Submittal Date: Wed Jul 25 17:35:12 EDT 2018

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Committee: NEC-P10

Copyright Assignment

I, Brian Rock, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Brian Rock, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 295-NFPA 70-2018 [ Section No. 230.67(B) ]

(B) Location.

SPDs identified with an enclosure-type number shown in Table 110.28 solely for indoor use or marked"Indoor Use Only" shall be located indoors. SPDs identified with an enclosure-type number as shown inTable 110.28 for outdoor use shall be permitted to be located outdoors. Open-type SPD shall be madeinaccessible to unqualified persons.

The surge protective device that provides protection to the service shall be an integral part of the serviceequipment or shall be located immediately adjacent thereto.

Exception: The surge protective device shall not be required to be located in the service equipment asrequired in (B) if located at each next - level distribution equipment downstream toward the load branchcircuit(s) .

Statement of Problem and Substantiation for Public Comment

• Existing 285.11 (being superseded by new Article 242, 242.13 in FR-8221) requires SPDs to be located mandatorially where inaccessible to unqualified persons, unless listed for installation in accessible locations, and permissively indoors or outdoors. However, UL Standard UL 1449, Clause 80.38, mandates that open-type SPDs be identified as requiring installation within an enclosure (i.e., live parts inaccessible to unqualified persons). Also, UL Standard UL 1449, Clause 80.14 Exception No. 1, requires Type 1 SPDs and Type 2 SPDs intended for outdoor usage to be evaluated and identified for Enclosure Numbers for outdoor use as indicated in NEC® Table 110.28. This proposed wording will bring the 230.67(B) requirements into alignment with UL 1449 and more readily enforceable to the AHJ. While in future Code cycles, 230.67 might migrate to Article 242, during the interim the 230.67(B) requirements for SPDs providing protection to service equipment, autonomous of Article 242, must maintain those location requirements..• Due to the Exception, the parent text of 230.67(B) requires clarification as to the intended purpose for mandating Type 1 SPDs or Type 2 SPDs to the service. Without this clarification, the Exception might be misinterpreted as precluding protection of cord-and-plug-connected utilization equipment "downstream" with Type 3 SPDs, in conflict with new Section 242..• Revise "... the load" to "... the branch circuit(s)". The load might not be in place or might be cord-and-plug-connected utilization equipment not there at the time of inspection by the AHJ. There also may be more than one branch circuit (or more than one load).

Related Item

• First Revision No. 8546-NFPA 70-2018 [ New Section after230.66 ]

• First Revision No. 8221-NFPA 70-2018 [ GlobalInput ]

Submitter Information Verification

Submitter Full Name: Brian Rock

Organization: Hubbell Incorporated

Street Address:

City:

State:

Zip:

Submittal Date: Wed Jul 25 18:15:55 EDT 2018

Committee: NEC-P10

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Copyright Assignment

I, Brian Rock, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Brian Rock, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 296-NFPA 70-2018 [ Section No. 230.67(C) ]

(C) SPD Type.

The surge protective device shall be listed and identified as a Type 1 SPD or Type 2 SPD, in accordancewith the specfications of 242 .21 or 242.23, respectively.

Statement of Problem and Substantiation for Public Comment

• Existing 285.6 (being superseded by new Article 242, 242.9 in FR-8221) requires SPDs to be listed. While in future Code cycles, 230.67 might migrate to Article 242, during the interim the 230.67(C) requirement for SPDs providing protection to service equipment, autonomous of Article 242, must maintain that listing requirement. Further, SPD Type numbers here should be referenced to their corresponding defining specifications in Article 242 in FR-8221 at 242.21 or 242.23; these SPD Type numbers do not define themselves within Article 230 or Article 100.

Related Item

• First Revision No. 8546-NFPA 70-2018 [ New Section after230.66 ]

• First Revision No. 8221-NFPA 70-2018 [ GlobalInput ]

Submitter Information Verification

Submitter Full Name: Brian Rock

Organization: Hubbell Incorporated

Street Address:

City:

State:

Zip:

Submittal Date: Wed Jul 25 18:56:28 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Brian Rock, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Brian Rock, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 297-NFPA 70-2018 [ Section No. 230.67(D) ]

(D) Replacement Service Equipment Replacements or Modifications .

Where service equipment is replaced or modified , all of the requirements of this section shall apply.

Statement of Problem and Substantiation for Public Comment

Although replacement of service equipment is addressed, 230.67(D) in FR-8546 is silent regarding modifications. Avoid enforcement ambiguity by addressing explicitly.

Related Item

• First Revision No. 8546-NFPA 70-2018 [ New Section after 230.66 ]

Submitter Information Verification

Submitter Full Name: Brian Rock

Organization: Hubbell Incorporated

Street Address:

City:

State:

Zip:

Submittal Date: Wed Jul 25 19:08:46 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Brian Rock, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Brian Rock, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 299-NFPA 70-2018 [ Section No. 230.71 ]

230.71 Maximum Number of Disconnects.

In general, each service shall have not more than one disconnecting means.

(A) General.

For the purpose of this section, disconnecting means installed as part of listed equipment and used solelyfor the following shall not be considered a service disconnecting means:

(1) Power monitoring equipment

(2) Surge-protective device(s)

(3) Control circuit of the ground-fault protection system

(4) Power-operable service disconnecting means

(B) Two to Six Service Disconnecting Means.

Two to six service disconnects shall be permitted for each service permitted by 230.2 or for each set ofservice-entrance conductors permitted by 230.40, Exception No. 1, 3, 4, or 5. The two to six servicedisconnecting means shall be permitted to consist of a combination of any of the following:

(1) Separate enclosures with a main service disconnecting means in each enclosure

(2) Panelboards with a main service disconnecting means in each panelboard

(3) A service disconnect in a switchboard where there is only one service disconnect in an enclosure

(4) A service disconnect in switchgear that is located in its own separate compartment

Informational Note: See 408.36, Exception No. 3, for service equipment in certain panelboards, andsee 430.95 for service equipment in motor control centers.

(C) Single Disconnecting Means Required for New Services

(1) All new facilities permitted after 2020 shall have a single main disconnecting means.

(2) The main disconnect shall be located in a location readily accessible to the FirstResponder in case of emergency.

(3) When GFCI protection is required, the GFCI settings shall be coordinated withdownstream overcurrent protection devices.

Statement of Problem and Substantiation for Public Comment

The requirement for a single main disconnecting means will enhance the safety of facilities. The six disconnect rule 230.71 (A) creates many problems for Electricians and Engineers in adding new electrical power distribution for new loads in an existing facility. A single main disconnect allows for the addition of new feeder devices without having to re-configure the service. Also, the single main disconnect is far safer as it allows the First Responder/Fire Department or building Electrician to easily disconnect power to the entire facility.Also, the new 2017 UL 67 Requirement for New Service Entrance Panelboards (NEC 408.3 (A) (2) requires that with service disconnect in the off position, no ungrounded uninsulated live part is exposed to inadvertent contact by persons while servicing any load terminal, including a neutral load terminal, a branch circuit equipment grounding terminal, or the neutral disconnect link. The six handle rule has been used to avoid compliance with the GFCI protection for main disconnects of 1000 Amps or higher (230.95).

Related Item

• Professional Electrical Engineer

Submitter Information Verification

Submitter Full Name: Glenn Clayden

Organization: Glenn A. Clayden & Associates Inc.

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Affiliation: Colorado Code Committee

Street Address:

City:

State:

Zip:

Submittal Date: Thu Jul 26 12:03:22 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Glenn Clayden, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Glenn Clayden, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 316-NFPA 70-2018 [ Section No. 230.71 ]

230.71 Maximum Number of Disconnects.

In general, each service shall have not more than one disconnecting means.

(A) General.

For the purpose of this section, disconnecting means installed as part of listed equipment and used solelyfor the following shall not be considered a service disconnecting means:

(1) Power monitoring equipment

(2) Surge-protective device(s)

(3) Control circuit of the ground-fault protection system

(4) Power-operable service disconnecting means

(B) Two to Six Service Disconnecting Means.

Two to six service disconnects shall be permitted for each service permitted by 230.2 or for each set ofservice-entrance conductors permitted by 230.40 , Exception No. 1, 3, 4, or 5. The two to six servicedisconnecting means shall be permitted to consist of a combination of any of the following:

(1) Separate enclosures with a main service disconnecting means in each enclosure

(2) Panelboards with a main service disconnecting means in each panelboard

(3) A service disconnect in a switchboard where there is only one service disconnect in an enclosure

(4) A service disconnect in switchgear that is located in its own separate compartment

Informational Note: See 408.36 , Exception No. 3, for service equipment in certain panelboards,and see 430.95 for service equipment in motor control centers.

Additional Proposed Changes

File Name Description Approved

Section_230.71_Recommended_Text.docx Text for 230.71 from 2017 NEC

Statement of Problem and Substantiation for Public Comment

Revert back to the 2017 Version of the NEC for this Section. The revised text will require a main for switchboards and panelboards where 2 - 6 disconnecting means in one switchboard or panelboard would suffice.

Related Item

• FR-8463

Submitter Information Verification

Submitter Full Name: Timothy Croushore

Organization: FirstEnergy

Affiliation: FirstEnergy

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 27 13:40:48 EDT 2018

Committee: NEC-P10

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Copyright Assignment

I, Timothy Croushore, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyrightin this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intendthat I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or anothersimilar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority toenter into this copyright assignment.

By checking this box I affirm that I am Timothy Croushore, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 53-NFPA 70-2018 [ Section No. 230.71 ]

230.71 Maximum Number of Disconnects.

In general, each service shall have not more than one disconnecting means.

(A) General.

For the purpose of this section, disconnecting means installed as part of listed equipment and used solelyfor the following shall not be considered a service disconnecting means:

(1) Power monitoring equipment

(2) Surge-protective device(s)

(3) Control circuit of the ground-fault protection system

(4) Power-operable service disconnecting means

(B) Two to Six Service Disconnecting Means.

Two to six service disconnects shall be permitted for each service permitted by 230.2 or for each set ofservice-entrance conductors permitted by 230.40, Exception No. 1, 3, 4, or 5. The two to six servicedisconnecting means shall be permitted to consist of a combination of any of the following:

(1) Separate enclosures with a main service disconnecting means in each enclosure

(2) Panelboards with a main service disconnecting means in each panelboardA service disconnect in a switchboard

(3) Switchboard where there is only one service disconnect in each vertical section

(4) Service disconnect in an enclosure

(5) A service disconnect in switchgear that where each disconnect is located in its own separatecompartment a separate compartment or equipment with barriers such that no uninsulated,ungrounded service busbar or service terminal is exposed to inadvertent contact by persons ormaintenance equipment while servicing load terminations. Barriers provided shall comply with230.62(C).

Informational Note: See 408.36, Exception No. 3, for service equipment in certain panelboards, andsee 430.95 for service equipment in motor control centers.

Statement of Problem and Substantiation for Public Comment

The product safety standard for switchboards, UL 891, defines a switchboard enclosure to include all of the vertical sections within the line-up since the installation of each section is required in order to provide a complete electrical enclosure. Item (3) should be revised to refer to individual vertical sections within a switchboard rather than a single switchboard enclosure.

The 2017 NEC revision to include line side service barriers for single service disconnect panelboards provided clear benefits to electrical service and maintenance personnel from a safety perspective. One of the reasons for limiting these requirements for single service disconnect applications was due to the large number of two to six service disconnect panelboard configurations and the difficulties associated with providing barriers in all cases. The first revision proposed to this section aligns well with that approach but there should be an allowance for the two to six service disconnects in a single enclosure where each disconnect is in a separate compartment or provided with barriers that provide equivalent safety.

Related Item

• FR 8463

Submitter Information Verification

Submitter Full Name: Vince Baclawski

Organization: Nema

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Street Address:

City:

State:

Zip:

Submittal Date: Wed Jun 27 14:44:59 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Vince Baclawski, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Vince Baclawski, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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NFPA Public Comment Form (For Proposing Revisions to the First Draft)

NOTE: All Public Comments must be received by 5:00 pm EST/EDST on the published Public Comment Closing Date.

For further information on the standards-making process, please contact the Codes and Standards Administration at 617-984-7249 or visit www.nfpa.org/codes.

For technical assistance, please call NFPA at 1-800-344-3555

FOR OFFICE USE ONLY

Log #:

Date Rec’d:

Date Name Vince Baclawski Tel. No. 703-841-3236

Company National Electrical Manufacturers Association (NEMA) Email [email protected]

Street Address 1300 North 17th Street, Suite 900 City Rosslyn State VA Zip 22209

Please indicate organization represented (if any) NEMA

1. (a) NFPA Document Title

National Electricrical Code NFPA No. & Year 70-2020

(b) Section/Paragraph 230.71

2. Identify First Revision and/or Input to which Comment relates: No(s).

FR 8463

2. Public Comment Recommends (check one): new text revised text deleted text

3. Proposed Text of Public Comment (include proposed new or revised wording, or identification of wording to be deleted):

[Note: Proposed text should be in legislative format showing proposed changes to the First Draft; i.e., use underscore to denote wording to be inserted (inserted wording) and strike-through to denote wording to be deleted (deleted wording).]

230.71 Maximum Number of Disconnects. In general, each service shall have not more than one disconnecting means.

(A) General.

For the purpose of this section, disconnecting means installed as part of listed equipment and used solely for the

following shall not be considered a service disconnecting means:

(1) Power monitoring equipment

(2) Surge-protective device(s)

(3) Control circuit of ground-fault protection system

(4) Power-operable service disconnecting means

(B) Two to Six Service Disconnecting Means.

Two to six service disconnects shall be permitted for each service permitted by 230.2, or for each set of service-

entrance conductors permitted by 230.40 Exception No. 1, 3, 4 or 5. The two to six service disconnecting means shall

be permitted to consist of a combination of any of the following:

(1) Separate enclosures with a main service disconnecting means in each enclosure

(2) Panelboards with a main service disconnecting means in each panelboard

(3) A service disconnect in a sSwitchboards where there is only one service disconnect in an enclosure each vertical

section

(4) A sService disconnects in switchgear an enclosure where each disconnect that is located in its own a separate

compartment or equipped with barriers such that no uninsulated, ungrounded service busbar or service terminal is

exposed to inadvertent contact by persons or maintenance equipment while servicing load terminations. Barriers

provided shall comply with 230.62(C).

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Informational Note: See 408.36, Exception No. 3, for service equipment in certain panelboards, and see

430.95 for service equipment in motor control centers.

4. Statement of Problem and Substantiation for Public Comment: (Note: State the problem that would be resolved by your

recommendation; give the specific reason for your Public Comment, including copies of tests, research papers, fire experience, etc. If more than 200 words, it may be abstracted for publication.)

The product safety standard for switchboards, UL 891, defines a switchboard enclosure to include all of the vertical sections within the line-up since the installation of each section is required in order to provide a complete electrical enclosure. Item (3) should be revised to refer to individual vertical sections within a switchboard rather than a single switchboard enclosure. The 2017 NEC revision to include line side service barriers for single service disconnect panelboards provided clear

benefits to electrical service and maintenance personnel from a safety perspective. One of the reasons for limiting

these requirements for single service disconnect applications was due to the large number of two to six service

disconnect panelboard configurations and the difficulties associated with providing barriers in all cases. The first

revision proposed to this section aligns well with that approach but there should be an allowance for the two to six

service disconnects in a single enclosure where each disconnect is in a separate compartment or provided with barriers

that provide equivalent safety.

5. Copyright Assignment

(a) I am the author of the text or other material (such as illustrations, graphs) proposed in the Public Comment.

(b) Some or all of the text or other material proposed in this Public Comment was not authored by me. Its source

is as follows: (please identify which material and provide complete information on its source)

I hereby grant and assign to the NFPA all and full rights in copyright in this Public Comment (including both the Proposed Text and the Statement of Problem and Substantiation). I understand that I acquire no rights in any publication of NFPA in which this Public Comment in this or another similar or analogous form is used. Except to the extent that I do not have authority to make an assignment in materials that I have identified in (b) above, I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this assignment.

Signature (Required)

PLEASE USE SEPARATE FORM FOR EACH PUBLIC COMMENT

To: Secretary, Standards Council National Fire Protection Association 1 Batterymarch Park ∙ Quincy, MA 02169-7471 OR

Fax to: (617) 770-3500 OR Email to: [email protected] 9/25/2018

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Public Comment No. 866-NFPA 70-2018 [ Section No. 230.71 ]

230.71 Maximum Number of Disconnects.

In general, each service shall have not more than one disconnecting means.

(A) General.

For the purpose of this section, disconnecting means installed as part of listed equipment and used solelyfor the following shall not be considered a service disconnecting means:

(1) Power monitoring equipment

(2) Surge-protective device(s)

(3) Control circuit of the ground-fault protection system

(4) Power-operable service disconnecting means

(B) Two to Six Service Disconnecting Means.

Two to six service disconnects shall be permitted for each service permitted by 230.2 or for each set ofservice-entrance conductors permitted by 230.40, Exception No. 1, 3, 4, or 5. The two to six servicedisconnecting means shall be permitted to consist of a combination of any of the following:

(1) Separate enclosures with a main service disconnecting means in each enclosure

(2) Panelboards with a main service disconnecting means in each panelboard

(3) A service disconnect in a switchboard where there is only one service disconnect in an enclosure

(4) A service disconnect in switchgear that is located in its own separate compartment

Informational Note: See 408.36, Exception No. 3, for service equipment in certain panelboards, andsee 430.95 for service equipment in motor control centers.

Additional Proposed Changes

File Name Description Approved

CN_64.pdf 70_CN 64

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 64 in the First Draft Report on First Revision No. 8463.

The Correlating Committee directs that this First Revision be reconsidered for grammar and clarity. The phrase “shall have not” should be replaced with “shall not have”.

The Correlating Committee also directs that this First Revision be reviewed and correlated with FR-8459. Section 230.71(B)(2) does not appear to correlate with the exception in 230.62(C).

This action will be considered a public comment.

The Correlating Committee directs CMP 9 to correlate with this action in 408.36 Exception No. 1.

This action will be considered a public comment.

Related Item

• FR 8463

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

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Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 13:29:00 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, CC on NEC-AAC, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am CC on NEC-AAC, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 867-NFPA 70-2018 [ Section No. 230.71 ]

230.71 Maximum Number of Disconnects.

In general, each service shall have not more than one disconnecting means.

(A) General.

For the purpose of this section, disconnecting means installed as part of listed equipment and used solelyfor the following shall not be considered a service disconnecting means:

(1) Power monitoring equipment

(2) Surge-protective device(s)

(3) Control circuit of the ground-fault protection system

(4) Power-operable service disconnecting means

(B) Two to Six Service Disconnecting Means.

Two to six service disconnects shall be permitted for each service permitted by 230.2 or for each set ofservice-entrance conductors permitted by 230.40, Exception No. 1, 3, 4, or 5. The two to six servicedisconnecting means shall be permitted to consist of a combination of any of the following:

(1) Separate enclosures with a main service disconnecting means in each enclosure

(2) Panelboards with a main service disconnecting means in each panelboard

(3) A service disconnect in a switchboard where there is only one service disconnect in an enclosure

(4) A service disconnect in switchgear that is located in its own separate compartment

Informational Note: See 408.36, Exception No. 3, for service equipment in certain panelboards, andsee 430.95 for service equipment in motor control centers.

Additional Proposed Changes

File Name Description Approved

CN_64.pdf 70_CN 64

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 64 in the First Draft Report on First Revision No. 8463.

The Correlating Committee directs that this First Revision be reconsidered for grammar and clarity. The phrase “shall have not” should be replaced with “shall not have”.

The Correlating Committee also directs that this First Revision be reviewed and correlated with FR-8459. Section 230.71(B)(2) does not appear to correlate with the exception in 230.62(C).

This action will be considered a public comment.

The Correlating Committee directs CMP 9 to correlate with this action in 408.36 Exception No. 1.

This action will be considered a public comment.

Related Item

• FR 8463

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

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Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 13:32:22 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, CC on NEC-AAC, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am CC on NEC-AAC, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1752-NFPA 70-2018 [ Section No. 230.71(B) ]

(B) Two to Six Service Disconnecting Means.

Two to six service disconnects shall be permitted for each service permitted by 230.2 or for each set ofservice-entrance conductors permitted by 230.40, Exception No. 1, 3, 4, or 5. For the purposes of thissection, a single handle operating multiple devices meets the intent of a single disconnect. The two to sixservice disconnecting means shall be permitted to consist of a combination of any of the following:

(1) Separate enclosures with a main service disconnecting means in each enclosure

(2) Panelboards with a main service disconnecting means in each panelboard

(3) A service disconnect in a switchboard where there is only one service disconnect in an enclosure

(4) A service disconnect in switchgear that is located in its own separate compartment

Informational Note: See 408.36, Exception No. 3, for service equipment in certain panelboards, andsee 430.95 for service equipment in motor control centers.

Statement of Problem and Substantiation for Public Comment

The revision in this first draft is overly restrictive. The intent of a single disconnect is really the operation of a single operating handle in each enclosure.

Related Item

• FR No. 8463-NFPA 70-2018 [ Section No. 230.71 ]

Submitter Information Verification

Submitter Full Name: Jeffrey Hidaka

Organization: QFE002 LLC

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 20:24:10 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Jeffrey Hidaka, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Jeffrey Hidaka, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 2198-NFPA 70-2018 [ Section No. 230.71(B) ]

(B) Two to Six Service Disconnecting Means.

Two to six service disconnects shall be permitted for each service permitted by 230.2 or for each set ofservice-entrance conductors permitted by 230.40, Exception No. 1, 3, 4, or 5. The two to six servicedisconnecting means shall be permitted to consist of a combination of any of the following:

(1) Separate enclosures with a main service disconnecting means in each enclosure

(2) Panelboards with a main service disconnecting means in each panelboard

(3) A service disconnect in a switchboard where there is only one service disconnect in an enclosure

(4) A service disconnect in switchgear that is located in its own separate compartment

(5) A single panelboard rated not more than 1600 amperes containing not more than six servicedisconnects each of which is rated less than 1000 amperes. This shall panelboard shall be equippedwith suitable barriers to pervent inadvertant contact with live parts.

Informational Note: See 408.36, Exception No. 3, for service equipment in certain panelboards, andsee 430.95 for service equipment in motor control centers.

Statement of Problem and Substantiation for Public Comment

While safety should not be comprised to save money, the purpose of the code is “the practical safeguarding of persons and property from the hazards associated with the use of electricity.” In my view FR 8463 provides safeguards that are of questionable value and is impractical in its application.

For example, under the new rule in FR 8463, a typical 3 phase wye fed small commercial building would no longer be permitted to use a 1200A Panel Board with 6 200A circuit breakers feeding 6 main lug panels panels. This is a very common installation that has been used successfully with a good safety record for many years. There two alternatives, roughly speaking:

1. Provide a ground fault protected and ARC fault mitigated Main Circuit Breaker. This adds considerable installation and maintenance cost with minimal benefit. The ARC fault mitigation the ground main are solutions to design problems created by the new rule. Or:2. Provide a tap box or gutter (often the CT can) and tap to up to six disconnects or main breaker panels. This method is less safe than the six mains panel as the connections are now made on a field installed bus or with taps rather than behind the circuit breaker in a panel. Working in this “hot gutter” requires an outage, which is reasonable. However, if an electrician will take the outage, why wouldn’t she also take an outage to work in a six disconnects panel (as she should)? If she chooses to “work it hot,” the hot gutter is clearly a more hazardous environment than the six mains panelboard.

This comment proposes to limit the hazards to small projects by applying the six mains service to 1600 amp panelboards with breakers below the 1000 threshold that has been shown to increase ground fault hazards. It also includes the requirement for barriers that has been proposed to be added in this edition of the code.

Related Item

• FR 8463 • PI 672

Submitter Information Verification

Submitter Full Name: Nathan Philips

Organization: Integrated Electronic Systems

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 23:22:18 EDT 2018

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Committee: NEC-P10

Copyright Assignment

I, Nathan Philips, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Nathan Philips, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1485-NFPA 70-2018 [ Section No. 230.71 [Excluding any Sub-

Sections] ]

In general, each Each service shall have not more than one disconnecting means unless specificallypermitted otherwise below ..

Statement of Problem and Substantiation for Public Comment

The term "In general" is vague and unenforceable. More specific language is necessary for proper application of this requirement

Related Item

• FR8463

Submitter Information Verification

Submitter Full Name: James Rogers

Organization: Towns Of Oak Bluffs, Tisbury,

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 22:02:57 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, James Rogers, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am James Rogers, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 382-NFPA 70-2018 [ Section No. 230.71 [Excluding any Sub-

Sections] ]

In general, each Each service shall have not more than one disconnecting means, except as permitted in250 .71(B).

Statement of Problem and Substantiation for Public Comment

I slightly revised the text so that it's clear when more than one serivce disconnect is permitted.

Related Item

• FR-8463

Submitter Information Verification

Submitter Full Name: Mike Holt

Organization: Mike Holt Enterprises Inc

Street Address:

City:

State:

Zip:

Submittal Date: Sat Aug 04 14:47:00 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Mike Holt, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Mike Holt, and I agree to be legally bound by the above Copyright Assignment and the terms andconditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon mysubmission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1539-NFPA 70-2018 [ Section No. 230.82 ]

230.82 Equipment Connected to the Supply Side of Service Disconnect.

Only the following equipment shall be permitted to be connected to the supply side of the servicedisconnecting means:

(1) Cable limiters.

(2) Meters and meter sockets nominally rated not in excess of 1000 volts, if all metal housings and serviceenclosures are grounded in accordance with Part VII and bonded in accordance with Part V of Article250.

(3) Meter disconnect switches nominally rated not in excess of 1000 volts that have a short-circuit currentrating equal to or greater than the available fault current, if all metal housings and service enclosuresare grounded in accordance with Part VII and bonded in accordance with Part V of Article 250. A meterdisconnect switch shall be capable of interrupting the load served. A meter disconnect shall be legiblyfield marked on its exterior in a manner suitable for the environment as follows: METER DISCONNECTNOT SERVICE EQUIPMENT

(4) Instrument transformers (current and voltage), impedance shunts, load management devices, surgearresters, and Type 1 surge-protective devices.

(5) Conductors used to supply load management devices, circuits for standby power systems, fire pumpequipment, and fire and sprinkler alarms, if provided with service equipment and installed inaccordance with requirements for service-entrance conductors.

(6) Solar photovoltaic systems, fuel cell systems, wind electric systems, energy storage systems, orinterconnected electric power production sources, if provided with a disconnecting means listed assuitable for use as service equipment, and overcurrent protection as specified in Part VII of Article 230.

(7) Control circuits for power-operable service disconnecting means, if suitable overcurrent protection anddisconnecting means are provided.

(8) Ground-fault protection systems or Type 2 surge-protective devices, where installed as part of listedequipment, if suitable overcurrent protection and disconnecting means are provided.

(9) Connections used only to supply listed communications equipment under the exclusive control of theserving electric utility, if suitable overcurrent protection and disconnecting means are provided. Forinstallations of equipment by the serving electric utility, a disconnecting means is not required if thesupply is installed as part of a meter socket, such that access can only be gained with the meterremoved.

(10) Emergency disconnect switches in disconnects in accordance with 230.85, if all metal housings andservice enclosures are grounded in accordance with Part VII and bonded in accordance with Part V ofArticle 250.

(11) Meter-mounted transfer switches nominally rated not in excess of 1000 volts that have a short-circuitcurrent rating equal to or greater than the available fault current. A meter-mounted transfer switch shallbe listed and be capable of transferring the load served.

Statement of Problem and Substantiation for Public Comment

This Public Comment is being submitted by a Correlating Committee Task Group that was created as a result of Correlating Committee Note No. 65. Members of the Task Group included Larry Ayer (Co-Chair), James Dollard, David Hittinger, Vince Saporita (Co-Chair), and David Williams. The Correlating Committee directed the Task Group to review the term “Emergency disconnect switches” and correlate it with the terminology used in FR-8642 (new Section 230.85), FR 7770 (Section 445.18(A)), and FR 8942 (Section 706.15).

The term “emergency disconnect switches” is changed to “emergency disconnects” in new 230.82(10) to correlate with the term in new 230.85.

The term “emergency disconnect(s)” is changed to “emergency disconnects”, “switch(es)” is changed to “switches”, and “breaker(s)” is changed to “breakers” in 230.85 to agree with the NEC Style Manual.

For FR 8874, the term “Emergency stop switch” is used correctly in title of 445.18 and therefore no changes are

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necessary.

For FR 7846 (Section 445.18(D)), the term “First Responder Shutdown” is changed to “Emergency Shutdown” for correlation with these other changes.

For FR 8942 (Section 706.15), the ESS disconnecting means, or its remote control, must be grouped with the emergency disconnects required in new 230.85, for the safety of first responders. Unless the ESS switch or its remote control is in close proximity when first responders try to de-energize the service of the dwelling unit by utilizing the outdoor emergency disconnects required by new 230.85, they will expect that the entire dwelling unit is totally de-energized. If the ESS switch, or its remote control, is not in close proximity, the first responders may not know that the dwelling unit is still energized. The revised requirement will help the first responders recognize that there is an additional disconnecting means that is necessary to totally de-energize the dwelling unit. The term “ESS disconnecting means” is used correctly in 706.15.

Related Item

• FR 8623

Submitter Information Verification

Submitter Full Name: Vincent Saporita

Organization: Eaton’s Bussmann Business

Affiliation: Eaton's Bussmann Business

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 10:58:58 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Vincent Saporita, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Vincent Saporita, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1952-NFPA 70-2018 [ Section No. 230.82 ]

230.82 Equipment Connected to the Supply Side of Service Disconnect.

Only the following equipment shall be permitted to be connected to the supply side of the servicedisconnecting means:

(1) Cable limiters.

(2) Meters and meter sockets nominally rated not in excess of 1000 volts, if all metal housings and serviceenclosures are grounded in accordance with Part VII and bonded in accordance with Part V of Article250.

(3) Meter disconnect switches nominally rated not in excess of 1000 volts that have a short-circuit currentrating equal to or greater than the available fault current, if all metal housings and service enclosuresare grounded in accordance with Part VII and bonded in accordance with Part V of Article 250. A meterdisconnect switch shall be capable of interrupting the load served. A meter disconnect shall be legiblyfield marked on its exterior in a manner suitable for the environment as follows: METER DISCONNECTNOT SERVICE EQUIPMENT

(4) Instrument transformers (current and voltage), impedance shunts, load management devices, surgearresters, and Type 1 surge-protective devices.

(5) Conductors used to supply load management devices, circuits for standby power systems, fire pumpequipment, and fire and sprinkler alarms, if provided with service equipment and installed inaccordance with requirements for service-entrance conductors.

(6) Solar photovoltaic systems, fuel cell systems, wind electric systems, energy storage systems, orinterconnected electric power production sources, if provided with a disconnecting means listed assuitable for use as service equipment, and overcurrent protection as specified in Part VII of Article230 . in accordance with 705.11.

(7) Control circuits for power-operable service disconnecting means, if suitable overcurrent protection anddisconnecting means are provided.

(8) Ground-fault protection systems or Type 2 surge-protective devices, where installed as part of listedequipment, if suitable overcurrent protection and disconnecting means are provided.

(9) Connections used only to supply listed communications equipment under the exclusive control of theserving electric utility, if suitable overcurrent protection and disconnecting means are provided. Forinstallations of equipment by the serving electric utility, a disconnecting means is not required if thesupply is installed as part of a meter socket, such that access can only be gained with the meterremoved.

(10) Emergency disconnect switches in accordance with 230.85, if all metal housings and serviceenclosures are grounded in accordance with Part VII and bonded in accordance with Part V of Article250.

(11) Meter-mounted transfer switches nominally rated not in excess of 1000 volts that have a short-circuitcurrent rating equal to or greater than the available fault current. A meter-mounted transfer switch shallbe listed and be capable of transferring the load served.

Statement of Problem and Substantiation for Public Comment

There was a plea for CMP4, CMP5, and CMP10 to work together on this issue. That coordination never happened so now is the time to fix the overlapping requirements that have been developed in Articles 230, 250, and 705. The set of requirements belong in Article 705 and references should be made to 705.11.

Related Item

• FR 8608

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

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Affiliation: PVICC

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 12:59:17 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, William Brooks, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am William Brooks, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 2124-NFPA 70-2018 [ Section No. 230.82 ]

230.82 Equipment Connected to the Supply Side of Service Disconnect.

Only the following equipment shall be permitted to be connected to the supply side of the servicedisconnecting means:

(1) Cable limiters.

(2) Meters and meter sockets nominally rated not in excess of 1000 volts, if all metal housings and serviceenclosures are grounded in accordance with Part VII and bonded in accordance with Part V of Article250.

(3) Meter disconnect switches nominally rated not in excess of 1000 volts that have a short-circuit currentrating equal to or greater than the available fault current, if all metal housings and service enclosuresare grounded in accordance with Part VII and bonded in accordance with Part V of Article 250. A meterdisconnect switch shall be capable of interrupting the load served. A meter disconnect shall be legiblyfield marked on its exterior in a manner suitable for the environment as follows: METER DISCONNECTNOT SERVICE EQUIPMENT

(4) Instrument transformers (current and voltage), impedance shunts, load management devices, surgearresters, and Type 1 surge-protective devices.

(5) Conductors used to supply load management devices, circuits for standby power systems, fire pumpequipment, and fire and sprinkler alarms, if provided with service equipment and installed inaccordance with requirements for service-entrance conductors.

(6) Solar photovoltaic systems, fuel cell systems, wind electric systems, energy storage systems, orinterconnected electric power production sources, if provided with a disconnecting means listed assuitable for use as service equipment, and overcurrent protection as specified in Part VII of Article230 .

(7) Control circuits for power-operable service disconnecting means, if suitable overcurrent protection anddisconnecting means are provided.

(8) Ground-fault protection systems or Type 2 surge-protective devices, where installed as part of listedequipment, if suitable overcurrent protection and disconnecting means are provided.

(9) Connections used only to supply listed communications equipment under the exclusive control of theserving electric utility, if suitable overcurrent protection and disconnecting means are provided. Forinstallations of equipment by the serving electric utility, a disconnecting means is not required if thesupply is installed as part of a meter socket, such that access can only be gained with the meterremoved.

(10) Emergency disconnect switches in accordance with 230.85, if all metal housings and serviceenclosures are grounded in accordance with Part VII and bonded in accordance with Part V of Article250.

(11) Meter-mounted transfer switches nominally rated not in excess of 1000 volts that have a short-circuitcurrent rating equal to or greater than the available fault current. A meter-mounted transfer switch shallbe listed and be capable of transferring the load served.

Statement of Problem and Substantiation for Public Comment

This language is not necessary here as the issue is being addressed in a new 705.11 In addition this language will create enforcement issues such as how do you size the overcurrent protection and where is it located. The requirement for overcurrent protection for these inverter output conductors is already covered in Article 705 where it belongs. I would ask that CMP 10 look at the language in the new 705.11 and make comments there to address any concerns they may have but having these requirements in 2 locations with differing requirements will become an enforcement nightmare. Also having disconnects listed as suitable for use as service equipment simply means that there is an ability to bond any grounded conductor to the enclosure. The requirements located in Article 705 are much more descriptive and enforcable.

Related Item

• FR8628

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Submitter Information Verification

Submitter Full Name: James Rogers

Organization: Towns Of Oak Bluffs, Tisbury,

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 19:28:35 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, James Rogers, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am James Rogers, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 217-NFPA 70-2018 [ Section No. 230.82 ]

230.82 Equipment Connected to the Supply Side of Service Disconnect.

Only the following equipment shall be permitted to be connected to the supply side of the servicedisconnecting means:

(1) Cable limiters.

(2) Meters and meter sockets nominally rated not in excess of 1000 volts, if all metal housings and serviceenclosures are grounded in accordance with Part VII and bonded in accordance with Part V of Article250.

(3) Meter disconnect switches nominally rated not in excess of 1000 volts that have a short-circuit currentrating equal to or greater than the available fault current, if all metal housings and service enclosuresare grounded in accordance with Part VII and bonded in accordance with Part V of Article 250. A meterdisconnect switch shall be capable of interrupting the load served. A meter disconnect shall be legiblyfield marked on its exterior in a manner suitable for the environment as follows: METER DISCONNECTNOT SERVICE EQUIPMENT

(4) Instrument transformers (current and voltage), impedance shunts, load management devices, surgearresters, and Type 1 surge-protective devices.

(5) Conductors used to supply load management devices, circuits for standby power systems, fire pumpequipment, and fire and sprinkler alarms, if provided with service equipment and installed inaccordance with requirements for service-entrance conductors.

(6) Solar photovoltaic systems, fuel cell systems, wind electric systems, energy storage systems, orinterconnected electric power production sources, if provided with a disconnecting means listed assuitable for use as service equipment, and overcurrent protection as specified in Part VII of Article 230.

(7) Control circuits for power-operable service disconnecting means, if suitable overcurrent protection anddisconnecting means are provided.

(8) Ground-fault protection systems or Type 2 surge-protective devices, where installed as part of listedequipment, if suitable overcurrent protection and disconnecting means are provided.

(9) Connections used only to supply listed communications equipment under the exclusive control of theserving electric utility, if suitable overcurrent protection and disconnecting means are provided. Forinstallations of equipment by the serving electric utility, a disconnecting means is not required if thesupply is installed as part of a meter socket, such that access can only be gained with the meterremoved.

(10) Emergency disconnect switches in accordance with 230.85, if all metal housings and serviceenclosures are grounded in accordance with Part VII and bonded in accordance with Part V of Article250.

(11) Meter-mounted transfer switches nominally rated not in excess of 1000 volts that have a short-circuitcurrent rating equal to or greater than the available fault current. A meter-mounted transfer switch shallbe listed and be capable of transferring the load served. A meter-mounted transfer switch shall bemarked on its exterior:

METER-MOUNTED TRANSFER SWITCH

NOT SERVICE EQUIPMENT

Statement of Problem and Substantiation for Public Comment

Revisions processed as part of FR-7830 (Section 702.5) would require meter-mounted transfer switches to be “suitable for use as service equipment”. As noted in Section 230.82(11) (FR-8628), meter-mounted transfer switches are permitted to be connected to the supply side of the service disconnecting means. As such, these devices are NOT “service disconnects”, and would therefore not be suitable for use as “service equipment”. Requiring that these devices be suitable for service equipment would result in the need to bond the neutral to ground in the meter mounted transfer switch, resulting in multiple bonding points. If multiple bonding points are to be avoided, the existing service equipment would need to be modified and would no longer be the service disconnect. This is not the intent of the meter-mounted transfer switch.

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To clarify that the meter-mounted transfer switch is not service equipment, a marking is added to the new 230.82(11), similar to wording used in 230.82(3), that states “NOT SERVICE EQUIPMENT”. Lastly, Section 230.94 is revised with a new Exception, similar to Exception 1, stating that the meter-mounted transfer switch is permitted on the supply side of the (service) overcurrent device.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 218-NFPA 70-2018 [Section No. 230.94]

Public Comment No. 219-NFPA 70-2018 [Section No. 702.5]

Public Comment No. 218-NFPA 70-2018 [Section No. 230.94]

Public Comment No. 219-NFPA 70-2018 [Section No. 702.5]

Related Item

• FR 8628 • FR 7830

Submitter Information Verification

Submitter Full Name: Robert Osborne

Organization: UL LLC

Street Address:

City:

State:

Zip:

Submittal Date: Mon Jul 16 12:53:29 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Robert Osborne, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Robert Osborne, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 256-NFPA 70-2018 [ Section No. 230.82 ]

230.82 Equipment Connected to the Supply Side of Service Disconnect.

Only the following equipment shall be permitted to be connected to the supply side of the servicedisconnecting means:

(1) Cable limiters.

(2) Meters and meter sockets nominally rated not in excess of 1000 volts, if all metal housings and serviceenclosures are grounded in accordance with Part VII and bonded in accordance with Part V of Article250.

(3) Meter disconnect switches nominally rated not in excess of 1000 volts that have a short-circuit currentrating equal to or greater than the available fault current, if all metal housings and service enclosuresare grounded in accordance with Part VII and bonded in accordance with Part V of Article 250. A meterdisconnect switch shall be capable of interrupting the load served. A meter disconnect shall be legiblyfield marked on its exterior in a manner suitable for the environment as follows: METER DISCONNECTNOT SERVICE EQUIPMENT

(4) Instrument transformers (current and voltage), impedance shunts, load management devices, surgearresters, and Type 1 surge-protective devices.

(5) Conductors used to supply load management devices, circuits for standby power systems, fire pumpequipment, and fire and sprinkler alarms, if provided with service equipment and installed inaccordance with requirements for service-entrance conductors.

(6) Solar photovoltaic systems , fuel cell systems , wind electric systems ,and energy storage systems,or interconnected electric power production sources, if provided with a disconnecting means listed assuitable for use as service equipment, and overcurrent protection as specified in Part VII of Article 230.

(7) Control circuits for power-operable service disconnecting means, if suitable overcurrent protection anddisconnecting means are provided.

(8) Ground-fault protection systems or Type 2 surge-protective devices, where installed as part of listedequipment, if suitable overcurrent protection and disconnecting means are provided.

(9) Connections used only to supply listed communications equipment under the exclusive control of theserving electric utility, if suitable overcurrent protection and disconnecting means are provided. Forinstallations of equipment by the serving electric utility, a disconnecting means is not required if thesupply is installed as part of a meter socket, such that access can only be gained with the meterremoved.

(10) Emergency disconnect switches in accordance with 230.85, if all metal housings and serviceenclosures are grounded in accordance with Part VII and bonded in accordance with Part V of Article250.

(11) Meter-mounted transfer switches nominally rated not in excess of 1000 volts that have a short-circuitcurrent rating equal to or greater than the available fault current. A meter-mounted transfer switch shallbe listed and be capable of transferring the load served.

Statement of Problem and Substantiation for Public Comment

just to clean up the language a little bit

Related Item

• Public Input No. 188-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: Alfio Torrisi

Organization: electrician

Street Address:

City:

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State:

Zip:

Submittal Date: Sun Jul 22 09:33:13 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Alfio Torrisi, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Alfio Torrisi, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 312-NFPA 70-2018 [ Section No. 230.82 ]

230.82 Equipment Connected to the Supply Side of Service Disconnect.

Only the following equipment shall be permitted to be connected to the supply side of the servicedisconnecting means:

(1) Cable limiters.

(2) Meters and meter sockets nominally rated not in excess of 1000 volts, if all metal housings and serviceenclosures are grounded in accordance with Part VII and bonded in accordance with Part V of Article250.

(3) Meter disconnect switches nominally rated not in excess of 1000 volts that have a short-circuit currentrating equal to or greater than the available fault current, if all metal housings and service enclosuresare grounded in accordance with Part VII and bonded in accordance with Part V of Article 250. A meterdisconnect switch shall be capable of interrupting the load served. A meter disconnect shall be legiblyfield marked on its exterior in a manner suitable for the environment as follows: METER DISCONNECTNOT SERVICE EQUIPMENT

(4) Instrument transformers (current and voltage), impedance shunts, load management devices, surgearresters, and Type 1 surge-protective devices.

(5) Conductors used to supply load management devices, circuits for standby power systems, fire pumpequipment, and fire and sprinkler alarms, if provided with service equipment and installed inaccordance with requirements for service-entrance conductors.

(6) Solar photovoltaic systems, fuel cell systems, wind electric systems, energy storage systems, orinterconnected electric power production sources, if provided with a disconnecting means listed assuitable for use as service equipment, and overcurrent protection as specified in Part VI and Part VII ofArticle 230.

(7) Control circuits for power-operable service disconnecting means, if suitable overcurrent protection anddisconnecting means are provided.

(8) Ground-fault protection systems or Type 2 surge-protective devices, where installed as part of listedequipment, if suitable overcurrent protection and disconnecting means are provided.

(9) Connections used only to supply listed communications equipment under the exclusive control of theserving electric utility, if suitable overcurrent protection and disconnecting means are provided. Forinstallations of equipment by the serving electric utility, a disconnecting means is not required if thesupply is installed as part of a meter socket, such that access can only be gained with the meterremoved.

(10) Emergency disconnect switches in accordance with 230.85, if all metal housings and serviceenclosures are grounded in accordance with Part VII and bonded in accordance with Part V of Article250.

(11) Meter-mounted transfer switches nominally rated not in excess of 1000 volts that have a short-circuitcurrent rating equal to or greater than the available fault current. A meter-mounted transfer switch shallbe listed and be capable of transferring the load served.

Statement of Problem and Substantiation for Public Comment

The disconnecting means for solar photovoltaic, fuel cells systems, wind electric systems, energy storage systems or interconnected electric power productions sources should meet both Part VI and Part VII of Article 230. Part VI are the technical requirements for the disconnecting means that are needed to be included in this provision of 230.82.

Item (11) should be removed as it may or may not be placed on a meter socket under the exclusive control of the electric utility. Meter sockets under the exclusive control of the electric utility do not permit these devices.

Related Public Comments for This Document

Related Comment Relationship

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Public Comment No. 315-NFPA 70-2018 [Section No. 705.11(F)]

Related Item

• FR-8625

Submitter Information Verification

Submitter Full Name: Timothy Croushore

Organization: FirstEnergy

Affiliation: FirstEnergy

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 27 13:09:53 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Timothy Croushore, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyrightin this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intendthat I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or anothersimilar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority toenter into this copyright assignment.

By checking this box I affirm that I am Timothy Croushore, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 38-NFPA 70-2018 [ Section No. 230.82 ]

230.82 Equipment Connected to the Supply Side of Service Disconnect.

Only the following equipment shall be permitted to be connected to the supply side of the servicedisconnecting means:

(1) Cable limiters.

(2) Meters and meter sockets nominally rated not in excess of 1000 volts, if all metal housings and serviceenclosures are grounded in accordance with Part VII and bonded in accordance with Part V of Article250.

(3) Meter disconnect switches nominally rated not in excess of 1000 volts that have a short-circuit currentrating equal to or greater than the available fault current, if all metal housings and service enclosuresare grounded in accordance with Part VII and bonded in accordance with Part V of Article 250. A meterdisconnect switch shall be capable of interrupting the load served. A meter disconnect shall be legiblyfield marked on its exterior in a manner suitable for the environment as follows: METER DISCONNECTNOT SERVICE EQUIPMENT

(4) Instrument transformers (current and voltage), impedance shunts, load management devices, surgearresters, and Type 1 surge-protective devices.

(5) Conductors used to supply load management devices, circuits for standby power systems, fire pumpequipment, and fire and sprinkler alarms, if provided with service equipment and installed inaccordance with requirements for service-entrance conductors.

(6) Solar photovoltaic systems, fuel cell systems, wind electric systems, energy storage systems, orinterconnected electric power production sources, if provided with a disconnecting means listed assuitable for use as service equipment, and overcurrent protection as specified in Part VII of Article 230.

(7) Control circuits for power-operable service disconnecting means, if suitable overcurrent protection anddisconnecting means are provided.

(8) Ground-fault protection systems or Type 2 surge-protective devices, where installed as part of listedequipment, if suitable overcurrent protection and disconnecting means are provided.

(9) Connections used only to supply listed communications equipment under the exclusive control of theserving electric utility, if suitable overcurrent protection and disconnecting means are provided. Forinstallations of equipment by the serving electric utility, a disconnecting means is not required if thesupply is installed as part of a meter socket, such that access can only be gained with the meterremoved.

(10) Emergency disconnect switches in accordance with 230.85, if all metal housings and serviceenclosures are grounded in accordance with Part VII and bonded in accordance with Part V of Article250.

(11) Meter-mounted transfer switches nominally rated not in excess of 1000 volts that have a short-circuitcurrent rating equal to or greater than the available fault current. A meter-mounted transfer switch shallbe listed as suitable for use as service equipment and be capable of transferring the load served.

Statement of Problem and Substantiation for Public Comment

The public comment is for editorial clarity to align 230.82(11) to the language in FR-7830 to 702.5. FR-7830 requires that the meter mounted transfer equipment be suitable for use as service equipment.

Related Item

• Service equipment requirements/ FR 7830

Submitter Information Verification

Submitter Full Name: Brian Baughman

Organization: Generac Power Systems Inc

Street Address:

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City:

State:

Zip:

Submittal Date: Wed Jun 27 09:40:57 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Brian Baughman, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Brian Baughman, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 383-NFPA 70-2018 [ Section No. 230.82 ]

230.82 Equipment Connected to the Supply Side of Service Disconnect.

Only the following equipment shall be permitted to be connected to the supply side of the servicedisconnecting means:

(1) Cable limiters.

(2) Meters and meter sockets nominally rated not in excess of 1000 volts, if all metal housings and serviceenclosures are grounded in accordance with Part VII and bonded in accordance with Part V of Article250.

(3) Meter disconnect switches nominally rated not in excess of 1000 volts that have a short-circuit currentrating equal to or greater than the available fault current, if all metal housings and service enclosuresare grounded in accordance with Part VII and bonded in accordance with Part V of Article 250. A meterdisconnect switch shall be capable of interrupting the load served. A meter disconnect shall be legiblyfield marked on its exterior in a manner suitable for the environment as follows: METER DISCONNECTNOT SERVICE EQUIPMENT

(4) Instrument transformers (current and voltage), impedance shunts, load management devices, surgearresters, and Type 1 surge-protective devices.

(5) Conductors used to supply load management devices, circuits for standby power systems, fire pumpequipment, and fire and sprinkler alarms, if provided with service equipment and installed inaccordance with requirements for service-entrance conductors.

(6) Solar E lectric power production sources operating in parallel with a primary source(s) of electricitysuch as sol ar photovoltaic systems, fuel cell systems, wind electric systems, energy storage systems, or interconnected electric power production sources, if provided with a disconnecting means inaccordance with 705.11(F). The disconnecting means must be listed as suitable for use as serviceequipment, and overcurrent protection shall be provided as specified in Part VII of Article 230.

(7) Control circuits for power-operable service disconnecting means, if suitable overcurrent protection anddisconnecting means are provided.

(8) Ground-fault protection systems or Type 2 surge-protective devices, where installed as part of listedequipment, if suitable overcurrent protection and disconnecting means are provided.

(9) Connections used only to supply listed communications equipment under the exclusive control of theserving electric utility, if suitable overcurrent protection and disconnecting means are provided. Forinstallations of equipment by the serving electric utility, a disconnecting means is not required if thesupply is installed as part of a meter socket, such that access can only be gained with the meterremoved.

(10) Emergency disconnect switches One- and two-family dwelling unit first responder disconnect inaccordance with 230.85, if all metal housings and service enclosures are grounded in accordance withPart VII and bonded in accordance with Part V of Article 250.

(11) Meter-mounted transfer switches nominally rated not in excess of 1000 volts that have a short-circuitcurrent rating equal to or greater than the available fault current. A meter-mounted transfer switch shallbe listed and be capable of transferring the load served.

Statement of Problem and Substantiation for Public Comment

(6) Revised text is intended to match text in 750.1, and the reference to 705.11(F) will be helpful to the Code user. Note: This reference is to the 2020 NEC, not the 2017.(10) Change "Emergency disconnect switches" to One- and two-family dwelling unit first responder disconnect".

The term "Emergency" in the electrical industry relates to Article 700 Emergency Supply, this term should never be used except for those applications. The use of the term "Emergency" will create confusion in the field. Let's not do that...

Related Item

• FR-8625, FR-8623, and FR-8606

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Submitter Information Verification

Submitter Full Name: Mike Holt

Organization: Mike Holt Enterprises Inc

Street Address:

City:

State:

Zip:

Submittal Date: Sat Aug 04 14:52:35 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Mike Holt, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Mike Holt, and I agree to be legally bound by the above Copyright Assignment and the terms andconditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon mysubmission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 572-NFPA 70-2018 [ Section No. 230.82 ]

230.82 Equipment Connected to the Supply Side of Service Disconnect.

Only the following equipment shall be permitted to be connected to the supply side of the servicedisconnecting means:

(1) Cable limiters.

(2) Meters and meter sockets nominally rated not in excess of 1000 volts, if all metal housings and serviceenclosures are grounded in accordance with Part VII and bonded in accordance with Part V of Article250.

(3) Meter disconnect switches nominally rated not in excess of 1000 volts that have a short-circuit currentrating equal to or greater than the available fault current, if all metal housings and service enclosuresare grounded in accordance with Part VII and bonded in accordance with Part V of Article 250. A meterdisconnect switch shall be capable of interrupting the load served. A meter disconnect shall be legiblyfield marked on its exterior in a manner suitable for the environment as follows: METER DISCONNECTNOT SERVICE EQUIPMENT

(4) Instrument transformers (current and voltage), impedance shunts, load management devices, surgearresters, and Type 1 surge-protective devices.

(5) Conductors used to supply load management devices, circuits for standby power systems, fire pumpequipment, and fire and sprinkler alarms, if provided with service equipment and installed inaccordance with requirements for service-entrance conductors.

(6) Solar photovoltaic systems, fuel cell systems, wind electric systems, energy storage systems, orinterconnected electric power production sources, if provided with a disconnecting means listed assuitable for use as service equipment, and overcurrent protection as specified in Part VII of Article 230.

(7) Control circuits for power-operable service disconnecting means, if suitable overcurrent protection anddisconnecting means are provided.

(8) Ground-fault protection systems or Type 2 surge-protective devices, where installed as part of listedequipment, if suitable overcurrent protection and disconnecting means are provided.

(9) Connections used only to supply listed communications equipment under the exclusive control of theserving electric utility, if suitable overcurrent protection and disconnecting means are provided. Forinstallations of equipment by the serving electric utility, a disconnecting means is not required if thesupply is installed as part of a meter socket, such that access can only be gained with the meterremoved.

(10) Emergency disconnect switches in First responder disconnecting means in accordance with 230.85, ifall metal housings and service enclosures are grounded in accordance with Part VII and bonded inaccordance with Part V of Article 250.

(11) Meter-mounted transfer switches nominally rated not in excess of 1000 volts that have a short-circuitcurrent rating equal to or greater than the available fault current. A meter-mounted transfer switch shallbe listed and be capable of transferring the load served.

Statement of Problem and Substantiation for Public Comment

This new section cannot be added due to the requirements in 90.2(B)(5) which clearly states that "Equipment under exclusive control of an electric utility where such installations (a) Consist of service drops or service laterals, and associated metering" are not covered by the Code. It should be noted that the Underwriters Laboratory Product Spec database contains the following statement in product category WPXW Meter Mounted Transfer Switches, "The installation of these devices is intended to be under the exclusive control of the serving utility, and is not considered under the purview of ANSI/NFPA 70, "National Electrical Code." As such, these devices are not considered service equipment". So, why is it proposed to add them to the NEC? Because they are not covered by the Code and are not considered service equipment, provisions for them should not be added to 230.82. Adding this new section will cause confusion to the installer, electrical inspector, property owner and user of the NEC. How would this new provision meld with the definition of Service Point in Article 100 and the Informational Note

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following the definition? The service point for many installations is at the transformer or pedestal for underground installations. So, to make this definition work with the new proposed (11), we will need to have a service point at the transformer terminals, remove it for the meter transfer equipment and reinstate it on the load side of the meter transfer equipment. Also, please take a look at the requirement for identification requirement in 230.82(3) for meter disconnect switches. it requires a field marking "METER DISCONNECT NOT SERVICE EQUIPMENT. Why isn't there an equal requirement for the other service disconnects that are not one of the one-to-six service disconnecting means provided for in 230.71? if I am counting them correctly, at least four other service disconnects that ARE NOT service disconnects are permitted ahead of the service disconnecting means provided in 230.71! Any chance this section is really getting out of hand? If there is some pressing need for these meter transfer switches, add provision for them to 90.2(B)(5) to indicate they are not covered by the Code.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 573-NFPA 70-2018 [Section No. 230.85]

Public Comment No. 1125-NFPA 70-2018 [Section No. 702.5]

Related Item

• FR-8628

Submitter Information Verification

Submitter Full Name: Phil Simmons

Organization: Simmons Electrical Services

Street Address:

City:

State:

Zip:

Submittal Date: Sat Aug 11 20:39:12 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Phil Simmons, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Phil Simmons, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 869-NFPA 70-2018 [ Section No. 230.82 ]

230.82 Equipment Connected to the Supply Side of Service Disconnect.

Only the following equipment shall be permitted to be connected to the supply side of the servicedisconnecting means:

(1) Cable limiters.

(2) Meters and meter sockets nominally rated not in excess of 1000 volts, if all metal housings andservice enclosures are grounded in accordance with Part VII and bonded in accordance with Part V ofArticle 250.

(3) Meter disconnect switches nominally rated not in excess of 1000 volts that have a short-circuit currentrating equal to or greater than the available fault current, if all metal housings and service enclosuresare grounded in accordance with Part VII and bonded in accordance with Part V of Article 250. Ameter disconnect switch shall be capable of interrupting the load served. A meter disconnect shall belegibly field marked on its exterior in a manner suitable for the environment as follows: METERDISCONNECT NOT SERVICE EQUIPMENT

(4) Instrument transformers (current and voltage), impedance shunts, load management devices, surgearresters, and Type 1 surge-protective devices.

(5) Conductors used to supply load management devices, circuits for standby power systems, fire pumpequipment, and fire and sprinkler alarms, if provided with service equipment and installed inaccordance with requirements for service-entrance conductors.

(6) Solar photovoltaic systems, fuel cell systems, wind electric systems, energy storage systems, orinterconnected electric power production sources, if provided with a disconnecting means listed assuitable for use as service equipment, and overcurrent protection as specified in Part VII of Article230.

(7) Control circuits for power-operable service disconnecting means, if suitable overcurrent protection anddisconnecting means are provided.

(8) Ground-fault protection systems or Type 2 surge-protective devices, where installed as part of listedequipment, if suitable overcurrent protection and disconnecting means are provided.

(9) Connections used only to supply listed communications equipment under the exclusive control of theserving electric utility, if suitable overcurrent protection and disconnecting means are provided. Forinstallations of equipment by the serving electric utility, a disconnecting means is not required if thesupply is installed as part of a meter socket, such that access can only be gained with the meterremoved.

(10) Emergency disconnect switches in accordance with 230.85, if all metal housings and serviceenclosures are grounded in accordance with Part VII and bonded in accordance with Part V of Article250.

(11) Meter-mounted transfer switches nominally rated not in excess of 1000 volts that have a short-circuitcurrent rating equal to or greater than the available fault current. A meter-mounted transfer switchshall be listed and be capable of transferring the load served.

Additional Proposed Changes

File Name Description Approved

CN_65.pdf 70_CN65

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 65 in the First Draft Report on First Revision No. 8623.

The Correlating Committee directs the term “Emergency disconnect switches” be reviewed and correlated with the terminology used in FR-8462, newsection 230.85, FR-7770 and FR-8942. The Correlating Committee will establish a task group between the applicable panels to determine proper

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terminology for correlation throughout the code.This action will be considered as a public comment.

Related Item

• First Revision No. 8623

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 13:57:42 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, CC on NEC-AAC, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am CC on NEC-AAC, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Correlating Committee Note No. 65-NFPA 70-2018 [ Detail ]

Submitter Information Verification

Submitter Full Name: Sarah CaldwellCommittee: Submittal Date: Wed May 09 17:26:50 EDT 2018

Committee Statement and Meeting Notes

Committee Statement:

The Correlating Committee directs the term “Emergency disconnect switches” be reviewed and correlated with the terminology used in FR-8462, new section 230.85, FR-7770 and FR-8942. The Correlating Committee will establish a task group between the applicable panels to determine proper terminology for correlation throughout the code.

This action will be considered as a public comment.

First Revision No. 8623-NFPA 70-2018 [Detail]

Ballot Results

This item has passed ballot

12 Eligible Voters0 Not Returned

12 Affirmative All0 Affirmative with Comments0 Negative with Comments0 Abstention

Affirmative AllBrunssen, James E.

Dressman, Kevin L.

Hickman, Palmer L.

Hittinger, David L.

Holub, Richard A.

Johnston, Michael J.

Kovacik, John R.

Manche, Alan

McDaniel, Roger D.

Pierce, James F.

Saporita, Vincent J.

Williams, David A.

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Public Comment No. 940-NFPA 70-2018 [ Section No. 230.82 ]

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230.82 Equipment Connected to the Supply Side of Service Disconnect.

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Only the following equipment shall be permitted to be connected to the supply side of the servicedisconnecting means:

(1) Cable limiters.

(2) Meters and meter sockets nominally rated not in excess of 1000 volts, if all metal housings and serviceenclosures are grounded in accordance with Part VII and bonded in accordance with Part V of Article250.

(3) Meter disconnect switchesnominally

(4) rated not in excess of1000 volts that

(5) 1000v provided they meet all the following:

(6)1. They have a short

-circuit

currentrating equal to or greater than the available

fault current, if allshort circuit current.

2. They are marked suitable for service equipment.

3. A main bonding jumper shall connect the grounded conductor(s) to the meter disconnect switchenclosure.

4. All metal housings and service enclosures are grounded in accordance with

Part VIIPart VII and bonded in accordance with

Part VPart V of Article 250.

A meter disconnect switch shall be

5. They are capable of interrupting the load served.

A

6. The meter disconnect shall be legibly field marked on its exterior in a manner suitable for theenvironment as follows:

METER DISCONNECT

NOT SERVICE EQUIPMENT

Informational Note: See 250.24B2 for meter disconnect switch main bonding jumper requirement.”

(7) Instrument transformers (current and voltage), impedance shunts, load management devices, surgearresters, and Type 1 surge-protective devices.

(8) Conductors used to supply load management devices, circuits for standby power systems, fire pumpequipment, and fire and sprinkler alarms, if provided with service equipment and installed inaccordance with requirements for service-entrance conductors.

(9) Solar photovoltaic systems, fuel cell systems, wind electric systems, energy storage systems, orinterconnected electric power production sources, if provided with a disconnecting means listed assuitable for use as service equipment, and overcurrent protection as specified in Part VII of Article 230.

(10) Control circuits for power-operable service disconnecting means, if suitable overcurrent protection anddisconnecting means are provided.

(11) Ground-fault protection systems or Type 2 surge-protective devices, where installed as part of listedequipment, if suitable overcurrent protection and disconnecting means are provided.

(12) Connections used only to supply listed communications equipment under the exclusive control of theserving electric utility, if suitable overcurrent protection and disconnecting means are provided. Forinstallations of equipment by the serving electric utility, a disconnecting means is not required if thesupply is installed as part of a meter socket, such that access can only be gained with the meterremoved.

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(13) Emergency disconnect switches in accordance with 230.85, if all metal housings and serviceenclosures are grounded in accordance with Part VII and bonded in accordance with Part V of Article250.

(14) Meter-mounted transfer switches nominally rated not in excess of 1000 volts that have a short-circuitcurrent rating equal to or greater than the available fault current. A meter-mounted transfer switch shallbe listed and be capable of transferring the load served.

Statement of Problem and Substantiation for Public Comment

250.24B2 is a new proposal and included in this submittal.

The meter disconnect switch required provisions are placed in a list for easier reading.

The new #2 on this list is similar to 230.66. Although it is advertised with # 6 on this as ‘NOT SERVICE EQUIPMENT’, it is line side equipment and subject to the same conditions as equipment regarded as service equipment.

The new main bonding jumper entry (#3) is added following the logic of 250.24C. Whether it’s regarded as service equipment or a meter disconnect switch, it is placed line side in the system and is subject to the same conditions as the service equipment. The meter disconnect switch doesn’t know it isn’t service equipment. If each service disconnect switch is required to be bonded, the meter disconnect switch should be also. Presently, there is no code to enforce it this way. On the other hand, if the electrical code making panel finds the meter disconnect switch enclosure should not be bonded to the grounded conductor(s), a code entry should be implemented stating it shall not have the main bonding jumper installed.

Note: Some of that NFPA automated editing of what I submitted did not do it any favors.

Related Item

• 230.82(3)

Submitter Information Verification

Submitter Full Name: Norman Feck

Organization: State of Colorado

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 17:15:17 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Norman Feck, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Norman Feck, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1486-NFPA 70-2018 [ Section No. 230.85 ]

230.85 Emergency Disconnect(s).

For one- and two-family dwelling units, all service conductors shall terminate in disconnecting meanshaving a short-circuit current rating equal to or greater than the available fault current, installed in a readilyaccessible outdoor location. If more than one disconnect is provided, they shall be grouped. Eachdisconnect shall be one of the following:

(1) Service disconnect(s) marked as follows: EMERGENCY DISCONNECT, SERVICE DISCONNECT

(2) Meter disconnect(s) installed per 230.82(3) and marked as follows: EMERGENCY DISCONNECT,METER DISCONNECT, NOT SERVICE EQUIPMENT

(3) Other listed disconnect switch(es) or circuit breaker(s) on the supply side of each service disconnectthat are suitable for use as service equipment and marked as follows: EMERGENCY DISCONNECT,NOT SERVICE EQUIPMENT

Markings shall comply with 110.21(B).

Statement of Problem and Substantiation for Public Comment

It does not make sense to put "Meter Disconnects" here. These disconnects are intended for the servicing of utility meters and do not normally have interrupting ratings and are not intended to open services under load but rather are used as isolating devices for the safety of utility company personnel that are changing or servicing metering equipment.

Related Item

• FR8462

Submitter Information Verification

Submitter Full Name: James Rogers

Organization: Towns Of Oak Bluffs, Tisbury,

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 22:16:12 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, James Rogers, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am James Rogers, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1542-NFPA 70-2018 [ Section No. 230.85 ]

230.85 Emergency Disconnect(s) Disconnects .

For one- and two-family dwelling units, all service conductors shall terminate in disconnecting meanshaving a short-circuit current rating equal to or greater than the available fault current, installed in a readilyaccessible outdoor location. If more than one disconnect is provided, they shall be grouped. Eachdisconnect shall be one of the following:

(1) Service disconnect(s) marked disconnects marked as follows: EMERGENCY DISCONNECT,SERVICE DISCONNECT

(2) Meter disconnect(s) installed disconnects installed per 230.82(3) and marked as follows:EMERGENCY DISCONNECT, METER DISCONNECT, NOT SERVICE EQUIPMENT

(3) Other listed disconnect switch(es) or circuit breaker(s) on switches or circuit breakers on the supplyside of each service disconnect that are suitable for use as service equipment and marked as follows:EMERGENCY DISCONNECT, NOT SERVICE EQUIPMENT

Markings shall comply with 110.21(B).

Statement of Problem and Substantiation for Public Comment

This Public Comment is being submitted by a Correlating Committee Task Group that was created as a result of Correlating Committee Note No. 65. Members of the Task Group included Larry Ayer (Co-Chair), James Dollard, David Hittinger, Vince Saporita (Co-Chair), and David Williams. The Correlating Committee directed the Task Group to review the term “Emergency disconnect switches” and correlate it with the terminology used in FR-8642 (new Section 230.85), FR 7770 (Section 445.18(A)), and FR 8942 (Section 706.15).

The term “emergency disconnect switches” is changed to “emergency disconnects” in new 230.82(10) to correlate with the term in new 230.85.

The term “emergency disconnect(s)” is changed to “emergency disconnects”, “switch(es)” is changed to “switches”, and “breaker(s)” is changed to “breakers” in 230.85 to agree with the NEC Style Manual.

For FR 8874, the term “Emergency stop switch” is used correctly in title of 445.18 and therefore no changes are necessary.

For FR 7846 (Section 445.18(D)), the term “First Responder Shutdown” is changed to “Emergency Shutdown” for correlation with these other changes.

For FR 8942 (Section 706.15), the ESS disconnecting means, or its remote control, must be grouped with the emergency disconnects required in new 230.85, for the safety of first responders. Unless the ESS switch or its remote control is in close proximity when first responders try to de-energize the service of the dwelling unit by utilizing the outdoor emergency disconnects required by new 230.85, they will expect that the entire dwelling unit is totally de-energized. If the ESS switch, or its remote control, is not in close proximity, the first responders may not know that the dwelling unit is still energized. The revised requirement will help the first responders recognize that there is an additional disconnecting means that is necessary to totally de-energize the dwelling unit. The term “ESS disconnecting means” is used correctly in 706.15.

Related Item

• FR 8642

Submitter Information Verification

Submitter Full Name: Vincent Saporita

Organization: Eaton’s Bussmann Business

Affiliation: Eaton's Bussmann Business

Street Address:

City:

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State:

Zip:

Submittal Date: Wed Aug 29 11:09:09 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Vincent Saporita, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Vincent Saporita, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 313-NFPA 70-2018 [ Section No. 230.85 ]

230.85 Emergency Disconnect(s).

For one- and two-family dwelling units, all service conductors shall terminate in disconnecting meanshaving a short-circuit current rating equal to or greater than the available fault current, installed in a readilyaccessible outdoor location. If more than one disconnect is provided, they shall be grouped. Eachdisconnect shall be one of the following:

(1) Service disconnect(s) marked as follows: EMERGENCY DISCONNECT, SERVICE DISCONNECT

(2) Meter disconnect(s) installed per 230.82(3) and marked as follows: EMERGENCY DISCONNECT,METER DISCONNECT, NOT SERVICE EQUIPMENT

(3) Other listed disconnect switch(es) or circuit breaker(s) on the supply side of each service disconnectthat are suitable for use as service equipment and marked as follows: EMERGENCY DISCONNECT,NOT SERVICE EQUIPMENT

Markings shall comply with 110.21(B).

Statement of Problem and Substantiation for Public Comment

Delete Item 3. The disconnect is either a meter disconnect of the main disconnecting means for the service. Item 3 does not identify any regular device known at this time.

Related Item

• FR-8462

Submitter Information Verification

Submitter Full Name: Timothy Croushore

Organization: FirstEnergy

Affiliation: FirstEnergy

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 27 13:17:52 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Timothy Croushore, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyrightin this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intendthat I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or anothersimilar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority toenter into this copyright assignment.

By checking this box I affirm that I am Timothy Croushore, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 384-NFPA 70-2018 [ Section No. 230.85 ]

230.85 Emergency Disconnect 85 First Responder Disconnect (s).

For one- and two-family dwelling units, all service conductors shall terminate in disconnecting meanshaving a short-circuit current rating equal to or greater than the available fault current, installed in a readilyaccessible outdoor location. If more than one disconnect is provided, they shall be grouped. Eachdisconnect shall be one of the following:

(1) Service disconnect(s) marked as follows: EMERGENCY FIRST RESPONDER DISCONNECT,SERVICE DISCONNECT

(2) Meter disconnect(s) installed per 230.82(3) and marked as follows: EMERGENCY FIRSTRESPONDER DISCONNECT, METER DISCONNECT, NOT SERVICE EQUIPMENT

(3) Other listed disconnect switch(es) or circuit breaker(s) on the supply side of each service disconnectthat are suitable for use as service equipment and marked as follows: EMERGENCY FIRSTRESPONDER DISCONNECT, NOT SERVICE EQUIPMENT

Markings shall comply with 110.21(B).

Statement of Problem and Substantiation for Public Comment

The word "EMERGENCY" should only be used when apply the requirements related to 'Emergency Systems' as contained in Article 700. The use of the term Emergency for this application (not related to Emergency Systems, Article 700) will surley create confusion in the industry. No bueno...

Related Item

• FR-8462

Submitter Information Verification

Submitter Full Name: Mike Holt

Organization: Mike Holt Enterprises Inc

Street Address:

City:

State:

Zip:

Submittal Date: Sat Aug 04 15:10:47 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Mike Holt, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Mike Holt, and I agree to be legally bound by the above Copyright Assignment and the terms andconditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon mysubmission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 39-NFPA 70-2018 [ Section No. 230.85 ]

230.85 Emergency First Responder Disconnect(s).

For one- and two-family dwelling units, all service conductors shall terminate in disconnecting meanshaving a short-circuit current rating equal to or greater than the available fault current, installed in a readilyaccessible outdoor location. If more than one disconnect is provided, they shall be grouped. Eachdisconnect shall be one of the following:

(1) Service disconnect(s) marked as follows: EMERGENCY FIRST RESPONDER DISCONNECT,SERVICE DISCONNECT

(2) Meter disconnect(s) installed per 230.82(3) and marked as follows: EMERGENCY FIRSTRESPONDER DISCONNECT, METER DISCONNECT, NOT SERVICE EQUIPMENT

(3) Other listed disconnect switch(es) or circuit breaker(s) on the supply side of each service disconnectthat are suitable for use as service equipment and marked as follows: EMERGENCY FIRSTRESPONDER DISCONNECT, NOT SERVICE EQUIPMENT

Markings shall comply with 110.21(B).

Statement of Problem and Substantiation for Public Comment

The comment comment adds editorial clarity that the disconnect is for first responders as referenced by the committee statement to FR 7846. CMP-13 used similar language for a similar type of shutdown for optional standby generators that are installed on one and two family dwelling units. The term "Emergency" is used in NEC Article 700 and could create confusion where a listed optional standby service rated transfer is installed to meet the requirement in 230.85(1). The term "Emergency" means NFPA 110, Level 1 to the manufacturers and installers of generators and transfer equipment, and the term should be reserved for those systems for clarity purposes.

Related Item

• FR 8462 and FR 7846

Submitter Information Verification

Submitter Full Name: Brian Baughman

Organization: Generac Power Systems Inc

Street Address:

City:

State:

Zip:

Submittal Date: Wed Jun 27 09:48:34 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Brian Baughman, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Brian Baughman, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 474-NFPA 70-2018 [ Section No. 230.85 ]

230.85 Emergency Disconnect(s).

For one- and two-family dwelling units, all All service conductors shall terminate in disconnecting meanshaving a short-circuit current rating equal to or greater than the available fault current, installed in a readilyaccessible outdoor location. If more than one disconnect is provided, they shall be grouped. Eachdisconnect shall be one of the following:

(1) Service disconnect(s) marked as follows: EMERGENCY DISCONNECT, SERVICE DISCONNECT

(2) Meter disconnect(s) installed per 230.82(3) and marked as follows: EMERGENCY DISCONNECT,METER DISCONNECT, NOT SERVICE EQUIPMENT

(3) Other listed disconnect switch(es) or circuit breaker(s) on the supply side of each service disconnectthat are suitable for use as service equipment and marked as follows: EMERGENCY DISCONNECT,NOT SERVICE EQUIPMENT

Markings shall comply with 110.21(B).

Statement of Problem and Substantiation for Public Comment

PI 1169 would have made this rule apply to all except one and two family dwellings. The ability for first reponders to have easy access to the service disconnect is at least as important for other than one and two family dwellings. The rule should apply to all services, with an exception to permit the use of a shunt trip device for services where it is not practicable to locate the actual service disconnect on the exterior of the building.

Related Item

• Public Input No. 1169-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: Don Ganiere

Organization: [ Not Specified ]

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 08 19:03:40 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Don Ganiere, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Don Ganiere, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 573-NFPA 70-2018 [ Section No. 230.85 ]

230.85 Emergency Disconnect 85 First Responder Disconnect (s).

For one- and two-family dwelling units, all service conductors shall terminate in disconnecting meanshaving a short-circuit current rating equal to or greater than the available fault current, that is installed in areadily accessible outdoor location. If more than one disconnect is provided, they shall be grouped. Eachdisconnect shall be one of the following:

(1) Service disconnect(s) marked as follows: EMERGENCY DISCONNECT FIRSTRESPONDER DISCONNECT, SERVICE DISCONNECT

(2) Meter disconnect(s) installed per 230.82(3) and marked as follows: EMERGENCYDISCONNECT FIRST RESPONDER DISCONNECT, METER DISCONNECT, NOT SERVICEEQUIPMENT

(3) Other listed disconnect switch(es) or circuit breaker(s) on the supply side of each service disconnectthat are suitable for use as service equipment and marked as follows: EMERGENCYDISCONNECT FIRST RESPONDER DISCONNECT, NOT SERVICE EQUIPMENT

Markings shall comply with 110.21(B).

Statement of Problem and Substantiation for Public Comment

The term "Emergency" should not be used to describe the disconnecting means that is intended for use by first responders. The term "emergency" is used to describe emergency systems in Articles 225 and 230. Section 240.3 refers the user of the NEC to Article 700 for emergency systems. The term "emergency systems" is used throughout Article 517 to describe special conditions that require special equipment. Also, the term "Emergency System" is defined in 700.2.The term "First Responder" accurately describes the purpose of the additional disconnecting means and should be used.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 572-NFPA 70-2018 [Section No. 230.82]

Related Item

• FR-8462

Submitter Information Verification

Submitter Full Name: Phil Simmons

Organization: Simmons Electrical Services

Street Address:

City:

State:

Zip:

Submittal Date: Sat Aug 11 23:21:44 EDT 2018

Committee: NEC-P10

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Copyright Assignment

I, Phil Simmons, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Phil Simmons, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 640-NFPA 70-2018 [ Section No. 230.85 ]

230.85 Emergency Disconnect(s).

For one- and two-family dwelling units, it shall be permitted for all service conductors shall conductors toterminate in disconnecting means having a short-circuit current rating equal to or greater than the availablefault current, installed in a readily accessible outdoor location. If more than one disconnect is provided, theyshall be grouped. Each disconnect shall be one of the following:

(1) Service disconnect(s) marked as follows: EMERGENCY DISCONNECT, SERVICE DISCONNECT

(2) Meter disconnect(s) installed per 230.82(3) and marked as follows: EMERGENCY DISCONNECT,METER DISCONNECT, NOT SERVICE EQUIPMENT

(3) Other listed disconnect switch(es) or circuit breaker(s) on the supply side of each service disconnectthat are suitable for use as service equipment and marked as follows: EMERGENCY DISCONNECT,NOT SERVICE EQUIPMENT

Markings shall comply with 110.21(B).

Statement of Problem and Substantiation for Public Comment

The code text has been revised so that 230.85 is optional, not mandatory. The submitter of Public Input No. 1169 and First Revision No. 8462 submitted by CMP Panel 10 did not provide sufficient supporting technical data to justify the mandatory requirement for an Emergency Disconnect on the exterior of every one- and two-family dwelling. In the Committee Statement for Public Input No. 1169 it states "These requirements are practical, feasible and provide installers with multiple options." Installers have always had the option of installing service disconnects on the exterior of one- and two-family dwellings. If it was such a good idea more installers would be installing disconnects on the exterior of one- and two-family dwellings, when in fact it is rarely or never done in the state of Minnesota. It should remain an option; it should not be mandatory in every jurisdiction in the country. An exterior disconnecting means is not always going to be practical or feasible. Installing a disconnecting means on the exterior of a dwelling creates several unintended problems that greatly outnumber the need for, or the frequency of, a first responder to disconnect power from the dwelling. Unlocked exterior disconnect switches would pose a serious life safety hazard for curious children or unqualified persons; exterior disconnect switches locked in the closed position (which is not prohibited in the code) would defeat the purpose of the code change; the equipment would be subject to corrosive weather conditions and premature failure; vandalism of the exterior disconnect could result in property damage or other serious problems due to a loss of power for critical alarm systems, computer systems, heating and cooling equipment, medical support equipment, and other essential systems and equipment in today's homes; it would provide ready access for criminals to turn off power if they are intent on theft or doing harm to the occupants of the dwelling; exterior equipment is often subject to infestation and degradation by insects and small animals, etc. As for the concern of first responders, the U.S Fire Administration fire statistics actually show that from 2006 to 2015, the number of fires was down 19.1%, deaths were down 3.0%, injuries were down 8% and property losses were down 20.4%. The majority of calls for first responders are medical aid issues, not structure fires. For calendar year 2016, medical aid calls outnumbered fire calls 17:1. More information is available at www.usfa.fema.gov and www.nfpa.org . In general, construction codes provide basic and uniform standards that establish reasonable safeguards for health, safety, welfare, comfort and security for residents; mandatory application of 230.85 is not reasonable, and it does not exponentially enhance the health, safety, welfare, comfort and security for occupants of one- and two-family dwellings.

Related Item

• PI 1169, FR 8462

Submitter Information Verification

Submitter Full Name: John Williamson

Organization: Mn Dept Labor And Industry

Street Address:

City:

State:

Zip:

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Submittal Date: Tue Aug 14 13:37:08 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, John Williamson, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am John Williamson, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 218-NFPA 70-2018 [ Section No. 230.94 ]

230.94 Relative Location of Overcurrent Device and Other Service Equipment.

The overcurrent device shall protect all circuits and devices.

Exception No. 1: The service switch shall be permitted on the supply side.

Exception No. 2: High-impedance shunt circuits, surge arresters, Type 1 surge-protective devices, surge-protective capacitors, and instrument transformers (current and voltage) shall be permitted to beconnected and installed on the supply side of the service disconnecting means as permitted by 230.82.

Exception No. 3: Circuits for load management devices shall be permitted to be connected on the supplyside of the service overcurrent device where separately provided with overcurrent protection.

Exception No. 4: Circuits used only for the operation of fire alarm, other protective signaling systems, orthe supply to fire pump equipment shall be permitted to be connected on the supply side of the serviceovercurrent device where separately provided with overcurrent protection.

Exception No. 5: Meters nominally rated not in excess of 600 volts shall be permitted, provided all metalhousings and service enclosures are grounded.

Exception No. 6: Where service equipment is power operable, the control circuit shall be permitted to beconnected ahead of the service equipment if suitable overcurrent protection and disconnecting means areprovided.

Exception No. 7: A meter-mounted transfer switch shall be permitted on the supply side of theovercurrent device.

Statement of Problem and Substantiation for Public Comment

Revisions processed as part of FR-7830 (Section 702.5) would require meter-mounted transfer switches to be “suitable for use as service equipment”. As noted in Section 230.82(11) (FR-8628), meter-mounted transfer switches are permitted to be connected to the supply side of the service disconnecting means. As such, these devices are NOT “service disconnects”, and would therefore not be suitable for use as “service equipment”. Requiring that these devices be suitable for service equipment would result in the need to bond the neutral to ground in the meter mounted transfer switch, resulting in multiple bonding points. If multiple bonding points are to be avoided, the existing service equipment would need to be modified and would no longer be the service disconnect. This is not the intent of the meter-mounted transfer switch.

To clarify that the meter-mounted transfer switch is not service equipment, a marking is added to the new 230.82(11), similar to wording used in 230.82(3), that states “NOT SERVICE EQUIPMENT”. Lastly, Section 230.94 is revised with a new Exception, similar to Exception 1, stating that the meter-mounted transfer switch is permitted on the supply side of the (service) overcurrent device.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 217-NFPA 70-2018 [Section No. 230.82]

Public Comment No. 219-NFPA 70-2018 [Section No. 702.5]

Public Comment No. 217-NFPA 70-2018 [Section No. 230.82]

Public Comment No. 219-NFPA 70-2018 [Section No. 702.5]

Related Item

• FR 8628 • FR 7830

Submitter Information Verification

Submitter Full Name: Robert Osborne

Organization: UL LLC

Street Address:

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City:

State:

Zip:

Submittal Date: Mon Jul 16 13:00:47 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Robert Osborne, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Robert Osborne, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1862-NFPA 70-2018 [ Section No. 240.1 ]

240.1 Scope.

Parts I through VII of this article provide the general requirements for overcurrent protection andovercurrent protective devices not more than 1000 volts, nominal. Part VIII covers overcurrent protection forthose portions of supervised industrial installations operating at voltages of not more than 1000 volts,nominal. Part IX covers overcurrent protection over 1000 volts, nominal.

Informational Note 1 : Overcurrent protection for conductors and equipment is provided to open thecircuit if the current reaches a value that will cause an excessive or dangerous temperature inconductors or conductor insulation. See also 110.9 for requirements for interrupting ratings and110.10 for requirements for protection against fault currents.

Informational Note 2: For information regarding circuit breakers, see IEEE 3004.5 IEEERecommended Practice for the Application of Low-Voltage Circuit Breakers in Industrial andCommercial Power Systems

Statement of Problem and Substantiation for Public Comment

This comment is inspired by a recommendation from this committee to relocate the informational note TO Article 240 FROM the location suggested in the Public input phase. [Public Input No. 3250-NFPA 70-2017]

The stronger the linkage between the NFPA and IEEE on electrical power technology the better. This document replaces ANSI/IEEE 142 -- the so-called “Red Book”, which is now being sunsetted and superseded by 3004.5.

IEEE 3000 Standards Collection™ is the trademarked name of the family of industrial and commercial power systems standards formerly known as IEEE Color Books. The IEEE 3000 Standards Collection overall includes the same content as the Color Books that have been referenced into previous editions of the NEC but is now organized into approximately 70 IEEE “dot” standards that cover specific technical topics.

This method of development, of capturing and quickly conveying leading practice from transactions among academic experts and practitioners into our industry, supports the NFPA International mission of eliminating death, injury, property and economic loss due to fire, electrical and related hazards. My own experience with other international electrical standard developers suggests that closer coupling of the fire and electrical safety community in the US would be welcomed.

Details about this document is available at the link below:

https://standards.ieee.org/findstds/standard/3004.5-2014.html

Related Item

• Public Input No. 3250-NFPA 70-2017 Section No. 210.19(A) [Excluding any Sub-Sections]

Submitter Information Verification

Submitter Full Name: Michael Anthony

Organization: Standards Michigan

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 10:39:31 EDT 2018

Committee: NEC-P10

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Copyright Assignment

I, Michael Anthony, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Michael Anthony, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1376-NFPA 70-2018 [ Section No. 240.4(D) ]

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(D) Small Conductors.

Unless specifically permitted

in 240

in 240 .4(E)

or

or (G), the overcurrent protection shall not exceed that required by (D)(1) through (D)(7) after anycorrection factors for ambient temperature and number of conductors have been applied.

(1) 18 AWG Copper.

7 amperes, provided all the following conditions are met:

Continuous

1. Continuous loads do not exceed 5.6 amperes.

Overcurrent

2. Overcurrent protection is provided by one of the following:

1. Branch-circuit-rated circuit breakers listed and marked for use with 18 AWG copper

wire

2. Branch-circuit-rated fuses listed and marked for use with 18 AWG copper

wire

3. Class CC, Class J, or Class T fuses

(2) 16 AWG Copper.

10 amperes, provided all the following conditions are met:

Continuous

1. Continuous loads do not exceed 8 amperes.

Overcurrent

2. Overcurrent protection is provided by one of the following:

1. Branch-circuit-rated circuit breakers listed and marked for use with 16 AWG copper wire

2. Branch-circuit-rated fuses listed and marked for use with 16 AWG copper wire

3. Class CC, Class J, or Class T fuses

(3) 14 AWG

Copper

Copper at 60C insulation ampacity and copper-clad aluminum at 75C or higher insulation ampacity andtermination temperature ratings .

15 amperes

(4)

12 AWG Aluminum

12 AWG Aluminum and Copper-Clad Aluminum.

15 amperes

(5) 12 AWG

Copper

Copper 60C insulation ampacity and copper-clad aluminum at 75C or higher insulation ampacity andtermination temperature ratings .

20 amperes

(6) 10 AWG Aluminum

and

and Copper-Clad Aluminum.

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25 amperes

(7) 10 AWG

Copper

Copper at 60C insulation ampacity and copper-clad aluminum at 75C or higher insulation ampacity andtermination temperature ratings .

30 amperes

Additional Proposed Changes

File Name Description Approved

Prop_Table_310.15_B_16_.pdfProposed Table 310.15(B)16 adding 14 AWG Copper Clad Aluminum

CONCLUSIONS_FROM_UL_486C_SPRING.pdf14 AWG CCA Summary of Test: UL 486C Spring Action Sequence Push In Connectors

14_AWG_CCA_Summary.NSFvETL.pdf

14 AWG CCA Summary of Heat at 20 Amps Comparing Fact Finding from two different NRTL's

Cordage_Photos.pdfPhotos Of Applications of 24 AWG CCA: Very Small Conductor Size

UL_817_Fiinal.pdfETL Tested Cords Made with 24 AWG CCA per UL 817

Intetek.UL486C.SAS.103589128CRT-001A_003_.pdf

Test Report: UL 486C Copper Clad Aluminum THHN with Copper Only Push-In Connectors

14_AWG_Heat_Rise_Summary_NSF.pdfSummary of NRTL Report for 14 AWG CCA Heat Data

14_AWG_Thermal_Expansion_Summary.1535458407587_2_.pdf14 AWG CCA vs Cu Test Summary: Lineal Thermal Expansion ASTM E228

ETL.14awgCCA.Thermalstablei6049.04-106-31-r0.pdfETL Test Report. 14 AWG CCA Lineal Thermal Expansion ASTM E228

ETL.14awgCu.Thermalstablei6049.03-106-31-r0.pdfETL Test Report: 14 AWG Cu. Lineal Thermal Expansion per ASTM E228

WC_CopperAluminum_LTR-1117_DIGITAL.pdfUL DVVU2 Listing Program Designed to Verify CCA Bimetal Meets ASTM B566

Bond_Integrity_in_Aluminum-Copper_Clad_Metals.pdf

White Paper from Materion: Copper Clad Aluminum Material Used as a Component of OCPD's

Statement of Problem and Substantiation for Public Comment

PUBLIC COMMENT RESPONSE:• Proposed Text Clarifies Allowed Use. While 12 AWG copper at 60C ampacity can carry 20 Amps, the proposed text provides clarification for what is presently allowed in Code. 12 AWG copper-clad aluminum is rated 20 Amps at 75C from table 310.15(B)(16) which is the foundation ampacity table for most conductor applications. Many wiring devices and circuit breakers rated for 20 Amps are also rated for conductors at 75C. Therefore, the arbitrary limit for 12 AWG copper-clad aluminum to 15 amps based a 60C ampacity is not technically correct and overly restrictive. Practitioners of Code in the field are trained to know the temperature ratings of their circuit components, i.e. connectors, equipment, OCPD's, wire, etc. Code Making Panel's in general should take pains to not base Code-making decisions on the odd chance of product misuse, but rather reinforce and expand upon the

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Code values that already exists. Product misuse is ungovernable at the Code Making Panel level.• Circuit Breakers, Fuses, Equipment, et al, Are Essential to Over Current Protection -- Not Wire Diameter. Wire diameter (the conductive metallic component of the electrical conductor) is part of a circuit-wide system where the wire insulation and terminal temperature ratings largely govern the safety of the circuit. As demonstrated within the INTERTEK (an NRTL) reports attached to this Public Comment, proving the excellent thermal stability characteristics of Copper Clad Aluminum, 14 AWG CCA poses no safety hazard to the circuit due to thermal creep at the point of termination. There is no technical justification that 240.4(D) should limit the size of wire when the conductor insulation, the related terminals and the Code amperage tables provide for its safe use. Doing so eliminates the opportunity for manufacturers of circuit components and equipment to evolve products and solutions for specific applications in line with the specific current carrying capacity (amperage) of a wire. The general direction in society is to use less and less amperage per circuit, which points to smaller diameters of wire for the circuit. Note that a Public Comment has been submitted which would include 14 AWG CCA in the amperage Tables 310.16 and 310.17. That proposed table 310.16 has been attached to this Public Comment for your review. In the age of Green Energy and LED lighting, where the goal is to consume as little amperage as possible per circuit to safely power applications, to limit the size of the conductor would needlessly increase the cost of installation of the circuit to the consumer. Restrictions solely based on conductor size, and not considering insulation and terminal ratings, unduly limits the options for energy efficient economical installations. The revised text allows these conductors to be used where all the proper ratings and installation requirements are complied with.• “Listings” for Branch Circuit Conductors Guarantees Performance, Regardless of the Metallic Core Conductor. All commercially available copper-clad aluminum conductors carry listings from a recognized testing laboratory (NRTL) with wire & cable as part of their Scope of Recognition.• Copper-Clad Aluminum Routinely Drawn to 24 AWG for Coaxial Cable and Electrical Cordage Applications: ASTM B566 copper-clad aluminum Wire is durable and rugged. Current applications for copper-clad aluminum wire far exceed drawing to a relatively easy diameter such as 14 AWG. Heat Rise data clearly show that 14 AWG copper-clad aluminum, given the adequate insulation type, is safe to use in branch circuit applications. • Wire Insulation is the weakest link in Short Circuits, not Wire Diameter: Protection from Short Circuits is designed for both protection of the wire insulation as well as from damage or fusing of the conductor metal material, with the insulation being the weakest link. The three industrial metals recognized by Code (Copper Clad Aluminum, Aluminum and Copper) to carry current in a service, feeders, and branch circuits are capable of dealing with short circuits from a mechanical point of view. From an electrical point of view, any excess heat generated by a short circuit is more than adequately dealt with by those insulation types found in Tables 310.104(A) and 310.15(B)16, regardless of which metallic conductor is applied. Copper-Clad Aluminum conductors are UL Listed, which means that short circuit safety has already been considered. Kindly refer to UL 2556, Standard for Safety, Wire & Cable Test Methods. • ASTM B566 Copper-Clad Aluminum is a Super-Metal Designed to Utilize the Best Characteristics of High Purity Copper and 8000 series Aluminum: ASTM B566 copper-clad aluminum wire is neither aluminum nor copper, but is classified in metallurgical terms as one single metal, known in metallurgical terms as a bimetal. ASTM B566 is not an alloy, where by definition two or more metals are melted together to form an intermixed and unique microstructure. copper-clad aluminum combines two solid-state metals through a cladding process, maintaining each metal’s uniqueness, but fusing them together via a metallurgical bond that is stronger than either of the two metals by themselves. Bimetal may be drawn or shaped without losing the dimensional integrity of each metal. ASTM B566 bimetal is composed of 27% O₂ Free Copper (10% cross-sectional area of the surface), and 73% AA 8000 series aluminum (the core). Due to the metallurgical bond within ASTM B566, the less noble component of the bimetal (8000 Aluminum) is not sacrificial to the more-noble component (0₂ Free Copper). The corrosion resistance of ASTM B566 is equivalent to single-metal ETP copper, if not more so, due to the high purity of 0₂ Free Copper residing at its surface of copper-clad aluminum. copper-clad aluminum is not new; it has been referenced in Code since 1971. When meeting “listing” requirements for an electrical conductor in terms of mechanical strength, copper-clad aluminum as a material is held to the same standard as single-metal ETP copper. All copper-clad aluminum conductors are UL Listed.

Related Item

• 2121

Submitter Information Verification

Submitter Full Name: Peter Graser

Organization: Copperweld

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 27 15:02:32 EDT 2018

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Committee: NEC-P10

Copyright Assignment

I, Peter Graser, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Peter Graser, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 477-NFPA 70-2018 [ Section No. 240.6(A) ]

(A) Fuses and Fixed-Trip Circuit Breakers.

The standard ampere ratings for fuses and inverse time circuit breakers shall be considered as shown inTable 240.6(A). Additional standard ampere ratings for fuses shall be 1, 3, 6, 10, and 601. The use of fusesand inverse time circuit breakers with nonstandard ampere ratings shall be permitted.

Table 240.6(A) Standard Ampere Ratings for Fuses and Inverse Time Circuit Breakers

Standard Ampere Ratings

15 20 25 30 35

40 45 50 60 70

80 90 100 110 125

150 175 200 225 250

300 350 400 450 500

600 700 800 1000 1200

1600 2000 2500 3000 4000

5000 6000 — — —

Informational Note: The marked current ratings of Inverse time-current type circuit breakers, as listed to thestandard for Molded Case Circuit Breakers, UL 489, are determined at 25 and/or 40 C only. Somemanufacturers of this type of circuit breakers publish temperature rerating curves as notification to end-usersof the effect of changing ambient temperatures on the actual trip current levels. The “rerated” ampere ratingsare not recognized by the code.

Statement of Problem and Substantiation for Public Comment

The informational note proposed in PI 4241 provides important information that many code users do not have knowledge of. I fail to understand how the panel comment that this would be better addressed in the product standards applies to the proposed new note.

Related Item

• Public Input No. 4241-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: Don Ganiere

Organization: [ Not Specified ]

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 08 19:34:58 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Don Ganiere, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Don Ganiere, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 422-NFPA 70-2018 [ Section No. 240.6(C) ]

(C) Restricted Access Adjustable-Trip Circuit Breakers.

A circuit breaker(s) that has restricted access to the adjusting means shall be permitted to have an ampererating(s) that is equal to the adjusted current setting (long-time pickup setting). Restricted access shall bedefined as provided by one of the following:

(1) Located behind removable and sealable covers over the adjusting means

(2) Located behind bolted equipment enclosure doors

(3) Located behind locked doors accessible only to qualified personnel

(4) Password protected, with password accessible only to qualified personnel

Statement of Problem and Substantiation for Public Comment

The list options as part of 240.6(C) are not definitions but rather provisions. The correction of the words "defined as" to be replaced with "provided by" is a more accurate and clear as to the intent of this requirement.

Related Item

• FR 8636

Submitter Information Verification

Submitter Full Name: Thomas Domitrovich

Organization: Eaton Corporation

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 06 11:38:35 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Thomas Domitrovich, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understandand intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this oranother similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power andauthority to enter into this copyright assignment.

By checking this box I affirm that I am Thomas Domitrovich, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 257-NFPA 70-2018 [ Section No. 240.21(B) [Excluding any Sub-

Sections] ]

Conductors shall be permitted to be tapped or originate from an overcurrent device , without the correctovercurrent protection at the tap , to a feeder as specified in 240.21(B)(1) through (B)(5). Section 240.4(B)shall not be permitted for tap conductors.

Statement of Problem and Substantiation for Public Comment

To be clear this section only recognize CONDUCTORS that are tapped it does not take in to consideration the most commonly used connection which is to an over-current device with an over-current rating larger than the required conductor protection. this make it clear you may also have this rule apply to these conductors that are "Tapped" from and Over-current device that exceeds the capacity of the conductors as long as it follow the rules in this section.

Related Item

• Public Input No. 1811-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: Alfio Torrisi

Organization: electrician

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 22 09:39:47 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Alfio Torrisi, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Alfio Torrisi, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 945-NFPA 70-2018 [ New Section after 240.22 ]

TITLE OF NEW CONTENT

240.23 Change in Size of Grounded Conductor

Where ungrounded conductors are increased in size from the minimum size that has sufficient ampacity forthe intended installation, grounded conductors, where installed, shall be increased in size proportionately,according to the circular mil area of the ungrounded conductors.

Statement of Problem and Substantiation for Public Comment

Whether conductor sizes are increased for voltage drop or any other reason from their minimum size that has sufficient ampacity, the increased fault current carried by the ungrounded conductors is introduced to the grounded conductor (depending on the fault path). The grounded conductor is now expected to carry increased currents as is the case with proportionately upsized equipment grounding conductors of 250.122B.

Related Item

• 240.23

Submitter Information Verification

Submitter Full Name: Norman Feck

Organization: State of Colorado

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 17:23:48 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Norman Feck, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Norman Feck, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 868-NFPA 70-2018 [ Section No. 240.24(A) ]

(A) Accessibility.

Switches containing fuses, and circuit breakers shall be readily accessible and installed so that the centerof the grip of the operating handle of the switch or circuit breaker, when in its highest position, is not morethan 2.0 m (6 ft 7 in.) above the floor or working platform, unless one of the following applies:

(1) For busways, as provided in 368.17(C).

(2) For supplementary overcurrent protection, as described in 240.10.

(3) For overcurrent devices, as described in 225.40 and 230.92.

(4) For overcurrent devices adjacent to utilization equipment that they supply, access shall be permittedto be by portable means.

Exception: The use of a tool shall be permitted to access overcurrent devices located within listedindustrial control panels or similar enclosures.

Additional Proposed Changes

File Name Description Approved

CN_66.pdf 70_CN 66

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No.66 in the First Draft Report on First Revision No. 8638.

The Correlating Committee directs that this first revision be reviewed for clarity and grammar. “Circuit breakers and switches containing fuses” may be more appropriate language.

This action will be considered as a public comment.

Related Item

• FR 8638

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 13:37:20 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, CC on NEC-AAC, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am CC on NEC-AAC, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 946-NFPA 70-2018 [ Section No. 240.24(E) ]

(E) Not Located in Bathrooms.

In dwelling units, dormitory units, and guest rooms or guest suites, overcurrent devices, other thansupplementary overcurrent protection, shall not be located in bathrooms.

In other than dwelling units, overcurrent devices, other than supplementary overcurrent protection, shall notbe located in rooms with showering facilities.

Statement of Problem and Substantiation for Public Comment

Overcurrent protection devices are installed at the wet location outdoors all day and every day. Even so, showers mean no shoes, no clothes, almost guaranteed wet conditions and it would be best to prohibit overcurrent protective devices in these environments even if the panels were 110.28 compliant. The newer 210.8B7 does require GFCI protection for personnel in locker rooms with showering facilities.

Related Item

• 240.24E

Submitter Information Verification

Submitter Full Name: Norman Feck

Organization: State of Colorado

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 17:39:29 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Norman Feck, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Norman Feck, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 873-NFPA 70-2018 [ Section No. 240.33 ]

240.33 Vertical Position.

(A) Vertical Position.

Enclosures for overcurrent devices shall be mounted in a vertical position unless that is shown to beimpracticable.

(B) Horizontal Position.

Circuit breaker enclosures shall be permitted to be installed horizontally where the circuit breaker isinstalled in accordance with 240.81. Listed busway plug-in units shall be permitted to be mounted inorientations corresponding to the busway mounting position.

(C) Face-Up Position.

Panelboards shall not be installed in the face-up position.

Additional Proposed Changes

File Name Description Approved

CN_67.pdf 70_CN 70

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 67 in the First Draft Report on First Revision No. 8669.

The Correlating Committee directs that this First Revision be reconsidered with regard to the section title. The title of 240.33 is no longer applicable after the revisions to the first level subdivisions.

This action will be considered as a public comment.

The Correlating Committee directs that this FR be forwarded to CMP 1 and 9 for information.

Related Item

• FR 8669

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 14:03:38 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, CC on NEC-AAC, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am CC on NEC-AAC, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 875-NFPA 70-2018 [ Section No. 240.33 ]

240.33 Vertical Position.

(A) Vertical Position.

Enclosures for overcurrent devices shall be mounted in a vertical position unless that is shown to beimpracticable.

(B) Horizontal Position.

Circuit breaker enclosures shall be permitted to be installed horizontally where the circuit breaker isinstalled in accordance with 240.81. Listed busway plug-in units shall be permitted to be mounted inorientations corresponding to the busway mounting position.

(C) Face-Up Position.

Panelboards shall not be installed in the face-up position.

Additional Proposed Changes

File Name Description Approved

CN_67.pdf 70_CN 67

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 67 in the First Draft Report on First Revision No. 8669.

The Correlating Committee directs that this First Revision be reconsidered with regard to the section title. The title of 240.33 is no longer applicable after the revisions to the first level subdivisions.

This action will be considered as a public comment.

The Correlating Committee directs that this FR be forwarded to CMP 1 and 9 for information.

Related Item

• FR 8669

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 14:08:04 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, CC on NEC-AAC, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am CC on NEC-AAC, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

National Fire Protection Association Report https://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPar...

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Public Comment No. 876-NFPA 70-2018 [ Section No. 240.33 ]

240.33 Vertical Position.

(A) Vertical Position.

Enclosures for overcurrent devices shall be mounted in a vertical position unless that is shown to beimpracticable.

(B) Horizontal Position.

Circuit breaker enclosures shall be permitted to be installed horizontally where the circuit breaker isinstalled in accordance with 240.81. Listed busway plug-in units shall be permitted to be mounted inorientations corresponding to the busway mounting position.

(C) Face-Up Position.

Panelboards shall not be installed in the face-up position.

Additional Proposed Changes

File Name Description Approved

CN_67.pdf 70_CN 67

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 67 in the First Draft Report on First Revision No. 8669.

The Correlating Committee directs that this First Revision be reconsidered with regard to the section title. The title of 240.33 is no longer applicable after the revisions to the first level subdivisions.

This action will be considered as a public comment.

The Correlating Committee directs that this FR be forwarded to CMP 1 and 9 for information.

Related Item

• FR 8669

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 14:09:32 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, CC on NEC-AAC, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am CC on NEC-AAC, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1386-NFPA 70-2018 [ Section No. 240.33(C) ]

(C) Face-Up Position.

Panelboards shall An overcurrent device(s) in a panelboard enclosure shall not be installed in the face-upposition.

Statement of Problem and Substantiation for Public Comment

Change Panelboard to An Overcurrent device(s) in a panelboard enclosure.

Panelboard orientation should fall under the purview of CMP 9. Overcurrent devices are clearly under the purview of CMP 10. This revised text will address the concerns of CMP 10 by effectively preventing the installation of panelboards in the face-up position as no overcurrent devices would be allowed on such a panelboard.

This revised text maintains CMP 9 purview of panelboards and CMP 10 purview of overcurrent devices.

Related Item

• FR 8669

Submitter Information Verification

Submitter Full Name: David Clements

Organization: Intl Assoc Elec Insp

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 27 17:21:07 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, David Clements, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am David Clements, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1828-NFPA 70-2018 [ Section No. 240.33(C) ]

(C) Face-Up Position.

Panelboards Overcurrent devices in panelboard enclosures shall not be installed in the face-up position.

Statement of Problem and Substantiation for Public Comment

Panelboard orientation should fall under the purview of CMP 9. Overcurrent devices are clearly under the purview of CMP 10. The revised text will address the concerns of CMP 10 by effectively preventing the installation of panelboards in the face-up position as no overcurrent devices would be allowed on such a panelboard. This approach has been used before by CMP 10 most notably in section 240.24(D) where the prohibition of overcurrent devices in the vicinity of easily ignitable material, such as in clothes closets effectively restricts panelboards from these locations.

Related Item

• FR 8669

Submitter Information Verification

Submitter Full Name: David Humphrey

Organization: County of Henrico Virginia

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 09:25:30 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, David Humphrey, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am David Humphrey, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 524-NFPA 70-2018 [ Section No. 240.33(C) ]

(C) Face-Up Position.

Panelboards Enclosures for overcurrent devices shall not be installed in the face-up position.

Statement of Problem and Substantiation for Public Comment

The submitter of this Public Comment is in great support of this probation of panelboards NOT being installed in the face-up position. However, this proposed requirement seem to be in the wrong Article.The appropriate location for this restriction for panelboards is Article 408, not Article 240 for overcurrent devices. At this stage of the game (comment stage), I think it is too late to re-locate this restriction for panelboards to Article 408 (new material).. At this comment stage, I think the best solution is to match the current language at 230.33 in the 2017 NEC and the proposed language at 240.33(A) for the 2020 NEC First Draft. Additionally, using the term "enclosures for overcurrent devices" rather than "panelboard" will make it clear that this probation applies equally to circuit breaker and fuse enclosures.

Related Item

• 240.33(C) • FR-8669

Submitter Information Verification

Submitter Full Name: L. Keith Lofland

Organization: IAEI

Affiliation: Self

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 10 10:37:04 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, L. Keith Lofland, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am L. Keith Lofland, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 807-NFPA 70-2018 [ Section No. 240.33(C) ]

(C) Face-Up Position.

Panelboards Overcurrent devices in panelboards shall not be installed in the face-up position.

Statement of Problem and Substantiation for Public Comment

Article 240 for Overcurrent protection and the present wording does not correctly address overcurrent devices.

Related Item

• FR8669

Submitter Information Verification

Submitter Full Name: David Williams

Organization: Delta Charter Twp

Street Address:

City:

State:

Zip:

Submittal Date: Sat Aug 18 08:18:05 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, David Williams, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am David Williams, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 981-NFPA 70-2018 [ New Section after 240.61 ]

240.62 Reconditioned Equipment. Low voltage fuseholders and low voltage non-renewablefuses shall not be permitted to be reconditioned.

Additional Proposed Changes

File Name Description Approved

NEMA-Position_Refubishing_on_ElecEquip.pdf

Statement of Problem and Substantiation for Public Comment

This public comment is submitted by an NEC Correlating Committee appointed task group to address the global impacts of PI 2935. This PI would have required that “Reconditioned Equipment” be “listed as “reconditioned” and the “original listing marks removed”. This PI has ramifications that are global in nature and impacts all products referenced in the NEC under the purview of every CMP.

This proposed new section is safety-driven and is necessary to prevent the reconditioning of products that cannot be reconditioned, . This public comment is based on the global impact of public input 2935 and does not represent new material.

The “NEMA Policy on Reconditioned Electrical Equipment” is attached to this public comment. See also global public comment 979.The substantiation for global public comment 979 is provided below:

Public Comment No. 979-NFPA 70-2018 [Global Input]

This Public Comment is submitted on behalf of a task group appointed by the NEC® Correlating Committee. This Task Group was appointed to review the use of refurbished equipment throughout the NEC®. Task Group members are Jim Dollard, Robert Osborne, Jim Pierce, and David Williams. This task group has been charged with reviewing Public Input (PI) 2935 which was resolved by CMP-1 during the first draft stage. This PI would have required that “Reconditioned Equipment” be “listed as “reconditioned” and the “original listing marks removed”. This PI has ramifications that are global in nature and impacts all products referenced in the NEC under the purview of every CMP.

Task group members noted that some types of equipment are capable of being reconditioned, then re-evaluated to ensure compliance with the applicable product standards. Other types of equipment do not lend themselves to reconditioning due to the complexity of the product, the manufacturing process, or the level of knowledge the company performing the reconditioning may need, etc.

The “NEMA Policy on Reconditioned Electrical Equipment” details the following aspects of Reconditioning of Electrical Equipment:

• Fundamental Tenets for Reconditioning Electrical Equipment• Electrical Infrastructure and Worker Safety• Integrity of Reconditioned Equipment• Listing or Certification Marks• UL Guidance on the UL Mark• Components or Assemblies Not Suitable For Reconditioning (Appendix A)• Components or Assemblies Which May Be Reconditioned (Appendix B)

A PDF copy of this NEMA policy is attached and may also be found on the internet at the following URL: https://www.nema.org/Policy/Documents/NEMA-Position_Refubishing%20on%20ElecEquip.pdf

NEC® Section 110.21(A)(2), which was new for the 2017 Edition of the NEC®, included marking requirements for “Reconditioned Equipment”. PI 2935 would have required that “Reconditioned Equipment” be “listed as “reconditioned” and the “original listing marks removed”. CMP 1 resolved this PI. This Task Group appointed by the NEC® Correlating Committee has developed a number of public comments, based on the products identified in

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the referenced NEMA document, to determine whether or not equipment can be reconditioned, and if reconditioned, what additional requirements apply.

While several public comments were developed for specific equipment by this task group, not all equipment was addressed (neither was all the equipment noted in the NEMA Policy document addressed). This Global Public Comment requests each CMP to review the products required to be listed under their purview and determine whether reconditioning should be permitted. It is recommended that the NEMA Policy document be used as one of the guidelines in making this determination. It is also recommended that one of the following options/examples be chosen for listed equipment:

Option 1 - Equipment NOT suitable for Reconditioning (EXAMPLE):

695.10 Listed Equipment. Diesel engine fire pump controllers, electric fire pump controllers, electric motors, fire pump power transfer switches, foam pump controllers, and limited service controllers shall be listed for fire pump service. [20:9.5.1.1, 10.1.2.1, 12.1.3.1]Fire pump controllers and transfer switches shall not be permitted to be reconditioned.

Option 2 - Equipment which MAY BE suitable for Reconditioning (EXAMPLE):

408.8 Reconditioned Equipment.(A) Panelboards. The use of reconditioned panelboards shall comply with (1) and (2):(1) Industrial and commercial panelboards shall be permitted to be reconditioned. Reconditioned equipment shall be listed as “reconditioned” and the original listing mark removed.(2) Panelboards installed in dwelling units shall not be permitted to be reconditioned.(B) Switchboards and Switchgear. Low voltage switchgear, medium voltage switchgear and switchboards shall be permitted to be reconditioned. Reconditioned equipment shall be listed as “reconditioned” and the original listing mark removed.

Note that equipment where no specific guidance is provided would be permitted to be reconditioned and would only be required to meet the marking requirements in 110.21(A)(2).

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 979-NFPA 70-2018 [Global Input]

Public Comment No. 980-NFPA 70-2018 [New Section after 240.87(B)]

Public Comment No. 982-NFPA 70-2018 [New Section after 240.101(B)]

Public Comment No. 983-NFPA 70-2018 [Section No. 695.10]

Public Comment No. 984-NFPA 70-2018 [Section No. 700.5(C)]

Public Comment No. 985-NFPA 70-2018 [Section No. 701.5(C)]

Public Comment No. 986-NFPA 70-2018 [Section No. 702.5]

Public Comment No. 987-NFPA 70-2018 [New Section after 408.7]

Public Comment No. 979-NFPA 70-2018 [Global Input]

Public Comment No. 980-NFPA 70-2018 [New Section after 240.87(B)]

Public Comment No. 982-NFPA 70-2018 [New Section after 240.101(B)]

Public Comment No. 983-NFPA 70-2018 [Section No. 695.10]

Public Comment No. 984-NFPA 70-2018 [Section No. 700.5(C)]

Public Comment No. 985-NFPA 70-2018 [Section No. 701.5(C)]

Public Comment No. 986-NFPA 70-2018 [Section No. 702.5]

Public Comment No. 987-NFPA 70-2018 [New Section after 408.7]

Related Item

• PI 2935

Submitter Information Verification

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Submitter Full Name: James Dollard

Organization: IBEW Local Union 98

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 21 08:54:50 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, James Dollard, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am James Dollard, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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NEMA Policy on Reconditioned Electrical Equipment Executive Summary: The option of reconditioning existing equipment (instead of purchasing new equipment) exists today. Proper electrical equipment reconditioning provides a means to extend the life of electrical products as well as an opportunity in some cases to update installed equipment with the latest performance and safety features. However, not all components of the electrical infrastructure are candidates for reconditioning. There are a number of precautions that must be adhered to when reconditioning electrical equipment if that equipment is to operate safely and with acceptable performance. Those precautions are discussed below and include the use of design qualified parts, testing to industry-recognized safety standards, original manufacturer specification and/or recommendations, when possible, and reconditioning performed by qualified personnel. The integrity of reconditioned electrical equipment must be established by documenting and demonstrating that component replacement has not compromised the manufacturer’s original specifications and accepted industry standards. The third party certification mark must be removed or obliterated from reconditioned electrical products to indicate that an evaluation of the reconditioning process or reconditioned product has not been conducted by the original third party. As guidance, Appendix B provides a list of electrical products and components that are considered by NEMA suitable for reconditioning and Appendix A provides a list of electrical products considered not suitable for reconditioning. Medical Imaging Equipment is specifically not addressed by this policy (reference MITA 1, Good Refurbishment Practices for Medical Imaging Equipment). Introduction: The U.S. electrical industry includes discussions on implementing new technologies to enhance existing electrical infrastructure. Further, sustainability and safeguarding the environment are growing in importance. In the midst of this is the option for reconditioning existing equipment. Paramount in all this is the fundamental priority that all electrical systems operate while safe-guarding personnel and infrastructure from potential hazards (electrical, mechanical, fire, etc.). This forms the basis for the NEMA position on reconditioning electrical products. Given that electrical systems are diverse in design, function, and application, not all components of the electrical infrastructure are candidates for reconditioning. Definition:

Reconditioning: the process of restoring electromechanical systems, equipment, apparatus or components to operating conditions as recommended by the

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manufacturer’s instructions, using only design qualified parts. Reverse engineered parts (designs copied from existing parts by other manufacturers) are not considered to be “design qualified parts” unless specifically design verified under applicable Standards. Electrical industry practitioners and other organizations may also use the following terms/words to describe the process of reconditioning: remanufacturing, refurbishing, recycling, repairing, restoring, rebuilding, reengineering, and reusing.

In addition to design considerations, it is often impossible to obtain the service records, application environment, and operation parameters of all electrical components. Not having access to such information could have an adverse impact on the final safety and reliability of refurbished or reconditioned equipment. While NEMA supports the reconditioning of some electrical equipment, the components listed in Appendix A are not recommended for reconditioning, unless otherwise indicated by the original manufacturer. Normal servicing of equipment that remains within a facility should not be considered reconditioning or refurbishing. For electrical components suitable for reconditioning listed in Appendix B, the following fundamental tenets have been established. Fundamental Tenets for Reconditioning Electrical Equipment

Reconditioning electrical equipment may be a viable option for extending operational lifetime of equipment and enhancing equipment with additional features.

Electrical equipment reconditioning activity must be based on available guidance documentation from the Original Equipment Manufacturer, or industry-developed standards. Where any conflict in guidance is noted between the OEM and industry standards, the OEM guidance should take precedence. 

Electrical equipment must be reconditioned and qualified to an industry-developed standard that ensures equipment is in a usable and safe operating condition. An industry-developed standard is a widely agreed upon rule, set of rules, procedures or requirements for a product, assembly or process which are developed by members or organizations of an aggregate of manufacturing and technically productive enterprises in a particular field. Products deemed to be candidates for reconditioning must be reconditioned and qualified to industry standards containing the most relevant and critical design aspects, testing criteria and manufacturing specifications when the item was built.

Reconditioning work must be performed by qualified personnel. Electrical equipment that has been exposed to adverse conditions, such as fire,

water damage, etc., may not be suitable for reconditioning. A comprehensive assessment of the electrical equipment being considered for

reconditioning with service records, application, environment, service life, and operating parameters is critical before deciding to pursue reconditioning of the electrical equipment and system. Trained, skilled technicians should be able to assess whether a device or system is suitable for reconditioning through physical inspection and test.

Appendix A provides guidance on which components or assemblies of the electrical system are not suitable for reconditioning because they may pose a

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hazard. Appendix B provides guidance on the components or assemblies are suitable for reconditioning.

Reconditioning electrical equipment must utilize electrical product safety standards as they contain design aspects, testing criteria and manufacturing specifications to ensure a given product will function as intended. These requirements are established to deliver a usable and safe operating condition as a key component of intended product functionality.

Electrical Infrastructure and Worker Safety

Electrical equipment that is properly installed, tested, maintained, and operated will provide reliable power as well as protect the electrical infrastructure. The reconditioning of electrical equipment requires the electrical industry, in collaboration with manufacturers, to establish performance specifications and accepted industry standards to help ensure safe and reliable equipment that help protect our electrical infrastructure so workers and users can continue to benefit from a safe and effective electrical system. Reconditioning standards must include prescriptive actions and performance requirements that result in equipment that complies with standards that include but are not limited to CSA, IEC, IEEE, NEC, OSHA, NFPA 70E, NFPA 70B, NETA ATS, NETA MTS, and EASA AR100 for example. Qualified personnel must possess the knowledge of how to assess equipment condition, potential hazards, and specifications to accurately determine the suitability for reconditioning. A safe and reliable electrical infrastructure that can be safely maintained is dependent on compliance with manufacturers’ instructions, qualified workers, proper maintenance, and accepted industry standards for reconditioning activities. Electrical Equipment Reliability, Performance and Safety

Proper electrical equipment reconditioning provides a means to extend the life of electrical products as well as an opportunity to update installed equipment with the latest performance and safety features. Establishing well defined guidelines for those performing the reconditioning activity, based on original manufacturer’s requirements, creates a solid foundation for the electrical industry and users. It is paramount that reconditioned electrical equipment be reliable in not only providing power, but also in safely performing its intended function as part of a safe operating electrical system. Understanding the environment, electrical load characteristics and historical maintenance performed on equipment being considered for reconditioning are all important parts of an assessment for reconditioning that can have a significant bearing on reliability, performance and safety. The electrical equipment manufacturer is the foremost authority on the design, performance and intended safe application of their product. Reconditioned electrical equipment must not compromise the reliability, performance, safe operation, or maintenance of the electrical system. Integrity of Reconditioned Equipment

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Reconditioned electrical equipment must comply with all applicable standards at the time the equipment was initially built as a minimum as well as the original manufacturer’s performance requirements in accordance with the nameplate markings and ratings. Replacement parts shall meet the design criteria (form, fit, and function) for the device to perform its intended function and provide safe operation. Replacement parts shall not include counterfeit parts (i.e., parts that have been misrepresented to be an authorized item of the legally authorized source.) Equipment shall operate safely in its intended application after reconditioning occurs. Care must be taken to ensure specific operations such as timing, sequencing, control, transfer, etc. continue to function in the manner originally intended, unless changes are specified during the reconditioning process. The integrity of reconditioned electrical equipment must be established by documenting and demonstrating that component replacement and performance changes have not compromised the manufacturer’s specifications and accepted industry standards. Listing or Certification Marks

NEMA members manufacture products that are more than likely to be evaluated as part of a third party certification program to nationally recognized safety standards. These products can be marked with a listing or certification mark when the products are manufactured and shipped from the factory. The organization that reconditions the product is responsible for adhering to the guidelines from the issuing agency authorizing the mark to determine if the mark can remain on the product after reconditioning. The organization that reconditions is responsible for any actions necessary for the mark to remain on the product (analysis, testing, etc.). Otherwise, reconditioned electrical products must have their mark removed or obliterated to indicate that an evaluation of the reconditioning process has not been conducted by the original third party. The organization that reconditions the product is additionally responsible for applying a mark or seal that indicates that the equipment has been reconditioned. This mark must provide traceability to the reconditioning organization in the event that it is necessary to determine the details of who reconditioned the equipment and the report on what was completed during this process. There are a number of NEMA products that are not allowed to be reconditioned due to the inherent safety characteristics and requirements for those products to be evaluated according to a regular follow up program to evaluate the safety performance requirements as a condition of maintaining the listing or certification mark. This process cannot be applied to reconditioned electrical products since these are normally destructive tests and sample sets of reconditioned products are not possible due to limited quantities or ratings of specific devices. UL Guidance on the UL Mark When the manufacturer places the UL Mark on the product at the factory, it is their attestation that the product complies with the applicable requirements. Unless there is further oversight or review/inspection (field inspection) UL cannot ascertain that the

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product continues to comply with all requirements should field repairs, modifications or component replacements be made to the product. Obviously there is little control over what manufacturers will or can do to equipment which left the factory with a certification mark. UL has created rebuilt categories where the reconditioning of product is done in an organized consistent manner under the supervision of UL’s FUS (Follow-Up Services) field representatives. In these cases the first action conducted with equipment being rebuilt is the removal of the initial certification mark (if provided). Upon completion of the reconditioning, in accordance with the surveillance document, the manufacturer is permitted to affix a mark which clearly identifies the product as reconditioned.

Cases where a reconditioner is instructed to NOT remove any certification mark will result in confusion. Clearly such equipment in the field, which has undergone modification or reconditioning, is ineligible to bear a mark which designates a compliance with a certification standard.

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APPENDIX A

COMPONENTS OR ASSEMBLIES NOT SUITABLE FOR RECONDITIONING* Adjustable speed drives Arc fault circuit breakers Ballasts Busway (mylar wrapped) Busway (powder coated) Cable tray Cast resin transformers Components containing semiconductors and transistors Control transformers Dry type transformers Electrical Connectors Electrical submetering equipment Electrical vehicle supply equipment Enclosed switches Fire detectors, smoke alarms, co detectors Fire pump controllers Flexible and extension cords Flexible conduit Ground fault circuit breakers High performance wire and cable Lighting controls Liquid filled transformers Low and medium voltage fuse holders Low and medium voltage non-renewable fuses Low voltage power circuit breaker electronic trip units Luminaires Meters (electromechanical, electronic or digital) Meter sockets Molded case circuit breakers Non-Metallic conduit, tubing, raceways and fittings Non-metallic surface raceways and fittings Outlet and junction boxes Overload relays Pin and sleeve plugs receptacles and connectors Power and control cable Protective relays (electronic or digital) Residential panel boards Solid state contactors and starters Solid state drives Strut type channel raceway Surface metal raceways and fittings Surge protective devices Transfer switches Wire or cable Wireway Wiring devices

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*The components or products listed above are not recommended for reconditioning, unless otherwise indicated by the original manufacturer.

APPENDIX B

COMPONENTS OR ASSEMBLIES WHICH MAY BE RECONDITIONED Electromechanical protective relays, and current transformers High voltage circuit breakers Industrial and commercial panel boards Low and medium voltage power circuit breakers Low and medium voltage replaceable link fuses Low voltage switchgear Manual and magnetic controllers Medium voltage switchgear Metallic conduit, tubing, raceways and fittings Motor control centers Motors Switchboards Uninterruptible Power Supply Equipment

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Public Comment No. 1383-NFPA 70-2018 [ Section No. 240.67 ]

240.67 Arc Energy Reduction.

Where energized work is permitted and where fuses rated 1200 A or higher are installed, 240.67(A) and(B) shall apply. This requirement shall become effective January 1, 2020.

(A) Documentation.

Documentation shall be available to those authorized to design, install, operate, or inspect the installationas to the location of the fuses.

(B) Method to Reduce Clearing Time.

A fuse shall have a clearing time of 0.07 seconds or less at the available arcing current, or one of thefollowing shall be provided:

(1) Differential relaying

(2) Energy-reducing maintenance switching with local status indicator

(3) Energy-reducing active arc flash mitigation system

(4) Current-limiting, electronically actuated fuses

(5) An approved equivalent means

Informational Note No. 1: An energy-reducing maintenance switch allows a worker to set adisconnect switch to reduce the clearing time while the worker is working within an arc-flashboundary as defined in NFPA 70E-2018, Standard for Electrical Safety in the Workplace, and then toset the disconnect switch back to a normal setting after the potentially hazardous work is complete.

Informational Note No. 2: An energy-reducing active arc flash mitigation system helps in reducingarcing duration in the electrical distribution system. No change in the disconnect switch or thesettings of other devices is required during maintenance when a worker is working within an arc flashboundary as defined in NFPA 70E-2018, Standard for Electrical Safety in the Workplace.

Informational Note No. 3: IEEE 1584-2002, IEEE Guide for Performing Arc Flash HazardCalculations, is one of the available methods that provides guidance in determining arcing current.

Informational Note No. 4: NFPA 70E - 2018, Standard for Electrical Safety in the Workplace, onlypermits energized work when specific conditions exist. Generally, these conditions are when de-energizing the circuit will introduce additional hazards/risks or a task to be performed is infeasible ina de-energized state due to equipment design or operational limits.

Statement of Problem and Substantiation for Public Comment

NFPA 70E - 2018, Standard for Electrical Safety in the Workplace, identifies one method (and only one method) to establish an electrically safe working condition. It is to turn off all sources of power and apply lockout/tagout. In the majority of circuits where fuses are used, lockout/tagout can always be used. Almost all commercial, residential, restaurant and retail buildings fall in this category. A shutdown can be scheduled for any work on a circuit directly protected by a fuse rated 1200 amp or larger.

The inspection of an arc energy reduction system creates a liability for the AHJ, as it will require the examination of arc flash sensors to verify their proper placement for anticipated energized work. Evaluating the sensor placement may be a science of its own, since no one can predict where an arc flash event may occur. This liability to the AHJ should only exist on installations where energized work is permitted.

Informational Note No. 4 is added to help define energized work. It will provide guidance as to when an arc energy reduction method should be installed.

NFPA 70E – 2018, Article 120, requires a Lockout/Tagout Program for each employer. Adding an arc energy reduction method on any installation where lockout/tagout is always to be performed will serve no purpose. When the circuit is off, the methods identified in 240.67(B) cannot function because the device feeding the circuit is already off (and locked in the off position).

Providing an arc energy reduction method on an installation that should always use lockout/tagout would

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unnecessarily increase cost, and would likely increase injuries. Lockout/Tagout procedures are well-proven as the industry standard for safety, and should not be diminished by encouraging energized work when lockout/tagout should be used.

Related Item

• Opening sentence and Informational Note 4.

Submitter Information Verification

Submitter Full Name: James Erickson

Organization: Boltswitch Inc

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 27 16:50:28 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, James Erickson, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am James Erickson, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 2161-NFPA 70-2018 [ Section No. 240.67 ]

240.67 Arc Energy Reduction.

Where fuses rated 1200 A or higher are installed, 240.67(A) and (B) shall apply. This requirement shallbecome effective January 1, 2020.

(A) Documentation.

Documentation shall be available to those authorized to design, install, operate, or inspect the installationas to the location of the fuses.

(B) Method to Reduce Clearing Time.

A fuse shall have a clearing time of 0.07 seconds or less at the available arcing current, or one of thefollowing shall be provided:

(1) Differential relaying

(2) Energy-reducing maintenance switching with local status indicator

(3) Energy-reducing active arc flash mitigation system

(4) Current-limiting, electronically actuated fuses

(5) An approved equivalent means

Informational Note No. 1: An energy-reducing maintenance switch allows a worker to set adisconnect switch to reduce the clearing time while the worker is working within an arc-flashboundary as defined in NFPA 70E -2018, Standard for Electrical Safety in the Workplace , and thento set the disconnect switch back to a normal setting after the potentially hazardous work iscomplete.

Informational Note No. 2: An energy-reducing active arc flash mitigation system helps in reducingarcing duration in the electrical distribution system. No change in the disconnect switch or thesettings of other devices is required during maintenance when a worker is working within an arcflash boundary as defined in NFPA 70E -2018, Standard for Electrical Safety in the Workplace .

Informational Note No. 3: IEEE 1584-2002, IEEE Guide for Performing Arc Flash HazardCalculations , is one of the available methods that provides guidance in determining arcing current.

(C) Performance Testing. The arc energy reduction system shall be performance tested when first installedon site. This testing shall be conducted by a qualified person(s) using a test process of primary currentinjection, in accordance with instructions that shall be provided with the equipment. A written record of thistesting shall be made available to the AHJ.

Statement of Problem and Substantiation for Public Comment

Arc energy reduction systems are being installed in equipment and the general electrical industry does not understand or know how to set up and test these systems. The electrical worker is relying on the safety these system promise to provide, and the lack of performance testing is creating a hazardous situation for many workers.

Related Item

• PI 4345

Submitter Information Verification

Submitter Full Name: Howard Herndon

Organization: National Field Services

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 21:21:34 EDT 2018

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Committee: NEC-P10

Copyright Assignment

I, Howard Herndon, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Howard Herndon, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1269-NFPA 70-2018 [ New Section after 240.67(B) ]

(C) Performance Testing. The arc energy reduction system shall be performance tested whenfirst installed on site. This testing shall be conducted by a qualified person(s) in accordance withmanufacturer's instructions.

Performance testing of an instantaneous element of the protective device shall be conducted by aqualified person(s) using a test process of primary current injection and manufacturer'srecommended test procedures.

A written record of this testing shall be made and shall be available to the authority havingjurisdiction.

Statement of Problem and Substantiation for Public Comment

This public input seeks to require performance testing of the arc energy reduction system installed as required by 240.67. It is both practical and feasible to require such testing at the time of installation. The inclusion of performance testing criteria is not new in the NEC. See 210.13, 215.10 and 230.95 which mandate performance testing of required GFPE when first installed. The second sentence of the proposed text mandates that only qualified persons are permitted to perform this testing. Additionally, that sentence mandates that the manufacturer’s instructions be followed. That is extremely important as new technologies may not lend themselves well to traditional testing methods. The remainder of the proposed text mirrors that seen in 230.95.

Related Item

• PI 3144

Submitter Information Verification

Submitter Full Name: James Dollard

Organization: IBEW Local Union 98

Street Address:

City:

State:

Zip:

Submittal Date: Sat Aug 25 07:28:23 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, James Dollard, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am James Dollard, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1176-NFPA 70-2018 [ Section No. 240.67(B) ]

(B) Method to Reduce Clearing Time.

A fuse shall have a clearing time of 0.07 seconds or less at the available arcing current, or one of thefollowing shall be provided:

(1) Differential relaying

(2) Energy-reducing maintenance switching with local status indicator

(3) Energy-reducing active arc flash mitigation system

(4) Current-limiting, electronically actuated fuses

(5) An approved equivalent means

Exception: The arc energy reduction provisions of this section shall not be allowed for fuses that feed firepumps.

Informational Note No. 1: An energy-reducing maintenance switch allows a worker to set adisconnect switch to reduce the clearing time while the worker is working within an arc-flashboundary as defined in NFPA 70E-2018, Standard for Electrical Safety in the Workplace, and then toset the disconnect switch back to a normal setting after the potentially hazardous work is complete.

Informational Note No. 2: An energy-reducing active arc flash mitigation system helps in reducingarcing duration in the electrical distribution system. No change in the disconnect switch or thesettings of other devices is required during maintenance when a worker is working within an arc flashboundary as defined in NFPA 70E-2018, Standard for Electrical Safety in the Workplace.

Informational Note No. 3: IEEE 1584-2002, IEEE Guide for Performing Arc Flash HazardCalculations, is one of the available methods that provides guidance in determining arcing current.

Statement of Problem and Substantiation for Public Comment

It is well documented that an arc flash event can release sparks and molten metal equal to temperatures on the sun. Surely an arc flash event can start a fire. In the event of a fire, it is imperative that fire pumps remain energized so they can function. An arc flash event is bad. A worker’s life is endangered. But that worker understands the risks, draws a permit for the task, and is required to wear appropriate PPE. A fire can be far worse. It can cause much more damage, and can endanger the lives of many unsuspecting people.

Article 695 has special requirements for fire pumps. 695.4(B)(2) addresses overcurrent protection. Fuses must be oversized to the extent that they will not open unless considerable time has passed. 695.4(B)(3) addresses the disconnect means. Item (a)(2) states that all disconnecting devices that are unique to the fire pump loads must be lockable in the closed position. The methods identified in 240.67(B) cannot function on a disconnecting device that is locked in the closed position. Applying the requirements of 240.67 to fuses and/or disconnecting devices that feed fire pumps will defeat the special requirements spelled out in Article 695 to keep the circuit energized.

Related Item

• Exception to 240.67(B)

Submitter Information Verification

Submitter Full Name: James Erickson

Organization: Boltswitch Inc

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 10:06:30 EDT 2018

Committee: NEC-P10

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Copyright Assignment

I, James Erickson, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am James Erickson, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1202-NFPA 70-2018 [ Section No. 240.67(B) ]

(B) Method to Reduce Clearing Time.

A fuse shall have a clearing time of 0.07 seconds 12 seconds or less at the for all available arcingcurrent currents , or one of the following shall be provided. For (1), (2), or (3), the total clearing time for allavailable arcing currents shall be 0.12 seconds or less :

(1) Differential relaying

(2) Energy-reducing maintenance switching with local status indicator

(3) Energy-reducing active arc flash mitigation system

(4) Current-limiting, electronically actuated fuses

(5) An approved equivalent means

Informational Note No. 1: An energy-reducing maintenance switch allows a worker to set adisconnect switch to reduce the clearing time while the worker is working within an arc-flashboundary as defined in NFPA 70E-2018, Standard for Electrical Safety in the Workplace, and then toset the disconnect switch back to a normal setting after the potentially hazardous work is complete.

Informational Note No. 2: An energy-reducing active arc flash mitigation system helps in reducingarcing duration in the electrical distribution system. No change in the disconnect switch or thesettings of other devices is required during maintenance when a worker is working within an arc flashboundary as defined in NFPA 70E-2018, Standard for Electrical Safety in the Workplace.

Informational Note No. 3: IEEE 1584-2002, IEEE Guide for Performing Arc Flash HazardCalculations, is one of the available methods that provides guidance in determining arcing current.

Statement of Problem and Substantiation for Public Comment

Public Input 3351 should have been accepted.

The edit to "for all available arcing currents" in the first sentence is to clarify that the clearing time must must meet stated criteria for all available arcing currents and not just some. While fuses have very fast clearing times for sufficiently high currents, then can have significantly longer clearing times for lower currents.

The edit to allow 0.12 seconds clearing time for either a fuse or options (1) (2) or (3) is intended to clarify that a device that provides an instantaneous trip for all available arcing currents to a typical bolted pressure switch is an acceptable means of meeting this requirement. Bolted pressure switches require 6-7 cycles at 60 Hz including instantaneous relaying time to clear a fault, or 0.100 to 0.117 seconds. These values were confirmed by a bolted pressure switch manufacturer in a public comment and testimony to CMP-10 during the previous code cycle. And if for example a fuse has a clearing time of 0.10 seconds for the minimum arcing current, it would not make sense to require an energy reducing maintenance switch (ERMS) or other device with a clearing time of 0.12 seconds, so the limit is proposed to be the same for a fuse as for an ERMS or other approved device.

Related Item

• Public Input No. 3351

Submitter Information Verification

Submitter Full Name: Roy Sparks

Organization: Eli Lilly and Company

Affiliation: ACC

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 11:54:41 EDT 2018

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Committee: NEC-P10

Copyright Assignment

I, Roy Sparks, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Roy Sparks, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 54-NFPA 70-2018 [ Section No. 240.67(B) ]

(B) Method to Reduce Clearing Time Obtain Arc Energy Reduction .

A fuse shall have a clearing time of 0.07 seconds or less at the available arcing current, or one of thefollowing shall be provided:

(1) Differential relaying

(2) Energy-reducing maintenance switching with local status indicator

(3) Energy-reducing active arc flash mitigation system

(4) Current-limiting, electronically actuated fuses

(5) An approved equivalent means

Informational Note No. 1: An energy-reducing maintenance switch allows a worker to set adisconnect switch to reduce the clearing time while the worker is working within an arc-flashboundary as defined in NFPA 70E-2018, Standard for Electrical Safety in the Workplace, and then toset the disconnect switch back to a normal setting after the potentially hazardous work is complete.

Informational Note No. 2: An energy-reducing active arc flash mitigation system helps in reducingarcing duration in the electrical distribution system. No change in the disconnect switch or thesettings of other devices is required during maintenance when a worker is working within an arc flashboundary as defined in NFPA 70E-2018, Standard for Electrical Safety in the Workplace.

Informational Note No. 3: IEEE 1584-2002, IEEE Guide for Performing Arc Flash HazardCalculations, is one of the available methods that provides guidance in determining arcing current.

Statement of Problem and Substantiation for Public Comment

The real intent of 240.67 is to reduce energy. One method to accomplish that is to reduce clearing time. Another method is to reduce the arcing current to which the employee is exposed. It’s more appropriate therefore for the title to call out a reduction of energy, which can be accomplished by either method.

Related Item

• • PI 1129

Submitter Information Verification

Submitter Full Name: Vince Baclawski

Organization: Nema

Street Address:

City:

State:

Zip:

Submittal Date: Wed Jun 27 14:53:35 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Vince Baclawski, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Vince Baclawski, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 479-NFPA 70-2018 [ Section No. 240.67 [Excluding any Sub-

Sections] ]

Where fuses Where enclosures for fuses rated 1200 A or higher are installed, 240.67(A) and (B) shallapply. This requirement shall become effective January 1, 2020.

Statement of Problem and Substantiation for Public Comment

The submitter of PI 426 is correct. The current wording would require the addition of arc energy reduction when a blown fuse is replaced as a new fuse would be installed in place of the blown one.

Related Item

• Public Input No. 426-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: Don Ganiere

Organization: [ Not Specified ]

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 08 19:53:08 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Don Ganiere, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Don Ganiere, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 480-NFPA 70-2018 [ Section No. 240.83(A) ]

(A) Durable and Visible.

Circuit breakers shall be marked with their ampere rating and the ambient temperature at which the ratingis listed to in a manner that will be durable and visible after installation. Such marking shall be permitted tobe made visible by removal of a trim or cover.

Statement of Problem and Substantiation for Public Comment

PI 3970 should have been accepted. Sometimes the only way to force a change in the product standards is for the code to require it. The temperature rating is important information and often is not visible even after the trim cover has been removed.

Related Item

• Public Input No. 3970-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: Don Ganiere

Organization: [ Not Specified ]

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 08 20:00:39 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Don Ganiere, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Don Ganiere, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 789-NFPA 70-2018 [ Section No. 240.86(A) ]

(A) Selected Under Engineering Supervision in Existing Installations.

The series rated combination devices shall be selected by a licensed professional engineer engagedprimarily in the design or maintenance of electrical installations. The selection shall be documented andstamped by the professional engineer. This documentation shall be available to those authorized to design,install, inspect, maintain, and operate the system. This series combination rating, including identification ofthe upstream device, shall be field marked on the end use equipment.

For calculated applications, the engineer shall ensure that the downstream circuit breaker(s) that are part ofthe series combination remain passive during the interruption period of the line side fully rated, current-limiting device.

Equipment enclosures for circuit breakers or fuses applied in compliance with series combination ratingsselected under engineering supervision shall be legibly marked in the field as directed by the engineer toindicate the equipment has been applied with a series combination rating. The marking shall meet therequirements in 110.21(B) and shall be readily visible and state the following:

CAUTION - ENGINEERED SERIES COMBINATION SYSTEM RATED ______ AMPERES. IDENTIFIEDREPLACEMENT COMPONENTS REQUIRED.

Statement of Problem and Substantiation for Public Comment

This Input was rejected stating it shall remain in NEC 110. However, this labeling is not referred from any other parts of the NEC and therefore not a general statement. This labeling is specific to 240.86 and would be better served here. Labeling is standarized throughout the NEC such as 700.7(B), 701.7(B), 408.3 has multiple labeling requirements such as (F)(2) labeling for a High leg "Caution _____ Phase Has ____ Volts to Ground. NEC 408.4(B) has labeling requirements as to where panels were fed from. Previous Substantiation below:The proposed additional language is currently found in 110.22(B) under Part I of Article 110 which provides general requirements. The marking required in this section is not general at all but is rather specific to one unique type of installation only mentioned in Section 240.86 of the NEC. It would make sense to have all requirements related to series rated electrical systems located in 240.86 including the marking requirements currently found in 110.22(B). A companion proposal will be sent to CMP 1 to delete the language from 110.22(B)

Related Item

• PI #3349 • PI #3349

Submitter Information Verification

Submitter Full Name: James Dorsey

Organization: Douglas County Electrical Insp

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 17 11:32:37 EDT 2018

Committee: NEC-P10

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Copyright Assignment

I, James Dorsey, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am James Dorsey, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 736-NFPA 70-2018 [ Section No. 240.86(B) ]

(B) Tested Combinations.

The combination of line-side overcurrent device and load-side circuit breaker(s) is tested and marked onthe end use equipment, such as switchboards and panelboards.

Equipment enclosures for circuit breakers or fuses applied in compliance with the series combinationratings marked on the equipment by the manufacturer shall be legibly marked in the field to indicate theequipment has been applied with a series combination rating. The marking shall meet the requirements in110.21(B) and shall be readily visible and state the following:

CAUTION - SERIES COMBINATION SYSTEM RATED ______ AMPERES. IDENTIFIEDREPLACEMENT COMPONENTS REQUIRED.

Informational Note to (A) and (B): See 110.22 for marking of series combination systems.

Statement of Problem and Substantiation for Public Comment

This Input was rejected stating it shall remain in NEC 110. However, this labeling is not referred from any other parts of the NEC and therefor not a general statement. This labeling is specific to 240.86 and would be better served in NEC 240.86. There are many examples in the NEC that would support this input. NEC 408.3 has multiple labeling requirements such as (F)(2) labeling for a High leg "Caution _____ Phase Has ____ Volts to Ground. NEC 408.4(B) has labeling requirements as to where panels were fed from.

Related Item

• PI #3348

Submitter Information Verification

Submitter Full Name: James Dorsey

Organization: Douglas County Electrical Insp

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 16 15:57:41 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, James Dorsey, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am James Dorsey, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1270-NFPA 70-2018 [ New Section after 240.87(B) ]

(C) Performance Testing. The arc energy reduction protection system shall be performancetested when first installed on site. This test shall be conducted by a qualified person(s) inaccordance with manufacturer's instructions.

When performance testing of an instantaneous trip setting specified in 240.87(B)(5) orinstantaneous override specified in 240.87(B)(6), this testing shall be conducted by a qualifiedperson(s) using a test process of primary injection and manufacturer's recommended testingprocedures.

A written record of this testing shall be made and shall be available to the authority havingjurisdiction.

Statement of Problem and Substantiation for Public Comment

This public input seeks to require performance testing of the arc energy reduction system installed as required by 240.87. It is both practical and feasible to require such testing at the time of installation. The inclusion of performance testing criteria is not new in the NEC. See 210.13, 215.10 and 230.95 which mandate performance testing of required GFPE when first installed. The second sentence of the proposed text mandates that only qualified persons are permitted to perform this testing. Additionally, that sentence mandates that the manufacturer’s instructions be followed. That is extremely important as new technologies may not lend themselves well to traditional testing methods. The remainder of the proposed text mirrors that seen in 230.95.

Related Item

• PI 3151

Submitter Information Verification

Submitter Full Name: James Dollard

Organization: IBEW Local Union 98

Street Address:

City:

State:

Zip:

Submittal Date: Sat Aug 25 07:52:48 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, James Dollard, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am James Dollard, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 980-NFPA 70-2018 [ New Section after 240.87(B) ]

240.88 Reconditioned Equipment. Reconditioned equipment shall be listed as “reconditioned”and the original listing mark removed.

(A) Circuit Breakers. The use of reconditioned circuit breakers shall comply with (1) through (3):

(1) Molded case, circuit breakers shall not be permitted to be reconditioned.

(2) Low, and medium voltage power circuit breakers shall be permitted to be reconditioned.

(3) High voltage circuit breakers shall be permitted to be reconditioned.

(B) Components.  The use of reconditioned trip units, protective relays and current transformersshall comply with (1) and (2):

(1) Low voltage power circuit breaker electronic trip units shall not be permitted to bereconditioned.

(2) Electromechanical protective relays and current transformers shall be permitted to bereconditioned. Reconditioned equipment shall be listed as “reconditioned” and the original listingmark removed.

Additional Proposed Changes

File Name Description Approved

NEMA-Position_Refubishing_on_ElecEquip.pdf

Statement of Problem and Substantiation for Public Comment

This public comment is submitted by an NEC Correlating Committee appointed task group to address the global impacts of PI 2935. This PI would have required that “Reconditioned Equipment” be “listed as “reconditioned” and the “original listing marks removed”. This PI has ramifications that are global in nature and impacts all products referenced in the NEC under the purview of every CMP.

This proposed new section is safety-driven and is necessary to: (1) prevent the reconditioning of products that cannot be reconditioned, (2) ensure that reconditioned equipment is properly evaluated to ensure a level of safety equal to the original equipment listing/labeling and (3) ensure that reconditioned equipment is marked to identify suitability for both installer/maintainers and the inspection community.

This public comment is based on the global impact of public input 2935 and does not represent new material.

The “NEMA Policy on Reconditioned Electrical Equipment” is attached to this public comment. See also global public comment 979.

The substantiation for global public comment 979 is provided below:

Public Comment No. 979-NFPA 70-2018 [Global Input]

This Public Comment is submitted on behalf of a task group appointed by the NEC® Correlating Committee. This Task Group was appointed to review the use of refurbished equipment throughout the NEC®. Task Group members are Jim Dollard, Robert Osborne, Jim Pierce, and David Williams. This task group has been charged with reviewing Public Input (PI) 2935 which was resolved by CMP-1 during the first draft stage. This PI would have required that “Reconditioned Equipment” be “listed as “reconditioned” and the “original listing marks removed”. This PI has ramifications that are global in nature and impacts all products referenced in the NEC under the purview of every CMP.

Task group members noted that some types of equipment are capable of being reconditioned, then re-evaluated to ensure compliance with the applicable product standards. Other types of equipment do not lend themselves to reconditioning due to the complexity of the product, the manufacturing process, or the level of knowledge the company performing the reconditioning may need, etc. The “NEMA Policy on Reconditioned Electrical Equipment” details the following aspects of Reconditioning of Electrical Equipment:

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• Fundamental Tenets for Reconditioning Electrical Equipment• Electrical Infrastructure and Worker Safety• Integrity of Reconditioned Equipment• Listing or Certification Marks• UL Guidance on the UL Mark• Components or Assemblies Not Suitable For Reconditioning (Appendix A)• Components or Assemblies Which May Be Reconditioned (Appendix B)

A PDF copy of this NEMA policy is attached and may also be found on the internet at the following URL: https://www.nema.org/Policy/Documents/NEMA-Position_Refubishing%20on%20ElecEquip.pdf

NEC® Section 110.21(A)(2), which was new for the 2017 Edition of the NEC®, included marking requirements for “Reconditioned Equipment”. PI 2935 would have required that “Reconditioned Equipment” be “listed as “reconditioned” and the “original listing marks removed”. CMP 1 resolved this PI. This Task Group appointed by the NEC® Correlating Committee has developed a number of public comments, based on the products identified in the referenced NEMA document, to determine whether or not equipment can be reconditioned, and if reconditioned, what additional requirements apply.

While several public comments were developed for specific equipment by this task group, not all equipment was addressed (neither was all the equipment noted in the NEMA Policy document addressed). This Global Public Comment requests each CMP to review the products required to be listed under their purview and determine whether reconditioning should be permitted. It is recommended that the NEMA Policy document be used as one of the guidelines in making this determination. It is also recommended that one of the following options/examples be chosen for listed equipment:

Option 1 - Equipment NOT suitable for Reconditioning (EXAMPLE):

695.10 Listed Equipment. Diesel engine fire pump controllers, electric fire pump controllers, electric motors, fire pump power transfer switches, foam pump controllers, and limited service controllers shall be listed for fire pump service. [20:9.5.1.1, 10.1.2.1, 12.1.3.1]Fire pump controllers and transfer switches shall not be permitted to be reconditioned.

Option 2 - Equipment which MAY BE suitable for Reconditioning (EXAMPLE):

408.8 Reconditioned Equipment.(A) Panelboards. The use of reconditioned panelboards shall comply with (1) and (2):(1) Industrial and commercial panelboards shall be permitted to be reconditioned. Reconditioned equipment shall be listed as “reconditioned” and the original listing mark removed.(2) Panelboards installed in dwelling units shall not be permitted to be reconditioned.(B) Switchboards and Switchgear. Low voltage switchgear, medium voltage switchgear and switchboards shall be permitted to be reconditioned. Reconditioned equipment shall be listed as “reconditioned” and the original listing mark removed.

Note that equipment where no specific guidance is provided would be permitted to be reconditioned and would only be required to meet the marking requirements in 110.21(A)(2).

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 979-NFPA 70-2018 [Global Input]

Public Comment No. 981-NFPA 70-2018 [New Section after 240.61]

Public Comment No. 982-NFPA 70-2018 [New Section after 240.101(B)]

Public Comment No. 983-NFPA 70-2018 [Section No. 695.10]

Public Comment No. 984-NFPA 70-2018 [Section No. 700.5(C)]

Public Comment No. 985-NFPA 70-2018 [Section No. 701.5(C)]

Public Comment No. 986-NFPA 70-2018 [Section No. 702.5]

Public Comment No. 987-NFPA 70-2018 [New Section after 408.7]

Public Comment No. 979-NFPA 70-2018 [Global Input]

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Public Comment No. 981-NFPA 70-2018 [New Section after 240.61]

Public Comment No. 982-NFPA 70-2018 [New Section after 240.101(B)]

Public Comment No. 983-NFPA 70-2018 [Section No. 695.10]

Public Comment No. 984-NFPA 70-2018 [Section No. 700.5(C)]

Public Comment No. 985-NFPA 70-2018 [Section No. 701.5(C)]

Public Comment No. 986-NFPA 70-2018 [Section No. 702.5]

Public Comment No. 987-NFPA 70-2018 [New Section after 408.7]

Related Item

• PI2935

Submitter Information Verification

Submitter Full Name: James Dollard

Organization: IBEW Local Union 98

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 21 08:28:49 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, James Dollard, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am James Dollard, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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NEMA Policy on Reconditioned Electrical Equipment Executive Summary: The option of reconditioning existing equipment (instead of purchasing new equipment) exists today. Proper electrical equipment reconditioning provides a means to extend the life of electrical products as well as an opportunity in some cases to update installed equipment with the latest performance and safety features. However, not all components of the electrical infrastructure are candidates for reconditioning. There are a number of precautions that must be adhered to when reconditioning electrical equipment if that equipment is to operate safely and with acceptable performance. Those precautions are discussed below and include the use of design qualified parts, testing to industry-recognized safety standards, original manufacturer specification and/or recommendations, when possible, and reconditioning performed by qualified personnel. The integrity of reconditioned electrical equipment must be established by documenting and demonstrating that component replacement has not compromised the manufacturer’s original specifications and accepted industry standards. The third party certification mark must be removed or obliterated from reconditioned electrical products to indicate that an evaluation of the reconditioning process or reconditioned product has not been conducted by the original third party. As guidance, Appendix B provides a list of electrical products and components that are considered by NEMA suitable for reconditioning and Appendix A provides a list of electrical products considered not suitable for reconditioning. Medical Imaging Equipment is specifically not addressed by this policy (reference MITA 1, Good Refurbishment Practices for Medical Imaging Equipment). Introduction: The U.S. electrical industry includes discussions on implementing new technologies to enhance existing electrical infrastructure. Further, sustainability and safeguarding the environment are growing in importance. In the midst of this is the option for reconditioning existing equipment. Paramount in all this is the fundamental priority that all electrical systems operate while safe-guarding personnel and infrastructure from potential hazards (electrical, mechanical, fire, etc.). This forms the basis for the NEMA position on reconditioning electrical products. Given that electrical systems are diverse in design, function, and application, not all components of the electrical infrastructure are candidates for reconditioning. Definition:

Reconditioning: the process of restoring electromechanical systems, equipment, apparatus or components to operating conditions as recommended by the

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manufacturer’s instructions, using only design qualified parts. Reverse engineered parts (designs copied from existing parts by other manufacturers) are not considered to be “design qualified parts” unless specifically design verified under applicable Standards. Electrical industry practitioners and other organizations may also use the following terms/words to describe the process of reconditioning: remanufacturing, refurbishing, recycling, repairing, restoring, rebuilding, reengineering, and reusing.

In addition to design considerations, it is often impossible to obtain the service records, application environment, and operation parameters of all electrical components. Not having access to such information could have an adverse impact on the final safety and reliability of refurbished or reconditioned equipment. While NEMA supports the reconditioning of some electrical equipment, the components listed in Appendix A are not recommended for reconditioning, unless otherwise indicated by the original manufacturer. Normal servicing of equipment that remains within a facility should not be considered reconditioning or refurbishing. For electrical components suitable for reconditioning listed in Appendix B, the following fundamental tenets have been established. Fundamental Tenets for Reconditioning Electrical Equipment

Reconditioning electrical equipment may be a viable option for extending operational lifetime of equipment and enhancing equipment with additional features.

Electrical equipment reconditioning activity must be based on available guidance documentation from the Original Equipment Manufacturer, or industry-developed standards. Where any conflict in guidance is noted between the OEM and industry standards, the OEM guidance should take precedence. 

Electrical equipment must be reconditioned and qualified to an industry-developed standard that ensures equipment is in a usable and safe operating condition. An industry-developed standard is a widely agreed upon rule, set of rules, procedures or requirements for a product, assembly or process which are developed by members or organizations of an aggregate of manufacturing and technically productive enterprises in a particular field. Products deemed to be candidates for reconditioning must be reconditioned and qualified to industry standards containing the most relevant and critical design aspects, testing criteria and manufacturing specifications when the item was built.

Reconditioning work must be performed by qualified personnel. Electrical equipment that has been exposed to adverse conditions, such as fire,

water damage, etc., may not be suitable for reconditioning. A comprehensive assessment of the electrical equipment being considered for

reconditioning with service records, application, environment, service life, and operating parameters is critical before deciding to pursue reconditioning of the electrical equipment and system. Trained, skilled technicians should be able to assess whether a device or system is suitable for reconditioning through physical inspection and test.

Appendix A provides guidance on which components or assemblies of the electrical system are not suitable for reconditioning because they may pose a

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hazard. Appendix B provides guidance on the components or assemblies are suitable for reconditioning.

Reconditioning electrical equipment must utilize electrical product safety standards as they contain design aspects, testing criteria and manufacturing specifications to ensure a given product will function as intended. These requirements are established to deliver a usable and safe operating condition as a key component of intended product functionality.

Electrical Infrastructure and Worker Safety

Electrical equipment that is properly installed, tested, maintained, and operated will provide reliable power as well as protect the electrical infrastructure. The reconditioning of electrical equipment requires the electrical industry, in collaboration with manufacturers, to establish performance specifications and accepted industry standards to help ensure safe and reliable equipment that help protect our electrical infrastructure so workers and users can continue to benefit from a safe and effective electrical system. Reconditioning standards must include prescriptive actions and performance requirements that result in equipment that complies with standards that include but are not limited to CSA, IEC, IEEE, NEC, OSHA, NFPA 70E, NFPA 70B, NETA ATS, NETA MTS, and EASA AR100 for example. Qualified personnel must possess the knowledge of how to assess equipment condition, potential hazards, and specifications to accurately determine the suitability for reconditioning. A safe and reliable electrical infrastructure that can be safely maintained is dependent on compliance with manufacturers’ instructions, qualified workers, proper maintenance, and accepted industry standards for reconditioning activities. Electrical Equipment Reliability, Performance and Safety

Proper electrical equipment reconditioning provides a means to extend the life of electrical products as well as an opportunity to update installed equipment with the latest performance and safety features. Establishing well defined guidelines for those performing the reconditioning activity, based on original manufacturer’s requirements, creates a solid foundation for the electrical industry and users. It is paramount that reconditioned electrical equipment be reliable in not only providing power, but also in safely performing its intended function as part of a safe operating electrical system. Understanding the environment, electrical load characteristics and historical maintenance performed on equipment being considered for reconditioning are all important parts of an assessment for reconditioning that can have a significant bearing on reliability, performance and safety. The electrical equipment manufacturer is the foremost authority on the design, performance and intended safe application of their product. Reconditioned electrical equipment must not compromise the reliability, performance, safe operation, or maintenance of the electrical system. Integrity of Reconditioned Equipment

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Reconditioned electrical equipment must comply with all applicable standards at the time the equipment was initially built as a minimum as well as the original manufacturer’s performance requirements in accordance with the nameplate markings and ratings. Replacement parts shall meet the design criteria (form, fit, and function) for the device to perform its intended function and provide safe operation. Replacement parts shall not include counterfeit parts (i.e., parts that have been misrepresented to be an authorized item of the legally authorized source.) Equipment shall operate safely in its intended application after reconditioning occurs. Care must be taken to ensure specific operations such as timing, sequencing, control, transfer, etc. continue to function in the manner originally intended, unless changes are specified during the reconditioning process. The integrity of reconditioned electrical equipment must be established by documenting and demonstrating that component replacement and performance changes have not compromised the manufacturer’s specifications and accepted industry standards. Listing or Certification Marks

NEMA members manufacture products that are more than likely to be evaluated as part of a third party certification program to nationally recognized safety standards. These products can be marked with a listing or certification mark when the products are manufactured and shipped from the factory. The organization that reconditions the product is responsible for adhering to the guidelines from the issuing agency authorizing the mark to determine if the mark can remain on the product after reconditioning. The organization that reconditions is responsible for any actions necessary for the mark to remain on the product (analysis, testing, etc.). Otherwise, reconditioned electrical products must have their mark removed or obliterated to indicate that an evaluation of the reconditioning process has not been conducted by the original third party. The organization that reconditions the product is additionally responsible for applying a mark or seal that indicates that the equipment has been reconditioned. This mark must provide traceability to the reconditioning organization in the event that it is necessary to determine the details of who reconditioned the equipment and the report on what was completed during this process. There are a number of NEMA products that are not allowed to be reconditioned due to the inherent safety characteristics and requirements for those products to be evaluated according to a regular follow up program to evaluate the safety performance requirements as a condition of maintaining the listing or certification mark. This process cannot be applied to reconditioned electrical products since these are normally destructive tests and sample sets of reconditioned products are not possible due to limited quantities or ratings of specific devices. UL Guidance on the UL Mark When the manufacturer places the UL Mark on the product at the factory, it is their attestation that the product complies with the applicable requirements. Unless there is further oversight or review/inspection (field inspection) UL cannot ascertain that the

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product continues to comply with all requirements should field repairs, modifications or component replacements be made to the product. Obviously there is little control over what manufacturers will or can do to equipment which left the factory with a certification mark. UL has created rebuilt categories where the reconditioning of product is done in an organized consistent manner under the supervision of UL’s FUS (Follow-Up Services) field representatives. In these cases the first action conducted with equipment being rebuilt is the removal of the initial certification mark (if provided). Upon completion of the reconditioning, in accordance with the surveillance document, the manufacturer is permitted to affix a mark which clearly identifies the product as reconditioned.

Cases where a reconditioner is instructed to NOT remove any certification mark will result in confusion. Clearly such equipment in the field, which has undergone modification or reconditioning, is ineligible to bear a mark which designates a compliance with a certification standard.

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APPENDIX A

COMPONENTS OR ASSEMBLIES NOT SUITABLE FOR RECONDITIONING* Adjustable speed drives Arc fault circuit breakers Ballasts Busway (mylar wrapped) Busway (powder coated) Cable tray Cast resin transformers Components containing semiconductors and transistors Control transformers Dry type transformers Electrical Connectors Electrical submetering equipment Electrical vehicle supply equipment Enclosed switches Fire detectors, smoke alarms, co detectors Fire pump controllers Flexible and extension cords Flexible conduit Ground fault circuit breakers High performance wire and cable Lighting controls Liquid filled transformers Low and medium voltage fuse holders Low and medium voltage non-renewable fuses Low voltage power circuit breaker electronic trip units Luminaires Meters (electromechanical, electronic or digital) Meter sockets Molded case circuit breakers Non-Metallic conduit, tubing, raceways and fittings Non-metallic surface raceways and fittings Outlet and junction boxes Overload relays Pin and sleeve plugs receptacles and connectors Power and control cable Protective relays (electronic or digital) Residential panel boards Solid state contactors and starters Solid state drives Strut type channel raceway Surface metal raceways and fittings Surge protective devices Transfer switches Wire or cable Wireway Wiring devices

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7

*The components or products listed above are not recommended for reconditioning, unless otherwise indicated by the original manufacturer.

APPENDIX B

COMPONENTS OR ASSEMBLIES WHICH MAY BE RECONDITIONED Electromechanical protective relays, and current transformers High voltage circuit breakers Industrial and commercial panel boards Low and medium voltage power circuit breakers Low and medium voltage replaceable link fuses Low voltage switchgear Manual and magnetic controllers Medium voltage switchgear Metallic conduit, tubing, raceways and fittings Motor control centers Motors Switchboards Uninterruptible Power Supply Equipment

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Public Comment No. 1021-NFPA 70-2018 [ Section No. 240.87(B) ]

(B) Method to Reduce Clearing Time.

One of the following means shall be provided:

(1) Zone-selective interlocking

(2) Differential relaying

(3) Energy-reducing maintenance switching with local status indicator

(4) Energy-reducing active arc flash mitigation system

(5) An A normal, in service setting of the instantaneous trip setting that is less than the available arcingcurrent. Temporary adjustment of the instantaneous trip setting by the principal settings means toachieve arc energy reduction shall not be permitted.

(6) An instantaneous override that is less than the available arcing current

(7) An approved equivalent means

Informational Note No. 1: An energy-reducing maintenance switch allows a worker to set a circuitbreaker trip unit to “no intentional delay” to reduce the clearing time while the worker is workingwithin an arc-flash boundary as defined in NFPA 70E-2018, Standard for Electrical Safety in theWorkplace, and then to set the trip unit back to a normal setting after the potentially hazardous workis complete.

Informational Note No. 2: An energy-reducing active arc flash mitigation system helps in reducingarcing duration in the electrical distribution system. No change in the circuit breaker or the settings ofother devices is required during maintenance when a worker is working within an arc flash boundaryas defined in NFPA 70E-2018, Standard for Electrical Safety in the Workplace.

Informational Note No. 3: An instantaneous trip is a function that causes a circuit breaker to trip withno intentional delay when currents exceed the instantaneous trip setting or current level. If arcingcurrents are above the instantaneous trip level, the circuit breaker will trip in the minimum possibletime.

Informational Note No. 4: IEEE 1584-2002, IEEE Guide for Performing Arc Flash HazardCalculations, is one of the available methods that provide guidance in determining arcing current.

Statement of Problem and Substantiation for Public Comment

The temporary adjustment restriction is further specified to clarify that it is the knob on the circuit breaker that cannot be used. This eliminates ambiguity between a temporary setting being performed by the maintenance switch and the principal setting means of the circuit breaker instantaneous. Terms such as knob, dial, buttons, etc… are avoided to make the language inclusive.

Related Item

• FR 8671

Submitter Information Verification

Submitter Full Name: Thomas Papallo

Organization: Siemens

Affiliation: Siemens

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 21 15:18:00 EDT 2018

Committee: NEC-P10

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Copyright Assignment

I, Thomas Papallo, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Thomas Papallo, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1022-NFPA 70-2018 [ Section No. 240.87(B) ]

(B) Method to Reduce Clearing Time.

One of the following means set less than the available arcing current shall be provided:

(1) Zone-selective interlocking

(2) Differential relaying

(3) Energy-reducing maintenance switching with local status indicator

(4) Energy-reducing active arc flash mitigation system

(5) An instantaneous trip setting that is less than the available arcing current . Temporary adjustment ofthe instantaneous trip setting to achieve arc energy reduction shall not be permitted.

(6) An instantaneous override that is less than the available arcing current

(7) An approved equivalent means

Informational Note No. 1: An energy-reducing maintenance switch allows a worker to set a circuitbreaker trip unit to “no intentional delay” to reduce the clearing time while the worker is workingwithin an arc-flash boundary as defined in NFPA 70E-2018, Standard for Electrical Safety in theWorkplace, and then to set the trip unit back to a normal setting after the potentially hazardous workis complete.

Informational Note No. 2: An energy-reducing active arc flash mitigation system helps in reducingarcing duration in the electrical distribution system. No change in the circuit breaker or the settings ofother devices is required during maintenance when a worker is working within an arc flash boundaryas defined in NFPA 70E-2018, Standard for Electrical Safety in the Workplace.

Informational Note No. 3: An instantaneous trip is a function that causes a circuit breaker to trip withno intentional delay when currents exceed the instantaneous trip setting or current level. If arcingcurrents are above the instantaneous trip level, the circuit breaker will trip in the minimum possibletime.

Informational Note No. 4: IEEE 1584-2002, IEEE Guide for Performing Arc Flash HazardCalculations, is one of the available methods that provide guidance in determining arcing current.

Statement of Problem and Substantiation for Public Comment

The requirement that the setting is less than the available arcing current has been moved so that it applies to all means. The language “set less than the arcing current” is in the current code for instantaneous trip and is critical recognition that if the arc flash protection is not set properly then added safety is not achieved. The identical rational applies to all of the means. For example, three of the Maintenance Switch product solutions reviewed have pickup settings. These settings must also be below the arcing current to achieve the improvement in safety this code requirement is driving.

The requirement that the instantaneous be set to less than the arcing current for all means was also in PI 2638.

Related Item

• FR 8671

Submitter Information Verification

Submitter Full Name: Thomas Papallo

Organization: Siemens

Affiliation: Siemens

Street Address:

City:

State:

Zip:

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Submittal Date: Tue Aug 21 15:27:21 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Thomas Papallo, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Thomas Papallo, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 1200-NFPA 70-2018 [ Section No. 240.87(B) ]

(B) Method to Reduce Clearing Time.

One of the following means shall be provided:

(1) Zone-selective interlocking

(2) Differential relaying

(3) Energy-reducing maintenance switching with local status indicator

(4) Energy-reducing active arc flash mitigation system

(5) An instantaneous trip setting that is less than the available arcing current. Temporary adjustment ofthe instantaneous trip setting to achieve arc energy reduction shall not be permitted.

(6) An instantaneous override that is less than the available arcing current

(7) An approved equivalent means

Informational Note No. 1: An energy-reducing maintenance switch allows a worker to set a circuitbreaker trip unit to “no intentional delay” to reduce the clearing time while the worker is workingwithin an arc-flash boundary as defined in NFPA 70E-2018, Standard for Electrical Safety in theWorkplace, and then to set the trip unit back to a normal setting after the potentially hazardous workis complete.

Informational Note No. 2: An energy-reducing active arc flash mitigation system helps in reducingarcing duration in the electrical distribution system. No change in the circuit breaker or the settings ofother devices is required during maintenance when a worker is working within an arc flash boundaryas defined in NFPA 70E-2018, Standard for Electrical Safety in the Workplace.

Informational Note No. 3: An instantaneous trip is a function that causes a circuit breaker to trip withno intentional delay when currents exceed the instantaneous trip setting or current level. If arcingcurrents are above the instantaneous trip level, the circuit breaker will trip in the minimum possibletime.

Informational Note No. 4: IEEE 1584-2002, IEEE Guide for Performing Arc Flash HazardCalculations, is one of the available methods that provide guidance in determining arcing current.

Statement of Problem and Substantiation for Public Comment

This new requirement is not suitable for an installation code and should have been proposed for NFPA 70E. If a requirement of this type is left in the NEC, it should exemptSupervised Industrial Installations and other cases where qualified personnel can successfully adjust the instantaneous setting, which is what an Energy-ReducingMaintenance Switch does. Two methods by which this has been done successfully and safely in Supervised Industrial Installations are: (1) Using a toggle switch to enable analternate trip unit settings group. This method met 240.87(B)(5) previously but not 240.87(B)(3). (2) A qualified person resetting a digital trip unit in accordance with awritten procedure.

Related Item

• FR-8671

Submitter Information Verification

Submitter Full Name: Roy Sparks

Organization: Eli Lilly and Company

Affiliation: ACC

Street Address:

City:

State:

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Zip:

Submittal Date: Fri Aug 24 11:47:37 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Roy Sparks, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Roy Sparks, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 877-NFPA 70-2018 [ Section No. 240.91(B) ]

(B) Devices Rated Over 800 Amperes.

Where the overcurrent device is rated over 800 amperes, the ampacity of the conductors it protects shallbe equal to or greater than 95 percent of the rating of the overcurrent device in accordance with thefollowing:

(1) The conductors are protected within recognized time vs. current limits for short-circuit currents

Informational Note: Table 240.92(B) provides time vs. short-circuit current formulae todetermine limits for copper and aluminum conductors.

(2) All equipment in which the conductors terminate is listed and marked for the application.

Additional Proposed Changes

File Name Description Approved

CN_68.pdf 70_CN 68

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 68 in the First Draft Report on First Revision No. 8673.

The Correlating Committee directs that this First Revision be reviewed. The plural form of “formula” may be better written as “formulas”.

This action will be considered a public comment.

Related Item

• FR 8673

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 14:13:59 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, CC on NEC-AAC, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am CC on NEC-AAC, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 982-NFPA 70-2018 [ New Section after 240.101(B) ]

240.102 Reconditioned Equipment. Medium voltage fuseholders and medium voltage non-renewable fuses shall not be permitted to be reconditioned.

Additional Proposed Changes

File Name Description Approved

NEMA-Position_Refubishing_on_ElecEquip.pdf

Statement of Problem and Substantiation for Public Comment

This public comment is submitted by an NEC Correlating Committee appointed task group to address the global impacts of PI 2935. This PI would have required that “Reconditioned Equipment” be “listed as “reconditioned” and the “original listing marks removed”. This PI has ramifications that are global in nature and impacts all products referenced in the NEC under the purview of every CMP.

This proposed new section is safety-driven and is necessary to prevent the reconditioning of products that cannot be reconditioned, This public comment is based on the global impact of public input 2935 and does not represent new material.

The “NEMA Policy on Reconditioned Electrical Equipment” is attached to this public comment. See also global public comment 979.

The substantiation for global public comment 979 is provided below:

Public Comment No. 979-NFPA 70-2018 [Global Input]

This Public Comment is submitted on behalf of a task group appointed by the NEC® Correlating Committee. This Task Group was appointed to review the use of refurbished equipment throughout the NEC®. Task Group members are Jim Dollard, Robert Osborne, Jim Pierce, and David Williams. This task group has been charged with reviewing Public Input (PI) 2935 which was resolved by CMP-1 during the first draft stage. This PI would have required that “Reconditioned Equipment” be “listed as “reconditioned” and the “original listing marks removed”. This PI has ramifications that are global in nature and impacts all products referenced in the NEC under the purview of every CMP.

Task group members noted that some types of equipment are capable of being reconditioned, then re-evaluated to ensure compliance with the applicable product standards. Other types of equipment do not lend themselves to reconditioning due to the complexity of the product, the manufacturing process, or the level of knowledge the company performing the reconditioning may need, etc.

The “NEMA Policy on Reconditioned Electrical Equipment” details the following aspects of Reconditioning of Electrical Equipment:

• Fundamental Tenets for Reconditioning Electrical Equipment• Electrical Infrastructure and Worker Safety• Integrity of Reconditioned Equipment• Listing or Certification Marks• UL Guidance on the UL Mark• Components or Assemblies Not Suitable For Reconditioning (Appendix A)• Components or Assemblies Which May Be Reconditioned (Appendix B)

A PDF copy of this NEMA policy is attached and may also be found on the internet at the following URL: https://www.nema.org/Policy/Documents/NEMA-Position_Refubishing%20on%20ElecEquip.pdf

NEC® Section 110.21(A)(2), which was new for the 2017 Edition of the NEC®, included marking requirements for “Reconditioned Equipment”. PI 2935 would have required that “Reconditioned Equipment” be “listed as “reconditioned” and the “original listing marks removed”. CMP 1 resolved this PI. This Task Group appointed by the NEC® Correlating Committee has developed a number of public comments, based on the products identified in

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the referenced NEMA document, to determine whether or not equipment can be reconditioned, and if reconditioned, what additional requirements apply.

While several public comments were developed for specific equipment by this task group, not all equipment was addressed (neither was all the equipment noted in the NEMA Policy document addressed). This Global Public Comment requests each CMP to review the products required to be listed under their purview and determine whether reconditioning should be permitted. It is recommended that the NEMA Policy document be used as one of the guidelines in making this determination. It is also recommended that one of the following options/examples be chosen for listed equipment:

Option 1 - Equipment NOT suitable for Reconditioning (EXAMPLE):

695.10 Listed Equipment. Diesel engine fire pump controllers, electric fire pump controllers, electric motors, fire pump power transfer switches, foam pump controllers, and limited service controllers shall be listed for fire pump service. [20:9.5.1.1, 10.1.2.1, 12.1.3.1]Fire pump controllers and transfer switches shall not be permitted to be reconditioned.

Option 2 - Equipment which MAY BE suitable for Reconditioning (EXAMPLE):

408.8 Reconditioned Equipment.(A) Panelboards. The use of reconditioned panelboards shall comply with (1) and (2):(1) Industrial and commercial panelboards shall be permitted to be reconditioned. Reconditioned equipment shall be listed as “reconditioned” and the original listing mark removed.(2) Panelboards installed in dwelling units shall not be permitted to be reconditioned.(B) Switchboards and Switchgear. Low voltage switchgear, medium voltage switchgear and switchboards shall be permitted to be reconditioned. Reconditioned equipment shall be listed as “reconditioned” and the original listing mark removed.

Note that equipment where no specific guidance is provided would be permitted to be reconditioned and would only be required to meet the marking requirements in 110.21(A)(2).

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 979-NFPA 70-2018 [Global Input]

Public Comment No. 980-NFPA 70-2018 [New Section after 240.87(B)]

Public Comment No. 981-NFPA 70-2018 [New Section after 240.61]

Public Comment No. 983-NFPA 70-2018 [Section No. 695.10]

Public Comment No. 984-NFPA 70-2018 [Section No. 700.5(C)]

Public Comment No. 985-NFPA 70-2018 [Section No. 701.5(C)]

Public Comment No. 986-NFPA 70-2018 [Section No. 702.5]

Public Comment No. 987-NFPA 70-2018 [New Section after 408.7]

Public Comment No. 979-NFPA 70-2018 [Global Input]

Public Comment No. 980-NFPA 70-2018 [New Section after 240.87(B)]

Public Comment No. 981-NFPA 70-2018 [New Section after 240.61]

Public Comment No. 983-NFPA 70-2018 [Section No. 695.10]

Public Comment No. 984-NFPA 70-2018 [Section No. 700.5(C)]

Public Comment No. 985-NFPA 70-2018 [Section No. 701.5(C)]

Public Comment No. 986-NFPA 70-2018 [Section No. 702.5]

Public Comment No. 987-NFPA 70-2018 [New Section after 408.7]

Related Item

• PI 2935

Submitter Information Verification

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Submitter Full Name: James Dollard

Organization: IBEW Local Union 98

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 21 09:11:24 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, James Dollard, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am James Dollard, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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1

NEMA Policy on Reconditioned Electrical Equipment Executive Summary: The option of reconditioning existing equipment (instead of purchasing new equipment) exists today. Proper electrical equipment reconditioning provides a means to extend the life of electrical products as well as an opportunity in some cases to update installed equipment with the latest performance and safety features. However, not all components of the electrical infrastructure are candidates for reconditioning. There are a number of precautions that must be adhered to when reconditioning electrical equipment if that equipment is to operate safely and with acceptable performance. Those precautions are discussed below and include the use of design qualified parts, testing to industry-recognized safety standards, original manufacturer specification and/or recommendations, when possible, and reconditioning performed by qualified personnel. The integrity of reconditioned electrical equipment must be established by documenting and demonstrating that component replacement has not compromised the manufacturer’s original specifications and accepted industry standards. The third party certification mark must be removed or obliterated from reconditioned electrical products to indicate that an evaluation of the reconditioning process or reconditioned product has not been conducted by the original third party. As guidance, Appendix B provides a list of electrical products and components that are considered by NEMA suitable for reconditioning and Appendix A provides a list of electrical products considered not suitable for reconditioning. Medical Imaging Equipment is specifically not addressed by this policy (reference MITA 1, Good Refurbishment Practices for Medical Imaging Equipment). Introduction: The U.S. electrical industry includes discussions on implementing new technologies to enhance existing electrical infrastructure. Further, sustainability and safeguarding the environment are growing in importance. In the midst of this is the option for reconditioning existing equipment. Paramount in all this is the fundamental priority that all electrical systems operate while safe-guarding personnel and infrastructure from potential hazards (electrical, mechanical, fire, etc.). This forms the basis for the NEMA position on reconditioning electrical products. Given that electrical systems are diverse in design, function, and application, not all components of the electrical infrastructure are candidates for reconditioning. Definition:

Reconditioning: the process of restoring electromechanical systems, equipment, apparatus or components to operating conditions as recommended by the

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manufacturer’s instructions, using only design qualified parts. Reverse engineered parts (designs copied from existing parts by other manufacturers) are not considered to be “design qualified parts” unless specifically design verified under applicable Standards. Electrical industry practitioners and other organizations may also use the following terms/words to describe the process of reconditioning: remanufacturing, refurbishing, recycling, repairing, restoring, rebuilding, reengineering, and reusing.

In addition to design considerations, it is often impossible to obtain the service records, application environment, and operation parameters of all electrical components. Not having access to such information could have an adverse impact on the final safety and reliability of refurbished or reconditioned equipment. While NEMA supports the reconditioning of some electrical equipment, the components listed in Appendix A are not recommended for reconditioning, unless otherwise indicated by the original manufacturer. Normal servicing of equipment that remains within a facility should not be considered reconditioning or refurbishing. For electrical components suitable for reconditioning listed in Appendix B, the following fundamental tenets have been established. Fundamental Tenets for Reconditioning Electrical Equipment

Reconditioning electrical equipment may be a viable option for extending operational lifetime of equipment and enhancing equipment with additional features.

Electrical equipment reconditioning activity must be based on available guidance documentation from the Original Equipment Manufacturer, or industry-developed standards. Where any conflict in guidance is noted between the OEM and industry standards, the OEM guidance should take precedence. 

Electrical equipment must be reconditioned and qualified to an industry-developed standard that ensures equipment is in a usable and safe operating condition. An industry-developed standard is a widely agreed upon rule, set of rules, procedures or requirements for a product, assembly or process which are developed by members or organizations of an aggregate of manufacturing and technically productive enterprises in a particular field. Products deemed to be candidates for reconditioning must be reconditioned and qualified to industry standards containing the most relevant and critical design aspects, testing criteria and manufacturing specifications when the item was built.

Reconditioning work must be performed by qualified personnel. Electrical equipment that has been exposed to adverse conditions, such as fire,

water damage, etc., may not be suitable for reconditioning. A comprehensive assessment of the electrical equipment being considered for

reconditioning with service records, application, environment, service life, and operating parameters is critical before deciding to pursue reconditioning of the electrical equipment and system. Trained, skilled technicians should be able to assess whether a device or system is suitable for reconditioning through physical inspection and test.

Appendix A provides guidance on which components or assemblies of the electrical system are not suitable for reconditioning because they may pose a

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hazard. Appendix B provides guidance on the components or assemblies are suitable for reconditioning.

Reconditioning electrical equipment must utilize electrical product safety standards as they contain design aspects, testing criteria and manufacturing specifications to ensure a given product will function as intended. These requirements are established to deliver a usable and safe operating condition as a key component of intended product functionality.

Electrical Infrastructure and Worker Safety

Electrical equipment that is properly installed, tested, maintained, and operated will provide reliable power as well as protect the electrical infrastructure. The reconditioning of electrical equipment requires the electrical industry, in collaboration with manufacturers, to establish performance specifications and accepted industry standards to help ensure safe and reliable equipment that help protect our electrical infrastructure so workers and users can continue to benefit from a safe and effective electrical system. Reconditioning standards must include prescriptive actions and performance requirements that result in equipment that complies with standards that include but are not limited to CSA, IEC, IEEE, NEC, OSHA, NFPA 70E, NFPA 70B, NETA ATS, NETA MTS, and EASA AR100 for example. Qualified personnel must possess the knowledge of how to assess equipment condition, potential hazards, and specifications to accurately determine the suitability for reconditioning. A safe and reliable electrical infrastructure that can be safely maintained is dependent on compliance with manufacturers’ instructions, qualified workers, proper maintenance, and accepted industry standards for reconditioning activities. Electrical Equipment Reliability, Performance and Safety

Proper electrical equipment reconditioning provides a means to extend the life of electrical products as well as an opportunity to update installed equipment with the latest performance and safety features. Establishing well defined guidelines for those performing the reconditioning activity, based on original manufacturer’s requirements, creates a solid foundation for the electrical industry and users. It is paramount that reconditioned electrical equipment be reliable in not only providing power, but also in safely performing its intended function as part of a safe operating electrical system. Understanding the environment, electrical load characteristics and historical maintenance performed on equipment being considered for reconditioning are all important parts of an assessment for reconditioning that can have a significant bearing on reliability, performance and safety. The electrical equipment manufacturer is the foremost authority on the design, performance and intended safe application of their product. Reconditioned electrical equipment must not compromise the reliability, performance, safe operation, or maintenance of the electrical system. Integrity of Reconditioned Equipment

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Reconditioned electrical equipment must comply with all applicable standards at the time the equipment was initially built as a minimum as well as the original manufacturer’s performance requirements in accordance with the nameplate markings and ratings. Replacement parts shall meet the design criteria (form, fit, and function) for the device to perform its intended function and provide safe operation. Replacement parts shall not include counterfeit parts (i.e., parts that have been misrepresented to be an authorized item of the legally authorized source.) Equipment shall operate safely in its intended application after reconditioning occurs. Care must be taken to ensure specific operations such as timing, sequencing, control, transfer, etc. continue to function in the manner originally intended, unless changes are specified during the reconditioning process. The integrity of reconditioned electrical equipment must be established by documenting and demonstrating that component replacement and performance changes have not compromised the manufacturer’s specifications and accepted industry standards. Listing or Certification Marks

NEMA members manufacture products that are more than likely to be evaluated as part of a third party certification program to nationally recognized safety standards. These products can be marked with a listing or certification mark when the products are manufactured and shipped from the factory. The organization that reconditions the product is responsible for adhering to the guidelines from the issuing agency authorizing the mark to determine if the mark can remain on the product after reconditioning. The organization that reconditions is responsible for any actions necessary for the mark to remain on the product (analysis, testing, etc.). Otherwise, reconditioned electrical products must have their mark removed or obliterated to indicate that an evaluation of the reconditioning process has not been conducted by the original third party. The organization that reconditions the product is additionally responsible for applying a mark or seal that indicates that the equipment has been reconditioned. This mark must provide traceability to the reconditioning organization in the event that it is necessary to determine the details of who reconditioned the equipment and the report on what was completed during this process. There are a number of NEMA products that are not allowed to be reconditioned due to the inherent safety characteristics and requirements for those products to be evaluated according to a regular follow up program to evaluate the safety performance requirements as a condition of maintaining the listing or certification mark. This process cannot be applied to reconditioned electrical products since these are normally destructive tests and sample sets of reconditioned products are not possible due to limited quantities or ratings of specific devices. UL Guidance on the UL Mark When the manufacturer places the UL Mark on the product at the factory, it is their attestation that the product complies with the applicable requirements. Unless there is further oversight or review/inspection (field inspection) UL cannot ascertain that the

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product continues to comply with all requirements should field repairs, modifications or component replacements be made to the product. Obviously there is little control over what manufacturers will or can do to equipment which left the factory with a certification mark. UL has created rebuilt categories where the reconditioning of product is done in an organized consistent manner under the supervision of UL’s FUS (Follow-Up Services) field representatives. In these cases the first action conducted with equipment being rebuilt is the removal of the initial certification mark (if provided). Upon completion of the reconditioning, in accordance with the surveillance document, the manufacturer is permitted to affix a mark which clearly identifies the product as reconditioned.

Cases where a reconditioner is instructed to NOT remove any certification mark will result in confusion. Clearly such equipment in the field, which has undergone modification or reconditioning, is ineligible to bear a mark which designates a compliance with a certification standard.

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APPENDIX A

COMPONENTS OR ASSEMBLIES NOT SUITABLE FOR RECONDITIONING* Adjustable speed drives Arc fault circuit breakers Ballasts Busway (mylar wrapped) Busway (powder coated) Cable tray Cast resin transformers Components containing semiconductors and transistors Control transformers Dry type transformers Electrical Connectors Electrical submetering equipment Electrical vehicle supply equipment Enclosed switches Fire detectors, smoke alarms, co detectors Fire pump controllers Flexible and extension cords Flexible conduit Ground fault circuit breakers High performance wire and cable Lighting controls Liquid filled transformers Low and medium voltage fuse holders Low and medium voltage non-renewable fuses Low voltage power circuit breaker electronic trip units Luminaires Meters (electromechanical, electronic or digital) Meter sockets Molded case circuit breakers Non-Metallic conduit, tubing, raceways and fittings Non-metallic surface raceways and fittings Outlet and junction boxes Overload relays Pin and sleeve plugs receptacles and connectors Power and control cable Protective relays (electronic or digital) Residential panel boards Solid state contactors and starters Solid state drives Strut type channel raceway Surface metal raceways and fittings Surge protective devices Transfer switches Wire or cable Wireway Wiring devices

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*The components or products listed above are not recommended for reconditioning, unless otherwise indicated by the original manufacturer.

APPENDIX B

COMPONENTS OR ASSEMBLIES WHICH MAY BE RECONDITIONED Electromechanical protective relays, and current transformers High voltage circuit breakers Industrial and commercial panel boards Low and medium voltage power circuit breakers Low and medium voltage replaceable link fuses Low voltage switchgear Manual and magnetic controllers Medium voltage switchgear Metallic conduit, tubing, raceways and fittings Motor control centers Motors Switchboards Uninterruptible Power Supply Equipment

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Public Comment No. 1340-NFPA 70-2018 [ Article 242 ]

Article 242 Overvoltage Protection

Part I. General

242.1 Scope.

This article provides the general requirements, installation requirements, and connection requirements forovervoltage protection and overvoltage protective devices. Part II covers surge-protective devices (SPDs)permanently installed on premises wiring systems of not more than 1000 volts, nominal, while Part IIIcovers surge arresters permanently installed on premises wiring systems over 1000 volts, nominal.

242.3 Other Articles.

Equipment shall be protected against overvoltage in accordance with the article in this Code that coversthe type of equipment or location specified in Table 242.3.

Table 242.3 Other Articles

Equipment Article

Class I locations 501

Class II locations 502

Community antenna television and radiodistribution systems 820

Critical operations power systems 708

Elevators, dumbwaiters, escalators, movingwalks, platform lifts, and stairway chairlifts 620

Emergency systems 700

Equipment over 1000 volts, nominal 490

Fire pumps 695

Industrial machinery 670

Information technology equipment 645

Modular data centers 646

Outdoor overhead conductors over 1000 volts 399

Radio and television equipment 810

Receptacles, cord connectors, andattachment plugs (caps) 406

Wind electric systems 694

Part II. Surge-Protective Devices (SPDs), 1000 Volts or Less

Informational Note: Surge arresters 1000 volts or less are also known as Type 1 SPDs.

242.6 Uses Not Permitted.

An SPD device shall not be installed in the following:

(1) Circuits over 1000 volts

(2) On ungrounded systems, impedance grounded systems, or corner grounded delta systems unlesslisted specifically for use on these systems

(3) Where the rating of the SPD is less than the maximum continuous phase-to-ground voltage at thepower frequency available at the point of application

242.7 Number Required.

Where used at a point on a circuit, the SPD shall be connected to each ungrounded conductor.

242.9 Listing.

An SPD shall be a listed device.

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242.11 Short-Circuit Current Rating.

The SPD shall be marked with a short-circuit current rating and shall not be installed at a point on thesystem where the available fault current is in excess of that rating. This marking requirement shall notapply to receptacles.

242.13 Location.

SPDs shall be permitted to be located indoors or outdoors and shall be made inaccessible to unqualifiedpersons unless listed for installation in accessible locations.

242.15 Routing of Connections.

The conductors used to connect the SPD to the line or bus and to ground shall not be any longer thannecessary and shall avoid unnecessary bends.

242.19 Connection.

Where an SPD device is installed, it shall comply with 242.21 through 242.29.

242.21 Type 1 SPDs.

Type 1 SPDs shall be installed in accordance with 242.21(A) and (B).

(A) Installation.

Type 1 SPDs shall be permitted to be connected in accordance with one of the following:

(1) To the supply side of the service disconnect as permitted in 230.82(4)

(2) As specified in 242.23

(B) At the Service.

When installed at services, Type 1 SPDs shall be connected to one of the following:

(1) Grounded service conductor

(2) Grounding electrode conductor

(3) Grounding electrode for the service

(4) Equipment grounding terminal in the service equipment

242.23 Type 2 SPDs.

Type 2 SPDs shall be installed in accordance with 242.23(A) through (C).

(A) Service-Supplied Building or Structure.

Type 2 SPDs shall be connected anywhere on the load side of a service disconnect overcurrent devicerequired in 230.91 unless installed in accordance with 230.82(8).

(B) Feeder-Supplied Building or Structure.

Type 2 SPDs shall be connected at the building or structure anywhere on the load side of the firstovercurrent device at the building or structure.

(C) Separately Derived System.

The SPD shall be connected on the load side of the first overcurrent device in a separately derivedsystem.

242.25 Type 3 SPDs.

Type 3 SPDs shall be permitted to be installed on the load side of branch-circuit overcurrent protection upto the equipment served. If included in the manufacturer’s instructions, the Type 3 SPD connection shall bea minimum 10 m (30 ft) of conductor distance from the service or separately derived system disconnect.

242.26 Type 4 and Other Component Type SPDs.

Type 4 component assemblies and other component type SPDs shall only be installed by the equipmentmanufacturer.

242.27 Conductor Size.

Line and grounding conductors shall not be smaller than 14 AWG copper or 12 AWG aluminum.

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242.29 Connection Between Conductors.

An SPD shall be permitted to be connected between any two conductors — ungrounded conductor(s),grounded conductor, equipment grounding conductor, or grounding electrode conductor. The groundedconductor and the equipment grounding conductor shall be interconnected only by the normal operation ofthe SPD during a surge.

242.31 Grounding Electrode Conductor Connections and Enclosures.

Except as indicated in this article, SPD grounding connections shall be made as specified in Article 250,Part III. Grounding electrode conductors installed in metal enclosures shall comply with 250.64(E).

Part III. Surge Arresters, Over 1000 Volts

242.41 Number Required.

Where used at a point on a circuit, a surge arrester shall be connected to each ungrounded conductor. Asingle installation of such surge arresters shall be permitted to protect a number of interconnected circuitsif no circuit is exposed to surges while disconnected from the surge arresters.

242.43 Surge Arrester Selection.

The surge arresters shall comply with242.43(A) and (B).

(A) Rating.

The rating of a surge arrester shall be equal to or greater than the maximum continuous operating voltageavailable at the point of application.

(1) Solidly Grounded Systems.

The maximum continuous operating voltage shall be the phase-to-ground voltage of the system.

(2) Impedance or Ungrounded System.

The maximum continuous operating voltage shall be the phase-to-phase voltage of the system.

(B) Silicon Carbide Types.

The rating of a silicon carbide-type surge arrester shall be not less than 125 percent of the rating specifiedin 242.43(A).

Informational Note No. 1: For further information on surge arresters, see IEEE C62.11-2012,Standard for Metal-Oxide Surge Arresters for Alternating-Current Power Circuits (>1 kV), and IEEEC62.22-2009, Guide for the Application of Metal-Oxide Surge Arresters for Alternating-CurrentSystems.

Informational Note No. 2: The selection of a properly rated metal oxide arrester is based onconsiderations of maximum continuous operating voltage and the magnitude and duration ofovervoltages at the arrester location as affected by phase-to-ground faults, system groundingtechniques, switching surges, and other causes. See the manufacturer’s application rules forselection of the specific arrester to be used at a particular location.

242.45 Location.

Surge arresters shall be permitted to be located indoors or outdoors. Surge arresters shall be madeinaccessible to unqualified persons unless listed for installation in accessible locations.

242.47 Uses Not Permitted.

A surge arrester shall not be installed where the rating of the surge arrester is less than the maximumcontinuous phase-to-ground voltage at the power frequency available at the point of application.

242.49 Routing of Surge Arrester Equipment Grounding Conductors.

The conductor used to connect the surge arrester to line, bus, or equipment and to an equipmentgrounding conductor or grounding electrode connection point as provided in 242.51 shall not be any longerthan necessary and shall avoid unnecessary bends.

242.51 Connection.

The arrester shall be connected to one of the following:

(1) Grounded service conductor

(2) Grounding electrode conductor

(3) Grounding electrode for the service

(4) Equipment grounding terminal in the service equipment

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242.53 Surge-Arrester Conductors.

The conductor between the surge arrester and the line, and the surge arrester and the groundingconnection, shall not be smaller than 6 AWG copper or aluminum.

242.55 Interconnections.

The surge arrester protecting a transformer that supplies a secondary distribution system shall beinterconnected as specified in 242.55(A), (B), or (C).

(A) Metal Interconnections.

A metal interconnection shall be made to the secondary grounded circuit conductor or the secondarycircuit grounding electrode conductor, if, in addition to the direct grounding connection at the surgearrester, the connection complies with 242.55(A)(1) or (A)(2).

(1) Additional Grounding Connection.

The grounded conductor of the secondary has a grounding connection elsewhere to a continuous metalunderground water piping system. In urban water-pipe areas where there are at least four water-pipeconnections on the neutral conductor and not fewer than four such connections in each mile of neutralconductor, the metal interconnection shall be permitted to be made to the secondary neutral conductorwith omission of the direct grounding connection at the surge arrester.

(2) Multigrounded Neutral System Connection.

The grounded conductor of the secondary system is part of a multigrounded neutral system or static wireof which the primary neutral conductor or static wire has at least four grounding connections in each 1.6km (1 mile) of line in addition to a grounding connection at each service.

(B) Through Spark Gap or Device.

Where the surge arrester grounding electrode conductor is not connected as in 242.55(A), or where thesecondary is not grounded as in 242.55(A) but is otherwise grounded as in 250.52, an interconnectionshall be made through a spark gap or listed device as required by 242.55(B)(1) or (B)(2).

(1) Ungrounded or Unigrounded Primary System.

For ungrounded or unigrounded primary systems, the spark gap for a listed device shall have a 60-Hzbreakdown voltage of at least twice the primary circuit voltage but not necessarily more than 10 kV, andthere shall be at least one other ground on the grounded conductor of the secondary that is not less than6.0 m (20 ft) distant from the surge-arrester grounding electrode.

(2) Multigrounded Neutral Primary System.

For multigrounded neutral primary systems, the spark gap or listed device shall have a 60-Hz breakdownof not more than 3 kV, and there shall be at least one other ground on the grounded conductor of thesecondary that is not less than 6.0 m (20 ft) distant from the surge-arrester grounding electrode.

(C) By Special Permission.

An interconnection of the surge-arrester ground and the secondary neutral conductor, other than asprovided in 242.55(A) or (B), shall be permitted to be made only by special permission.

242.57 Grounding Electrode Conductor Connections and Enclosures.

Except as indicated in this article, surge-arrester grounding electrode conductor connections shall bemade as specified in Article 250, Parts III and X. Grounding electrode conductors installed in metalenclosures shall comply with 250.64(E).

Additional Proposed Changes

File Name Description Approved

242_5vs_07_13_18.doc Article 242 outline of how the Section should be listed

Statement of Problem and Substantiation for Public Comment

see the attached document --- For improved usability, this order would be more usable to the readers and enforcers of Article 242. Part II and Part III have been aligned to create as much continuity as possible.

Related Item

• FR 8221

Submitter Information Verification

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Submitter Full Name: Vince Baclawski

Organization: Nema

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 27 11:27:02 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Vince Baclawski, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enterinto this copyright assignment.

By checking this box I affirm that I am Vince Baclawski, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature

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NFPA Public Comment Form (For Proposing Revisions to the First Draft)

NOTE: All Public Comments must be received by 5:00 pm EST/EDST on the published Public Comment Closing Date.

For further information on the standards-making process, please contact the Codes and Standards Administration at 617-984-7249 or visit www.nfpa.org/codes.

For technical assistance, please call NFPA at 1-800-344-3555

FOR OFFICE USE ONLY

Log #:

Date Rec’d:

Date Name Vince Baclawski Tel. No. 703-841-3236

Company National Electrical Manufacturers Association (NEMA) Email [email protected]

Street Address 1300 North 17th Street, Suite 900 City Rosslyn State VA Zip 22209

Please indicate organization represented (if any) NEMA

1. (a) NFPA Document Title

National Electricrical Code NFPA No. & Year 70-2020

(b) Section/Paragraph 242

2. Identify First Revision and/or Input to which Comment relates: No(s).

FR 8221

2. Public Comment Recommends (check one): new text revised text deleted text 3. Proposed Text of Public Comment (include proposed new or revised wording, or identification of wording to be deleted): [Note: Proposed text should be in legislative format showing proposed changes to the First Draft; i.e., use underscore to denote wording to be inserted (inserted wording) and strike-through to denote wording to be deleted (deleted wording).]

Part II - SPDs Part III – Surge Arrester 242.6 Uses Not Permitted 242.47 Uses Not Permitted 242.9 Listing 242.11 Short-Circuit Current Rating 242.21 Type 1 SPDs 242.43 Surge Arrester Selection 242.23 Type 2 SPDs 242.25 Type 3 SPDs 242.17 Type 4 and Other Component Type SPDs

242.7 Number Required 242.41 Number Required 242.13 Location 242.45 Location 242.15 Routing of Connections 242.49 Routing of Surge Arrestor Grounding

Conductors 242.19 Connection 242.51 Connections 242.27 Conductor Size 242.53 Surge Arrester Conductors 242.29 Connection between Conductors 242.55 Interconnections 242.31 Grounding Electrode Conductor Connections and Enclosures

242.57 Grounding Electrode Conductor Connections and Enclosures

4. Statement of Problem and Substantiation for Public Comment: (Note: State the problem that would be resolved by your recommendation; give the specific reason for your Public Comment, including copies of tests, research papers, fire experience, etc. If more than 200 words, it may be abstracted for publication.)

For improved usability, this order would be more usable to the readers and enforcers of Article 242. Part II and Part III have been aligned to create as much continuity as possible.

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5. Copyright Assignment

(a) I am the author of the text or other material (such as illustrations, graphs) proposed in the Public Comment.

(b) Some or all of the text or other material proposed in this Public Comment was not authored by me. Its source is as follows: (please identify which material and provide complete information on its source)

I hereby grant and assign to the NFPA all and full rights in copyright in this Public Comment (including both the Proposed Text and the Statement of Problem and Substantiation). I understand that I acquire no rights in any publication of NFPA in which this Public Comment in this or another similar or analogous form is used. Except to the extent that I do not have authority to make an assignment in materials that I have identified in (b) above, I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this assignment.

Signature (Required)

PLEASE USE SEPARATE FORM FOR EACH PUBLIC COMMENT To: Secretary, Standards Council National Fire Protection Association

1 Batterymarch Park ∙ Quincy, MA 02169-7471 OR Fax to: (617) 770-3500 OR Email to: [email protected]

9/4/2018

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Public Comment No. 331-NFPA 70-2018 [ Section No. 242.9 ]

242.9 Listing and SPD Type Number .

An SPD shall be a listed device. listed and identified as a Type 1 SPD, a Type 2 SPD, or a Type 3 SPD, inaccordance with the specifications of 242.21, 242.23, or 242.25, respectively.

Statement of Problem and Substantiation for Public Comment

ENFORCEABILITY:.• SPD Type numbers should be referenced to their corresponding defining specifications in FR-8221 at 242.21 or 242.23 or 242.25. These SPD Type numbers are essential to preclude misapplication of a given SPD Type at an incorrect circuit location. Therefore, SPD Type number must be identified to the installer and to the AHJ..• The listing standard UL 1449 in Clause 80.1 c) and in its Exception No. 4 requires that the SPD Type number be marked on the product itself or on the smallest-unit shipping container as part of the listing..• The word of 242.9 in FR-8221 and of existing 285.6 states effectively that a "surge protective DEVICE shall be a listed DEVICE" is a redundant, blank check as to what the product is listed as beyond a nebulous "device"; just state that a "surge protective DEVICE shall be listed ...", implicit that it's listed as a surge protective device and not as some other device.

Related Item

• First Revision No. 8221-NFPA 70-2018 [ Global Input ]

Submitter Information Verification

Submitter Full Name: Brian Rock

Organization: Hubbell Incorporated

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 01 12:31:43 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Brian Rock, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Brian Rock, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Public Comment No. 335-NFPA 70-2018 [ Section No. 242.13 ]

242.13 Location.

SPDs identified with an enclosure-type number shown in Table 110.28 solely for indoor use or marked"Indoor Use Only" shall be located indoors. SPDs identified with an enclosure-type number as shown inTable 110.28 for outdoor use shall be permitted to be located indoors or outdoors and outdoors. Open-type SPDs shall be made inaccessible to unqualified persons unless listed for installation in accessiblelocations .

Statement of Problem and Substantiation for Public Comment

ENFORCEABILITY:.• Existing 285.11 (being superseded by new 242.13 in FR-8221) requires SPDs to be located mandatorially where inaccessible to unqualified persons, unless listed for installation in accessible locations, and permissively indoors or outdoors. .• By contrast, the listing requirements mandate that SPDs during normal usage be suitable for personal contact by unqualified persons in accessible locations; being enclosed electrically is inherent to the basic SPD listing. It is solely open-type SPDs that are listed solely to be rendered inaccessible to personal contact by unqualified persons..• UL Standard UL 1449, Clause 80.38, mandates that open-type SPDs be identified as requiring installation within an enclosure (i.e., live parts inaccessible to unqualified persons). .• UL Standard UL 1449, Clause 80.14 Exception No. 1, requires Type 1 SPDs, Type 2 SPDs, and Type 3 SPDs intended for outdoor usage to be evaluated and identified for Enclosure Numbers for outdoor use as indicated in NEC® Table 110.28..• This proposed wording here will bring the requirements into alignment with the listing standard UL 1449 and therefore more readily enforceable to the AHJ.

Related Item

• First Revision No. 8221-NFPA 70-2018 [ Global Input ]

Submitter Information Verification

Submitter Full Name: Brian Rock

Organization: Hubbell Incorporated

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 01 13:11:19 EDT 2018

Committee: NEC-P10

Copyright Assignment

I, Brian Rock, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Brian Rock, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, uponmy submission of this form, have the same legal force and effect as a handwritten signature

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Page 266: NATIONAL ELECTRICAL CODE CODE-MAKING PANEL 10 ......NATIONAL ELECTRICAL CODE® CODE-MAKING PANEL 10 NFPA 70 Second Draft Meeting Agenda October 29 – November 3, 2018 San Diego, CA

National Fire Protection Association Report https://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPar...

189 of 189 9/14/2018, 10:13 AM

Code-Making Panel 10 Second Draft Meeting Agenda October 29 - November 3, 2018

Page 266 of 266