Building Comments 1.pdfCity of Edmonds
PLAN REVIEW COMMENTS
BUILDING DIVISION
(425) 771-0220
DATE: February 28, 2019
TO: Scott Becker
the design COLLECTIVE
scottb(a),thed-c.com
FROM: Chuck Miller, Senior Plans Examiner
chuck.miller(2edmondswa. gov
RE: Plan Check: BLD2019-0134 —1st review
Project Address: 400 Dayton Street
Project: Bennett & Bennett tenant improvement
Scope: Alteration of floor framing-remove/add non -bearing interior walls/doors to
reconfigure spaces -lighting changes -plumbing included — nonseparated Business
group B occupancy — undetermined number of occupants — VB construction — no
sprinkler system — fire alarm, etc. under separate permits
Please be advised that the building plans for the above referenced project have been disapproved
for the purposes of obtaining a building permit. During a review of the plans by the Building
Division for compliance with the applicable building codes, it was found that the following
information, clarifications, or changes are needed. Reviews by other divisions, such as Planning,
Engineering, or Fire, may result in additional comments that require attention beyond the scope of
this letter.
A complete review cannot be performed until the revised plans/documents, including a
written response in itemized letter format indicating where the `clouded' or otherwise
highlighted changes can be found on the revised plans, have been submitted to a Permit
Coordinator. Only those sheets specifically referenced as follows need to be resubmitted.
Resubmittals must be made at the Development Services Department on the 2nd Floor of City Hall.
Permit Center hours are M, T, Th, & F from 8am-4:30pm and from 8:30am-12pm on Wednesdays.
General plan review comment: The configuration of the structure completed under permit
BLD1981-0207 resulted in two separate two-story suites, each with their own means of egress. The
second floor of each suite was allowed to have only one exit from that level because the occupant
load was less than 11. The second floor of each suite also had an area that was `open to below'.
The work proposed under this permit appears to remove a portion of the second story wall
separating the two suites, resulting in one larger area now required to be served by two exits due to
an exit access travel distance greater than that allowable for 1 exit per International Building Code
(IBC) Table 1006.3.2(2). The opening in the second floor over the `SOUTH SUITE' also appears
to have been eliminated. The preceding criteria framed the review of the proposed project and
resulted in the following plan review comments.
On the City of Edmonds `Building Permit Application':
1. PLUMBING FIXTURE COUNTS — Clarify on the plans the selection and number of the
following fixtures:
• Hose Bibbs — 2 — There does not appear to be any nature of work where a fixture of
that type would be installed.
Sinks — 4 — While the two sinks on the upper level appear to be in different locations
than that represented on the approved plans for permit BLD 1981-0207, and therefore
require the plumbing serving them to be relocated, the locations of the remaining two
sinks on the main floor appear to be unchanged. Merely changing the fixture at the
same point -of -use does not effectively change the plumbing system and be required
to be inspected.
Toilets — 4 - While the toilet on the upper level appears to be in a different location
than that represented on the approved plans for permit BLD1981-0207, and therefore
require the plumbing serving it to be relocated, the locations of the remaining two
toilets on the main floor appear to be unchanged. Merely changing the fixture at the
same point -of -use does not effectively change the plumbing system and be required
to be inspected. There does not appear to be a represented location of a fourth toilet.
Refrigerator Water Supply — I — There does not appear to be a proposed installation
of an appliance utilizing such a water supply referenced or represented on the plans.
Water Heater — Tankless? Y or N — N - There does not appear to be a proposed
installation of a water heater to replace either/both of those located below the sinks
in the main level restrooms referenced or represented on the plans.
On sheet A0.01— COVER SHEET:
2. GENERAL AND ENERGY NOTES
a. APPLICABLE CODES — Change on the plans the following to correspond with that
currently adopted or applicable:
• From `International Residential Code' to `International Building Code' (IBC)
• From `International Energy Code' to `Washington State Energy Code'
(WSEC)
o Eliminate `Option 3' and change climate zone `1' to `Marine 4'
• Eliminate `Washington State Ventilation & Indoor Air Quality Code' (those
provisions were incorporated into the International Mechanical Code (IMC)
and the International Residential Code (IRC) in 2009).
• From `Edmonds Municipal Code' to `Edmonds Community Development
Code' (ECDC)
b. ENERGY NOTES —Eliminate from the plans the reference to `V.LA.Q.'.
i. INSULATION — Change on the plans the code section regarding the
installation of insulation from `707' to `C402'.
ii. INSULATION MATERIALS — Change on the plans the referenced code
regarding the characteristics of the insulation from `UBC Standard 8-1' to
`IBC Section 720'.
iii. CLEARANCES - Eliminate from the plans the reference to `W.S.V.I.A.Q.'.
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iv. AIR LEAKAGE — Change on the plans the American Society for Testing of
Materials (ASTM) standard regarding the leakage rate of windows from `E
283-73' to `E 283-04'. Currently, the WSEC regulates air leakage of the
complete building envelope in accordance with ASTM E 779 per WSEC
C402.5.1.2.
v. WATER SERVICE HEATING
1. Change on the plans the code version and code table regarding the
insulation of piping from a water heater from `2009' and `Table 5-12'
to `2015' and `Table C403.2.9'.
2. Eliminate from the plans the qualifier `non -recirculating' regarding
the required freeze protection of hot and cold water pipes per Uniform
Plumbing Code (UPC) 312.6.
3. Change on the plans the Washington Administrative Code (WAC)
chapter adopting the UPC from `51.26' to `51-56'.
4. Eliminate from the plans the qualifier `...with non -rigid water
connections and over 4' in height...' regarding the seismic anchorage
of water heaters per UPC 507.2.
5. Change on the plans the U-factor of doors in enclosures for water
tanks and furnaces provided with combustion air openings to the
exterior from `0.40' to `0.37' per WSEC Table C402.1.4.
On sheet A0.12 — FLOOR PLAN — CODE SUMMARY:
3. UPPER FLOOR PLAN — CODE SUMMARY
a. OCCUPANT LOAD (table to the left of the floor plan) — WAITING AREA —
Clarify on the plans the indicated function of space used in determining the number
of occupants in space `202' — LOUNGE. It appears to imply the use by other than
staff in an area noted elsewhere as not part of the primary function.
b. Indicate on the plans the furnishings used for seating in space `202' — LOUNGE —
per the City of Edmonds tenant improvement submittal requirements. Of particular
concern is the accounting of the `net square feet' (NSF) used to determine the
number of occupants per IBC Table 1004.1.2.
c. Clarify on the plans the identified use of space `208' — OFFICE. Of particular
concern is IBC 1016.2, Item 2.
4. MAIN FLOOR PLAN — CODE SUMMARY - Indicate on the plans the furnishings used for
seating and any built-in furnishings in spaces `100' and `115' — WAITING — and spaces
`101' and `114' — SECRETARY - per the City of Edmonds tenant improvement submittal
requirements. Of particular concern is the accounting of the `net square feet' (NSF) used to
determine the number of occupants per IBC Table 1004.1.2. It appears that areas used as
walkways (not otherwise delineated by walls or other permanent elements) have been
deducted, beyond that defined for `net floor area'.
5. CODE SUMMARY NOTES
a. OCCUPANCY GROUP
i. Eliminate from the plans the reference to `incidental use' for those areas
used for `waiting'. Incidental uses shall not be individually classified in
accordance with Section 302.1 per IBC 509.2.
ii. Eliminate from the plans the implied reference to an evaluation for an
`accessory occupancy' based upon the portion of the floor area used for
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`waiting'. The use of a portion of a structure classified as a Business Group
B occupancy as a `waiting area' does not require that area to be separately
classified and does not meet the criteria for classification as an Assembly
Group A-3 occupancy per IBC 303.4.
b. CONSTRUCTION TYPE
i. TABLE 601: BUILDING ELEMENTS — Eliminate from the plans the
noted occupancy classification. Occupancy classification is not a criteria
for the fire -resistance rating requirements of building elements per IBC
Table 601.
ii. EXTERIOR WALL LOCATIONS — SOUTH WALL — Change on the
plans the requirement regarding the fire -resistance rating of the exterior
wall from `at alterations' to `to be maintained' to reflect that determined
under permit BLD1981-0207.
c. FIRE RATING OF BUILDING ELEMENTS — Eliminate from the plans the
provided information. It appears to be redundant to that found in
`CONSTRUCTION TYPE'.
d. INTERIOR FINISHES — Change on the plans the selected International Existing
Building Code (IEBC) compliance method chapter from `4' to `8' per that noted in
`ALTERATION TYPE'.
e. OCCUPANT LOAD CALCULATIONS
i. AREA/OCCUPANCY TYPE — Change on the plans that used to determine
the number of occupants (using the corresponding `occupant load factor')
from `occupancy type' to `function of space' — see plan review comment
`5.a.ii'.
ii. TOTAL OCCUPANT LOAD — Update on the plans the indicated number
of occupants in the various functions of space to reflect that determined in
response to earlier plan review comments.
f. EXITING
i. MINIMUM NUMBER OF EXITS — Change on the plans the number of
exits provided from each suite on the main floor from `one' to `two'.
ii. MINIMUM EXIT WIDTHS — Change on the plans the required placement
of handrails to be maintained from `one side' to `both sides' per the 1979
edition of the Uniform Building Code (UBC), Section 33050).
iii. MINIMUM DISTANCE BETWEEN EXITS
I. REQUIRED - Change on the plans the provided information to reflect
that required for the upper floor per IBC 1007.1.1. The length of the
maximum overall diagonal dimension appears to be greater than that
indicated.
2. PROVIDED - Change on the plans the provided information to reflect
that required for the upper floor to comply with IBC 1007.1.1. The
distance between the exit access stairways indicated on the `UPPER
FLOOR PLAN - CODE SUMMARY' is greater than that noted
(which would not comply for either floor).
iv. In the comment regarding the signage over doors that are permitted to have
key -operated locking hardware, change on the plans the wording from
`...DURING BUSINESS HOURS' to `WHEN BUILDING IS
OCCUPIED' per IBC 1010.1.9.3, Item 2.2.
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V. In the comment regarding the existing stairs, guards, and handrails, change
on the plans the required placement of handrails to be maintained from `one
side' to `both sides' per the 1979 edition of the UBC, Section 33050).
g. EXISTING VERTICAL OPENINGS — Change on the plans the provided
information to reflect the following:
• The vertical opening enclosure(s) are not required by the IBC because the
exit access travel distance without a sprinkler system does not exceed 200
feet per IBC Table 1007.1. (The complete means of egress requirements
are as follows: The one larger area on the upper floor is required to be
served by two exits due to an exit access travel distance greater than that
allowable for 1 exit for a story per IBC Table 1006.3.2(2) (instead of that
noted on the plans for spaces per 1006.2.1). The two exit access stairways
provided are required to have a minimum distance between each other per
IBC 1007.1.1. The common path of travel to the point where occupants
have separate and distinct access to the two exit access stairways cannot
exceed IBC Table 1006.3.2(2). The exit access travel distance from any
point cannot exceed IBC Table 1007.1 - if it did, the exit access
stairway(s) (not otherwise required to be enclosed per IBC 1019.3, Item 1)
must be enclosed (creating an interior exit stairway — an exit component)
and the protection be maintained to the exit discharge per IBC 1023.1)
h. ACCESSIBILITY
i. Change on the plans the referenced IEBC section regarding the accessibility
requirements for Level 2 Alterations from `410.7' to `806' per that noted in
`ALTERATION TYPE'.
ii. Change on the plans the referenced IEBC section regarding the accessible
route requirements for Level 2 Alterations affecting an area of primary
function from `410.7' to `705.2'.
i. CODE PLAN NOTES — Note 3 — Change on the plans the referenced IBC section
regarding the identification of accessible elements from `I 110.1' to `I 111.1'.
On sheet A2.01 — DEMO FLOOR PLANS:
6. DEMO UPPER FLOOR PLAN — Clarify on the plans the difference in the indicted
configuration of spaces/location of interior walls and of that represented on the approved
plans for that originally constructed under permit BLD1981-0207, and altered under permit
BLD2002-0375. Of particular concern are the existing -to -remain walls enclosing space
`212' — OFFICE — and areas of the second floor openings that appear to have been altered or
eliminated/filled-in without review or inspection. The scope of work on the application and
on the construction documents must clearly indicate all of the work required to achieve that
proposed under this permit, including that completed without approval at a prior time.
On sheet A2.10 — FLOOR PLANS:
7. UPPER FLOOR PLAN
a. Clarify on the plans whether the door serving space `212'- OFFICE — has been
provided with both a closer and a latch, and required to be provided with
maneuvering clearance per IEBC 705.1/IBC 1104.3.1/ICC Al 17.1-2009 Section
404.2.3.
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b. Clarify on the plans the indicated dimension in space `204' — HALLWAY — at the
door serving space `203' — OFFICE. It does not appear to provide the required
maneuvering clearance from the `push' side of door `U2' when provided with both a
closer and a latch (specified on sheet `A9.10' — DOOR & WINDOW SCHEDULES)
per IEBC 705.1/IBC 1104.3.1/ICC Al 17.1-2009 Section 404.2.3.
c. Clarify on the plans the indicated location of door `U2' serving space `203' —
OFFICE. It does not appear to provide the required maneuvering clearance from the
`pull' when provided with both a closer and a latch (specified on sheet `A9.10' —
DOOR & WINDOW SCHEDULES) per IEBC 705.1/IBC 1104.3.1/ICC A117.1-
2009 Section 404.2.3.
d. Clarify on the plans the identified use of space `208' — OFFICE. Of particular
concern is IBC 1016.2, Item 2.
On sheet A5.02 — RCP UPPER FLOOR PLAN:
8. RCP UPPER FLOOR PLAN
a. Specify on the plans the proposed lighting fixture to be used in the restroom
(presumed to be `SCONCE - RESTROOM' per the `LIGHTING FIXTURES'
schedule).
b. Clarify on the plans the identified use of space `208' — OFFICE. Of particular
concern is IBC 1016.2, Item 2.
9. ELECTRICAL FIXTURES
a. Indicate on the plans the required occupancy sensor controls per WSEC C405.2.1.
b. Indicate on the plans the required time switch controls for those areas not provided
with occupancy sensor controls per WSEC C405.2.2. The installation of occupancy
sensor controls, although otherwise not required per WSWEC C405.2.1, is an
acceptable alternative to time switch controls.
10. LIGHTING FIXTURES — Clarify on the plans the indicated wattage for the `TRACK
LIGHT'. It does not appear to reflect that required per WSEC C405.4.1, Equation 4-10,
LTPB for track lighting.
11. LIGHTING CALCULATION
a. Provide as part of a complete permit application submittal 2015 WSEC `Compliance
Forms for Commercial Buildings including R2, R3, R4 over 3 stories and all R1' as
required for the selections noted on the `Interior and Exterior Lighting Alterations'
section of the WSEC Lighting Summary — LTG -SUM. The completed forms must
include `LTG-INT-SPACE' and `LTG-CHK' at a minimum.
b. Clarify on the plans the proposed calculation method for determining total connected
lighting power. It appears to be similar to the WSEC `Building Area Method'
typically used for larger, open areas. Per WSEC C405.4.2.2, areas enclosed by
partitions that are 80 percent of the ceiling height or taller should use the `Space -by -
Space Method'. The indicated `lighting power allowance' (LPA — expressed in
watts/ft2) also does not appear to reflect that allowed for office areas per WSEC
Table C405.4.2(1).
On sheet A6.01 — INTERIOR ELEVATIONS:
12. Elevation 5 — LOUNGE — SOUTH — Change on the plans the `space numbering' of the
`HALLWAY' from `208' to `206'.
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On sheet A9.10 — DOOR & WINDOW SCHEDULES:
13. Indicate on the plans (on the DOOR SCHEDULE - REMARKS or the DOOR SCHEDULE
NOTES) the required hardware for door `U1' that will be exposed and usable from both
sides when in the fully open position per IEBC 705.1/IBC 1104.3.1/ICC A117.1-2009
Section 404.2.6.
On sheet 52.2 — Upper Floor Framing Plan:
14. Upper Floor Framing Plan — Clarify on the plans the difference in the design of the floor
framing and of that represented on the approved plans for permit BLD1981-0207. As
represented on these plans, the north -south beam over the east end of space `115' —
WAITING — (specified as a 2-2X12 Hem Fir #2 on the original plans) appears to fail in
bending.
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