1 IEEE Standards Coordinating Committee on National Fire Protection Association Standards (SCC 18) Report on Comments 2008 National Electrical Code CMP #11 Actions Articles 409, 430, 440, 460, 470 & Annex D Example D8 Lynn Saunders, Principal Arthur Smith, Alternate January 3, 2007

2 CMP #11 Actions Summary of Panel Activities: 42 Comments Total (Inc. 1 CMP Comment) Accept1130% Accept in Principal 3 8% Accept in Part 1 3% Accept in Prin. in Part 3 8% Reject 24 51% 15 Voting Members on CMP #11

3 Topics to Review with IEEE SCC 18 1.Wiring space in Industrial Control Panels 2.Valve Actuator Motors 3.Use of Formula for calculation of conductor protection - “Engineering Supervision” 4.Ground Fault Protection for Motor Circuits 5.Motor Disconnects – “Readily accessible”

4 1. Wiring space in Industrial Control Panels Comment 11-1 Log #2325 Panel Action:ACCEPT Proposal 11-8( (B)) Article Industrial Control Panels RECOMMENDATION: Revise text to read as follows: Wiring Space in Industrial Control Panels. (B) Wire bending space. Wire bending space for the main supply terminals shall be in accordance with the requirements in Wire bending space within industrial control panels for other field wiring terminals shall be in accordance with the requirements in (B). The gutter space shall comply with SUBSTANTIATION: The proposal should have been accepted in principle for the following reasons: offers two wire bending options with a number of exceptions. The options necessitate the knowledge of where the field connected conductors will enter the enclosure. This is seldom known at the time of the placement of the components in an industrial control panel unless it is field assembled at the installation site. A panel assembler remote from the installation could comply with the requirements of by placing the components in a panel suitable for conductor entry at 90 to the component terminals, effectively allowing only about one half the space required for a straight in" entry that might be needed at the installation. Such a misapplication can’t happen with the wire bending space according to Table (B) since its spacing requirements account for the worst case installation. Further, the panel statement indicating that provides "increased wire bending space for supply terminals" seems to imply an advantage, but that would only be true if there was evidence that the spacings required in Table (B) did not provide adequate wire bending space for supply terminals. The spacings shown in Table (B) have been unchanged for years and have been applied for all types of field connected terminals and there was no proposal to change them during this code cycle. Continued --

5 The Proposal at this ROP meeting received a vote of (13-AFFIRMITIVE, 2-NEGATIVE,) to REJECT. (We voted AFFIRMITIVE). In the ROC Meeting, this revised comment received a vote to ACCEPT. RECOMMENDED IEEE SCC 18 Position: We request direction to ACCEPT the panel action to ACCEPT this Proposal (This is a reversal of our original position on the proposal – BASED ON THE NEW SUBSTANTIATION.) SUBSTANTIATION (con’t) 2. The existing text in the second sentence "for other terminals" is ambiguous as to whether these "terminals" are for field connection or those that are interconnected with other components in the panel during its assembly and wiring. The changing to the revised text "for field wiring terminals" mitigates this problem. 3. The last sentence should have been eliminated from (B), as proposed, since the gutter requirements in are essentially part of the (A) existing text. PANEL ACTION:ACCEPT 1. Wiring space in Industrial Control Panels (Con’t) 11-1 Log #2325 Panel Action:ACCEPT Proposal 11-8( (B))

6 2. Valve Actuator Motor – Eight (8) Comments 11-3, 11-4, 11-6, 11-11, 11-12, 11-14, 11-23, Comment Log#612 Final Action: Accept in Principle in Part ( (A) Exception No. 3) Submitter: Paul Guidry, Fluor Enterprises, Inc. Comment on Proposal No: Recommendation: This is a companion proposal for the addition of valve actuator motors. Companion proposal section numbers are: 430.2, 430.6(D), (F), (B), and (E). Add new (A) Exception No. 3 as follows: Exception No. 3: The disconnecting means shall not be required to be in sight of valve actuator motor assemblies containing the controller under either condition (a) or (b), provided the disconnecting means is capable of being locked in the open position. The provision for locking or adding a lock to the disconnecting means shall be installed on or at the switch or circuit breaker used as the disconnecting means and shall remain in place with or without the lock installed. (a) Where such a location of the disconnecting means introduces additional or increased hazards to persons or property (b) In industrial locations, with written safety procedures, where conditions of maintenance and supervision ensure that only qualified persons service the equipment. FPN No. 1: An example of increased or additional hazard is where the valve actuator motor is used for a process emergency shutdown and the failure of the disconnecting means near the valve actuator motor containing the controller would prevent the valve from operating.

7 Comment Log#612 Final Action: Accept in Principle in Part ( (A) Exception No. 3) Substantiation: This comment is based on proposal It was my understanding in the proposal stage that the panel felt like Valve Actuator Motors (VAMs) should be covered by Article 430 (panel comment on proposal 11-81), and that it was reasonable in some situations not to require a disconnecting means within sight of the controller. However, instead of adding the new Part XI as proposed, it was suggested that the current structure of the Code be modified for any rules regarding VAMs. This text is based on the existing exception for motor disconnects in (B). I believe the existing (B) applies to VAMs without an integral controller already and doesn’t require modification.

8 RECOMMENDED IEEE SCC 18 Position: We request direction to ACCEPT the panel action to ACCEPT IN PRINCIPLE IN PART this proposal. Panel Meeting Action: Accept in Principle in Part Add a new exception to (A) to read as follows: Exception No. 3: The disconnecting means shall not be required to be in sight from valve actuator motor (VAM) assemblies containing the controller where such a location introduces additional or increased hazards to persons or property and conditions (a) and (b) are met. (a) Provided the valve actuator motor assembly is marked with a warning label giving the location of the disconnecting means. (b) The provision for locking or adding a lock to the disconnecting means shall be installed on or at the switch or circuit breaker used as the disconnecting means and shall remain in place with or without the lock installed. Panel Statement: The panel rejects the submitter’s part (b) and the FPN. The panel recognizes there could be an increased safety hazard associated with part (b) of the submitter's recommendation. The FPN note is not required because the text of (A) Exception No. 3 is considered sufficient. The panel edits the submitter s Exception NO. 3 for clarity. Comment Log#612 Final Action: Accept in Principle in Part ( (A) Exception No. 3)

9 2. Valve Actuator Motor – Eight (8) Comments 11-3, 11-4, 11-6, 11-11, 11-12, 11-14, 11-23, Comment 11- 4Log#814 Final Action: Accept in Principle in Part (430.2) Submitter: Paul Guidry, Fluor Enterprises, Inc. Comment on Proposal No: Recommendation: This is a companion proposal for the addition of valve actuator motors. Companion proposal section numbers are: 430.6(D), (F), (B), (E) and (A). Add text to read as follows: Valve Actuator Motor Assemblies (VAMs). A manufactured assembly consisting of a valve. valve actuator motor, and other components such as controllers, torque switches. limit switches, and overload protection. Valve actuator motor assemblies are also commonly referred to as "motor-operated valves" or "MOVs. FPN: Valve actuator motors have considerable differences in operating characteristics as compared to NEMA Design B motors due to the VAMs unique design. NEMA Design B motors are continuous duty and rated in horsepower. Which implies a constant torque. Valve actuator motors are usually characterized as short duty time, high starting torque motors and are neither continuous duty or constant torque motors.

10 Substantiation: This comment is based on proposal It was my understanding in the proposal stage that the panel felt like Valve Actuator Motors (VAMs) should be covered by Article 430 (see panel comment on proposal 11-81). However, instead of adding a new Part XI, it was suggested that the current structure of the Code be modified for any rules regarding VAMs. Adding this definition (directly from IEEE Std. 1290) to should satisfy the panel’s concern that the requirements for VAMs won’t be confused with valve modulating motors. Users in the industrial/petrochemical have tried for years to apply Article 430 to valve actuator motors without success. These motors do not fit into any of the present rules that are in Article 430. I believe they need their own special rules in some areas. Comment 11- 4Log#814 Final Action: Accept in Principle in Part (430.2)

11 Panel Meeting Action: Accept in Principle in Part Add a new definition to to read as follows: Valve Actuator Motor (VAM) Assemblies. A manufactured assembly used to operate a valve consisting of an actuator motor, and other components such as controllers, torque switches, limit switches, and overload protection. FPN: VAMs typically have short-time duty and high torque characteristics. Sequence in alphabetical order with existing definitions. Panel Statement: The panel rejects the part of the definition pertaining to the valve and the reference to motor-operated valves (MOVs). The panel also rejects the part of the submitter’s FPN that pertains to NEMA Design B motors. The panel edits the definition and FPN for clarity. Comment 11- 4Log#814 Final Action: Accept in Principle in Part (430.2) RECOMMENDED IEEE SCC 18 Position: We request direction to ACCEPT the panel action to ACCEPT IN PRINCIPLE IN PART this proposal.

12 Comment Panel Meeting Action: Accept in Principle Panel Statement: The submitter’s concerns are addressed by the action on Comment See action and statement on Comment Comment (D) Panel Meeting Action: Reject Panel Statement: Valve actuator motors (VAMs) are high torque motors and are already covered in 430.6(A)(1). 2. Valve Actuator Motor – Eight (8) Comments 11-3, 11-4, 11-6, 11-11, 11-12, 11-14, 11-23, Comment (F) Panel Meeting Action: Reject Panel Statement: Valve actuator motor (VAM) conductors are already covered in the main rule of (E) based on the full load current of (A)(1). Comment (B) Panel Meeting Action: Reject Panel Statement: The submitter s concerns are addressed in 430.6(A)(1) and

13 Comment (E) Panel Meeting Action: Accept in Principle Panel Statement: The submitter s concerns are addressed in existing Table The existing Table for "single-phase motors" and "AC polyphase motors other than wound-rotor squirrel cage other than Design B energy-efficient" applies to AC valve actuator motor assemblies. Comment 11-24( (A) Exception No. 3) Submitter:Louis Barrios Panel Meeting Action: Accept in Principle in Part Panel Statement: The panel rejects the expansion of the exception to industrial locations. The panel chooses not to expand the exception beyond valve actuator motor (VAM) assemblies. The submitter s other concerns are addressed by the action on Comment See the action and statement on Comment Valve Actuator Motor – Eight (8) Comments 11-3, 11-4, 11-6, 11-11, 11-12, 11-14, 11-23, RECOMMENDED IEEE SCC 18 Position: We request direction to ACCEPT the panel action to for the specific actions for these proposals.

14 3. Use of Formula for calculation of conductor protection, and ; “Engineering Supervision” Comment Log#2327 Final Action: Accept (430.28(4)) Submitter: Jim Pauley, Square D Company Comment on Proposal No: Recommendation: Reject the Proposal. Substantiation: The negative commenter's are correct and raise substantial issues that make this an unacceptable approach. This proposal will reduce electrical safety. Overcurrent protection rules in the NEC need to be uniformly applied across application. This revision creates a significant anomaly to that uniformity. The expectation that the system is controlled enough to be able to have such exacting requirements for conductor protection is a flawed expectation. The current tap rules have served well in a large variety of installations and they are consistent with the engineering and maintenance approaches taken in all installations including large industrial.

15 ACTION AT ROP MEETING -- PANEL ACTION:ACCEPT IN PRINCIPLE at ROP PANEL STATEMENT: Revise Add NEW (4) as follows: Be suitably protected from physical damage or in a raceway and protected under short-circuit conditions and determined under engineering supervision to be protected under short-circuit conditions. 3. Use of Formula for calculation of conductor protection, and ; “Engineering Supervision” (Con’t) SUBSTANTIATION : The panel accepts the submitter’s recommendation and the use of formulas rather than tables and has reformatted the recommendation to reflect this. In addition the application has been limited to being performed only under engineering supervision. RECOMMENDED IEEE SCC 18 Position: We request direction to ACCEPT the panel action to ACCEPT this comment (to REJECT the PROPOSAL). This is a REVERSAL of the Action at the ROP Meeting to Accept the use of the Formulae and add a Definition for “Engineering Supervision”. TCC Action: It was the action of the Technical Correlating Committee that this Proposal be reported as “Reject” because less than two-thirds of the members eligible to vote have voted in the affirmative. The reader is directed to the panel statement on Proposal for reference. The panel statement shown in Proposal does not correlate with the action taken by the panel. Proposal 11-16a to add a definition of “Engineering Supervision” was also Rejected by the TCC.

16 4. Ground Fault Protection for Motor Circuits Proposal ( (New) This proposal (and its companion Proposals 2-6, 2-88, and Comments submitted separately) should be accepted. Add to the end of the proposed wording: This requirement shall become effective January 1, This aligns with Mr. Weber's Explanation of Negative for Proposal 2-88 regarding the development of new, life-saving concepts and addresses the Panel Statement of Proposal The Proposal wording, and its included phrase "shall be permitted," is important so the GFCIS-3Ph is identified as a specific permitted alternative. The Panel Statement, "The panel recognizes that the application of this system is permitted to be used for motor circuits as an added technology," avoids the reality that unless a permitted concept is identified in the NEC, it will not be applied. Adding the delayed effective date would provide the incentive and the necessary time for the Three-Phase Ground-Fault Circuit-Interrupter System (GFCIS-3Ph) to be further developed and commercialized. Comment Log#1889 Panel Action:REJECT (430.28(4)) Submitter: Paul S. Hamer Richmond, CA Comment on Proposal No: Recommendation:

17 The Panel Statement of Proposal 2-88, the base Proposal for the GFCIS-3Ph concept, includes "...The submitter's substantiation notes that the hazard is when unqualified persons work on equipment without taking the appropriate precautions to deenergize the circuit and verify that circuit is disconnected...". There are numerous instances where unqualified persons were electrocuted by faulty or defective equipment (see the supporting material submitted with the proposals), and these people may have been protected from electrocution by the proposed GFCIS-3Ph. The patent applications are pending for the GFCIS-3Ph as of this date, but further field measurements made since the Proposal submittal date indicate that the distributed phase capacitances on an actual installed three- phase 480 volt power system are balanced enough to permit the sensitivity described in the proposals. 4. Ground Fault Protection for Motor Circuits (Con’t) Proposal ( (New) Comment Log#1889 Final Action: REJECT (430.28(4)) Substantiation:

18 The submitter has not provided any new motor-related substantiation for reconsideration. Although the panel rejects the submitter's comment, this new technology is an important step forward in the protection of electrical systems and personnel. The panel encourages the submitter to return in the next Code cycle with documentation to the effectiveness, reliability, and availability of this new technology. Again, the panel recognizes that the application of this system is permitted to be used for motor circuits as an added technology. 4. Ground Fault Protection for Motor Circuits (Con’t) Proposal ( (New) Comment Log#1889 Final Action: REJECT (430.28(4)) Panel Statement: RECOMMENDED IEEE SCC 18 Position: We request direction to ACCEPT the panel action to REJECT these proposals. Comment Log#1890 Panel Action: REJECT Proposal (430.64(New)) Add a new section: Ground-Fault Protection of Motor Feeder Circuits. A motor feeder circuit shall be protected from ground faults by the feeder short-circuit and ground-fault protective device, (similar to ) SAME BASIC COMMENT AND ACTIONS – FOR MOTOR FEEDER CIRCUITS

19 5. Motor Disconnects – “Readily accessible” Comment Log #568Final Action: Reject ( (B)) Submitter: J. Ron Caccamese, Nathan Alterman Electric Company, Ltd. / Rep. International Brotherhood of Electrical Workers Comment on Proposal No: Recommendation: Accept the Proposal to Revise as follows: Location. (B) Motor. A disconnecting means shall be located in sight and be readily accessible from the motor location and the driven machinery location. Substantiation: In addition to the substantiation provided by the submitter of Proposal (window as a barrier), there are other obstacles (elevation, fencing, and inaccessible terrain) that would prevent access even though a disconnect is "within sight". The submitter s concern is well founded, and even though provides " readily accessible" requirements, further evaluation is warranted due to safety issues associated with controller disconnect accessibility. This is a safety issue regarding the installation of disconnecting means and readily accessible.

20 5. Motor Disconnects – “Readily accessible” (Con’t) Comment Log #568Final Action: Reject ( (B)) Panel Statement: The panel reiterates its position on Proposal The disconnecting means for the motor is not always required to be readily accessible from the motor. See for readily accessible requirements. Existing Code text requires that at least one of the disconnecting means be readily accessible. In addition, the definition of "in sight from" allows up to 50 feet between the disconnecting means and the motor. The disconnecting means and the motor do not have to be accessible from each other. This Action received a “Voice Vote” of “10 for – 5 against” in the ROC Meeting – We voted for RECOMMENDED IEEE SCC 18 Position: We request direction to ACCEPT the panel action to REJECT these proposals.