HomeMy WebLinkAboutPlaintiffs' Expert Disclosure
Bob Barrett
(303) 526-1800 (main)
(303) 526-1805 (fax)
Bob.Barrett@b2ce.com
Consulting Engineers
EXPERT REPORT
Date: March 18, 2013
To: T.J. Voboril – Thompson, Brownlee & Voboril, LLC
From: Bob Barrett – B2CE, Inc.
RE: Arthrex Tenant Finish in Vail Gateway Building – Mechanical System Investigation
B2CE Job No.: 12050.00
This progress report provides my professional opinion regarding the subject building systems I
have reviewed to date. The report’s opinions are based on the documents I have reviewed so far
and my knowledge and experience as a mechanical engineer. This report augments and modifies
my original summary memo dated March 21, 2013.
I reserve the right to modify my opinions pending further review of additional information, should
that information become available to me.
HOA’S CONCERNS
This report addresses my perceptions regarding the Gateway Homeowner’s concerns regarding
the Arthrex space in the Vail Gateway Building. I assume the HOA is:
1. Concerned about odors or airborne and/or waterborne contaminates affecting the other
tenants in the building.
2. Concerned about code violations in the tenant finish construction.
3. Concerned that the construction process did not follow the required building covenants and
approval process. This issue is not addressed by this memo
DOCUMENTS REVIEWED
I have reviewed the drawings for the tenant finish work, which were generally dated 07-19-11
(Permit Set). The prime design professional for the project was Pierce Architects.
I reviewed modifications to the Heating, Ventilating and Air Conditioning (HVAC) and Plumbing
drawings, prepared by Architectural Engineering Consultants (AEC) through Rev 3, dated 11-07-
11.
I have reviewed the base-building drawings and a code analysis letter dated November 29, 2012
51199840 Mar 18 2013 10:42PM
March 18, 2013 B2CE, Inc. Memo Page 2 of 16
by Hughes Associates, Inc. The letter was primarily a Fire Protection and Life Safety evaluation of
the Parking Garage – but provided information on the likely construction building code and code
interpretation for the base-building.
I have also reviewed the file you've made available to me. This information includes:
1. Information you obtained from the City of Vail’s Building Department.
2. MSDS information from Arthrex.
3. Disclosure documents from the Architect – Pierce Architects; the General Contractor –
Viele; the HVAC sub-contractor – R&H; the Plumbing sub-contractor – PSI; and AEC.
4. Information on the on-going lawsuit.
OBSERVATION
I made a site observation, with you, on February 6, 2013. Unfortunately, I was blocked from
inspected cabinet contents and was not allowed to ask questions about the process or activities in
the Arthrex space.
DISCUSSION REGARDING THE ARTHREX SPACE
1. Observations of the Construction Process
a. In general, the tenant finish work for the Arthrex space was treated as a "typical"
commercial tenant finish project (i.e., 1988 Uniform Building Code – UBC, B-1
occupancy) by the building owner, the Town of Vail and the Design and
Construction Team. This may be appropriate.
However, the laboratory/dissection area may include elements that make it a
“medical or laboratory facility” (I - Institutional occupancy). Such facilities,
depending on their function, have more stringent design and construction code
requirements. They are more “complicated than a "typical" tenant finish.
In my opinion, the use of human cadavers and associated preservation and
instrument and surface cleaning chemicals may require make the Arthrex space a
medical laboratory facility in certain code-recognized ways – regardless of
designated code occupancy.
The space may warrant a design that more completely separated the building’s
Heating, Ventilating and Air Conditioning (HVAC) system from the rest of the
building. The current installation does not protect from plumbing cross-connections
adequately.
b. The mechanical (HVAC and Plumbing) and electrical engineer, AEC, provided a
proposal for engineering services that included “typical”, minimum tenant finish
services appropriate to an office or retail tenant finish.
However, the HVAC design appears to have evolved during the course of design.
March 18, 2013 B2CE, Inc. Memo Page 3 of 16
For example, AEC’s design provided significant modifications and additions to the
base-building HVAC system, primarily for the laboratory/dissection area.
The original proposal contemplated a maximum 20 person occupancy. Their final
design accommodates 58 people.
AEC also proposed minimal construction phase services, but appear to have
provided more CA services than contemplated. This is true for Pierce as well.
AEC’s fee was increased to reflect some of this increased scope, but I do not know
how much. I do not know if Pierce received additional fee for their increased scope
of work, either.
c. The HVAC permit drawings do not closely match the final “as-built” configuration of
the space. This is primarily due to the alignment of pre-existing tenant and base-
building components above the ceiling.
d. There is no record of the HVAC or pluming equipment (or any mechanical
equipment) being submitted and reviewed in the information I have seen to date.
Submittal review is a fairly standard requirement for most construction, but is
sometimes overlooked in “standard” tenant finish projects.
e. There were minimal closeout documents in the record that I have reviewed to date.
For example, Operational and Maintenance (O&M) information for the new
mechanical equipment does not seem to exist for the project.
i. However, the air-side of the HVAC system did have a Test, Adjust and
Balance (TAB) report.
1. The report showed that the existing VAV boxes were short on air
(compared to design).
2. On the other hand, the report showed that tenant specific ventilation
system for the space was greater than design (for both outside air
and exhaust).
2. Notes on Arthrex Process and Chemicals
a. I was blocked from inspected cabinet contents and was not allowed to ask questions
about the process or activities in the space.
b. Since I was prevented from asking questions about the process, I may not interpret
the use of chemicals, cadavers or the installed equipment correctly.
c. Some of the chemicals listed in the MSDS sheets provided by your office are
classified as high or very high hazard. Some are moderately or acutely toxic (for
example, paint remover”). Some have unknown toxicology effects (for example,
“Virex”). Depending on the amount of each chemical stored and used, the Arthrex
space could be considered a “hazardous” occupancy, as defined by the building
code. Such occupancy has much more stringent requirements than a typical “retail
or office” or even “institutional” occupancy, as defined by the building code.
March 18, 2013 B2CE, Inc. Memo Page 4 of 16
Potentially hazardous or questionable chemicals used in the space (based on the
MSDS sheets), include:
i. Jasco Premium Paint Remover
ii. Virex 256
iii. Liquid Spearhead
iv. (Depending on quantity used) “Eco-San” and unidentified “Liquid Bleach”
v. Other, as yet undisclosed cadaver preservative chemical
d. Arthrex' clients are warned about removing gloves and other protective gear from
the laboratory (via a sign at the back stairway, exit). This prohibition raises
additional concerns as it implies that potentially hazardous medical waste or
chemical residue might be transmitted to the rest of the building otherwise.
3. Concerns regarding Potentially Hazards is Due to Insufficient Information
Since the medical dissection process and quantity of potentially hazardous or toxic
chemicals is unknown, the positive pressurization of the space; and the plumbing cross-
connection hazards discussed below may or may not have an impact on the health of other
occupants in the building.
DISCUSSION REGARDING THE HVAC DESIGN
1. Base Building HVAC System
The HVAC system for the Arthrex tenant finish uses the base building common air handler
and new, dedicated outside air systems and exhaust fans.
The base building system consists of a central built-up air handler with an outside
air/economizer, a variable speed supply fan and heating and cooling coils. The air handler
serves the commercial units (only) by delivering medium pressure air to variable air volume,
parallel fan-powered “terminal boxes” (VAV boxes) in the ceiling of the occupied spaces.
The VAV boxes include a hydronic heating coil that is served by the base building boiler
plant.
The boxes draw a fixed amount of mixed air consisting of 1) Return Air (from the plenum)
and 2) Primary air (from the air handler). The amount of primary air is controlled by the
thermostat – as described below. The fan circulates this “mixed air” through the heating
coil and new, supplemental cooling coils to condition the supply air, which is delivered to
the space via ceiling diffusers.
2. Notes on the HVAC design:
a. The HVAC drawings prepared by AEC called the existing VAV boxes “fan coil units”.
They are called FC-9 and FC-10 on their drawings. FC-9 serves the lecture area.
FC-10 serves the laboratory/dissection area. Both FC units are located above the
lecture area.
March 18, 2013 B2CE, Inc. Memo Page 5 of 16
b. Minor deviation from the drawings:
i. The AEC design intended to have the new outside air system ducted to the
intake of the existing VAV boxes, adding a third component to the mixed air
stream. Instead, tempered outside air appears to be ducted to the near
vicinity of the FC(VAV) intakes, where it positively pressurizes the return air
plenum.
ii. There are two FC(VAV) boxes for the Arthrex tenant finish located above the
ceiling in the lecture area. There is a third box in the Arthrex space, which
serves the adjacent “Suite 300-A” space. This box is not shown on AEC’s
drawings.
It is not unusual for adjacent spaces to share a VAV box or for a VAV box to
be located in an adjacent space for “normal” occupancy tenant finish areas.
However, if the Arthrex space occupancy was to be re-classified, the location
of Suite 300-A’s VAV box and the lack of separation at its demising wall
might be a concern, as discussed below.
c. Conditioned “supply air” from the VAV boxes is delivered to the space through
ceiling diffusers. It returns to the VAV boxes and the central air handler via a return
air plenum above the ceiling.
d. All commercial tenants have similar VAV boxes and share the same return air
plenum system.
It may be the case that there is nothing exceptionally hazardous created in the
Arthrex space (as compared to the other tenants).
However, if there is something hazardous about the Arthrex process or chemicals
used, all of the building occupants are exposed to those contaminates to varying
degrees.
See the discussion regarding Space Pressurization, below. The residents would
primarily be exposed to the contaminates by positive pressurization of the Arthrex
space and by “stack effect”. They would likely experience relatively lower
concentrations. All of the commercial tenants share the same air-handler and return
air, so they would tend to be exposed to higher levels of contaminates (if they exist).
Tenants closest to the Arthrex space may be exposed to higher levels of
contaminates (if they exist) due to positive pressurization of the Arthrex space.
Suite 300-1 may see the highest concentrations of contaminates due to its proximity
to the Arthrex space; because it is not separated from the Arthrex space by full-
height, fire-rated demising walls; and because its VAV box is located above the
Arthrex space.
e. The VAV boxes are controlled by a thermostat located in the occupied space. The
controls are pneumatically controlled (as is most of the base building system).
The “base-building standard” VAV boxes control space temperature as discussed
March 18, 2013 B2CE, Inc. Memo Page 6 of 16
below:
i. The main air handler controls the supply air temperature using the
economizer and heating and cooling coils.
1. The air handler was maintaining approximately 62° supply air
temperature at the time of our observation. Markings on the control
panel indicate that it may be reset as low as 55° in the summertime
and as high as 70° in the wintertime.
ii. The VAV controls indirectly control space temperature by controlling the
amount of cool (or “cold”) primary air supplied to the mixed air for each box.
Primary air is increased as space temperature rises.
iii. If heating is necessary, the primary air dampers modulate to a fixed
minimum position, and the heating coil is energized.
iv. The VAV fan is intended to run continuously when the space is occupied.
In the case of the modified VAV boxes that serve the Arthrex space, the air may
also be re-cooled by the new DX refrigeration cooling coils located downstream of
the boxes.
3. Space Pressurization
Return air flow (back to the central air handler) is induced by slight negative pressurization
of the return air plenums above the ceilings in the commercial spaces. Depressurization is
created by the main air handler’s fan. Therefore, all commercial spaces have negatively
pressurized plenums (when referenced to the pressure in their occupied space). This does
not mean their occupied spaces, themselves, are negatively pressurized.
Due to mixing of outside air, the base building system supplies more air than it returns.
Therefore, it tends to positively pressurize the building (as a whole). The degree of
pressurization is controlled by the amount of outside air directed into the intake (“mixed”) air
stream, which is controlled by the air handler’s outside air damper position and the fan’s
speed.
However, the base building HVAC system may positively or negatively pressurize a given
tenant space, depending on the quantity of primary air delivered to that particular space,
and depending on the air flow out that space (compared to the rest of the building).
As well, exhaust fan operation tends to negatively pressurize those spaces served by
dedicated exhaust fan(s). For example, bathroom exhaust fans tend to depressurize toilet
rooms. As a result of the negative pressure, these fans tend to minimize odor transmission
to the rest of the building.
The Arthrex space includes two dedicated exhaust fans as discussed below.
Outside air temperature and wind pressures also affect building and tenant space
pressurization. Windward facing exterior walls tend to be positively pressurized by outside
air infiltration. Leeward facing exterior walls tend to be negatively pressurized.
In the wintertime, the highest areas of the building are also pressurized by "stack effect"
March 18, 2013 B2CE, Inc. Memo Page 7 of 16
airflow from the lower floors in the building.
Each tenet space is positively or negatively pressurized by the net supply of air to the space
(from all sources). If a space has the same amount of intake (or “supply”) air as exhausted
or returned, it is said to be “neutrally pressurized.” If the supply airflow exceeds the exhaust
and return airflow, the space is positively pressurized, with respect to the rest of the
building. If the exhaust and return airflow exceeds the supply air, the space will be
negatively pressurized, with respect to the rest of the building.
4. Arthrex Space is Positively Pressurized (with Respect to the Rest of the Building)
The Arthrex space is positively pressurized with respect to the rest of the building.
In addition to the influences of the base-building system – to positively pressurize the space
– the new HVAC system includes two additional sources of outside air. Its two dedicated
exhaust fans exhaust far less air than is supplied.
The AEC drawing calculates a minimum outside air requirement of 1136 cubic feet per
minute (CFM) for ventilation of the Arthrex space. This is the reason for the positive
pressurization. This outside air was intended to come from a combination of primary air
(through the base building system) and the new, dedicated outside air systems.
a. Sources of Supply Air
i. The base building air handling system may pressurize or depressurize a
specific space as described above.
For the Arthrex space, the drawings call for 825 CFM “minimum outside air”
to be supplied at all times from the existing FC (VAV) boxes. They also
require 2850 total (fan-forced) and 1785 maximum primary airflow rates.
The TAB report did not measure or balance maximum or minimum primary
airflow. However, total airflow was measured at 2184 CFM (fan-forced).
However, the FC (VAV) boxes do not directly control outside air, only
primary air. Depending on the main air handler’s outside air damper
position: The primary airflow may be as little as 10%, to as much as 90%
outside air. Therefore, the scheduled ventilation rates from the existing
equipment are generally not achieved in the installed system. This variable
flow of outside air (from the base building system) affects the Arthrex space
pressurization in a variable way (depending on primary air flow – and the
percentage of outside air in that airstream).
1. Control of Main Air Handler Outside Air
The base building air handler has “Economizer mode” capacity. It
mixes outside and return air to meet the desired supply temperature,
when outside air temperatures allow. The controls allow the outside
and return air dampers to modulate fully closed. However, the
dampers leak when fully closed. The minimum effective delivery
from the air handler is therefore about 10% outside air; the maximum
is about 90% outside air. The air handler was operating in
economizer mode at the time of my observation, at approximately 40
March 18, 2013 B2CE, Inc. Memo Page 8 of 16
to 50% outside air.
The base building air handler’s outside air damper will modulate to its
minimum position at very high or very low outside air temperatures.
The quantity of outside air delivered by the base-building system
under these conditions will be minimal. Therefore, the resultant
space pressurization by the base-building system will be minimal.
a. As a result: The base building system pressurizes the Arthrex
space but to an unknown and variable amount.
b. The primary air minimum and maximum damper positions in
the FC (VAV) boxes are unknown.
ii. Supplemental Ventilation Air in the Arthrex Space
The Arthrex space also has a supplemental source of outside air. This
system is the primary cause of positive space pressurization in the Arthrex
space (with reference to the rest of the building).
Outside air from intakes on residential decks (above the Arthrex space) is
ducted to new supply fans (SF). These fans are intended to be energized
via a time clock, whenever the space is occupied. The outside air is
tempered by electric duct heaters (EDH). The supplemental cooling coils at
the discharge of the existing FC (VAV) boxes provide additional cooling, if
required. Both supply fans were running at the time of our observation.
The drawings require the supply fans to provide an additional 880 CFM of
outside air to the space. The TAB report shows the actual airflow at 1125
CFM. Therefore, the supplemental system, by itself, meets the ventilation
requirements for the 58 person occupancy shown on AEC’s drawings.
The SF provides an additional “supply” quantity of 1125 CFM, which
pressurizes the space.
b. Dedicated Exhaust
The tenant finish drawings also call for dedicated exhaust from certain areas in the
Arthrex space. EF-1 serves the new bathroom. It is rated at 65 CFM (and balanced
to 78 CFM). EF-2 serves the vacuum pump closet and is rated at 480 CFM (and
balanced to 498 CFM). EF-2 exhausts air from the vacuum pump closet. The
vacuum pump exhausts (presumably) contaminated air from the medical suction
equipment at the “stations” in the lab/dissection area.
EF-1 is controlled by the wall switch that controls the bathroom lights, and is
normally off. EF-2 is controlled by a wall thermostat in the vacuum pump closet. It
was set to 60⁰ (and running) at the time of our observation.
Therefore, the net space pressurization in the Arthrex space varies, but is always
positive during occupied hours.
March 18, 2013 B2CE, Inc. Memo Page 9 of 16
c. Indirect pressurization from the base building system is variable, but probably
minimal. Direct pressurization (from the new dedicated SF and EF units) is (1125 –
498) = 627 CFM most of the time. This is significant positive pressurization for the
approximately 2100 sq.ft. of the Arthrex space.
Pressurization increases to 1125 CFM if both exhaust fans are off. The space is
only pressurized by the base-building system during unoccupied hours and may be
negatively de-pressurized if EF-2 continues to run after SF-1 & -2 are de-energized.
d. “Plenum Exhaust Fans”
The AEC drawings refer to non-existent “plenum exhaust fans”. SF-1 & -2 were
intended to be interlocked with these fans (see the SEQUENCE OF OPERATION
on sheet M1.0). AEC may believe that these imagined fans somehow exhaust the
same amount of air as is supplied by their new SF systems and/or somehow
maintain the Arthrex space at a negative pressure. This is not the case.
e. Space Pressurization v. Common Return Air
The Arthrex space is generally very positively pressurized when occupied. Any
positive pressurization will tend to cause air from the lab/dissection area to exfiltrate
into adjacent businesses and the central lobby/atrium. A typical exfiltration path is
shown in Figure 1, below. If present, contaminates or toxic chemicals from the
Arthrex space will therefore be distributed throughout the building.
However, regardless of actual space pressurization (with respect to the rest of the
building), the base building HVAC system is constantly removing air-borne
contaminates from the Arthrex space (as well as all other commercial spaces),
mixing them with a variable amount of outside air, then re-supplying the remaining
contaminates throughout the commercial space (via the VAV boxes).
Additionally, winter time stack pressurization will tend to cause air from the
commercial spaces to infiltrate into the residential units located immediately above
the Arthrex space.
DISCUSSION REGARDING INTENDED SEPARATIONS BETWEEN SPACES
1. Required Fire Separation between the Arthrex Space and the Rest of the Building
The architectural drawings include sheet A001. This sheet is entitled “Existing Diagram &
Fire Rated Assemblies” on the drawing index (on sheet A000). However, sheet A001 does
not clarify fire rating requirements. The same wall type is indicated at all tenant demising
walls, but perhaps is not required for the common lobby/atrium exiting pathway at the
entrance to the Arthrex space.
2. Observations of Fire-Rated Separations:
a. I observed fire-rated above-ceiling wall construction in the tenant walls to the north
of the project. Similarly rated tenant and exterior wall construction appears to be
required (or at least indicated) on sheet A001.
March 18, 2013 B2CE, Inc. Memo Page 10 of 16
b. The air devices have fire dampers, which imply that the ceiling is also intended to be
a rated separation.
Figure 1: (Taken February 6, 2013). Entrance to Arthrex Space. INSET: Typical gaps at glass sections (where Arthrex
air can exfiltrate into the lobby/atrium area.
Figure 2: (Taken February 6, 2013). Return Air transfer opening on north side of lab area. Note fire damper.
March 18, 2013 B2CE, Inc. Memo Page 11 of 16
I understand that the building was originally permitted and constructed as an indoor
“mall”, which would be consistent with this type of separation. If this is the case, the
plenum for certain groups of areas are required to be separated from adjacent
spaces and non-mall exit corridors by a full height, fire-rated wall. All penetrations
of the wall are intended to be protected with a fire-damper (if required for return air
flow), or fire stopped.
I believe that Pierce’s architectural drawings intended full-height, fire-rated walls
throughout the space. See the note on sheet D201, which reads, “INFILL
OPENINGS TO PROVIDE PROTECTION TO ADJACENT TENANT.” (emphasis
mine).
However, there is no full-height, fire-rated demising wall between the Arthrex space
and Suite 300-1. The demising wall does not run all the way to the underside of the
structural deck. See Figure 3.
Figure 3: (Taken February 6, 2013). Stub-up wall into RA plenum. Dark area behind is plenum above 300-A. Contrast
above-ceiling wall with wall shown in Figure 2.
The lack of separation between the Arthrex space and the rest of the building may
violate Pierce’s architectural design intent. However, I currently believe it does not
violate the intent of the code under which the building was originally permitted and
constructed.
March 18, 2013 B2CE, Inc. Memo Page 12 of 16
In fact, the Authority Having Jurisdiction’s (AHJ)’s interpretation of the building code has
been satisfied. The construction of the space has been reviewed, and a certificate of
occupancy was granted. The building department further justified their actions with a
memorandum regarding the “Arthrex, Inc. processes and procedures” dated December
15, 2011.
3. Other Code Issues Related to the HVAC System
a. Plastic is not allowed in return air plenums, and is a special hazard for fire rated
ceiling plenums. PVC plastic pipe serves the condensate drains for the new DX
cooling coils for FC(VAV)-9 and -10. This exposed piping violates code.
b. Some of the electrical control boxes are open.
4. Exam/Dissecting Table Plumbing Code Violations
There are 10 exam/dissecting “stations" in the lab/dissection area. Each station includes a
morgue-type table with a large monitor and multiple racks of Arthrex equipment on the wall.
Each station also includes a below-table water distribution system consisting of a water
closet fill valve and bucket, with small diameter tubes leading from the bucket to some of
the racked Arthrex equipment. See Figure 4. The tops of the buckets are higher than the
approved air gap or vacuum breaker in the fill valve. If the valve fails open, the air
gap/vacuum breaker (whichever it is) will be under water. The water hose runs from the
adapter on the hose bibb, into the bucket, and is the same water as the clear recirculation
tubes that connect to the medical equipment.
The fill valve is connected by a hose to 2-way garden splitter fitting, which is connected to a
hose bibb. The hose bibb is located slightly below the level of the table. The other end of
the splitter is connected to a wash-down spray hose (similar to what one would see on a
kitchen sink). See Figure 5>
The hose bibb (HB-1) is called out in the “PLUMBING FIXTURE CONNECTION
SCHEDULE” on sheet P2.0. The building department review resulted in a vacuum breaker
being added to the schedule.
The basis-of-design HB was not installed and the installed HB did not appear to have the
required vacuum breaker.
There are three violations of the plumbing code with the exam “station” set-up:
a. The hose bibb does not, in fact, appear to be protected with any type of backflow
prevention device.
i. Some AHJ might have required a better backflow preventer for this type of
facility. However, it must be (at minimum), an atmospheric vacuum breaker.
b. If a vacuum breaker was installed, the hose bibb is below the table and too close to
the finished floor.
See paragraph 608.3.1 of the 2009 International Plumbing Code (IPC), which is part
of section 608, PROTECTION OF POTABLE WATER SUPPLY. It reads,
March 18, 2013 B2CE, Inc. Memo Page 13 of 16
“608.3 Devices, appurtenances, appliances and apparatus.
All devices, appurtenances, appliances and apparatus intended
to serve some special function, such as sterilization, distillation,
processing, cooling, or storage of ice or foods, and that
connect to the water supply system, shall be provided with protection
against backflow and contamination of the water supply
system. Water pumps, filters, softeners, tanks and all other
appliances and devices that handle or treat potable water shall
be protected against contamination.
608.3.1 Special equipment, water supply protection. The
water supply for hospital fixtures shall be protected against
backflow with a reduced pressure principle backflow
preventer, an atmospheric or spill-proof vacuum breaker, or
an air gap. Vacuum breakers for bedpan washer hoses shall
not be located less than 5 feet (1524 mm) above the floor.
Vacuum breakers for hose connections in health care or laboratory
areas shall not be less than 6 feet (1829 mm) above the floor” (emphasis mine).
Figure 4: (Taken February 6, 2013). Typical below-table bucket and fill valve assembly. Braided hose is the water
supply (from the hose bibb). Clear tubes go to medical equipment above the table.
March 18, 2013 B2CE, Inc. Memo Page 14 of 16
Figure 5: (Taken February 6, 2013). Typical dissection table with bucket/fill valve assembly and indirect table drain
hose inserted into the floor drain. The hose bibb is just out of the picture at the right. INSET: Typical hose bibb and
splitter assembly. The braided hose on the left serves the bucket/fill valve assembly. The braided hose on the right
serves the table wash-down spray hose.
It is possible, though unlikely, for contaminates on the exam/dissection table or the
bucket to be introduced into the domestic water supply for the building as a result of
this arrangement. This is called a cross-contamination hazard (due to back
siphonage or backflow).
c. Water is drained from the table via a sidewall gutter system, which is drained by
large diameter clear hoses which join into a single hose which is currently inserted
into the floor drain.
In my opinion, this arrangement violates paragraph 802.1, of the IPC, which reads,
in part,
“All health-care related fixtures, devices and equipment shall discharge
to the drainage system through an indirect waste pipe by
means of an air gap in accordance with this chapter and Section 713.3”
March 18, 2013 B2CE, Inc. Memo Page 15 of 16
The lack of an air gap creates a potential cross-contamination from the public sewer
to the exam table.
One may believe that the improper drain termination might confine the hazard to the
Arthrex space. However, contamination in the space can be spread throughout the
rest of the building when occupants travel out of the space, and by the HVAC
system (due to positive space pressurization).
I believe the hose should be above the “flood level rim of the receptacle” (or an inch
above the drain).
5. Other Potential Plumbing Code Violations
There is no floor drain for the water heater, so the P&T relief is not routed to a
receptacle as required by code. However, there is a floor drain within a few feet of the
water heater closet. This code requirement is a typical, violation of the plumbing code.
It creates a water damage hazard for Arthrex and other tenants, but it is not a life-safety
violation.
RECOMMENDATIONS
1. Obtain Better Information on Processes and Chemical used in the Arthrex Space
a. The AHJ should specifically examine the dissection procedures in the space and
confirm that the laboratory does not constitute a (1988 UBC) Type “I”, Institutional,
medical occupancy. A memo of interpretation can be requested by the HOA.
The AHJ should specifically examine the amounts and frequency of use of
potentially hazardous or toxic chemicals in the space and issue a memo of
interpretation with regard to space pressurization and common return air health
hazards.
If the AHJ determines that there is no hazard, changes to the HVAC system are
practically unenforceable.
However, upon further examination, the AHJ may impose additional HVAC system
modifications. Such modifications may require supplemental controls to maintain
the Arthrex laboratory space at a negative pressure (with respect to the rest of the
building). Re-designation of the occupancy as an “H” or “I” occupancy may require
complete isolation of the Arthrex laboratory space HVAC system from adjacent
spaces.
2. Correct Plumbing Code Violations
a. HB Installation
Install two reduced pressure principal backflow preventers in the ceiling for the two
¾” domestic cold water lines serving the dissection table hose bibbs. The
preventers should be equipped with a minimum 1-1/2-inch diameter drain line, which
should be routed to an indirect drain (with air gap) at the nearest floor drain.
March 18, 2013 B2CE, Inc. Memo Page 16 of 16
b. Dissection Table Indirect Drain
Provide a mechanism to secure each indirect drain above the floor drain (with the
outlet turned vertically) and with the required 1-inch air gap.
3. Correct Fire Code Violations
a. Use of PVC plastic pipe in the return air plenum
Provide plenum rated insulation (such as kraft-faced fiberglass, or plenum rated
closed-cell foam) covering of all exposed PVC piping within the plenum.
b. Properly seal all open control and line-voltage J-boxes in the plenum.
END OF MEMO
W:\B2CE\Jobs\Arthrex TF Investigation @ Vail Gateway.12050.00\Reports\Prelim MEP Expert Report. Arthrex Gateway. B2CE-Bob.18 Mar 13.docx / 3/18/2013 10:17:00 PM / 3/18/2013 10:24:00 PM