thanx for the input, we got the response on the RFI, now, they are goint to consider the primary protected by the breaker feeding it because it is within 50 feet, and visible, if two sets of doors remain open.
the secondary will be protected by a 1200A fusible disconnect that is 69"H, 18"D, and 36"W. this will be big enough for our 3- 3" Conduits with 4-500KCmil and 2/0 ground.
thanx again for the input.
matt
