We had a failure in a 13,800 substation. We had to shut down the 13,800 side of the transformer. We had the electricians use a hot stick and 20,000 volt rated glowes. The DOE inspector violated us for not doing a ARC Flash Calc and using protective clothing and Face shield. We tried to explain to her that actually none of the above were required since 70E requires PPE to be used when exposed to live parts. This transformer had no exposed live parts and the breaker was oil emersed using FP3 cooper oil. We explained if there were live parts and arc flash calc were used it would be in excess of 156 cal. and the utility would have to be contacted to totally shut down the project. At 156 cal, there is no PPE that would properly protect these electricians. For example at 46 cal. a face shield would melt.
I would greatly appreciate so opinions so I can defend our position.
