Transformer OCPD

The inverter side of a 480/277V wye to 208V delta interconnection transformer is the secondary.
That is clear under 2023/2026 NEC 705.30(F). But 2020 NEC 690.9(D) sometimes required considering it primary for compliance with 450.3. So when discussing 690.9(D), it is more clear to stick with inverter side and utility side.

Cheers, Wayne
 
2020 NEC 690.9(D) Exception says you don't have to do that if the sum of the ratings of the inverters does not exceed the transformer rating (only reasonable way to read it for multiple inverters). Now 2023/2026 NEC 705.30(F) says you never have to do that. So it's less restrictive.
It was safe to remove this since there are other NEC sections that require conductors and equipment in the backfeed path be sized to the PV system. That would include the transformer. The requirement in the exception in 690.9(D) was more of a reminder. To remind AHJs that the transformer does not require protection from a current limited source as long as the rating is equal to or greater than the source rating. These types of reminders were more common in the code in the past when objections by AJHs less familiar with PV came up more often.
 
The requirement in the exception in 690.9(D) was more of a reminder. To remind AHJs that the transformer does not require protection from a current limited source as long as the rating is equal to or greater than the source rating.
OK, but under the 2023 NEC that has now changed to the transformer never needing protection from the source with the lower fault current, regardless of the transformer rating compared to the source rating. So it seems the historical progression has been "some AHJs are being overly conservative with transfomers and PV" to "690.9(D) is there to inform them when that is necessary" to "actually, it's never necessary per 705.30(F)."

Also, to step back for a minute, more on this notion of "current limited source." Safety-wise, does an inverter really behave at least as well as if it had an OCPD installed on its AC output, with setting equal to its maximum rated continuous current?

If so, then to get to ggunn's question, where 240.21(C) would require a secondary conductor OCPD and permit it to be located at the inverter (e.g. the transformer and inverter are both outside), it does seem that there is no additional hazard from omitting that OCPD, even if 240.21(C) does not have any allowance for its omission. Conversely, where 240.21(C) would require secondary conductor OCPD closer to the transformer than the inverter (e.g. the transformer is indoors and the inverter is more than 25' away), then the inverter's being a current limited source is not relevant for compliance with 240.21(C).

Cheers, Wayne
 
That is clear under 2023/2026 NEC 705.30(F). But 2020 NEC 690.9(D) sometimes required considering it primary for compliance with 450.3. So when discussing 690.9(D), it is more clear to stick with inverter side and utility side.
The convention used by all the AHJs I have dealt with since I designed the first system where I had to step down from 480V to 208V has always been the the side of the transformer connected to the utility is the primary side.
 
Also, to step back for a minute, more on this notion of "current limited source." Safety-wise, does an inverter really behave at least as well as if it had an OCPD installed on its AC output, with setting equal to its maximum rated continuous current?
Yes.
 
To remind AHJs that the transformer does not require protection from a current limited source as long as the rating is equal to or greater than the source rating. These types of reminders were more common in the code in the past when objections by AJHs less familiar with PV came up more often.

Bingo, before this was added we had lots of headaches with AHJs wanting redundant protection, even took it to the state and lost which baffled me. State inspector pretty much went "woops my bad" when it was finally cleared up with that exemption in the next code cycle and they had to renege their decision that was adding ton of extra senseless OCPD devices on the secondary side of the transformer. It also created issues with the transformer winding being specified as primary towards the utility, which still creates issues with inspectors that don't understand this conceptually; however, that has been resolved with the new "PV duty" designation that most transformer manufacturers have now.
 
The convention used by all the AHJs I have dealt with since I designed the first system where I had to step down from 480V to 208V has always been the the side of the transformer connected to the utility is the primary side.
That's great for pre 690.9(D), or post 705.30(F). But for the 2020 NEC and earlier versions with 690.9(D), if the arrangement didn't qualify for the exception, then also considering the inverter side as primary and complying with 450.3 from that point of view was required (for better or worse).

Cheers, Wayne
 
Great. So if we accept that, now to omit OCPD at the inverter when it and the transformer are outside, and 240.21(C)(1) does not apply, you just need to get 240.21(C)(4) changed to permit secondary conductors to terminate on a current limited source, rather than on "a single circuit breaker or a single set of fuses". Since as you say there is no additional hazard. Or maybe it would be better added to 705.30(F).

Cheers, Wayne
 
Great. So if we accept that, now to omit OCPD at the inverter when it and the transformer are outside, and 240.21(C)(1) does not apply, you just need to get 240.21(C)(4) changed to permit secondary conductors to terminate on a current limited source, rather than on "a single circuit breaker or a single set of fuses". Since as you say there is no additional hazard. Or maybe it would be better added to 705.30(F).

Cheers, Wayne
I will continue to use 690.9(D) until it is no longer there or until an AHJ rules against me. I have invoked it several times in more than one jurisdiction and it has never been challenged.
 
I will continue to use 690.9(D) until it is no longer there or until an AHJ rules against me. I have invoked it several times in more than one jurisdiction and it has never been challenged.
690.9(D) does not reference 240.21(C) and in no way provides any relief from its requirements. The topic of 690.9(D) is "overcurrent protection for a transformer" not "overcurrent protection for conductors."

Cheers, Wayne
 
690.9(D) does not reference 240.21(C) and in no way provides any relief from its requirements. The topic of 690.9(D) is "overcurrent protection for a transformer" not "overcurrent protection for conductors."
690.9(D) says "Overcurrent protection for a transformer..." Overcurrent protection for conductors is covered by 690.9(A)(1). I am sorry you do not agree, but I have tested this with several AHJs, and in every case they approved my design.
 
Overcurrent protection for conductors is covered by 690.9(A)(1).
That's a 2020 NEC reference, and these transformer secondary conductors connected to the inverter AC outputs fall under 2020 NEC 690.9(A)(2), which says:

"A circuit conductor connected at one end to a current-limited supply, where the conductor is rated for the maximum circuit current from that supply, and also connected to sources having an available maximum circuit current greater than the ampacity of the conductor, shall be protected from overcurrent at the point of connection to the higher current source.

So OCPD is required for them, and 240.21(C) tells you how to do it.

Cheers, Wayne
 
So, do I have this correct?

  1. For years 240.21(C) has been largely ignored because 690 and 705 distracted from it with references to 450.
  2. It's probably safe, generally, for a current limited inverter to be connected to transformer secondary conductors without OCPD. More precisely, if the secondary conductors followed the rules of 240.21(C) in all respects except that they landed on a single current limited inverter without OCPD instead of on a 'single circuit breaker or set of fuses', we'd all be fine.
  3. Given that 705 now invokes 240.21(C) explicitly, we ought to have an exception in 705.30(F) to those parts of 240.21(C), assuming we accept the previous statement.
 
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