B08_System_Analysis_-_GAAR.pdf
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This document is a trip report from an electrical engineering firm summarizing an assessment of electrical distribution systems at multiple facilities within Gates of the Arctic National Park and Preserve. The firm inspected systems at buildings including the Coldfoot Ranger Station, Marion Creek Generator Building, Anaktuvuk Pass Ranger Station/Residence, Bettles Visitor Center, Bettles houses and other buildings. The report identifies various code compliance issues found within the different facility systems such as mounting heights above recommended limits, improper grounding, lack of labeling and protective conduit/raceway. Accompanying diagrams and photos depict specific issues found. The report will help inform an accurate arc flash calculation and safety labeling of equipment to address any deficiencies.
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670 W. Fireweed Ln, Ste 200 Anchorage, AK (907) 276-0521 l www.rsa-ak.com
Mechanical & Electrical Engineers
September 19, 2022
United States Department of the Interior National Park Service Denver Service Center 12795 W. Alameda Parkway P.O. Box 25287 Denver, CO 80225-0287
ATTENTION: Simon Evans
Dear Simon, REFERENCE: NPS Arc Flash Evaluation - GAAR Trip Report
On 6/30/22 through 7/1/22 Billy Comer, with Consolidated Contracting and Connor Zietlow, with RSA Engineering travelled to GAAR National Park to investigate the electrical distribution systems. The intent of the site visit was to gather information on the electrical equipment to provide an accurate arc flash calculation and warning labels for the equipment and to determine any code deficiencies present. Any equipment which is single phase and 240V, or less, an arc flash calculation is not required. See one-line diagrams for further information on site electrical systems. The following report will address any code issues we discovered as part of our investigation.
CXF – Coldfoot Ranger Station:
The Coldfoot Ranger Station consists of a 120/240V, 125A, 1Ø Cutler-Hammer type Combination Meterbase/Disconnect (CMD) with a 125A 2-Pole disconnect fed from a pad-mounted utility transformer. This disconnect feeds the normal power side of a Manual Transfer Switch (MTS) mounted nearby. The emergency side of the MTS is fed from a twist lock plug & cord, for connection to a portable generator, assumed to have integral over current protection based on onsite personnel information. The load side of the MTS feeds what is assumed to be a 120/240V, 125A, 1Ø Siemens panelboard with main lugs due to lack of markings on the inside of the panel and installed breaker types, designated panel ‘A’. On panel ‘A’ a 50A 2-Pole breaker feeds a 120/240V, 125A, 1Ø Siemens Outdoor Load Center series A with main lugs, designated panel ‘Lean to’ which is mounted on the exterior of a conex adjacent to the Coldfoot Ranger Station.
After Site investigation it is determined that the Coldfoot Ranger Station’s Comfort Station has no power fed to it.
The following are issues we noted with the distribution system:
1. The CMD and MTS mounted on the exterior of the building are mounted at about +7’ AFG to the highest breaker position, which is above the acceptable mounting height. Recommend relocating the CMD and MTS to a height of no greater than 6’7” AFG to the highest breaker or handle position.
2. Feeders to panel ‘A’ have no visible markings, but appear to be #2 AWG Al, which are rated only for 75A. Recommend replacing feeders with #2 AWG Cu or reducing the size of the building disconnect on the CMD if the load of the building is small enough to allow it.
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CXF – Visitor Center:
The Coldfoot Visitor Center consists of utility service equipment fed from a pad-mounted utility transformer. There are no utility markings, we are assuming it is rated 112.5KVA, 120/208V, 3Ø and are designating it transformer ‘VC’. Transformer ‘VC’ feeds a 120/208V, 800A, 3Ø Hoffman CT cabinet where the power usage of the building is metered remotely. The CT cabinet feeds to a splice cabinet where the incoming feed has (3) taps. (2) taps each feed a 120/208V, 225A, 3Ø Square D Circuit Breaker Enclosure with a 200A 3-Pole disconnect, designated disconnect ‘A’ and ‘B’. The third tap feeds a 200A 3-Pole Square D fused disconnect with 50A fuses, which in turn feeds a fire pump control panel, designated ‘Fire Pump Disconnect’. Disconnect ‘A’ feeds (2) panels both of which are 120/208V, 225A, 3Ø Square D type NQOD panelboards with main lugs, designated panels ‘A Sec. 1’ and ‘A Sec. 2’. Panel ‘A Sec. 1’ subfeeds a 120/208V, 60A, 3Ø Square D type QO load center with main lugs, designated panel ‘Theater’, with a 50A 3-Pole breaker. Disconnect ‘B’ feeds to the normal power side of a 200A 3-Pole MTS designated MTS ‘STBY’, and there is no connection to the emergency side of the transfer switch. According to onsite personnel, an emergency back-up generator will be installed and connected to the MTS ‘STBY’ in the near future. The load side of MTS ‘STBY’ feeds to a 120/208V, 225A, 3Ø Square D type NQOD panelboard with main lugs, designated Panel ‘STBY’.
1. Labeling for the ‘Fire Pump Disconnect’ does not comply with NEC guidelines. Relabel ‘Fire
Pump Disconnect’ to comply with NEC 695.4(3)(4)(C).
2. ‘Fire Pump Disconnect’ fuses are not rated for the locked rotor amperage of the 10hp fire pump. Replace 50A fuses with 200A fuses rated for use in the enclosure.
MACB – Generator Building (Existing):
The Marion Creek Generator building consists of 2 generators for redundant power. The primary standby generator is a 12 kW Stamford Generator with a 50A 2-Pole Square D type QO breaker, on standby to AutoStart when the voltage in the battery bank, see below, gets below a set voltage. The secondary standby generator is 16 kW with no manufacturer name or information, which must be manually started. The primary and secondary standby generators feed a 100A 2-Pole MTS and are terminated on the emergency and normal sides, respectively. The load side of the MTS is connected to a hybrid inverter/charger system by Schneider Electric type Xantrex XW PDP. This system consists of an inverter control panel and for redundancy, (2) inverters, which are connected to a battery bank. The inverters are then connected to a solar array through a series of disconnects and a charge controller, see the one-line 3/E1 for further details. The inverter control panel has sets of
(2) 60A 2-Pole breakers used for overcurrent protection to allow for each of the following situations:
The first is an option to bypass the solar array, the second to bypass the generator, and the third is to disconnect the inverter control panel from the grid of which it is feeding. Also located on the inverter control panel are (2) 250 ALM disconnects for inverters 1 & 2 from the DC system. From the hybrid inverter/charger system, power is distributed to a 120/240V, 125A, 1Ø GE PowerMark Load Center with main lugs, designated panel ‘C’. Panel ‘C’ feeds buildings C1, (MACB – Ranger Residence (C1)), and C2, (MACH – Transient Housing (C2)), through surface-mounted splice cabinet mounted on the exterior of the generator building. Building C1 is fed off the main lugs of panel ‘C’ and building C2 is fed from a 60A 2-Pole breaker on the bus of panel ‘C’.
1. The solar array disconnect located on the exterior of the generator building has the designated hot conductors terminated in the neutral bar and the designated neutral conductors terminated in the line side of the disconnects. Recommend using phase tape to correctly designate conductors based on their intended or current purpose.
2. Panel ‘C’ has improperly terminated ground wires and no ground bar. Recommend redoing grounding system terminations inside of panel enclosure onto new ground bar.
3. Conductors in panel ‘C’ are spliced together without the use of a splice connector.
Recommend re-splicing conductors using a Polaris connector, or other approved means.
4. The MTS has a more knock outs than are necessary and has conductors from and to the primary and secondary standby generators using knockouts without conduit, flex, or any form of protection. Recommend providing KO seals in the MTS enclosure, and providing conduit, PVC, flex, or other approved form of raceway to protect conductors entering or leaving MTS enclosure.
5. The MTS has corrugated tubing in the enclosure which is empty. Recommend demolishing back to source.
6. In the surface-mounted gutter located on the exterior of the generator building there are capped conductors assumed to be for a, no-longer in use, remote generator start/stop button located in the MACB – Ranger Residence (C1), see below, based on onsite personnel information. Recommend demolishing conductors back to source.
7. PVC conduit coupling to exterior gutter is no longer attached to the gutter. Recommend repairing incoming conduit so that is securely fastened to the exterior gutter.
MACB – Ranger Residence (C1):
Building C1 consists of an exterior mounted splice cabinet fed from panel ‘C’, see MACB – Generator Building (Existing) above. The splice cabinet feeds a 120/240V, 125A, 1Ø Square D CMD with a 100A 2-Pole building disconnect. The building disconnect feeds a 120/240V, 125A, 1Ø Square D type QO load center with main lugs, designated panel ‘Normal’. Panel ‘Normal’ feeds the normal side of a 60A 2-Pole Square D MTS located inside the building via a 60A 2-Pole breaker. Feeding the emergency side of the MTS is a 50A Hubbell twist lock flanged inlet located on the exterior of the building, for connection to a portable generator, assumed to have integral over current protection based on onsite personnel information. The MTS feeds a 120/240V, 125A, 1Ø Square D type QO load center with main lugs, designated panel ‘EM’. Panel ‘EM’ feeds what appears to be, based off existing panel schedules and onsite personnel information, an old fire suppression switch and an old communications station receptacle switch. The fire suppression switch which is a 30A 2-Pole Square D safety switch is not in use any longer and is fed from a 25A 2-Pole breaker on panel ‘EM’. The communications station receptacle switch is a 120/240V, 70A, 1Ø Square D type QO load center with main lugs, fed via a 20A 1-Pole breaker on panel ‘EM’.
1. The splice cabinet mounted to the exterior of the building has the conductors of a no-longer in use remote generator start/stop button, located inside. As mentioned as a deficiency above, recommend demolishing conductors back to source.
2. There is a surge protection device connected to the building CMD that has been destroyed assumedly during a lightning strike, based on onsite personnel information. Recommend replacing the device and all wiring with new.
3. Feeding into and out of the old communications station receptacle switch are (2) feeds of Romex through a ¾” knock out with no bushing. Recommend providing bushing in knock out to prevent ware on incoming and outgoing conductors.
MACH – Transient Housing (C2):
Building C2 consists of a surface mounted 120/240V, 125A, 1Ø Square D CMD with a 100A 2-Pole building disconnect fed from panel ‘C’, see MACB – Generator Building (Existing) above. From the building disconnect there are (2) subfeeds. One feed goes to a 120/240V, 70A, 1Ø Square D type QO load center with a 20A 2-Pole breaker. This Breaker is used to disconnect power to a receptacle in the Well House and was designated ‘Well House Disconnect’. The other feed goes to a 120/240V, 125A, 1Ø Square D type QO load center with main lugs, designated panel ‘Normal’. Panel ‘Normal’ feeds the utility side of a 60A 2-Pole Square D MTS located inside the building, via a 60A 2-Pole breaker. Feeding the emergency side of the MTS is a 50A Hubbell twist lock flanged inlet located on the exterior of the building, for connection to a portable generator, assumed to have integral over current protection based on onsite personnel information. The MTS feeds a 120/240V, 125A, 1Ø Square D type QO load center with main lugs, designated panel ‘EM’.
1. The ‘Well House Disconnect’ is fed from the CMD without the use of any shielding other than wire insulation. Recommend providing conduit, PVC, flex, or other approved form of raceway to protect conductors.
2. The ‘Well House Disconnect’ has a 20A 2-Pole disconnect breaker tapped with only one conductor feeding to the Well House receptacle. Recommend replacing 20A 2-Pole disconnect with 20A 1-Pole disconnect for the Well House receptacle.
3. The neutral and ground wire for the ‘Well House Disconnect’ circuit is bypassing the enclosure and feeding straight through to the CMD. Recommend terminating ground and neutral conductors on a new ground bar and existing neutral bar in the disconnect.
4. The surface-mounted exterior CMD has multiple dissimilar metals terminated on the load side of the disconnect. Recommend providing an Anti-Oxidation compound in the screw terminals to prevent oxidation.
5. The surface-mounted exterior CMD ‘Well House Disconnect’ bonding jumper needs to be properly terminated on the CMD ground bar.
6. The ‘Well House Disconnect’ has no bushings between flex leaving disconnect and enclosure. Recommend providing bushing.
AKPB – Ranger Station/Residence:
The Ranger Station/Residence building in Anaktuvuk Pass consists of a remotely meter panel designated ‘Water/Sewer’ and a CMD for the building, both fed from a utility pole mounted transformer nearby. Panel ‘Water/Sewer’ is a 120/240V, 125A, 1Ø Square D type QO load center with a 100A 2-Pole MCB. The CMD for the building is a 120/240V, 125A, 1Ø Square D with a 100A 2-Pole disconnect subfeeding a 120/240V, 125A, 1Ø Square D type QO load center with main lugs, designated panel ‘Normal’ which was protected by a surge protection device. Panel ‘Normal’ feeds the normal side of a 100A 2-Pole MTS with a 60A 2-Pole breaker and a 60A 3-Pole Siemens type disconnect, designated ‘Windmill’ disconnect. The emergency side of the MTS is fed via a 50A plug assumed to be a Hubbell twist lock flanged inlet based off a lack of visible markings and previously documented buildings. The load side of the MTS feeds a 120/240V, 125A, 1Ø Square D type QO load center with main lugs, designated panel ‘EM’. The ‘Windmill’ disconnect is metered upstream between panel ‘Normal’ and it and draws its power from an out of service windmill located just outside of the Ranger Station/Residence.
1. Panel ‘EM’ had missing screws in the enclosure. Recommend providing extra screws for panel enclosure and dead-front to securely fasten cover.
AKPB – Bunk House:
The Bunk House building in Anaktuvuk Pass consists of a CMD, with no visible markings or designations, assumed to be a 120/240V, 100A, 1Ø Square D type CMD with a 100A 2-Pole disconnect, based off the interior disconnect breaker type and size, which is fed from a utility pole mounted transformer nearby. This CMD feeds an interior recess-mounted panel with no visible marking or designations assumed to be a 120/240V, 100A, 1Ø Westinghouse panelboard with main lugs, designated panel ‘Bunk’, based off the interior disconnect breaker type and size.
1. The surface-mounted exterior CMD has begun to rust and has no visible markings on the exterior or interior of panel. Recommend replacing with new similar CMD.
2. Panel ‘Bunk’ has no visible markings. Recommend providing visible marking to designate panel type and rating.
3. Panel ‘Bunk’ has improper grounding. Recommend providing ground bar or similar device to allow for multiple ground taps to the panel enclosure.
4. Panel ‘Bunk’ has a bookshelf which is screwed to the wall directly in front of it, violating the working clearance of the panel. Recommend relocating bookshelf and all other objects/equipment to at least 3’ away from the front of the panel.
BTTB – Bettles Visitor Center:
The Bettles Visitor Center consists of a 120/240V, 200A, 1Ø Square D type Meter Main with a 100A 2-Pole disconnect and a 200A 2-Pole disconnect which takes up to (4) spaces, fed from a pad-mounted 15kVA, 120/240V, 1Ø utility transformer. The 200A disconnect feeds a fire pump control panel located in the crawl space beneath the Visitor Center. The 100A disconnect feeds the utility side of an exterior surface-mounted 120/240V, 100A, 1Ø Square D double throw enclosed switch.
The emergency side of the MTS is fed by from an adjacent surface-mounted enclosure with a cord and NEMA 14-50P plug used to connect to a portable generator, assumed to have integral overcurrent protection, based on site personnel information. The MTS feeds a recess-mounted 120/240V, 400A, 1Ø Square D type NQOD panelboard with main lugs, designated panel ‘A’ which is remotely metered inside its enclosure. Panel ‘A’ in turn is connected to (2) panels, designated panels, ‘Inverter Sub’ and ‘M’. Panel ‘Inverter Sub’, a surface-mounted 120/240V, 40A, 1Ø Square D type NQOD panelboard with a 40A 2-Pole MCB, is fed via a 40A 2-Pole breaker on panel ‘A’, and is connected via a 30A, 3-Pole Siemens type Enclosed Switch, via (3) 15A 2-Pole breakers, for disconnecting (3) solar panel Inverters, ‘A’, ‘B’, and ‘C’ which, in turn, are connected to solar panels mounted on the exterior of the building which provide an alternative power source for panel ‘A’. Panel ‘M’, a surface-mounted 120/240V, 100A, 1Ø Square D type NQOD panelboard with main lugs, is fed from an 80A 2-Pole breaker on panel ‘A’.
1. Conductors feeding the emergency side of the MTS are short and lie directly on top of the terminals for the utility side feed. Recommend stripping more of the cable insulation for the emergency side cable to allow for more slack in the MTS enclosure.
2. Panel ‘Inverter Sub’ is providing an alternative source of power to the bus of panel ‘A’. Per NEC 705.10, markings on the plaque or directory of panel ‘A’ are required with wording as follows: “CAUTION: MULTIPLE SOURCES OF POWER.” And shall be marked in accordance with 110.21 (B).
BTTB – Bettles Visitor Center - Adjacent:
The Bettles Visitor Center – adjacent building was not listed among building required for this survey.
During site investigation the building’s power systems were investigated and determined to consist of a 120/240V, 125A, 1Ø Challenger Electrical Equipment Corp. type CMD with a 125A 2-Pole building disconnect fed from a nearby pad-mounted 15kVA 120/240V, 1Ø utility transformer, see AKPB – Bettles Visitor Center above. The CMD feeds a 120/240V, 225A, 1Ø Square D type NQ panelboard with main lugs, designated panel ‘Shop’.
1. If any upgrades are to be performed to the distribution system, recommend replacing the Challenger Electrical Equipment Corp. type CMD with similar CMD that has more available replacement parts.
BTTB – Employee Recreation Hall & Cache:
The Bettles Employee Rec Hall building consists of an exterior surface-mounted 120/240V, 125A, 1Ø Cuttler Hammer Series B CMD with (2) 100A 2-Pole disconnects, assumed to be fed from a nearby pad-mounted 15kVA 120/240V, 1Ø utility transformer. One of the 100A disconnects feeds a surface-mounted 120/240V, 125A, 1Ø Cuttler-Hammer type panelboard with a 30A 2-Pole MCB, designated panel ‘Cache’ located inside of the Cache building nearby. The other 100A disconnect feeds a surface-mounted 120/240V, 125A, 1Ø Cuttler Hammer type panelboard with main lugs, designated panel ‘Rec’ located directly inside the Recreation Hall building.
1. The surface-mounted exterior CMD located on the Employee Recreation Hall is mounted 7’ AFG to the highest breaker position, which is above the acceptable mounting height.
Recommend relocating the CMD to a height of no greater than 6’7” AFG to the highest breaker position.
2. Panel ‘Rec’ has a neutral designated wire feeding the line side of its busway, and an unmarked conductor bonded to the neutral bar in the panel. Recommend using phase tape to reflect installation of conductors.
3. Panel ‘Cache’ has tape covering circuits 10 with a note labeled “DO NOT TURN OFF”.
Recommend providing lockouts for above circuit in question.
BTTB – 108 Well House:
The Bettles 108 Well House consists of an exterior surface-mounted 120/240V, 125A, 1Ø Cuttler Hammer type CMD with a 100A 2-Pole disconnect, assumed to be fed from a nearby pad-mounted 15kVA 120/240V, 1Ø utility transformer. The CMD feeds a surface-mounted 120/240V, 125A, 1Ø Eaton type panelboard, designated panel ‘Well House’ with main lugs, located in the basement of the Well House.
1. Panel ‘Well House’ is fed from a 100A 2-Pole breaker on the CMD using wire not rated for 100A. Recommend replacing 100A 2-Pole breaker with breaker rated to protect conductors, or refeeding panel with (3) #2 AWG Cu.
2. Panel ‘Well House’ has a tank within 3’ in front of the panel violating its working clearance space. Recommend relocating tank and all other objects/equipment to at least 3’ away from the front of the panel or relocating panel to a space with 3’ of clearance in front of it.
BTTH – House 106, 107, 109, & 110:
The Bettles houses 106, 107, 109, and 110 are all the same in construction and consist of an exterior surface-mounted 120/240V, 125A, 1Ø Cuttler-Hammer type CMD with a 100A 2-Pole disconnect, fed from a nearby pad-mounted 15kVA 120/240V, 1Ø utility transformer. The CMD feeds a recess-mounted 120/240V, 180A, 1Ø I-T-E type panelboard with main lugs, located in the boiler room of each house.
1. The surface-mounted CMD on the exterior of House 106 has been heaved off the building.
Replace service lateral conduit and wire, resecure CMD to the exterior of the house and coordinate with AP&T for final connection.
2. The surface-mounted CMD on the exterior of House 107 has missing bolts for the dead-front.
Recommend providing new bolts to secure dead-front to enclosure.
3. Panel ‘A’ in House 109 has a broken handle to the enclosure. Recommend replacing enclosure door.
4. Panel ‘A’ in House 109 has no ground bar and has the exterior ground bonding wire and EGCs tied to the neutral bar inside of the panel. Recommend providing new ground bar for panel and moving ground rod connection point, EGCs off the neutral bar to the new ground bar in the panel.
5. Panel ‘A” in House 110 has its EGCs landed on the neutral bar in the panel. Recommend moving EGCs to existing ground bar in panel.
BTTH – House 105:
The Bettles house 105 consists of an exterior surface-mounted 120/240V, 125A, 1Ø Square D type CMD with a 100A 2-Pole disconnect, assumed to be fed from a nearby pad-mounted 15kVA 120/240V, 1Ø utility transformer. The CMD feeds an interior recess-mounted 120/240V, 125A, 1Ø Square D type Load Center with main lugs, designated panel ‘Normal’. Panel ‘Normal’ feeds the Normal side of a 100A 2-Pole MTS via a 60A 2-Pole breaker on panel ‘Normal’. Feeding the emergency side of the MTS is a 50A Hubbell twist lock flanged inlet located on the exterior of the building, for connection to a portable generator, assumed to have integral over current protection based on onsite personnel information. The MTS feeds a recess-mounted 120/240V, 125A, 1Ø Square D type Load Center with main lugs, designated panel ‘E’. According to the Arc Flash site notes provided by NPS, there is supposed to be a 7,500W generator used to provide emergency power to BTTH – House 105, but during site investigation, no generator was found on, or near the premises.
There are no issues we noted with the distribution system.
BTTH – House 104:
The Bettles house 104 consists of an exterior surface-mounted, assumed to be, 120/240V, 200A, 1Ø Square D type CMD with a 200A 2-Pole disconnect, base on disconnect size. The CMD is assumed to be fed from a nearby pad-mounted 15kVA 120/240V, 1Ø utility transformer. The CMD feeds a recess-mounted, assumed to be, 120/240V, 225A, 1Ø Square D type QO Load Center with main lugs, located inside of the house, based on size of disconnect size.
There are no issues we noted with the distribution system.
ATTACHMENTS
NPS Arc Flash Deficiency Log - DENA.xlsx M1180 ONE-LINES GAAR.pdf Arc Flash Report - GAAR.pdf
Image #1 – Coldfoot Ranger Station CMD Image #2 – Coldfoot Ranger Station Panel ‘A’
Image #3 – MACB-Gen Bldg Solar Disconnect Image #4 – MACB-Gen Bldg Panel ‘C’
Image #5 – MACB-Gen Bldg MTS Image #6 – MACB-Gen Bldg Gutter
Image #7 – MACB-Gen Bldg Gutter Raceway Image #8 – MACB-(C1) CMD
Image #9 – MACB-(C1) Com. Recp. Switch Image #10 – MACB-(C2) Wellhouse Disc.
Image #11 – MACB-(C2) CMD Image #12 – AKPB-Bunkhouse CMD
Image #13 – AKPB-Bunkhouse Panel ‘Bunk’ Image #14 – AKPB-Bunkhouse Panel ‘Bunk’
GND
Image #15 – BTTB-Visitor Center MTS Image #16 – BTTB-Visitor Center Panel ‘A’
Image #17 – BTTB-Panel ‘Rec’ Image #18 – BTTB-Panel ‘Cache’
Image #19 – BTTB-Well House CMD Image #20 – BTTB-Panel ‘Well House’
Image #21 – BTTH-House 106 CMD Image #22 – BTTH-House 109 Panel ‘A’
Image #23 – BTTH-House 110 Panel ‘A’
If you have any questions concerning the above, please do not hesitate to call me.
Sincerely, Patrick Collins, P.E.
Electrical Project Engineer pcc/hhm 22-0424/M1180
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