For a ground mount PV system with a DC combiner, the PV source circuits are not 
in or on a building so RS doesn’t apply to them. And the definition of a charge 
controller in Art. 100 is in its relationship to batteries/storage, not really 
the charging source - fundamentally it’s there to protect the 
storage/batteries, so it’s best considered part of that system, not the PV 
system (and over the last several cycles nearly all references to charge 
control/lers have been moved out of 690). 





Brian

> On Feb 1, 2022, at 3:15 PM, Bradley Bassett <[email protected]> wrote:
> 
> 
> "A switch, outside of the building, opening the PV circuit to the power 
> electronics, and functioning as the pv system disco and the rapid shutdown 
> initiation device, should be all that is required."
> 
> That is what I have found most inspectors will accept, but not all. A strict 
> reading of the code does come to the same conclusion that William comes to, 
> and some inspectors will require that. The code is not very specific on where 
> the PV system disconnect should go. It seems to be mostly accepted to be on 
> the PV side of the charge control, but when I read the code strictly it seems 
> to me it should be on the battery side of the charge control since it is only 
> a PV device. Fortunately the PV side is more accepted because that makes 
> things much easier. 
> 
> What I'm still having trouble with is the requirement for breaking both pos 
> and neg legs in the PV system disconnect unless solidly grounded which most 
> systems are not (690.13(E)). I see that most installers do not break both 
> poles, but only the positive leg, which is of course easier and less 
> expensive. I've quoted the use of dual pole breakers when possible, but 
> OutBack does not really call for that always, and if you ask about their 2 
> pole 300V breakers they (and Carling) don't say they can be used that way. 
> And if you do, you have to run the wires in opposite directions for polarity. 
> I've asked for clarification but have not received it yet. Then there are the 
> high voltage charge controls like Schneider, where often one uses the SqD 
> HU361, which can be wired in various ways to meet the 600V requirement. It 
> can be wired one pole for up to 18A Isc for PV, or up to 30A if two poles in 
> series, or one pos and one neg pole in the circuit. The Schneider RS Disco 
> does break both poles, one of the few devices that make it clear. I'm curious 
> what others are doing.
> 
> Brad
> 
>> On Tue, Feb 1, 2022 at 11:23 AM Brian Mehalic <[email protected]> wrote:
>> Sorry, forgot to state my previous comment was in regards to a ground-mount. 
>> 
>> Brian
>> 
>>>> On Feb 1, 2022, at 12:19 PM, William Miller <[email protected]> 
>>>> wrote:
>>>> 
>>> 
>>> Ray:
>>> 
>>>  
>>> 
>>> Thanks for that input.  I was hoping I was wrong.  I looked for that 
>>> discussion in the archives but could not find it.
>>> 
>>>  
>>> 
>>> William
>>> 
>>>  
>>> 
>>> Miller Solar
>>> 
>>> 17395 Oak Road, Atascadero, CA 93422
>>> 
>>> 805-438-5600
>>> 
>>> www.millersolar.com
>>> 
>>> CA Lic. 773985
>>> 
>>>  
>>> 
>>>  
>>> 
>>> From: RE-wrenches [mailto:[email protected]] On 
>>> Behalf Of Ray
>>> Sent: Tuesday, February 1, 2022 10:11 AM
>>> To: [email protected]
>>> Subject: Re: [RE-wrenches] Rapid Shutdown for Off-grid systems
>>> 
>>>  
>>> 
>>>  Ground mounts do NOT require RSS.  We hashed this out years ago on the 
>>> Wrenches list, when NEC 2017 came out.
>>> 
>>> See Figure 690.1(B) Note (2): " The PV system disconnect in these diagrams 
>>> separates the PV system from all other systems".
>>> 
>>> Thus, the PV disconnect is defined as the transition point from the PV 
>>> system to all other systems, like battery or inverter systems. The 
>>> installer/ designer decides where to put that disconnect.  I usually put it 
>>> on the wall before it goes into the building, and I have never had an 
>>> inspector question that.
>>> 
>>> Thanks,
>>> 
>>> Ray Walters
>>> Remote Solar
>>> 303 505-8760
>>> On 2/1/22 10:06 AM, William Miller wrote:
>>> 
>>> Jay:
>>> 
>>>  
>>> 
>>> Here is the text from 2017:
>>> 
>>>  
>>> 
>>> 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).
>>> 
>>>  
>>> 
>>> Exception: Ground mounted PV system circuits that enter buildings, of
>>> 
>>> which the sole purpose is to house PV system equipment, shall not be
>>> 
>>> required to comply with 690.12.
>>> 
>>>  
>>> 
>>> The wording is interesting.  The requirement is directed at “PV system 
>>> circuits…”, not PV arrays.  The passage does not specify where the PV 
>>> feeding those circuits is located, it just addresses where the circuits 
>>> are, specifically “in or on a building.”
>>> 
>>>  
>>> 
>>> The only circuits that are exempt are those feeding a building that serves 
>>> only one purpose, to house PV equipment.  For circuits that enter building 
>>> with other uses—homes, garages, barns, workshops, etc.-- it would seem 
>>> there is a requirement to have rapid shutdown systems (RSS).
>>> 
>>>  
>>> 
>>> Reading through the rest of the section, I don’t see any language that gets 
>>> us out of the requirement to reduce voltages to less than 80 volts within 
>>> 30 seconds inside the array boundary, as in module level shutdown, 
>>> regardless of roof-top or ground-mount.  Although the 2020 code includes 
>>> some differing language, I don’t see it as exempting ground mount systems.
>>> 
>>>  
>>> 
>>> The moral of the story is this:  For ground-mounts:  either install RSS or 
>>> put your equipment (inverters, charge controllers, batteries, BOS) in a 
>>> separate building housing only that equipment.
>>> 
>>>  
>>> 
>>> I don’t necessarily like the requirement, but I think it exists.  Jay, or 
>>> anyone, please, please tell me I am reading this incorrectly. 
>>> 
>>>  
>>> 
>>> By the way, regarding battery circuits, here is a quote from a post by Bill 
>>> Brooks on March 16, 2016:
>>> 
>>>  
>>> 
>>> In the 2017 NEC, we were very careful to carve out all batteries and loads,
>>> 
>>> that were previously part of PV systems, and place them in their own
>>> 
>>> articles.
>>> 
>>>  
>>> 
>>> I have not read through the battery sections of the code to verify this, I 
>>> am taking Bill at his word.
>>> 
>>>  
>>> 
>>> William Miller
>>> 
>>>  
>>> 
>>> Miller Solar
>>> 
>>> 17395 Oak Road, Atascadero, CA 93422
>>> 
>>> 805-438-5600
>>> 
>>> www.millersolar.com
>>> 
>>> CA Lic. 773985
>>> 
>>>  
>>> 
>>>  
>>> 
>>> From: Jay [mailto:[email protected]] 
>>> Sent: Tuesday, February 1, 2022 6:07 AM
>>> To: [email protected]; RE-wrenches
>>> Subject: Re: [RE-wrenches] Rapid Shutdown for Off-grid systems
>>> 
>>>  
>>> 
>>> 2017 code has a specific exception/clarification for ground mount solar 
>>> that it does not need RS. 
>>> 
>>> It’s in the first line after 690.12
>>> 
>>>  
>>> 
>>> Jay
>>> 
>>>  
>>> 
>>> On Feb 1, 2022, at 12:13 AM, William Miller <[email protected]> wrote:
>>> 
>>> 
>>> 
>>> Jerry:
>>> 
>>>  
>>> 
>>> Yes it is required.  Rapid Shutdown:  NEC 690.12.  All buildings except 
>>> dedicated solar buildings.  Read it and weep.
>>> 
>>>  
>>> 
>>> William
>>> 
>>>  
>>> 
>>> Miller Solar
>>> 
>>> 17395 Oak Road, Atascadero, CA 93422
>>> 
>>> 805-438-5600
>>> 
>>> www.millersolar.com
>>> 
>>> CA Lic. 773985
>>> 
>>>  
>>> 
>>>  
>>> 
>>> From: Jerry Shafer [mailto:[email protected]] 
>>> Sent: Monday, January 31, 2022 7:21 PM
>>> To: William Miller; RE-wrenches
>>> Subject: Re: [RE-wrenches] Rapid Shutdown for Off-grid systems
>>> 
>>>  
>>> 
>>> William
>>> 
>>> Are you sure RSD is required on a non habitable building, historically its 
>>> not required. Now that being said we use fire raptor with the best results, 
>>> yes it takes an extra conduite and might require a button and power supply 
>>> depending on inverter application.
>>> 
>>> Jerry
>>> 
>>>  
>>> 
>>> On Mon, Jan 31, 2022, 9:57 AM William Miller <[email protected]> 
>>> wrote:
>>> 
>>> Friends:
>>> 
>>>  
>>> 
>>> It is quite rare for us to install off-grid systems on roof-tops.  We have 
>>> one coming up with about 20kW on a large barn roof.  This will be our first 
>>> off-grid with a module-level rapid shutdown requirement.  I see no 
>>> exemptions from RSS for off-grid systems in the code.  I have looked at the 
>>> options and this is what I have found:
>>> 
>>>  
>>> 
>>> 1.   Fire Raptor
>>> 
>>> 2.   Tigo TS4-F
>>> 
>>> 3.   AC coupling with micro-inverters or optimizers
>>> 
>>>  
>>> 
>>> No one of these approaches seems ideal.  The fire raptor requires extra 
>>> wiring for control leads.  The Tigo requires a wireless control system 
>>> which worries me about reliability.  With AC Coupling systems floating the 
>>> proposed AGM batteries may be awkward.  Furthermore, with AC coupled 
>>> systems one cannot charge batteries unless the mini-grid is operational, a 
>>> big problem.
>>> 
>>>  
>>> 
>>> Have any of you implemented module-level RSS on a battery-based inverter 
>>> system?  I looked in the archives and found no threads that apply.  Thank 
>>> in advance.
>>> 
>>>  
>>> 
>>> William Miller
>>> 
>>>  
>>> 
>>>  
>>> 
>>>  
>>> 
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