690.31( E ) Marking or Labeling Required

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690.31 ( E ) States the wiring methode shall comply with aditional requirement of 1- 4 of 690.31.
There has been some discussion of weather or not this requirement pertains to the conduit system on the exterrior of a residence from a Solar System Installer.
690.31 ( E ) ( 3 ) (1) States that exposed raceway and other wiring methods , Shall be marked .
The Question arises does this only pertain to the inside of the structure as stated in the main body or does the inclusion of the verbage ( from the point of penetration of the structure to the first readily accessible disconnecting means ) imply that all conduit system from the roof to the first dissconnect reqquire marking?????
I have been asked to present this Question to the forum for review.
I await your response.
 

PEDRO ESCOVILLA

Senior Member
Location
south texas
if you are in the 2011, go to 690.31 (E) (4) iit saysthe marking or labelingshall be visible after installation.PPV circuit labels shall appear on every sectionof the wiring systen that is separated by enclosures, walls, partitions.........spacing shall be not more than 10 feet . when i was introduced to the code, the fella that taught me also siad, "whenever you are looking somthing up, don't be a hurry, always look above and belo here you are reading, you may see it right there. This is not to say don't ask questions, just passing on sage advice that has served me well.
 
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jaggedben

Senior Member
Location
Northern California
Occupation
Solar and Energy Storage Installer
In my reading it pertains to to any raceway before the disconnect, inside or outside. I don't see how it can be read as only pertaining to inside raceways.

The point of the labeling requirement, as I understand it, is to alert firefighters that these circuits are not and cannot be de-energized by cutting power at the service or the solar disconnect. Thus in particular any DC conduit that is possibly not in the same field of view as the solar panels ought to be marked. If the panels are on one side of the roof and the conduit is on the other side, are firefighters necessarily going to see the panels first and put two and two together in the heat of battle?

In my opinion the requirement doesn't or at least shouldn't apply to AC branch circuits feeding micro-inverters, but in my company we label them anyway. I don't think inspectors or firefighters or code-makers have really caught up to that distinction yet.
 
Labeling Reply

Labeling Reply

Thank you for your response.
In the text of the article it is stated that the Systems ar run INSIDE of the building or structure to the first readily accessible disconnect shall comply with article 690.14 (A) (B) (D).
The hang up with the installers and inspections seems to be at the point weather the system is inside or outside.


My point of contention is where the system orignates on the roof then penetrates the roof system then the system would be considered inside the structure.

In a recent edition of Renewable energy and the nec CORNER thay state on page 115 left side paragraph 2.
690.31(E) DC Source and Output Circuits Inside a Building . This where these installer are saying the section only applies to the system run Inside of the structure as in the attic,basement,garage and not on the outside of the structure.

We as inspection are not allowing this and are getting alot of grievance on this matter and I am interested in what the others reading this have to say in this regard.
I whole heartedly agree with the statement on the Fire Fighters regards. The installer state that the system will shut down if power is interupted from the source. This bring me to another call in the Back-fed circuit breakers. 690.10(E) Back fed plugin type cirtcuit breakers shall be secured as per 408.36(D).
I know what the Code states I am interested what the industry feels in this matter.
for the sake of safety for Homeowners, Firefighters and the like it is a good Idea to label all associated conduits and wiring for these systems.
 

ggunn

PE (Electrical), NABCEP certified
Location
Austin, TX, USA
Occupation
Electrical Engineer - Photovoltaic Systems
This bring me to another call in the Back-fed circuit breakers. 690.10(E) Back fed plugin type cirtcuit breakers shall be secured as per 408.36(D).
Utility interactive inverters are exempted. In the NEC2008 the pertinent article is 690.64(B)(6), and in the NEC2011 it was moved to 705.14(D)(6). I think the reasoning is that since under UL1741 the inverter shuts down when it no longer sees the grid, if you pull the breaker with the inverter running, both terminals are unenergized.
 
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jaggedben

Senior Member
Location
Northern California
Occupation
Solar and Energy Storage Installer
Thank you for your response.
In the text of the article it is stated that the Systems ar run INSIDE of the building or structure to the first readily accessible disconnect shall comply with article 690.14 (A) (B) (D).
The hang up with the installers and inspections seems to be at the point weather the system is inside or outside.

Well, now that I look at it again (2011 version) the code does seem to require it only for raceways inside a building. My opinion is revised. But I can't argue that it's a bad practice to put on more safety labels than the code requires.

We as inspection are not allowing this and are getting alot of grievance on this matter and I am interested in what the others reading this have to say in this regard.

A lot of grievance for putting on a few extra stickers? I mean, I would cut installers some slack on labeling conduit where it obviously leads to a solar array, but where it is not obvious ... This would be a case where as an installer I would be happy to comply with a request from an inspector for something a bit above and beyond the code.

The installer state that the system will shut down if power is interrupted from the source.

Well the inverter will shut down, but DC source circuits will still be energized at hundreds of volts and thousands of watt potential. Unless it is an AC micro-inverter system (or perhaps a DC optimizer system with safety controls, but those barely exist at this point), that's a severe problem for firefighters, especially if they don't know which conduit contains the conductors that may have started the fire or may start a new fire if damaged by a fire caused independently.

for the sake of safety for Homeowners, Firefighters and the like it is a good Idea to label all associated conduits and wiring for these systems.

I would generally agree, and add that the labels should specifically distinguish DC photovoltaic source circuits from other (AC) solar conduits and wiring.
 
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Marvin_Hamon

Member
Location
Alameda, CA
Thank you for your response.
In the text of the article it is stated that the Systems ar run INSIDE of the building or structure to the first readily accessible disconnect shall comply with article 690.14 (A) (B) (D).
The hang up with the installers and inspections seems to be at the point weather the system is inside or outside.
My point of contention is where the system orignates on the roof then penetrates the roof system then the system would be considered inside the structure.

I have had some interesting conversations with architects about what constitutes "inside the structure" when it comes to roofs. That aside if you can go in the attic and see the wiring or conduit it is inside the structure and that comes under 690.31(E).


We as inspection are not allowing this and are getting alot of grievance on this matter and I am interested in what the others reading this have to say in this regard.
I whole heartedly agree with the statement on the Fire Fighters regards. The installer state that the system will shut down if power is interupted from the source. This bring me to another call in the Back-fed circuit breakers. 690.10(E) Back fed plugin type cirtcuit breakers shall be secured as per 408.36(D).
I know what the Code states I am interested what the industry feels in this matter.
for the sake of safety for Homeowners, Firefighters and the like it is a good Idea to label all associated conduits and wiring for these systems.

While an AHJ can require more than the code requires you can expect people to not be happy with it, even if safety related, if it goes too far beyond industry standards. Requirements that are far outside industry standards can even get a city or county labeled as anti-solar if it unduly restricts installations in their area. This can bring on some less than flattering publicity. You will probably be happy to hear that the next revision of the IBC will have lots of PV circuit marking requirements, perhaps even more than you are currently asking for.

690.10 only applies to PV systems that operate in a stand-alone mode, this includes off grid systems and battery backed up grid tied systems, therefore 690.10(E) only applies to these systems. Applying this to grid tied systems without battery backup would be incorrect. The reason is that the circuit breaker could be energized from its load side with stand-alone systems, but not with a grid tied system. It is recognized that E is not as clearly written as it could be and changes have been proposed for the 2014 NEC to make it clearer.
 
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