CEN WS 36 Doc. N045 - Comments... · 2008. 11. 14. · (12) ge I have read your description of...

Template for comments and Proposers/Secretariat observations Date: 10/11/2008 Document: prCWA 36 ver 3.0 (3-oct-08)

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Comment (justification for change) by the WS 36 participant Proposed change by the WS 36 participant Proposers/Secretariat observations

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A= Accept, NA = Not Accept, PA Partial Accept, CR Clarification

Required. GC= General Comment

1 Participant = CEN WS 36 registered participant; comments from the ISO/CS editing unit are identified by **) 2 Type of comment: ge = general te = technical ed = editorial NOTE Columns 1, 2, 4, 5 are compulsory.

page 1 of 98 ISO electronic balloting commenting template/version 2001-10

Notes by the Secretariat 1. Participants are asked to read all the Comments and Responses in order to have a complete overview of a particular issue. It is hoped that this will avoid the repetition of points of view as, in some cases, the comment given for one issue is good for another issue 2. For some cases, when relating to subject very close to the Unresolved Technical Issues (UTI) , reference to N035rev1 is made. 3. Some comments were translated by the Secretariat or slightly rephrased for clarity 4. Unless otherwise noted, responses are provided by the Proposers 5. In summary, 40 participants responded of which 33 agreed (82,5% approval) and 7 asked for modifications (ranging from editorial to asking that the work be stopped). 6. The 7 participants who asked for modifications submitted 244 comments. Out of these, approximately 68 were agreed to or partially agreed (code A or PA) and 120 rejected (code NA), while the rest were characterised as General comments (GC) or required clarification (CR). The previous numbers are only indicative as the counting does not take into account many comments that were similar or identical and also the fact that, in some “rows” of the table, multiple comments were contained General statement by the Proposers

There is clear evidence that some participants (Appellants / Mineral Wool companies) reject part of the Business Plan: 3 test cells minimum, ask for the CWA title to be changed and ask that the project be stopped (please refer to items highlighted in mauve)

-

ACTIS AISLAMIENTOS/CH (1)

Ge The new CWA36 that has been completed and finalized corresponds to what I‘ve expected in term of in situ testing protocol as well as in situ data analysis. I agree without any additional comments.

Thank you for your support

ORION/SC (2)

Ge For the first time, opportunity is given to PME to propose alternative method in order to evaluate the thermal performances of multifoil insulation products. I would like to join the other supporters by giving my agreement on the last version of the CWA36.


ACTIS Insulation UK/MK

(3)

Ge I would like to express my satisfaction to finally see the CWA36 now complete and ready for the experimental evaluation to begin.

I support the CWA36 version 3 and I consider this a better and more relevant test than laboratory methods which use only steady state conditions and take no consideration of important factors that can affect the thermal properties of insulation and building materials.


ACTIS S.A. FR/DB

(4)

Ge The “Complete CWA36” document updated and posted in the WS36 web site is finalized. It gives, from ACTIS point of view, a good, innovative and complementary method of test that I fully agree with.


ACTIFOND/PV

(5)

Ge No other European or national protocol of test permits to evaluate insulation materials in real conditions of test as the CWA36 proposed to do. As multifoil insulation consultant, I would like to give the chance to this method to be fully agreed by giving my support and especially on the


CEN WS 36 Doc. N045


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CWA36 version 3

ALBA / GR

(6)

Ge Thank you also for providing the final version of the CWA 36 document. I understand that you require confirmation of “agreement” or “opposition” to this. I therefore have pleasure in confirming my “agreement” to this document.


ALUTHERMO/LJ

(7)

Ge …meanwhile I wish to express my total agreement with the CWA 36 revision 3. This in situ test will bring up a new view on the thermal performance of any insulation material. I can therefore understand that some will be opposed to the launch of the RRT but scientifically speaking there are no arguments for it.


ATI /YB

(8)

Ge CWA 36 Ver.3.0 seems to us to be the most efficacious way of calculating Energy Saving .It seems to aim more efficiency and accuracy than usual laboratory internal tests


BM TRADA/DP (9)

Ge However, in the short term, I would like to say that BM TRADA are satisfied with the draft Workshop Agreement text so far as the basis for the Round Robin Trials


Com. Con. Ltd/JR (10)

Ge With reference to WS36 I am pleased to see this finally seems to be resolved and look forward to the start of the real testing.


DACHSYSTEME/HJG (11)

Ge I have read the material sent and I am in agreement with the content of CWA


DEG/HS

(12)

ge I have read your description of ""Complete CWA 36 rev 3 from 2008. 10.10 very carefully. Accordingly I will raise no objections and additionally I have no proposals for change.


DEL BA/TL (13)

Ge I give my agreement on the Complete and Final version of the CWA36 as it is proposed


EDILIZIA/AL (14)

Ge we are in accord with last version of CWA36 Thank you for your support

EEM/

MD (15)

ge A new important stage is now proceeding. I give my agreement on the new complete version of the CWA36 in order to give the possibility to validate it and permit its validation through experimental testing. In the near



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future I hope and wish that, the results of this new and alternative protocol of test, as suggested in the CMC report about the complaint, would be proposed as complementary information already given by conventional standardized methods.

HAPEJA/HR (16)

Ge No need to use long statement to say that I support the new and complete version of the CWA36.


HPC/SA

(17)

Ge HPC-SA represented by Regis LECUSSAN fully agree on the CWA36 rev 3 document and don't have any comment on it.


ISO IN./AV (18)

Whole Document

Ge I would like to give my full support to the document “complete CWA36” My company is very enthusiast and confident in the CWA36 version 3 that have been completed. Please find my agreement on it.


ITR/RB

(19)

Whole Document

Ge I would like to give my full support to the document "complete CWA36" My company is very enthusiastic and confident in the CWA36 version 3 that has been completed. Please find my agreement on it.


Malagoli/CDM

(20)

ge We see and we agree with the last version of your Workshop


NORMAPME/LG

(21)

Ge I want to express our support, for the version 3 of CWA36. We will respond in due time to version 4 after reading it thoroughly.


LENZING PLASTICS/RJ (22)

Ge I can confirm that we completely agree with the suggestion / position of the European Multifoil manufacturers


LTSA/

VB (23)

Ge I would like the WS36 Secretary to record my full support of the WS36 work in general and to the Complete CWA36 document in particular.


PPE MISTRAL ISOL/R

ge I’m quite happy to see the CWA36 ready at this time. It is useful to run now the RRT that will permit to confirm the viability of this new alternative and innovative method of evaluation of multifoil insulation products.



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M (24) Please note my full support on the project.

PREGIS/DL (25)

Ge Moreover I had already given my agreement for the previous version of CWA 36 and I repeat it for the complete and final version.


SFIRMM/AL (26)

The state of writing of the draft document CWA36 number 36, version 3.0 of October 2008 has reached a sufficient level now to enable the undertaking of trials on test cells, during a Round Robin Test. Indeed, the conditions which specify these trials, both at the level of the cells and their level of equipment (installation of insulation products, general conditions concerning climatic data, guarded chamber .. ), than both at the level of the leading of the trials (input data, recording .) are defined in a sufficient precise and complete way. Otherwise, a solid basis is presented for the use and the interpretation of collected data. It will allow the use of data even if some improvements can prove to be later useful, in the light of such an acquired experience. Thus, in the name of SFIRMM, I approve this document so that it can be validated and applied, particularly firstly for a Round Robin Test


SAME/FS (27)

ge SA.M.E. is in accord with the final version of CWA36. Thank you for your support

SIMET/EA (28)

ge I read the CWA 36 version 3 and I like it .


TRADA/VK (29)

Ge We are satisfied with the draft Workshop Agreement text as the basis for the Round Robin Trials. We would expect the methodology to be further refined as a results of the RRT, and that is one of the aims of doing them.


TECOS/AM (30)

Ge After examining the document cwa 36, we think it is extremely important to proceed and we agree with all the highlighted modifications


U. Of Toulouse/MM (31)

Ge I wanted to tell you that, as a member of the Modelling Group, I fully agree with the content of the CWA.

VALTECH/EV (32)

Ge I would like to congratulate the good job achieved by the chairman, secretary and also the Modelling group that permit to finalise the complete CWA36 that I agree and support in spite of the strong opposition from



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competitors to the multifoil insulation products who have, in my point of view, no interest in this matter, except to protect their own market by stopping the lot of efforts made in the WS36.

PAROC/JF (33.1)

Whole document

ge It is complicated to give all the reasons for the comments below, they are very technical and should need a thorough discussion in the WS, but there has been very few opportunities to discuss technical issues, and in most cases the discussion has ended in a vote (it is not possible to vote on physical laws) or then the comments or proposals have been neglected.

The Unresolved Technical Issues (UTI) that have been identified as fundamental technical issues have been answered electronically. An additional and voluntary physical meeting which was organised by the Proposer has been held, all items discussed, for most of them a solution was found with no fundamental problems. GC

PAROC/JF (33.2)

Whole document

ge Change “in situ” by a relevant wording, e.g. “in a cell test/ in test cells/comparative test”

Objections to the use of in situ have been discussed and the objections were answered. In situ has been accepted by the majority of participants. The Commenter gives no obvious reasons for such a change.

This is in opposition to the title of the WS36 and Business Plan which is already agreed. NA

STGOBAIN/AK

(34.1)

- In general I still don’t see the need for use of 3 test cells, especially the one with “traditional” insulation material is redundant. In fact you measure with two standards. For all constructions (floor, wall) except the roof you accept that their in situ performance is the same as the declared values, only for the roof you say you need two constructions to show the difference. If all materials have a certain factor to come from declared to design value how can you find out what these factors are by changing only 1 part of the construction?

Reconsider the complete WS36, technically it is with poor foundations. Results of the measurement will never give the result that is in the scope of the WS36 agreement. My advice is to stop this work.

This is in opposition to the title of the WS36 and Business Plan which is already agreed. NA

The comment represents a complete rejection of the CWA by the Commenter.

The Commenter has totally rejected the principles for the CWA as set down in the Business Plan.

After all the discussion on


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such basic elements of the CWA and the rejection of such proposals by the majority, these comments at this late stage in the process shows a total disregard for the normal methods of working in CEN technical committee work.

STGOBAIN/AK

(34.2)

- It is wrong to exclude the periods because of thermal inertia. This is part of the total system and is a thermal effect, although the effect could be low.

Reconsider the complete WS36, technically it is with poor foundations. Results of the measurement will never give the result that is in the scope of the WS36 agreement. My advise is to stop this work.

It is not understood to what specific part of the text of the CWA the commenter is referring to. Please clarify. CR

The comment represents a complete rejection of the CWA by the Commenter. The Commenter has totally rejected the principles for the CWA as set down in the Business Plan. NA

STGOBAIN/AK

(34.3)

The ratio external surface/volume of the designed test cell is app. 3.

Your proposal is to have maximum 3,8 for n50Pa for a surface/volume ration of 0,75. For this test cell it means that the final air tightness at 50 Pascal is around 15! This is the old comparison method used by certain companies. With mineral wool insulation installed in a proper way you can reach lower than 1 (evidence see e.g. WG12 report N111). With these high values you can’t exclude energy loss by ventilation at all. Total energy use by this ventilation loss is much higher then the transmission loss. And this leads to wrong conclusions!

Reconsider the complete WS36, technically it is with poor foundations. Results of the measurement will never give the result that is in the scope of the WS36 agreement. My advice is to stop this work.


The ratio is around 1,5 for the RRT suggested design. This is not general for the CWA36, because other ratios can be used.

N111 refers to concrete buildings and, even for that, great efforts have been required to achieve a low level of air tightness.

According to the laws of physics, the exponential


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function of air infiltration rate depends on the difference of pressure. Thus, Zero wind = negligible difference of pressure = negligible air exchange rate = negligible associated heat losses by air exchange.

STGOBAIN/AK

(34.4)

The mentioned accuracy of the temperature sensors that are used in the construction is +- 0,1K. Their location is not specifically mentioned. It’s certain that there is not indicated that the temperature of the reflective foil should be measured.

If I make a calculation wit TRISCO for three setups the temperature of the surface of the internal and external plasterboard are:

1. 6 cm glass wool int. T 0,62 out T 18,32 2. 8 cm glass wool int. T 0,48 out T 18,70 3. mrf foil int. T 0,59 out T 18,40

So, if you look to the difference of 6 and 8 cm glass wool it’s only 0,2. That is the value you give in 6.3.1 as accuracy (+ or – 0,1K). In practice the value of the U value is more then 25%!

Reconsider the complete WS36, technically it is poor foundations. Results of the measurement will never give the result that is in the scope of the WS36 agreement. My advise is to stop this work.

Your comments are not true, not balanced, not constructive and not complying with the aim to support the Business Plan.


The comments on the position of temperature sensors are not true The positions are mentioned in 5.4.1.1, 5.4.1.2, etc …

- at mid-height in the centre of the roofed test cell (for example at approximately 1,5m above the floor)

- one in each corner (4 sensors): 0,05m from the floor, at 1m from each wall;

- at three different heights in the centre of the roofed test cell (3 sensors): one at 0,05m from the floor, one close to RTD sensor used for the regulation and one 0,05m from the roof.

(it is not true) The surface temperature of the product is proposed and


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described in section 5.4.1.3 & 5.4.4.

Concerning the calculation using TRISCO:

- There is not enough detail on the example given in order to be properly analysed. Additionally TRISCO is not available at EMM or EMM members (only Bisco). Please give a more precise report of your calculations and boundary conditions (same remark that you made about the Modelling Group interim report): which external condition? What does internal / external plaster board mean? …

- You asked originally to participate to the Modelling Group and then resigned. It would have been more constructive and productive to have proposed this work to the WG. Now it is very late to propose such matters.

- You are well informed about some of Modelling Group participants with whom you were able to share such results, why did you not to do that before?.

- In any case, this is a prediction (theory), and it could be pertinent for everybody to have such analysis during the RRT, that would be able to validate the accuracy


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of the TRISCO simulation, compared to recorded data, and also the analysis of the effect on accuracy.

- To be noted also that there is no reason that your comment cannot be applied for laboratory tests (such as guarded Hot Box). That seems to mean that the problem you raise is the same for conventional standardized measurements?.

STGOBAIN/AK

(34.5)

I have made calculations with Trisco for two constructions with a rafter. It is clear that the heat flow through the constructions is completely different for mrf and glass wool. How would you ever take this effect into account if you don’t measure the heat-flow. My answer: never. So it is impossible to fulfil the goal of the WS to come to values for the insulation material only.

Trisco comparison.zip

Please look at this, this is an important issue. Heat flow measurements should be obligatory.

Heat flows are proposed to be measured with HFM in section 5.4.4.

There is no need to compare the performance of MRF with Glass Wool, so no reason to consider your comments

The question of obligatory heat flow measurements was discusses as part of the UTI: electronically and at the UTI physical meeting, to which you were invited to participate but did not attend

During this UTI physical meeting, no evidence was identified about the claim for mandatory use HFM that are already described in the CWA36. NA

EPFA/KF (35.1)

General ed Throughout this prCWA the expression ‘due to’ is used incorrectly. In English the word ‘due’ is only associated correctly with time.

Replace ‘due to’ by ‘owing to’, ‘as a result of’, ‘because of’, ‘caused by’, ‘resulting from’ or appropriate words.

Thanks are given to the Commenter for providing a variety of appropriate words or phrases that can be used to replace “due”. A

Knauf/SW

General These comments are reiterated here and I await the There seems to be a


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(36.1) outcome of the discussions on the 5th November with interest. To reiterate, briefly, these comments raise concerns regarding Air tightness, Measurement of Heat Flux and Thermal Bridging. The fact that there is to be a discussion regarding these issues makes detailed comment redundant at this stage. It should be noted that I wished to attend this meeting but due to the late confirmation of the date, indeed until three weeks before the date proposed there was no indication that workshop management would grant this meeting, I cannot attend due to a completely inflexible prior engagement.

feeling by some of the Commenters within the group of Appellants that they have “rights” and the Proposers have only “responsibilities”. There are a number of commenters from the group of appellants who have total disregard for the majority opinion of WS participants. They are offered opportunities to discuss their comments and ignore the opportunity. But still insist on full and detailed answers to questions that have been discussed and responded to before.

The KNAUF Insulation representative was invited to the physical meeting to discuss the issues including that raised by Knauf. The date of the meeting was sent 2 week before the meeting according to the WS Rules,

- Knauf did not confirmed their participation as requested,

- A representative arrived late to the meeting (2pm)

- The Knauf representative was not a technical expert, as requested, but a lobbyist who has already spent a lot of the time of WS 36 raising many questions on procedure. The UTI physical meeting was strictly confined to technical matters. A request for technical experts was clearly indicated in the


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invitation.

If the UTI physical meeting was so important for KNAUF, they should have provided a relevant expert and arrived on time in accordance with announcement as Rockwool and Paroc did. GC

RW/HH

(37.1)

General GE The issue of v.3 is unacceptable for the following reasons:

• There has not been any attempt to obtain consensus as the comments to earlier versions have not been treated in a proper way. This doesn't imply that all comments shall be accepted, but consideration of comments and explanation of how the comments are handled must be a step in the process of reaching consensus.

• As an appellant to CWA 36 I have been asked to present a compilation of essential technical comments not being considered. This was delivered mid August but I have never received any response except a document number. I can now see from v.3 that none of the comments have had any influence on the text, except a minor and insufficient change of power adjustment to heat loss.

• I have also made a 12 page compilation of comments not handled properly, but this has not resulted in an answer. If such a situation had been experienced in the CEN EN standardisation system it would have resulted in full stop for further advancement of the document until a satisfactory resolution have been made.

1st bullet, Specific HH comments and responses has been provided showing that your comments have been considered completely or partially. Where partially consideration/ acceptance has been given the remainder will be considered, for example (“Shall / Should”). Thus we believe that we have dealt with your comments and therefore do not accept your comment.

2nd Bullet: the answers to the comments are contained in doc N035rev1 according to the list submitted by Appellants for UTI consideration. You have also participated to the 5th November physical meeting …

3rd bullet: You are reminded that CEN Workshops are intentionally different operationally from CEN Technical Committees producing ENs You have thought necessary to prepare these comments following your rejection of many of the working


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• A general change throughout v.3 is a change of tolerance from absolute values to standard deviations. This raises two questions:

1) The wisdom in applying statistics to a limited number of observations e.g. 3.

2) The result is a reduction of the tolerance as one standard deviation represents approximately 2/3 of the population. In some cases it may be serious and in others acceptable, but how can such a change be made without seeking approval from the CWA members.

decisions taken at the WS meetings. Your apparent insistence on special treatment runs counter to the spirit of CEN Workshops. The intention is that Workshops are intended for groups of like minded people and organizations. It has been clear from the pre Kick-Off meetings that your organisation has had the intention to stop the work of WS36. You had the opportunity to raise your concerns about UTI on the 5th Nov and receive scientific answers from the proposer (EMM) and their members.

4th Bullet: during the 5th

November meeting it was identified that the term standard deviation was used in a wrong manner. So the right information is X% around the mean value of the 3 test cells (for example). The reason why this was changed is following the discussion you personally raised during the 3rd PM about accuracy and the fact that there is no “truth” value. That means that for a specific requirement it is not relevant to calculate a difference compared to one specific value, but better to calculate a difference between the mean of the values. GC

RW/HH (37.2)

General

Additional comments to comments already given dated 2008 10 17. The conclusion based upon the comments given is that the prCWA as presented in v. 3 cannot be accepted.

The Commenter has been a member of the Appellants who came with two legal representatives that had been especially


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employed by Rockwool to stop the work of WS 36 (as stated in the Appellants letter to CEN CMC). The Commenter thus has apparently come to defend a point of view which opposes the very basic concepts on which the WS36 was started and on which the CWA has been developed. Thus it is not surprising that the Commenter states his disagreement with the handling of his comments. The commenter’s comments which have challenged the basics of the CWA have met with disapproval from the majority of participants. The UTI procedure as recommended by the CMC has been fulfilled and some solutions found to resolve the differences of opinion. Thus it considered unreasonable for the Commenters included in the Appellants to maintain their opposition. They have been offered alternative possibilities to record their disagreement and to record even their ideas for an “alternative test protocol” but the have not accepted such offers. GC

RW/HH

(37.3)

General I have commented on Clauses 1 to 7 and also presented extracts of unresolved technical issues and on comments being either ignored or answered by issues unrelated to the comment.

This has been done upon request from Mr. Ketchell, in spite of that, the technical issues have been resolved by voting without addressing technical content and the complaint on handling of comments dated August 14 is

See comments above GC


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up to now ignored.

The following addresses only clause 8 XL mat (38) General

all draft GE

One more time, we agree with the CWA rev 3 documents. We think that the method of work is in line with that described at the first meeting, the aim of the WS36. We continue to consider this CWA 36 as the method to determine the real insulation power of insulation products.


JS/URSA (39.1)

Title Thermal insulation – Building roof elements - Evaluation of thin multi-layer reflective Insulation Products by in situ Testing

GE At today's stage the prCWA doesn’t produce as a result the product performance but only the so called “global dynamic thermal performance”

Words “in situ” is misused. On international standards “in situ” means on real buildings (see as example ISO 140). Testing on a test cell is not an “in situ test”

Thermal insulation – Building roof elements - Evaluation of global dynamic thermal performance in a test cell containing or not Multi-layer reflective insulation products under weather conditions

The Title takes account of the majority of participants opinion that the use of “in situ” in the title and in the CWA is correct. NA

The definition of in situ is:

“in its natural position” or “In the original position. » or « In place, on site »

The comment that the words “in situ” are misused are not accepted. NA

Knauf/SW (36.2)

Title Evaluation of thin multi-layer reflective Insulation Products by in situ Testing

te It is not possible to describe this as an in situ test. The CWA describes a comparative test methodology with some weather effects.

Evaluation of thin multi-layer reflective Insulation Products by comparative Testing

The Commenter is mistaken, it is not a comparative test, and it is still an in situ test. NA

This is also in opposition to the title of the WS36 and Business Plan which is already agreed.

PAROC/JF (33.3)

Title Thermal insulation – Building roof elements - Evaluation of thin multi-layer reflective Insulation Products by in situ testing

ge The words “in situ” are misused. The CWA describes a comparative test method, which is thought to give a performance value to the used thin multi-layer reflective insulation, but this is not possible.

Thermal insulation – Building roof elements - Evaluation of thin multi-layer reflective Insulation Products by comparative testing

The Title takes account of the opinion of the majority of participants that the use of “in situ” in the title and in the CWA is correct. NA


The Commenter is mistaken, it is not a comparative test, and it is


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still an in situ test.

STGOBAIN/AK (34.6)

Title Building roof elements Add “sloped” This is the title of the Business Plan. No need to change the BP for that. It is sufficiently clear in the document and not fundamental. NA

JS/ URSA

(39.2)

All document

GE Changing “in situ” by “in a test cell” The Commenter is mistaken; it is still an in situ test. A

The definition of in situ is:

“in its natural position” or “In the original position. » or « In place, on site »


The comment that the words “in situ” are misused are not accepted.

BING /JR (40.1)

Foreword Ed It has been previously agreed that the completed CWA would contain only a list of registered participants that have approved the final CWA. Including all participants without stating which approved and do not approve would suggest tacit approval, which may not be the case. This is made clear on the front page of this document’ ‘The CEN Workshop agreement has been drafted and approved by a workshop of representatives of interested parties, the constitution of which is indicated in the foreword of this document’.

Revert to original phrasing to comply with original intent and page 1.

The commenter is advised to consult the CEN Website for the details of the lists that are associated with CWAs. NA

According to the CEN rules, two list will exist:

• Complete list of participants

• Detailed list of those who agree the CWA …

The regulations only foresee the list of participants to be included in the CWA. A list of supporters of the CWA is to be available at the CMC.

EPFA/KF (35.2)

Foreword Note, para.1

ed

The first paragraph is not a sentence insert ‘is’ between ‘participants’ and ‘to be’ The text of the Foreword will follow that of the CEN Template for CWAs


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PA EPFA/KF (35.3)

Foreword Note, para 2.

ge

The list referred to should show both approving and disapproving companies and organisation in order to demonstrate, if necessary, that there was continuing opposition to the CWA and hence no consensus to its issue.

Include both approving and disapproving bodiers.

The commenter is advised to consult the CEN Website for the details of the lists that are associated with CWAs NA

According to the CEN rules, two list will exist:

• Complete list of participants

• Detailed list of those who agree the CWA …

The regulations only foresee the list of participants to be included in the CWA. A list of supporters of the CWA is to be available at the CMC.

JS/ URSA

(39.3)

Foreword The list of companies / organizations which approved CWA must be at the same place than WS participants

NA

See above

Knauf /SW (36.3)

Forward

Page 4

ge

I understand that CEN rules state that the document is only to include the names of organisations that approve the document.

Note by the Secretariat: a list of registered participants approving the document to be completed at the end according to the CEN method of presentation

NA

See above

PAROC/JF (33.4)

Foreword ed No separate list should be available upon request, both lists shall be included.

The list of companies / organizations which approved CWA should be at the same place.

NA

See above

Knauf /SW (36.4)

Introduction Page 5

Whole introduction

te Steady state tests on products are the first fundamental step in understanding how real buildings and construction elements that include those products will perform. In situ testing should be used to inform the understanding of the differential between the anticipated performance of the building elements from the calculation models used to estimate thermal transmittance and what is achieved in reality. Using results from a comparative testing methodology to work back to a declared thermal value is not a scientifically valid technique. The comparative technique is useful if the amount of heat flux is also measured.

Whole introduction needs rewriting. If required am happy to suggest a text

Given the challenges made by the commenter on the existence of WS36 and the very basis of the test as proposed, it is difficult to believe that the resulting proposal would reflect the objectives as given in the Business Plan or reflect the current content of the CWA.

In any case you are at liberty to suggest another


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introduction that also complies with the BP, in order to be able to evaluate the benefit of it. PA

CWA36 it is not a comparative test protocol as explained several times, as well as in the BP and in the CWA related to test methods and not products…

JS/ URSA

(39.4)

Introduction

Pag 5

This CEN CWA has been developed in …...

Te This sentence is false.

From many years is well proved than steady state tests on products are well adapted to provide useful information in order to predict the thermal behaviour on a buildings even under dynamic conditions.

This sentence is contradictory / against / in conflict all European standards

Delete. If the commenter’s belief in the usefulness of conventional steady state test methods is correct, it will be confirmed by the results coming from the results according to clause 8.2 of the CWA.

A fundamental issue with the use of conventional methodologies to predict the effect of dynamic weather conditions is that the applier of the differing factors has to have a profound knowledge of the weather conditions which will apply. Whereas the in situ test method provides real life weather conditions and not estimations or predictions.

The Commenter refers to traditional, homogeneous, dense materials. CWA36 is dealing with multifoil reflective insulation with air gaps. From the experience of the proposer steady state tests are not sufficient.

In any case, the CWA36 gives complementary information of steady state results, whatever they are prejudged as


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relevant or not. NA

PAROC/JF (33.5)

Introduction

Page 5

This CEN CWA has been developed in …...

te It is proved than steady state tests on products are well adapted to provide useful information in order to predict the thermal behaviour of buildings also under dynamic conditions.

Delete the first para. See response above NA

STGOBAIN/AK (34.7)

Introduction Par 1 This CEN…. know how insulation products Add “thin multi layer” between how and insulation. If you don’t you pretend to talk about all insulation materials and that is not the scope.

It is clearly state in the title as well in the second paragraph of the introduction that “This CEN CWA … describes the requirements for in situ testing … of thin multi-layer reflective insulation products”...

However, the CWA36 describes the use of other insulation products with the objective of comparing the results of conventional and standardized with in situ records.

This link, as well as the paragraph, are part of the Business Plan that you have agreed and agreed to support.

Note that the addition has been made at the 7th paragraph when talking about the final result of the CWA36. PA.

STGOBAIN/AK

(34.8)

Introduction Par 1 under actual climatic conditions delete actual, what does it mean? It is agreed to replace by “real A

STGOBAIN/AK

(34.9)

Introduction Par 1 …laboratory predictions. Change …laboratory measurements. Agreed

Prediction replaced by “Laboratory measurement and associated calculations” A

EPFA/KF

Introduction para.2 te If the method produced has scientific merit, then why If there is confidence in the test method, The proposer is


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(35.4) would it be suitable only for multi-layer reflective insulation products?

claim it as a test method for thermal insulation products in general.

concerned with Multifoil insulation products only. The adaptation or use for other insulation products is out side of its interest. NA

If this CWA36 can give help for in situ tests of all kind of insulation product it will be good.

BING /JR (40.2)

Introduction Paragraph 3

Te With laboratory tests, it is the absolute measurement uncertainty that is expressed with a confidence limit. The absolute measurement uncertainty is an estimate of how far away from the “actual value” the measured value is likely to be. The repeatability of the test (how the answer will vary when the same product is measured by the same laboratory in the same apparatus) is just a component in that estimate. To validate the measurement uncertainty of these tests, one would need to measure a reference test element of known “dynamic” thermal performance, in those climatic conditions, installed in that building. This will be very difficult to achieve.

It will also be very difficult to estimate the repeatability or reproducibility of tests that use real climatic conditions as one of its boundary conditions, as it will almost never be possible to replicate a particular set of climatic conditions a number of times. Some of the data analysis appears to be directed at modifying the results to predict the dynamic performance exposed to different climatic conditions. Quantifying error in that process will be challenging

Reword this paragraph to reflect actuality.

• Concerning the question of accuracy, it was widely discussed during plenary meetings that the definition referring to laboratory is not directly applicable for the CWA36.

However, the CWA36 proposes to use the GUM method as common for standards as well as 2 additional methods based on “sensitivity analysis” and “analysis of the dispersion of the result”. This is also support by other comments below.

It has to be accepted that for this purpose the result of the RRT will give sufficient data that will permit to deal with the uncertainty purpose.

• Concerning the question of repeatability and reproducibility, the MG is confident on the possibility of achieving the objective of demonstrating it. This will be evaluated and expected to be confirmed during the RRT. GC

As explained previously, similar days or part of days will be compared to the other from the same site and also between sites. Another easy task


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will be to compare final results based on identical groups of weather conditions.

BING /JR (40.3)


Ed ……..experienced and knowledgeable test organisations....

This needs to be more clearly defined. Test organisations must be competent and experienced in thermal testing not merely in -situ testing

The existing sentence does not make any reference of the experience on in situ testing.

Proposition agreed taking into account an agreement reached during the 3rd PM referring to “experience on thermal testing and/or in situ testing”. PA

EPFA/KF (35.5)

Introduction para.3 te

‘...experienced and knowledgeable test organisation...’ Define the necessary experience and knowledge which must include thermal property determination.

See response above PA

STGOBAIN/AK

(34.10)

Introduction Par 3 “as close as possible” and “as accurate as possible” are weak and meaningless

Delete this part. As long as you don’t precise this judgement it literally doesn’t mean anything. E.g. if you measured a U-value for the roof of 1000 W/m2K you can always say that this result was found by doing it as accurate as possible.

This is an Introduction with the intension to explain what is the aim (intention) of the project. The detail comes later within the CWA

No need to change, from the proposer point of view. NA

STGOBAIN/AK

(34.11)

Introduction Par 3 These test..precision Still strange that only experienced and knowledgeable is added. Propose to delete this, who is judging if lab is meeting this conditions?

What is the meaning of this comment in terms of confidence that you seem to give to European notified laboratories?

No reason to prejudge that the labs will not meet this condition. NA

EPFA/KF (35.6)


‘...in specific conditions of use.’

‘This is expected to enable...’

It is agreed that the performance properties determined would be under very specific conditions of use and hence there would be no way from the results of knowing the general performance of the product.

Expected is not a suitable word for a test method which actually does what it sets

What is the “general performance of the product”? What the CWA36 intends is to show is the real performance of the product.

What has not to be


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out to. Use ‘will’’ if there is any belief in the CWA or drop the sentence.

forgotten is that conventional methods of test and associated calculations aim to achieve results for all conditions of use (using EN 10456, EN 6946, …). In situ testing is doing the same, but with the advantage, that it makes measurements directly, and does not make use of predictive assumptions,. The CWA additionally permits the comparison between prediction and direct measurements based on simple building designs. GC

Agree to replace “expected” by “will” A

JS/ URSA

(39.5)

Introduction

Pag 5

In situ testing gives a more realistic picture of how insulation products perform

TE This sentence is not proved.

Even on previous paragraph is mentioned the lower confidence. If “the aim is to be as close as possible”, it means lower realistic picture

Delete

Generally, it is more realistic to measure directly instead of predicting without verification.

Laboratory tests under artificial conditions measuring a single attribute under steady state conditions provides high accuracy with low relevance to real conditions of use. In situ testing gives lower accuracy but a much higher relevance to the real conditions of use.

The sentence needs to be kept in its full original version in order to be understandable “In situ testing gives a more realistic picture of how insulation products perform in specific conditions of use”


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NA

PAROC/JF (33.6)

Introduction

Page 5

5th para

In situ testing gives a more realistic

te I the preceding para it is said that the aim is to be as close as possible to laboratory tests, which indicates a lower realistic picture.

Delete the para Laboratory tests under artificial conditions measuring a single attribute under steady state conditions provides high accuracy with low relevance to real conditions of use. In situ testing gives lower accuracy but a much higher relevance to the real conditions of use. NA

STGOBAIN/AK

(34.12)

Introduction Par 5 how insulation products Add “thin multi layer” between how and insulation. If you don’t you pretend to talk about all insulation materials and that is not the scope.

It is clearly stated in the title as well in the second paragraph of the introduction that “This CEN CWA … describes the requirements for in situ testing … of thin multi-layer reflective insulation products”...

However, the CWA36 describes the use of other insulation products with the objective of comparing the results of conventional and standardized with in situ records.

This link, as well as the paragraph, are part of the Business Plan that you have agreed to support.

Note that the addition has been made at the 7th paragraph when talking about the final result of the CWA36. PA

JS/ URSA

(39.6)

Introduction

Pag 5

The basis of …. is the measurement of total energy consumption of the

TE The basis of the product performance must be the thermal heat flow.

Equation (6) shows in reality “dynamic thermal performance” Uc is derivate from thermal heat flow

The basis of these test cell is the measurement of total heat flow going trough the insulated part of the roof over extended periods of time

Sorry but this is contrary to the Business Plan that all participant have agreed to support. NA


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test cell … This provides a picture of how insulation products perform ….

PAROC/JF (33.7)

Introduction

Page 5

The basis of …. is the measurement of total energy consumption of the test cell … This provides a picture of how insulation products perform ….

te The basis of the product performance must be the thermal heat flow through the product, not through the test cell. A part of the heat ( the energy consumption of the test cell) goes through other parts than the tested product, as is mentioned in this para. If the performance of these parts is unknown it is impossible to get a through picture of the performance of the product.

The basis of the test is the measurement of heat flow going trough the insulated part of the roof over extended periods of time

The measurement of the total energy consumption has been the basis of the CWA since the beginning of the Workshop. NA

Measuring heat flow through a part of the structure will give

1) inaccurate information due to the dynamic in situ conditions and

2) it provides information that is not representative of the full test area.

As it has been explained before, the energy consumption is the more relevant and necessary information to know the full energy lost by the structure.

Additionally: a) The CWA states in the

introduction that “This requires means of determining the energy going through the test area and its thermal bridges and what is lost through the rest of the cell construction”.

b) Details are given in clause 8 in order to isolate the part of the extra losses through the thermal bridges and air exchange (using conventional calculations)


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c) If the energy loses for IMMR is greater than expected by the conventional methods; this means that the thermal efficiency of the insulation product will be initially under-estimated, so the final result will be secured for the end user compared to the real thermal efficiency of the IMMR.

d) The Proposer is confident on the fact that the proposed analysis of the in situ data is able to give consistent information about the thermal efficiency of the IMMR especially with Uca. The RRT is especially done to confirm it.

PAROC/JF (33.8)

Introduction

Page 5

This in situ test provides a range of design values arising …

ge The use of “Design value” here is wrong. A design value is related to a specific construction during specific conditions, taken into account corrections on declared values. The measured value cannot be used as a design value In another design that is not a simple roofed test cell, as the performance of the product depends on the orientation etc.

Delete “in situ” and “design” in the first sentence.

According to the definition of “in situ” (see comments above), the CWA is really an in situ test. NA

According also to the “Design value definition” this is related to a specific construction during specific conditions. There is no reason to consider that the design value is obligatorily defined by correction on the declared value.

The definition of “declared value” given in existing standard is especially for homogeneous and traditional insulation material.

It should be noted that the CWA36 gives design values of the thermal efficiency of the tested insulation product. This


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design value is not so far from the declared value, especially in the Uca expression because the conditions of test are close to the laboratory test conditions.

JS/ URSA (39.7)

Introduction

Pag 5

This in situ test provides a range of design values arising …

GE Design values are related to corrections to introduce on declared values due to real installation in real buildings.

Delete The definition you refer to is for homogeneous insulation products, laboratory test and associated conventional calculations. NA

CWA36 is an in situ test that gives a direct measurement on site, In its original position. This is also a design value. As for fire protection or acoustic in situ tests, the result can be compared to other laboratory methods of evaluation and their associated calculations.

BING /JR (40.4)


Te The “dynamic” thermal performance values, obtained under specific climatic conditions and whilst installed in a specific building will not be suitable for using in conventional design calculations which assume the data has been obtained in the steady state and then use classic heat transfer theory to obtain the performance of a specific building in specific climatic conditions. ALSO The term “thermal transmittance” should not be used in this context. – Thermal transmittance is by definition a steady state property and is defined in BS EN ISO 7345 as:- Heat flow rate in the steady state divided by area and by the temperature difference between the surroundings[1] on each side of a system. Note [1] The “temperature of the surroundings” are defined in terms of the “environmental temperature” - which is defined in ISO 8990 as “representing the proper weighting of air and radiant temperatures for the purposes of determining the heat flow to the surface.”

Reword this paragraph to reflect reality.

Reword to clearly define what is in fact being measured, and do not confuse with existing defined terms.

The definition given in clause 3.1.8 is specific to the CWA36 and in situ testing. NA

There is no way to confuse the definition with the steady state definition. NA

EPFA/KF (35.7)


‘(thermal transmittance)’ This is a steady state property and cannot be determined by a dynamic method.

Omit ‘(thermal transmittance)’. It appears that you are stating that the thermal transmittance can be


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determined only by existing steady state methods.

It seems unreasonable to restrict definitively the measurement of the thermal transmittance to the existing methods. That does not give any opportunity for innovation and improvement of methods of test.

The definition given in clause 3.1.8 expresses the difference between dynamic and steady state thermal transmittances. NA

EPFA/KF (35.8)

Introduction para.8 ed

In line one, the definitive article is not appropriate in ‘... of the insulation product...’

Replace ‘the’ with ‘an’ or ‘product’ with ‘products’.

Agree A

EPFA/KF

(35.9)

Introduction para.8. te ‘… these corrections are based on hypotheses and conventions…’ This is incorrect. The coefficients given in EN ISO 10456, for example, were determined by measurement and involved a great deal of scientific experimentation.

Delete last sentence of this paragraph. There is no doubt that ISO 10456 has involved a great deal of scientific experimentation, even if this experimentation was especially based on steady state and laboratory tests.

This does not change the fact that correction factors given for a specific configuration are conventional (considered as responding by convention for all similar situations – result of a mean value – laboratory value expected to be representative when applied in real conditions of use).

Concerning the term “hypothesis”, it is not reducing the relevance of the correction factor. This is just a term normally used in many sciences with the intent to impose


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the verification of he applicability of such correction factors before their use for specific design and conditions of use.

By definition, dynamic in situ conditions of test are different than steady state laboratory conditions, then hypothesis of the original condition may be close (necessity of control in order to identify if the hypotheses are applicable or not) and even if they comply, this is generally (and by definition) not 100%.

Anyway, the UTI physical meeting proposed to modify part of the sentence. Please refer to the next version. PA

PAROC/JF (33.9)

Introduction

Page 5

However, these corrections are based on hypotheses and conventions and are prone to being wrongly estimated thus leading to unrealistic results

ed The sentence is in contradiction with existing standards Delete Please refer to the response above.

Thanks to discussion with you during the physical UTI meeting held on the 5th Nov. we were able to find an agreement on the modification of this sentence. PA

JS/ URSA

(39.8)

Introduction

Pag 5

However, these corrections are based on hypotheses and convention

This sentence is only an “opinion” from proposers

If this sentence remains it will be in contradiction with existing standards

Delete Please see response above PA


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s and are prone to being wrongly estimated thus leading to unrealistic results

BING /JR (40.5)


Te We do not agree with this statement, according to CEN TC 89 WG 12 existing conventional test methods are adequate to provide thermal values for multi layer reflective products.

Remove this paragraph. It is incontestable that the Proposer has extensive experience of in situ testing. This experience makes them and the multifoil manufacturers very confident and convinced about the necessity to complete the information given by conventional methods with the results of in situ measurements.

Additionally there is scientific literature that identifies the differences between predicted and in situ measurements.

The CWA36 will permit making the comparison between laboratory and associated calculated predictions with in situ measurement. Whatever the result (overlap or not) the results will be complementary to conventional existing methods. NA

EPFA/KF (35.10)

Introduction para.9. te

CEN/TC89/WG12 has determined that traditional methods are valid for multi-layer insulation products.

Justify, fully, the reason why it is thought that the experts of TC 89/WG12 are wrong.

It is clear that TC89 WG12 doesn’t want to consider in situ testing as an alternative method. This because of the resolution already voted by the WG12, despite the opposing opinion of the major representative of multifoil manufacturers. This is also because the fact that relevant in situ


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reports have shown significant differences between laboratory predictions and in situ measurement that have been ignored by the WG12.

WG12 is following the specific route of laboratory test in steady state conditions. There is no reason that another CEN item cannot follow another route, especially when the proposed method is complementary (competing but not conflicting) and also especially if this new method can draw on additional expertise or experience that can help the scientific community to have a better view and understanding about the effect of weather conditions and real conditions of use on the thermal performance of building materials.

WG12 is dealing with conventional, steady state laboratory tests based on guarded hot box or hot plate. This is definitively different than in situ test which is another way to measure, which is complementary and not conflicting.

Moreover it is proposed to compare both results (conventional and in situ) and analyse the potential difference as it is scientifically expected and also proposed in EN 832 and EN 13790. If there is a significant overlap of the result this is a benefit, If


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there is difference, this is also a benefit because the results are complementary. GC

STGOBAIN/AK (34.13)

Introduction Par 9 Delete this paragraph Experience of “traditional” insulation manufacturers has shown the opposite (see WG12 and outcomes of that). There has not been any evidence of this remarks put into WS36.

Please refer to the responses above NA

Knauf /SW (36.5)

Introduction Page 5

The in situ test detailed in this CEN Workshop Agreement

te

There is a significant amount of conflicting evidence that suggests this is not the case. This paragraph suggests that the author wishes to ignore any evidence that does not suit their case and prejudges the outcome.

Delete the paragraph The CWA36 is not a standard. It is an alternative method of measurement proposed and supported by a large number of multifoil manufacturers that wish to compile their experience and expertise on the matter in a workshop agreement. NA

In situ test take account of solar radiation, wind, humidity and variation in temperature, while steady state laboratory test do not. Thus in situ does take a more complete evaluation.

PAROC/JF (33.10)

Introduction

Page 5

The in situ test detailed in

I have not seen any report or study that could confirm this statement, but many on the contrary.

Delete more complete Your statement is not true. There is sufficient evidence that scientific references exist. Some of them were proposed to WG12 and are on its web link.

The term “more complete” is based on the fact that much more information will be recorded and that the analysis will be able to identify more complete information about the effect of boundary conditions (external weather parameters) on


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the thermal efficiency of IMMR. So the wording is justified. The CWA will provide a more complete evaluation than existing conventional methods of evaluation proposed to do. NA

EPFA/KF (35.11)

Introduction para.10. te Multifoils are no different from any other insulation product with a reflective surface and requiring a trapped layer of air adjacent to its surface to give best insulation performance.

If the test is valid for multifoils then it would be valid for all insulation products.

IMMR are quite different from traditional insulation products including single reflective surfaced insulation product.

The thermal heat transfer modes are not the same. This is easily understandable when analysing steady state laboratory tests results in terms of evolution of apparent equivalent thermal conductivity depending on the difference of temperature and number of internal reflective films.

As it was explained during the Kick Off Meeting and is proposed in the Business plan; this CWA36 is in a first stage and established for a specific reduced range of multifoil reflective insulation products (5 layers minimum) in order to concentrate first on this kind of insulation product. Later and with additional experience on in situ testing based on this CWA36 several kinds of insulation products could then be evaluated. GC

JS/ URSA (39.9)

Introduction

Pag 5

The in situ test …more complete evaluation

At today’s stage only dynamic thermal performance of the test cell is given as a result, no information at product level.

Section 8 of the CWA36 details the thermal efficiency of the IMMR with their air gaps.


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of the thermal characteristics of multi-layer reflective insulation products ….

Heat losses through the floor and door entrance are negligible. Thermal losses by thermal bridges are removed from the recorded energy consumption. Thermal losses from air exchanges are negligible in some identified conditions and removed from the recorded energy consumption in other cases.

Moreover, if the thermal performances of the IMMR was considered as the thermal performances of the test cell, integrating the extra losses from the floor, thermal bridges, air exchange rate, … then the result will be underestimated compared to the specific thermal performance of the IMMR itself. This test cell level result would be a safe result. So there is no risk for the end result about a potential over estimation of the thermal performance. GC

BING /JR (40.6)


Te Multifoils are no different to any other insulation system that employ a reflective layer on its external surfaces and require adjacent trapped air layers to maximise their thermal performance. This testing method would be of equal value to all insulation systems.

Clearly define how the link with data for ‘similar traditional insulation products’. What are the similar traditional insulation products meant here?

This is the purpose of the use of traditional insulation products in the CWA and the specific section 8.2.

There is no need to make a link between traditional and multifoil insulation products. But it is necessary to make a link with this new in situ test method and the conventional calculation methods initially produced for building insulation products.


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In other words, existing conventional test methods are well defined and estimated as relevant for these materials in an European and standardized level. Then, traditional insulation products when used as a link in the in situ testing will permit the comparison of predicted steady state thermal efficiency (design value extrapolated using EN 10456, EN 6946, …) with direct in situ test measurements. This result will assist to calibrate the in situ test as well, and will also permit to complete the single information given by existing standards with in situ tests results specifying several and different conditions of test that are closer to the common and intended use of the insulation product. GC

BING /JR (40.7)


Te Round robin testing is used to measure repeatability and reproducibility at different sites using identical test methods and materials. The CWA so far produced is not sufficiently detailed or specific to allow this to happen. How will labs know if any differences are due to the climate or to the materials and structures with such a wide allowed variation?

Remove this paragraph In terms of thermal efficiency of the IMMR, the several labs will be able to compare their results that should be close together. The differences between results will contribute to the repeatability and reproducibility analysis.

This is especially possible thanks of the split of weather conditions on identical and identified specific conditions (with/without wind, with/without solar radiation, …). These isolated weather conditions will be similar


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in each test site, and then directly comparable as well as the associated dynamic thermal transmittances.

The RRT is done in order to not prejudge the results of the CWA36, but to validate it (or correct it) based on experimental data recorded and analyse. NA

EPFA/KF (35.12)

Introduction para.11. te Does it follow that, if the RRT gives a range of results rather than a common agreed result, then the reason for this will be that the test cells were in different climatic conditions and not because the test method is not scientifically sound?

The logic of testing to obtain results for various climatic conditions and getting a result that can be shown to verify the reliability of the test method needs to be examined.

The examination of the reliability of in situ test is also applicable to existing conventional methods of test (laboratory – steady state conditions). Thus it is not specific to in situ tests that permit the comparison between these two methods.

There is no proposition of change in your comment.

The RRT shall give a range of results that compared together will give both information about the dynamic thermal performance of IMMR and repeatability and reproducibility of these identified thermal performances. Any necessary changes on the CWA36 will be done thank to the RRT result even if the Proposer is already confident in the fact that the proposed version of the CWA36 is sufficient. GC

BING /JR (40.8)

Scope Paragraphs 2 and 3

Te The proposers have repeatedly stated that the object of the CWA was not to end up with comparative testing which is known to be a fundamentally flawed approach. It is not clear to us what this statement really means if it is not to end up with a comparative test methodology.

Clarify the real intent behind the test methodology.

These paragraphs express the need and opportunity for CWA36 to be comparable with other methods of test. The comparison is clearly


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between methods of measurement and not insulation products and then there is no reason to consider that as a flawed approach.

From a scientific approach, all comparison of results between different methods of test is a benefit especially if that permits to: - validate existing

knowledge - complete existing

knowledge - improve existing

knowledge and methods of test

- give more complete information to scientists, decision makers and/or end users

- provide a wide range of data for further programs of scientific research

All these reasons make relevant the comparison between the predicted thermal performances of insulation products with recorded in situ data. This is usually called “control” or “verification” by experimentation and it is strongly suggested for all scientific studies as well by existing standards. GC

EPFA/KF (35.13)

1. Scope para.2. te This para. makes little sense. What does it mean when it is stated that the dynamic design values obtained from the cells are ‘target’ values?

Explain. In situ tests based on a simple design test cell will permit to compare and validate the results given by existing conventional calculation. This is because the recorded thermal performance of the insulation product is more directly


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representative of reality (especially when applied as close as possible to the real and final condition of use). Additionally, because conventional calculations are based on specific sets of conditions measured in a laboratory that are extrapolated by calculation to other specific conditions of use that are much more complex and severe than the previous calculations.

Because the conventional calculations are standardized for traditional insulation products, the use of these traditional insulation products in the CWA in in situ tests will permit making a useful link between theory and practice. GC

EPFA/KF (35.14)

1. Scope para.3 te How does one obtain a ‘declared’ value from the proposed test method? If this is a declared value obtained from traditional methods then the product has to have a product standard, under TC88, by which the declared value is determined as a λ90/90.

Explain ‘;declared value’ as meant in this paragraph.

This is relevant to both conventional and in situ test methods.

The CWA36 describes the evaluation of the dynamic thermal performances of IMMR using in situ testing as well as it requires an initial measurement of the steady state thermal performance of insulation products in a laboratory. This will permit to compare the declared and design values resulting from each method of test.

In other words:

- Conventional methods of test provide declared value which associated conventional


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calculations permits to extrapolate the Design value. Then additional and standardized calculations permit to predict energy needs and energy used.

- In situ testing (as described in the CWA36) permits the measurement of the energy used. The proposed data analysis will permit the evaluation of the thermal performances that can be compared to conventional predicted design and declared values as well as being considered as complementary information to the steady state results. GC

JS/ URSA

(39.10)

Scope

Pag 6

the objective is to extract from in situ measurements the thermal transmittance of an insulation product

TE The thermal transmittance word is misused related to a product.

Thermal transmittance must be related to a complete building component

The objective is to extract from test cell measurements the thermal transmittance of a building roof element.

U value, which is the thermal transmittance, can be applied to a product or a system. It is especially used when it is not possible and/or difficult to define an R value.

By definition, the thermal transmittance, U is the coefficient of heat transmission through a building envelope component or assembly, equal to the time rate of heat flow per unit area. Temperature difference is between the warm and cold side. NA

Knauf /SW (36.6)

Scope Page 6

the objective is to extract from in situ measurem

te Thermal Transmittance relates to the build element or complete building. Products thermal performance should be referred to by either its thermal resistance, or the combination of characteristics that contribute

The objective is to evaluate the combined thermal transmittance of building roof and gable elements from cell test measurements. The thermal transmittance

As a result of the UTI physical meeting It was proposed to clarify this in section 5.1.7 when talking


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ents the thermal transmittance of an insulation product

towards the products thermal resistance. In the case of homogeneous insulation the thermal conductivity and thickness, in the case of products that use reflective layers the resistance of the core and the emissivity values for surfaces facing airspaces.

This method could provide and estimate the thermal transmittance of the building element as is used in this design, not the thermal resistance of a single component. However even this is not possible in the proposed methodology because the roof and gable walls are being compared so the estimate of thermal transmittance is of the roof gable wall combination.

Further it is impossible to derive the performance of the reflective insulation when the heat flow through the insulation is unknown.

is only valid for the actual design, and the conditions used in the evaluation.

about roof and gable end walls. PA

PAROC/JF (33.11)

Scope

Page 6

the objective is to extract from in situ measurements the thermal transmittance of an insulation product

te The method gives the thermal transmittance of the complete building component in the used design, not the transmittance of the insulation.

It is impossible to derive the performance of the reflective insulation when the heat flow through the insulation is unknown, and when two different designs are mixed, the roof insulation, and the gable end insulation.

The objective is to evaluate the combined thermal transmittance of building roof and gable elements from cell test measurements. The thermal transmittance is only valid for the actual design, and the conditions used in the evaluation.

The proposed data analysis permits the elimination of thermal losses from thermal bridges, air exchange, …. And then consider moving from the test cell to the test structure and then to the IMMR with its air gaps.

Please refer to other answers above and below. NA

JS/ URSA (39.11)

Scope

Pag 6

The results of the test procedures of the CEN CWA are to be expressed as the declared value of the insulation product tested plus the design value of the insulation product

TE Again there is a confusion between transmittance (the test objective as mentioned in preceeding sentence) and thermal product characteristics

The results of the test procedures of the CEN CWA are to be expressed as the declared value of the roof element tested plus the design value of the roof element

The U value of the IMMR product including its air gaps shall be considered as the results of the in situ test as well as its design value. NA

These results are complementary information compared to steady state declared value and design values extrapolated with associated conventional calculations.

In your proposed change your mentioning the declared value of the roof element that seems to be not pertinent, because usually the declared value


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refers to insulation material as expressed in the original text.

Knauf/SW (36.7)

Scope

Page 6

The results of the test procedures of the CEN CWA are to be expressed as the declared value of the insulation product tested plus the design value of the insulation product

te As previously described in these comments by simply comparing energy consumption of cells it is not possible to estimate with any reasonable degree of accuracy the declared value of any individual component in either roof.

Accuracy could only be improved by measurement of heat flux through the insulation elements of the roof.

The test might be able to provide information that allows for a value of the roof element, as installed in this test method to be derived.

The results of the test procedures of the CEN CWA are to be expressed as performance values of the roof element during different conditions, but cannot be used to evaluate either declared or design values for the insulation.

There is no evidence in the CWA36 that the thermal performance of the insulation products is estimated by simple comparison of the energy consumption! NA

Moreover the measurement of heat flow through the insulation element is allowed and described in the CWA36 section 5.4.4.

As a first step this CWA permits to obtain a value of the roof element tested (by direct application). This, for several weather ranges.

The CWA proposes a data analysis that evaluates the dynamic thermal performance based on the recorded energy consumption and is representative of the performance of the insulation product.

PAROC/JF (33.12)

Scope

Page 6

The results of the test procedures of the CEN CWA are to be expressed as the declared value of the insulation product tested plus the design value of the

te The declared value of the insulation product cannot by this method be evaluated, especially not with the accuracy required by other thermal insulation products.

The results of the test procedures of the CEN CWA are to be expressed as performance values of the roof element during different conditions, but cannot be used to evaluate either declared or design values for the insulation.

The declared values to which you refer are calculated by use of conventional laboratory test methods as clearly stated in clause 1.1 Limits of application para 5 subclause c).

Energy consumption recorded on site, as described by this CWA, is equal to:

Consumption = [ (Th losses / structure) + (Th losses / th bridges) + (Th losses / air exchange) ] x


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insulation product

DT x t

By eliminating the extra thermal losses from the recorded energy consumption and by considering specific weather ranges, it is clearly intended to obtain the thermal performance of the test structure. Then, after removing the extra losses from integrated thermal bridges the result is extrapolated for the IMMR including its air gaps.

Therefore the original text is justified. NA

Knauf /SW (36.8)

1.1 Limits of application Page 6

Whole Section

te Despite the stated aim this methodology at best measures the thermal transmittance of the roof and gable wall elements in this design. Unless the measurement of heat flux through the roof element is made mandatory then it is not possible to understand the thermal transmittance of the roof element alone.

There is much justification of the proposed test method in terms of the accuracy and realistic nature of results. There is no evidence to support the arguments for the supposedly superior accuracy of the proposed method against the existing methods that can be applied to roofs other than those with exactly the identical in all respects to those in the test. .

There are no propositions for any changes. Only comments CR

The CWA and the Proposers have talked earnestly and openly about the relative accuracy of in situ testing compare to laboratory tests using steady sate conditions.

However, there has been much arguing by the manufacturers of traditional insulation about the accuracy of the steady sate laboratory test with pre-conditioned test materials, but little about the relatively low relevance of the results to real conditions of use

The RRT will permit to raise this question and to provide sufficient information in order to judge (and not prejudge) the reliability of the


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results.

St. Gobain/AK (34.14)

1.- Limits of application

From long experience it is known that in situ testing is not intended as a high precision method as with laboratory tests …..

It is clearly expressed than test cells have less precision

This is just a comment that does not propose any change on the text.

Later in the CWA it is expressed that less precision on more realistic results are preferable to highly accurate results based on unrealistic conditions of test. GC

PAROC/JF (33.13)


From long experience it is known that in situ testing is….

Here the CWA clearly expresses that cell test has less precision, and therefore the claim above is wrong. This sentence only confirms my comment above.

Keep the sentence as it is correct, but take the consequences, and do not in another sentence claim the opposite.

From the Proposer side this sentence is justified and not in conflict. As explained in a following paragraph, precision is dependent also on the representativeness of the results to the conditions of use. NA

BING /JR

(40.9)

1.1 Paragraphs 2 and 3

Ed

Te

The statements in these paragraphs are very confused. Surely it makes sense to use a methodology which gives the most accurate result. Perhaps the proposers are confusing accuracy and precision here? What is meant by realistic and unrealistic is also unclear, again accuracy and precision are being mistaken. These types of tests may be realistic in some circumstances but they may be completely unrealistic in others It is difficult to see how confidence limits can be obtained for these types of tests (see comment 2). Do the group intend to publish how that is going to be achieved?

Clarify these paragraphs. It was agreed during the 3rd PM to change the term “accuracy” by “precision”.

Measuring the thermal performance directly on site, according to the common conditions of use, is more realistic than on a small sample, in steady state conditions, in laboratory, with specific conditions of test that are not representative to the usual conditions of use.

Conventional test results are predicted; in situ testing produces results from tests carried out under real weather conditions GC

EPFA/KF (35.15)

1.1 para.2 te The final sentence is nonsense. Words such as ‘realistic’ are not appropriate for a technical document.

Delete final sentence. The version 3 of the CWA36 does not use any more the word realistic and has proposed


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another wording to clarify the sentence. PA

JS/ URSA (39.12)


design (using design calculation according the EN 10456, EN 6946, …) is probably the most accurate method but the results are not necessarily applicable to the real conditions of use of the insulation product due to the limitations of the test condition

TE For many years it is accepted and proved than actual calculations standards are well adapted to predict energy behavior on buildings under real weather conditions.

This sentence is in contradiction / against / in conflict with existing standards.

Conventional calculation methods must be adapted to predict delivered energy because they are daily used by building engineers and building control in order to design the heating / cooling systems, as well as determining the level of performance of the building in terms of KWh/m2/year (A to F).

However their use to accurately predict energy behaviour relies on knowledge of real weather conditions and this is subject to significant error. NA

These calculations seem to be especially adapted for traditional materials that are dense, homogeneous, isotropic, … because they are created for this purpose.

In situ test cells are nothing else than a very simple test design that permit simplified calculations.

It is to be noted that you make no allowance for the existing standards that you seem to support through other Technical committees. NA

EPFA/KF (35.16)

1.1 para.3 te Use of ‘realistic’ again. The paragraph is best described as ‘waffle’.

Delete paragraph. Proposition for change is following:

“ Thus in essence, laboratory tests are more accurate compared to in situ tests, but the in situ tests provide results


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which take direct account of the real conditions of use and real weather conditions to which the insulation product will be subjected to.” Second sentence deleted. PA

JS/ URSA (39.13)


Thus, in essence, laboratory tests are more accurate compared to in situ tests, but the in situ tests provide more realistic results even if they are less accurate. ……

GE Proposers are accepting less accuracy.

More realistic is only one opinion.

Opinions are no place on a CEN document

The Proposers have years of experience to support their comments NA

More realistic cannot be challenged, because it is intended and clear that the thermal performance of the insulation product measured on site under natural boundary conditions will give a picture more representative than if the same product is evaluated in laboratory, on a small conditioned sample and under steady state and controlled conditions.

This is moreover true when it is pointed out that from a scientific point of view, each physical characteristic shall be applied corresponding to the conditions on which it is used. Thus, for insulation products, conditions near to the building environment is to be considered as more relevant than specific laboratory conditions (even if corrector factors are described in the EN 10456 or EN 6946).

Please refer also to the comments above and below. NA


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PAROC/JF (33.14)


Thus in essence

It is unrealistic to claim that laboratory tests and correctly made corrections give more unrealistic results than this s c “in situ” test.

Delete the whole para In the experience of the Proposers the paragraph is fully justified NA

From the experience of the proposers, and also supported by several publications, the thermal performance of buildings recorded on site may be significantly different to the expected and predicted result coming from conventional existing standards.

This has been shown in the first instance with some results of the Modelling Group.

In clause 8.2, the CWA36 proposes to make the comparison between in situ and conventional measured and associated calculations.

Results based on the expertise of several laboratories will be able to produce relevant information that will no doubt permit the validation of this statement.

The target which is needed for all parts of the building profession is the realistic behaviour of building component. For this reason, all in situ tests seem to be closer to this objective than all other methods. NA

PAROC/JF (33.15)


design (using design calculation according the EN

te For many years is accepted and proved that actual calculations standards are suitable to predict energy behaviour of buildings under real weather conditions.

This sentence is in conflict with existing standards.

Delete the last part of the sentence.. “but the results are not necessarily applicable to the real conditions of use of the insulation product due to the limitations of the test condition”

In situ testing as presented in this CWA36 is a new, innovative, complementary and alternative method that is proposed by IMMR


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10456, EN 6946, …)

producers. There is no conflict with existing standards, because no standards exist for in situ testing as proposed in the CWA36. Additionally there are no standards for IMMR.

The CWA36 brings some additional information that will improve the information for the users of IMMR, and that are at present not available with conventional standards. The influence of weather parameters on the thermal behaviour of IMMR as well as the link with conventional methods of evaluation are part of the new information that from an obvious and scientific point of view, it cannot be refused, at least for a CWA which is not a standard but a common approval backed by the relevant industry organizations.

So as explained for other responses above, the in situ measurement is intended to be closer to the real condition of use, thus more directly applicable compared to conventional steady state condition in a laboratory.

Finally it is the aim of this CWA to bring complementary information that can be used to improve the representativeness of conventional methods. The link proposed in the CWA and explained in the Business Plan will


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help to bring complementary information as well it will contribute to the calibration of such a new protocol of test initiated for a new kind of insulation materials.

NA

PAROC/JF (33.16)


Thus, in essence, laboratory tests are ……

ge … much more realistic is only an opinion.

Delete the sentence PA

It is not mentioned “much more realistic” but “more realistic results”. Moreover this is not an opinion but more a consideration “is considered better than”. This sentence is true in all the cases independently of the subject.

A proposition for changing the sentence has been made below. Please refer also to the new version of the CWA36.

EPFA/KF (35.17)

1.1 para. 4 te ‘....experienced and knowledgeable...’ Define, exactly, the knowledge, with respect to the determination of thermal properties, that a test laboratories are required to have.

This is done later in the clause 1.4.1 that has been completed according to the discussions held during the 3rd plenary meeting. A

BING /JR (40.10)

1.1 Paragraph 4

Ed Experienced and knowledgeable test laboratories does not give sufficient explanation. What is needed are laboratories who are experienced in thermal measurement of insulation materials, previous experience of using previously flawed in- situ methodology is not sufficient qualification.

Clearly define hat is meant by experienced and knowledgeable test laboratories.

This is done later in the clause 1.4.1 according to the discussions held during the 3rd plenary meeting. A

BING /JR (40.11)

1.1 Paragraph 9

Ed/Te The terms “dynamic thermal transmittance” and “global dynamic thermal transmittance” appear to have been defined only in this document. Those definitions are complex – where do these definitions come from? Are the definitions critical to the ranking of the thermal performance of the various products?

Clarify definitions and supply further information

This thermal transmittance is intended to be “dynamic” in the sense that it is measures under dynamic conditions and defined as dependent of weather parameters (Uca, Ucb, …) as well as a global


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value for a complete weather condition (Ug). The term global does not refer to the global test cell but to the global weather conditions. PA

STGOBAIN/AK (34.15)

1.1 Par1 as close as Delete for the same reasons as mentioned above. A standard or CWA should never have this kind of vague implications. Be precise!

The proposed change is the following

“However the aim is to be as near as is reasonable and practicable to the level of confidence of laboratory tests, given the inherent differences between the proposed in situ tests and conventional tests conducted under steady state laboratory conditions. “

PA

STGOBAIN/AK (34.16)

1.1. Par 3 Thus, in essence… I consider this to be complete nonsense. Please delete this total paragraph. Based on what you make these assumptions?

What this sentence says is true in all cases.

NA

STGOBAIN/AK (34.17)

1.1 Point c make it more clear, sentence is to long with too many commas.

two times thickness? proposal is not clear

Sentence will be reviewed in final editing PA

STGOBAIN/AK (34.18)

1.1 Point e delete traditional It is used for all insulation materials (even other building materials).

NA

Traditional material is intended to be for differentiation compared to IMMR. This wording is very common and already used in technical documentation as on the Web.

Conventional methods of test and associated calculations were created for building materials that are defined as homogeneous, and the hypotheses used refer to dense, isotropic, …


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characteristics. At least this wording is appropriate.

PAROC/JF (33.17)


Page 7

the dynamic thermal transmittance) ……. the global dynamic thermal transmittance (Ug) for ……

ge None of these results are related to product level but at cell test o roof level.

Change to : the following properties for the test cell can be determined:

NA

The U value is not necessary at roof level. It can relate also to a structure, system and product.

It is clear that the CWA36 aims to determine the thermal transmittance that is representative to the IMMR product including its air gaps, which, from a thermal point of view, cannot be separated from the reflective product.

This thermal transmittance is intended to be “dynamic” in the sense that it is measures under dynamic conditions and defined as dependent of weather parameters (Uca, Ucb, …) as well as a global value for a complete weather condition (Ug). The term global does not refer to the global test cell but to the global weather conditions.

JS/ URSA (39.14)


Pag 7

the dynamic thermal transmittance) ……. the global dynamic thermal transmittance (Ug) for ……

GE None of these results are related to product level but at test cell or roof level.

Please refer to other comments above.

NA

Knauf /SW (36.9)

1.1 page 7 Based on the measurem

te None of the properties that are mentioned can be related to the product, all relate to the cell.

a) the dynamic thermal transmittance of the test cell (Ua, Ub, Uc, Ud) dependent

Please refer to other comments above.


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ent of the above mentioned…..

upon the external weather conditions (see clause 8.3.2)..

b) the global dynamic thermal transmittance (Ug) of the test cell for the complete test period and extended to other reference weather data (see clause 8.3.3).

NA

BING JR (40.12)

1.2 Paragraph 2

Ed Does this conclusion come from the results of the work carried out by this group? Has this work been published in any way?

Provide additional information to clarify concerns.

Yes, part of this clause is coming from the Modelling Group discussion and decisions.

The new report of the MG will be posted with the updated CWA36 and related documents.

PA BING JR (40.13)

1.2 Paragraph 3

How are the “appropriate corrections” for other building designs going to be obtained and validated?

Provide further clarification. As it is expressed in this paragraph, it depends on the expertise of the laboratory as it can provide sufficient confidence on the results or produce a specific in situ test. However, in order to be closer to the recommendations made by the Modelling Group the following sentence is to be added: «Ideally and for a complete confidence on this method, a validation should be made thanks to in situ test experience “ PA

EPFA/KF (35.18)

1.2.1 para.2 te This para. appears to allow any test laboratory to construct any design of test cell it wishes and still claim its viability under this CWA.

Surely this is not a valid as apart of a CWA. The para. describes specific tests where the property determined is valid only for that test configuration.

This is still in line with the CWA36 that proposes to associate directly the result to the design of the test cell

All other results found with other test cell designs, complying with building regulations from other European countries,


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are proposed to be part of a data base that with time will increase the confidence on repeatability, reproducibility, as well as the confidence on the extrapolation of the results. NA

EPFA/KF (35.19)

1.2.1 para. 3, 2nd bullet

te

What are ‘appropriate corrections’ and how are they determined, obtained or validated?

Explain. As it is expressed in this paragraph, it depends on the expertise of the laboratory as he can provide sufficient confidence on the result or produce a specific in situ test. However, in order to be closer to the recommendations made by the Modelling Group the following sentence has been added: «Ideally and for a complete confidence on this method, a validation should be made thanks to in situ test experience “ GC

EPFA/KF (35.20)

1.2.1 4th bullet points

5th bullet point

te

te

This point seems to indicate the freedom mentioned above to carry out any specific test, in a cell of any design and quote the result.

As for 4th bullet point – this is specific use testing.

Such specific testing is always valid for the conditions under which it was carried out for any property of any product. It has no place, however, in a standardised document such as a CWA. Not valid in a CWA.

This is still in line with the CWA36 that propose to associate directly the result to the test cell design tested.

All other results found with other test cell designs, complying with building regulations from other European countries, are proposed to be part of a data base that with time will increase the confidence on repeatability, reproducibility as well as the confidence on the extrapolation of the results.

The clause is also clear


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on the fact that “The results of an in situ test are directly associated with the product tested and the specific design and construction of the structure used for the test” NA

EPFA/KF (35.21)

1.4 te This clause is considered unsuitable for a CWA. It is not personnel qualifications that are being considered but the authority of the laboratory, which should show sufficient knowledge and experience in the measurement of thermal properties of insulation materials. It is up to the laboratory to determine the personnel that it uses for the actual tests.

Delete 1.4. Alternatively replace 1.4 with a clause stating that the laboratory used should be a notified body with specific knowledge of the testing of thermal properties of poor thermal conductors.

This item was discussed during the 3rd plenary meeting and the sentence completed as decided. NA

STGOBAIN/AK

(34.19)

1.4 In general how is this checked? Do people need to show a diploma?

Delete this. Please refer to the response above. NA

EPFA/KF (35.22)

2. Normative references

General ed It is not normal to refer to specific dated issues of standards unless specific paragraphs are referenced in the document in which the reference is made. The latest edition of the standard is expected to be used.

Delete all date references unless specific paragraphs are referenced by number in the CWA.

Accepted and done A

EPFA/KF (35.23)

2. Normative references

5th normative reference

19th normative reference

ed

ed

ISO 9229:2007 should read EN ISO 9229

Standard number should not be italicised

Insert ‘EN’ Accepted and done A

STGOBAIN/AK (34.20)

3 ed Start sentences with capitols. Accepted and done A

BING /JR (40.14)

3.1.8 Dynamic thermal transmittance – This is not a “standard” ISO defined property and so it will have to be defined much more specifically than this. The dynamic thermal transmittance as measured in this way will depend on:- i) the product under test

ii) how it was installed in the structure iii) the design of the structure iv) the external climatic conditions v) the period of time utilised to calculate the property

vi) the internal set point temperature and how precisely the control systems keep the internal temperature at this set point

vii) the air infiltration rate and the method of calculating the heat loss or gain associated with that air infiltration rate.

iii) the mathematical process by which the value is

Further clarification is required. This is a new definition that by definition cannot be compared to another one.

Your comment is partially accepted and the definition improved in the new version of the CWA36. PA


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calculated from the very large data set obtained during the test.

To be able to compare products all these parameters will have to be standardised.

EPFA/KF (35.24)

3.1.8 te This is not an EN/ISO defined property and will, therefore, have to be defined much more carefully.

Provide precise definition. Please refer to the response above. PA

JS/ URSA (39.15)

3 Terms…

Pag 10

dynamic thermal transmittance (under dynamic conditions - measured insitu) value of thermal transmittance of a building component or product under real dynamic external conditions and specific internal conditions

TE Again confusion between building element and product dynamic thermal transmittance (under dynamic conditions - measured in a test cell) value of thermal transmittance of a building component under weather conditions

Your comment is partially accepted and the definition improved in the new version of the CWA36. PA

EPFA/KF (35.25)

3.1.9 material

te Very poor definition. If a ‘product’ includes a facing then you cannot have a piece of a ‘product’ without a facing!

Material should be defined as ‘that uniform part of an insulation product which is specifically present to impart thermal insulation properties’ or something similar. Better still, omit the definition.

Agreed, definition deleted. A

EPFA/KF (35.26)

3.1.10 product

te ‘ready for use’ is not definable. Use the standard TC88 expression ‘as placed on the market’.

Definition deleted. A

EPFA/KF (35.27)

3.2 Terms. Symbols and units

e thickness ed After the unit [m] the words ‘building materials’ appear gratuitously.

Delete ‘building materials’. Accepted A

STGOBAIN/AK (34.21)

3.2 ed make it clear with right tabs This will be done at the final stage of the CWA36 (editorial stage) A

BING 4 Ed Again it would appear form this section that the intention Clarification is needed of the principles of As mentioned in the


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/JR (40.15)

is that this is essentially a comparative method where the object is to show how the target insulation behaves relative to a reference material installed in a similar structure. If this is the case then this methodology has been shown to be fundamentally flawed and the proposers have declared that this is not the intention of the CWA The test cells and methodology described in this document are more suited to research than for producing thermal performance data that can be used to compare products.

the test method. Business Plan, for an initial period there is need to indicate the link between the results from the test method proposed by the CWA, compared with the results obtained by conventional test methods. It is considered that one way of providing this link is to indicate what happens when a tradition homogeneous insulation product, having a well known declared value, is subjected to the in situ test method.

The details of the parameters used are given in the contents of the CWA. NA

The Business Plan, as well as the introduction and contents of the CWA36, are considered as sufficient by the majority of e WS36 participants.

EPFA/KF (35.28)

4. Principles of the test method

para 2.

para.3.

te

te

This talks about ‘....(in order to have a link with......)’. This is not a scientific method of expressing anything. ‘...predefined parameters.’

The paragraph should be re-written to explain that the method is comparative, although this would contradict the introduction, which appears to say that the test method will determine thermal properties rather than compare them.

Make reference to these ‘predefined parameters’ or state where they can be found.

Both the paragraph and the Introduction are correct as the test is to provide both thermal characteristic of the IMMR tested and a link with conventional existing methods of test and calculations associated. As mentioned in the Business Plan, for an initial period there is need to indicate the link between the results from the test method proposed by the CWA, compared with the results obtained by conventional test methods. It is considered that one way of providing this link is to indicate


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what happens when a tradition homogeneous insulation product, having a known declared value, is subjected to the in situ test method.

The details of the parameters used are given in the contents of the CWA, especially Clause 5 Apparatus NA

JS/ URSA

(39.16)

4.- Principles

Pag 11

One cell is insulated with a thin multi-layer reflective insulation product, ….

GE In my opinion one test cell is enough if direct heat flow trough the insulated part of the roof is accurately measured.

In this way tests are less expensive and this CWA can be used not only for MRRF but for any product

Only one test cell containing the product under consideration

A minimum of three test cells was stated in the Business plan and is to be maintained. NA

What you propose in totally in opposition with the Business plan that you have already agreed, as well as its full support.

Knauf / SW (36.10)

4 page 11 One cell is insulated with a thin multi-layer reflective insulation product, one insulated with a traditional insulation product……

te

If heat flow is measured it is not necessary to have three test cells. The test cell with no insulation does not provide useful information. If sufficient sensors are used including tracer gas to measure air leakage and heat flow measurements then it will only be necessary to have one test cell to determine the performance of the cells and the products. However two cells insulated with the same products would provide a more robust result than one

Rewrite A minimum of three test cells was stated in the Business plan and is to be maintained. NA

What you propose in totally in opposition with the Business plan that you have already agreed as well as its full support.

The non-insulated test cell has the important function of permitting to know, under similar external weather conditions, what is the thermal inertia due to the test structure and the thermal inertia due to insulation systems.

The use of several test cells provides also important information that will permit, among others, relevant information to be


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compared with existing conventional calculations.

When the link with conventional calculation will be no more necessary, then the test cells will be used in order to measure several IMMR in the same time or the same one in several test cell.

As it was also suggested at the 1st plenary meeting, a 4th or 5th test cell will permit to make cross measurements as you suggest

PAROC/JF

(33.18)

4.- Principles

Page 11

One cell is insulated with a thin multi-layer reflective insulation product, ….

ge In my opinion one test cell is enough if direct heat flow trough the insulated part of the roof is accurately measured.

The test cell without insulation will not give any value to the test and will only make it more expensive.

Only one test cell containing the product under consideration. Delete the one without insulation



Please refer to the response above.

STGOBAIN/AK (34.22)

4 Par 2 How do you know that all the materials are performing following their declared values?

The total setup of comparison three test cells isn’t correct. In good cases for mineral wool lambda declared is equal to lambda design. In very bad installed cases lambda declared isn’t equal to lambda declared. There is no use of comparing with other materials.

There is no reason to compare insulation materials together in this CWA36. The only comparison is with conventional calculation methods.

All WS36 participants are well aware that in the best case the insulation performs as it design thermal resistance which can be close to the declared thermal resistance.

There is no reason to have a bad (or very bad) installed insulation product. The CWA36


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details sufficient requirement in order to prevent such case. Moreover you make no allowance for the requirements of the CWA for the installation of the insulations products the recommendation for the expertise of test laboratories.

NA

If differences exist between declared and design value, compared to in situ results, this will be dependant of the weather conditions that is the principle of this CWA to make evidence of that.

STGOBAIN/AK (34.23)

4 Par 5 This provides…use. Where is the foundation for this remark?

If not delete. The foundation for this remark is to be found in this CWA. NA

The clause 4 is for explaining the principle of the test method without any need for detail at this level.

STGOBAIN/AK (34.24)

4 Par 6 In this part you underline the fact that you don’t need other test cells so delete the comparison. It makes test unnecessarily expensive for SME’s.



JS/ URSA

(39.17)

5.1 Roofed test cell

A minimum of three…

TE In my opinion one test cell is enough if direct heat flow trough the insulated part of the roof is accurately measured.

In this way tests are less expensive and this CWA can be used not only for MRRF but for any product

Many or subsequent parts of the document are affected

Only one test cell containing the product under consideration.


What you propose in totally in opposition with


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by this proposal the Business plan that you have already agreed as well as its full support.

PAROC/JF

(33.19)

5.1 Roofed test cell

A minimum of three…

te One test cell is enough if the test is a real in situ test, and two is enough if the test is a comparative test.

Change accordingly. A minimum of three test cells was stated in the Business plan and is to be maintained. NA

What you propose in totally in opposition with the Business plan that you have already agreed as well as its full support.

BING /JR (40.16)

5.1 Second bullet point

Te We would again recommend that a uniform thickness of plain expanded polystyrene (EPS) is used as the insulation in the reference test cell. The exact thickness of the EPS and its thermal conductivity would then be accurately known (essential if results from different test cells are to be compared). This would NOT be true if mineral wool, especially low-density, mineral wool were used as the reference material. This would have different thicknesses in different parts of the installation and worse still, the thermal conductivity of low density mineral wool varies with density and so it will be very difficult to produce a reference cell with consistent (and therefore reproducible) thermal properties in all parts of the external envelope.

Change reference material to a more stable type which may help to give meaningful results to the work.

Again it must be pointed out the reference insulation product has been chosen to be the most commonly used form of insulation product used in sloping roof applications. This has been consistently supported by the majority of participants. NA

It must be pointed out also that low confidence is given for mineral wool as stable and capable of keeping its original declared value when installed in real life.

JS/ URSA

(39.18)

5.1.1 Design of roofed test cell

Add a bullet point:

When an insulation product is used thermal bridges (as rafters,..) must be corrected in order to minimise it’s impact

Clause 6.4.2 paragraph 2 takes care of thermal bridges. PA

The installation of the insulation products shall not be in conflict with national building regulation as well as complying with the manufacturer technical documentations that does probably take this requirement into account.

PAROC/JF

5.1.1 The note is not necessary Delete note 2:

It is considered of supplementary value and


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(33.20) should remain NA

PAROC/JF (33.21)

5.1.2 Standard deviation

te Standard deviation of only three values is not a good measure here

Change back to difference Modification has been made concerning all references on standard deviations. Please refer to the new version of the CWA36. PA

BING /JR (40.17)

5.1.2 Te NB:-This comment is prompted by this section although it might be more appropriate elsewhere. To ensure that the criteria used for deciding if the cells are sufficiently uniform are adequate and to understand what is actually being measured, it is important that a sensitivity analysis of the test cells is carried out. This would determine by calculation the relative contribution of the following under a variety of likely climatic conditions: • Heat transfer through the cold bridging of the

rafters • Heat transfer through the floor • Heat transfer resulting from air infiltration. It would also be useful to determine • The power required, in the steady state, to sustain

specific temperature differences across the building envelope. This would give an indication of how much of the measured power was being used to heat (or cool) the test cell structure which is much more massive than any of the insulation systems that will be tested.

Adjust wording to take these points into account.

The sensitivity analysis is already suggested in the version 3 of the CWA36 (clause 8.4.4).

This was identified by the Modelling Group where sufficient arguments have been provided to doing this analysis specifically relevant for the in situ test (probably more relevant than the GUM method).

No reason to adjust the wording in this section 5.1.2.

NA

EPFA/KF (35.29)

5.1.2 4th bullet point

8th bullet point

te

ed

Is it meaningful to speak about ‘standard deviation’ when you are making, e.g. 3 linear measurements?

The word ‘level’ has no meaning after ‘temperature’ here.

Are statistical terms meaningful here? There are several other instances of similar use of ‘statistics’ in the CWA.

Delete ‘level’.

There have been a number of requests for tolerances to be given. Why should they not be given for the dimensions of the test cell? NA

According to the discussion raised during the 3rd PM about accuracy, it was agreed that no true value is available for in situ testing. This is the reason why the requirements have been changed by comparison between individual value with the average value instead of the individual values together.

Change wording to


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“internal temperature T(1)” . A

BING /JR (40.18)

5.1.2 8th bullet point

ed Temperature level has no real meaning.

Remove the word ‘level.’

Change wording to “internal temperature T(1)” . A

EPFA/KF (35.30)

5.1.3 Location 3rd bullet point

te The two subsidiary bullet points under this point could be mutually conflicting in the case of a prevailing wind having a major component of direction which is easterly or westerly.

Re-think this requirement. Preference given for the best compromise between the 2 parameters. PA

STGOBAIN/AK

(34.25)

5.1.3 What is leading, sun or wind direction? Preference given for the best compromise between the 2 parameters. PA

BING /JR (40.19)

5.1.4 Te By using the information gained from the comment to 5.1.2 the importance of the power used to heat or cool the guarded entrance will become apparent. A great deal of care is needed to ensure that the influence of the guarded entrance is not significant and is the same for all three test cells.

The qualification stage is to ensure that the thermal responses of all the test cells are within the quoted limits. PA

This is also the reason why the set point temperature is required to be 1°C less than the test cell volume.

Moreover, compared to version 2, the CWA36 version 3 includes new requirements that ask to control the energy consumed in the guarded spaces during the calibration phase and the main test in order to be able to identify a potential significant difference that can inform about the effect of one guarded entrance on the test cell.

EPFA/KF (35.31)

5.1.4 Entrance

para.1 te There is no definition of the amount of heat loss/gain that is acceptable as a result of the ‘guarded entrance chamber’ and this paragraph raises more questions than it answers.

Define ‘minimise heat transfer’. Clear up thinking on this matter.

As the maximum heat loss through the floor is 10 % and the guarded entrance may be through the floor or through the gable end wall, the combined maximum heat


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loss shall remain within the same limit of 10% A

It is very common for a standard that has an objective as defined as “ minimise heat transfer”, Then it is up to the laboratory to ensure this is achieved with any technical solution.

The fact that the entrance is to be guarded is one efficient solution that does not need more details.

The RRT will permit to identify the specific requirement that are not sufficient.

EPFA/KF (35.32)

5.1.4 Location para.2 te Does this mean that the entrance is always in a gable end? One assumes so from the Annex A drawing. What if there is no north or east side of the building when considering the requirements of 5.1.3 (if these can be understood).

‘The walls of the guarded entrance shall be insulated...’.

Once again this indicates unclear and unscientific thinking. Define the gable into which the door will be built as being that ‘with a substantially northerly or easterly aspect’.

Define ‘insulated’. With what is it insulated and to what U value?

The assumption is incorrect; as described in the first paragraph access may be via a trap door in the floor.

The requirement for 1° C temperature difference between the temperature within the test cell and the use of a HFM through the door will enable the heat loss to be minimised and measured

The test laboratory shall specify the necessary type and U value of insulation to be used to ensure compliance with the CWA .NA

But in order to clarify the purpose of the second paragraph, a sentence will be added: When the guarded entrance is placed against the test cell …

BING /JR (40.20)

5.1.5 Air exchange requireme

Te Also see comment to 3.1.8- This could be a very significant component of the heat loss/gain of such a small, extremely well insulated enclosure. The air

The air exchange rates have to be as low as possible and the same for all test cells. Tracer gas methods should be used to

The use of the Blower door method according to EN 13829, combined with


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nts infiltration rate must be the same for all the test cells (which may have a bearing on how the Test Cells are made as one is to be tested without any insulation and so will not obtain any air tightness benefit from the insulation installation)

measure air exchange rate. a thermography test using the infra-red camera method according to ISO 6781, are considered sufficient to permit accurate results to be obtained.

The use of tracer gas methods are considered to be very difficult to maintain over long periods of test and very expensive to run. This is the reason why its use is not defined in the CWA36. However, the CWA allows, in clause 8.4.4 as well as for the RRT purposes, the individual measurement with tracer gas, independently to the CWA36, in order to have additional information.

Moreover, in the section 8.3, it is clearly explained that weather data without any wind shall conduce to a negligible air exchange between inside and outside. PA

EPFA/KF (35.33)

5.1.5 Air exchange

te The air exchange could be a very significant part of the heat loss of the well insulated test cells. Hence it is essential that it is the same for all three cells and it is difficult to see how this will be achieved with one cell un-insulated and, therefore, of a different construction to the other two. The accuracy of the blower door method to measure the air exchange, at ±15%, appears inadequate.

It is felt essential that a more accurate method of determining both air exchange rates and the position of the ‘leaks’ in the cells is specified.

The use of the Blower door method according to EN 13829, combined with a thermography test using the infra-red camera method according to ISO 6781, are considered sufficient to permit accurate results being obtained NA.

JS/ URSA (39.19)

5.1.5 Air exchange

Pag 15

…ratio external surface/volume equal to 0,75 according to EN

TE This reference is used for indoor air quality not due to air leakage on building elements

The reference to EN 15242 is considered relevant to the building in which IMMR is most commonly used.

Please refer also to other responses above and


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15242:2007

below NA

PAROC/JF

(33.22)

5.1.5 Air exange

Page 15

Air exchange rate shall be kept to a common and fixed value in conformity with existing building regulations of the country

te Building regulations are applicable to real buildings and not to test cells.

On real buildings airs exchange rate is justified in order to maintain healthy ambiance inside, it’s not the case for cell test.

The test cells have no windows, doors etc and therefore the air exchange rates must be lower than required by the building codes in order to make the cell comparable.

Max Air exchange rate shall be <1 (preferable 0,5)

An objective of the design of the test cell is to reflect common designs of buildings including form, materials and methods of construction. To do this it requires that local building regulations should be applied which would affect the building. Taking the medium level means that it is lower than that permitted by EN 15242: 2007 NA

It has been a stated aim that the conditions that the test cell is subjected to are to be as relevant as possible and practicable to a real building. Thus such things as air exchange rates are to be relevant to building regulations. NA

As it was explained and repeated during the physical UIT meeting (to which you were invited) a large majority of existing or new buildings are not airtight and this has an influence on the thermal performance of the insulation system. The CWA do not intent to represent only 1% of the European building but able to represent a much more representative part of the construction.

This is why low air exchange rates are allowed by this CWA36, as well as others, if chosen by the laboratory and the requestor.


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Moreover the proposed data analysis permits to have both information in the same in situ test results: without air exchange (without wind) and with air exchange. Given a real chance with this method to have some information about the impact of this parameter on the thermal performance of insulation.

STGOBAIN/AK (34.26)

5.1.5 The surface/volume of the designed test cell is app. 3. So you should be able (easily) to reach maximum 3,8 for n50;Pa for this test cell. If you don’t do this the air tightness at 50 Pas is around 15! This is the old comparison method used by certain producers. With mineral wool insulation installed in a proper way you can reach lower than 1 (see WG12 report N111).

Change S/V ratio to 3. The ratio surface / volume is around 1,5 for the RRT suggested design. This is not general for the CWA36, because all other ratios can be used. This is why, by convention, the N50 is expressed for a S/V=0,75.

N111 refer to concrete building and, even then great efforts are needed in order to achieve a low level of air tightness.

According to physic laws and especially the exponential function of air infiltration rate dependence to the difference of pressure, then: Zero wind = negligible difference of pressure = negligible air exchange rate = negligible associated heat losses by air exchange.

Please refer also to other responses below and above. NA

JS/ URSA (39.20)

5.1.5 Air exange

Pag 15

Air exchange rate shall be kept to

TE Building regulations are applicable to real buildings and not to test cells.

On real buildings air exchange rate is justified in order

Air exchange rate shall be kept at minimum possible level.

It has been a stated aim that the conditions that the test cell is subjected to are to be as relevant


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a common and fixed value in conformity with existing building regulations of the country

to maintain healthy ambiance inside, this is not the case for test cell.

The air permeability on roof, walls,.. on real buildings is much lower than air exchange rates referred on building codes (for that reason ventilation systems are introduced on buildings)

as possible and practicable to a real building. Thus such things as air exchange rates are to be relevant to building regulations. NA

As it was explained and repeated during the physical UIT meeting (to which you were invited) it is that a large majority of existing or new buildings are not airtight and this has an influence on the thermal performance of the insulation system. The CWA do not intent to represent only 1% of the European building but able to represent a much more representative part of the constructions.

This is why low air exchange rates are allowed by this CWA36, as well as others, if chosen by the laboratory and the requestor.

Moreover, the proposed data analysis permits to have both information in the same in situ test results: without air exchange (without wind) and with air exchange. Giving the opportunity for this method to have give information about the impact of this parameter on the thermal performance of insulation.

BING /JR (40.21)

5.1.6 Additional requirements

Te As the floor area is a large fraction of the test area this will need to be monitored carefully. Thermocouples will need to be fixed to the external and internal surfaces of the floor insulation and the thickness and thermal conductivity of the floor insulation known. The heat transfer through the floor can then be determined.

Additional measuring requirements for thermal losses through the floor area.

The limit for heat loss through the floor is specified in the clause. Additionally The use of heat flux meters to measure heat flow through the floor is a


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requirement of clause 5.4.4. Thus the thickness and type of insulation used in the floor is for the laboratory to specify that will comply with the requirements. PA

PAROC/JF (33.23)

5.1.6.

Page 15

The floor of the roofed test cells shall be heavily insulated ……

te Without mandatory measurements on all heat flows the additional requirements can not be verified.

Infra-red thermography can be optional, the design of the cell already determines the thermal bridges, and heat transfer through these cannot be measured with this technique.

Heat flow measurement must be mandatory

The use of heat flux meters for measuring heat flow through the floor is a requirement of clause 5.4.4

Other uses of heat flux meters are given in 5.4.4. NA

STGOBAIN/ AK (34.27)

5.1.6 I have made some calculation with energy performance calculation tool used in the Netherlands (base for EPBD). If you want to get the 80% of energy through the roof you need to:

1. R value roof 2 m2K/w you need for floor and gable wall to reach a R value of 15 m2K/W

2. R value roof 6 m2K/W you need for floor and gable wall to reach a R value of 30 m2K/w

FYI I have added the excel sheets with calculation results. If needed I could explain.

WS 36 EP calculations.zip

You can’t obtain the adequate accurate thermal performance if you set this rule. How would you prove all this statements?

First of all, the space under the floor is guarded AND the floor heavily insulated AND the heat flows through the floor are more difficult than for other parts (flow down). Then the low thermal transmittance through the floor is by definition ensured and controlled by HFM.

Same consideration for the door entrance.

The proposed CWA requires that 80% of the total energy through the test area, which is considered as the roof and the gable end walls.

CWA36 allows also the use of HFM in order to permit the potential evaluation of the heat flow through the parts of the structure and then possibly correct it according to the requirement. NA

JS/ URSA

5.1.6. Aditional requirements

The floor of the roofed test

TE Without mandatory measurements on all heat flows the additional requirements can not be verified.

Heat flow measurement must be mandatory

The use of heat flux meters to measure heat flow through the floor is a


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(39.21) Pag 15 cells shall be heavily insulated ……

requirement of clause 5.4.4

Other uses of heat flux meters are given in 5.4.4. NA

JS/ URSA (39.22)

Pag 15 Installation of the insulation products shall comply with the manufacturers’ instructions …

TE The suggested installation on annex is not according with manufacturer’s instructions

Modify the suggested construction on annexes and so called RRT

The suggested construction in Annex A is one example that already complies with most of the national buildings rules.

The CWA is not expected to be an encyclopaedia of manufacturers installation instructions NA.

PAROC/JF (33.24)

Page 15 Installation of the insulation products shall comply with the manufacturers’ instructions …

te The suggested installation of reflective insulation in gable ends will make the evaluation more complicated. It is easy to insulate the gable ends with high performance insulation, which is not as dependent on the orientation as reflective ins.

Modify the suggested construction on gable ends .

This is one of the subjects that have been proposed in the UTI, without changing the opinion of the majority of participants to use the gable ends for the tested insulation products. The reasons for the choice are stated in clause 5.1.7. NA

This question has also been widely discussed with you and the proposer during the UTI physical meeting held on the 5th of November.

JS/ URSA (39.23)

5.1.1 Internal temperature setting Pag 16

The internal temperature settings used shall be between 18°C and 23°C

TE Internal temperatures must be differentiated during a winter period and a summer period; if not an unrealistic behaviour can be introduced.

The internal temperature settings shall be between 18 and 20 ºC during winter season and between 24 to 26 ºC during summer season

Time has been already spent on this question and your proposal does not change anything for the needs of the CWA36. NA

The CWA just needs to have a requirement about the internal temperature.

This requirement should be sufficiently large to permit a sufficient difference of temperature during test, between inside and outside. This,


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depending of the country, that can be on the south or the north of Europe with very different external winter conditions.

Your proposition is understandable, but why not between 18° and 26°, or between 18° and 25°, … CR

PAROC/JF (33.25)

5.1.7

2) te A calculation with fewer steps, but with much more uncertain values, will not increase the accuracy. This sentence has been put here only to justify a wrong installation.

Delete the sentence The 2nd sentence does not diminish in any way the requirement of the CWA that the highest attention to detail shall be paid to the correct installation of the insulation products and to the verification of the installation NA

BING /JR (40.22)

5.2.1 &

5.2.2&

5.2.3

Heating and cooling requirements

Te As the energy used to keep the test cell at a specified temperature is the most important part of this measurement it should be approached more as one would to a laboratory apparatus rather than as it appears in this document which is the way one would heat a house. Suggestions for improving the heating system are:- • Use a heater with the minimum power output that

will be required – you do not want large amounts of heat being switched on for short periods of time.

• Use a heater system that has the smallest

temperature difference to the target air temperature that will achieve the control required.

• Use a heater system that covers the whole width

(length) of the test cell. • Use DC heaters as it is easier to accurately

measure the power used (compared to the cost of the initial set up of the three test cells, DC power supplies would only be a small additional expense).

• Use PID controllers not on/off thermostats. Again

these can be purchase quite cheaply now.

Take account of recommended improvements and include these in a revised methodology.

By experience of the Proposers, the proposed requirements are considered as sufficient and subject of validation thanks to the RRT next stage.

The CWA includes a proposal for using two of four heaters to permit a balanced heat input into the test cell and reduce large fluctuations in the internal temperature.

The heater system has to be able to cope with large fluctuation in external temperature and large seasonal changes.

Fan heaters provide good distribution of heat.

It is for the laboratory to select the most appropriate heaters.

It is for the laboratory to select the most


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appropriate control system. PA

EPFA/KF (35.34)

5.2.1 Heating - general

para.3 te It seems strange that a heating system with only on/off controls and no power control is recommended. Why are not three (or at least two) term controllers recommended and the heat input controlled more accurately?

Recommend the use of multi-term controllers for heat input.

The switching devices and temperature sensors would be separate to the fan heaters. NA

The data analysis (especially during the calibration of the test cell) will permit such control of this requirement.

EPFA/KF (35.35)

5.2.2 te Do normal commercial fan heaters actually have a ± 0.5oC switching range. This is doubted.

Use multi-term heat control as recommended above.

The switching devices and temperature sensors would be separate to the fan heaters. NA

The data analysis (especially during the calibration of the test cell) will permit such control of this requirement.

EPFA/KF (35.36)

5.2.3 para.1 te Do fan heaters actually have a thermal efficiency of 1? What about the fan which will generate some heat from the motor.

Ensure that the statement in this paragraph is correct.

The heat goes into the test cell therefore it is used to maintain the temperature. NA

Please refer also to the answer below

JS/ URSA (39.24)

5.2.3 Heating system

Pag 17

…is strongly recommended to use a system that gives a rate equal to 1 between

TE Unfortunately systems (generation + emission + regulation) with efficiency equal to 1 don’t exist. In the best cases will be near to 1.

How “near” do you propose? CR

Fan heaters installed inside the test cell produce 100% thermal energy equal to 100% of the electric energy consumption consumed. This considers that the energy used by the fan is directly transformed in thermal energy through the Joules effect.

This seems also be the same consideration for laboratory test that uses


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heaters. BING /JR (40.23)

5.2.4 Cooling system

Te Calibrating the thermal efficiency of cooling systems over a variety of conditions is very difficult and rather inaccurate – the errors this will introduce are likely to be large. Great care must be taken to ensure additional systematic errors between the three test cells are not introduced with this step.

Further detail required to ensure no errors are introduced from the cooling system

The measurement and calculation of the coefficient of performance of cooling system is common. The CWA permits to have two sets of information on it: the nominal COP when calibrated (full power rate for a sufficient long period and under similar boundary conditions) and by an individual measurement during the main test.

However, it has to be agreed that the uncertainty may be greater for summer test using cooling system than for winter test using heater that does not need COP. PA

EPFA/KF (35.37)

5.2.4 te Annex B gives a method for the determination of the efficiency of a cooling unit. Has this been agreed by a refrigeration engineer not an installer?

Annex B and, hence, the comments in this paragraph concerning efficiency of air conditioning systems need to be verified by a fully qualified refrigeration engineer.

Verification will be done as requested.

A

BING /JR (40.24)

5.4 Internal sensors

2nd paragraph

Te This statement is vague and irrelevant. The test method must clearly state the equipment to be used

Remove this paragraph. Agreed : The text is deleted. A

Please refer to the response below.

EPFA/KF (35.38)

5.4 Internal sensors

para. 1, line 3

para 2.

ed

te

‘control’ is not correct English

This sentence is too vague to have meaning and can be no part of a ‘scientific’ document.

Replace ‘control’ with ‘ensure’.

Delete this sentence.

Agree to replace “control”. PA

Why do you want to delete the second paragraph that states that the list below is not restrictive and that other equipments and sensors may be used?

STGOBAIN/AK (34.28)

5.4 The mentioned accuracy of the temperature sensors that are used in the construction is +- 0,1K. Their location is not specifically mentioned. It’s certain that there is not indicated that the temperature of the reflective foil should be measured.

If I make a calculation wit TRISCO for three setups the temperature of the surface of the internal and external

There is not enough details in your explanation for have a complete view of what you meant. Moreover TRISCO is not available


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plasterboard are:

1. 6 cm glass wool int. T 0,62 out T 18,32 2. 8 cm glass wool int. T 0,48 out T 18,70 3. mrf foil int. T 0,59 out T 18,40

So if you look to the difference of 6 and 8 cm glass wool it’s only 0,2. That is the value you give in 6.3.1 as accuracy (+ or – 0,1K). In practice the value of the U value is more then 25%!TRISCO files are embedded in the document, I ask to look at them. If need support could be given.

Trisco WS36 AK.zip This shows also that with different solutions the temperature difference on the internal side of the construction is the same. So how would you come to thermal loss without measuring the heatflow is still questionable.

to the proposer (only BISCO), then the files cannot be opened

Our first reaction: if your comment is right for in situ testing, it must also be right for laboratory test and Guarded Hot Box measurement that use the energy balance to evaluate the thermal flow from the energy consumption. It is the case?

It is to be noted that you initially expressed the whish to participate to the modelling group, but resigned later. Such of calculation and software consideration was one of the purposes of the work of the Modelling Group. It is regrettable that you do not participate and/or bring your expertise through other modelling group participant that you know.

Surface temperature measurement recorded during the RRT will permit to compare the prediction of your software prediction with experimentation, then a clear view of what you raised will be obtained. This is the role of RRT to conduce to such of control and verifications. CR

EPFA/KF (35.39)

5.4.1 Temperature sensors

te Yes they do! Bad ones do not. The accuracy of temperature sensors is defined in 6.3.1 and this clause is of no worth to the CWA.

Delete. This sentence is used in other standards.

It seems that experts have previously considered the necessity to write such a sentence. NA


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BING /JR (40.25)

5.4.1.1 1st paragraph

Te Obtaining temperature sensors accurate to ± 0.1oC is not easy. If Class 1 Type T thermocouples are used the standard tables are quoted as being within ± 0.5 °C - if Class 2 Type T thermocouples are used the standard tables are quoted as being within ± 1.0°C. If individually calibrated (or a batch of wire is calibrated) the normal uncertainty offered will be about ± 0.3 °C . It is possible to get Type T calibrated to ± 0.1 °C but you have to ask for it specially. The most important thing is to ensure all the thermocouples in the three cells are consistent. If you measure the mean temperature 0.5 °C too high or low it is not important but if you measure the temperature difference 0.5 °C too high or low it could be a large error.

Internal temperature is very important for the consideration of thermal transfer. The better is the accuracy of the thermal sensor, the better will be the accuracy of the result.

The specific sentence already uses the EN 9869.

It seems to be relevant (as experts have previously considered this requirement) that “If the temperature difference is obtained by subtracting two temperatures, the sensors shall be calibrated to an accuracy of ± 0,1 K”. NA

BING /JR (40.26)

5.4.1.1 2nd paragraph

RTD is not defined Define what is meant by RTD Full name to be given in text A All laboratories know what is a RTD! (Resistance Temperature Detector) A resistance temperature detector (RTD) operates on the principle that electrical resistance of metal changes as its temperature changes. The resistance of the sensing element increases as the temperature rises.

EPFA/KF (35.40)

5.4.1.1 para. 2 ed ‘RTD’ is not defined and should be added to the definitions in 3.

Add ‘RTD’ to 3. Full name to be added in text PA

BING /JR (40.27)

5.4.1.2 Te The ‘’plastic tube’ used to protect the thermocouples needs to be better defined.

Define the plastic tube used to protect the temperature sensors

If you consider that a better description is required please propose one CR


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EPFA/KF (35.41)

5.4.1.2 para.1 te ‘....mounting inside a plastic tube.’ The mounting tubes must be described and specified

If you consider that a better description is required please propose one CR

BING /JR (40.28)

5.4.2 Te See comment to 5.2.1, 5.2.2, 5.2.3 Please refer to associated responses

EPFA/KF (35.42)

5.4.2 Energy consumption sensors

1st bullet point, 2nd sub-bullet

ed ‘precision’ is incorrect Change ‘precision’ to ‘accuracy’. One may wish to define the precision also.

Agree to change to accuracy A

BING /JR (40.29)

5.4.4 Te As has been discussed many times in the WS 36, there is a strong scientific view that heat flow meters are essential to determine the heat loss through the roof system

Use of heat flow meters should be extended to provide full information on heat flows through the test structure.

The CWA36 already permit such a requirement.

See also response to URSA comment at end of document NA

EPFA/KF (35.43)

5.4.4 Heat flow meters

te The use of heat flow meters is recommended as the principal means of collecting heat flow information.

Make HFMs obligatory. See response to URSA comment at end of document NA

PAROC/JF (33.26)

5.4.4

Page 19

Heat flow meters

te

Heat transfer through the insulation shall be measured; HFM is one method which can be used.

Heat flow meters must be placed in all relevant parts of the test cell (insulated part of the roof, gable ends, floor …)

The CWA36 already permit such a requirement.


JS/ URSA

(39.25)

5.4.4 Heat flow meters

Pag 19

TE Heat flow meters must be placed in all relevant parts of the test cell (insulated part off the roof, thermal bridges,…)

The CWA36 already permits such a requirement.


JS/ URSA

(39.26)

Pag 20 It is pointed out that heat flux measurements and surface temperature measurements can

It is for that reason that Heat flow meters must be mandatory and the fundamental part of the measurements on the test cell

Heat flow meters must be mandatory The reason why they can be used (and proposed to be) is for control purposes in order to have some information about local heat transfers that permit, when using conventional calculation, to validate some of the calculation parameters


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provide information that permits a link between energy consumption and thermal properties of the insulation system

and give greater confident about their reliability for the specific calculation.


PAROC/JF (33.27)

5.4.4

Page 20

It is pointed out that heat flux measurements …

te It is for that reason that Heat flow meters must be mandatory and a fundamental part of the measurements on the test cell

Heat flow meters must be mandatory The reason why they can be used (and proposed to be) is for control purposes in order to have some information about local heat transfers that permit, when using conventional calculation, to validate some of the calculation parameters and give greater confident about their reliability for the specific calculation.


STGOBAIN/AK

(34.29)

5.4.1.3

OUT OF ORDER

Surface temperature surfaces

How would you like to use the temperatures to quantify the linear thermal bridges?

Delete – number 2 Heat transfer equations permit also to know the temperature in all parts of the structure. Recording a surface temperature may allow the comparison of measurement with prediction and then the validation or correction of the conventional coefficient selected for conventional calculations. NA

BING /JR (40.30)

6 3rd paragraph1

Ed The sentence referring to frequency of verification does not seem to be as intended.

Reword to give correct meaning Reword first sentence to read “As the roofed test cells are themselves


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considered as part of the test apparatus,.. A

EPFA/KF (35.44)

6. Calibration para.3 te/ed The first sentence is meaningless. Write what is meant or delete. Add to sentence “as detailed below”. A

EPFA/KF (35.45)

6.1 para.2 te It is not understood to what thermal energy data the statistics are being applied.

Clarify statistical references. Agree to clarify paragraph A

Sentence has been changed for clarification “This difference (5% at maximum) shall be evaluated by comparing individual values to the average of these values.”

PAROC/JF (33.28)

6.2 The user should,…

ge The user (who is it?) shall not define the accuracies, the CWA should require them

Change accordingly where the accuracy is not given, and delete the sentence.

Agree the sentence is redundant due to the last sentence of indent b) A

EPFA/KF (35.46)

6.3.1 para. 3 te ‘Special procedures..’ What special procedures? Define precisely what is meant. This sentence is commonly used and actually used in existing standards in order to explain that relevant thermal sensor shall be used considering the specific range of considered temperatures during the test. It is considered as sufficiently understandable. NA

EPFA/KF (35.47)

6.3.2 line 2 ed The word ‘an’ has been deleted but should remain. an stet. Agree A It is done

EPFA/KF (35.48)

6.3.3 line 3 ed The word ‘an’ has been deleted but should remain. an stet. Agree A It is done

EPFA/KF (35.49)

6.4.2 para.2 te ‘In case of abnormal thermal...’ Define abnormal. Outside what parameters is an instance of thermal bridging or air leakage to be declared ‘abnormal’?

Define the conditions to be declared ‘abnormal’.

Clarification to be given in CWA A

It is done EPFA/KF (35.50)

6.4.4 para.2 te ‘(less than 5% maximum difference)’ refers to temperatures. Temperatures are not quantities. If it meant 5% of the recorded value of temperature then the recording must be defined as oC or oA. (5% of 293 is

Specify temperature scale or define meaning of 5%.

CWA to be modified A

it is done.


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very different from 5% of 20!) BING /JR (40.31)

7.1 Te This is a most important step. If the intention is to make these tests carried out in different institutes, comparable with each other (and if they are not - what use are they) then how and what traditional insulation is installed in the reference cell is extremely important and must be the same for all reference cells and so should be specified carefully. See previous comments on the choice of traditional insulation material.

Further detail required This comment shows a profound misunderstanding of the proposed CWA. The Proposers have made much effort to explain the flexible approach taken. NA

Sufficient approaches have been defined in order to ensure the relevant installation of all insulation products as especially summarised in clause 8.4.1.

EPFA/KF (35.51)

7.6 para. 4 te The relevance of the actual weather conditions, so long as they are fully and accurately recorded, to the local or national weather conditions must be irrelevant. In most countries in Europe, ‘national’ weather conditions would be meaningless. In the UK, as an example, there is skiing in Scotland while palm trees grow along the sea front in Cornwall. What does it matter what the ‘local’ normal weather conditions are so long as the actual conditions are properly recorded?

This whole concept of any kind of ‘normal’ weather and its relevance to the test procedure is not understood.

Comment potentially referring to clause 7.7 and not 7.6

It appears the commenter is looking at the test from the point of view of laboratory condition tests. The basis for the in situ testis that the test cells are exposed to weather conditions. Weather can be unpredictable thus some check that the weather conditions recorded are relevant to “Official recorded ” weather conditions NA

The reason why it is needed to compare recorded weather parameter on the test site with weather data recorded by an independent party close to the test site (airport, …) is especially in order to control that there are no significant differences that can be due to incorrect recording / sensor information, as well as potential building or vegetable masking.


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JS/ URSA

(39.27)

7.8 Measurements and records

Pag 27

TE According to the opinion that heat flow is a mandatory (and the most relevant) measurement this parameter must be recorded

Add a bullet point: Different Heat flow measured

Heat flow measurement will be maintained as a control. Energy consumed is the main measurement of the CWA NA

It is clear that they are recorded; if not no reason to have such sensor for in situ testing and relevant description in clause 5.4.4.

The clause 7.8 details the “main parameters to be measured and recorded” as it is clearly written. Main does not mean an exhaustive list.

PAROC/JF

(33.29)

7.8 Measurements and records

Page 27

te Heat flow measurements shall be mandatory and recorded

Add a bullet point: Measured Heat flows

NA

See response above

BING /JR (40.32)

8 Complete section

Ge Due to the complexity and detail of this section it has not been possible in the time allowed to give a detailed analysis.

It should be noted that many of the symbols are not clear, for example on p 60 it is difficult to understand the suffixes.

The formulas including suffixes will be made legible in the published version. A

All of the suffixes and symbols are taken from conventional and standardized calculation methods.

The RRT is especially done for validating the full data analysis method. This is why the RRT is considered as a fundamental part of the WS36 and shall start just after the validation of the final version of the CWA36.

EPFA/KF (35.52)

8.1 para. 1 te ‘...an obvious error condition...’ Some can be obvious (e.g. signal failure from a sensor or a temperature inside the cell of 200oC) but others are not o easily defined as error conditions.

There should be a definition (statistical?) of error condition.

Details about the errors to be considered are given in clause 8.1.2: “Identification of reliable


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data and unusable data”

If you have identified other missing please inform the WS36. NA

JS/ URSA

(39.28)

8.1.1 Summary and presentation…

TE Heat flows are not only Control parameters but the real result of the test cell

Introduce a new column with heat flows Heat flow measurement will be maintained as a control. Energy consumed is the main measurement of the CWA NA

Reasons why were widely explained as well as details in clause 5.4.4

HH RW (37.4)

8.1.1Table 1 Table 1 ed Internal temperature is stated as "Set point temperature…". Printing error?

Internal temperature Noted for correction A

It is done

HH RW (37.5)

8.1.1Table 1 Table 1 te As the heading is "in situ recorded data" will be understood continuously it is not correct to have the entry "air tightness level …….."

Your assumption is not accepted., the CWA specifies the recording interval NA

PAROC/JF (33.30)

8.1.1 Table 1 te Heat flows are not only Control parameters but the real result of the test cell

Add a column with heat flows, and move it from Control and related parameters

Heat flow measurement will be maintained as a control for the reason explained in 5.4.4 as well as explained during plenary meeting, UTI discussions and written comments and responses. Energy consumed is the main measurement of the CWA NA

HH RW (37.6)

8.1.2 c te " non insulated test cell: if there is ………no thermal inertia"

It is not correct to state that the test cell has no thermal inertia as the inertia is due to the structure and the insulation has a very limited influence on thermal inertia.

Rephrase to show that the thermal inertia is mainly attributed to the structure. Also the inertia of the uninsulated structure is of no interest as uninsulated is not used to-day

It is not stated that non-insulated test cell does not have thermal inertia but just “if” it does not have. This is a condition not an affirmation. The third bullet considers the condition when the non-insulated test cell has a thermal inertia. NA


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PAROC/JF

(33.31)

8.1.2c Third bullet

te Non insulated test cell

(Its structure has thermal inertia)

Delete the non insulated test cell Of course the non-insulated test cell can have a thermal inertia. The purpose of this clause is to identify this thermal inertia, and by comparison with the insulated test cells, to be able to identify the part of the inertia due to the insulation product / system as well.

This analysis requires the non insulated test cell. Without it, this analysis is not possible. NA

EPFA/KF (35.53)

8.1.2 d) te See comment immediately above. See associated response

NA STGOBAIN/AK (34.30)

8.1.2 I thought this test should be in-situ. So you should not exclude the thermal inertia as mentioned under c

Thermal inertia effects are not excluded. The length of the test period is sufficiently long to avoid uncertainty due heat storage. More over the averages of the recorded data permit to tae into consideration the time response of the insulation system and structure in order to make associable the difference of energy consumption with the difference of external weather conditions (clause 8.1.3)

NA

PAROC/JF (33.32)

8.2.

Table 4: test cell without insulation Delete the column Why? There is no explanation given for your claim. CR

JS/ URSA (39.29)

8.2.3 Principles of conventional calculations

Table 3

TE It is nor sure that methods collected and used are validated for real buildings can be directly used on a test cell (no relevant solar or internal gains, very different ratio envelope area / internal volume, seasonal or monthly calculations,…)

The utilisation factor for gains is only validated for monthly or seasonal periods of calculation, probably

Technical discussion about the possibility to use this approach must be done before to use it. The suggested approach on this document is probably not adapted for a test cell under dynamic (short time) variable conditions.

Conventional calculation methods must be adapted to predict delivered energy because there are used daily by building engineers and building control in order to design


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using this approach on a hourly (or less) period introduces inaccuracy.

There is no “predicted delivery energy” or there is confusion between Delivered and use Energy.

the heating / cooling systems as well as determining the level of performance of the building in terms of KWh/m2/year (A tot F).

These calculations seem to be especially adapted for traditional building materials that are dense, homogeneous, isotropic, … because they were created for this purpose.

In situ test cells are nothing else than a very simple test design that permit simplified calculations. NA

HH RW (37.7)

8.2.3 ed The following clauses are very difficult to read as the usual table of symbols and units is missing, table 3 is not a full replacement for symbols, units, subscripts and abbreviations.

Greek letters are randomly upper and lower case, apparently without difference in meaning.

Equations are written with full stop as multiplication

Follow the CEN template and common editing

Noted for checking during final editing. A

STGOBAIN/AK (34.31)

8.2.3 Table 3 HV Heat transfer Should be air exchange Thank you for your remark, this is corrected. A

STGOBAIN/ AK (34.32)

8.2.3 Table 3 °H is not in situ. So how you can explain that you want to deduce results mentioned to be in-situ compared with predicted energy used based on °H?

Another remark to underline that the setup of this prCWA isn’t correct.

As °H can be evaluated based on a national weather data file, it can also be easily evaluated using a recorded weather data file. In this case °H is directly applied to in situ test and then results compared. NA

HH RW (37.8)

8.2.5 Te How shall the reader/user interpret this chapter, Please give guidance to the reader/user how to react in case of great or small difference or deviation according to table 4

Details are already given in clause 8.2.6 that talks about the analysis of the results GC

HH RW

(37.9)

8.2.5 Table 5 te Please give more detail on how the confidence levels are to be understood.

As a starting point: What type of distribution do you assume

It is a statistical analysis that permits the calculation of the number of predicted data that are included ± X% around


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the recorded ones. This number, divided by the total number of available data corresponds to the statistical percentage of predicted data complying with the expected tolerance (X%).

This will be evaluated also during the RRT. GC

STGOBAIN/AK

(34.33)

8.2.5 Table 5 Seems to come from the sky. Where is the foundation for this remarkable assumptions?

Sorry but your comment is not understandable and no proposition for improvement is made.

Please see above CR

HH RW (37.10)

8.2.6 Second line

ed Reference: 8.2.45 ? Please refer to response to 8.2.4/5

HH RW (37.11)

8.2.6 Te First paragraph: What is the conclusion when this applies and what further action shall be taken?

If the results overlap significantly that means that declared value issue from laboratory and designed values associated are to be considered as the thermal performance of the insulation products tested.

In this case, the result of section 8.3 must give the same result. In any case section 8.3 gives the additional benefit to permit the determination of thermal performances associated to specific ranges of weather conditions.

The RRT will permit to make this kind of comparison between conventional method and recorded in situ data, by several and different independent laboratories. This shall permit to have reliable results about the proposed method. GC


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HH RW (37.12)

8.2.6 Te The second paragraph: If the difference between actual and predicted value is higher and/or the difference is +X% for one case and -Y% (per example +30% and -10%) for another, this reveals that the thermal performance of the test cells, including thermal insulation systems is being incorrectly interpreted by conventional calculations.

The above paragraph in italics doesn't present the whole picture as the use of conventional calculations requires correct use of calculations, correct design and proper workmanship of the cells. Neglecting these parameters will lead to another conclusion: The test cells gives wrong results due to errors in construction and test procedure.

Unfortunately the prCWA v. 3 is not applying the needed requirement as:

• The lenient air tightness requirement and no continuous monitoring of air exchange make it impossible to quantify the heat losses by ventilation it may be 10% or 100% of the losses of the cell envelope.

• Thermal bridges as rafters and studs cannot be neglected as the approximate influence is 10% for multifoil and 20% for MW compared to one dimensional heat flow.

The solution is either to improve the air tightness to a level where the ventilation loss is insignificant or use tracer gas to determine the ventilation losses during the test.

Calculate with programs as: Heat 2&3, Therm or Trisco

Conventional calculation methods must be adapted to predict delivered energy because they are used daily by building engineers and building control in order to design the heating / cooling systems as well as determining the level of performance of the building in terms of KWh/m2/year (A tot F).

In situ test cells are nothing else than a very simple test design that permit simplified calculations.

Here the CWA explains that (by experience) it is possible that in situ test can show energy consumption less than the conventional calculation predicted (-X%). In this case what is the conclusion except the fact that the thermal performances of the insulation product is under estimated?

As you are well aware low levels of air tightness is permitted by his CWA36. NA.

Concerning Trisco calculation, as your participation in the Modelling group has shown, it is not capable of considering inclined surfaces as a pitch roof is composed.

If relevant calculations using such software are pertinent as you seem to


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claim, it was the opportunity for you to provide sufficient demonstration during the Modelling group meetings. However, if you wish to provide additional calculations / software they will be considered and also be evaluated during the RRT.

EPFA/KF (35.54)

8.2.6 Note te This comment on the usefulness of the data collected is irrelevant to the CWA. The value of such a database is questionable and not a part of the business plan of WS36

Delete the note. There is a marked inconsistency with some of the Commenters especially with the “appellants”. Some criticise the lack of explanations others criticise for having explanatory notes. The Business Plan is to explain the principles it is not to provide all the details otherwise it would contain the text of the CWA. NA

No scientists can criticise the availability of such of data base that will permit to increase the possibility of building studies and program research as well as the analysis of repeatability and reproducibility of the results. It is to be noted that such a database is already available for R and λ (lambda) values which have permitted to have lists of material characteristics that now do not need systematic measurements.

HH RW

(37.13)

8.2.6 Second bullet page 37

te The statement that wind ≤ 0.5 m/s eliminates air exchange between inside and outside is highly questionable, in particular considering the lenient air tightness requirement proposed.

See also 8.3.2 a)

Delete the statement or make it conditional to be shown by tracer gas analysis

It is not stated in this clause that air exchange is eliminated. Moreover; as you are well aware, the CWA36 permits a


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lower air exchange rate (n50).

The annex A of the RRT as well as the CWA36 in clause 8.4.4 proposes the option to use tracer gas measurement (independently to the CWA36) in order to control and validate this statement. PA

STGOBAIN/AK

(34.34)

8.2.6 5th par second point

Moreover….appropriate. This IMMR materials are behaving the same as traditional insulation. The thing they are changing is the thermal resistance of the air layer next to it.

IMMR has reflective surfaces and defined air layers inside the product which makes if behave differently form traditional insulation. NA

Conventional calculations were initially determined for dense, homogeneous, isotropic, … material. IMMR are not dense, homogeneous, …

STGOBAIN/AK (34.35)

8.2.6. Table 6 Is not true Delete What proof is there of the commenter statement? NA

This is a part of the result of the Modelling Group work, already detailed in the interim report.

JS/ URSA (39.30)

Page 37 If the difference between actual and predicted value is ……

TE Other possibility is the calculation method is not adapted to predict delivered energy on a test cell (not real building)

Technical discussion about the possibility to use this approach must be done before to use it

Conventional calculation methods must be adapted to predict delivered energy because daily used by building engineers and building control organizations in order to design the heating / cooling systems. as well as determining the level of performance of the building in terms of KWh/m2/year (A tot F).

In situ test cells are nothing else than a very simple test design that permit simplified


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calculations. NA

PAROC/JF (33.33)

8.2.6

Page 37

If the difference between actual and predicted value is ……

te The analysis of the overlap <10% and a high difference is not clear as there is no specific limit given for the difference and what to conclude.

technical discussion about the possibility to use this approach must be done and limits given when to reject conventional calculations (if this is the purpose)

The purpose of the CWA is not to reject the conventional calculation, but on the contrary to permit for each individual in situ testing to make a comparison between conventional calculation and recorded results.

It is evident that if the results overlap significantly that mean that declared value issue from laboratory and designed values associated are to be considered as the thermal performance of the insulation products tested.

In this case, the result of section 8.3 must give the same result. In any case section 8.3 gives the additional benefit of permitting the determination of thermal performances associated to specific ranges of weather conditions.

The RRT will permit to have this kind of comparison between conventional method and recorded in situ data, by several and different independent laboratories. This will permit to have reliable results about the proposed method. NA

JS/ URSA (39.31)

Pag 39 Equation (2)

TE The only input data coming from measurement is Pn all other parameters are unknown it’s not possible to solve this equation in an univoque < unequivocal> way

All methodology must be reviewed When conventional and standardized methods permit to determine all heat loss transfers, this makes the determination also available for the CWA.

Removing the predicted


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Annex (e.g. 3.1)


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heat losses from the energy consumption will permit to isolate the heat losses through the insulation material product, that is the aim of the CWA36 with the specific purpose to make the analysis of the results under specific weather conditions. NA

PAROC/JF (33.34)

Page 39 Equation (2)

te Without measuring other parameters than Pn it’s not possible to solve this equation in an unequivocal way. Only linear bridges are included

Correct the formula and review method. The method proposed permits to identify all necessary parameters by using, as suggested, the conventional calculations methods.

Thermal bridges are well considered: - linear thermal bridges

(Ψ.L.∆T) - integrated thermal

briges (rafters, …) - punctual thermal

bridges if existing (Χ.DT) NA

JS/ URSA

(39.32)

Pag 39 Equation (3)

TE There are at minimum these variables unknown:

Air volume infiltration at any time step

Linear thermal transmittance for all thermal bridges.

Solar factor (U depending) for opaque elements.

Under this situation equation 3 cannot be solved.

All methodology must be reviewed Please see response below NA

PAROC/JF (33.35)


te Equation 3 cannot be solved because many variables are unknown:

Air volume infiltration at any time step

Linear thermal transmittance for all thermal bridges.

Solar factor (U depending) for opaque elements.

Review method Normally, when an architect or a building engineer has to design the power rating necessary to maintain a constant temperature inside a building zone, he has the possibility to use conventional and standardized methods to do it.

This CWA proposes to use the same method for evaluating the different


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thermal losses.

So all parameters are known by conventional determination.

The RRT will permit to validate the use of the proposed method and equation. NA

JS/ URSA (39.33)

Pag 39 When the integral thermal bridges are made with homogeneous, ….. …) the conventional simplification about heat losses [= difference of temperature x equivalent thermal conductivity / thickness] can be applied.

TE Not true.

Thermal bridges effect have always a 2D or 3D dimensions approach

Suggested simplification under- or overestimates the thermal bridging impact

Non accurate methodology

All methodology must be reviewed Please see response below NA

PAROC/JF (33.36)

Page 39 When the integral thermal bridges are made with homogeneous,

te Not true.

Thermal bridges have a 2D or 3D effect

Suggested simplification under or over estimates the influence of the thermal bridges

Review method The Modeling Group were well aware about the potential need to use 2D or 3D calculations, but this is relevant if these calculations are able to consider the full heat transfers due to weather conditions, mixed effect of wind, humidity, DT, solar radiation, … But these complete 3D heat transfers are not yet available and when


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available for a part of them the model and/or calculation methods are not easy to use and equipments (software / computer) not available.

Because most of the existing standards allow already simplified and recognized calculation methods it was agreed to used them. NA

JS/ URSA (39.34)

Pag 39 Equation (4)

TE There are some other relevant thermal bridges than rafters:

Intersection between roof and gables, intersection between slopes on roof, intersection between roof and floor,…

All methodology must be reviewed Thermal bridges are well considered: - linear thermal bridges


bridges (rafters, …) - Point thermal bridges

if existing (Χ.DT) NA PAROC/JF (33.37)


te There are other relevant thermal bridges than rafters:

Intersection between roof and gables, intersection between slopes on roof, intersection between roof and floor,…

Review method Thermal bridges are well considered: - linear thermal bridges


bridges (rafters, …) - Point thermal bridges

if existing (Χ.DT) NA JS/ URSA (39.35)

Pag 39 Equation (5)

TE This equation tries to calculate the thermal heat flow trough the roof but in reality it calculates the total test cell heat flow (door, floor, roof, gables,…)

It is not possible to calculate it due to no information about the thermal bridging impact, the air infiltration impact,…

All methodology must be reviewed Thermal losses through the floor and door entrance are considered as negligible because they are guarded and controlled.

The equation 7 details the other thermal losses that are well considered, including the thermal bridges, solar gains and air exchange. NA

PAROC/JF (33.38)


te This equation tries to calculate the thermal heat flow through the roof but in reality it calculates the total test cell heat flow (door, floor, roof, gables,…)

It’s no possible to calculate it when no information about the impact of thermal bridges, air infiltration etc exist.

Review method Thermal losses through the floor and door entrance are considered as negligible because they are guarded and controlled.

Equation 7 details the other thermal losses that


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are well considered, including the thermal bridges, solar gains and air exchange. NA

JS/ URSA (39.36)

Pag 39 Equation (6)

TE There is a confusion between total thermal transmittance and roof thermal transmittance

All methodology must be reviewed Thermal losses through the floor and door entrance are considered as negligible because they are guarded and controlled.

Equation 7 details the other thermal losses that are well considered, including the thermal bridges, solar gains and air exchange. NA

JS/ URSA (39.37)

All previous calculations are trying to obtain the heat flow trough the insulated part of the roof of the test cell, this information can directly be measured, no calculations are needed if it can be directly measured.

No need for three test cells; only one is enough to obtain Uc directly on the insulated part of the roof is using thermal heat flows as starting point.

Consider directly measured thermal heat flow trough the insulated part of the roof in order to obtain the thermal transmittance of the current structure under weather conditions.

NA.

One of the basic concepts of the CWA is to derive the thermal efficiency of the insulation product from the energy consumption. Changing the test as proposed is a fundamental change from the BP and still will only provide incomplete information for a variety of weather conditions. And it will not be representative of the global heat losses.

However, heat flow measurement, in spite of the lack of relevancy, are allowed to be used for control purposes and described in section 5.4.4

PAROC/JF (33.39)


te There is a confusion between total thermal transmittance and roof thermal transmittance

Review method Thermal losses through the floor and door entrance are considered as negligible because they are guarded and controlled.


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Equation 7 details other thermal losses that are well considered, including the thermal bridges, solar gains and air exchange. NA

PAROC/JF (33.40)

All previous calculations are aimed to obtain the heat flow trough the insulated part of the roof of the test cell. As this information can be measured directly, no calculations are needed.

Three test cells are not needed, one is sufficient to obtain Uc of the insulated part of the roof, if thermal heat flow meters are used.

Consider direct measurement of thermal heat flow trough the insulated part of the roof in order to obtain the thermal transmittance of the current structure under weather conditions.

One of the basic concepts of the CWA is to derive the thermal efficiency of the insulation product from the energy consumption. Changing the test as proposed is a fundamental change and still only provides incomplete information for a variety of weather conditions. NA

JS/ URSA (39.38)

Pag 40 There is no wind thus no air exchange therefore M.ρ.Cp.∆T = 0

Probably not true.

Even with no wind some air leakage can exist.

False assumption and simplification

Non accurate methodology

All methodology must be reviewed Questions of weather are bound by the laws of nature. Weather cannot be controlled as in a laboratory. NA

PAROC/JF (33.41)

Page 40 There is no wind thus no air exchange therefore M.ρ.Cp.∆T = 0

Even with no wind some air leakage is possible.

Questionable simplification

Review testing method, tracer gas to verify the assumption shall be mandatory.

The use of tracer gas has been discussed a number of times and has been rejected as an obligation by the majority of participants due to high costs and extreme difficulty to maintain system over the periods of test NA

Because from a scientific point of view the term “no air exchange” is replaced by “negligible air exchange” – discussed and agreed during the UTI physical meeting held on the 5th of November. PA


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JS/ URSA

(39.39)

Pag 40 Equation 7a and 7b and 7c and 7d

There are three unknown variables (Uc; Ψ and Φitb·Aitb) in a only one equation

All methodology must be reviewed Ψ and Φitb·Aitb are determined thanks to conventional and standardized methods.

Ψ is a conventional value that is chosen according to the relevant design of the linear thermal bridges and additional measurement using thermocouple if available.

Φitb.Aitb = Uitb . ∆T

And Uitb can be easily calculated using conventional and standardized calculation methods.

Details are added in the before the equation 5 GC

PAROC/JF (33.42)

Page 40 Equation 7a and 7b and 7c and 7d

There are three unknown variables (Uc; Ψ and Φitb·Aitb) in a only one equation, not possible to solve

Review method Please see the responses above GC

HH RW (37.14)

8.3.1 Equation 2 te Contains only linear thermal bridges, constructional thermal bridges e.g. rafters shall also be included as they may represent more than 10% of total heat loss

Correct the equation They are already included in the “φp.Ap. ∆T” which are the heat losses through the opaque structure including constructional thermal bridges (called “integrated thermal bridges” in the CA).

They are details and considered later in equation 4 and 5 NA

EPFA/KF (35.55)

8.3.1 para. 1

para. 6 sub-para.4

ed

te

‘These data directly result...’ Incorrect English.

The declared value used for conventional thermal insulation products is not ‘calculated’ in the laboratory but measured.

‘These data result directly...’

Replace ‘calculation’ with ‘determination’

The correction will be made A

There is no direct measurement of the Declared value. The Guarded Hot Box measures the energy consumed and the Guarded Hot Plates measures the thermal


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flow. Calculations are necessary for determination.

HH RW (37.15)

8.3.1 Definitions below Eq. 2

Te Line losses shall be multiplied by ∆T. Unit for Ψ is W/mK

Correct Thank you for your comment.

A HH RW (37.16)

8.3.1 Eq. 5 Te

As above Correct it is done also on equation 5 and following. A

HH RW

(37.17)

8.3.1 Page 39 in the middle of page

te "When the thermal bridges ………………….can be applied.

I understand the text as when thermal bridges are made from dense construction materials as wood, concrete, metal, then they can be ignored and eq. 3 simplified, this is not correct and will lead to grave errors, see comment above.

I don't see the need for simplifications of calculations nowadays with the assistance of computers, but if needed a possibility is to change the surface calculation from internal- to external dimensions; by this the linear losses can be eliminated.

Delete the paragraph and correct eq. 5 and following eqs. accordingly

Your request for deletion is not accepted NA

The calculation proposed for traditional, dense, homogeneous materials are those commonly proposed by standards and used for building calculations. Then it is not the CWA that proposes the simplified calculation but existing standards.

What the CWA explains is the fact that the simplified calculation proposed by existing standards shall be applied only when initial hypotheses are respected. This is especially the case when these calculations are applied to traditional material.

HH RW

(37.18)

8.3.1 Third last paragraph page 39

te "The thermal performance……………….."

It is correct that results from in situ testing are significantly different from lab testing. To complete the picture it should also be mentioned that results from in situ testing (as compiled by CEN TC 98 WG 12) shows an extraordinary variance which doesn't allow for conclusions.

Delete the paragraph or bring the complete story

The text indicates that dynamic design transmittance which is the result of the proposed in situ test is “significantly different” from the “declared thermal performance” measured in steady state conditions in a laboratory.

Wide variations of other in situ test are not


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relevant to commenting on the WS36 proposed tests. As the Proposers has stated the test must be carried out with care and attention to detail by experienced and knowledgeable organizations

As clarification and explanation of the logical difference between in situ and laboratory results the following text is to be added: “because relating to significantly different conditions of use. In in situ testing the boundary conditions are close to the real and final conditions of use. In laboratory testing the boundary conditions are conventional and fixed as a single condition of DT, without wind, without solar radiation, dry sample and low relative humidity)” PA

STGOBAIN/AK

(34.36)

8.3.1 Point bridges are forgotten in all the equations Should be in, is part of the energy consumption of a test cell and not negligible.

You are correct.. However the CWA is describing the principle of the method, and because, when referring to existing conventional standards calculations, you cannot give all details because it would mean making a full copy of the considered standard and this is not reasonable.

However, a sentence will be added in order to make this calculation possible. Text added: “When


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existing, point thermal bridges shall also be considered using the relevant calculation according the EN 10211 (χ[W/K])” PA

HH RW

(37.19)

8.3.2 a) Uca te See comment to 8.2.6 See response to 8.2.6 comment NA

HH RW (37.20)

8.3.2 c) Uca Te

Ws< 0.5 m/s thus no air exchange is a highly questionable conclusion, especially due to the very lenient air tightness requirement, this needs to be verified.


For the RRT a tracer gas test (independently to the WS36) is specifically suggested as an option in order to validate this evident evidence, in order to give a confirmation of it.

For reasons also explained in the UTI, the tracer gas cannot be reasonably considered as a continuous measurement for all the in situ test that can be over 1 month.

Moreover increasing the airtightness reduces the relevance of the results to the “normal” conditions experienced in buildings. PA

HH RW (37.21)

8.3.2 b)Ucb depending on wind speed and ∆T

Te

It is stated for this purpose without solar radiation, the two last paragraphs shows ∆T+Isol , and no Ws. Also the text on relative humidity is confusing as there is no explanation.

I assume the expression M.ρ.Cp.∆T is the ventilation loss, the air change rate is missing.

Correct the mix up with solar and wind.

Explain the significance of relative humidity and how it is used

Correct

Thank you for this pertinent remark. The necessary modifications have been done in clause 8.3 in order correct the mix.

Concerning the humidity, a sentence has been added also at the beginning of the clause 8.3 in order to give more details

Note added: It is not possible to sort the data on relative humidity


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because it is not possible to find periods without relative humidity. This is the reason why the results of calculations shall be considered at a specified level of external humidity which is equal to the mean value of the recorded relative humidity associated to the test period considered. A

HH RW (37.22)

8.3.2 b)Ucb depending on wind speed and ∆T

"Making a graph Uc = function(∆T+Ws) will ………"

Te

Establishing the relationship between wind speed and heat loss doesn't explain what is lost by air exchange from cell and what is lost by reduced efficiency of the insulation.

With the chosen, very lenient, air tightness level the air exchange causes a significant part of the total heat loss. How great the heat loss due to this is, is difficult to predict as you don't know the air exchange rate during the test, only that it probably is lower than tested at 50Pa. If the actual air exchange rate varies between 0.1 to 0.5 it causes heat loss due to air exchange between 10% and 50% of the heat loss through roof and gables.


This is already done in the CWA36. So your proposition is already respected:

- in all cases when considering data without wind (Uca, Ucc)

- in cases where wind speed is > 0,5 (Ucb, Ucd) by removing thermal losses due to air exchange (– M.ρ.Cp. ∆T)

- in the case of the laboratory and the requestor choose a n50 value close to 0 (this is already permitted by the CWA36) PA

JS/ URSA (39.40)

8.3.5 Validation

This shall be done by using the dynamic thermal transmittance, extracted from the in situ test, in order to predict the behavior of the test cell

The behaviour of the test cell it is not the performance of the roof neither of the product.

Test result is in fact the behaviour of the test cell

The behavior of the test cell is predicted based on the dynamic thermal performance (in the same way that is normally done using the Design value resulting from the Declared one). This need to add to the calculation the extra losses previously eliminated for expression of the result.

Then, the dynamic thermal performances calculated in clauses


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8.3.2 and 8.3.3 are referring to the IMMR and its air gaps and not to the complete test cell.

Please refer also to the responses above and below. NA

PAROC/JF (33.43)

8.3.5 Validation

This shall be done by using the dynamic thermal transmittance, …

The behaviour of the cell test alone cannot be used to assess the performance of the roof nether the product.

The actual version of the document can only be used to determinate the total cell test performance (mixing roof + gables + floor + door + air infiltration+ thermal bridges,…); there is no given method to determinate the thermal performance of the insulated part of the roof neither of the insulation system or product. Under these considerations the actual document doesn’t respect the Business Plan and cannot be approved.

First of all, the thermal losses through the floor and entrance are negligible as well as the air infiltration in certain indentified weather conditions. For all other cases the extra losses are eliminated from the recorded energy consumption (see clause 8.3.2). If by clause 8.3.5 if it is possible to reproduce the dynamic behaviour of the test cell using the result found in clause 8.3.2 then this demonstrates that the result is really representative of the thermal performance of the evaluated IMMR. NA

HH RW

(37.23)

8.4 General te I have made a comment to N026 clause 9 asking for requirements for the time needed to give reliable result and also given references to the building physics literature. These comments have been ignored until the response on N026 states that i will be given in 8.4, but the promise has not been fulfilled as there is no guidance for this in 8.4.

To ensure the validity of data, means for checking if sufficient period has elapsed, is needed.

The UTI meeting held on the 5h of November permited to raise this question and to find an agreement for at minimum for the test period. (clause 7.7) Text added: The strict minimum duration of test period shall be no less that 1 week. However, by experience, this minimum should be more than3 weeks. PA

PAROC/JF (33.44)

8.4.1 1) Use a set-up

ge As national regulations can be very different, this gives no clear conditions for the test, and the test result can therefore not be used in other parts of the world.

This is a wrong principle, but it also shows that the

Delete the bullet The compliance with national building regulations was on the insistence of the


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whole method cannot give a comparable result and no declared value or even a reliable design value for the product. This is in conflict with the Business Plan.

It also undermines the validation of the method, and makes the RRT a farse.

conventional insulating product group. Now it is criticized? OK NA

The intention is also to permit the evaluation of the in situ thermal performance at the place where the test is carried out or where the product will be used. This means that the associated local regulations shall be applied. If not, there is no sense to evaluate the product through a UK regulation if it will be used in SPAIN for example.

The CWA clearly indicates that the intention of the in situ test method is to determine design values.

Your continual attacks on the principles on which the CWA and the Business Plan are based put seriously into question your support for the objectives of the Business Plan. NA

EPFA/KF (35.56)

8.4.3 General

para.6

te

te

Does this mean that the result of the tests carried out under this CWA would be a different design λ for every set of weather conditions in every place that it was measured? What use is that?

Does this really mean what it says? If the weather conditions do not represent the national conditions, then one continues with the test? The sentence is not logical.

Make the sentence meaningful or delete it.

It has been stated from the beginning that the CWA was intended to produce results relevant to local weather conditions and designs of buildings NA

This paragraph does mean that while the recorded weather condition is not representative to the national one, the test shall continue.

Concerning the reproducibility of the


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result on several sites and then different external weather condition, the split weather condition will permit a direct comparison of the result together.

HH RW (37.24)

8.4.4 Te A test method shall include a statement on accuracy and trueness/bias or include uncertainty budget

As it is not possible in a foreseeable future to have a "Standard reference cell" another route is to establish a uncertainty budget as proposed composed of all the parameters leading to the insulating product performance.

This is much more complicated than the impression given by 8.4.4 as there are alternatives so more guidance is needed.

See the article by U Hammerschmidt on GHP

International Journal of Thermophysics, Volume 23, Number 6

GUM method is commonly used in standardisation. Two other complementary methods are also proposed.

That seems to be more than usually expected.

The RRT will give concrete example of accuracy, repeatability and reproducibility results base on a large volume of available data . PA

EPFA/KF (35.57)

8.5.2 para. 1 ed ‘form’ should read ‘from’. Replace ‘form’ with ‘from’. The correct spelling will be used. A

OK, done but refer to 8.5.3 in fact

EPFA/KF (35.58)

8.5.3 1st bullet point

5th bullet point

ed

te

‘...reference of national...’

‘...global)’ Global what?

Replace ‘of’ with ‘to’.

Clarify.

Agree A

EPFA/KF (35.59)

Annex B vol./wt. ratios...

te Why bring dm3 into this at all? We all know that 1m3 = 103dm3

Simplify by omitting reference to dm3 If dm3 is known then it can be used NA

EPFA/KF (35.60)

Annex C te This is not easy to follow. What does the ‘Related weather’ box indicate. What do the equations mean?

Add an explanatory description if there really is an explanation.

Sorry but there is no mention of ‘Related weather’ box’ in the annexes.

Do not understand your comment and proposal. Clarification is required CR

EPFA/KF (35.61)

Annex C ‘Thermal Efficiency’

ed ‘Claculated’ is an error. Replace with ‘calculated’. The correct spelling will be used. A


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box EPFA/KF (35.62)

Annex G ed Several of the suffixes are illegible in the bold type equations. These have obviously been scanned.

Re-type to make the equations more legible.

The equations will be made legible A

Final consideration: JS/ URSA The actual version of the document can only arrive to the determination of the total test cell performance (mixing roof + gables + floor + door + air infiltration+ thermal bridges,…). There is no way (or it is not written) to determine the thermal performance of the insulated part of the roof neither of the insulation system or product. Under these considerations the actual document doesn’t respect the Business Plan and cannot be approved. Response: The test protocol requires that heat loss through the floor, door air infiltration and thermal bridges are regulated within specified limits and controls are required to check on the requirements. The proportion of total heat loss through the roof and gable end are also controlled. Thus sufficient is known of the thermal environment in which the insulation product operates to determine the effect on the energy consumed and thus determine the effective efficiency of the insulation product. The commenter should adjust his requirement of test conditions to align with the conditions normal to in situ testing. Suggestion: JS/ URSA There is the possibility to adapt the entire document by considering direct heat flow going trough the insulated part of the roof as the staring point to obtain the Thermal transmittance of the roof under weather conditions. Using this “new approach” it will be possible only one test cell without any comparative approach and the metrology can be used for any kind of product. Response: From the start of the work on WS36 it has been stated by the Proposers that the energy consumed was the basis from which the thermal efficiency of the insulation product would be determined. The continued insistence by the Commenter that the basis of the protocol should be changed is a direct challenge to the Business Plan. The commenter has continually insisted along with other “Appellants” that the use of Heat flow meters to measure the heat flow through the insulation product shall be “mandatory” and form the basis of the test method. Heat flow meters, as mentioned in the related EN, are intended for unidirectional heat flows, whilst the test conditions clearly will give bidirectional heat flow. Secondly the measurement is measuring conductance; Thirdly the area measured by heat flow meters is minute in comparison with the forty square meters of insulation product foreseen to be used in the WS36 protocol.

TRISCO - Calculation Results

TRISCO data file: plaster - 6 cm gw - plaster.trc

Number of nodes = 3751Heat flow divergence for total object = 3.79934e-007Heat flow divergence for worst node = 2.98015e-005

Col. Type Name tmin X Y Z tmax X Y Z [°C] [°C] _ 3 BC_SIMPL binnen 18.47 10 40 10 18.47 10 40 9 5 BC_SIMPL buiten 0.47 8 10 0 0.47 2 10 2 6 MATERIAL plasterboard 0.47 8 10 0 18.47 10 40 9 7 MATERIAL 0.62 0 20 0 18.32 0 30 1

Col. Type Name ta Flow in Flow out [°C] [W] [W] 3 BC_SIMPL binnen 11.80032 0.00000 5 BC_SIMPL buiten 0.00000 11.80032

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TRISCO data file: plaster - 8 cm gw - plaster.trc


Col. Type Name tmin X Y Z tmax X Y Z [°C] [°C] _ 3 BC_SIMPL binnen 18.82 10 40 10 18.82 0 40 10 5 BC_SIMPL buiten 0.36 0 10 0 0.36 2 10 2 6 MATERIAL plasterboard 0.36 0 10 0 18.82 0 40 10 7 MATERIAL 0.48 0 20 0 18.70 10 30 7

Col. Type Name ta Flow in Flow out [°C] [W] [W] 3 BC_SIMPL binnen 9.11216 0.00000 5 BC_SIMPL buiten 0.00000 9.11216

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TRISCO data file: plaster - mrf - plaster.trc


Col. Type Name tmin X Y Z tmax X Y Z [°C] [°C] _ 3 BC_SIMPL binnen 18.53 3 60 3 18.54 0 60 0 5 BC_SIMPL buiten 0.45 0 10 0 0.45 7 10 7 6 MATERIAL plasterboard 0.45 0 10 0 18.54 0 60 0 10 BC_FREE luchtlaag 0.59 0 20 0 8.08 10 30 10 11 BC_FREE luchtlaag 10.90 10 40 10 18.40 10 50 10 20 MATERIAL multiple reflec 8.08 5 30 5 10.91 5 40 5

Col. Type Name ta Flow in Flow out [°C] [W] [W] 3 BC_SIMPL binnen 11.30200 0.00000 5 BC_SIMPL buiten 0.00000 11.30200 10 BC_FREE luchtlaag 4.34 11.30200 11.30200 11 BC_FREE luchtlaag 14.65 11.30200 11.30200

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Setup multi reflective foil. Emissivity of the foil is 0,05. Core material set as 0,040.

Temperature construction inside 20C outside 0C

Heatflow construction mrf

Glass wool setup with same thickness lambda 0,040 W/mK

Temperature across the construction

Heat flow across the construction.

If you compare the two proposed constructions it is clear that the heat flow through the construction is different. So it is impossible to derive from this the thermal properties of the insulation material by simply compare the energy use of two test cells. How can you ever state what area is effected by the wooden rafter?

WS 36 roof 5 wall floor 30.epwResultatenEnergiepost [MJ] Qprim/QtoelQprim;verw 12255 0,955Qprim;hulp;verw 0 0Qprim;tap 9159 0,714Qprim;vent 0 0Qprim;vl 1692 0,132Qzom;comf 108 0,008Qprim;koel 0 0Qprim;bev 0 0Qprim;pv 0 0Qprim;comp;WK 0 0Qpres;tot 23214 1,81Qpres;toel 12831Ag;verwz [m2] 30Ag;verlies [m2] 68EPC-eis [-] 0,8EPC [-] 1,45EPC voldoet nietSpecificatie verwarming

Verwarmde zone 1QT;verw [MJ] 3493QV;verw [MJ] 5869Qzon;verw [MJ] 0Qint;verw [MJ] 5676Qverlies;verw [MJ] 9362Qwinst;verw [MJ] 5676Qwinst;verw [MJ]Qbeh;verw [MJ] 4779Nsys;verw [-] 1Nafgifte;verw [-] 1Ncirc;verw [-] 1Ndistr;verw [-] 1Qbeh;verw;bruto [MJ] 4779Qze;verw [MJ] 0

Nopw;verw [-] 0,39Qprim;verw [MJ] 12255Verwarming per maandVerwarmde zone 1Omschrijving januari februari maart april mei juni juli augustus september oktober november decemberHT;verw [W/K] 13,1 13,1 13,1 13,1 13,1 13,1 13,1 13,1 13,1 13,1 13,1 13,1QT;verw [MJ] 544 485 435 339 214 85 35 56 143 238 407 512HV;verw [W/K] 22,01 22,01 22,01 22,01 22,01 22,01 22,01 22,01 22,01 22,01 22,01 22,01QV;verw [MJ] 913 814 731 570 359 143 59 94 240 401 684 860Qzon;verw [MJ] 0 0 0 0 0 0 0 0 0 0 0 0Qint;verw [MJ] 482 435 482 467 482 467 482 482 467 482 467 482Qverlies;verw [MJ] 1457 1299 1166 910 573 227 94 150 382 639 1092 1372Qwinst;verw [MJ] 482 435 482 467 482 467 482 482 467 482 467 482Qwinst;verw/Ag [-] 16 15 16 16 16 16 16 16 16 16 16 16Gamma [-] 0,331 0,335 0,414 0,513 0,841 2,051 5,128 3,205 1,221 0,754 0,427 0,351Nb;verw [-] 1 1 1 0,998 0,955 0,487 0,195 0,312 0,787 0,976 1 1Qbeh;verw [MJ] 975 864 684 444 113 0 0 0 15 169 625 890Deelgegevens transmissieVerwarmde zone 1Omschrijving A·U [W/m2K] l·Psi [W/K] LD [W/K] LS;verw [W/K] b [-] HU [W/K] HT;verw [W/K]Gevel 1 0,34 -- 1,48 0 0 0 1,48Dak 1 5,05 -- 7,71 0 0 0 7,71Vloer 1 0,9 -- 3,9 0 0 0 3,9 roof/totalTotaal 6,3 0 13,1 0 0 13,1 80%Deelgegevens ventilatie

Verwarmde zone 1C1 [-] 0qv;10;verw [dm3/s] 1,087qv;verw;nat [dm3/s] 18,338nv;i;k [-] 0qv;i;k [dm3/s] 0qv;verw;mech [dm3/s] 0qv;verw;mech [dm3/s]qv;verw [dm3/s] 18,338qv;over [dm3/s] 0Hv;verw [W/K] 22,01

Bijdrage zonne-energiesysteemSpecificatie hulpenergie

Verwarming 1Qhulp;verw;gas [MJ] 0Qhulp;verw;gas [MJ]Qhulp;pomp;el [kWh] 0Qhulp;buf;vat;el [kWh] 0Qhulp;vent;el [kWh] 0Qhulp;el;el [kWh] 0Qhulp;verw;el [kWh] 0Qprim;hulp;verw [MJ] 0Specificatie tapwater

Tapwater 1Qbeh;tap [MJ] 2040Qbeh;tap;badr [MJ] 1632Qbeh;tap;aanr [MJ] 408Qbeh;tap;aanr [MJ]Nleid;badr [-] 0,86Nleid;aanr [-] 0,48Nleid;tap [-] 0,74Nconv;tap [-] 1Ncirc;tap [-] 1Ndistr;tap [-] 1Nsys;tap [-] 0,742Nsys;tap [-]Qbeh;tap;bruto [MJ] 2748Ctap* [-] 1,000*Cbron [-] 1Nopw;tap [-] 0,3Qze;tap [MJ] 0Qprim;tap [MJ] 9159Bijdrage zonne-energiesysteemSpecificatie ventilatorenVerwarmde zone Systeem Qvent [kWh]Qprim;vent [MJ]Verwarmde zone 1 (geen ventil 0 0Totaal Totaal Totaal 0

Specificatie verlichtingVerwarmde zone Ag [m2] Qprim;vl [MJ]Verwarmde zone 1 30 1692Totaal 30 1692Specificatie zomercomfort

Verwarmde zone 1QT;koude [MJ] 5145QV;koude [MJ] 16971Qzon;koude [MJ] 0Qint;koude [MJ] 5676Qverlies;koude [MJ] 22116Qwinst;koude [MJ] 5676Qwinst;koude [MJ]Qbeh;koude [MJ] 127Fzom;comf [-] 1,17Qzom;comf [MJ] 108Specificatie koeling

Verwarmde zone 1QT;koude [MJ] 5145QV;koude [MJ] 16971Qzon;koude [MJ] 0Qint;koude [MJ] 5676Qverlies;koude [MJ] 22116Qwinst;koude [MJ] 5676Qwinst;koude [MJ]Qbeh;koude [MJ] 127Nsys;koude [-] 0Qbeh;koude;bruto [MJ] 0Nopw;koude [-] 0Qprim;koel [MJ] 0Koeling per maandVerwarmde zone 1Omschrijving januari februari maart april mei juni juli augustus september oktober november decemberHT;koude [W/K] 13,1 13,1 13,1 13,1 13,1 13,1 13,1 13,1 13,1 13,1 13,1 13,1QT;koude [MJ] 684 611 575 475 354 221 175 196 278 379 543 652HV;koude [W/K] 43,2 43,2 43,2 43,2 43,2 43,2 43,2 43,2 43,2 43,2 43,2 43,2

QV;koude [MJ] 2256 2017 1897 1568 1168 728 578 648 918 1249 1792 2152Qzon;koude [MJ] 0 0 0 0 0 0 0 0 0 0 0 0Qint;koude [MJ] 482 435 482 467 482 467 482 482 467 482 467 482Qverlies;koude [MJ] 2940 2628 2472 2043 1523 948 754 844 1197 1628 2335 2804Qwinst;koude [MJ] 482 435 482 467 482 467 482 482 467 482 467 482Gamma [-] 0,164 0,166 0,195 0,228 0,317 0,492 0,639 0,571 0,39 0,296 0,2 0,172akoude [-] 3,456 3,456 3,456 3,456 3,456 3,456 3,456 3,456 3,456 3,456 3,456 3,456Nb;koude [-] 0,998 0,998 0,997 0,995 0,987 0,954 0,911 0,933 0,976 0,989 0,997 0,998Qbeh;koude [MJ] 1 1 1 2 6 21 43 32 11 5 1 1Deelgegevens transmissieVerwarmde zone 1Omschrijving A·U [W/m2K] l·Psi [W/K] LD [W/K] LS;koude [W/Kb [-] HU [W/K] HT;koude [W/K]Gevel 1 0,34 -- 1,48 0 0 0 1,48Dak 1 5,05 -- 7,71 0 0 0 7,71Vloer 1 0,9 -- 3,9 0 0 0 3,9Totaal 6,3 0 13,1 0 0 13,1Deelgegevens ventilatie

Verwarmde zone 1qv;koude;nat [dm3/s] 36nv;koude [-] 0qv;koude;mech [dm3/s] 0qv;koude;mech [dm3/s]qv;koude [dm3/s] 36Hv;koude [W/K] 43,2Specificatie bevochtigingSpecificatie PV-cellenSpecificatie WKQbeh;bruto;verw [MJ] 0Qbeh;bruto;tap [MJ] 0Fpref;wk [-] 0Qbeh;bruto;WK [MJ] 0Ewk;el [-] 0Ewk;w [-] 0Qprim;comp;WK [MJ] 0Risico te hoge temperaturenOmschrijving zone TOjuli

Verwarmde zone 1 0,28 laag - matig risicoIndicatie CO2-emissie

Elektrisch Aardgas Kolen en olieAfvalverbrandingQprim;verw [MJ] 12255 0 0 0Qprim;hulp;verw [MJ] 0 0 -- --Qprim;tap [MJ] 0 9159 0 0Qprim;vent [MJ] 0 -- -- --Qprim;vl [MJ] 1692 -- -- --Qprim;koel [MJ] 0 -- -- --Qprim;bev [MJ] 0 -- -- --Qprim;pv [MJ] 0 -- -- --Qprim;comp;wkk [MJ] 0 -- -- --Qpres;tot [MJ] 13947 9159 0 0CO2 [kg/MJ] 0,0694 0,056 0,0877 0,0157 (*)CO2 [kg] 968 513 0 0CO2-emissie [kg] 1481

WS 36 roof 2 wall floor 15.EPWResultatenEnergiepost [MJ] Qprim/QtoelQprim;verw 17958 1,4Qprim;hulp;verw 0 0Qprim;tap 9159 0,714Qprim;vent 0 0Qprim;vl 1692 0,132Qzom;comf 98 0,008Qprim;koel 0 0Qprim;bev 0 0Qprim;pv 0 0Qprim;comp;WK 0 0Qpres;tot 28907 2,253Qpres;toel 12831Ag;verwz [m2] 30Ag;verlies [m2] 68EPC-eis [-] 0,8EPC [-] 1,81EPC voldoet nietSpecificatie verwarming

Verwarmde zone 1QT;verw [MJ] 5921QV;verw [MJ] 5869Qzon;verw [MJ] 0Qint;verw [MJ] 5676Qverlies;verw [MJ] 11791Qwinst;verw [MJ] 5676Qwinst;verw [MJ]Qbeh;verw [MJ] 7004Nsys;verw [-] 1Nafgifte;verw [-] 1Ncirc;verw [-] 1Ndistr;verw [-] 1Qbeh;verw;bruto [MJ] 7004Qze;verw [MJ] 0

Nopw;verw [-] 0,39Qprim;verw [MJ] 17958Verwarming per maandVerwarmde zone 1Omschrijving januari februari maart april mei juni juli augustus september oktober november decemberHT;verw [W/K] 22,2 22,2 22,2 22,2 22,2 22,2 22,2 22,2 22,2 22,2 22,2 22,2QT;verw [MJ] 921 822 737 575 363 144 59 95 242 404 691 868HV;verw [W/K] 22,01 22,01 22,01 22,01 22,01 22,01 22,01 22,01 22,01 22,01 22,01 22,01QV;verw [MJ] 913 814 731 570 359 143 59 94 240 401 684 860Qzon;verw [MJ] 0 0 0 0 0 0 0 0 0 0 0 0Qint;verw [MJ] 482 435 482 467 482 467 482 482 467 482 467 482Qverlies;verw [MJ] 1835 1636 1468 1146 722 286 118 189 481 805 1375 1728Qwinst;verw [MJ] 482 435 482 467 482 467 482 482 467 482 467 482Qwinst;verw/Ag [-] 16 15 16 16 16 16 16 16 16 16 16 16Gamma [-] 0,263 0,266 0,328 0,407 0,668 1,629 4,072 2,545 0,97 0,599 0,339 0,279Nb;verw [-] 1 1 1 1 0,989 0,61 0,246 0,393 0,908 0,995 1 1Qbeh;verw [MJ] 1353 1201 986 679 245 2 0 0 58 325 908 1246Deelgegevens transmissieVerwarmde zone 1Omschrijving A·U [W/m2K] l·Psi [W/K] LD [W/K] LS;verw [W/K] b [-] HU [W/K] HT;verw [W/K]Gevel 1 0,8 -- 1,94 0 0 0 1,94Dak 1 12,5 -- 15,16 0 0 0 15,16Vloer 1 2,1 -- 5,1 0 0 0 5,1 Roof/totalTotaal 15,4 0 22,2 0 0 22,2 81%Deelgegevens ventilatie

Verwarmde zone 1C1 [-] 0qv;10;verw [dm3/s] 1,087qv;verw;nat [dm3/s] 18,338nv;i;k [-] 0qv;i;k [dm3/s] 0qv;verw;mech [dm3/s 0qv;verw;mech [dm3/s]qv;verw [dm3/s] 18,338qv;over [dm3/s] 0Hv;verw [W/K] 22,01

Bijdrage zonne-energiesysteemSpecificatie hulpenergie

Verwarming 1Qhulp;verw;gas [MJ] 0Qhulp;verw;gas [MJ]Qhulp;pomp;el [kWh] 0Qhulp;buf;vat;el [kWh 0Qhulp;vent;el [kWh] 0Qhulp;el;el [kWh] 0Qhulp;verw;el [kWh] 0Qprim;hulp;verw [MJ] 0Specificatie tapwater

Tapwater 1Qbeh;tap [MJ] 2040Qbeh;tap;badr [MJ] 1632Qbeh;tap;aanr [MJ] 408Qbeh;tap;aanr [MJ]Nleid;badr [-] 0,86Nleid;aanr [-] 0,48Nleid;tap [-] 0,74Nconv;tap [-] 1Ncirc;tap [-] 1Ndistr;tap [-] 1Nsys;tap [-] 0,742Nsys;tap [-]Qbeh;tap;bruto [MJ] 2748Ctap* [-] 1,000*Cbron [-] 1Nopw;tap [-] 0,3Qze;tap [MJ] 0Qprim;tap [MJ] 9159Bijdrage zonne-energiesysteemSpecificatie ventilatorenVerwarmde zone Systeem Qvent [kWh Qprim;vent [MJ]Verwarmde zone 1 (geen ventilator) 0 0Totaal Totaal Totaal 0

Specificatie verlichtingVerwarmde zone Ag [m2] Qprim;vl [MJ]Verwarmde zone 1 30 1692Totaal 30 1692Specificatie zomercomfort

Verwarmde zone 1QT;koude [MJ] 8721QV;koude [MJ] 16971Qzon;koude [MJ] 0Qint;koude [MJ] 5676Qverlies;koude [MJ] 25693Qwinst;koude [MJ] 5676Qwinst;koude [MJ]Qbeh;koude [MJ] 115Fzom;comf [-] 1,17Qzom;comf [MJ] 98Specificatie koeling

Verwarmde zone 1QT;koude [MJ] 8721QV;koude [MJ] 16971Qzon;koude [MJ] 0Qint;koude [MJ] 5676Qverlies;koude [MJ] 25693Qwinst;koude [MJ] 5676Qwinst;koude [MJ]Qbeh;koude [MJ] 115Nsys;koude [-] 0Qbeh;koude;bruto [M 0Nopw;koude [-] 0Qprim;koel [MJ] 0Koeling per maandVerwarmde zone 1Omschrijving januari februari maart april mei juni juli augustus september oktober november decemberHT;koude [W/K] 22,2 22,2 22,2 22,2 22,2 22,2 22,2 22,2 22,2 22,2 22,2 22,2QT;koude [MJ] 1159 1036 975 806 600 374 297 333 472 642 921 1106HV;koude [W/K] 43,2 43,2 43,2 43,2 43,2 43,2 43,2 43,2 43,2 43,2 43,2 43,2

QV;koude [MJ] 2256 2017 1897 1568 1168 728 578 648 918 1249 1792 2152Qzon;koude [MJ] 0 0 0 0 0 0 0 0 0 0 0 0Qint;koude [MJ] 482 435 482 467 482 467 482 482 467 482 467 482Qverlies;koude [MJ] 3415 3053 2872 2373 1769 1102 876 981 1390 1892 2712 3258Qwinst;koude [MJ] 482 435 482 467 482 467 482 482 467 482 467 482Gamma [-] 0,141 0,143 0,168 0,197 0,273 0,423 0,55 0,491 0,336 0,255 0,172 0,148akoude [-] 3,114 3,114 3,114 3,114 3,114 3,114 3,114 3,114 3,114 3,114 3,114 3,114Nb;koude [-] 0,998 0,998 0,997 0,995 0,987 0,959 0,923 0,941 0,978 0,989 0,997 0,998Qbeh;koude [MJ] 1 1 2 2 6 19 37 28 10 5 2 1Deelgegevens transmissieVerwarmde zone 1Omschrijving A·U [W/m2K] l·Psi [W/K] LD [W/K] LS;koude [W/K] b [-] HU [W/K] HT;koude [W/K]Gevel 1 0,8 -- 1,94 0 0 0 1,94Dak 1 12,5 -- 15,16 0 0 0 15,16Vloer 1 2,1 -- 5,1 0 0 0 5,1Totaal 15,4 0 22,2 0 0 22,2Deelgegevens ventilatie

Verwarmde zone 1qv;koude;nat [dm3/s] 36nv;koude [-] 0qv;koude;mech [dm3/ 0qv;koude;mech [dm3/s]qv;koude [dm3/s] 36Hv;koude [W/K] 43,2Specificatie bevochtigingSpecificatie PV-cellenSpecificatie WKQbeh;bruto;verw [MJ] 0Qbeh;bruto;tap [MJ] 0Fpref;wk [-] 0Qbeh;bruto;WK [MJ] 0Ewk;el [-] 0Ewk;w [-] 0Qprim;comp;WK [MJ] 0Risico te hoge temperaturenOmschrijving zone TOjuli

Verwarmde zone 1 0,21 laag - matig risicoIndicatie CO2-emissie

Elektrisch Aardgas Kolen en oAfvalverbrandingQprim;verw [MJ] 17958 0 0 0Qprim;hulp;verw [MJ] 0 0 -- --Qprim;tap [MJ] 0 9159 0 0Qprim;vent [MJ] 0 -- -- --Qprim;vl [MJ] 1692 -- -- --Qprim;koel [MJ] 0 -- -- --Qprim;bev [MJ] 0 -- -- --Qprim;pv [MJ] 0 -- -- --Qprim;comp;wkk [MJ] 0 -- -- --Qpres;tot [MJ] 19650 9159 0 0CO2 [kg/MJ] 0,0694 0,056 0,0877 0,0157 (*)CO2 [kg] 1364 513 0 0CO2-emissie [kg] 1877

EP woonfuncties en woongebouwenNEN, NPR 5129

ALGEMENE GEGEVENSProjectomschrijving : Test cell WS36

Bestandsnaam : C:\Werk\EP calculations\WS 36 roof 6 wall floor 5.epw

Omschrijving bouwwerk : Slope roofed test cell

Adres :

Soort bouwwerk : Woonfunctie

EPC-eis : 0,80

INDELING GEBOUWType Omschrijving zone Ag [m²]

Verwarmd Verwarmde zone 1 30,00

BOUWKUNDIGE GEGEVENS - TRANSMISSIEDefinitie scheidingsconstructies zone: Verwarmde zone 1

constructie begrenzing constructiedeel A Hkr Rc U ZTA helling zon- beschaduwing

[m²] [m] [m²K/W] [W/m²K] [-] [°] wering

Gevel 1 buiten, Z Gable wall 5,7 5,00 0,19

Gable wall 5,7 5,00 0,19

Dak 1 buiten, boven Sloped roof 1 13,3 6,00 0,16

Sloped roof 2 13,3 6,00 0,16

Vloer 1 buiten, onder Floor 30,0 5,00 0,19

---------- +

Totaal 68,0

BOUWKUNDIGE GEGEVENS - LINEAIRE KOUDEBRUGGENEr is gerekend volgens de forfaitaire methode m.b.t. de koudebruggen.

Bij de forfaitaire methode wordt een correctie op de U-waarde toegepast.

Geen gegevens voor lineaire koudebruggen ingevoerd

BOUWKUNDIGE GEGEVENS - INFILTRATIEqv10;kar/m² van de woonfunctie: 1,087 [dm³/sm²]

BOUWKUNDIGE GEGEVENS - THERMISCHE CAPACITEITbouwtype van de woonfunctie: volledig houtskeletbouw

26 okt 2008 - 9:31 / EPC=1,68 blz. 1EPW - NPR 5129 V2.02

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This software is official NEN software used for energy performance of buildings. Based on this reports people can get building permits. The EPBD calculations are based on the same model that is used for this tool.

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Here you see the different surfaces and their U values.

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Regarding linear bridges one can choose for different methods. I have chosen for the most simple one (the most negative).

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Air tightness level, conform Dutch standards (n50 is appr. 3)

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Thermal inertia of the building, set as wooden building type.


INSTALLATIE W - VERWARMING EN HULPENERGIEVerwarmingssysteem 1 - Verwarming 1

verwarmingstoestel type toestel : lokale elektrische verwarming

installatiekenmerken individuele bemetering : ja

installatie voorzien van buffervat : nee

type verwarmingslichaam : vloer- en/of wandverwarming

opwekkingsrendement (Nopw;verw) : 0,390 [-]

systeemrendement (Nsys;verw) : 1,000 [-]

hulpenergie aantal ketels-cv/luchtverwarmers met waakvlam : 0

gasketels-cv : niet voorzien van ventilator

: niet voorzien van elektronica

: geen circulatiepomp aanwezig

warmtepomp : geen circulatiepomp aanwezig

individuele warmtepomp : geen parallel buffervat aanwezig

gebouwgebonden warmte-kracht : lengte circulatieleiding 0,00 km

aangewezen zones: Verwarmde zone 1

INSTALLATIE W - WARMTAPWATERnr. opwekkingstoestel klasse Nopw;tap qv;wp aantal aantal Lbadr Laanr Lcirc d;inw Qbeh;tap;bruto

[-] [dm³/s] badr aanr [m] [m] [m] [mm] [MJ]

1 gasgestookt warmwater of comb... - 0,300 - 0 0 6-8 8-10 0,0 <= 10 2748

INSTALLATIE W - VENTILATIEVentilatiesysteem 1 - Ventilatie 1

ventilatievoorziening : natuurlijke luchttoe- en afvoer

type warmteterugwinning : geen warmteterugwinning

type voorverwarming : geen voorverwarming

aangewezen zones : Verwarmde zone 1

INSTALLATIE W - VENTILATORENventilatiesysteem type ventilator

Ventilatiesysteem 1 - Ventilatie 1 (geen ventilator)

INSTALLATIE W - KOELINGkoelsysteem: type toestel : geen koelmachine aanwezig

vrije koeling : nee

opwekkingsrendement voor koeling (Nopw;koel) : 0,000 [-]

systeemrendement voor koeling (Nsys;koel) : 0,000 [-]


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Heating device, chosen electricity efficiency 1

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Warm water, could not be switched off because for normal buildings is obligatory.

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Ventilation system, natural air exchange.

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Cooling devices, nothing selected.

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Ventilators, none selected.


INSTALLATIE E - VERLICHTINGomschrijving zone Ag [m²] Qprim;vl [MJ]

Verwarmde zone 1 30,0 1692

RESULTATEN - INFORMATIEFCO2-emissie 1733 kg

Risico te hoge temperaturen [TOjuli]

Omschrijving zone TOjuli

Verwarmde zone 1 0,23 (laag - matig risico)


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Lightning, fixed.

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To high temperature foreseen in July (low risk)


RESULTATEN - ENERGIEPRESTATIEGEGEVENSverwarming Qprim;verw 15883 MJ

hulpenergie Qprim;hulp;verw 0 MJ

warmtapwater Qprim;tap 9159 MJ

ventilatoren Qprim;vent 0 MJ

verlichting Qprim;vl 1692 MJ

zomercomfort Qzom;comf 101 MJ

koeling Qprim;koel 0 MJ

bevochtiging Qprim;bev 0 MJ

comp. PV-cellen Qprim;pv 0 MJ

comp. WK Qprim;comp;WK 0 MJ

----------------- +

totaal Qpres;tot 26835 MJ

Qpres;toel 12831 MJ

Qpres;totaal / (( 330 * Ag;verw + 65 * Averlies ) * Cepc ) = EPC

26835 30,0 68,0 1,12 1,68 Epc voldoet niet aan EPC-eis Bouwbesluit 1 januari 2006

RESULTATEN - AANDACHTSPUNTEN

Bij het warmtapwatertoestel '1 - Tapwater 1' is het aantal aansluitpunten badruimte en aanrecht niet opgegeven.


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Energy use, heating15883 MJ. In the separate Excel files you can see the different surface and heatflow.

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Check if building meets requirements. In this case not.

CEN WS 36 Doc. N045 - Comments... · 2008. 11. 14. · (12) ge I have read your description of...

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Transcript of CEN WS 36 Doc. N045 - Comments... · 2008. 11. 14. · (12) ge I have read your description of...