Flash wrote:
This is a great topic, I have two comments/questions. I do technically agree with what you are saying, but, the legal aspect is one where I can not side with you:
1. Where does NFPA 70E say we can exclude the 208 volt circuits within a study and wasn't that section regarding the the exclusion of <125 kVA circuits removed?
Yes, it was removed. This is technically correct. The only risk assessment that NFPA 70E has is the tables. It references no less than 8 different methods for calculating an arc flash hazard as well as a single (but woefully incomplete) risk assessment method in the annexes. Since only one of the 8 hazard calculation methods currently specifies the exception, it would be inappropriate to put it in NFPA 70E, irrespective of the reason that it was purportedly inserted and then later removed.
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2. Where in 1584 does it say "there is no reason to do this because the arc is unlikely to be self sustaining".
It is buried in a couple paragraphs. And yes, it is so darned convoluted and weakly stated and given so with absolutely no justification whatsoever that the reliance on it is tenuous at best to say the least. The way folks talk about it, you'd think it's much stronger than it is. If it was acceptable prior to NFPA 70E-2012, it is just as acceptable in IEEE 1584. But if you actually bother to read the justification for it, you won't feel so comfortable with your position.
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I do not like the rules, but, we must play by them and I do not believe you can circumvent NFPA 70E. On the other hand I also believe as you do that most 120/208V faults are not self sustaining, however, I did serve as an expert witness in a case where the the source was a small dry type 120/208V transformer and the electrician did receive a 50% body burn. I have it well documented and would like to write a white paper on the events if I can get a venue.
There's a space on this forum for articles. That being said, you're not circumventing 70E. 70E is similar to NESC in this respect. Both give a relatively complete risk assessment method based on a set of tables. Neither specifically attributes any particular source to where the values came from. In the case of 70E, the Technical Committee used IEEE 1584 and then made some adjustments ("credits") without documenting the logic behind those decisions, nor mentioning IEEE 1584. In the case of IEEE C2 (NESC), they used ArcPro for the calculations and then gave an extensive list of adjustments for various tasks which at least in the draft version I've seen (I have not seen what made into the official NESC-2012 document), it was heavily footnoted with sources. ArcPro is not mentioned anywhere in IEEE C2 either...you just have to know about it.
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Even a bit more interesting is a study that I just did. The project had approximately 100 dry type transformers that were < 125 kVA. I ended up modeling the 45, 75 and 112 kVA transformers. I ran studies on a large portion of the units and i also ran studies on the secondary feeder circuits. Every transformer secondary bus and every circuit 100 amperes and greater on the secondary side was a less than 4 cal/sq cm. I do not think this will vary too much on any site. In the future I will spot check these smaller transformer as I do circuit of less than 70 amperes (that is my general cut-of), however, I will start designating all these transformers as a 4 cal/sq cm node.
Be careful here. So what specific PPE does the secretary or janitor need when they enter the building in the morning, never mind go into the broom closet and use a snap switch? We really do need not only a "0" category but a "00" category, or else need to get serious about doing risk assessments and not just hazard assessments and call them risk assessments. Right now the proverbial secretary/janitor needs (with your cutoff of 4 cal/cm^2) long sleeve FR pants and shirts, gloves, an arc flash resistant face shield, hard hat, safety glasses, and leather work boots. Although there are some men and women who dress far more casually than is appropriate for the business environment, this does seem kind of ridiculous doesn't it?