Comment #1Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: Page 1Paragraph / Figure / Table / Note: 806 GAS LEAKAGE TESTComment Type: EditorialComment: As an employee of a natural gas utility and an energy rater, I feel the standard is over kill. Natural gas has an odorant added, mercapton, that smells. Natural gas employees do not go to the lengths of the resnet proposed standard. Leak detection is used when there is a leak complaint. Even minor gas leaks in the house can be detected by smell. To ask a rater to soap every fitting is a standard that is not feasible. What about fittings in concealed walls, attic space or crawl spaces? This should only be a requirement if a customer has a suspicion of a gas leak. Then, it should follow utility company protocol. This is beyond the scope of the raters training and responsibility. Let's have a standard that is more appropriate. Let utilities do their job and allow raters to do theirs. I suggest if their is any indication of a gas leak, vacate the premises and notify the proper utility authorities.
As an employee of a natural gas utility and an energy rater, I feel the standard is over kill. Natural gas has an odorant added, mercapton, that smells. Natural gas employees do not go to the lengths of the resnet proposed standard. Leak detection is used when there is a leak complaint. Even minor gas leaks in the house can be detected by smell. To ask a rater to soap every fitting is a standard that is not feasible. What about fittings in concealed walls, attic space or crawl spaces? This should only be a requirement if a customer has a suspicion of a gas leak. Then, it should follow utility company protocol. This is beyond the scope of the raters training and responsibility. Let's have a standard that is more appropriate. Let utilities do their job and allow raters to do theirs. I suggest if their is any indication of a gas leak, vacate the premises and notify the proper utility authorities.
Comment #2Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 3Paragraph / Figure / Table / Note: 807.7.1Comment Type: TechnicalComment: 807.7.1 states As an alternative to the auxiliary exhaust flows specified in 807.6 the target CAZ pressure in 807.10 may be adjusted as follows: there is no target pressure specified in 807.10...do you mean 807.2 and 807.3? Proposed Change: Clarify where and what the "target pressures" are
807.7.1 states As an alternative to the auxiliary exhaust flows specified in 807.6 the target CAZ pressure in 807.10 may be adjusted as follows:
there is no target pressure specified in 807.10...do you mean 807.2 and 807.3?
Clarify where and what the "target pressures" are
Comment #3Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 3Paragraph / Figure / Table / Note: 807.7Comment Type: TechnicalComment: Are 807.7.2 and .3 alternatives to 807.7? Also more clarification on what this table means would be helpful...I'm not sure what is required. for instance, in the use of table 807.2 are you saying that a house that tests 500 cfm50 blower door must adjust the house pressure to 23 pa for the CAZ testing purposes? Then to add to the confusion, the gray shaded areas say the house fails and stop testing. What about natural conditions? Does this mean that a house with 1000cfm 50 fails the test? If so then does this imply that a house with an open hearth fireplace cannot be tighter than 1000cfm50? Also shouldn't the pa be more specifially negative "-" pa 807.14.2—refers to “89713.3”…I think this means 807.13.3?? 808.7.1-- consider making exemption for when vents terminate at the roof. Having employees on the roof kills our insurance rates, therefore we have a company policy to never go on the roof. Proposed Change: Provide clarifiacion and editing to address the comments above.
Are 807.7.2 and .3 alternatives to 807.7?
Also more clarification on what this table means would be helpful...I'm not sure what is required. for instance, in the use of table 807.2 are you saying that a house that tests 500 cfm50 blower door must adjust the house pressure to 23 pa for the CAZ testing purposes?
Then to add to the confusion, the gray shaded areas say the house fails and stop testing. What about natural conditions? Does this mean that a house with 1000cfm 50 fails the test? If so then does this imply that a house with an open hearth fireplace cannot be tighter than 1000cfm50?
Also shouldn't the pa be more specifially negative "-" pa
807.14.2—refers to “89713.3”…I think this means 807.13.3??
808.7.1-- consider making exemption for when vents terminate at the roof. Having employees on the roof kills our insurance rates, therefore we have a company policy to never go on the roof.
Provide clarifiacion and editing to address the comments above.
Comment #4Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 1Comment Type: GeneralComment: The Building Performance Institute, Inc (BPI) is currently developing a candidate American National Standard (ANS) under the ANSI process that includes gas leakage testing protocols and assessment. As a recently ANSI accredited Standards Development Organization RESNET should work to support the effort by BPI and harmonize these proposed revisions to that candidtae ANS. The proposed revisions when republished will mostly conflict or be incompatible with other standards including the candidate ANS that BPI is developing regarding this topic.
The Building Performance Institute, Inc (BPI) is currently developing a candidate American National Standard (ANS) under the ANSI process that includes gas leakage testing protocols and assessment. As a recently ANSI accredited Standards Development Organization RESNET should work to support the effort by BPI and harmonize these proposed revisions to that candidtae ANS. The proposed revisions when republished will mostly conflict or be incompatible with other standards including the candidate ANS that BPI is developing regarding this topic.
Comment #5Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 2,3,5,6Paragraph / Figure / Table / Note: 807.3.1, 807.3.3, 807.4, 807.5, 807.8, 807.9, 807.10, 807.14Comment Type: TechnicalComment: 807.3.1 Not sure how you are going to get a rater / inspector to take apart a vent system for inspection of blockage – or go up on the roof to inspect from the top side. Is this beyond reasonable expectation for a rater? Not being part of the discussion on it being here I suggest removal of the blockage wording. 807.3.3 There is no way a rater / auditor / inspector is going to know for sure if the heat exchanger has a hole in it. Is this beyond reasonable expectation for a rater? Maybe specify the area of inspection. 807.4 Move FAS operation up from 807.8 because we need to have it off to measure baseline anyway and it was sending the wrong message in the other location. 807.5 Should be re-worded for clarity 807.8 Move the FAS wording up to a new 807.4.1 – want to have it off for Baseline pressure measurement and also don’t want to imply here that the doors do not need to be closed unless there is a FAS. Just tell them to close the doors at this point. 807.9 First two sentences: • Too many steps and pressure measurements – a home with two baths and a utility room would require 6 pressure measurements and much walking • Also, why? It seems as if the only reason this task makes any sense is if there is a shared wall from a room with an exhaust fan to the CAZ and it was leaky and was affecting the CAZ. • If this is what these first two sentences are trying to address: o Lots of work in the majority of the homes where it doesn’t matter trying to catch the rare house where it may be a problem o Not logical in format as the following “alternative” eliminates catching that scenario Sentences 3 and 4: • The room with the fan will always be negative if the CAZ is affected with the room door closed and if this alternative was followed, the door would then be opened – negating the reason/effect of the 1st two sentences of this section. First half of sentence 5 - "Repeat this procedure for all interior doors..." • Why do this procedure for any of the interior doors? o The set up already has interior doors closed except those with fans o The FAS is not operating o The doors to rooms with exhaust fans are almost always going to end up being left open (the exception would be the rare shared wall scenario) o If any of the other rooms were leaky enough to be trying to provide make-up air for an exhaust fan, it will be under a positive pressure when tested with smoke and the door will stay closed o If there is little or no indication of direction of smoke flow we would still want the door closed to reduce the house volume for the exhaust fans o The default position for all the doors to rooms with no fans should be closed o Seems to be a waste of time and travel Last of sentence 5 - "...and the CAZ door." • The CAZ door is the exception. • Because you could have an exhaust fan either in the CAZ or affecting the CAZ, you could either: o Measure the CAZ pressure with the CAZ door both open and closed o Smoke/pressure test the CAZ door to determine its position and then measure the CAZ pressure o One measurement versus two. Do you want to address "shared surfaces" and if so, how? It’s a fine line between what “covers most houses most of the time” versus trying to have a process that is as comprehensive as you can make it. I also think this is much less of an issue than the doors that separate portions of the house. For example, what if a CAZ with a door was located in a basement that had a door at the top of the basement stairs? What is the position of the door at the top of the stairs with the FAS on and off? It could be closed with the FAS off and open with the FAS on. This is not addressed. A determination is needed on door position for shared walls, main body doors and the CAZ door. My recommendation is that you just smoke the CAZ door and leave it at that. I have included in the proposed changes section a suggested re-write with shared surface and odd doors as ancillary to the process. (Assuming you want to address a rare “shared surface”) 807.10 • Lots of walking and CAZ pressure measurements each time a door is closed – can you really get someone to do this? • Suggest the default position for doors should be closed if no real pressure change –reducing volume for the exhaust fans – somewhat of a cumulative effect • If the CAZ door is neutral, I suggest the default to be closed – kind of a combustion air test Suggest pressure testing/smoking the doors instead of CAZ pressure measurements. You also really would not have to smoke every door. You could just specify smoking only the doors to rooms that have exhaust fans or ducted return forced air systems. Could be stated either way – all doors or just some doors. 807.14 • Disagree here – all appliances should be kept operating to see if additional appliances affect operation of others. Vent capacity or configuration problems may be identified. They all need to function properly together. • Do not believe common vented versus separately vented need separate clarification – it would be better to just specify appliances that “share combustion air” – you could have a water heater in a kitchen that is back-drafted by a boiler in a furnace room in another part of the house • This will also address appliance testing when they are located in a separate CAZ Proposed Change: Suggested re-writes: (sorry it is not in the format you wanted - I don't have the time to change it at this point) 807.3.1 Inspect the venting system for proper size, horizontal pitch, leakage, corrosion or other deficiencies that could cause an unsafe condition. 807.3.3 Inspect furnace heat exchanger in the burner area for cracks, openings or excessive corrosion. 807.4 Put the home into BASELINE conditions by: 807.4.1 Turning off any forced air system operation 807.4.2 Closing all the exterior doors and windows of the home. 807.4.3 Closing fireplace damper(s) if fireplace is present. 807.4.4 Opening all interior doors ensuring that all vented appliances and exhaust fans have been turned off. If the CAZ is in a closet or an enclosed utility room, then the CAZ door shall be closed. 807.5 Obtain the BASELINE CAZ pressure by measuring the pressure difference between the CAZ with respect to (WRT) outside. 807.8 Close all interior doors to rooms without exhaust fans. For rooms without exhaust fans that are between a room with an exhaust fan and the CAZ leave the door open3 807.9 Determine the position of the CAZ door. Measure the pressure difference across the door or use flow visualization smoke with the CAZ door closed. If the pressure in the CAZ is more negative WRT the building or if the smoke indicates air flow into the CAZ, leave the door closed. If the pressure in the CAZ is less negative WRT the building or if the smoke indicates air flow out of the CAZ, open the door. If appropriate, determine other door positions per 807.9.1 and 807.9.2. Measure CAZ pressure (WRT) outside. 807.9.1 If the CAZ shares a surface (wall, floor or ceiling) with a room that contains an exhaust fan, measure the CAZ pressure WRT outside with the door to the room with the exhaust fan open and closed. Leave the room door in the configuration that makes the CAZ more negative. 807.9.2 To determine the position of a door which isolates portions of the building from the CAZ1 (other than the CAZ door), measure the pressure difference across the door or use flow visualization smoke with the door closed. If the pressure is more negative on the CAZ side of the door or if smoke indicates air flow toward the CAZ, leave the door closed. If the pressure is less negative on the CAZ side of the door or if the smoke indicates air flow away from the CAZ, open the door. 1 For example: a CAZ in a basement has a door and there is also a door at the top of the stairs separating the basement from the house 807.10 If there is a forced air system (FAS), turn on the FAS blower. Check for proper position of each interior door one at a time starting with the room furthest from the CAZ. Measure the pressure difference across the door or use flow visualization smoke to determine the correct position of the door. If the pressure is more negative on the CAZ side of the door or if the smoke indicates air flow away from the CAZ, open the door. If the pressure is less negative on the CAZ side of the door or if smoke indicates air flow toward the CAZ, leave the door closed. Leave the door closed if neutral pressure measurement or no clear indication of smoke flow direction. Repeat this procedure for all interior doors and the CAZ door. If there is more than one FAS, then repeat this procedure for each FAS blower and all combinations of FAS blowers. Measure CAZ pressure (WRT) outside. OR 807.10 If there is a forced air system (FAS), turn on the FAS blower. Check for proper position of interior doors to rooms that contain either an exhaust fan or a forced air ducted return. After checking interior doors, check for proper position of the CAZ door. Measure the pressure difference across the door or use flow visualization smoke to determine the correct position of the door. If the pressure is more negative on the CAZ side of the door or if the smoke indicates air flow away from the CAZ, open the door. If the pressure is less negative on the CAZ side of the door or if smoke indicates air flow toward the CAZ, leave the door closed. Leave the door closed if neutral pressure measurement or no clear indication of smoke flow direction. If appropriate, determine other door positions per 807.10.1. If there is more than one FAS, then repeat this procedure for each FAS blower and all combinations of FAS blowers. Measure CAZ pressure (WRT) outside. 807.10.1 To determine the position of a door which isolates portions of the building from the CAZ1 (other than the CAZ door), measure the pressure difference across the door or use flow visualization smoke with the door closed. If the pressure is more negative on the CAZ side of the door or if smoke indicates air flow toward the CAZ, leave the door closed. If the pressure is less negative on the CAZ side of the door or if the smoke indicates air flow away from the CAZ, open the door. 1 For example: a CAZ in a basement has a door and there is also a door at the top of the stairs separating the basement from the house 807.14 Testing additional appliances. For all combustion appliances that utilize the same volume of air for combustion, turn on other combustion appliances (with other smaller appliances still operating) one at a time, in order of increasing capacity, and repeat 807.13.1 through 807.13.3 for every appliance that is on after each one is turned on.
807.3.1
Not sure how you are going to get a rater / inspector to take apart a vent system for inspection of blockage – or go up on the roof to inspect from the top side. Is this beyond reasonable expectation for a rater? Not being part of the discussion on it being here I suggest removal of the blockage wording.
807.3.3
There is no way a rater / auditor / inspector is going to know for sure if the heat exchanger has a hole in it. Is this beyond reasonable expectation for a rater? Maybe specify the area of inspection.
807.4
Move FAS operation up from 807.8 because we need to have it off to measure baseline anyway and it was sending the wrong message in the other location.
807.5
Should be re-worded for clarity
807.8
Move the FAS wording up to a new 807.4.1 – want to have it off for Baseline pressure measurement and also don’t want to imply here that the doors do not need to be closed unless there is a FAS. Just tell them to close the doors at this point.
807.9
First two sentences:
• Too many steps and pressure measurements – a home with two baths and a utility room would require 6 pressure measurements and much walking • Also, why? It seems as if the only reason this task makes any sense is if there is a shared wall from a room with an exhaust fan to the CAZ and it was leaky and was affecting the CAZ. • If this is what these first two sentences are trying to address: o Lots of work in the majority of the homes where it doesn’t matter trying to catch the rare house where it may be a problem o Not logical in format as the following “alternative” eliminates catching that scenario
Sentences 3 and 4:
• The room with the fan will always be negative if the CAZ is affected with the room door closed and if this alternative was followed, the door would then be opened – negating the reason/effect of the 1st two sentences of this section.
First half of sentence 5 - "Repeat this procedure for all interior doors..."
• Why do this procedure for any of the interior doors? o The set up already has interior doors closed except those with fans o The FAS is not operating o The doors to rooms with exhaust fans are almost always going to end up being left open (the exception would be the rare shared wall scenario) o If any of the other rooms were leaky enough to be trying to provide make-up air for an exhaust fan, it will be under a positive pressure when tested with smoke and the door will stay closed o If there is little or no indication of direction of smoke flow we would still want the door closed to reduce the house volume for the exhaust fans o The default position for all the doors to rooms with no fans should be closed o Seems to be a waste of time and travel
Last of sentence 5 - "...and the CAZ door."
• The CAZ door is the exception. • Because you could have an exhaust fan either in the CAZ or affecting the CAZ, you could either: o Measure the CAZ pressure with the CAZ door both open and closed o Smoke/pressure test the CAZ door to determine its position and then measure the CAZ pressure o One measurement versus two.
Do you want to address "shared surfaces" and if so, how? It’s a fine line between what “covers most houses most of the time” versus trying to have a process that is as comprehensive as you can make it. I also think this is much less of an issue than the doors that separate portions of the house. For example, what if a CAZ with a door was located in a basement that had a door at the top of the basement stairs? What is the position of the door at the top of the stairs with the FAS on and off? It could be closed with the FAS off and open with the FAS on. This is not addressed.
A determination is needed on door position for shared walls, main body doors and the CAZ door. My recommendation is that you just smoke the CAZ door and leave it at that. I have included in the proposed changes section a suggested re-write with shared surface and odd doors as ancillary to the process. (Assuming you want to address a rare “shared surface”)
807.10
• Lots of walking and CAZ pressure measurements each time a door is closed – can you really get someone to do this? • Suggest the default position for doors should be closed if no real pressure change –reducing volume for the exhaust fans – somewhat of a cumulative effect • If the CAZ door is neutral, I suggest the default to be closed – kind of a combustion air test
Suggest pressure testing/smoking the doors instead of CAZ pressure measurements. You also really would not have to smoke every door. You could just specify smoking only the doors to rooms that have exhaust fans or ducted return forced air systems. Could be stated either way – all doors or just some doors.
807.14
• Disagree here – all appliances should be kept operating to see if additional appliances affect operation of others. Vent capacity or configuration problems may be identified. They all need to function properly together. • Do not believe common vented versus separately vented need separate clarification – it would be better to just specify appliances that “share combustion air” – you could have a water heater in a kitchen that is back-drafted by a boiler in a furnace room in another part of the house • This will also address appliance testing when they are located in a separate CAZ
Suggested re-writes: (sorry it is not in the format you wanted - I don't have the time to change it at this point)
807.3.1 Inspect the venting system for proper size, horizontal pitch, leakage, corrosion or other deficiencies that could cause an unsafe condition.
807.3.3 Inspect furnace heat exchanger in the burner area for cracks, openings or excessive corrosion.
807.4 Put the home into BASELINE conditions by:
807.4.1 Turning off any forced air system operation
807.4.2 Closing all the exterior doors and windows of the home.
807.4.3 Closing fireplace damper(s) if fireplace is present.
807.4.4 Opening all interior doors ensuring that all vented appliances and exhaust fans have been turned off. If the CAZ is in a closet or an enclosed utility room, then the CAZ door shall be closed.
807.5 Obtain the BASELINE CAZ pressure by measuring the pressure difference between the CAZ with respect to (WRT) outside.
807.8 Close all interior doors to rooms without exhaust fans. For rooms without exhaust fans that are between a room with an exhaust fan and the CAZ leave the door open3
807.9 Determine the position of the CAZ door. Measure the pressure difference across the door or use flow visualization smoke with the CAZ door closed. If the pressure in the CAZ is more negative WRT the building or if the smoke indicates air flow into the CAZ, leave the door closed. If the pressure in the CAZ is less negative WRT the building or if the smoke indicates air flow out of the CAZ, open the door. If appropriate, determine other door positions per 807.9.1 and 807.9.2. Measure CAZ pressure (WRT) outside.
807.9.1 If the CAZ shares a surface (wall, floor or ceiling) with a room that contains an exhaust fan, measure the CAZ pressure WRT outside with the door to the room with the exhaust fan open and closed. Leave the room door in the configuration that makes the CAZ more negative.
807.9.2 To determine the position of a door which isolates portions of the building from the CAZ1 (other than the CAZ door), measure the pressure difference across the door or use flow visualization smoke with the door closed. If the pressure is more negative on the CAZ side of the door or if smoke indicates air flow toward the CAZ, leave the door closed. If the pressure is less negative on the CAZ side of the door or if the smoke indicates air flow away from the CAZ, open the door.
1 For example: a CAZ in a basement has a door and there is also a door at the top of the stairs separating the basement from the house
807.10 If there is a forced air system (FAS), turn on the FAS blower. Check for proper position of each interior door one at a time starting with the room furthest from the CAZ. Measure the pressure difference across the door or use flow visualization smoke to determine the correct position of the door. If the pressure is more negative on the CAZ side of the door or if the smoke indicates air flow away from the CAZ, open the door. If the pressure is less negative on the CAZ side of the door or if smoke indicates air flow toward the CAZ, leave the door closed. Leave the door closed if neutral pressure measurement or no clear indication of smoke flow direction. Repeat this procedure for all interior doors and the CAZ door. If there is more than one FAS, then repeat this procedure for each FAS blower and all combinations of FAS blowers. Measure CAZ pressure (WRT) outside.
OR
807.10 If there is a forced air system (FAS), turn on the FAS blower. Check for proper position of interior doors to rooms that contain either an exhaust fan or a forced air ducted return. After checking interior doors, check for proper position of the CAZ door. Measure the pressure difference across the door or use flow visualization smoke to determine the correct position of the door. If the pressure is more negative on the CAZ side of the door or if the smoke indicates air flow away from the CAZ, open the door. If the pressure is less negative on the CAZ side of the door or if smoke indicates air flow toward the CAZ, leave the door closed. Leave the door closed if neutral pressure measurement or no clear indication of smoke flow direction. If appropriate, determine other door positions per 807.10.1. If there is more than one FAS, then repeat this procedure for each FAS blower and all combinations of FAS blowers. Measure CAZ pressure (WRT) outside.
807.10.1 To determine the position of a door which isolates portions of the building from the CAZ1 (other than the CAZ door), measure the pressure difference across the door or use flow visualization smoke with the door closed. If the pressure is more negative on the CAZ side of the door or if smoke indicates air flow toward the CAZ, leave the door closed. If the pressure is less negative on the CAZ side of the door or if the smoke indicates air flow away from the CAZ, open the door.
807.14 Testing additional appliances. For all combustion appliances that utilize the same volume of air for combustion, turn on other combustion appliances (with other smaller appliances still operating) one at a time, in order of increasing capacity, and repeat 807.13.1 through 807.13.3 for every appliance that is on after each one is turned on.
Comment #6Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 2Paragraph / Figure / Table / Note: Table 807.1Comment Type: TechnicalComment: Table 807.1, NFPA 54 venting categories: This table is not easy for auditors/raters to interpret. Proposed Change: At a minimum this language needs a description that provides examples of the appliance types, and a definition of “excessive condensate” should be provided somewhere in the standard if not on this page.
Table 807.1, NFPA 54 venting categories: This table is not easy for auditors/raters to interpret.
At a minimum this language needs a description that provides examples of the appliance types, and a definition of “excessive condensate” should be provided somewhere in the standard if not on this page.
Comment #7Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: pg allComment Type: GeneralComment: I have been reviewing the Std 806-808 and I have lots of concerns with the document as it stands. I believe that the document should be on hold and even rewritten. It starts with looking at the scope of work for the Rater and even the Comprehensive rater. I believe that this standard proposed far exceeds scope. Then on to the renaming of the test (which is used by BPI, CHEERS, DOE Weatherization to mention a few). Then the gas leak testing that far exceeds the gas utility standards. The setup for the worst case depressurization ( what about supply registers in the CAZ) and measuring the CO in a confined space CAZ and also how do I look at spillage? What about venting termination, combustion/dilution air? I think this document should cease and be reworked or put in the combustion chamber with a nice hot fire!
I have been reviewing the Std 806-808 and I have lots of concerns with the document as it stands. I believe that the document should be on hold and even rewritten.
It starts with looking at the scope of work for the Rater and even the Comprehensive rater. I believe that this standard proposed far exceeds scope.
Then on to the renaming of the test (which is used by BPI, CHEERS, DOE Weatherization to mention a few).
Then the gas leak testing that far exceeds the gas utility standards.
The setup for the worst case depressurization ( what about supply registers in the CAZ) and measuring the CO in a confined space CAZ and also how do I look at spillage?
What about venting termination, combustion/dilution air?
I think this document should cease and be reworked or put in the combustion chamber with a nice hot fire!
Comment #8Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 3Paragraph / Figure / Table / Note: 807.7Comment Type: TechnicalComment: 100 CFM is OK for stoves in general but is much too high for modern, air-tight EPA rated wood or pellet stoves. Something like 25-30 CFM is more realistic, and should be included as an option (along with a corresponding adjustment table to go along with 807.2 and 3). There is as big a difference between a fireplace with glass doors and an airtight wood stove as there is between an open fireplace and one with doors, and that distinction is being made. Proposed Change: A table should be added for airtight wood and pellet stoves, assuming 30 CFM (along with the appropriate language specifying 30 CFM for EPA-listed airtight stoves in paragram 807.7. The formula would be: Padj = 9413 × CFM50^(−1.54), with a table 807.4 based on that formula at CFM50s of 500, 1000, etc. (at 2000 CFM50, the pressure developed is only 0.07, so values above 2000 CFM need not be included).
100 CFM is OK for stoves in general but is much too high for modern, air-tight EPA rated wood or pellet stoves. Something like 25-30 CFM is more realistic, and should be included as an option (along with a corresponding adjustment table to go along with 807.2 and 3). There is as big a difference between a fireplace with glass doors and an airtight wood stove as there is between an open fireplace and one with doors, and that distinction is being made.
A table should be added for airtight wood and pellet stoves, assuming 30 CFM (along with the appropriate language specifying 30 CFM for EPA-listed airtight stoves in paragram 807.7. The formula would be: Padj = 9413 × CFM50^(−1.54), with a table 807.4 based on that formula at CFM50s of 500, 1000, etc. (at 2000 CFM50, the pressure developed is only 0.07, so values above 2000 CFM need not be included).
Comment #9Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 3Paragraph / Figure / Table / Note: 807.7Comment Type: TechnicalComment: Consider eliminating the option for simulation using a fan entirely, or at least making that the "alternate" and the calculated adjustments the first choice. The calculated values are more repeatable and reliable, and far less time consuming; most users will default to the calculated values in any case. Proposed Change: 807.7 If one or more fireplaces or solid fuel stoves are present that are not direct vent appliances, then operate an auxiliary exhaust fan1 to exhaust 300 cfm for an open hearth fireplace, or to exhaust 100 cfm for a solid fuel stove or fireplace with glass doors use the formulas or tables shown below as follows: 807.7.1 As an alternative to the auxiliary exhaust flows specified in 807.6 the target CAZ pressure in 807.10 may be adjusted as follows: 807.7.21 For an open hearth fireplace the pressure adjustment Padj shall be calculated using Equation 807.1 using the envelope leakage CFM50 from Section 802 of this standard or use Table 807.2. 807.7.32 For a solid fuel stove or fireplace with glass doors the pressure adjustment Padj shall be calculated using Equation 807.2 using the envelope leakage CFM50 from Section 802 of this standard or use Table 807.3.
Consider eliminating the option for simulation using a fan entirely, or at least making that the "alternate" and the calculated adjustments the first choice. The calculated values are more repeatable and reliable, and far less time consuming; most users will default to the calculated values in any case.
807.7 If one or more fireplaces or solid fuel stoves are present that are not direct vent appliances, then operate an auxiliary exhaust fan1 to exhaust 300 cfm for an open hearth fireplace, or to exhaust 100 cfm for a solid fuel stove or fireplace with glass doors use the formulas or tables shown below as follows:
807.7.1 As an alternative to the auxiliary exhaust flows specified in 807.6 the target CAZ pressure in 807.10 may be adjusted as follows: 807.7.21 For an open hearth fireplace the pressure adjustment Padj shall be calculated using Equation 807.1 using the envelope leakage CFM50 from Section 802 of this standard or use Table 807.2.
807.7.32 For a solid fuel stove or fireplace with glass doors the pressure adjustment Padj shall be calculated using Equation 807.2 using the envelope leakage CFM50 from Section 802 of this standard or use Table 807.3.
Comment #10Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 3 thru 8Paragraph / Figure / Table / Note: 808.7.1 to 808.6.3Comment Type: TechnicalComment: 807.7.1 There are no flows specified in 807.6, they are in 807.7. The maximum depressurization is not a target we are trying to achieve, but a depressurization limit that we don't want to exceed. This target (limit) is no longer in 807.10 or anywhere else so I added the -5Pa limit here. Perhaps it should be in a separate paragraph. 807.9 This section says to measure the pressure difference between the CAZ and outside while closing doors to determine worst case door position. With only a slight wind causing pressure fluctuations, this will be nearly impossible. It also is impractical due to having to measure the CAZ, which might be in the basement, while opening and closing doors, that might be on the second floor. You could run long hoses, or record CAZ pressure and note times when doors are open and closed, but I think it will be much more accurate and easy to determine proper door position by measuring the room to main body pressure or using smoke visualization. See Tom Andrews’ comments and suggested rewrite of this. I support Tom’s wording. 807.11 I added the word CAZ to make it clear which, of the many pressures that are being measured, that we are concerned with here. In 807.12 it says "the work scope shall specify remediation through pressure balancing, duct sealing, and/or other pressure-relief measures." If this is a HERS confirmed rating on a new house will there be a work scope? If there won’t be a work scope, how does this get reported? Should the rater refuse to complete a rating until the condition is fixed? 807.13.2 I added text that says to install a probe to measure flue gas CO. Without saying this it's not clear that CO in flue gas must be measured or when to do it. 807.13.3 I added the words "flue gas" before CO in 2 places to clarify which of the 2 CO measurements are to be recorded and trigger specifying remediation. 808.6.3 I corrected paragraph numbers referred to. 807.12 says nothing about CO. Proposed Change: 807.7.1 As an alternative to the auxiliary exhaust flows specified in 807.67 the target CAZ pressure in 807.10 depressurization limit of -5Pa may be adjusted as follows: 807.11 Put the house doors, CAZ door and FAS blower into the condition that gave the most negative CAZ pressure in 807.9 or 807.10. 807.13.2. If the smoke is not fully drawn up the flue, the appliance has spillage under depressurized conditions. According to section 808, install probe to measure CO levels in the appliance’s flue gasses at 5 minutes of burner run time. 807.13.3 Record the results of the spillage test and the highest observed flue gas CO level. NOTE: When spillage occurs or flue gas CO exceeds the limits specified below in section 808, the work scope shall specify remediation (e.g., equipment repair, equipment replacement, and/or building pressure remediation). If both spillage and high CO are found during the test, the homeowner shall be notified of the recorded results and need for remediation. 808.6.3 Take sample during worst-case depressurization test and/or under natural conditions, as required by paragraphs 807.12, 807.13, and 807.14, 807.15, and 807.16. Record the CO level.
807.7.1 There are no flows specified in 807.6, they are in 807.7. The maximum depressurization is not a target we are trying to achieve, but a depressurization limit that we don't want to exceed. This target (limit) is no longer in 807.10 or anywhere else so I added the -5Pa limit here. Perhaps it should be in a separate paragraph.
807.9 This section says to measure the pressure difference between the CAZ and outside while closing doors to determine worst case door position. With only a slight wind causing pressure fluctuations, this will be nearly impossible. It also is impractical due to having to measure the CAZ, which might be in the basement, while opening and closing doors, that might be on the second floor. You could run long hoses, or record CAZ pressure and note times when doors are open and closed, but I think it will be much more accurate and easy to determine proper door position by measuring the room to main body pressure or using smoke visualization. See Tom Andrews’ comments and suggested rewrite of this. I support Tom’s wording.
807.11 I added the word CAZ to make it clear which, of the many pressures that are being measured, that we are concerned with here.
In 807.12 it says "the work scope shall specify remediation through pressure balancing, duct sealing, and/or other pressure-relief measures." If this is a HERS confirmed rating on a new house will there be a work scope? If there won’t be a work scope, how does this get reported? Should the rater refuse to complete a rating until the condition is fixed?
807.13.2 I added text that says to install a probe to measure flue gas CO. Without saying this it's not clear that CO in flue gas must be measured or when to do it.
807.13.3 I added the words "flue gas" before CO in 2 places to clarify which of the 2 CO measurements are to be recorded and trigger specifying remediation.
808.6.3 I corrected paragraph numbers referred to. 807.12 says nothing about CO.
807.7.1 As an alternative to the auxiliary exhaust flows specified in 807.67 the target CAZ pressure in 807.10 depressurization limit of -5Pa may be adjusted as follows:
807.11 Put the house doors, CAZ door and FAS blower into the condition that gave the most negative CAZ pressure in 807.9 or 807.10.
807.13.2. If the smoke is not fully drawn up the flue, the appliance has spillage under depressurized conditions. According to section 808, install probe to measure CO levels in the appliance’s flue gasses at 5 minutes of burner run time.
807.13.3 Record the results of the spillage test and the highest observed flue gas CO level. NOTE: When spillage occurs or flue gas CO exceeds the limits specified below in section 808, the work scope shall specify remediation (e.g., equipment repair, equipment replacement, and/or building pressure remediation). If both spillage and high CO are found during the test, the homeowner shall be notified of the recorded results and need for remediation.
808.6.3 Take sample during worst-case depressurization test and/or under natural conditions, as required by paragraphs 807.12, 807.13, and 807.14, 807.15, and 807.16. Record the CO level.
Comment #11Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 2Paragraph / Figure / Table / Note: 807.1Comment Type: EditorialComment: "Manometers" should be singular, not plural. There is no need for multiple manometers in the test procedures. Proposed Change: One or more manometer(s) with a resolution..."
"Manometers" should be singular, not plural. There is no need for multiple manometers in the test procedures.
One or more manometer(s) with a resolution..."
Comment #12Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 5Paragraph / Figure / Table / Note: 807.8Comment Type: EditorialComment: Change language to make it clearer; the implication as-is is that the fan is already running. Proposed Change: "807.8 If there is a Forced Air system (FAS) turn it, ensure that it is turned off at the thermostat and close all interior doors..."
Change language to make it clearer; the implication as-is is that the fan is already running.
"807.8 If there is a Forced Air system (FAS) turn it, ensure that it is turned off at the thermostat and close all interior doors..."
Comment #13Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 5-6Paragraph / Figure / Table / Note: 807.9 and 10Comment Type: TechnicalComment: Measuring the direct effect of door closure on the CAZ pressure is much less precise in most, if not all, cases than testing the room behind the door with pressure or smoke directly,. As well, repeated returns to the CAZ for measuments would be so time consuming that few will bother—it should be omitted entirely. Also the case where the room is neutral needs to be added (leave door closed). Further, 807.10 is unnecessarily onerous—“repeat this procedure for each FAS and all combinations of FAS blowers”. So for a house with 3 air handlers, there would be eight iterations of this test in the entire house, recording the net CAZ depressurization 8 times. Under the best of conditions, this step alone might take 30-45 minutes. Meanwhile, there is no provision to monitor wind conditions or make note of a changing baseline throughout the lengthy procedure. In windy conditions these tests may actually be impossible to conduct satisfactorily, and no guidance is given for that situation. If the baseline changes by several pascals between the beginning of the test and the end (or between each tested combination of door closures and air handlers), there is no way to interpret which is truly the worst case and the whole procedure must then be repeated? And if the changing baseline is not recorded the results will be meaningless and the choice of "worst case" will likely be incorrect. (Note, there is far more attention paid to baseline variability due to wind in 802.5 and 802.6 -- the blower door test -- even though the results of that test are arguably less sensitive to wind than this CAZ pressure test, yet no mention at all is made here.) This whole section should be amended to include a simpler, “typical worst case” room/door setup and a procedure to monitor wind/baseline variability before and after the test, and to correct for that variability. Proposed Change: 807.9 Starting with the room furthest from the CAZ, for each room or suite with an exhaust fan, measure the pressure difference between the CAZ and outside room or suite and the main body of the house with the door open and closed. Leave the door in the configuration that makes the CAZ more negative. As an alternative, it is permissible to measure the pressure difference across the closed door or use flow visualization smoke with the door closed. If the room is depressurized, or the smoke indicates air flow into the room or suite, then open the door. If the room is pressurized or neutral, or the smoke indicates no air flow or air flow out of the room or suite, then close the door. Repeat this procedure for all interior doors and the CAZ door. Measure the CAZ depressurization. 807.10 If there is a are one or more forced air systems (FAS), turn on the FAS blower(s) and open all interior doors. Starting with the room furthest from the CAZ, close each interior door one at a time. For each door closing measure the pressure difference between the CAZ and outsideroom or suite and the main body of the house. If the pressure difference between the CAZ and outside is more negative, If the room is depressurized, or the smoke indicates air flow into the room or suite, then open the door. If the room is pressurized or neutral, or the smoke indicates no air flow or air flow out of the room or suite, then leave the door closed. If it is more positive or zero, open the door. Repeat this procedure for all interior doors and the CAZ door. If there is more than one FAS, then repeat this procedure for each FAS blower and all combinations of FAS blowers. 807.11 [renumber subsequent steps] Turn off the exhaust fans and FAS blowers, and open the interior doors. Record the pressure difference in the CAZ WRT outside, and compare it to the baseline CAZ pressure in stip 807.5. If the pressure difference has changed by more than 1 Pa from the original baseline, repeat steps 807.6-807.10 as necessary until a consistent worst-case CAZ pressure is established.
Measuring the direct effect of door closure on the CAZ pressure is much less precise in most, if not all, cases than testing the room behind the door with pressure or smoke directly,. As well, repeated returns to the CAZ for measuments would be so time consuming that few will bother—it should be omitted entirely. Also the case where the room is neutral needs to be added (leave door closed).
Further, 807.10 is unnecessarily onerous—“repeat this procedure for each FAS and all combinations of FAS blowers”. So for a house with 3 air handlers, there would be eight iterations of this test in the entire house, recording the net CAZ depressurization 8 times. Under the best of conditions, this step alone might take 30-45 minutes. Meanwhile, there is no provision to monitor wind conditions or make note of a changing baseline throughout the lengthy procedure. In windy conditions these tests may actually be impossible to conduct satisfactorily, and no guidance is given for that situation. If the baseline changes by several pascals between the beginning of the test and the end (or between each tested combination of door closures and air handlers), there is no way to interpret which is truly the worst case and the whole procedure must then be repeated? And if the changing baseline is not recorded the results will be meaningless and the choice of "worst case" will likely be incorrect. (Note, there is far more attention paid to baseline variability due to wind in 802.5 and 802.6 -- the blower door test -- even though the results of that test are arguably less sensitive to wind than this CAZ pressure test, yet no mention at all is made here.)
This whole section should be amended to include a simpler, “typical worst case” room/door setup and a procedure to monitor wind/baseline variability before and after the test, and to correct for that variability.
807.9 Starting with the room furthest from the CAZ, for each room or suite with an exhaust fan, measure the pressure difference between the CAZ and outside room or suite and the main body of the house with the door open and closed. Leave the door in the configuration that makes the CAZ more negative. As an alternative, it is permissible to measure the pressure difference across the closed door or use flow visualization smoke with the door closed. If the room is depressurized, or the smoke indicates air flow into the room or suite, then open the door. If the room is pressurized or neutral, or the smoke indicates no air flow or air flow out of the room or suite, then close the door. Repeat this procedure for all interior doors and the CAZ door. Measure the CAZ depressurization.
807.10 If there is a are one or more forced air systems (FAS), turn on the FAS blower(s) and open all interior doors. Starting with the room furthest from the CAZ, close each interior door one at a time. For each door closing measure the pressure difference between the CAZ and outsideroom or suite and the main body of the house. If the pressure difference between the CAZ and outside is more negative, If the room is depressurized, or the smoke indicates air flow into the room or suite, then open the door. If the room is pressurized or neutral, or the smoke indicates no air flow or air flow out of the room or suite, then leave the door closed. If it is more positive or zero, open the door. Repeat this procedure for all interior doors and the CAZ door. If there is more than one FAS, then repeat this procedure for each FAS blower and all combinations of FAS blowers.
807.11 [renumber subsequent steps] Turn off the exhaust fans and FAS blowers, and open the interior doors. Record the pressure difference in the CAZ WRT outside, and compare it to the baseline CAZ pressure in stip 807.5. If the pressure difference has changed by more than 1 Pa from the original baseline, repeat steps 807.6-807.10 as necessary until a consistent worst-case CAZ pressure is established.
Comment #14Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 7Paragraph / Figure / Table / Note: 802.17Comment Type: TechnicalComment: This section says to repeat “the procedures” for each CAZ separately. If the 3 FAS’s all are in separate CAZ’s I interpret that conservatively to mean the entire procedure, from 807.2 to 807.16. That means (without also changing 807.9 and 807.10 per my recommendations) that all 8 sets of door closure tests (in the entire house) must be repeated 3 separate times, leading to a total of 24 rounds of door closure. For a house with 4 separate CAZs serving 4 FASs, that’s 64 rounds. This could take hours in some houses, and is completely unnecessary. If a “standard worst case” door closure/setup is followed, the setup for a reasonable worst case condition only needs to happen once, which is a reasonable standard of care. Proposed Change: 807.17 If more than one CAZ is present, repeat the procedures in sections 807.13-807.16 for each CAZ separately. The steps in sections 807.2-807.12 may be conducted for all CAZs together, provided the CAZ pressures WRT outside are recorded separately for each CAZ.
This section says to repeat “the procedures” for each CAZ separately. If the 3 FAS’s all are in separate CAZ’s I interpret that conservatively to mean the entire procedure, from 807.2 to 807.16. That means (without also changing 807.9 and 807.10 per my recommendations) that all 8 sets of door closure tests (in the entire house) must be repeated 3 separate times, leading to a total of 24 rounds of door closure. For a house with 4 separate CAZs serving 4 FASs, that’s 64 rounds. This could take hours in some houses, and is completely unnecessary. If a “standard worst case” door closure/setup is followed, the setup for a reasonable worst case condition only needs to happen once, which is a reasonable standard of care.
807.17 If more than one CAZ is present, repeat the procedures in sections 807.13-807.16 for each CAZ separately. The steps in sections 807.2-807.12 may be conducted for all CAZs together, provided the CAZ pressures WRT outside are recorded separately for each CAZ.
Comment #15Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: pp 2-7Paragraph / Figure / Table / Note: Section 807Comment Type: TechnicalComment: 1.) The standard should separately address gas-fired appliances, which are covered by the National Fuel Gas Code (NFGC), Z223.1/NFPA 54 and the International Fuel Gas Code (IFGC), and implementation of CAZ testing requirements and depressurization limits from other combustion appliances that are not similarly covered by national consensus standards for installation, combustion air, and venting. This separation of coverage is recognized by the U. S. Environmental Protection Agency (EPA) Healthy Indoor Environment Protocols for Home Energy Upgrades and should be treated separately from non-gas-fired appliances under the RESNET standard as well. 2.) If RESNET includes CAZ testing and depressurization requirements for gas-fired appliances, it will have violated its standards development procedures, which under Section 10.8.1 of the “RESNET Standards Development Process” (found in the document, “Standards Development Policy and Procedures Manual,” Version 1.1, January 2, 2012) state: “If the SMB (Standards Management Board) identifies [upon a review of existing standards] any potential conflict with other published standards, the SDC (Standards Development Committee) shall be directed to work with the organization that developed the other standards to ensure to the extent possible that the two standards are not inconsistent or incompatible. This effort shall be documented.” To date, neither the SMB nor the SDC have contacted American Gas Association (AGA), the American National Standards Institute (ANSI) secretariat for the National Fuel Gas Code (NFGC), ANSI Z223.1/NFPA 54 with respect to inconsistencies and incompatibilities of current and proposed CAZ testing provisions of Section 807 with the NFGC. It is inconceivable that neither the SMB nor the SDC would be familiar with the NFGC and its scope of coverage for combustion air and venting of gas-fired appliances. AGA invites RESNET to work with the NFGC Code Committee and the secretariat for addressing these inconsistencies and incompatibilities in the current RESNET standard text. However, the currently proposed text perpetuates and expands these problems and should not be implemented. The proposed revision to the text addresses these inconsistencies and incompatibilities in the near term. 3.) The section would be technically flawed in requiring CAZ testing and depressurization criteria for all Category I and Category II gas-fired appliances since, under NFGC Section 9.3, combinations of outdoor and indoor air may provide adequate combustion air and air supporting proper venting. Such installations are pressure neutral since depressurizing influences drive greater airflow into the structure from outside the pressure boundary of the house. For such installations, CAZ testing and depressurization criteria play no reasonable technical role. 4.) No cases have been documented for improper venting performance of Category I or Category II gas-fired appliances where venting is properly installed in accordance with the NFGC, Chapter 12, “Venting of Appliances” and where sufficient combustion air is provided in accordance with Section 9.3, “Air for Combustion and Ventilation.” As a result, CAZ testing and use of depressurization criteria is superfluous. 5.) Interaction of gas-fired appliance venting with exhaust systems and other mechanical sources of depressurization are addressed in NFGC Section 9.3.1.5 and its complementary coverage in the International Fuel Gas Code (IFGC), Section 304.4, “Makeup Air Provisions” as minimum code requirements. If blower door testing suggests that these systems would interfere with proper venting, remediation measures to provide makeup air are required by minimum code. Proposed Change: 1.) Change title of Section 807 to "APPLIANCE VENTING," organize the text that follows under an new subheading, "807.2 Appliances Other Than Gas-Fired Appliances," and renumber the subsections that follow accordingly. 2.) Add a new section "807.1 Gas-Fired Appliances," and add the following text: "Gas-fired appliances and air for combustion and venting shall be reviewed for compliance with the National Fuel Gas Code (NFGC), Z223.1/NFPA 54 (2012), Chapter 12, “Venting of Appliances” and Section 9.3, “Air for Combustion and Ventilation.” The local authority having jurisdiction shall be informed where venting systems do not meet the requirements of Chapter 12 of the NFGC and where insufficient air for combustion is provided according to requirements of Section 9.3 the NFGC. Potential sources of depressurization addressed in NFGC Section 9.3.1.5 and its complementary coverage in the International Fuel Gas Code (IFGC), Section 304.4, “Makeup Air Provisions. Performance testing of installed gas-fired appliances, where called for by local authorities having jurisdiction, shall be performed in accordance with Annex G of the NFGC, “Recommended Procedure for Safety Inspection of an Existing Appliance Installation,” 3.) Deleted the second paragraph of the proposed text beginning, "Vented combustion appliances..." and Table 807.1, which are superfluous to non-gas fired appliances and since Chapter 12 and Section 9.3 of the NFGC are the governing code for gas-fired appliances.
1.) The standard should separately address gas-fired appliances, which are covered by the National Fuel Gas Code (NFGC), Z223.1/NFPA 54 and the International Fuel Gas Code (IFGC), and implementation of CAZ testing requirements and depressurization limits from other combustion appliances that are not similarly covered by national consensus standards for installation, combustion air, and venting. This separation of coverage is recognized by the U. S. Environmental Protection Agency (EPA) Healthy Indoor Environment Protocols for Home Energy Upgrades and should be treated separately from non-gas-fired appliances under the RESNET standard as well.
2.) If RESNET includes CAZ testing and depressurization requirements for gas-fired appliances, it will have violated its standards development procedures, which under Section 10.8.1 of the “RESNET Standards Development Process” (found in the document, “Standards Development Policy and Procedures Manual,” Version 1.1, January 2, 2012) state:
“If the SMB (Standards Management Board) identifies [upon a review of existing standards] any potential conflict with other published standards, the SDC (Standards Development Committee) shall be directed to work with the organization that developed the other standards to ensure to the extent possible that the two standards are not inconsistent or incompatible. This effort shall be documented.”
To date, neither the SMB nor the SDC have contacted American Gas Association (AGA), the American National Standards Institute (ANSI) secretariat for the National Fuel Gas Code (NFGC), ANSI Z223.1/NFPA 54 with respect to inconsistencies and incompatibilities of current and proposed CAZ testing provisions of Section 807 with the NFGC. It is inconceivable that neither the SMB nor the SDC would be familiar with the NFGC and its scope of coverage for combustion air and venting of gas-fired appliances. AGA invites RESNET to work with the NFGC Code Committee and the secretariat for addressing these inconsistencies and incompatibilities in the current RESNET standard text. However, the currently proposed text perpetuates and expands these problems and should not be implemented. The proposed revision to the text addresses these inconsistencies and incompatibilities in the near term.
3.) The section would be technically flawed in requiring CAZ testing and depressurization criteria for all Category I and Category II gas-fired appliances since, under NFGC Section 9.3, combinations of outdoor and indoor air may provide adequate combustion air and air supporting proper venting. Such installations are pressure neutral since depressurizing influences drive greater airflow into the structure from outside the pressure boundary of the house. For such installations, CAZ testing and depressurization criteria play no reasonable technical role.
4.) No cases have been documented for improper venting performance of Category I or Category II gas-fired appliances where venting is properly installed in accordance with the NFGC, Chapter 12, “Venting of Appliances” and where sufficient combustion air is provided in accordance with Section 9.3, “Air for Combustion and Ventilation.” As a result, CAZ testing and use of depressurization criteria is superfluous.
5.) Interaction of gas-fired appliance venting with exhaust systems and other mechanical sources of depressurization are addressed in NFGC Section 9.3.1.5 and its complementary coverage in the International Fuel Gas Code (IFGC), Section 304.4, “Makeup Air Provisions” as minimum code requirements. If blower door testing suggests that these systems would interfere with proper venting, remediation measures to provide makeup air are required by minimum code.
1.) Change title of Section 807 to "APPLIANCE VENTING," organize the text that follows under an new subheading, "807.2 Appliances Other Than Gas-Fired Appliances," and renumber the subsections that follow accordingly.
2.) Add a new section "807.1 Gas-Fired Appliances," and add the following text: "Gas-fired appliances and air for combustion and venting shall be reviewed for compliance with the National Fuel Gas Code (NFGC), Z223.1/NFPA 54 (2012), Chapter 12, “Venting of Appliances” and Section 9.3, “Air for Combustion and Ventilation.” The local authority having jurisdiction shall be informed where venting systems do not meet the requirements of Chapter 12 of the NFGC and where insufficient air for combustion is provided according to requirements of Section 9.3 the NFGC. Potential sources of depressurization addressed in NFGC Section 9.3.1.5 and its complementary coverage in the International Fuel Gas Code (IFGC), Section 304.4, “Makeup Air Provisions. Performance testing of installed gas-fired appliances, where called for by local authorities having jurisdiction, shall be performed in accordance with Annex G of the NFGC, “Recommended Procedure for Safety Inspection of an Existing Appliance Installation,”
3.) Deleted the second paragraph of the proposed text beginning, "Vented combustion appliances..." and Table 807.1, which are superfluous to non-gas fired appliances and since Chapter 12 and Section 9.3 of the NFGC are the governing code for gas-fired appliances.
Comment #16Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: pp. 7-9Paragraph / Figure / Table / Note: Section 808Comment Type: TechnicalComment: 1.) The U. S. Consumer Product Safety Commission (CPSC) carbon monoxide (CO) action levels and occupant and first responder actions described in the CPSC document, “Responding to Residential Carbon Monoxide Incidents: Guidelines for Fire and Other Emergency Response Personnel” represent the primary authoritative source for both first responders and actions involving occupants. The current Section 808.5 and 808.9 text is ad hoc and lacks the specific guidance provided by CPSC. 2.) The ANSI Standard Z21.1, “Household Cooking Appliances” performance tests for carbon monoxide involves the specific design certification procedures and requirements for listing of gas-fired household cooking appliances. Use of other procedures, including some that might violate manufacturers’ installation and operating procedures, may produce inconsistent results with respect to the terms of ANSI certification. 3.) Deviation from (i.e., lowering of) maximum CO thresholds from the ANSI standard maximums may “fail” appliances that are operating well within their design certification performance. Such actions would inappropriate and may constitute restraint of trade. The standard should attempt to reproduce, to the extent reasonable, the design certification conditions in testing for CO emissions performance, but it should not, in conducting air-free CO testing, deviate from the ANSI standard limits. Proposed Change: 1.) Modify Sections 808.5 and 808.9 to be consistent with the U. S. Consumer Product Safety Commission (CPSC) carbon monoxide (CO) action levels and occupant and first responder actions described in the CPSC document, “Responding to Residential Carbon Monoxide Incidents: Guidelines for Fire and Other Emergency Response Personnel,” CPSC, July, 2002. 2.) Revise Section 808.78 for consistency with performance test procedures for gas-fired appliances under ANSI Standard Z21.1, “Household Cooking Appliances” (2005), including test setup, modes of operation, and loads on top burners. 3.) Revise Section 808.8 CO levels for consistency with ANSI Standards Z21.1 through Z21.88 covering gas-fired appliances in terms of maximum air-free CO. These design certification maximums include 800 ppm air free for two simultaneously-operating top burners for cooking appliances and the oven (tested separately) and 400 ppm air free for all other appliances.
1.) The U. S. Consumer Product Safety Commission (CPSC) carbon monoxide (CO) action levels and occupant and first responder actions described in the CPSC document, “Responding to Residential Carbon Monoxide Incidents: Guidelines for Fire and Other Emergency Response Personnel” represent the primary authoritative source for both first responders and actions involving occupants. The current Section 808.5 and 808.9 text is ad hoc and lacks the specific guidance provided by CPSC.
2.) The ANSI Standard Z21.1, “Household Cooking Appliances” performance tests for carbon monoxide involves the specific design certification procedures and requirements for listing of gas-fired household cooking appliances. Use of other procedures, including some that might violate manufacturers’ installation and operating procedures, may produce inconsistent results with respect to the terms of ANSI certification.
3.) Deviation from (i.e., lowering of) maximum CO thresholds from the ANSI standard maximums may “fail” appliances that are operating well within their design certification performance. Such actions would inappropriate and may constitute restraint of trade. The standard should attempt to reproduce, to the extent reasonable, the design certification conditions in testing for CO emissions performance, but it should not, in conducting air-free CO testing, deviate from the ANSI standard limits.
1.) Modify Sections 808.5 and 808.9 to be consistent with the U. S. Consumer Product Safety Commission (CPSC) carbon monoxide (CO) action levels and occupant and first responder actions described in the CPSC document, “Responding to Residential Carbon Monoxide Incidents: Guidelines for Fire and Other Emergency Response Personnel,” CPSC, July, 2002.
2.) Revise Section 808.78 for consistency with performance test procedures for gas-fired appliances under ANSI Standard Z21.1, “Household Cooking Appliances” (2005), including test setup, modes of operation, and loads on top burners.
3.) Revise Section 808.8 CO levels for consistency with ANSI Standards Z21.1 through Z21.88 covering gas-fired appliances in terms of maximum air-free CO. These design certification maximums include 800 ppm air free for two simultaneously-operating top burners for cooking appliances and the oven (tested separately) and 400 ppm air free for all other appliances.
Comment #17Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: pp. 1Paragraph / Figure / Table / Note: Section 806Comment Type: TechnicalComment: 1.) National Fuel Gas Code (NFGC), ANSI Z223.1/NFPA 54 (2012), Chapter 8, “Inspection, Testing, and Purging” represents national consensus standard requirements for inspecting and testing for leaks from natural gas and LP gas systems. The RESNET standard should not implement ad hoc and potentially conflicting requirements with this national consensus standard. 2.) If RESNET includes conflicting requirements, it will have violated its standards development procedures, which under Section 10.8.1 of the “RESNET Standards Development Process” (found in the document, “Standards Development Policy and Procedures Manual,” Version 1.1, January 2, 2012) state: “If the SMB (Standards Management Board) identifies [upon a review of existing standards] any potential conflict with other published standards, the SDC (Standards Development Committee) shall be directed to work with the organization that developed the other standards to ensure to the extent possible that the two standards are not inconsistent or incompatible. This effort shall be documented.” To date, neither the SMB nor the SDC have contacted American Gas Association (AGA), the American National Standards Institute (ANSI) secretariat for the National Fuel Gas Code (NFGC), ANSI Z223.1/NFPA 54 with respect to inconsistencies and incompatibilities of current and proposed CAZ testing provisions of Section 807 with the NFGC. It is inconceivable that neither the SMB nor the SDC would be familiar with the NFGC and its scope of coverage for combustion air and venting of gas-fired appliances. AGA invites RESNET to work with the NFGC Code Committee and the secretariat for addressing these inconsistencies and incompatibilities in the current RESNET standard text. 3.) Annex C of the NFGC, “Suggested Method for Checking for Leakage” and Annex D, “Suggested Emergency Procedures for Gas Leaks” represent informative appendices of the NFGC but in no way defer national consensus standard coverage to other organizations, which may implement conflicting coverage. The NFGC Committee has carefully reviewed requirements for mandatory and informative sections of the Code and has determined that Annex C and D belong as informative appendices that may be required by local authorities having jurisdiction, but national model code requirement are not warranted. RESNET should infringe upon this local authority governance of requirements for natural gas and LP gas systems. Proposed Change: Delete the text in Section 806 in its entirety and replace it with the following: 806 GAS LEAKAGE Natural gas and LP gas systems should be tested and inspected in accordance with the National Fuel Gas Code (NFGC), ANSI Z223.1/NFPA 54 (2012), Chapter 8, “Inspection, Testing, and Purging” and, where called for by local authority having jurisdiction, shall be tested in accordance with Annex C of the NFGC, “Suggested Method for Checking for Leakage.” Also, where called for by the local authority having jurisdiction, the response procedures documented in Annex D of the NFGC, “Suggested Emergency Procedures for Gas Leaks” shall be carried out.
1.) National Fuel Gas Code (NFGC), ANSI Z223.1/NFPA 54 (2012), Chapter 8, “Inspection, Testing, and Purging” represents national consensus standard requirements for inspecting and testing for leaks from natural gas and LP gas systems. The RESNET standard should not implement ad hoc and potentially conflicting requirements with this national consensus standard.
2.) If RESNET includes conflicting requirements, it will have violated its standards development procedures, which under Section 10.8.1 of the “RESNET Standards Development Process” (found in the document, “Standards Development Policy and Procedures Manual,” Version 1.1, January 2, 2012) state:
To date, neither the SMB nor the SDC have contacted American Gas Association (AGA), the American National Standards Institute (ANSI) secretariat for the National Fuel Gas Code (NFGC), ANSI Z223.1/NFPA 54 with respect to inconsistencies and incompatibilities of current and proposed CAZ testing provisions of Section 807 with the NFGC. It is inconceivable that neither the SMB nor the SDC would be familiar with the NFGC and its scope of coverage for combustion air and venting of gas-fired appliances. AGA invites RESNET to work with the NFGC Code Committee and the secretariat for addressing these inconsistencies and incompatibilities in the current RESNET standard text.
3.) Annex C of the NFGC, “Suggested Method for Checking for Leakage” and Annex D, “Suggested Emergency Procedures for Gas Leaks” represent informative appendices of the NFGC but in no way defer national consensus standard coverage to other organizations, which may implement conflicting coverage. The NFGC Committee has carefully reviewed requirements for mandatory and informative sections of the Code and has determined that Annex C and D belong as informative appendices that may be required by local authorities having jurisdiction, but national model code requirement are not warranted. RESNET should infringe upon this local authority governance of requirements for natural gas and LP gas systems.
Delete the text in Section 806 in its entirety and replace it with the following:
806 GAS LEAKAGE Natural gas and LP gas systems should be tested and inspected in accordance with the National Fuel Gas Code (NFGC), ANSI Z223.1/NFPA 54 (2012), Chapter 8, “Inspection, Testing, and Purging” and, where called for by local authority having jurisdiction, shall be tested in accordance with Annex C of the NFGC, “Suggested Method for Checking for Leakage.” Also, where called for by the local authority having jurisdiction, the response procedures documented in Annex D of the NFGC, “Suggested Emergency Procedures for Gas Leaks” shall be carried out.
Comment #18Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 8Paragraph / Figure / Table / Note: 808.7.3Comment Type: TechnicalComment: There needs to be an exception for vent terminations that are inaccessible. Proposed Change: 808.7.3 Take sample during worst-case depressurization test and/or under natural conditions, as required by paragraphs 807.12, 807.13 and 807.14. Record the CO level. Exception: the CO test sample is optional when the vent termination is inaccessible, or accessible only with an extension ladder or by climbing onto the roof.
There needs to be an exception for vent terminations that are inaccessible.
808.7.3 Take sample during worst-case depressurization test and/or under natural conditions, as required by paragraphs 807.12, 807.13 and 807.14. Record the CO level. Exception: the CO test sample is optional when the vent termination is inaccessible, or accessible only with an extension ladder or by climbing onto the roof.
Comment #19Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 8Paragraph / Figure / Table / Note: 808.5Comment Type: EditorialComment: The wording is incorrect--"are" is redundant. Adding "recorded as" would clarify the intent since the actual measurement procedure may be taken directly or calculated from CO and O2 measurements. Proposed Change: ...the CO concentrations are shall be recorded as "air free" measurements....
The wording is incorrect--"are" is redundant. Adding "recorded as" would clarify the intent since the actual measurement procedure may be taken directly or calculated from CO and O2 measurements.
...the CO concentrations are shall be recorded as "air free" measurements....
Comment #20Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 7Paragraph / Figure / Table / Note: 808.1Comment Type: TechnicalComment: Once the CAZ tests have been conducted under both worst-case and natural conditions, the idea that the auditor would need to continue monitoring ambient CO during the remainder of an audit is unneccessary. The below markup reverts to the original language but with clarifications for more complete testing, and updated references. Proposed Change: 808.1 CO testing of ambient air shall be performed continuously when initially entering a property, when first entering any CAZ, and while performing a Worst Case Depressurization Test and/or under natural conditions, the tests as required by paragraph 807.143 through 807.16. Ambient CO shall be measured continuously during the energy audit.
Once the CAZ tests have been conducted under both worst-case and natural conditions, the idea that the auditor would need to continue monitoring ambient CO during the remainder of an audit is unneccessary. The below markup reverts to the original language but with clarifications for more complete testing, and updated references.
808.1 CO testing of ambient air shall be performed continuously when initially entering a property, when first entering any CAZ, and while performing a Worst Case Depressurization Test and/or under natural conditions, the tests as required by paragraph 807.143 through 807.16. Ambient CO shall be measured continuously during the energy audit.
Comment #21Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 7Paragraph / Figure / Table / Note: 808.1Comment Type: TechnicalComment: correction to suggested reference for continuous CO monitoring Proposed Change: 808.1 CO testing of ambient air shall be performed continuously when initially entering a property, when first entering any CAZ, and while performing a Worst Case Depressurization Test and/or under natural conditions, the tests as required by paragraph 807.14 sections 806 through 808. Ambient CO shall be measured continuously during the energy audit.
correction to suggested reference for continuous CO monitoring
808.1 CO testing of ambient air shall be performed continuously when initially entering a property, when first entering any CAZ, and while performing a Worst Case Depressurization Test and/or under natural conditions, the tests as required by paragraph 807.14 sections 806 through 808. Ambient CO shall be measured continuously during the energy audit.
Comment #22Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 1Paragraph / Figure / Table / Note: 806.1Comment Type: TechnicalComment: "Must provide an alarm when detecting the LEL exceeds 10%. This is the alarm condition for evacuating the building." This section is supposed to be defining the equipment requirements, but it appears to have a directive to act (to evacuate the building) under the noted circumstance. Delete this bulleted item, and (if evacuation is actually the desired action) the procedure and defined action should be explicitly stated in 806.2 or a subsequent paragraph. (for example, if gas concentration exceeds 10% of LEL in an isolated area immediately adjacent to an identified leak vs. in ambient air.) No guidance is given; it needs to be detailed in the procedure if this is the intent. Proposed Change: Must provide an alarm when detecting the LEL exceeds 10%. This is the alarm condition for evacuating the building.
"Must provide an alarm when detecting the LEL exceeds 10%. This is the alarm condition for evacuating the building."
This section is supposed to be defining the equipment requirements, but it appears to have a directive to act (to evacuate the building) under the noted circumstance. Delete this bulleted item, and (if evacuation is actually the desired action) the procedure and defined action should be explicitly stated in 806.2 or a subsequent paragraph. (for example, if gas concentration exceeds 10% of LEL in an isolated area immediately adjacent to an identified leak vs. in ambient air.) No guidance is given; it needs to be detailed in the procedure if this is the intent.
Comment #23Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 1Paragraph / Figure / Table / Note: 806.2Comment Type: TechnicalComment: Add a provision for testing at or near floor level when entering a confined space containing LP gas distribution pipes. LP gas is heavier than air and the added odor may not be immediately detectable when standing. Proposed Change: 806.2.1 When entering a confined space containing LP gas distribution pipes, test the ambient air at or near (within 6 inches of( the floor level.
Add a provision for testing at or near floor level when entering a confined space containing LP gas distribution pipes. LP gas is heavier than air and the added odor may not be immediately detectable when standing.
806.2.1 When entering a confined space containing LP gas distribution pipes, test the ambient air at or near (within 6 inches of( the floor level.
Comment #24Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 2Paragraph / Figure / Table / Note: Section 807.2Comment Type: EditorialComment: Proposed editorial change to improve clarity. Proposed Change: Add the sub-heading “Test Procedure” to Section 807.2 and renumber subsequent sections as sub-subections of Section 807.2.
Proposed editorial change to improve clarity.
Add the sub-heading “Test Procedure” to Section 807.2 and renumber subsequent sections as sub-subections of Section 807.2.
Comment #25Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 2Paragraph / Figure / Table / Note: Section 807Comment Type: EditorialComment: Proposed editorial change to correct capitalization and a typo. Proposed Change: “..shall require an aAppliance vVenting (sStandardized dDepressurization) test to be performed using the protocol in Section 807.”
Proposed editorial change to correct capitalization and a typo.
“..shall require an aAppliance vVenting (sStandardized dDepressurization) test to be performed using the protocol in Section 807.”
Comment #26Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 3Paragraph / Figure / Table / Note: Section 807.3.3Comment Type: EditorialComment: Revise Section for clarity and move last sentence to a separate Section. Proposed Change: Begin to measure the CO level in the CAZ using the equipment and test procedures in Section 808.2 and 808.3. Continue to measure the CO level for the remainder of this test procedure and halt the test procedure if CO rises above 35 ppm in the CAZ. During all depressurization testing measure the CO level in the CAZ. Halt testing if CO rises above 35 ppm in the CAZ using the equipment and test procedures in sections 808.2 and 808.3. 807.2.2 Inspect furnace heat exchangers for cracks, openings or excessive corrosion. New Section: Inspect furnace heat exchangers for cracks, openings or excessive corrosion.
Revise Section for clarity and move last sentence to a separate Section.
Begin to measure the CO level in the CAZ using the equipment and test procedures in Section 808.2 and 808.3. Continue to measure the CO level for the remainder of this test procedure and halt the test procedure if CO rises above 35 ppm in the CAZ. During all depressurization testing measure the CO level in the CAZ. Halt testing if CO rises above 35 ppm in the CAZ using the equipment and test procedures in sections 808.2 and 808.3. 807.2.2 Inspect furnace heat exchangers for cracks, openings or excessive corrosion.
New Section: Inspect furnace heat exchangers for cracks, openings or excessive corrosion.
Comment #27Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 3Paragraph / Figure / Table / Note: Section 807.7Comment Type: EditorialComment: Clarify the intent of this section with regards to Padj when the auxiliary exhaust fan is used. Proposed Change: If one or more fireplaces or solid fuel stoves are present that are not direct vent appliances, then operate an auxiliary exhaust fan to exhaust 300 cfm for an open hearth fireplace, or to exhaust 100 cfm for a solid fuel stove or fireplace with glass doors. If the auxiliary exhaust fan is operated during the test, then Padj shall equal 0 when calculating the target CAZ pressure in Equation 807.3.”
Clarify the intent of this section with regards to Padj when the auxiliary exhaust fan is used.
If one or more fireplaces or solid fuel stoves are present that are not direct vent appliances, then operate an auxiliary exhaust fan to exhaust 300 cfm for an open hearth fireplace, or to exhaust 100 cfm for a solid fuel stove or fireplace with glass doors. If the auxiliary exhaust fan is operated during the test, then Padj shall equal 0 when calculating the target CAZ pressure in Equation 807.3.”
Comment #28Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 3Paragraph / Figure / Table / Note: Section 807.7.1Comment Type: EditorialComment: Correct a typo and improve clarity. Proposed Change: As an alternative to the auxiliary exhaust flows specified in 807.67 the target CAZ pressure in Equation 807.3 807.10 may be adjusted as follows:
Correct a typo and improve clarity.
As an alternative to the auxiliary exhaust flows specified in 807.67 the target CAZ pressure in Equation 807.3 807.10 may be adjusted as follows:
Comment #29Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 3Paragraph / Figure / Table / Note: Section 807.7.2Comment Type: EditorialComment: Improve clarity of this Section. Proposed Change: For an open hearth fireplace, the pressure adjustment Padj shall either be calculated using Equation 807.1 or determined using Table 807.2, where the CFM50 value is the envelope leakage determined using the envelope leakage CFM50 from Section 802 of this standard or use Table 807.2.
Improve clarity of this Section.
For an open hearth fireplace, the pressure adjustment Padj shall either be calculated using Equation 807.1 or determined using Table 807.2, where the CFM50 value is the envelope leakage determined using the envelope leakage CFM50 from Section 802 of this standard or use Table 807.2.
Comment #30Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 4Paragraph / Figure / Table / Note: Section 807.7.3Comment Type: EditorialComment: Improve clarity of this Section. Proposed Change: For a solid fuel stove or fireplace with glass doors, the pressure adjustment Padj shall either be calculated using Equation 807.2 or determined using Table 807.3, where the CFM50 value is the envelope leakage determined using the envelope leakage CFM50 from Section 802 of this standard or use Table 807.3.
For a solid fuel stove or fireplace with glass doors, the pressure adjustment Padj shall either be calculated using Equation 807.2 or determined using Table 807.3, where the CFM50 value is the envelope leakage determined using the envelope leakage CFM50 from Section 802 of this standard or use Table 807.3.
Comment #31Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 3 and 5Paragraph / Figure / Table / Note: Section 807.4.3 and Section 807.8Comment Type: EditorialComment: Improve clarity of these two Sections through an editorial change. Proposed Change: In Section 807.8: "If there is a Forced Air system (FAS) turn it off and cClose all interior doors to rooms without exhaust fans. For rooms without exhaust fans that are between a room with and exhaust fan and the CAZ leave the door open." Add this equipment type to Section 807.4.3: “Opening all interior doors, ensuring that all vented appliances, Forced Air Systems (FAS), and exhaust fans have been turned off. If the CAZ is in a closet or an enclosed utility room, then the CAZ door shall be closed."
Improve clarity of these two Sections through an editorial change.
In Section 807.8:
"If there is a Forced Air system (FAS) turn it off and cClose all interior doors to rooms without exhaust fans. For rooms without exhaust fans that are between a room with and exhaust fan and the CAZ leave the door open."
Add this equipment type to Section 807.4.3:
“Opening all interior doors, ensuring that all vented appliances, Forced Air Systems (FAS), and exhaust fans have been turned off. If the CAZ is in a closet or an enclosed utility room, then the CAZ door shall be closed."
Comment #32Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 5Paragraph / Figure / Table / Note: Section 807.8Comment Type: EditorialComment: Clarify the intent of this Section through an editorial change. Proposed Change: If there is a Forced Air system (FAS) turn it off and close all interior doors to rooms without exhaust fans. For rooms without exhaust fans that are between a room with and exhaust fan and the CAZ leave the door open.Close the interior door of all rooms except those that meet either of the following conditions: a) the room has an exhaust fan or b) the room is between an exhaust fan and the CAZ. For example, for a master suite with a connected bathroom that has an exhaust fan, do not close either the door to the bathroom or the door to the master suite.
Clarify the intent of this Section through an editorial change.
If there is a Forced Air system (FAS) turn it off and close all interior doors to rooms without exhaust fans. For rooms without exhaust fans that are between a room with and exhaust fan and the CAZ leave the door open.Close the interior door of all rooms except those that meet either of the following conditions: a) the room has an exhaust fan or b) the room is between an exhaust fan and the CAZ. For example, for a master suite with a connected bathroom that has an exhaust fan, do not close either the door to the bathroom or the door to the master suite.
Comment #33Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 5Paragraph / Figure / Table / Note: Section 807.9Comment Type: GeneralComment: Please clarify in this Section the phrase, "If the room is depressurized..". Should the depressurizatoin of the room be measured relative to the main body of the house or relative to the outside?
Please clarify in this Section the phrase, "If the room is depressurized..". Should the depressurizatoin of the room be measured relative to the main body of the house or relative to the outside?
Comment #34Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 6Paragraph / Figure / Table / Note: Section 807.14.1Comment Type: EditorialComment: Clarify the intent of this Section through an editorial change. Also, clarify whether the appliances in Section 807.14.1 are to remain turned on after testing in this Section, 807.14.1, is complete. Proposed Change: Leave the vented combustion appliance that was tested in Section 807.13 turned on. Identify the group of For combustion appliances that are not commonly vented (i.e., sharing the same flue) with this vented combustion appliance., tTurn on each appliance in this group other combustion appliances (with other smaller appliances still operating within the CAZ) one at a time, in order of increasing capacity, and repeat Section 807.13.1 through 807.13.3 for every appliance that is on after each one is turned on. Note that once an appliance is turned on, it shall remain on until the testing in this Section, 807.14.1, is complete.
Also, clarify whether the appliances in Section 807.14.1 are to remain turned on after testing in this Section, 807.14.1, is complete.
Leave the vented combustion appliance that was tested in Section 807.13 turned on. Identify the group of For combustion appliances that are not commonly vented (i.e., sharing the same flue) with this vented combustion appliance., tTurn on each appliance in this group other combustion appliances (with other smaller appliances still operating within the CAZ) one at a time, in order of increasing capacity, and repeat Section 807.13.1 through 807.13.3 for every appliance that is on after each one is turned on. Note that once an appliance is turned on, it shall remain on until the testing in this Section, 807.14.1, is complete.
Comment #35Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 6Paragraph / Figure / Table / Note: Section 807.14.2Comment Type: EditorialComment: Clarify the intent of this Section through an editorial change and the correction of a typo. Proposed Change: Leave the vented combustion appliance that was tested in Section 807.13 turned on but turn off all other vented combustion appliances. Identify the group of combustion appliances that are commonly vented (i.e., share the same flue) with this vented combustion appliance. Turn on each appliance in this group For combustion appliances that are commonly vented (sharing the same flue), test combustion appliances one at a time, in order of increasing capacity, and repeat Section 807.13.1 through 89713.3807.13.3 for the two appliances that are on, then turn off the appliance in this group. for every appliance. Do not leave on an appliance after it has been tested.
Clarify the intent of this Section through an editorial change and the correction of a typo.
Leave the vented combustion appliance that was tested in Section 807.13 turned on but turn off all other vented combustion appliances. Identify the group of combustion appliances that are commonly vented (i.e., share the same flue) with this vented combustion appliance. Turn on each appliance in this group For combustion appliances that are commonly vented (sharing the same flue), test combustion appliances one at a time, in order of increasing capacity, and repeat Section 807.13.1 through 89713.3807.13.3 for the two appliances that are on, then turn off the appliance in this group. for every appliance. Do not leave on an appliance after it has been tested.
Comment #36Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 7Paragraph / Figure / Table / Note: Section 808.1Comment Type: EditorialComment: The text in Section 808 and Section 808.1 is identical. Delete Section 808.1 and renumber the subsequent sub-sections accordingly. Proposed Change: 808.1 Ambient CO shall be measured continuously during the energy audit.
The text in Section 808 and Section 808.1 is identical. Delete Section 808.1 and renumber the subsequent sub-sections accordingly.
808.1 Ambient CO shall be measured continuously during the energy audit.
Comment #37Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 8Paragraph / Figure / Table / Note: Section 808.5Comment Type: EditorialComment: Correct two minor typos in this Section. Proposed Change: In sections 808.6, 808.7 and 808.8 the CO concentrations are shall be "air free" measurements. All CO measurements, with the exception of ambient air measurements, shall be adjusted to air free values either using the built-in capabilities of the test equipment or using the following equation and O2 measurement (in ppm).
Correct two minor typos in this Section.
In sections 808.6, 808.7 and 808.8 the CO concentrations are shall be "air free" measurements. All CO measurements, with the exception of ambient air measurements, shall be adjusted to air free values either using the built-in capabilities of the test equipment or using the following equation and O2 measurement (in ppm).
Comment #38Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 8Paragraph / Figure / Table / Note: Section 808.6.2Comment Type: EditorialComment: Correct minor typo through editorial change. Proposed Change: CO readings should be taken at after at least 5 minutes of operation.
Correct minor typo through editorial change.
CO readings should be taken at after at least 5 minutes of operation.
Comment #39Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 8Paragraph / Figure / Table / Note: Section 808.6.3 and Section 808.7.3Comment Type: EditorialComment: Improve clarity by referencing the proper name of the revised test in these two Sections. Proposed Change: 808.6.3 Take sample during worst-case Appliance Venting (Standardized dDepressurization) test and/or under natural conditions, as required by paragraphs 807.12, 807.13 and 807.14. Record the CO level. 808.7.3 Take sample during worst-case Appliance Venting (Standardized dDepressurization test and/or under natural conditions, as required by paragraphs 807.12, 807.13 and 807.14. Record the CO level
Improve clarity by referencing the proper name of the revised test in these two Sections.
808.6.3 Take sample during worst-case Appliance Venting (Standardized dDepressurization) test and/or under natural conditions, as required by paragraphs 807.12, 807.13 and 807.14. Record the CO level.
808.7.3 Take sample during worst-case Appliance Venting (Standardized dDepressurization test and/or under natural conditions, as required by paragraphs 807.12, 807.13 and 807.14. Record the CO level
Comment #40Amendment: Proposed Amendment on Revision of the Gas Leakage Test Portion of RESNET 8 (SECTIONS 806-808)Page Number: 8Paragraph / Figure / Table / Note: Section 808.7.2Comment Type: GeneralComment: Section 808.7.2 requires that readings be taken “at steady state” while Section 808.6.2 does not. Is this intentional? If not, then the two Sections should be aligned by either adding this phrase to Section 808.6.2 or removing the phrase from Section 808.7.2. If it is intentional, then perhaps it should be clarified how the Rater is to assess whether steady-state conditions have been reached.
Section 808.7.2 requires that readings be taken “at steady state” while Section 808.6.2 does not. Is this intentional?
If not, then the two Sections should be aligned by either adding this phrase to Section 808.6.2 or removing the phrase from Section 808.7.2.
If it is intentional, then perhaps it should be clarified how the Rater is to assess whether steady-state conditions have been reached.
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