ELECTRICAL SAFETY TASK GROUP

1. ELECTRICAL SAFETY TASK GROUP Query NFPA 70E Implementation Benchmark of National Laboratories Greg Christensen, INL Gregory.christensen@inl.gov July 18, 2016

2. PARTICIPANTS • NREL • SRS • PORTSMOUTH • SLAC • JEFFERSON • HANFORD • PNNL • ORNL • PANTEX • INL • LLNL • ARGONNE • WTP • SNL • BNL • LBNL • WRPS-RL • NETL • PPPL • LANL • Other (3)

3. PURPOSE Query sites regarding: • NFPA 70E Implementation • Switching practices • Maintenance of OCPDs

4. PREVENTING MURPHY’S LAW “If there is any way the technician can do it wrong he will” • A failure will not appear until after final inspection • Hindsight is an exact science • Design error • Faulty install • Inspection does not detect problem • Maintenance performed incorrectly • Performance test not performed correctly • Arc analysis error • Risk assessment error • Sign of impending failure not detected

5. BACKGROUND NFPA 70E recognizes arc flash hazards may exist even when equipment is in an enclosed condition. This includes operators whose only interaction is with the equipment in an enclosed condition. There are situations where opening or closing a switch or breaker has been a contributing factor to an arc flash event.

6. SURVEY QUESTIONS • What version of NFPA 70E are you following? • Does your site require PPE for switching of breakers, disconnects and switches? • Does your site apply the Task Table 130.7(C)(9)(a) in 70E to identify PPE for switching of breakers, disconnects and switches? • Is PPE for switching of breakers, disconnects and switches based on an incident energy analysis? • Has your site implemented or plan to implement NFPA 70E 2015? • If your site has implemented NFPA 70E 2015, please explain your site's approach to switching operations.

7. SURVEY QUESTIONS • Does your site have a program to inspect, test and maintain overcurrent circuit protection devices? • In regard to normal operations of a breaker, switch, contactor or starter, is your site going to allow operation without PPE? • Will there be any exceptions that require the use of PPE based on voltage class or incident energy level? What method/s will be used to verify there is no evidence of impending failure? • Have you implemented a documented risk assessment process at your site for electrical work? Who performs the assessment? • Have you performed a risk assessment of breaker operations? Any thresholds or criteria that require additional controls?

8. SURVEY QUESTIONS • How does the age and condition of you electrical systems factor into your risk assessment? • What tests are performed on Power Breakers and at what intervals? • What tests are performed on Molded Case Circuit Breakers and at what intervals? • Does your site exclude any voltage or amperage ranges of MCCBs from testing? • Should a best practice be developed with regard to criteria for risk assessment and maintenance and testing of Over Current Protection Devices to assist in assigning arc flash controls?

9. NFPA 70E VERSION Various versions of NFPA 70E are implemented • 2004 • 2009 • 2012 • 2015 (majority of sites are evaluating and generally have not implemented)

10. EVALUATING ARC FLASH • Some sites have completed incident energy analysis and are labeling equipment to assign PPE based on the Incident Energy Level • Some sites rely on the 70E task tables to assign PPE • With the advent of NFPA 70E 2015, some sites are incorporating aspects of risk analysis into their approach

11. EVALUATING ARC FLASH (Continued) PPE for breaker and switching operations is required at most of the sites. • Some exceptions are made: • < 125 KVA at ≤ 240 V • < 1.2 cal/cm2 lower threshold • < 4 cal/cm2 lower threshold • > 40 cal/cm2 is often cited as an upper limit

12. ASSESSING RISK NFPA 70E 2015 Employers are responsible for assessing the risk from the arc hazard for employees that interact with electric equipment. Some sites are struggling with the concept of risk analysis and its impact to operations

13. ASSESSING RISK (Continued) • When risk assessment is performed no PPE required if following criteria is met • Installed properly • Maintained properly • Covers in place and secured • Doors closed and secured • No evidence of impending failure The standard does not impose any voltage or incident energy limitations

14. IMPENDING FAILURE Sites questioned how verification will be performed to ensure: No evidence of impending failure Performance tests detect approximately 2% failure rate

15. A PERCEIVED ISSUE 25 cal/cm2 Incident Energy • Properly installed • Properly maintained • Cover on and secure • no evidence of impending failure Risk = high consequence/low probability = No PPE required per 70E 2015

16. RISK Is operating overcurrent devices without PPE as safe, or safer than wearing PPE?

17. PREDICTING THE FUTURE Predicting the future from the past has inherent uncertainty

18. NFPA 70E MAINTENANCE Many sites have implemented maintenance programs which are at varying levels of maturity. • Maintenance practices and tests performed are widely varied and not consistent. • Funding and resource limitations affect schedules and determine extent of maintenance. • Problems noted with having necessary equipment and expertise to test overcurrent circuit protective devices

19. NFPA 70E MAINTENANCE (cont) • MCCB maintenance omitted at some sites • Some sites conduct performance testing • Instantaneous testing performed to validate trip time of breaker and arc analysis results. • Overcurrent testing performed at some sites to validate fire prevention equipment protection • External infrared scan on loaded/energized MCCBs; and visual, torque tightness, and mechanical operation on de-energized MCCBs • Breakers considered to be “critical" to arc flash mitigation are prioritized

20. PROBABILISTIC THEORY Blaise Pascal’s (1623-1662) Wager A Game is being played... where heads or tails will turn up. You must wager it is not optional. Existing in a state of uncertainty, we are forced to choose…

21. CONCLUSIONS The complex would benefit from the development of an EFCOG Best Practice and provide a consistent approach for: • Minimum maintenance practices of overcurrent protection devices • Assessment criteria, limits and thresholds to assist in assigning arc flash controls