Understanding the regulatory process for power installations

Addressing regulatory concerns at the onset of a major project ensures timely and successful commissioning of on-site generating plants.


Figure 1: This flowchart represents a roadmap of typical regulatory approval processes. Understanding and addressing regulatory issues early can help stakeholders avoid pitfalls. Courtesy: IntertekWith many major capital projects in the public or private domain, regulatory issues must be addressed as early as possible in the design review and bid specification processes, and independent power installations are no exception (see Figure 1). The crux of the regulatory process is in determining compliance of the equipment, and in compliance of the overall installation to the appropriate codes and standards. The enforcement of the codes and standards described in this article is intended to mitigate the risks associated with fire, electric shock, energy, grid protection, life safety, mechanical hazards, explosion, and employee health and safety. Of course, this list is not all-inclusive. The generator construction and performance as well as the installation itself will come under scrutiny as part of the regulatory process.

Stakeholders and documentation
A key area often overlooked when kicking off a power installation project is the importance of identifying stakeholders (see Figure 2). It is essential these interested parties be determined early on, because the stakeholder matrix will be what defines-at least in part-the regulatory process and requirements. This matrix will vary somewhat with the facility or occupancy to which the power plant is connected, but it is reasonable to assume that the stakeholders will consist of the designers and specifying professionals, installers, owners, insurers, equipment manufacturers, major component vendors, and authorities having jurisdiction (AHJs).

The primary documents governing installation related to independent power generation are the National Electrical Code (NEC) and NFPA 37: Standard for the Installation and Use of Stationary Combustion Engines and Gas Turbines. The generating plant as a manufactured piece of equipment is covered by UL 2200: Standard for Safety for Stationary Engine Generator Assemblies. A number of other installation codes will also come into play, including NFPA 110: Standard for Emergency and Standby Power Systems, NFPA 99: Health Care Facilities Code, and NFPA 30: Flammable and Combustible Liquids Code. Additionally, it is possible that the National Electrical Safety Code (NESC, IEEE C2) will be invoked. This document provides guidance and requirements for the practical safeguarding of persons during the installation, operation, or maintenance of electrical generating plants and associated equipment. The NESC also covers electrical supply conductors and equipment, including structural considerations of electric generating plants. Although intended primarily for utilities, electric generating plants under the exclusive control of qualified persons authorized by a controlling or regulating entity such as an industrial complex or utility interactive system may also be subject to the rules of the NESC.

Field evaluation, independent testing
The regulatory process for a power installation will optimally require independent third-party involvement. This third party, generally a nationally recognized testing laboratory (NRTL), will conduct a compliance evaluation of the generator and auxiliary equipment before and during construction of the physical equipment. The presence of an NRTL mark is evidence the compliance evaluation has been conducted and the equipment has been determined to be in compliance with the appropriate standards (see Figure 3). It is important to note that the installation is still subject to inspection by AHJs and other stakeholders.

Figure 2: Stakeholders should be identified early when kicking off a power installation project. Courtesy: IntertekAlternatively, power generating equipment not subject to an independent assessment may still be eligible for field evaluation. If successful, this will result in the application of a field label indicating a minimum level of electrical safety compliance with the appropriate standards. On-site testing will be required for a field label and may be conducted in conjunction with any commissioning tests required by the owner or other stakeholders. A review of construction will also take place as part of a field evaluation. The introduction of a generating plant into a power installation without any independent evaluation may result in extensive modifications as well as real-time testing prior to approval. These activities would likely introduce delays in the commissioning of the power plant. Typical issues that may require corrective action include:

  • Unlisted or undocumented major components
  • Lack of proper internal bonding or grounding
  • Improper output circuit protection
  • Unimpeded access to uninsulated live parts
  • Unsuitability for the environment
  • Inability to effectively ground equipment
  • Missing guards on moving parts and high-temperature parts. 

Implicit with either a listing or a field evaluation is the responsibility of the manufacturer to have control over the design and manufacturing process, as well as component and vendor selection. The compliance evaluation will require the NRTL to conduct a complete design review of the generator and auxiliary equipment. This review entails a clause-by-clause comparison of the requirements in the appropriate standards with the observed construction of the equipment, as well as review of installation instructions. Critical components are identified and they will be required to be listed or recognized, or undergo special investigations to ensure their suitability for the application. Any disparities or noncompliances are communicated to the manufacturer and corrective actions must be taken. Importantly, the certification organization is only allowed to report the findings and not the actual corrective actions. Therefore, it is not uncommon for a consultant to be brought in at this stage to assist with corrective actions and project completion. The product standards also define the required testing needed for the manufacturer to claim compliance. A listed product is subject to routine production-line testing, which would reduce or eliminate any verification testing that would be required for a field evaluation.

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