[RE-wrenches] Rapid Shutdown Again?
cwarfel
cwarfel at entech-engineering.com
Tue Aug 28 12:41:24 EDT 2018
Thanks Rebecca, This will help. Chris
On 8/28/2018 9:59 AM, Rebekah Hren wrote:
> Hi all,
> What you need to do now - to get your voices heard about rapid
> shutdown requirements- is to make public comments on the first draft
> of the 2020 NEC. *_Comments are due AUGUST 30 at midnight!!! _*
>
> Here is the link to a press release
> <https://www.necanet.org/about-us/news/news-release-archive/news/2018/07/02/nfpa-releases-2020-nec-first-draft-for-public-review> with
> links to read the draft and input your comments:
> https://www.necanet.org/about-us/news/news-release-archive/news/2018/07/02/nfpa-releases-2020-nec-first-draft-for-public-review
>
> The process for changing the NEC is standardized by the NFPA and while
> it may not be perfect, it's what we've got!
>
> Best,
> Rebekah Hren
>
> On Tue, Aug 28, 2018 at 6:50 AM cwarfel
> <cwarfel at entech-engineering.com
> <mailto:cwarfel at entech-engineering.com>> wrote:
>
> I like your solutions to this. Just sticking to rapid shutdown and
> not the fire code, I think a lot of the problems with 690.12 could
> be reduced if the maximum string voltage was 150 or even 250. It
> reduces the ampacity on a roof for a given power and I feel that
> is more of a danger than array voltage that the Firefighters are
> highly likely to avoid.
>
> I still cannot get Outback Power to provide a corrected
> installation manual or a start up procedure on the RSI/ICS
> equipment. Two plus months and all I get are repeated vague or
> incorrect information. One expert at OB said that they really
> didn't deal much with Rapid Shutdown............
>
> I cannot install any more Outback on roofs at this time.
>
> I'll see if it is ok to provide a link to an online petition to
> change 690.12.
>
>
> Chris
>
>
>
> On 8/27/2018 2:13 PM, Ray wrote:
>>
>> HI Chris;
>>
>> As with all things bureaucratic, good intentions can go awry
>> when actually implemented. Years ago, I was one of the wrenches
>> pushing for some form of disconnect closer to the power source,
>> or the PV array. I had no idea it would come back to bite us
>> small off grid folks so hard, though. I'm not quite for
>> scrapping all of 690.12, but I do think it needs some serious
>> work. /In or on the building/ needs to be defined more clearly as
>> 'on the roof'. Ground mounts need a clearer exemption. The PV
>> disconnect needs to be clearly defined and also clearly stated
>> that the Rapid disconnect system stops there. The time limit
>> needs to be bumped up to 90 seconds: no one is going to throw the
>> switch and be hacking on the roof that fast. The array voltage
>> should be 150 vdc, so that lower voltage off grid systems could
>> be exempt, and I really think 690.12 should only apply to larger
>> arrays (over 10kW) that have long exposed runs of conduit (over
>> 10 yards) or that cover more than a certain percentage of the
>> total roof area. If an array covers one face of the garage it
>> should be exempt, and if it covers half the total roof, then it
>> should have Rapid disconnect, for instance. We need to be
>> sensible, do the fire fighters have a good spot to cut and vent
>> the roof without electrical hazards or not?
>>
>> Its interesting how article 690 has morphed from being almost
>> entirely oriented towards off grid in 99 and 02, to now off grid
>> is barely even considered. Just look at the lack of thought when
>> they wrote the definitions for /DC to DC Converters/. The solar
>> industry has been ready and willing to be thrown under the bus at
>> every turn. I think its about time we started advocating for our
>> own self interests like all the other parties involved. This
>> also means that us off grid folks need to be properly
>> represented, and off grid considered with all code changes. I
>> think DC coupled PV should have its own section and be separated
>> from AC coupled PV. The systems are so different that it doesn't
>> make sense to throw them into the same section. The emergence of
>> article 706 is a step in the right direction.
>>
>> Ray Walters
>> Remote Solar
>> 303 505-8760
>> On 8/23/18 5:31 PM, cwarfel at entech-engineering.com
>> <mailto:cwarfel at entech-engineering.com> wrote:
>>>
>>> I think Rapid Shutdown should be scrapped professionally and
>>> personally. It was ill conceived and ill written. Anyone
>>> willing to join me in a petition to CMP 44 and the like, contact
>>> me off list.
>>>
>>> To your question directly, you have a ground mounted system and
>>> you are not subject to 690.12 unless your conductors are "in or
>>> on building" which i cannot seem to find what that actually
>>> means. Exempted are buildings that are isolated only for the PV
>>> system This is a big win for installers as almost everyone
>>> installs systems like this....... Right. They used to have a
>>> dimension to this, but I guess that gave installers too much
>>> information. This is a stupid Code addition for roof mounted pv
>>> systems, disguised as protecting Firefighters, but not doing so
>>> in reality. The NEC looks politically compromised by consultants
>>> and manufacturers who too advantage of this fear mongering. No
>>> other country with a pv industry has historically done this. Why
>>> are installers not up in arms about this?
>>>
>>> This is the NEC reference.
>>>
>>> 690.12 Rapid Shutdown of PV Systems on Buildings. PV system
>>> circuits installed on or in buildings shall include a rapid
>>> shutdown function to reduce shock hazard for emergency
>>> responders in accordance with 690.12(A) through (D).
>>>
>>> If your system is ground mounted, you are outside the
>>> "altruistic" intent of 690.12 of protecting Firefighters. Put a
>>> initiation device disconnect switch at the array. Any
>>> supporters of RS should chime in with the support of 690.12 and
>>> add clarity and guidance to those of us who actually install
>>> systems and have to deal with this baloney. 690.12 has caused
>>> more problems for multimode systems than any tariffs, which are
>>> bad enough. I don' think the industry needs any more "safe
>>> design and installation" assistance from the CMPs involved with
>>> this issue.
>>>
>>> Chris Warfel
>>>
>>>
>>>
>>>
>>>
>>>
>>> On 2018-08-23 00:31, Ray wrote:
>>>
>>>> Greetings fellow wrenches;
>>>>
>>>> I know we have beat this many times but I once again have not
>>>> been able to resolve the contradictory information in 690 in
>>>> regards to implementing 690.12. As Rebekah Hren pointed out
>>>> before, the diagrams shown in Figure 690.1(b) show that the /PV
>>>> System DC Circuit/ stops at the /PV Disconnect/. Note 2 says
>>>> specifically the '/PV Disconnect separates the PV system from
>>>> all other systems/'. But then in the definitions in 690.2 on
>>>> the next page, the new definition of a /P//V System DC Circuit/
>>>> says that it includes DC to DC converter output circuits.
>>>> (which are Solar Edge module level controls, but could be
>>>> interpreted as a MPPT battery charge Controller?)
>>>>
>>>> Then 690.12 which only applies to '/PV System circuits in or on
>>>> buildings/', says we have to control conductors more than 3 ft
>>>> after penetrating the building.
>>>>
>>>> So in my case, I'm looking at a ground mount, and installing an
>>>> external lockable disconnect on the wall before it goes into
>>>> the building. This will officially be the PV Disconnect. In
>>>> my interpretation, I should not need to do any Rapid Shutdown,
>>>> because I've essentially prevented the /PV system/ from ever
>>>> entering the building at all ( based on the 5th diagram and
>>>> Note 2) However, I could see an AHJ claiming I had to do RS all
>>>> the way to the output side of the charge controller.
>>>>
>>>> If this were true, could I simply apply RS equipment from the
>>>> PV disconnect to the output of the charge controller, or am I
>>>> back to module level shutdown for my ground mounted array, or
>>>> could I build a tiny building that just housed the PV
>>>> Disconnect and take the exemption for '/buildings with the sole
>>>> purpose of housing PV system equipment/'?
>>>>
>>>> Essentially the definitions in 690.2 are too broad, and are at
>>>> odds with the Figure and Notes of 690.1. They really didn't
>>>> fix this in the 2017 code for us lowly off gridders. Charge
>>>> controllers are covered by article 706.23___/Charge Control/_,
>>>> and NOT by 690.12 at all. IMHO, the charge controller needs to
>>>> be clearly defined and differentiated from DC to DC converters
>>>> like Solar Edge's module level DC equipment.
>>>>
>>>> I just want to go back to doing solar designs and
>>>> installations, and quit acting like an attorney parsing every
>>>> word of this confusing code language.
>>>>
>>>> --
>>>> Ray Walters
>>>> Remote Solar
>>>> 303 505-8760
>>>>
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>>
>>
>>
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>
> --
>
> Christopher Warfel, PE
> ENTECH Engineering, Inc.
> PO Box 871, Block Island, RI 02807
> (401)466-8978
>
> EEI logo <http://entech-engineering.com>
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> --
> Tel: 336.266.8800
> NABCEP Certified Solar PV Installation Professional™ 091209-85
> NC Licensed Electrical Contractor
>
>
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--
Christopher Warfel, PE
ENTECH Engineering, Inc.
PO Box 871, Block Island, RI 02807
(401)466-8978
EEI logo <http://entech-engineering.com>
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