Report of the Committee on Jeffrey L. Steplowski, Emergency Power Supplies Herbert V. Whittall, Douglas S. Erickson,

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1 Copright 2001, NFPA Report of the Committee on Emergency Power Douglas S. Erickson, Chair American Society for Healthcare Engineering, VI [U] Manuel J. DeLerno, Secretary S-P-D Industries Inc., IL [SE] Ernest E. Allen, Ohio Hospital Insurance Co., OH [I] Rep. NFPA Health Care Section Lawrence A. Bey, Onan Corporation, MN [M] Ford W. Burgess, Westinghouse Savannah River Co., SC [U] Dan Chisholm, Motor and Generator Institute, Inc., FL [IM] Kenneth A. Cotton, Enviroguard, CA [M] Herbert Daugherty, Middlesex County Utilities Authority, NJ [M] Rep. Electrical Generating Systems Assoc. Dennis DeMoss, Sargent & Lundy, IL [SE] William H. Everard, Everard Fire Protection Engineering Limited, VA [SE] Ronald Marts, Telcordia Technologies, Inc., NJ [U] Louis R. Myers, Marathon Electric, WI [M] Rep. National Electrical Manufacturers Association David K. Norton, U.S. Department of Veterans Affairs, DC [U] Daniel J. O Connor, Schirmer Engineering Corporation, IL [SE] Rep. American Hotel & Lodging Association Stan Pukash, ASCO Power Technologies, NJ [M] Harry Ruetschlin, Underwriters Laboratories Inc., IL [RT] Timothy G. Stillman, Fort Lauderdale, FL [C] David Stymiest, Smith Seckman Reid, Inc., LA [SE] Delmont C. Thurber, Great Falls, MT [SE] David E. Watters, H. F. Lenz Co., PA [IM] Fred M. Zelkowitz, SBC Services, Inc., CA [U] Alternates Charles D. Hughes, Westinghouse Savannah River Co., SC [U] (Voting Alt.) James R. Iverson, Onan Corporation, MN [M] (Alt. to L. A. Bey) Michael S. Shulman, Underwriters Laboratories Inc., CA [RT] (Alt. to H. Ruetschlin) Ronald M. Smidt, Carolinas HealthCare System, NC [U] (Alt. to D. S. Erickson) Jeffrey L. Steplowski, U.S. Department of Veterans Affairs, DC [U] (Alt. to D. K. Norton) Herbert V. Whittall, Electrical Generating Systems Association, FL [M] (Alt. to H. Daugherty) Staff Liaison: Craig H. Kampmier Committee Scope: This Committee shall have primary responsibility for documents on performance criteria for the selection and assembly of the components for emergency and standby power systems in buildings and facilities, including categories of power supplies, transfer equipment, controls, supervisory equipment, and all related electrical and mechanical auxiliary or accessory equipment needed to supply emergency or standby power to the utilization equipment. The Committee also shall be responsible for criteria on the maintenance and testing of the system. This Committee does not cover requirements for the application of emergency power systems, self-contained emergency lighting units, and electrical wiring, except that wiring that is an integral part of the system up to the load side of the transfer switch(es). This list represents the membership at the time the Committee was balloted on the text of this edition. Since that time, changes in the membership may have occurred. A key to classifications is found at the front of this book. This portion of the Technical Committee Report of the Committee on Emergency Power is presented for adoption. This Report on Comments was prepared by the Technical Committee on Emergency Power, and documents its action on the comments received on its Report on Proposals on NFPA 110, Standard for Emergency and Standby Power Systems, 1999 edition, as published in the Report on Proposals for the November Meeting. This Report on Comments has been submitted to letter ballot of the Technical Committee on Emergency Power, which consists of 22 voting members. The results of the balloting, after circulation of any negative votes, can be found in the report. 41

2 (Log #CC1) (Chapter 2 Tank Integral): Reject RECOMMENDATION: Adopt the preferred definitions from the NFPA Glossary of Terms for the following terms: Tank, Integral. (preferred) NFPA 31, 1997, ed. A tank that is furnished by the manufacturer as an integral part of an oil-burning appliance. Tank, Integral (secondary) NFPA 110, 1999, ed. A fuel tank furnished by the EPS manufacturer and mounted on the engine or the engine subbase. SUBSTANTIATION: Adoption of preferred definitions will assist the user by providing consistent meaning of defined terms throughout the National Fire Codes. Retain NFPA 110 definition. COMMITTEE STATEMENT: The definition is unique to NFPA 110. The preferred definition does not address the committee's intent. (Log #CC2) (Table 2-2.1(a)): Accept RECOMMENDATION: Revise the following: Type U Type 10 Type 60 Type 120 Type M To read as follows: Type U Type 10 Type 60 Type 120 Type M Table 2.2.1(a) Types of EPSSs Basically uninterruptible (UPS Systems 10 seconds 60 seconds 120 seconds Manual stationary or nonautomatic no time limit Table Types of EPSSs Basically uninterruptible (UPS Systems 10 seconds 60 seconds 120 seconds Manual stationary or nonautomatic no time limit SUBSTANTIATION: Editorial. The NFPA 110 Draft does not contain the text as it currently exists in NFPA 110. No changes were made to this table during the proposal period. (Log #4) (3-2.1): Reject SUBMITTER: Kenneth M. Elovitz, Foxboro, MA RECOMMENDATION: Reject the proposal. SUBSTANTIATION: I find the explanations of negative votes persuasive. COMMITTEE STATEMENT: The revised wording would not force a listed generator set on anyone who doesn't want one for whatever the reason, but also recognizes the reality in the industry that UL2200 has been published and that listed generator sets are becoming available. The comment preserves the two existing alternatives in of prototype testing of a complete generator set or component testing only,if acceptable. The revision is to add one new alternative; a listed generator set. AFFIRMATIVE: 15 CHISHOLM: Concerning NFPA 110, 3-2.1, Comment Regarding Third Party Certification With UL/Onan's Comment suggesting a compromise where the UL2200 listing would represent one of three option, many have adopted the attitude that as long as there are options, and there is presumably the choice NOT to list, what is the harm in accepting the Comment on their Proposal? I wish to emphasize that, indeed, there IS harm. We must not be misled by the sound of this compromise nor by verbal assurances concerning price; if this modification is passed, UL2200 will inevitably become a requirement for every generator set installation in the United States - and at a cost that will be borne by all of us. It will be as if the other options did not exist. Why? Because when presented with a choice between expenditure of time, effort, and expense involved in job site acceptance testing, and passing the buck, inspectors will pass the buck - - it's just human nature. I believe we are in agreement that UL has never proven their case for the establishment of a standard for listing generators. The industry also agrees that such a listing standard will not increase the reliability of the EPS nor will it reduce safety hazards for the operator. By their own admission, UL states that they shall not be responsible to anyone for the use of or reliance upon this Standard. (See Yet now we are afraid that if we just say no to UL we will be charged with obstructing their right to business. The issue should not be whether we are stepping on UL's rights to make money, but how to best guarantee the proper functioning of the EPS during an emergency. Can we say that UL2200 will enhance this mission, or that it is in our best interest? Not only do I not believe UL2200 is a solution; I'm afraid it may indirectly cause problems. One of my biggest concerns about UL and I know I am not alone in this - is that the false sense of confidence conveyed by the listing will lead to a lax attitude towards maintenance and testing. By saying yes to UL2200, I believe we will be inevitably faced with an increase in problems and failures of the EPS associated with poor maintenance practices. The UL/Onan Comment for a compromise is a clever way to achieve their original goal: mandating third party certification. Please consider the impact UL2200 will have on just the cost of health care - increased costs which will not translate to increased reliability, and vote not to accept this Comment. MARTS: After listening to several conversations, I have become convinced that UL 2200 should not be referenced in NFPA 110. It is a solution to a nonexistent problem. I have seen no documentation or evidence that we have had an unacceptable level of problems with EPSS. Referencing this standard will not add value but will add cost. Additionally, the reference is not in NFPA 37. DeLERNO: I have abstained because I am not convinced of the inequality of merit of the two opposing positions. The real issue is political, not technical. I serve no interest group on this committee, hence feel that I can remain neutral at this stage of the deliberations. (Log #5) (3-2.1): Accept in Part RECOMMENDATION: Revise text as follows: The capability of the energy converter, with its controls and accessories, to survive without damage from common and abnormal disturbances in actual load circuits shall be demonstrable: 1. by tests on separate prototype models, or 2. by acceptable tests on the system components as performed by the component suppliers, or 3. by listing for emergency service as a completely factory - assembled and factory-tested apparatus, or 4. by any combination of 1 through 3. 42

3 SUBSTANTIATION: This comment addresses the concerns of committee members who voted negatively on the original proposal. The revised wording would not force a listed generator set on anyone who doesn t want one for whatever the reason, but also recognizes the reality in the industry that UL 2200 has been published and that listed generator sets are becoming available. The comment preserves the two existing alternatives in of prototype testing of a complete generator set or component testing only, if acceptable. The revision is to add two new alternatives; a listed generator set, or a generator set that demonstrates the requirement by more than one criterion. COMMITTEE ACTION: Accept in Part. Accept items 1, 2, and new number 3. Reject Item No. 4. COMMITTEE STATEMENT: Item number 4 is redundant. AFFIRMATIVE: 14 NEGATIVE: 3 MYERS: UL 2200 is a non-ansi standard at this time. I do not feel that it would be in the best interest of NFPA 110 to reference this standard or to allow a third option using it. NFPA 110 is inclusive enough without mentioning UL 2200 or referring to UL In addition, the incompleteness of UL 2200 can also place undo burden upon the genset manufacturer, and final end user, where none had existed before. An AHJ could select this third option as an exclusive, therefore eliminating the other two. This could give way to personal preference rather than an objective use of the NFPA 110 standard. At the same time, the requirement of a genset to be UL 2200 listed, as required by an AHJ, could create a market advantage for some manufacturers. This requirement could prohibit the end user from using the most cost/performance effective genset, as well as restricting the use of prototype testing not witnessed by UL. Not to mention that some EPS suppliers may view it as a barrier to trade. Also, the UL 2200 standard has not been, to my knowledge, finalized into a working document that completely encompasses a genset, and its requirements. It contains specifications that UL has drawn from other standards, which are unproven, and it contains statements that are unclear. This standard will have to be revised several times before it is complete and user friendly. Therefore, NFPA 110 should not be using it as a reference. Finally, while listing a set may have some advantages, the standard does nothing to improve the NFPA 110 standard. In fact, due to it's incompleteness, and non-ansi status, it could lower the credibility of NFPA 110. For these reasons, I vote Negative on the committee's action on comment (Log #5). (Log #11) (3-2.1): Reject SUBMITTER: Rick Zurich, Martin Memorial Health Systems Inc. RECOMMENDATION: I agree with the Committees Action. This proposal must be rejected. SUBSTANTIATION: Reject this proposal. COMMITTEE STATEMENT: The revised wording would not force a listed generator set on anyone who doesn't want one for whatever the reason, but also recognizes the reality in the industry that UL2200 has been published and that listed generator sets are becoming available. The comment preserves the two existing alternatives in of prototype testing of a complete generator set or component testing only,if acceptable. The revision is to add one new alternative; a listed generator set. AFFIRMATIVE: 14 ABSTENTION: 2 ERICKSON: While the compromise position of offering three different means of assuring energy converter reliability is better than the initial proposal to offer UL 2200 as the only means for demonstrating survivability, the American Society for Healthcare Engineering membership is evenly split on this recommended change and therefore does not have a formal position to offer at this time. (Log #12) (3-2.1): Reject SUBMITTER: Rodney J. Allen, Lee Memorial Health System - Cape Coral Hospital RECOMMENDATION: I agree with the Technical Committee s rejection. SUBSTANTIATION: None given. COMMITTEE STATEMENT: See Committee Statement on Comment (Log #11). AFFIRMATIVE: 15 (Log #15) (3-2.1): Accept in Principle SUBMITTER: Thomas J. Garvey, State of Wisconsin RECOMMENDATION: Accept revised text as submitted. SUBSTANTIATION: As an AHJ I agree and support the submitter s substantiation without listing, inconsistent examination and approval between jurisdictions is guaranteed. Emergency system reliability is most certainly a safety issue. I strongly disagree with the negative statements of Committee Members. COMMITTEE STATEMENT: Listed generators are an option. See Committee Action taken on Comment (Log #5). AFFIRMATIVE: 15 43

4 (Log #3) (3-3.1): Reject SUBMITTER: Kenneth M. Elovitz, Foxboro, MA COMMENT ON PROPOSAL NO: RECOMMENDATION: Revise text as follows: The EPS shall be heated as necessary to maintain the water jacket temperature determined published by the EPS manufacturer in its engineering catalog or application data for cold start and load acceptance for the type of EPSS. SUBSTANTIATION: There is no point to imposing this requirement if the manufacturers are not similarly obligated to make the necessary details known to the engineering community so the requirement can be addressed during system design. COMMITTEE STATEMENT: The EPS manufacturer is not presently required to publish a temperature. The committee has decided by its action on Proposal (Log #7) to move to a performance based requirement instead of prescriptive. AFFIRMATIVE: 17 NEGATIVE: 1 CHISHOLM: I disagree with the TC statement that requiring EPS manufacturers to publish their recommended temperature readings would move us away from performance-based standards. Since we are to maintain EPSs according to manufacturer's specifications we must know what they are to be able to perform maintenance as recommended. I agree with Mr. Elovitz's substantiation. (Log #CC4) ( ): Accept RECOMMENDATION: Revise the following: Governors shall maintain a bandwidth of rated frequency for any constant load (steady-state condition). As follows: Governors shall maintain a bandwidth of rated frequency for any constant load (steady-state condition) that is compatible with the load. SUBSTANTIATION: Editorial clarification. (Log #CC3) ( ): Accept RECOMMENDATION: Revise the following: the maintenance-free variety. As follows: the maintenance-free (valve regulated type) variety. SUBSTANTIATION: Editorial clarification of nomenclature. (Log #CC3) ( ): Accept RECOMMENDATION: Revise the following: the maintenance-free variety. As follows: the maintenance-free (valve regulated type) variety. SUBSTANTIATION: Editorial clarification of nomenclature. (Log #8) (5-2.5): Accept in Principle COMMENT ON PROPOSAL NO: RECOMMENDATION: Revise text to read as follows: The EPS equipment shall be installed in a location that permits ready accessibility and a minimum of 30 in. (76 cm) 36 in. (76 cm) clearance from the prime mover valve covers from the skid rails in the direction of access for inspection, repair, maintenance, cleaning, or replacement. This requirement shall not apply to units in outdoor housings. SUBSTANTIATION: The prime mover valve covers are not a good reference point for working clearances, it doesn t work on an in-line six cylinder unit for example. The valve covers don t work at all as a reference point from the generator end of the unit. The skid base rails do work as a reference point in all the directions of access. Standard industry practice for generator sets in outdoor housings and shelters is to provide access through service doors, not between the unit and the inside walls of the housing. Modify the submitter s recommendation: Revise text to read as follows: The EPS equipment shall be installed in a location that permits ready accessibility and a minimum of 30 in. (76 cm) 36 in. (76 cm) clearance from the prime mover valve covers from the skid rails outermost point in the direction of access for inspection, repair, maintenance, cleaning, or replacement. This requirement shall not apply to units in outdoor housings. COMMITTEE STATEMENT: The skid rails are sometimes narrower than the valve covers of a V-shaped engine, and there is a need for 30 inches clearance from the outermost projection from the generator set. (Log #2) (5-7.6, 5-7.7): Reject SUBMITTER: Kenneth M. Elovitz, Foxboro, MA COMMENT ON PROPOSAL NO: RECOMMENDATION: Delete this section. SUBSTANTIATION: With the proposed new Section (Proposal 110-7), there is no need for this section as a separate requirement. COMMITTEE STATEMENT: One need speaks to the ambient room temperature. The other need is for the engine jacket temperature. Both temperatures need to be identified within this document. (Log #1) ( ): Accept SUBMITTER: Michael A. Ratcliff, Rowen, Williams Davies & Irwin, Inc. RECOMMENDATION: Add new text as follows: For reciprocating engines, the piping shall terminate in 44

5 any of the following: (1) raincap (2) tee (3) ell, pointing downward from the prevailing wind (4) vertically upwards oriented stack with suitable provisions for trapping and draining rain and snow water. SUBSTANTIATION: Vertical exhaust is preferred over horizontal exhaust from raincaps, tees and ells. Horizontal exhaust is much more likely to reenter a building, in violation of Section of NFPA 110. Horizontal exhaust will be trapped by winds in wake of building unless a very tall stack is provided. Vertical stack should be allowed. (Log #7) ( ): Accept COMMENT ON PROPOSAL NO: RECOMMENDATION: Revise text as follow: A unity power factor shall be acceptable permitted for on-site testing... SUBSTANTIATION: Editorial. (Log #14) ( (New) ): Accept in Principle SUBMITTER: Robert Bourke COMMENT ON PROPOSAL NO: RECOMMENDATION: Add a new to read: The operational test shall be initiated at an automatic transfer switch and shall include testing of each EPSS component that maintenance or repair has been performed, including the transfer of each automatic and manual transfer switch to the alternate power source, for a period of not less than 30 minutes under operating temperature. SUBSTANTIATION: We agree partially with the negatives from Chisholm and Johnson. The proposed wording better clarifies that the testing would only be on the equipment that maintenance or repair was performed. This was also added as a new section for ease in use. Modify the recommendation as follows: Add a new to read: The operational test shall be initiated at an automatic transfer switch and shall include testing of each EPSS component that on which maintenance or repair has been performed, including the transfer of each automatic and manual transfer switch to the alternate power source, for a period of not less than 30 minutes under operating temperature. COMMITTEE STATEMENT: Editorial, changing that to on which. (Log #10) (6-4.2(a)): Accept in Principle SUBMITTER: Dan Chisholm, Healthcare Circuit News-MGI RECOMMENDATION: Revise text to read as follows: Under operating temperature conditions or and at not less than 30 percent of the EPS standby amperage nameplate rating. SUBSTANTIATION: The present text actually gives two options. I don t believe this was the intent. The term nameplate rating has caused confusion and endless debates on kw vs. kva and whether power factors should be considered. Modify the recommendation as follows: Under operating temperature conditions or and at not less than 30 percent of the EPS standby amperage nameplate Kw rating. COMMITTEE STATEMENT: Kw represents the true engine loading, which is the intent of the committee. (Log #13) (6-4.8, , A-6-4.8): Accept in Principle COMMENT ON PROPOSAL NO: RECOMMENDATION: Add text to read as follows: The EPSS shall be tested for the duration of its assigned Class (see 2-2.3), or for a duration agreed to by the Authority Having Jurisdiction not to exceed 4 hours, at least once within every 36 months The load shall be the connected EPSS system load. The test shall be initiated by opening all switches or breakers supplying normal power to the EPSS. A power interruption to non-epss loads shall not be required. A The intent of this requirement is to provide reasonable assurance that the EPSS with all of its auxiliary subsystems is capable of running for the duration of its assigned Class with its connected load. A full facility power outage is not intended for this test, but is not precluded either. Supplemental load banks should not be required. After the test the fuel supply should be replenished if necessary. SUBSTANTIATION: A Task Group was formed to look at this issue, chaired by Dan Chisolm and including members Stymiest, Norton, and Bey. As a result of Task Group discussion the following revisions to the Committee Action on Proposal are suggested. Renumber as a new and A making the test a mandatory test. Revised EPS to EPSS to clarify this is a system-wide test. Changed the duration of the test to a maximum of 4 hours and reduce the frequency to once in 36 months based on EPSS system test experience from Y2k preparations of a large user. Added clarification in concerning the test load to be used and that the test does not necessarily include removing normal power to the entire facility. Revised the Appendix note to clarify the intent. Modify as follows: The EPSS shall be tested for the duration of its assigned Class (see 2-2.3), or for a duration agreed to by the Authority Having Jurisdiction not to exceed for at least 4 hours, at least once within every months The load shall be the connected EPSS system load running at the time of the test. The test shall be initiated by opening all switches or breakers supplying normal power to the EPSS. A power interruption to non-epss loads shall not be required. A The intent of this requirement is to provide reasonable assurance that the EPSS with all of its auxiliary subsystems is capable of running for the duration of its assigned Class with its running connected load. A full facility power outage is not intended for this test, but is recommended where a total facility power outage has not occurred within the last 48 months not precluded either. Supplemental load banks should are not be required. After the test the fuel supply should be replenished if necessary. COMMITTEE STATEMENT: The committee's intent with this proposal is to require a minimum, rather than a maximum, test duration within a reasonable period. The committee's intent is not to require that all or additional loads be turned on for this test. AFFIRMATIVE: 17 ERICKSON: I want to thank the task force that worked to come up with a compromise on the proposed requirements for additional EPSS testing. It is my opinion that the new sections will 45

6 provide the end user with a much more reliable system. With all of the daily modifications in health care facility infrastructures, a three to four year test of the entire EPSS system seems to make good common sense. However, the American Society for Healthcare Engineering membership is evenly split on this new requirement as many of our members have a strong opinion over the need for the test and how this test is going to be performed without an adverse patient related incident. (Log #9) (A (New) ): Accept in Principle SUBMITTER: Jim Everitt COMMENT ON PROPOSAL NO: RECOMMENDATION: Revise to read: A For additional guidance in determining compliance with this section see UL 2200 Standard for Stationary Engine Generator Assemblies. SUBSTANTIATION: Provided additional guidance to the user and enforcer on compliance with this section. Modify as follows: A For additional guidance in determining compliance with this section see UL 2200 Standard for Stationary Engine Generator Assemblies. COMMITTEE STATEMENT: Editorial. AFFIRMATIVE: 16 CHISHOLM: I disagree with the TC action to accept this comment. Since UL 2200 does not mention the most important and simplest OSHA lockout/tagout requirements found in , I cannot see where relying on UL 2200 for guidance is a good idea. Additionally, the following statement is found in the Foreword of UL 2200 (page 4, Section E'): UL, in performing its functions in accordance with its objectives, does not assume or undertake to discharge any responsibility of the manufacturer or any other party. The opinions and findings of UL represent its professional judgment given with due consideration to the necessary limitations of practical operation and state of the art at the time the Standard is processed. UL shall not be responsible to anyone for the use of or reliance upon this standard by anyone. UL shall not incur any obligation or liability for damages, including consequential damages, arising out of or in connection with the use, interpretation of or reliance upon this Standard. COMMENT ON AFFIRMATIVE: ALLEN: At the time of the first proposal there was only one manufacturer UL certified, and it was assumed that the UL certification fee would be expensive. Much has changed, as now almost all generator manufacturers are or will be UL certified. Another significant factor is that the manufacturers' price lists show the same price for UL certified and non-ul certified units. Although I am not aware of any patient injury from a malfunction of an emergency generator, the UL certification testing process may identify and eliminate potential deficiencies. It has been reported by representatives of the manufacturers that modifications were made as a result of the UL certification process. Thus, a UL listed generator could help prevent a malfunction and resulting injury. If there was a generator failure with patient injury and lawsuit filed, it may help to have UL certification. For example, if the cause of failure was difficult to determine, a jury might have doubts as to why the hospital did not purchase a UL listed unit, especially if the cost was the same. The plaintiff attorney could make a successful argument that his client would still be alive if the hospital had cared enough to buy a UL listed unit. I believe that there should still be acceptance testing for installation of new generators, whether UL listed or not. It is needed to show the unit was not damaged in shipment and was installed correctly. NFPA 110 remains important to provide guidance for installation, maintenance and testing of the generator. In summary, with the price and availability issues eliminated, UL certification is appropriate per the committee action. (Log #6) (A-6-3.6): Accept COMMENT ON PROPOSAL NO: RECOMMENDATION: Revise the text to read: A battery load test should be performed quarterly. SUBSTANTIATION: There are several problems with this proposal as accepted and modified by the Committee. While the intent of the proposal to include load testing of the starting batteries is good, there are problems with how to test the battery. First, there are no specifications given for the recording voltmeter to be used, so different meters and meter dampening would give different results. Second, there is no substantiation for the 20 percent voltage drop during cranking, the actual voltage drop of a healthy battery could be more than 20 percent. Third, there is no recognition of cranking voltage varying over time as the starter motor accelerates. In other words, both excessive voltage drop and a slow recovery to nominal would evidence a weak battery. Fourth, the integrity of the battery is a vague concept. What would be investigated? The Committee modification references back to the low battery voltage alarm, but low battery voltage is actually an indication of a battery charger problem, not bad batteries. 46