[RE-wrenches] Rapid Shutdown Again?
cwarfel
cwarfel at entech-engineering.com
Thu Aug 30 09:01:43 EDT 2018
In submitting my comments, I only could access 2017, and that's where I
made my comments. Does anyone have more information, or is it too late?
On 8/29/2018 10:05 PM, Ray wrote:
>
> The link to review the first draft of the 2020 code is not working.
> Do you have just the changes for 690? I'd really like to submit some
> comments.
>
> Thanks,
>
> Ray Walters
> Remote Solar
> 303 505-8760
> On 8/28/18 7:59 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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>
>
>
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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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