Properly trained commissioning agents with years of practical experience are needed to perform acceptance tests on all emergency power supply system (EPSS) components. Moreover, they are also needed to advise and coordinate efforts from the onset of a new or refurbished emergency power project.
In fact, it has now become the norm to contract with agents for EPSS commissioning, which is not the same as “Acceptance Testing” as found in the National Fire Protection Association’s NFPA 110 Standard for Emergency and Standby Power Systems.
The commissioning agent must foster collaboration between project members during the design process by involving all contractors, engineers, facilities staff and various specialists so the project is coordinated and is practical and fully code compliant.
This requires bringing contractors into the project early—before bidding or negotiated contracts are complete—thus creating some very creative agreements or associations between contractors, owners and engineers.
In fact, advanced EPSS technology, tighter construction budgets, increasingly stringent regulations, more components and best practice planning for patient safety and code compliance has caused the number of people involved in EPSS planning, design and implementation to double over the past few years. Managing the resulting increase in people trying to deliver an EPSS that will be all things to all people at all times has become daunting. Because of this, it now requires someone overseeing the process to make sure the hospital is getting what it needs to guarantee safety, comply with sometimes conflicting codes and, hopefully, prevent litigation claims.
Finally, the Joint Commission has made it clear with its “Sentinel Event Alert #37” (www.jointcommission.org/SentinelEvents/SentinelEventAlert/sea_37.htm) that it plans to suggest and survey for more robust EPSSs that will not only meet code, but power nonessential loads as well. Thus, some hospital administrators have decided to provide emergency power to the entire hospital rather than take chances.
In addition, the Environmental Protection Agency and local emissions’ agencies have set annual limits on the amount of hours sophisticated EPSSs can be tested to ensure the systems will work as designed. In some cases, this has reduced reliability.
Designers and commissioning agents must take these limits into consideration when designing systems and integrating sophisticated components.
Key issues
The goal of a robust commissioning program is to find problems before system startup. While each project has its own particular characteristics, many EPSS problems are the result of one or more of the following key issues:
EPSS components being placed in less than friendly environments / EPSS components should be placed in areas that are protected from the environment. This does not include basements or areas below flood levels, outdoors (unless protected by approved housings) or on rooftops. Emergency power means that it must be available when the utility power isn’t. Therefore, it must be more reliable. Placing components in unfriendly environments increases the odds of failure.
Contractors not understanding or following installation codes / General, electrical, mechanical and plumbing contractors should be interviewed to determine whether they have an intimate understanding of the installation requirements dictated by NFPA 70 (National Electrical Code®) as well as NFPA 99, 101 and 110. Referrals from other health facilities managers should also be obtained.
Some of the most common non-code compliant items and best practice issues include the following: Duplex fuel pumps fed from one panel (and sometimes from normal power); no manual bypass valve in fuel lines where solenoids are installed; silencers installed without condensation drains; mineral-insulated cable integrity; and gate valves used in fuel lines versus indicating valves. These are only a few of the 176 items that need to be checked before and during the installation of components.
Vendors supplying equipment that marginally meets specifications / Vendors must be able to make a decent profit on the equipment they sell. However, their products must meet the specifications when placed in the environment dictated by the plans. Specifying engineers must compare the entire submittal with the location of the equipment. In most cases, elevation, ambient temperature and humidity are extremely important.
Inadequate specifications and plans / Inadequate specifications are the bane of most designs. Improper maintenance and testing are the leading causes of EPSS failures, but improper design and installation are catching up.
For instance, on-site fuel storage must carefully be considered to comply with requirements set by federal, state and local jurisdictions for continuous emergency generator system run time. Storage tank supply dip tubing does not typically extend to the bottom of the tank. This creates several inches of fuel that is not accessible to the generator system and can equate to several gallons of unusable fuel depending on the storage tank dimensions. This unusable quantity needs to be calculated and subtracted from the vendor advertised tank capacity to accurately comply with the generator system run time fuel storage requirements for the site. Although bifuel packages are becoming a popular option for extending run times far past the legal requirements, the minimum fuel storage requirements still apply.
Generator day-tanks should be sized for approximately two hours of full-load run time as good practice to allow time for reaction to fuel pumping problems, overheating and fuel disruptions. The present building code standards limit the aggregate gallons of fuel in a building unless special construction methods are employed.
Electrical fault and coordination studies should be performed on the entire electrical system. Without this information, ratings of equipment may be incorrect; breakers, fuses and relays cannot be properly set; and coordination with upstream devices may not be occurring. This may not allow a fault on the lower part of the distribution system to be cleared by the closest upstream device but by a device located at the primary level, leaving the whole distribution service off-line.
As-built documentation of the existing equipment ratings, settings, feeder sizes and lengths, and equipment locations must be verified or obtained. This information needs to be gathered because it is necessary before the fault and coordination studies can be performed. Because gathering this information requires the removal of panel and switchgear covers and investigating inside this equipment, it is suggested that an electrical contractor be retained to obtain this information in association with available hospital electrical staff. The information could then be recorded on drawings and in tabular form by the engineer.
The final documentation must then be reviewed with hospital staff to determine actions necessary where existing equipment is not properly rated or set. These studies are necessary to comply with the National Electrical Code (NEC) 2005, paragraphs 110.9 and 110.10 and NFPA 99, 2005 Health Care Facilities Standard, paragraphs 4.4.1.1.1 with all subparagraphs and 4.4.1.1.2.
A sequence of operations describing in detail how the EPSS switchgear is intended to function during all known modes of operation and how the switchgear interfaces with the utility switchgear is vital to the commissioning process. Priority load schedules are also an important factor. Reconnection of loads must be properly sequenced to avoid large currents that trip overcurrent devices or overload generators.
An emergency power system supplying a Level 1 EPSS system—the smallest generator rating in the lineup when paralleling multiple generator sets—must be capable of bringing all priority one loads online within 10 seconds. When three or more generators are used, and if the legally required emergency system (life safety and critical branch) priority one loads cannot be supplied by a single generator, a tiebreaker must be installed in the paralleling switchgear. This will allow one generator on each side of the tiebreaker to parallel within 10 seconds, supplying all current Level 1 loads. This eliminates the limitations of the single generator rating and thus allows the hospital future growth capacity of their Level 1 loads.
Underwriters Laboratories Inc.’s UL 2200 is now being used by authorities having jurisdiction (AHJs) as a measure of quality control. Any generator that is not carrying the label has the potential to be rejected by an AHJ as being substandard.
The hospital’s master plan must be considered thoroughly or expansions can be problematic if EPSSs are not designed to handle the anticipated increased electrical load. Oversizing generators is rarely the answer.
Lack of coordination of team members’ efforts / Coordination of team members can fall under the purview of the project manager, but the project manager is often so busy overseeing many different individual projects that he or she literally doesn’t have time to confirm compliance with all code and performance issues in each stage of the commissioning process.
Limited factory testing of components / Limited factory testing can result in delays caused by failed equipment during the acceptance testing phase. The engineer’s specifications should state that witnessing factory tests is a must item. In addition, the factory tests should be completed with the equipment in the same configuration as they will be delivered.
A good example are generators tested at the factory without the cooling fan attached. Because cooling fans require significant horsepower, a 100 percent on-site load test can sometimes fail because the fans were not considered.
In another case, a generator that was tested for only two minutes at the factory failed on-site during the first 30 minutes when an oil galley plug on one cylinder started leaking because an “O” ring was not installed. This should have been caught at the factory. Instead, it caused the project to be delayed by two days while repairs were made and contractors rescheduled their staffs.
Limited time specified for testing systems once they are in place / Limited time allocated for generator acceptance testing can result in predictable failures. Best practices call for generators and all ancillary components to be tested for a minimum of eight hours under varying load conditions.
Worker safety protection not adequately considered / Worker safety is sometimes forgotten during the construction process. One example is proper lockout provisions being omitted. The Occupational Safety and Health Administration (OSHA) regulation 29 Code of Federal Regulations (CFR) 1910.147 (c)(2)(iii) has dictated since 1990 that new equipment have such devices.
Likewise, eyewash stations should be installed in the generator room where batteries are present, according to 29 CFR 1910.151(c); and emergency power off or break-glass stations should be installed outside the generator room, according to NFPA 110, 5.6.5.6.
An incident arc energy study, or “arc flash,” is a requirement commonly overlooked. The subject of protecting electrical workers from the effects of arcing faults has become a high-visibility item within the industry. Personal protective equipment (PPE) level labels are to be provided on electrical gear to tell the electrician what level of clothing he or she must wear to service or maintain the equipment. An incident arc energy study must be performed to determine the PPE level required at each piece of gear. These studies are necessary in order to comply with the NFPA 70E-2004, article 130.1; NFPA 70 (NEC), article 110.16; and OSHA 29 CFR 1910.
Inadequate monitoring of EPSS components / Inadequate monitoring of each EPSS component can result in failures that otherwise could have been caught. In fact, the amount of damage can far exceed the cost of the monitoring system.
Fortunately, there are systems on the market today that not only will tell what happened but also what’s about to happen. All good systems monitor both the electrical and mechanical parameters. But these systems do more than monitor—they manage. In today’s health care environment, they are needed to assist the health facilities manager and hospital staff where full-time employees are at a premium.
Anxiety reduced
The benefits of a well-planned and executed EPSS commissioning program led by a seasoned expert in the health care engineering field are innumerable.
Anxiety resulting from EPSSs not functioning according to the owner’s intent six months after turnover can be dramatically reduced; staff familiarity with system controls can be greatly enhanced; and delays in final inspections because of noncompliant code issues can be totally eliminated.
Dan Chisholm Sr. is principal at MGI Systems Inc. (www.mgisys.com), Winter Park, Fla., and publisher of the Healthcare Engineering Network Web site (www.healthcareengineering.net). He can be reached via e-mail at dan.chisholm@mgisys.com. Vince M. Rea, P.E., LEED AP, is associate and senior electrical engineer at TLC Engineering for Architecture, Orlando, Fla. He can be contacted via e-mail at vince.rea@tic-eng.com.
This article first appeared in the December 2007 issue of HFM.
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