Response to BLDG 2 Comments.pdfMarch 27, 2018
Chuck Miller
Plans Examiner
City of Edmonds
chuck.miller@edmondswa.gov
425.771.0220
Re: Plan Check: BLD2017-1711— 2nd review
Dear Mr. Miller,
The items below and responses in bold are per your review dated March 15, 2018.
RESUB
APR 0 5 2018
BUcIIDTIfF EDMO DG T
1. General plan review comments regarding the fire -resistance rated requirements for the 'Type V 1-hour' construction of
the structure per Uniform Building Code (UBC) Table 17-A under permit BLD1985-0302:
A specified compliance path for the construction of those elements required to have one -hour fire -resistance rated
protection does not appear anywhere in the permit drawings for the work completed under permit BLD1985-0320. While
technically correct, vague notations on the plans such as '1-hr rated susp. ACP clg.' and 'ACP susp. clg. 1 hr. rated' for the
floor/ceiling and roof/ceiling assemblies, '5/8" GWB — X ea. side of stud wall' for the interior walls, and 'cdr. siding on W
gyp. sht'g.' for the exterior walls, suggested methods to be used without indicating the required construction per an
accepted standard. Fortunately, most of that noted on the plans achieves compliance for many of the building elements
(see below), however the lack of clear direction resulted in the utilization of a method for those areas of the roof -ceiling
assembly with framing placed 24 inches on -center that did not meet the requirements of the code in effect then or now.
BUILDING ELENIF.N'f METHOD OF CONST COMPLIANCE PATH
Fxtcrior bearing walls 'S'dr. siding on 1 /2" gyp. '82 UBC Table 43-13, Item 75
shl`g.' on 16" o.c. wood studs' or
w/ int. 5/8" type 'X' ' 15 IBC Table 721.1(2).
Item 15-1.1
Interior bearing walls '5/8" GWB X ca. Side of '82 UBC Table 43-13, Item 71
stud wall' or
' 15 IBC Table 721.1(2), Item
Structural (primary) frame
Floor construction and
associated secondary members
Light -frame construction
I -hr. rated cusp. ACP clg.'
Roof construction and GWB attached to 2x 12 vaulted
associated secondary members raf)crs at 12" o.c. or 'AC'P
sysp. c)g. I hr. rated' below
2x4 trusses or 2x 12 rafters at
24" o.c.
Pagel of 5 425.778.1530 I 21911 76' Ave W. Suite 210
Edmonds, WA 98026
Not required per UBC 1702 or
IBC 704.4
Over crawl space - not
required per UBC 1703 or
IBC 711,2.E
Floor/ceiling between
basement and main levels -
UL L210
Vaulted areas - UBC Table
43-C, Item 25 or IBC Table
721.1(3), Item 13-1.4 or
calculated fire -resistance per
IBC 722.6 or 1C'C ESR-1338
or Gypsum Association 'GA
File No. FC5406'
Trusses and flat roof areas
None known for that noted on
plans -- closest would be UL
L526 however framing in
excess of 16" o.c. needs to be
addressed
tgb architects
TGB Response:
Compliance paths are now indicated on HORIZONTAL 1-HOUR FIRE -RESISTIVE (ROOF -CEILING)
CONSTRUCTION, and on PARTITIONS — VERTICAL EXTENT AND VERTICAL CONFIGURATION on sheet-A0.22.
On sheet A0.22 — Code -Related and Fire -Resistive Construction:
2. Horizontal 1-Hour Fire -Resistive (Roof -Ceiling) Construction
At Suspended Acoustical Ceilings — Indicate on the plans requirement that the placement of the roof framing
members may be no greater than 16 inches on -center per the referenced Underwriters Laboratories (UL) fire-
resistant rated assembly design — UL Design No. L210. The construction drawings from permit BLD1985-0320
specify the placement of the roof framing members in the 'sloped' roof/rafter-vaulted ceiling areas at 16 inches
on -center. Most of the ceiling finishes in those areas are attached directly to the underside of the rafter and
would comply with that required for a number of assemblies (IBC prescriptive method Table 721.1(3), Item 13-
1.4, IBC calculated fire resistance 722.6, ICC ESR-1338, and Gypsum Association 'GA File No. FC5406'). The
remaining roof framing, such as 'sloped' roof areas with flat ceilings framed with 2x4 trusses and flat roof
areas with flat ceilings, is noted as being placed at 24 inches on -center, greater than that permitted to support
the one -hour fire -resistance rated suspended acoustical ceiling assembly. An 'engineering judgement,
prepared by a 'third -party' using extrapolation or a combination of approved standards, methods, or systems
commonly referenced in the IBC, may be submitted to justify the use of 24" on -center framing members per IBC
104.11. The response to the earlier plan review comment states: "At suspended acoustical ceilings, Sheet
A0.22 HORIZONTAL ROOF -CEILING CONSTRUCTION drawing has been clarified to show that the existing is
SIMILAR to construction per UL Design L210, except that existing framing may be up to 24" OC and the
omission of finish flooring. Design has been completed by addition of proprietary suspended ceiling system
below. See clouded drawing.". Substitutions/deviations from that specified in listed assemblies are limited to
that noted in the listing. None can be found that permits the framing members to be placed at greater than
that specified. The 'proprietary suspended ceiling system below' is not an 'addition' to that specified, but a
required element of the listed assembly. As noted in IBC 703.3, the required fire resistance of a building
element, component or assembly shall be permitted to be established by a number of indicated methods. To
date, IBC 703.3, Items 1, 2, 3, and 5 have failed to support the proposal to use UL Design L210. The remaining
alternatives allow an 'engineering judgement', prepared by a 'third -party' using extrapolation or a
combination of approved standards, methods, or systems commonly referenced in the IBC, to be submitted to
justify the use of 24" on -center framing members per IBC 104.11, or for that proposed to be tested and
certified by an approved agency — see also plan review comment'13.b'.
TGB Response:
Fire -rated Roof -Ceiling designs has been revised to comply with GA Design FC-5406. And UL aDesignb 1-210
only. See relevant clouded portion of HORIZONTAL 1-HOUR FI RE-RESISTIVE(ROOF-CEI LING) CONSTRUCTION
on sheet A0.22.
a. At Gypsum Board Ceilings
III. Clarify on the plans the alternate proposal to utilize ICC ESR-1338 for those areas having a suspended
ceiling with a gypsum board finish. The qualifier to substitute a suspended ceiling system with a
gypsum board finish for ceilings where the gypsum wallboard is attached directly to the underside of
the roof framing is where gypsum board ceilings are directly attached to steel framing as set forth in
the IBC prescriptive methods of Table 721.1(3) per Section 4.2.3.1 — Alternate Suspended Ceiling
Construction. The response to the earlier plan review comment states: "At Gypsum Board Ceilings,
Sheet A0.22 HORIZONTAL ROOF -CEILING CONSTRUCTION drawing has been clarified to show that
the existing structure conforms to IBC Table 721.1(3) item 21.1.1— wood joists, I -joists or wood
trusses at 24" OC. On that design, gypsum board ceiling is directly attached (and is identical to
direct attached ceiling assembly for metal structure at 24" OC per 721.1(3) item 22.1.1). Drawing
indicates that ICC ESR-1338 allows for substitution of suspended gypsum board on compliant metal
system to be substituted for direct attached gypsum board. As the direct -attached ceiling is
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identical in the IBC Table for wood structure at 24" OC and metal structure @ 24" OC except for
fastener length, the "qualified' substitution seems reasonable. We believe this is the 1-HR Roof -
Ceiling that is in place throughout much of the building. See clouded drawing.". There is no
agreement to the first statement, "...that the existing structure conforms to IBC Table 721.1(3) item
21.1.1". While it can be agreed that IBC 721.1(3), Item 21-1.1 and IBC 721.1(3), Item 22-1.1are quite
similar, it does not necessarily follow that ICC ESR-1338, Section 4.2.3.1 (specifically noted as an
alternate to gypsum board ceilings directly attached to steel framing (emphasis by plans examiner)
per IBC 721.1(3)) may be extended to IBC 721.1(3), Item 21-1.1, especially since it was not noted as
an alternative to it in the listing. Again, an engineering judgment may be submitted as noted above,
or the proposed assembly can be tested and certified by an approved agency — see also plan review
comment'13.a.ii'.
TGB Response:
Fire -rated Roof -Ceiling designs have been revised to comply with GA Design FC-5406 and UL Design
L-210 only. See relevant clouded portion of HORIZONTAL 1-HOUR FIRE-RESISTIVE(ROOF-CEILING)
CONSTRUCTION on sheet A0.22.
Additional plan review comments regarding resubmitted construction documents:
On sheet A0.22 — Code -Related and Fire -Resistive Construction:
13. Horizontal 1-Hour Fire -Resistive (Roof -Ceiling) Construction
a. In the information regarding the installation of a suspended ceiling with a gypsum board finish:
i. Clarify on the plans the note; "Permit drawings from 1985 (existing building) indicate the following
existing roof construction - conforming to IBC Table 721.1(3),". The roof -ceiling construction
supporting suspended ceilings (with both gypsum board and acoustic ceiling panel finishes)
represented in the construction documents for permit BLD1985-0320 does not conform with IBC
Table 721.1(3), where the gypsum board is required to be directly attached to the roof framing
members.
TGB Response:
1-hour fire -resistive assemblies and approaches have been revised. See relevant clouded portions
of Sheet A0.22.
ii. Clarify on the plans the proposed installation of a listed assembly constructed per ESR-1338, Section
4.2.3.1 to provide the required fire resistance of the roof framing per UBC Table 17-A/IBC Table 601.
The assembly specifically references steel roof framing members — see also plan review comment
'2.b.iii'.
TGB Response:
1-hour fire -resistive assemblies and approaches have been revised. See relevant clouded portions
of Sheet A0.22.
b. In the information regarding the installation of a suspended ceiling with acoustic ceiling panels — Clarify on the
plans the proposed installation of a listed assembly per UL Design L210 to provide the required fire -resistance
of the roof framing per UBC Table 17-A/IBC Table 601. The assembly specifically references roof framing
members placed at 16 inches on -center — see also plan review comment '2.a'.
TGB Response:
1-hour fire -resistive assemblies and approaches have been revised. See relevant clouded portions of Sheet
A0.22.
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14. Partitions —Materials and Construction —Partition 'FR' — Change on the plans the spacing (in inches) of the fasteners at
vertical joints from '12' to '8', and at floor and ceiling runners and intermediate studs from '24' to '12' per Gypsum
Association 'Fire Resistance Design Manual' —GA File No. WP 1350.
TGB Response:
Drawing has been so revised. See relevant clouded portion of PARTITION FR on sheet A0.22.
On sheet A2.21— Ceiling Plan:
15. Lighting Legend — Reformat on the plans the provided information regarding the proposed lighting installation. The
descriptions and details of each of the lighting fixtures does not appear to be 'aligned' with the various 'marks' for
each.
TGB Response:
All text in last drawing set was inadvertently reduced in size during the last printing process. New submitted print
is at the correct size and lighting legend is now reformatted to align properly.
16. Ceiling Plan — Level 2 - New
a. Clarify on the plans the lighting control indicated by 'flag 1' to be installed in the following areas:
• 2202 — Workroom
• 2204 — Storage
• 2205 —Staff Toilet
• 2206 — Patient Restroom
• 2207 — Doctor
• 2208 — N P 2
• 2209 — N P 1
• 2210 — Medical Assistants
• 2218—NP3
None of the specified areas appear to be subject to the 'daylight responsive control' requirements of WSEC
C405.2.4 due to the lack of windows or number of fixtures in the daylight zones. Typically, occupancy sensors
are installed per WSEC C405.2.1.
TGB Response:
"Flag 1" has been removed from the rooms above on the ceiling plan and the ceiling plan key notes.
b. Clarify on the plans the lighting controls indicated by'flag 2' to not be installed in the following areas:
• 2212 — Exam
• 2213 — Exam
• 2214 — Exam
• 2215 — Exam
• 2216 — Exam
• 2217 — Exam
None of the specified areas appear to be exempt from the 'occupancy sensor control' requirements of WSEC
C405.2.1. The noted exception, WSEC C405.2.2, Item 2, applies to those areas not otherwise provided with
occupancy sensor controls. Unlike occupancy sensor controls, which would sense the presence of a medical
provider/patient and allow the space to remain illuminated at desired/required levels, time switch (and
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daylight responsive (reduction)) controls would turn off or reduce the lighting level as programmed (without
regard to the use/need), justifying the exception of those controls.
TGB Response:
"Flag 2" has been removed from the rooms above on the ceiling plan and the ceiling plan key notes.
In addition, time switch control(s) with a manual override should be provided for the lighting serving the
following spaces:
• 2200 — Waiting
• 2201— Corridor
• 2203 — Reception
• 2211- Corridor
TGB Response:
"Flag 1" has been added to the above rooms on the ceiling plan and the ceiling plan key notes with new text
"Install time switch lighting control(s) with a manual override."
On sheet 53.01— Structural Details:
17. Detail 2 — Top of Shear Wall to (E) Roof Parallel Framing — Clarify on the plans the specified fasteners to be used to
attach the '2x14' to the existing roof framing. It appears that the method to be used to attach the gypsum board to the
top -track of the wall framing was inadvertently substituted for the '0.162" 0 nails' specified earlier.
TGB Response:
Structural drawing has been revised to show OSB instead of 2x14, and has been revised with respect to the fasteners
Into the joists and the fasteners for the top track to the OSB.
Other revisions that were made, but were not required by Plan Check: BLD2017-1711— 2nd review, are also clouded and
marked revision U. There updates are insignificant to the permit process, and include:
1. Existing support post, to remain, was added to the drawings. It was recently discovered during demolition slightly
north of grid A on gridline 3. This location interfered with a planned open nook area. So the design was modified to
align the wall initially planned east of the post, to now be in line with the post on grid 3. Revisions pertaining to
that can be seen clouded on Sheets A2.01, A2.11, A2.21, A2.410 A7.02.
2. Sheet A6.01: During Revision #2, door 2206 changed from 3'6" wide to 3'0" wide. The plans and door schedule were
updated at that time, however the door schedule wasn't clouded at that time. Simply, a cloud was added to the
door schedule showing that the size of the door is 3'000.
3. Sheet A7.01: Drawing 6 and 9 had minor updates to clarify casework intentions.
Sincerely,
Vernita Lytle, IID , NCIDQ
Interior Designer
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