Manual Shutdown Switch

Q: We got a hit on our life safety inspection because we were told the manual shutdown switch be detached from the generator. The deficiency report says “The manual shutdown switch should be located external to the waterproof enclosure of the generator and should be appropriately identified.” The manual shut off switches of our generators are on the outside of the waterproof enclosure but they are on the outside of the generator but on the side of it. Just getting some clarification before calling an electrician to put a switch away from generator.

A: The surveyor got it right… the manual shut-down switch must not be connected to the generator containment structure. According to section A.5.6.5.6 of NFPA 110-2010, the manual shut-down switch must be mounted exterior of the weatherproof container for the generator. This was discussed in great length at a recent HITF annual meeting and the conclusion was the same; the manual switch must be mounted separate from the container housing the generator.

Temporary Emergency Power Generators

Q: We are going to have temporary generators onsite for two months that we will use during our construction project to replace the main power distribution gear for our bed tower, installing new substation and distribution gear. During the time we will have 10 shutdowns from 4 hours to 12 hours at a time. We will be on the regular emergency power generators and ATS’s normally and only on the temporary units for the shutdowns. This affects normal critical and life safety circuits. Do we have to do monthly generator, and ATS transfers on the temporary units or would the shut downs count for testing? And for annunciation, we are planning to have the generators manned anytime they are in operation with no other temporary remote annunciation. Is this permissible?

A: These are all good questions, and I can provide you with answers on how I would approach this, but ultimately you need to talk with your state, local, and accreditation AHJs in order to get their opinions. Their opinions count and mine does not.

But since you asked, the accreditation organizations already allow an actual emergency event when the generators operate to count as one of the monthly load tests, provided the emergency event meets all of the requirements for a monthly load test. Therefore, I do not see any difference if the temporary generators operate or the regular emergency generators operate during an emergency event. So, I would say you still need to conduct monthly load tests on the generators (normal and temporary units), but an emergency event can count as one of the monthly load tests if it meets all of the requirements for a monthly load test.

I would think an ILSM on the annunciation issue should be sufficient, rather than running a temporary annunciation panel.

Emergency Power Generators

Q: I am a consultant and I visited an ASC that had a natural gas generator housed indoors, located in the basement of the facility. The ATS switch was located in the same room as the generator. I am not used to seeing generators located inside of the building. Is the ATS allowed to be in the same room? Also, there was no emergency battery backup light at the location of the generator and there was no emergency stop button located anywhere in or outside of the facility. Isn’t this required?

A: The fact that the generator is located inside the building may be acceptable, depending when the generator was installed. NFPA 110-2010, section 7.2.1 says the generator shall be installed in a separate room and emergency power supply system equipment shall be permitted to be installed in this room. So, this allows the generator to be installed inside the building in a room, and this allows the ATS to be mounted in the same room.

According to section 7.2.1.1 the room must be separated from the rest of the building by 2-hour fire rated barriers, or the generator may be located outdoors. So, when you see generators mounted inside in a room, check the entrance door (if the door connects the room to the rest of the building) rating as it must be 90-minute fire rated, and the walls must be 2-hour fire rated without any unsealed penetrations.

According to section 7.2.1.2 nothing else, other than what has been described, may be permitted in this room. So the room cannot be used to store ladders, equipment, supplies, etc.

According to section 7.2.3, the room housing the generator must be designed and located to minimize the damage from flooding, caused by fire-fighter flooding; sewer backup; natural disaster. So, locating a generator in a basement does not seem to fit this requirement. This requirement was also found in the 1999 edition of NFPA 110, which was required to be complied with by CMS since March 11, 2003. So, if this generator was installed since March 11, 2003, I would say it is subject to a finding by a surveyor for not locating the generator in an area that would not be affected by flooding.

According to section 7.3.1, the generator equipment location must be provided with a battery-powered emergency lighting. So, if there is no battery powered emergency lighting unit, then that is a potential finding by a surveyor.

According to section 5.6.5.6 the generator must have a remote manual stop station located outside the room that houses the generator, and the remote manual stop station needs to be labeled. So, again, if there is no remote stop switch, then that is another potential finding by a surveyor.

Generator Battery Conductance Test

As you may be aware, you are now permitted to have maintenance free batteries to start your generators. Previous to the adoption of the 2012 edition of the Life Safety Code, the editions of NFPA 110 that had been adopted did not recognize sealed lead acid batteries for use to start the generators. Many AHJs did not accept the maintenance free batteries and made the healthcare facilities remove them.

But that is in the past. According to the edition of NFPA 110 that is now adopted (2010 edition), section 8.3.7.1 says maintenance of lead-acid batteries shall include the monthly testing and recording of electrolyte specific gravity. However, battery conductance testing shall be permitted in lieu of the testing of specific gravity when applicable or warranted. When you have maintenance free batteries you cannot get to the electrolyte to conduct the specific gravity test, so you perform the conductance test.

Electrical conductance in a battery is measured by siemens (symbolized S) and is the Standard International (SI) unit of electrical conductance. The electrical conductivity units are siemens per metre, S⋅m-1. The siemens also used to be referred to as a mho – this is the reciprocal of an ohm, and this is inferred by spelling ohm backwards. Conductance is the reciprocal of resistance and one siemens is equal to the reciprocal of one ohm.

Surveyors are now citing healthcare organizations when you fail to perform the conductance test when you cannot perform the specific gravity test on the electrolyte. You will need to have a special meter (like the one in the picture) that measures siemens (or mhos) and the common volt meter is not capable of performing this test.

Make sure you record this reading on a monthly basis.

 

 

 

Generator and ATS Testing

Q: I am new in my position and I would like to know what the weekly generator inspection consists of? I also would like to know what the monthly generator inspection and transfer switch testing consist of?

A: Some of this depends on your accreditation organization. Not all AOs survey generators the same way. So I will provide you with what the Life Safety Code requires, with the understanding you need to check with your AO to determine if they have additional requirements. The following information is derived from NFPA 110-2010, which says the routine maintenance and operation testing program must be based on the manufacturer’s recommendations and instruction manuals (section 8.1.1):

Weekly Inspections:

  • Inspection per manufacturer’s recommendation
  • Storage batteries, including electrolyte levels or battery voltage, used in conjunction with systems must be inspected weekly and maintained in accordance with the manufacturer’s specifications. (8.3.7)
  • Emergency Power Supply Systems (EPSS), including all appurtenant components, must be inspected weekly. (8.4.1)

Monthly Inspections:

  • Maintenance of lead-acid batteries must include the testing and recording of electrolyte specific gravity, Battery conductance testing is permitted in lieu of the testing of specific gravity when applicable or warranted. (8.3.7.1)
  • Emergency Power Supply Systems (EPSS), including all appurtenant components, must be exercised under load at least monthly. (8.4.1)
  • Diesel generator sets in service shall be exercised at least once monthly, for a minimum of 30 minutes, using one of the following methods (8.4.2):
    • Loading that maintains the minimum exhaust gas temperatures as recommended by the manufacturer
    • Under operating temperature conditions and at not less than 30 percent of the EPS nameplate kW rating
  • Diesel-powered EPS installations that do not meet the requirements of 8.4.2 shall be exercised monthly with the available EPSS load and shall be exercised annually with supplemental loads at not less than 50 percent of the EPS nameplate kW rating for 30 continuous minutes and at not less than 75 percent of the EPS nameplate kW rating for 1 continuous hour for a total test duration of not less than 1.5 continuous hours (8.4.2.3).
  • Spark-ignited generator sets shall be exercised at least once a month with the available EPSS load for 30 minutes or until the water temperature and the oil pressure have stabilized (8.4.2.4).

Annual Test:

  • A fuel quality test must be performed annually in accordance with ASTM D 975 Standard Specification for Diesel Fuel Oils.

3-Year Testing:

  • Level 1 EPSS shall be tested at least once within every 36 months (8.4.9)
  • Level 1 EPSS shall be tested continuously for the duration of its assigned class (8.4.9.1).
  • Where the assigned class is greater than 4 hours, it shall be permitted to terminate the test after 4 continuous hours (8.4.9.2).
  • The test shall be initiated by operating at least one transfer switch test function and then by operating the test function of all remaining ATSs, or initiated by opening all switches or breakers supplying normal power to all ATSs that are part of the EPSS being tested (8.4.9.3).

Automatic Transfer Switches:

  • Transfer switches shall be operated monthly (8.4.6).
  • The monthly test of a transfer switch shall consist of electrically operating the transfer switch from the standard position to the alternate position and then a return to the standard position (8.4.6.1).

Circuit Breakers:

  • EPSS circuit breakers for Level 1 system usage, including main and feed breakers between the EPS and the transfer switch load terminals, shall be exercised annually with the EPS in the “off” position (8.4.7).
  • Circuit breakers rated in excess of 600 volts for Level 1 system usage shall be exercised every 6 months and shall be tested under simulated overload conditions every 2 years (8.4.7.1).
  • The routine maintenance and operational testing program shall be overseen by a properly instructed individual.

Spark-Ignited Generators

Q: I have two questions regarding spark-ignited emergency power generators:

  1. What maintenance tests are required for natural or propane Generators?
  2. Are load bank test required for Natural gas or Propane gas powered generators.

A: Monthly tests, but since they are spark-ignited generators they do not have to meet a particular load. They just have to operate with the available EPSS load for a minimum of 30 minutes or until the water temperature and oil pressure have stabilized. (See section 8.4.2.4 of NFPA 110-2010).

No, spark-ignited generators are not required to have an annual load bank tests. An annual load bank test is required when diesel powered generators cannot meet the minimum load of 30% of the nameplate rating (in kW) during each monthly load test. Spark-ignited generators are exempt from having to meet this requirement.

A 3-year 4-hour load test is required for all generators, including spark-ignited generators. But you are not permitted to use a load bank on spark-ignited generators. The 3-year 4-hour load test must operate using the load from the ATS. For spark-ignited generators, the load is permitted to be the available load. (See section 8.4.9.5.3 of the NFPA 110-2010.) Load banks are not permitted for the 3-year 4-hour load test for spark-ignited generator.

Generator Starting Batteries

Q: I’m getting conflicting answers as to when generator batteries need to be replaced. Some say in a hospital they need to be replaced every 5 years unless the hospital is a trauma center then it is every 3 years. I have also been told that it doesn’t matter if it is a trauma center; hospital or nursing home; the batteries need to be replaced every 3 years. Can you please tell me what is correct?

A: The correct answer as to how often generator starting batteries need to be replaced in hospitals depends on which authority having jurisdiction you’re talking to. That may be why you are receiving conflicting answers. The typical hospital has 5 or 6 different authorities having jurisdiction (AHJ) that enforce the Life Safety Code:

  • CMS                                             (Medicare/Medicaid)
  • Accreditation Organization    (i.e. Joint Commission)
  • State health department
  • State fire marshal
  • Local fire inspector
  • Insurance company

Any one of these AHJs may have a requirement for testing/inspection/replacement of generator starting batteries that the other AHJs may not have. The hospital would have to comply with the most restrictive.

First… I cannot find any specific requirements in the NFPA codes and standards for generator starting batteries to be replaced at a different frequency if the generator serves a trauma center or not. But the hospital’s state or local AHJ may have a specific requirement that addresses trauma centers that I am not aware of.

Second… According to NFPA 110-2010, the hospital is required to replace lead-acid batteries used for generator starting every 24 – 30 months. This would be enforced by the CMS standards and the accreditation organization (AO) standards. This is found in the Annex section A.5.6.4.5.1 of NFPA 110-2010, and CMS and the AOs usually (not always) enforces the Annex section requirements of the NFPA standards.

I checked the 1999 edition of NFPA 110 and the Annex section in that edition recommended replacing the batteries every 24 – 30 months, so I don’t see anything in current or past NFPA standards that would support your 5-year frequency to replace generator starting batteries.

NFPA 101-2012 Life Safety Code requires all healthcare occupancies and ambulatory healthcare occupancies to comply with NFPA 110-2010, so this means all hospitals, nursing homes, and trauma centers, would have to have their generator starting lead-acid batteries replaced every 24 – 30 months, according to CMS and AO standards.

I suggest you contact the hospital’s state and local authorities to determine if they have more restrictive requirements.

Generator Annual Load Test

Q: My client installed a generator in a Phase 1 project that does not and will not for some time be able to meet the requirements for the 30% load during the monthly test due to low current loading. As I understand it, 8.4.2.3 in NFPA 110 allows you to do the monthly test as is and do a supplemental annual test yearly as outlined which would then meet the requirement for the monthly test. Is that the proper interpretation as the generator will not meet the 30% requirement until some unknown future date?

A: Yes… section 8.4.2.3 of NFPA 110-2010 is the correct reference when any one of the monthly tests cannot meet the requirement for at least a 30% load. The annual test must be conducted within 12 months of the first monthly test that was incapable of meeting the 30% load requirement, and then no more than 12 months from the last annual load test.

Your client should continue to conduct the monthly load tests (not less than 20 days and not more than 40 days) with the available load. For the annual load test, a supplemental load (i.e. load bank) of not less than 50% of the nameplate kW rating for 30-minutes and a supplemental load of 75% of the nameplate kW rating for 60-minutes must be conducted, for a total test of 90 continuous minutes.

The cool-down period for the generator is not part of this 90-minute test.

Generator Testing

Q: Does our hospital have to test the generator for 30 minutes every week, and then 1-hour once a month? We have programmed our generators to operate every Wednesday at 12 noon and run for 30 minutes. We do ATS test once a month and record information when running.

A: According to section 9.1.3.1 of the 2012 Life Safety Code, emergency power generators must be tested in accordance with NFPA 110. Section 8.1.1 of NFPA 110-2010 says the routine testing of the emergency power generators must be based on all of the following:

  • Manufacturer’s recommendations
  • Instruction manuals
  • The requirements of NFPA 110
  • The AHJ’s requirements

While NFPA 110 does not have any requirements to operate the generator on a weekly basis, there may be manufacturer requirements or AHJ requirements that do. Section 8.4.1 of NFPA 110-2010 specifically says generators must be inspected weekly but operated under load on a monthly basis. Section 8.4.2 requires the monthly load test to operate for 30 minutes. I suggest you check with your generator manufacturer and your state and local AHJs to see if they have specific weekly run-tests of the generator.

Generator Fuel Testing

Q: What are the guidelines on the diesel fuel test for the generator as far as having it treated or a sample sent off for testing?

A: The new 2012 Life Safety Code references the 2010 edition of NFPA 110, the standard for emergency and standby power systems. Section 8.3.8 of the NFPA 110-2010 requires the fuel for the generators to be tested annually for quality. According to more recent editions of NFPA 110, this test is to be conducted in accordance with ASTM D975, Standard Specification for Diesel Fuel Oils. You may purchase a copy of the standard direct for the ASTM website https://www.astm.org/Standards/D975.htm