DEPARTMENT OF THE AIR FORCE

HEADQUARTERS AIR FORCE CIVIL ENGINEER SUPPORT AGENCY

19 JAN 2011

FROM: HQ AFCESA/CEO
139 Barnes Drive Suite 1
Tyndall AFB FL 32403-5319

SUBJECT: Engineering Technical Letter (ETL) 11-9: Electrical Manhole Entry

and Work Procedures

1. Purpose. This ETL provides electrical safety guidance and criteria for working inside
electrical manholes and handholes. It applies to base personnel and contractors
working on Air Force installations. This ETL does not apply to airfield lighting circuits.

This ETL supplements Air Force instruction (AFI) 32-1064, Electrical Safe Practices,
paragraph 5.4.

2. Application. Requirements in this ETL are mandatory. Any deviations require written
approval from the Chief Electrical Engineer, HQ AFCESA/CEOA.

2.1. Authority: AFI 32-1064, Electrical Safe Practices

2.2. Effective Date: Immediately

2.3. Intended Users:

 Major command (MAJCOM) engineers
 Base civil engineers (BCE)

2.4. Coordination:
 MAJCOM electrical engineers
 Air Force Safety Center, Ground Safety Division (AFSC/SEG)

3. Referenced Publications.

3.1. Air Force (available at http://www.e-publishing.af.mil):

 AFI 32-1063, Electric Power Systems
 AFI 32-1064, Electrical Safe Practices
 AFI 90-901, Operational Risk Management
 Air Force pamphlet (AFPAM) 90-902, Operational Risk Management (ORM)
Guidelines and Tools
 Air Force Occupational Safety And Health (AFOSH) standard 91-25, Confined
Spaces

3.2. Joint (available at http://www.wbdg.org/ccb/browse_cat.php?o=29&c=4):

APPROVED FOR PUBLIC RELEASE: DISTRIBUTION UNLIMITED

  Unified Facilities Criteria (UFC) 3-550-01, Exterior Electrical Power
Distribution
 UFC 3-560-01, Electrical Safety, O&M

3.3. Industry:
 Institute of Electrical and Electronics Engineers (IEEE) C2, National Electrical
Safety Code (NESC), http://www.ieee.org/index.html

4. Background.

4.1. AFI 32-1064, paragraph 5.2, states: “Work on or near energized distribution
lines is prohibited except in rare circumstances and then only when approved by the
BCE.” Work on or near energized electrical equipment in manholes is extremely
dangerous and requires that all circuits inside the manhole be deenergized.
UFC 3-560-01, Electrical Safety, O&M, states that all equipment inside a manhole,
including insulated conductors, should be deenergized before allowing entry into a
manhole.

4.2. Questions have been raised regarding whether or not an insulated conductor is
considered energized equipment. An IEEE interpretation, dated 14 January 2009,
regarding IEEE C2 (National Electrical Safety Code) Rule 410A3, confirms that the
phrase “on or near energized parts or equipment” applies to energized insulated
conductors inside manholes. IEEE C2 Rule 443 does allow a qualified employee,
working alone, to enter a manhole where energized cables or equipment are in
service for the purpose of inspection, housekeeping, taking readings, or similar work
if such work can be performed safely.

4.3. In some instances, it can be difficult to deenergize all circuits inside a manhole
when accomplishing repair or installation activities because of the number of circuits
inside the manhole. Accordingly, this ETL provides guidance regarding the type of
work activities permitted inside manholes containing energized circuits.

5. Definitions.

5.1. Handhole. An opening in an underground system containing cable, equipment,

or both into which personnel reach, but do not enter, for the purpose of installing,
operating, or maintaining cable, equipment, or both.

5.2. High voltage. For the purpose of this ETL, a class of nominal system voltages
greater than 34,500 volts.

5.3. Low voltage. For the purpose of this ETL, a class of nominal system voltages
less than or equal to 600 volts.

5.4. Manhole. A subsurface enclosure that personnel may enter, used for installing,
operating, and maintaining cable.

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 Note: UFC 3-550-01, Exterior Electrical Power Distribution, paragraph 3-11.5,
requires the following for manholes intended for use at 15 kilovolts (kV) and below:
“Determine the size of power manholes by the number of circuits, voltage ratings
and splicing requirements of the cables within. Manholes shall be a minimum 2 m
(6.5 ft) deep.”

5.5. Medium voltage. For the purpose of this ETL, a class of nominal system
voltages above 600 volts and less than or equal to 34,500 volts.

5.6. Qualified person. A person permitted to work on or near exposed energized

equipment or conductors, who is, at a minimum, trained in and familiar with the
following:
 The skills and techniques necessary to distinguish exposed live parts from
other parts of electric equipment, including wire and cables;
 The skills and techniques necessary to determine the nominal voltage of
exposed live parts;
 The clearance distances and corresponding voltages to which the qualified
person will be exposed; and
 Confined space training.

6. Acronyms.

AFI - Air Force instruction

AFPAM - Air Force pamphlet
BCE - base civil engineer (or equivalent)
ft - foot
IEEE - Institute of Electrical and Electronics Engineers
m - meter
MAJCOM - major command
ORM - operational risk management
PPE - personal protective equipment
UFC - Unified Facilities Criteria

7. Requirements.

Work on or near energized electrical equipment in manholes is extremely

dangerous and prohibited except in accordance with the following paragraphs.

7.1. Electrical Handholes. Work on or near energized electrical equipment in

handholes is prohibited because the available working space is too small for safe
work practices. All handhole electrical circuits shall be completely de-energized
before starting any troubleshooting, maintenance, or repair action within the
handhole.

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7.2. Electrical Manholes Containing Low-Voltage Circuits. Work on or near
energized electrical equipment in manholes containing low-voltage circuits is
prohibited because of high arc flash results for secondary circuits downstream of
distribution transformers. Manhole low-voltage electrical circuits shall be completely
de-energized before starting any troubleshooting, maintenance, or repair actions.

7.3. Electrical Manholes Containing Medium-Voltage Circuits. Before entering a

manhole containing medium-voltage energized circuits, first visually confirm that the
manhole’s installed configuration allows entry without disturbing any installed
conductors or equipment. If it is not possible to enter the manhole without disturbing
conductors, or if is not possible to move around inside the manhole without
disturbing conductors (adequate working space), then all circuits inside the manhole
must be deenergized before entry. Figures 1 through 3 show examples of manholes
where entry is prohibited without first deenergizing all circuits inside the manhole.
The chief of the electrical shop is responsible for making the assessment regarding
safe entry.

Note: Comply with the requirements in AFI 32-1064, AFOSH Standard 91-25,
Confined Spaces, and UFC 3-560-01 related to confined space entry.

Figure 1. Example Manhole with Inadequate Working Space

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 Figure 2. Example Manhole with Inadequate Working Space

Figure 3. Example Manhole Where Entry Disturbs Conductors

7.3.1. Access for Inspection Only – No Known Problems.

Note: Entry into a manhole containing energized circuits is not permitted for
inspection activities if problems are suspected inside the manhole, such as
conductor damage associated with a short circuit.

Note: Up to 0.5 inch of standing water is permitted for inspection activities.

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 7.3.1.1. Allowed Activities. The following activities are allowed if no
conductors will be disturbed or moved:
 Manhole and sump inspection.
 Sump cleaning.
 Inspection of conductors and splices.
 Inspection of equipment installed in the manhole, including load
junctions, t-splices, switches, and submersible transformers.
 Installing conduit plugs on spare conduits.

Note: Lightly brushing dust from conductors or nameplates is not considered

disturbing the circuit.

7.3.1.2. Energized Work Permit and Personal Protective Equipment (PPE)

Requirements. An energized work permit must be prepared in advance and
as a minimum include:
 Description of manhole and configuration. Include a written
assessment by the chief of the electrical shop that the manhole can be
entered and the activity accomplished without disturbing energized
conductors.
 Description of intended inspection or activity.
 Evidence of completing the job briefing, i.e., safety requirements, tools,
PPE, any other hazards.
 Rescue plan for incapacitated workers.
 Confirmation that Category 2 PPE shall be worn as defined by
UFC 3-560-01, Table 4-1.
 Confirmation that confined space entry requirements are met.
 Minimum of two qualified persons are required for this activity.
Qualification requirements are specified in UFC 3-560-01.
 Egress plan in the event of an emergency.

7.3.1.3. The energized work permit for “inspection only access” shall be
approved by the chief of the electrical shop. The energized work permit for
“inspection only access” can be discarded after the activity is complete.

7.3.2. Authorized Work Inside Manholes Containing Energized Circuits.

Note: No standing water is permitted for work.

7.3.2.1. Authorized Work. The following work activities are permitted:

 Removing conduit plugs.
 Spare conduit inspection using fish tape, boroscope, or other devices.
 Splicing deenergized conductors.
 Pulling new conductors in spare conduits.
 Removing abandoned (deenergized) circuits, including load break or
dead break elbows, if nearby energized circuits are not disturbed.

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 Note: Reracking energized conductors is not permitted. The circuits must be
deenergized before the conductors can be disturbed.

7.3.2.2. Energized Work Permit and PPE Requirements. The energized work
permit must be prepared in advance and as a minimum include:
 Description of manhole and configuration.
 Confirmation that:
1. The manhole can be entered and the work accomplished without
disturbing other energized conductors or equipment.
2. When splicing deenergized conductors, an 18-inch (0.5-meter) safe
working distance from other energized conductors or equipment
can be maintained during the work.
 Description of planned work practices to be followed.
 Rescue plan for incapacitated workers.
 Evidence of completing the job briefing, i.e., safety requirements, tools,
PPE, any other hazards.
 Confirmation that Category 2 PPE shall be worn as defined by UFC
3-560-01, Table 4-1.
 Confirmation that confined space entry requirements are met.
 Minimum of two qualified persons are required for this activity.
Qualification requirements are specified in UFC 3-560-01.
 Egress plan in the event of an emergency.

7.3.2.3. The energized work permit for “authorized work inside a manhole
containing energized circuits” shall be approved by the BCE. The chief of the
electrical shop shall retain the approved energized work permit for one year.

7.3.3. Other Work Inside Manholes Containing Energized Circuits.

Note: This paragraph applies to work activities inside manholes containing

energized circuits that are not addressed by paragraphs 7.3.1 or 7.3.2.

Note: No standing water is permitted for work.

7.3.3.1. Operational Risk Management (ORM) Requirements. Prepare an

ORM analysis detailing the rationale and energized work procedures to be
followed while working in the manhole. The BCE shall approve the ORM after
review by the base safety office and forward an information copy to the
MAJCOM Operations Branch; Air Force Safety Center, Engineering and
Standards Branch (HQ AFSC/SEGS); and Air Force Civil Engineer Support
Agency, Engineering Support Branch (HQ AFCESA/CEOA). Follow guidance
in AFI 90-901, Operational Risk Management, and AFPAM 90-902,
Operational Risk Management (ORM) Guidelines and Tools.

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 7.3.3.2. Energized Work Permit and PPE Requirements. The energized work
permit must be prepared in advance and as a minimum include:
 Description of manhole and configuration.
 Copy of approved ORM.
 Description of planned work practices to be followed.
 Electrical shock analysis and boundaries (safe working distance).
 Arc flash hazard analysis and flash boundary determination.
 Necessary PPE to safely perform the task, i.e., arc flash, shock, or
other required PPE.
 Options and means to restrict access by unqualified persons in the
work area.
 Rescue plan for incapacitated workers.
 Evidence of completing the job briefing, i.e., safety requirements, tools,
PPE, any other hazards.
 Confirmation that confined space entry requirements are met.
 Minimum of three qualified persons are required for this activity.
Qualification requirements are specified in UFC 3-560-01.

7.3.3.3. Electrical analysis software packages that perform arc flash

calculations do not account for an electrical manhole configuration in which
the electrical worker is inside an enclosed area rather than standing adjacent
to an enclosure. Increase the arc flash PPE requirements by a minimum of
one (1) arc flash hazard category above the arc flash calculation result.

7.3.3.4. The energized work permit for “other work inside a manhole
containing energized circuits” shall be approved by the BCE. The chief of the
electrical shop shall retain the approved energized work permit for one year.

7.4. Electrical Manholes Containing High-Voltage Circuits. Work on or near

energized electrical equipment in manholes containing high-voltage circuits is
prohibited. All manhole electrical circuits shall be completely de-energized before
starting any troubleshooting, maintenance, or repair action within the manhole.

8. Point of Contact. The authority having jurisdiction on all matters discussed within
this ETL is the Chief Electrical Engineer, HQ AFCESA/CEOA. To reach the Chief
Electrical Engineer, e-mail AFCESAReachBackCenter@tyndall.af.mil, call DSN 523-
6995 or commercial (850) 283-6995, or mail to 139 Barnes Drive, Suite 1, Tyndall AFB,
FL 32408-5319.

CLIFFORD C. FETTER, P.E., GS-15, DAF 1 Atch

Acting Chief, Operations and Programs Support 1. Distribution List

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