Generator Testing

Q: We have a generator that doesn’t meet the 30% load for the monthly run so we have to do an annual run with the load at 50% for 30 min and 75% for 60 min for a 90-minute continuous run. Our contractor did the annual run but he ran it with 52% for 30 min, 75% for 30 min and 81% for 30 min, then he continued to run it for 2½ more hours dropping the percentages as he went for 4 continuous hours at not less than 30%. My question is does these meet the intent of the standards for both an annual and a 3-year load test?

 A: According to section 8.4.9.7 of NFPA 110-2010, when the 3-year load test is combined with the annual load test, the first three hours shall be not less than 30-percent of the nameplate kW rating, and the remaining hour shall be not less than 75-percent of the nameplate kW rating.

I would say the test as you described could meet both the annual requirements and the 3-year test requirements, depending on how the test was administered. It is obvious that an external load bank would be required for the annual test since the building load did not meet the minimum 30%.

But section 8.4.9.3 of NFPA 110-2010 requires the 3-year test to begin with the building’s load through the ATS and only supplement the load with a load bank if the load cannot meet 30%. It is not at all that easy to combine an annual load test with a 3-year load test, because the 30% minimum load is not achieved through the building’s load.

The generator load testing requirements are minimum load settings, and it is permitted to exceed these minimums.

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 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.

Fire Pump ATS

Q: A state surveyor cited us for not doing a monthly fire pump automatic transfer switch (ATS) test. We are doing a weekly churn test and an annual fire pump flow test that includes switching over the ATS. I was not aware that this had to be done monthly.

A: Yes… NFPA 110-1999, section 6-4.5 requires all transfer switches in Level I and Level II systems (hospitals typically have Level I systems) to be tested monthly. The state surveyor is correct. I find that it is not uncommon for some hospitals to overlook the ATS serving the fire pump. I guess they don’t always see that it is part of the Level I emergency power supply system. Out-of-site is out-of-mind!