Re: [RE-wrenches] Location of DC disconnect vis-a-vis rapid shutdown exemption

[Rebekah Hren]

Hi Ray,
The stand-alone diagram calls out the PV system disconnect right after the
PV system DC circuits and prior to the point of common coupling with the
batteries and the stand-alone inverter. Yes, you are correct a controller
or DC to DC converter is not shown in the this diagram or the dc-coupled
diagram.

The reason the charge controller is not called out in the diagram is
because it can be on either side of the PV system disconnect, depending on
the topology of the system. For example, a controller connected to a DC bus
with multiple power sources that would still be operational if the PV
system is disconnected would be outside the PV system disconnect
demarcation. If the controller serves no purpose when the PV system is
disconnected, then it makes sense to have the charge controller output
circuit be the location of the PV system disconnect.

One way to think about this is what happens when you open (turn off) the PV
system disconnect. So for example a multimode inverter doesn't care if the
PV system disco is open, it will just keep on doing its job, pulling power
from the batteries and providing power to the loads. If the charge
controller can't keep doing its job with no PV power source, then it really
belongs to the PV system.  Maybe this seems silly, but as particularly
energy storage systems and microgrids get more complicated, it doesn't
always make sense to have hard and fast rules about what equipment belongs
to which system.

I realize this makes rapid shutdown more confusing. But for a DC-coupled
stand-alone system it seems the major question here is whether the RS
shutdown switch (or switches) control the circuits before or after the
charge controller. For most typical small systems, I would say probably
after the controller, but I think this is open to some debate.

The rules for locating a DC PV system disconnect are found in 690.13 - it
really just has to be readily accessible. It may or may not also serve the
purpose of the rapid shutdown initiation switch, that's up to you as the
system designer.

Best,
Rebekah



On Wed, Apr 18, 2018 at 12:56 AM, Ray  wrote:

> Hi Rebekah;
>
> Thanks for pointing out the changes to the diagrams.  I especially
> appreciate Note (2). *The PV system disconnect in these diagrams
> separates the PV system from all other systems.*
> That seems simple enough for defining the boundaries of RSS, until you
> think about off grid, and look at the last diagram of 690.1(b) titled
> "Stand Alone System".  The charge controller is not shown at all.  Then
> Figure 690.1(a) shows a *DC to DC Converter (optional location)*, shows a
> fuse after, shows the power going with an arrow to no where, on a line
> labeled *PV or DC to DC converter output circuit.* But finally, the
> cause of my greatest confusion: it does not show the *PV System
> Disconnect* anywhere.
>
> I have several questions:
> Is a charge controller a *DC to DC converter*?  What about non MPPT
> controllers that don't convert voltage?
> Is a charge controller considered *DC* *utilization Equipment* mentioned
> in the definition of *PV Output Circuit*, or is the inverter and DC loads
> the utilization equipment?
> All of which leads to the $20 thousand dollar question: Is the *PV System
> Disconnect* before or after the charge controller?
> If before the charge controller, where can the PV Disconnect be?  Could it
> be outside, at the pole, or does it need to be within 3 ft of the building
> entry?
>
> Even with all the changes made in 2017, it seems that we still are left
> with too much uncertainty about where a PV circuit ends, or what
> constitutes the "PV Disconnect" in an off grid system.  Not such a big
> deal, until we are required to apply 690.12.
>
> Thanks everyone for your answers and opinions,
>
> Ray Walters
> Design Engineer
> Remote Solar
>
>
> On 4/17/18 7:15 AM, Rebekah Hren wrote:
>
> Hi everyone,
>
> I strongly recommend looking at the figures that were added in NEC 2017 at
> the beginning of Article 690 in 690.1(b).
>
> What they show is equipment that is part of the PV system (to the left of
> the PV system disconnect called out in the diagrams), and equipment that is
> not part of the PV system (to the right of the PV system disconnect). These
> are really helpful diagrams, in terms of figuring out where the
> requirements of Article 690 apply.
>
> Equipment *not* part of the PV system is not a "PV system circuit" and
> thus is *not* subject to rapid shutdown requirements per 690.12.
>
> In every type of system you will see that energy storage is *not *part of
> the PV system, and neither is the multimode inverter for a system with
> energy storage. So rapid shutdown requirements shouldn't affect any of the
> loads, multimode inverter, or batteries in an off-grid system.
>
> In the 2017 NEC, the PV system disconnect, as shown on the diagrams, is
> required to be readily accessible per 690.13(A). For a system without
> batteries, the PV system disconnect 

Re: [RE-wrenches] Location of DC disconnect vis-a-vis rapid shutdown exemption

[Ray]

Hi Rebekah;

Thanks for pointing out the changes to the diagrams.  I especially 
appreciate Note (2). /The PV system disconnect in these diagrams 
separates the PV system from all other systems./


That seems simple enough for defining the boundaries of RSS, until you 
think about off grid, and look at the last diagram of 690.1(b) titled 
"Stand Alone System".  The charge controller is not shown at all.  Then 
Figure 690.1(a) shows a /DC to DC Converter (optional location)/, shows 
a fuse after, shows the power going with an arrow to no where, on a line 
labeled /PV or DC to DC converter output circuit./ But finally, the 
cause of my greatest confusion: it does not show the *PV System 
Disconnect* anywhere.


I have several questions:
Is a charge controller a *DC to DC converter*?  What about non MPPT 
controllers that don't convert voltage?
Is a charge controller considered *DC* *utilization Equipment* mentioned 
in the definition of *PV Output Circuit*, or is the inverter and DC 
loads the utilization equipment?
All of which leads to the $20 thousand dollar question: Is the *PV 
System Disconnect* before or after the charge controller?
If before the charge controller, where can the PV Disconnect be? Could 
it be outside, at the pole, or does it need to be within 3 ft of the 
building entry?


Even with all the changes made in 2017, it seems that we still are left 
with too much uncertainty about where a PV circuit ends, or what 
constitutes the "PV Disconnect" in an off grid system.  Not such a big 
deal, until we are required to apply 690.12.


Thanks everyone for your answers and opinions,

Ray Walters
Design Engineer
Remote Solar

On 4/17/18 7:15 AM, Rebekah Hren wrote:

Hi everyone,

I strongly recommend looking at the figures that were added in NEC 
2017 at the beginning of Article 690 in 690.1(b).


What they show is equipment that is part of the PV system (to the left 
of the PV system disconnect called out in the diagrams), and equipment 
that is not part of the PV system (to the right of the PV system 
disconnect). These are really helpful diagrams, in terms of figuring 
out where the requirements of Article 690 apply.


Equipment *not* part of the PV system is not a "PV system circuit" and 
thus is *not* subject to rapid shutdown requirements per 690.12.


In every type of system you will see that energy storage is *not *part 
of the PV system, and neither is the multimode inverter for a system 
with energy storage. So rapid shutdown requirements shouldn't affect 
any of the loads, multimode inverter, or batteries in an off-grid system.


In the 2017 NEC, the PV system disconnect, as shown on the diagrams, 
is required to be readily accessible per 690.13(A). For a system 
without batteries, the PV system disconnect is *always *an AC 
disconnect, not a DC disconnect. It can be the backfed breaker per 
690.13(F)(1). For a system with batteries the PV system disconnect is 
always before the batteries.



Equipment disconnects, like the DC inverter disconnect, are not 
required to be readily accessible, but must be within 10 feet of the 
equipment, per 690.15(A).


Also note that the boundary for rapid shutdown shrank to *one foot* 
from the perimeter of the array in the 2017 NEC, so the inverter must 
be positioned within one foot of the array if there is not going to be 
any other RS equipment. The PV system disconnect (backfed breaker) or 
the service disconnect can serve as the rapid shutdown initiation 
device in that case.


Best,
Rebekah Hren, Member of NEC CMP-4 for Solar Energy International

--
Tel: 336.266.8800
NABCEP Certified Solar PV Installation Professional™ 091209-85
NC Licensed Electrical Contractor


On Mon, Apr 16, 2018 at 9:00 PM, Ray > wrote:


For GT using Solar edge or Enphase, its not so hard to comply, but
If you are looking at off grid systems, it's not just someone's
opinion, its $1,000s of dollars extra to comply with 690.12. It
also results in a system that is less reliable, which is less safe
off grid where lives depend on that power for heat, light,
refrigeration, and even breathing machines.

Ray Walters

Remote Solar


On 4/16/18 7:44 AM, Brian Mehalic wrote:

Hey y'all, I'm going to disagree about the NEC getting "worse and
worse when it comes to PV," (see disconnect and grounding
requirements, for instance!), but as with previous posters,
that's just an opinion.

Regarding location - the 2014 version had very little to say
about the location of any rapid shutdown initiation device; 2017
adds the requirement [690.12(C)] that RS initiation devices for
one- and two-family dwellings be readily accessible (defined in
Article 100), AND outside the building. Seems reasonable for a
device that is intended to control energized conductors to make
it more safe to enter a building.

Cheers,


Brian Mehalic
NABCEP Certified Solar PV 

Re: [RE-wrenches] Location of DC disconnect vis-a-vis rapid shutdown exemption

[Rebekah Hren]

Hi everyone,

I strongly recommend looking at the figures that were added in NEC 2017 at
the beginning of Article 690 in 690.1(b).

What they show is equipment that is part of the PV system (to the left of
the PV system disconnect called out in the diagrams), and equipment that is
not part of the PV system (to the right of the PV system disconnect). These
are really helpful diagrams, in terms of figuring out where the
requirements of Article 690 apply.

Equipment *not* part of the PV system is not a "PV system circuit" and thus
is *not* subject to rapid shutdown requirements per 690.12.

In every type of system you will see that energy storage is *not *part of
the PV system, and neither is the multimode inverter for a system with
energy storage. So rapid shutdown requirements shouldn't affect any of the
loads, multimode inverter, or batteries in an off-grid system.

In the 2017 NEC, the PV system disconnect, as shown on the diagrams, is
required to be readily accessible per 690.13(A). For a system without
batteries, the PV system disconnect is *always *an AC disconnect, not a DC
disconnect. It can be the backfed breaker per 690.13(F)(1). For a system
with batteries the PV system disconnect is always before the batteries.


Equipment disconnects, like the DC inverter disconnect, are not required to
be readily accessible, but must be within 10 feet of the equipment, per
690.15(A).

Also note that the boundary for rapid shutdown shrank to *one foot* from
the perimeter of the array in the 2017 NEC, so the inverter must be
positioned within one foot of the array if there is not going to be any
other RS equipment. The PV system disconnect (backfed breaker) or the
service disconnect can serve as the rapid shutdown initiation device in
that case.

Best,
Rebekah Hren, Member of NEC CMP-4 for Solar Energy International

-- 
Tel: 336.266.8800
NABCEP Certified Solar PV Installation Professional™ 091209-85
NC Licensed Electrical Contractor


On Mon, Apr 16, 2018 at 9:00 PM, Ray  wrote:

> For GT using Solar edge or Enphase, its not so hard to comply, but If you
> are looking at off grid systems, it's not just someone's opinion, its
> $1,000s of dollars extra to comply with 690.12. It also results in a system
> that is less reliable, which is less safe off grid where lives depend on
> that power for heat, light, refrigeration, and even breathing machines.
>
> Ray Walters
>
> Remote Solar
>
> On 4/16/18 7:44 AM, Brian Mehalic wrote:
>
> Hey y'all, I'm going to disagree about the NEC getting "worse and worse
> when it comes to PV," (see disconnect and grounding requirements, for
> instance!), but as with previous posters, that's just an opinion.
>
> Regarding location - the 2014 version had very little to say about the
> location of any rapid shutdown initiation device; 2017 adds the requirement
> [690.12(C)] that RS initiation devices for one- and two-family dwellings be
> readily accessible (defined in Article 100), AND outside the building.
> Seems reasonable for a device that is intended to control energized
> conductors to make it more safe to enter a building.
>
> Cheers,
>
>
> Brian Mehalic
> NABCEP Certified Solar PV Installation Professional™ R031508-59
> 520.204.6639
>
> Solar Energy International
> http://www.solarenergy.org
>
> SEI Professional Services
> http://www.seisolarpros.com
>
>
> On Mon, Apr 16, 2018 at 12:04 AM, Mark Frye 
> wrote:
>
>> Thanks Darryl.
>>
>> I guess I can add that I am in CA and so looked only at the 2014. I also
>> looked at the 2017 article. Man, I have to say, my impression remains that
>> really starting with 2008 the code has just gotten worse and worse when it
>> comes to PV, but that is just me.
>>
>> Not really sure what might need to be "Outside readily accessible". Is
>> there something other than 690.12 that I need to look at?
>>
>> Mark
>> On 4/15/2018 8:26 PM, Darryl Thayer wrote:
>>
>> I think the code says Outside readily accessible,
>>
>> On Sun, Apr 15, 2018 at 12:22 PM, Mark Frye 
>> wrote:
>>
>>> Folks,
>>>
>>> As I recall, an inverter and it's integrated DC disconnect need only be
>>> placed in an accessible location. I am thinking of putting an inverter high
>>> up on the wall inside a garage. That would be OK vis-a-vis the location of
>>> the disconnect (still accessible for maintenance).
>>>
>>> If I do put the inverter high up on the wall, I can limit my DC
>>> conductors to less that 10 feet total from the array and less that 5 feet
>>> inside the garage.
>>>
>>> That means I get the exemption from the rapid disconnect requirement,
>>> right?
>>>
>>> There is nothing in the Code linking the accessibility of the DC
>>> disconnect to the exemption from rapid shutdown, right?
>>>
>>> Mark Frye
>>>
>>>
>>> ___
>>> List sponsored by Redwood Alliance
>>>
>>> List Address: RE-wrenches@lists.re-wrenches.org
>>>
>>> Change listserver email address & 

Re: [RE-wrenches] Location of DC disconnect vis-a-vis rapid shutdown exemption

[Ray]

For GT using Solar edge or Enphase, its not so hard to comply, but If 
you are looking at off grid systems, it's not just someone's opinion, 
its $1,000s of dollars extra to comply with 690.12. It also results in a 
system that is less reliable, which is less safe off grid where lives 
depend on that power for heat, light, refrigeration, and even breathing 
machines.


Ray Walters

Remote Solar


On 4/16/18 7:44 AM, Brian Mehalic wrote:
Hey y'all, I'm going to disagree about the NEC getting "worse and 
worse when it comes to PV," (see disconnect and grounding 
requirements, for instance!), but as with previous posters, that's 
just an opinion.


Regarding location - the 2014 version had very little to say about the 
location of any rapid shutdown initiation device; 2017 adds the 
requirement [690.12(C)] that RS initiation devices for one- and 
two-family dwellings be readily accessible (defined in Article 100), 
AND outside the building.  Seems reasonable for a device that is 
intended to control energized conductors to make it more safe to enter 
a building.


Cheers,


Brian Mehalic
NABCEP Certified Solar PV Installation Professional™ R031508-59
520.204.6639

Solar Energy International
http://www.solarenergy.org

SEI Professional Services
http://www.seisolarpros.com 


On Mon, Apr 16, 2018 at 12:04 AM, Mark Frye > wrote:


Thanks Darryl.

I guess I can add that I am in CA and so looked only at the 2014.
I also looked at the 2017 article. Man, I have to say, my
impression remains that really starting with 2008 the code has
just gotten worse and worse when it comes to PV, but that is just me.

Not really sure what might need to be "Outside readily
accessible". Is there something other than 690.12 that I need to
look at?

Mark

On 4/15/2018 8:26 PM, Darryl Thayer wrote:

I think the code says Outside readily accessible,

On Sun, Apr 15, 2018 at 12:22 PM, Mark Frye
> wrote:

Folks,

As I recall, an inverter and it's integrated DC disconnect
need only be placed in an accessible location. I am thinking
of putting an inverter high up on the wall inside a garage.
That would be OK vis-a-vis the location of the disconnect
(still accessible for maintenance).

If I do put the inverter high up on the wall, I can limit my
DC conductors to less that 10 feet total from the array and
less that 5 feet inside the garage.

That means I get the exemption from the rapid disconnect
requirement, right?

There is nothing in the Code linking the accessibility of the
DC disconnect to the exemption from rapid shutdown, right?

Mark Frye


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Re: [RE-wrenches] Location of DC disconnect vis-a-vis rapid shutdown exemption

[Glenn Burt]

Mark,

 

Darryl might be alluding to the 690.13A requirements for a DC disconnect – 
typically located outside the structure before conductors enter the building, 
and readily accessible.

 

-Glenn

 

From: RE-wrenches <re-wrenches-boun...@lists.re-wrenches.org> On Behalf Of Mark 
Frye
Sent: Monday, April 16, 2018 12:04 AM
To: re-wrenches@lists.re-wrenches.org
Subject: Re: [RE-wrenches] Location of DC disconnect vis-a-vis rapid shutdown 
exemption

 

Thanks Darryl.

I guess I can add that I am in CA and so looked only at the 2014. I also looked 
at the 2017 article. Man, I have to say, my impression remains that really 
starting with 2008 the code has just gotten worse and worse when it comes to 
PV, but that is just me.

Not really sure what might need to be "Outside readily accessible". Is there 
something other than 690.12 that I need to look at?

Mark

On 4/15/2018 8:26 PM, Darryl Thayer wrote:

I think the code says Outside readily accessible, 

 

On Sun, Apr 15, 2018 at 12:22 PM, Mark Frye <ma...@berkeleysolar.com 
<mailto:ma...@berkeleysolar.com> > wrote:

Folks,

As I recall, an inverter and it's integrated DC disconnect need only be placed 
in an accessible location. I am thinking of putting an inverter high up on the 
wall inside a garage. That would be OK vis-a-vis the location of the disconnect 
(still accessible for maintenance).

If I do put the inverter high up on the wall, I can limit my DC conductors to 
less that 10 feet total from the array and less that 5 feet inside the garage.

That means I get the exemption from the rapid disconnect requirement, right?

There is nothing in the Code linking the accessibility of the DC disconnect to 
the exemption from rapid shutdown, right?

Mark Frye


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Re: [RE-wrenches] Location of DC disconnect vis-a-vis rapid shutdown exemption

[Brian Mehalic]

Hey y'all, I'm going to disagree about the NEC getting "worse and worse
when it comes to PV," (see disconnect and grounding requirements, for
instance!), but as with previous posters, that's just an opinion.

Regarding location - the 2014 version had very little to say about the
location of any rapid shutdown initiation device; 2017 adds the requirement
[690.12(C)] that RS initiation devices for one- and two-family dwellings be
readily accessible (defined in Article 100), AND outside the building.
Seems reasonable for a device that is intended to control energized
conductors to make it more safe to enter a building.

Cheers,


Brian Mehalic
NABCEP Certified Solar PV Installation Professional™ R031508-59
520.204.6639

Solar Energy International
http://www.solarenergy.org

SEI Professional Services
http://www.seisolarpros.com


On Mon, Apr 16, 2018 at 12:04 AM, Mark Frye  wrote:

> Thanks Darryl.
>
> I guess I can add that I am in CA and so looked only at the 2014. I also
> looked at the 2017 article. Man, I have to say, my impression remains that
> really starting with 2008 the code has just gotten worse and worse when it
> comes to PV, but that is just me.
>
> Not really sure what might need to be "Outside readily accessible". Is
> there something other than 690.12 that I need to look at?
>
> Mark
> On 4/15/2018 8:26 PM, Darryl Thayer wrote:
>
> I think the code says Outside readily accessible,
>
> On Sun, Apr 15, 2018 at 12:22 PM, Mark Frye 
> wrote:
>
>> Folks,
>>
>> As I recall, an inverter and it's integrated DC disconnect need only be
>> placed in an accessible location. I am thinking of putting an inverter high
>> up on the wall inside a garage. That would be OK vis-a-vis the location of
>> the disconnect (still accessible for maintenance).
>>
>> If I do put the inverter high up on the wall, I can limit my DC
>> conductors to less that 10 feet total from the array and less that 5 feet
>> inside the garage.
>>
>> That means I get the exemption from the rapid disconnect requirement,
>> right?
>>
>> There is nothing in the Code linking the accessibility of the DC
>> disconnect to the exemption from rapid shutdown, right?
>>
>> Mark Frye
>>
>>
>> ___
>> List sponsored by Redwood Alliance
>>
>> List Address: RE-wrenches@lists.re-wrenches.org
>>
>> Change listserver email address & settings:
>> http://lists.re-wrenches.org/options.cgi/re-wrenches-re-wrenches.org
>>
>> List-Archive: http://www.mail-archive.com/re
>> -wrenc...@lists.re-wrenches.org/maillist.html
>>
>> List rules & etiquette:
>> www.re-wrenches.org/etiquette.htm
>>
>> Check out or update participant bios:
>> www.members.re-wrenches.org
>>
>>
>
>
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Re: [RE-wrenches] Location of DC disconnect vis-a-vis rapid shutdown exemption

[Mark Frye]

Thanks Darryl.

I guess I can add that I am in CA and so looked only at the 2014. I also 
looked at the 2017 article. Man, I have to say, my impression remains 
that really starting with 2008 the code has just gotten worse and worse 
when it comes to PV, but that is just me.


Not really sure what might need to be "Outside readily accessible". Is 
there something other than 690.12 that I need to look at?


Mark

On 4/15/2018 8:26 PM, Darryl Thayer wrote:

I think the code says Outside readily accessible,

On Sun, Apr 15, 2018 at 12:22 PM, Mark Frye > wrote:


Folks,

As I recall, an inverter and it's integrated DC disconnect need
only be placed in an accessible location. I am thinking of putting
an inverter high up on the wall inside a garage. That would be OK
vis-a-vis the location of the disconnect (still accessible for
maintenance).

If I do put the inverter high up on the wall, I can limit my DC
conductors to less that 10 feet total from the array and less that
5 feet inside the garage.

That means I get the exemption from the rapid disconnect
requirement, right?

There is nothing in the Code linking the accessibility of the DC
disconnect to the exemption from rapid shutdown, right?

Mark Frye


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Re: [RE-wrenches] Location of DC disconnect vis-a-vis rapid shutdown exemption

[Darryl Thayer]

I think the code says Outside readily accessible,

On Sun, Apr 15, 2018 at 12:22 PM, Mark Frye  wrote:

> Folks,
>
> As I recall, an inverter and it's integrated DC disconnect need only be
> placed in an accessible location. I am thinking of putting an inverter high
> up on the wall inside a garage. That would be OK vis-a-vis the location of
> the disconnect (still accessible for maintenance).
>
> If I do put the inverter high up on the wall, I can limit my DC conductors
> to less that 10 feet total from the array and less that 5 feet inside the
> garage.
>
> That means I get the exemption from the rapid disconnect requirement,
> right?
>
> There is nothing in the Code linking the accessibility of the DC
> disconnect to the exemption from rapid shutdown, right?
>
> Mark Frye
>
>
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[RE-wrenches] Location of DC disconnect vis-a-vis rapid shutdown exemption

[Mark Frye]

Folks,

As I recall, an inverter and it's integrated DC disconnect need only be 
placed in an accessible location. I am thinking of putting an inverter 
high up on the wall inside a garage. That would be OK vis-a-vis the 
location of the disconnect (still accessible for maintenance).


If I do put the inverter high up on the wall, I can limit my DC 
conductors to less that 10 feet total from the array and less that 5 
feet inside the garage.


That means I get the exemption from the rapid disconnect requirement, right?

There is nothing in the Code linking the accessibility of the DC 
disconnect to the exemption from rapid shutdown, right?


Mark Frye


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