Friends:


One of my favorite things about this list-service:  The minute I think I
have posted something really stupid, someone agrees with me.  What a
self-esteem builder!  Thanks, Bradley!



Here are two conclusions I think I am arriving at with this discussion:



1.   The language in the 2017 NEC is pretty vague on the issue.  Hopefully
this improves over time.

2.   The point is really open to interpretation.  If you can convince your
building department that RSS is not required on a ground mount array, I
think it is entirely safe to omit the RSS.  This is a reasonable case to
make if one goes on the assumption the intent is to protect firefighters on
roofs.

Thanks for the lively discussion.  The points we are all thoughtfully
presented.



William



Miller Solar

17395 Oak Road, Atascadero, CA 93422

805-438-5600

www.millersolar.com

CA Lic. 773985





*From:* Bradley Bassett [mailto:bbasse...@gmail.com]
*Sent:* Tuesday, February 1, 2022 2:15 PM
*To:* RE-wrenches
*Cc:* William Miller
*Subject:* Re: [RE-wrenches] Rapid Shutdown for Off-grid systems



"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 <br...@solarenergy.org> 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 <will...@millersolar.com> 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:re-wrenches-boun...@lists.re-wrenches.org] *On
Behalf Of *Ray
*Sent:* Tuesday, February 1, 2022 10:11 AM
*To:* re-wrenches@lists.re-wrenches.org
*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:jay.pe...@gmail.com]
*Sent:* Tuesday, February 1, 2022 6:07 AM
*To:* will...@millersolar.com; 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 <will...@millersolar.com> 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:jerrysgarag...@gmail.com]
*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 <will...@millersolar.com>
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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