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Legacy Electrical Rooms and NEC 110.26 – When Compliance Isn’t Possible

jar546

CBO
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Oct 16, 2009
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Not where I really want to be
In South Florida, it's common to find FPL transformer vaults located inside older condominium buildings, including both mid-rise and high-rise structures. These vaults are typically only accessible by FPL from the outside—there are no interior doors or access points from within the building. The buildings are almost always Type I or Type II construction, with concrete or solid poured masonry walls separating the vault from the rest of the structure. You’ll usually find the building’s main service disconnects and switchgear on the opposite side of one of these vault walls.

Many of these buildings were constructed in the late 1950s through the 1980s, a time when building code enforcement in many parts of South Florida was inconsistent at best. That brings us to the problems we face today.

In quite a few cases, the required electrical workspace doesn’t come close to meeting today’s standards—or even the minimum requirements that have been in place for decades. NEC 110.26, which establishes the minimum clear working space around electrical equipment for safe operation and maintenance, would be wishful thinking. In one example, a building that was initially a hotel was converted into condominiums, and a chiller system was later installed. The chilled water piping runs right through the electrical service room, clearly violating not just NEC 110.26 but other sections as well. This has been the case for over 30 years, a legacy of South Florida’s “wild west” era of enforcement.

Now, many of these buildings have electrical switchgear that is well beyond its useful life. In some cases, the equipment has deteriorated to the point where certain breaker buckets no longer function at all. Replacement is not just needed—it’s overdue. But how is that handled? At what point does a situation like this demand a no-nonsense approach that mandates compliance?

In many instances, full compliance is physically impossible. The electrical rooms—already undersized—are often located directly adjacent to the FPL vaults, and in some cases, mechanical piping and ductwork have been added over the years that would now need to be completely removed, at an extreme cost, to bring the room up to code.

So, where does the NEC intersect with the IEBC in addressing these existing conditions? That’s the real-world question. These are not theoretical scenarios—they're daily challenges. Many of these buildings are themselves beyond their intended life expectancy, yet the only viable path is to keep repairing and maintaining them.

This is a discussion worth having. These legacy conditions force us to confront tough choices between practicality, life safety, code compliance, and the economic reality of aging infrastructure.
 
Expanding on this a little more, how could compliance be achieved? In many cases, the only option would be to build a small room as an addition just to house the service switchgear and turn the existing electrical room into all junction boxes. Often, there is no room for that because of setback issues, which can be considered for a variance, but sometimes there literally is no more room. Add to the fact that many of these are on the ocean in a VE zone, and now we are talking about an elevated electrical room. The real fix for compliance is an expensive proposition, although the word 'expense' is not in the NEC.
 
If the proposed work will increase the safety of the installation and the remediation that would be required in order to comply with code is not possible... well then perhaps the value of the proposed work outweighs strict code compliance. Given that the installation already violates 110.26 and is now dangerous for other reasons, a prudent approach would be to make it safer if not perfect.
 
If the proposed work will increase the safety of the installation and the remediation that would be required in order to comply with code is not possible... well then perhaps the value of the proposed work outweighs strict code compliance. Given that the installation already violates 110.26 and is now dangerous for other reasons, a prudent approach would be to make it safer if not perfect.
What about situations where 4-6" chiller pipes run on the ground right in front of the service disconnects? Not just below but about 1' in front of them. What about situations like that?
 
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Do you see options? I see options.
"Housekeeping pad"...

Hopefully this turns into a good discussion because Shirley you will have the "A violation is always a violation" folks and those of us who try to figure out if it is WWOP and that is the violation or somehow the AHJ "APPROVED" a violation.....

IF they are "adding more amps" or something else that makes it "less safe" we send them to the State for a modification....We can't approve deviations locally...

The house meter is a violation of the panel above it too FWIW.....
 
The house meter is a violation of the panel above it too FWI
110.26(A)(3) Height of Working Space.
The work space shall be clear and extend from the grade, floor, or platform to a height of2.0 m (614 ft) or the height of the equipment, whichever is greater. Within the height requirements of this section, other equipment or support structures, such as concrete pads, associated with the electrical installation and located above or below the electrical equipment shall be permitted to extend not more than 6 in. beyond the front of the electrical equipment.

Exception No. 3: Meters that are installed in meter sockets shall be permitted to extend beyond the other equipment. The meter socket shall be required to follow the rules of this section.
 
110.26(A)(3) Height of Working Space.
The work space shall be clear and extend from the grade, floor, or platform to a height of2.0 m (614 ft) or the height of the equipment, whichever is greater. Within the height requirements of this section, other equipment or support structures, such as concrete pads, associated with the electrical installation and located above or below the electrical equipment shall be permitted to extend not more than 6 in. beyond the front of the electrical equipment.

Exception No. 3: Meters that are installed in meter sockets shall be permitted to extend beyond the other equipment. The meter socket shall be required to follow the rules of this section.
Because that section is written so horribly....Does it have to be exempt from all 3? H W & D?
 
The example in the picture I could live with. I was envisioning much tighter clearances.

If the chiller pipes are protected from physical damage, I wouldn't move them either. Not for an existing structure.

We get down to having 24" of clearance in front of the equipment or less, then I will start to worry.
 
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