NFPA 70E and Electric Utilities

Does 70E apply to utilities? If I am reading Article 90.1 (B) (5) it does not. However, it seems many utilities are pro active about arc flash studies. What is driving this? Liability?

NFPA 70E and Utilities

I believe it is a catch 22. Utilities are bound by OSHA which references 70E then 70E has an exemption for electric utility transmission, generation and distribution. Therefore most utilities that I know are attempting to follow 70E as best as they can even though the nature of the business does not alllow working electrically safe very often. I am sure someone is also thinking about liability also.

I have worked on both utility and non utility systems and my opinion is that NFPA 70E would stop most utilties from performing the work the way they have for the past 100 years.

OSHA clarifies that all referenced material is ONE but not the ONLY way to meet the intent of providing a safe woring environment. The Utilities have been far ahead of NFPA 70E with their own safety practices and standards and have the numbers to back it up. They can continue their practices with the consent of their legal departments and remain square with OSHA. (IMOW of course.)

Don't utiities follow the NESC and would't this be in place of 70E or must they comply with both?

Joe

For transmission work yes I agree, but distribution level they dont take any arc flash precautions, not in my area anyway and not the last place I lived either. We see utilities do all sorts of stuff hot without any PPE all the time, just last week I saw a guy repairing a cable termination (Replaceing mounting bolt for B phase that had broke of and was single phasing transformer).

I imagine this will all change (Slowly, like it has in our world) when the NESC adopts parts of the 70E, which they are in process of doing now.

Electric Distribution System Live Work

One might find it surprising but for many 15 kV distribution systems out there using inst trip attachments on feeder breakers, even at high levels of fault duty the IE can be less than 1 for the primary system. Many systems worst case are still less than 4 cal. Many linemen are wearing FR clothing of at least 4 cal while most would be 7 to 8 cal. Since we don't deal with the arc in a box issue, the energy is not totally focused on the lineman. Once you get to 25 and 35 kV it can get a little worse, but with proper relay settings it is still not an issue....just for info.

Alan

Its not the lines I worry about, it is the padmount tansformers, this guy I saw last week was on the 480V side of the padmount (Long clearing times and high fault currents) replacing a broken connection while energized. Just jeans and a T-shirt.

Padmounts

I do think that if there are significant issues, the pad/ground mounted equipment is where they will be.

Generating Facilities

Generating facilities are technically categorized as "utility" entities. However, their environment is much more industrial (typical switchgear enclosures, lots of low voltage equipment, etc.). Does anyone know of any cases where a generating facility, for liability purposes, specifically avoided citing NFPA 70E in their arc flash policy?

Are these facilites technically exempt from NFPA 70E?

IMO yes they are, article 90.2 (B)(5)
90.2 Scope
B - Not covered
5 - installations under the exclusive control of an electric utility where such installations
c- Are on property owned or leased by the electric utility for the purposes of ..generation..of electric energy

Generating Facilites and NFPA-70E

Thanks. So despite being technically exempt, is it typical for generating facilities to use NFPA-70E as the means for compliance with OSHA and NESC requirements? Any examples?

I have not seen many utility owned generation facilities follow the 70E, but I have seen many commercially or privately owned generation facilities following the 70E.

Zog is correct, but make sure you understand the exemptions in 70E. Just because it is generation does not exempt it! It must meet the exemption requirements to fall under the NESC. Is this a utility owned, maintained, and controlled installation?

Alan

I haven't heard any one reference article 410 in the NESC yet. 410 talks about assesing for potential arc exposure. If the arc exposure is greater than 2 cal/cm2 then they need FR ppe. It even goes on to use the word arc hazard analysis and give specifics that should be considered in the analysis.

Either the guy at the transformer calculated that the hazard was under 2 cals or he was out of compliance.

The generating facilities are large base load units, but are privately owned. What other source(s) describe exempt entities besides that cited by Zog above? Thanks.

I only quoted part of the 70E scope, read it all. 90.2(A)(1) Implies that anything privatly or public owned is covered, unless noted in the exceptions. My interpretation is a private owned generation facility would be covered by the 70E. You can also reference OSHA 1910.269.

As in my previous post:

Just because it is generation does not exempt it!

Appears that you need to follow 70E.
Alan

We are using IEEE-1584 as the calculation method (within SKM) to determine compliance with NESC for our municipal utility clients' generating facilities. We use ArcPro for overhead utility systems.

NFPA 70E does not exempts TDG. It exempts electric utilities. Many plants have distribution systems that fall in the 1910.269 and under NFPA 70E. There are also many facilties that co-gen but are not electric utilities and they all are under NFPA 70E.

As far as utilities following 70E, they are not exempt from the General Duty Clause under OSHA rules and OSHA says since NFPA 70E is a industry standard, that they will use it in evaluating whether the utility did everything they could to protect the employee. With all the electricl utility employees getting killed every year I can see where the legal departments are going to win out even though 70E is not a legal standard. Strange though, the fine for failing to report the transformers in the yard with PCB's is 100 times higher than having an employee get killed not wearing PPE.