[RE-wrenches] Rapid Shutdown Compliance
Christopher Warfel
cwarfel at entech-engineering.com
Thu May 7 11:08:53 EDT 2020
To change this, we need to recognize we are "fighting City Hall", and I
doubt the CMP will be motivated to make changes on their own. Maybe
this has always been more political than technical, but it seems that
those who are opposed to the current requirements need to make it known
through the formal processes. The CMP is required to respond and in that
response we can learn of their reasons for not accepting any changes, or
the changes they would be willing to consider. I just don't see things
changing otherwise.
On 5/7/2020 10:18 AM, James Jarvis wrote:
> If first responders are the point of all the rapid shutdown, there
> needs to be better exemptions. I personally have a 20kW solar array on
> a 100 year old unused barn at my farm. The roof is at 50 degrees slope
> and needs a 60ft boom lift to access. There was significant extra
> expense and effort for the rapid shut down. And there is absolutely
> zero chance that a first responder would do anything other than watch
> the barn burn. And now I have an array that needs a $1,000 piece of
> rental equipment to get to the back of any module.
>
> There is a big difference between the stuff that is in big cities and
> what is in rural and what is in remote locations. For my telecom
> customers in Alaska and Antarctica, what is the point of decreasing
> reliability by putting module level electronics on solar arrays that
> require a multiple hour helicopter flight to get to. That's not
> protecting anybody other than the MLPE manufacturer's profit.
>
>
> -James Jarvis
> APRS World, LLC
> +1-507-454-2727
> http://www.aprsworld.com/
>
>
> On Thu, May 7, 2020 at 8:43 AM Christopher Warfel
> <cwarfel at entech-engineering.com
> <mailto:cwarfel at entech-engineering.com>> wrote:
>
> I believe Rapid Shutdown was mostly a solution looking for a
> problem. The only way I see this becoming "reasonable" is to
> present "grievances" to the Code Making Panel WITH a solution for
> their consideration. Based on experience from being part of an
> outreach program that taught approximately 10k firefighters over
> four years, I have asked that they add to the Directory, the
> language that states what type of solar electric system is on site
> (Microinverter, dc optimizer, string, multimode, grid isolated) so
> that First Responders don't have to guess. I realize this is
> different than MLPE, but it targets the person who Rapid Shutdown
> came into being for, and that was the First Responder. Chris
>
>
> On 5/6/2020 10:37 PM, Ray wrote:
>>
>> Spending more time on the roof, while putting more equipment and
>> parts to meet MLPE, means more trips up the ladder, which
>> increases, not decreases the #1 worker safety danger: Falls.
>> Please correct me if I have somehow misunderstood this, but MLPE
>> is not making installers safer based on OSHA information
>> provided. Also after installation, which system is more likely to
>> require workers to return to work on the roof, pulling up
>> modules, trying to find problem equipment? More connections is
>> More safe? Really? I haven't had to climb back up on the roof
>> on any of my older, lower voltage off grid work in almost a decade.
>>
>> Once again, MLPE has its place, (larger systems, multiple
>> subarrays, higher voltage) but we should have sensible exemptions
>> as have been mentioned already. We are endangering ourselves and
>> our employees needlessly, to comply with 690.12.
>>
>> Ray Walters
>> Remote Solar
>> 303 505-8760
>> On 5/6/20 8:41 PM, drake.chamberlin at redwoodalliance.org
>> <mailto:drake.chamberlin at redwoodalliance.org> wrote:
>>>
>>> Interestingly enough, the data on the link
>>> <https://www.osha.gov/pls/imis/AccidentSearch.search?p_logger=1&acc_description=&acc_Abstract=solar&acc_keyword=&sic=&naics=&Office=All&officetype=All&endmonth=05&endday=05&endyear=2002&startmonth=05&startday=05&startyear=2021&InspNr=> provided
>>> shows accidents from gas explosions, falls, health problems and
>>> industrial injuries. None of these incidents could have been
>>> prevented by module level power electronics. This is typical of
>>> the data that I've seen so far.
>>>
>>> ---
>>>
>>>
>>> On 2020-05-06 17:22, Martin Herzfeld wrote:
>>>
>>>> There could be an issue of encouraging MLPE for worker safety?
>>>> 1. This is data involving incidents with workers in the OSHA
>>>> Fatalities and Catastrophe Investigation Summaries found here:
>>>> https://www.osha.gov/pls/imis/AccidentSearch.search?p_logger=1&acc_description=&acc_Abstract=solar&acc_keyword=&sic=&naics=&Office=All&officetype=All&endmonth=05&endday=05&endyear=2002&startmonth=05&startday=05&startyear=2021&InspNr=
>>>> 2. In the past I've observed an arc fault at the module level
>>>> with traditional string systems without a listed arc-fault
>>>> circuit interrupter NEC/CEC 690.11. The function in NEC/CEC
>>>> 690.12 would be - to _reduce the shock hazard _- for /emergency
>>>> responders/ or /firefighters? (NEC 2020)./ However, I've
>>>> observed thermal events in the panelboard with plans and
>>>> workmanship issues.
>>>> On the other hand, falls are the #1 reason for incidents in the
>>>> construction industry.
>>>> All the best,
>>>>
>>>> Martin Herzfeld, Interstate Renewable Energy Council (IREC)
>>>> Certified Master Trainer ™ for Photovoltaics (PV) Installation
>>>> Professional #IREC 10037
>>>> Contract Training Provider (CTP)
>>>> Adjunct Professor, Energy
>>>>
>>>> California Solar & Electrical Contractor License #00833782
>>>> C46, C10, D56, D31, C-7 - Since 2004
>>>> Solar, Electrical, Trenching, Pole Installation & Maintenance,
>>>> Instrumentation
>>>>
>>>> Contract Solar (PV) Technical Inspector - 3rd Party Inspections
>>>> Underwriters Laboratories (UL) Certified PV Installer #17, OSHA 30
>>>> OSHA-Authorized Construction Trainer #32-0105338
>>>> CompTIA Certified Technical Classroom Trainer (CTT+)
>>>> #T3NSZCNBBKB4QTQG
>>>>
>>>> * Professional Member, International Association of Electrical
>>>> Inspectors #7035507 - Since 2006
>>>> * Accredited and Registered North American Board of Certified
>>>> Energy Practitioners (NABCEP) Continuing Education (CE)
>>>> Training Provider
>>>>
>>>> On Thu, Apr 30, 2020, 8:29 AM
>>>> <drake.chamberlin at redwoodalliance.org
>>>> <mailto:drake.chamberlin at redwoodalliance.org>> wrote:
>>>>
>>>>
>>>> I would like to see real data on the fire risk of string
>>>> inverters. Anecdotal problems are not data.
>>>> The industry is definitely heading toward MLPE due to the
>>>> rapid shutdown requirements. In many cases MLPE makes
>>>> sense, in other cases it doesn't.
>>>> Systems that are more cost effective and reliable can often
>>>> be built by using string inverters.
>>>> ---
>>>>
>>>>
>>>> On 2020-04-29 22:05, Jason Szumlanski wrote:
>>>>
>>>> "Rapid Shutdown does not prevent fires."
>>>>
>>>> Not true. If the effect of RS is to steer the market to
>>>> MLPE, I believe it has a significant impact on reducing
>>>> fire risk. As one who has watched a DC conductor fire
>>>> smolder out of control, I am sold on an AC module or
>>>> microinverter architecture. While RS on a DC array
>>>> doesn't necessarily reduce fire risk within the array,
>>>> it still has the potential to reduce severity and
>>>> spread. Nothing is going to prevent all fires. I get
>>>> that. We're talking about risk mitigation when it comes
>>>> to RS.
>>>> As for "dependable string inverters," the one
>>>> dependable feature is failure at least once in the
>>>> module lifetime, accompanied by a shocking repair bill.
>>>> I'm not a shiny object following kind of guy, but the
>>>> writing is on the wall. MLPE is the future. Modular,
>>>> serviceable, disposable if you will. Like it or not,
>>>> Edison is going to lose this battle to Tesla (Tom vs
>>>> Nikola). And I live less than 5 minutes away from Tommy
>>>> E's winter home in Fort Myers, FL. And I "grew up" in
>>>> the industry living off-grid in DC power. But AC
>>>> distribution wins for safety at various scales.
>>>>
>>>>
>>>>
>>>> On Wed, Apr 29, 2020, 9:42 PM
>>>> <drake.chamberlin at redwoodalliance.org
>>>> <mailto:drake.chamberlin at redwoodalliance.org>> wrote:
>>>>
>>>> Rapid Shutdown does not prevent fires; it was
>>>> originally drafted to allow firefighters to vent a
>>>> roof without being hindered by energized PV arrays.
>>>> This rule was expanded to include other DC wiring
>>>> from PV sources.
>>>>
>>>> As for PV safety, I'd like to see some significant,
>>>> statistical evidence that shows there is a major
>>>> fire danger from PV relative to other sources. A
>>>> fire from a solar array gets a lot more press than
>>>> one from a gas leak, bad wiring or an ash tray
>>>> emptied into a wastepaper basket.
>>>>
>>>> Large public buildings should have all the
>>>> protection that is available. Does one size fit all?
>>>>
>>>> Would it be reasonable to allow residential
>>>> installations under 12 kW, with 1/4 of the roof
>>>> adjacent to the array available for venting, to be
>>>> excepted from 690.12? What about sparsely occupied
>>>> commercial buildings with ample roof area open for
>>>> ventilation?
>>>>
>>>> Many of us have chosen to work with renewable
>>>> energy technology to lessen the harms caused by
>>>> fossil fuel extraction and combustion. The need for
>>>> non-carbon based energy sources has become
>>>> extremely clear.
>>>>
>>>> The old string inverters still chug along year
>>>> after year, with little or no maintenance. Someone
>>>> must pay for the ongoing maintenance of module
>>>> level electronics. Dependable string inverter
>>>> systems should be allowed unless statically
>>>> significant danger can be demonstrated.
>>>>
>>>> Drake
>>>>
>>>> ---
>>>>
>>>>
>>>> On 2020-04-29 16:01, Jason Szumlanski wrote:
>>>>
>>>> I have been to several PV fires for string
>>>> inverter systems, both commercial and
>>>> residential, and have seen many DC systems at
>>>> serious risk of fires or in various stages of
>>>> melted insulation and connectors. Most of these
>>>> systems have exhibited good to excellent
>>>> workmanship. Things just went wrong. Some
>>>> were traceable to animal damage, wind, or other
>>>> unmitigated factors, and some were unexplained.
>>>> I disagree that there isn't justification for
>>>> rapid shutdown.
>>>> In my opinion, what we need is some additional
>>>> innovation and competition in the MLPE space.
>>>> Reliability is clearly a key factor, but there
>>>> is no denying that MLPE has added safety
>>>> benefits among other benefits. And if you do
>>>> enough volume and set up your business for
>>>> efficiency (standardization of product
>>>> offerings), MLPE isn't much more expensive. It
>>>> becomes a negligible cost relative to the
>>>> benefit. The value proposition is easy to
>>>> convey. There are limits to this, but for the
>>>> majority of residential and small commercial
>>>> installations, MLPE has become the de facto
>>>> standard around here. String inverters are
>>>> dinos, and replacing 8-12 year old transformer
>>>> based inverters is many times more annoying
>>>> than some MLPE swaps. I will admit that the
>>>> roofs around here are pretty easy to walk, so
>>>> that is a factor that might not apply to you.
>>>> If you go under due to manufacturer product
>>>> failures, you are not writing your contracts
>>>> right or not charging enough for service issues
>>>> beyond your control. I believe that's a red
>>>> herring. You might suffer some reputation
>>>> damage, but for someone that has been
>>>> installing MLPE for over a decade, that is
>>>> totally manageable. Consumers find a service
>>>> call to replace MLPE a LOT more palatable than
>>>> a surprise inverter replacement that could cost
>>>> thousands of dollars. People just don't plan
>>>> for that.
>>>> Regarding rapid shutdown devices, I have also
>>>> come across a few that "someone" has bypassed
>>>> around here. I don't know if they were never
>>>> installed properly or disabled/bypassed due to
>>>> failure. It seemed suspicious to me at the
>>>> time. I remember that it made me wonder what
>>>> good is a rapid shutdown device if it is easily
>>>> defeated? That's another argument for MLPE. It
>>>> has pretty failsafe MLPE functionality.
>>>> Jason Szumlanski
>>>> Florida Solar Design Group
>>>>
>>>> On Wed, Apr 29, 2020 at 10:59 AM
>>>> <drake.chamberlin at redwoodalliance.org
>>>> <mailto:drake.chamberlin at redwoodalliance.org>>
>>>> wrote:
>>>>
>>>> Clearly, rapid shutdown increases cost and
>>>> reduces reliability. Given the excellent
>>>> safety record of PV, prior to rapid
>>>> shutdown being required, it is unnecessary.
>>>> The few anecdotal incidents of PV fires
>>>> were not enough to justify the requirement,
>>>> especially on smaller systems.
>>>>
>>>> According to a friend who worked for a
>>>> local installation company that went under,
>>>> a big part of the reason for their failure
>>>> was the chronic replacement of
>>>> microinverters and optimizers.
>>>>
>>>> What steps can be taken to create some
>>>> balance in the rapid shutdown requirements
>>>> that are in the NEC?
>>>>
>>>>
>>>> ---
>>>>
>>>>
>>>> On 2020-04-29 07:27, Sky Sims wrote:
>>>>
>>>> So far rapid shutdown has been a
>>>> nightmare. It's added a lot of cost for
>>>> no measurable benefit.
>>>> Using always off devices like midnight
>>>> solar and Tigo makes it impossible to
>>>> test open circuit voltages. Which opens
>>>> the door to tons of problems when
>>>> commissioning systems.
>>>> Also we've been trying out midnight
>>>> Solar's product and have had an absurd
>>>> failure rate. Which means lots of truck
>>>> rolls and troubleshooting and system
>>>> downtime. They send replacement product
>>>> but they aren't paying for the lost
>>>> weeks of productivity.
>>>> We have Tigo product in hand and are
>>>> deciding which project to try it on.
>>>> But our big concern about using it is
>>>> not only the inability to confirm open
>>>> circuit voltage of the strings but also
>>>> the way panels bypass if the device
>>>> doesn't allow the panel to connect
>>>> properly. Both of these features are a
>>>> recipe for problems and potential
>>>> troubleshooting nightmares. The
>>>> warranty from Tigo doesn't cover our
>>>> expense if the product fails. And
>>>> that's really what our reservations
>>>> about the product boil down to right
>>>> now. If we're on a job with 50 units
>>>> and one fails, the contractor or the
>>>> homeowner will be the ones eating the
>>>> expense of finding it and replacing it.
>>>> There has to be a better option.
>>>>
>>>> Sky Sims
>>>> Https://EcologicalSystems.biz
>>>>
>>>> On Apr 28, 2020, at 7:46 PM, Corey
>>>> Shalanski <coresolar at gmail.com
>>>> <mailto:coresolar at gmail.com>> wrote:
>>>>
>>>> Now that 690.12 of the /NEC/ 2017
>>>> has been in effect for several
>>>> years, I am curious how designers
>>>> and installers are meeting the
>>>> associated requirements with string
>>>> inverter-based systems (*not*
>>>> considering microinverters or DC
>>>> optimizers). I am generally a fan
>>>> of the KISS principle, and as best
>>>> I can determine the /Tigo/ TS4-F
>>>> device is one of the simplest
>>>> options currently available on the
>>>> market. What are others finding?
>>>> I'd love to hear about favored
>>>> options for complying with rapid
>>>> shutdown. Any success stories? or
>>>> better yet, any early failures?
>>>> --
>>>> Corey Shalanski
>>>> Jah Light Solar
>>>> Portland, Jamaica
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