RELEVANT TO CSA C445 and C447
NOTE: CSA International has reviewed
the two installation standards pertaining to earth energy systems (C445
for residential; C447 for commercial) and combined both into CSA C448,
which will take effect early in 2002. The following letter was submitted
by EESC to the review process, in order to summarize a number of concerns
for the EE industry in Canada.
This document ... reflects the input received
from a small number of directors and industry participants (following distribution
of your questionnaire form) and reflects the experience of the author in
coping with the realities of the 445 standard under the former CEEA program.
The document sequentially addresses the 14 response areas on your three-page
questionnaire, and includes both 'pro' and 'con' aspects.
To invoke a brand name in standard would
be unacceptable to the non-included fluid manufacturers, and could restrain
trade and inhibit evolution to a new 'wonder fluid' if one were formulated
in future. It would allow system pressure drops to be standardized (depending
on the number of fluids specified) and may lead to reductions in wholesale
fluid prices if the measure helps to develop economy of scale.
Sizing of heat
Many of the mistakes in CEEA's program
were due to under-sizing, both of unit (based on heat loss) and on loop
lengths (to minimize trenching costs). On the former, many problems are
directly related to the inability of dealers to calculate a heat loss,
or an attempt to minimize system installation costs. The standard must
mandate 100% of heat demand; the issue is how much is to be provided by
the EE unit. Does the industry agree on the calculations that show 60%
to be optimal benefit? If a sizing percentage is specified, would it be
based on the gross or the net heat loss (the implications for commercial
cooling load impacts).
To make sizing requirements more specific,
it could become very convoluted based on all inputs (heat loss, cooling
load, soil conditions, etc) and make it difficult for many dealers to comprehend.
In light of sizing (unit and loop) as the #1 problem under the CEEA program,
something must be done. If the standard invokes a computer program, there
is discrimination against non-specified programs. If more than one is specified,
there are problems if they are not compatible. Should the industry design
a composite to address all issues, or would the product be too generic
to be of value? If design concerns could be addressed and the industry
agree, a standardized loop length would be the greatest boost to the industry.
If a dealer fuses the pipe properly and
pressure-tests, there should be minimal failures (excepting GS4, the CEEA
program had only two reported failures of pipe that were not directly due
to human incompetence). Few dealers pressurized the loop to the 445 specification
due to inadequate equipment. Of those that did, most apparently boosted
the pressure after the loop was covered (for expediency with trenchers).
Proper pressure testing would identify any fusing errors at a timely stage.
One recommended option is to mandate a 24-hour test, where the pressure
would be set to (example) 160 PSI, and be allowed to fluctuate by x% during
that period. This monitoring could be done by the building owner, but there
is a cost factor with the equipment required. To formalize reporting procedures,
the report must be sent somewhere. To whom, and what is the 'penalty' for
non-compliance? One recommended option for the residential market is to
have a monitoring checklist, where the owner confirms post-installed performance
levels, such as pressure, temperature, etc, and serves as a 'sign off'
by the owner for proper installation practices. Stringent testing procedures
would be very helpful if: the cost to test were minimal; there is some
verification of the results (ie: not self-reporting by dealer); there is
some accountability by someone if something goes wrong.
Your question should be: should grouting
be required? The current requirements only contain three conditions: must
be grouting; tremie; bottom-to-top. If you agree with the need for grouting,
it has to be bottom-up. If dealers are allowed discretion in the "totality"
of grouting, there will be problems. Few dealers would know the correct
sub-surface conditions. Mandating different grouting requirements would
confuse them. Again, monitoring / verification becomes key. Also, if there
is a problem, who is accountable?
I thought that bentonite was the most
effective in cost and performance, and the grout of choice. If you specify
brand names, you will have problems. If you specify certain types for certain
applications, you must ensure that someone is accountable for the wrong
selection. The more complex the formula, the less likely that the industry
can install without mistake, and the liability for making a selection from
a complex menu would be the dealers. Combining 445 and 447 makes eminent
sense IF you want a standard (that has credibility and teeth of enforcement
and the benefit of good industry practice) and IF there are no problems
for the engineers and architects who approve small commercial buildings.
A commercial system almost certainly would require some form of verification
or certification at commissioning, so the process would need to be easily
adaptable to a residential unit of any size (ie: the same requirement for
a 2-ton supplementary unit as for a 10,000 ft2 commercial system). There
are advantages and disadvantages to maintaining a dichotomy between applications
(residential and commercial) as opposed to size of building.
A standard(s) is only as strong as its
enforcement, and there are five obvious ways to achieve compliance:
inspection by industry body (similar to
Each has pros and cons. All have a cost element,
and higher prices are not in the best interests of the industry ... but
nor are poor installations. A major deficiency in 445 is the lack of 'responsibility'
by equipment manufacturers, who can completely disavow any liability for
poor installation by an approved dealer. A proposal was made to develop
a 'Lloyds of London' insurance program, where participating manufacturers
approve a pool of authorized dealers in whom the manufacturers have confidence.
All parties (manufacturer, dealer, consumer) put a premium into a reserve
on an actuarial basis to cover well-defined contingencies. A proper warranty
would be offered to participating parties, and the additional premium would
be promoted as a 'rolls royce' installation with protection. If anything
went wrong under the well-defined parameters, it would be corrected. If
outside the parameters, tough. The standard(s) could also provide best-practice
guidelines and state that compliance is voluntary. If someone were concerned
with quality of installation, there would be verification measures to ensure
compliance and legal recourse if eligible problems occured. If the owner
chose not to bother with a test at commissioning, there would be no guarantee
that the system would work as quoted (caveat emptor).
inspection by the manufacturer (possibly
the ultimate liable party);
inspection by government agency (fed-prov-mun-utility);
inspection by for-profit company, perhaps
for interested parties only;
self-inspection by building owner to specific
Adoption of ISO:
Most units sold in Canada are manufactured
in the US and rated to ARI (required for participation in various state
incentive programs). When the US migrates to ISO, continued use of 446
will isolate the Canadian industry even more. There is sufficient criticism
of the technical quality of 446 that it makes sense to harmonize with the
US and to migrate to ISO as quickly as possible. The background debate
over earth energy systems in the federal EnerGuide program and other programs,
indicates that all units in Canada should be performance rated. Migration
to ISO likely would precipitate one-time support from government to ensure
that all Canadian product is rated and ready for market penetration.
Extensive legal action under the CEEA
program offers evidence of many deficiencies in 445 that need to be addressed.
Some random points include:
- circulating pumps are not part of the
heat pump 'system,' and dealers are allowed to configure their own, leading
to failures that are not manufacturer problems;
Numerous other problems with 445 were identified
in legal actions involving CEEA and installing dealers, but are of a fine-tuning
nature at this stage. The danger with mandating specific clauses that may
evolve or change, is that the standard needs to be amended to incorporate
those changes. This imposes a disincentive to change. A national standard
should allow an annual 'procedure' document to be invoked which would (for
example) list the brand products of grout available for use under the standard.
It could dictate that the annual list must be released each year, to provide
- there is no correlation between the
loop sizing and capacity of heat pump;
- there is no protection against 'do it
- proliferation of manufacturer design
software leads to non-conforming heat loss estimates;
- most CEEA problems related to poor initial
design (heat loss calculations), yet there is lack of clarity and lack
of responsibility related to mistakes made at that stage;
- the problems with potassium acetate
indicate that there are loopholes;
- problems related to DX units when there
was no performance standard for DX units also indicate loopholes that need
to be plugged;
- it is unclear which department is the
'authority with jurisdiction'.
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(613) 371-3372 (371-EESC)
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