Alburg Springs VT LPOE Code Report - 20260206 (1).pdf

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REPORT

FIRE PROTECTION & LIFE SAFETY &

ACCESSIBILITY CODE COMPLIANCE

REPORT

GSA Alburg Springs VT, LPOE

PREPARED FOR

Schwartz Silver Architects Inc.

75 Kneeland Street

Boston, MA 02111

Report #: 1ARG00342

Date: 02/06/2026

PREPARED BY

Jensen Hughes

33 Arch Street, 16th Floor

Boston, MA 02110

PROPERTY OF THE UNITED STATES GOVERNMENT. This is controlled unclassified information. Do not remove the CUI marking. Properly destroy or return document when no longer needed.

FIRE PROTECTION & LIFE SAFETY & ACCESSIBILITY CODE COMPLIANCE REPORT Alburg Springs, VT LPOE

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Table of Contents

1.0 INTRODUCTION

2.0 BASIS OF DESIGN

2.1 Building Descriptions

2.2 Applicable Laws, Regulations, and standards

3.0 BUILDING CODE COMPLIANCE APPROACH

3.1 Historic Buildings

3.2 Existing Structures

3.3 Applicability to Existing Buildings

3.3.1 Classification of the Project Work

3.3.2 Means of Egress

4.0 USES & OCCUPANCY

4.1 Use and Occupancy

5.0 BUILDING CODE COMPLIANCE OVERVIEW

5.1 Construction Classification and Building Height and Area

5.2 Fire Resistance Ratings

5.2.1 Vertical Openings

5.2.2 Exterior Wall Fire Resistance Ratings

5.2.3 Fire Resistance Rated Enclosures & Separations

5.3 Means of Egress

5.3.1 Overall Configuration

5.3.2 Occupant Load and Egress Capacity

5.3.3 Exit Travel Distance, Common Path of Travel

5.3.4 Doors

5.3.5 Egress Lighting

5.3.6 Exit Signs

5.3.7 Places of Confinement (Lockups)

5.4 Interior Finish

6.0 FIRE PROTECTION SYSTEMS

6.1 Fire Alarm System

6.2 Automatic Sprinkler Systems

6.3 Other Fire protection systems

7.0 ACCESSIBILITY

FIRE PROTECTION & LIFE SAFETY & ACCESSIBILITY CODE COMPLIANCE REPORT GSA Alburg Springs VT, LPOE

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1.0 Introduction

As required by the PBS Core Building Standards Memorandum published on February 24, 2025, this narrative report is a written description of the existing and proposed new fire protection, life safety, and accessibility features and systems in the building located at 300 Alburg Springs Road, Alburg Springs, Vermont.

The site consists of two buildings, both constructed in 1937: The “Main Building”, a rectangular brick, clad, Colonial Revival-style building with a hipped roof canopy attached to the front and a detached 2-bay automobile garage located southwest of the Main Building. The two buildings are listed on the National

Register of Historic Places (NRHP).

The project is a major interior renovation with minor exterior work. The project includes the repair and alteration of the existing buildings including complete interior renovation, updated MEP systems, and exterior improvements.

As part of this renovation project, a complete replacement of the fire alarm system is anticipated. The existing buildings are not equipped with a sprinkler system, and the new work will not include an automatic fire sprinkler system.

2.0 Basis of Design

2.1 BUILDING DESCRIPTIONS

+ Use Group – Business.

+ Square Footage – The total existing facility consists of approximately 2,820 square feet.

+ Building Height – 3 stories

+ Number of Floors Above Grade – 2 Plus Attic

+ Number of Floors Below Grade – 1 Basement (used for MEP purposes)

+ Types of Occupancies Within the Building – The building is primarily used as a Business Occupancy.

However, there are additional building spaces used for reception, kitchen, holding, mechanical, and storage.

+ Type(s) of Construction – Type - VB

+ Hazardous Material Usage and Storage – N/A

+ High Storage Over 12 Ft of Commodities within the Building – N/A

+ Site Access Arrangement for Emergency Response Vehicles – The Alburgh Volunteer Fire Department

(AVFD) has vehicular access to the Building directly off Border Road (Public Way) and Line Road Town

Highway 8 (Public Way)

+ Area of Work – The main office building (Basement, Level 1 and Level 2) and the storage area of the separate garage. Inside the garage there will be a generator. There is a possibility to add a small addition to the main building.

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2.2 APPLICABLE LAWS, REGULATIONS, AND STANDARDS

In accordance with Executive Orders issued since January 20, 2025, and the subsequent cancellations of associated GSA and PBS orders, the current version of The Facilities Standard for Public Buildings Service

(P100) is no longer applicable and is rescinded, unless otherwise permitted by interim guidance or by written occurrence of the PBS Commissioner. Until a process is developed to update the P100, Appendix A: PBS

Interim Core Building Standards (PBS-Interim CBS) of the PBS Core Building Standards Memorandum serves as the list of laws, regulations, and codes for projects under design and construction.

Facilities built on Federal property are exempt from State and local building codes. It is PBS-Interim CBS’ policy to comply with State and local building codes to the maximum extent feasible per 40 USC §3312;

cooperation with State and/or local government officials is required for the consultation, review, and inspection process (PBS-Interim CBS).

Per the scoping language of PBS-Interim CBS, the latest published edition of the provided authorities and references, including any subsequent executive orders, in effect at the time of the project’s solicitation date are required to be used throughout the design and construction of the facility.1

The date of the execution of the Exchange Agreement is October 17, 2023. Accordingly, the project will comply with the following codes, standards, and guides:

+ Public Buildings Service Interim Core Building Standards (PBS-Interim CBS); Issued February 24, 2025

+ Land Port of Entry Design Standard, September 2022 Edition (PBS-Interim CBS §9)

+ Architectural Barriers Act Accessibility Standard (ABAAS) per USC 42 §4152 and 41 CFR §102-76.60, which includes 36 CFR §1191: ABA Chapters 1-10 and Appendices C and D and FMR Part 102-76, Subpart C.

GSA’s National Accessibility Program Standards Policies and Procedures fulfill the Modifications and

Waivers requirements per ABAAS §F103, by describing accessibility expectations and the process for administering waivers/modifications.

+ International Building Code (IBC), 2024 Edition (First Printing August 2023) except that the technical means of egress requirements of NFPA 101, Life Safety Code® must be used in place of the technical egress requirements in the IBC (40 USC §3312)

+ International Existing Building Code (IEBC), 2024 Edition (First Printing August 2023)

+ International Mechanical Code (IMC), 2024 Edition (First Printing June 2023)

+ International Plumbing Code (IPC), 2024 Edition (First Printing June 2023)

+ International Fire Code (IFC), 2024 Edition (First Printing October 2023)

+ National Fire Protection Association (NFPA) Codes:

NFPA 4, Standard for Integrated Fire Protection and Life Safety System Testing, 2024 Edition

(effective date August 10, 2023)

NFPA 70, National Electrical Code®, 2023 Edition (effective date September 1, 2022).

NFPA 72, National Fire Alarm and Signaling Code, 2022 Edition (effective date September 15, 2021)

1 P100 was rescinded and the Core Building Standards was put in place, all other building codes that A/E's follow to design federal buildings remain in place and the version that was in place at the time of award of the design contract shall be followed unless changed by the Contracting Officer through a modification to the design contract (Interim Core Building Standards RFI).

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NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilation Systems, 2024 Edition

(effective date May 13, 2023)

NFPA 101, Life Safety Code®, 2024 Edition (effective date September 14, 2023 - Egress

Requirements only)

NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations, 2022

Edition (effective date April 8, 2021)

3.0 Building Code Compliance Approach

This section contains general scoping for the code compliance approach to the project.

3.1 HISTORIC BUILDINGS

Per PBS-Interim CBS:

The building is required to comply with The National Historic Preservation Act (NHPA) of 1966, as amended by Pub. L. 89-665, 80 Stat. 915. Federal agencies shall strive to rehabilitate historic properties in a manner that preserves their architectural character, in accordance with the Secretary of Interior’s

Standards for the Treatment of Historic Properties (36 CFR §68) and 54 USC §300101.

Furthermore, the building is required to comply with the IBC and NFPA 101 (for egress), along with many other codes and standards. The two buildings are listed in the National Register of Historic Places. It is noted that both the IBC and NFPA 101 contain explicit sections for historic buildings.

In general, historic buildings must comply with requirements for non-historic buildings. Both codes allow deviations and allowances for historic buildings to maintain the historic nature of the building.

At this time, the project is considering compliance with non-historic buildings. Any areas that cannot comply with the requirements for non-historic buildings will be further evaluated.

3.2 EXISTING STRUCTURES

The following excerpts from IBC §102 outline the code’s applicability to existing structures:

+ Existing Structures – The legal occupancy of any structure existing on the date of adoption of the code

(IBC) shall be permitted to continue, without change, except as is specifically covered in IBC or as is deemed necessary by the Building Official for the general safety and welfare of the occupants and the public (IBC §102.6).

+ Laws in Effect – Unless specifically provided otherwise in this code (IBC), and narrow to the provisions of IBC, any existing building or structure shall meet and shall be presumed to meet the provisions of the applicable laws, codes, rules or regulations, bylaws or ordinances in effect at the time such building or structure was constructed or altered and shall be allowed to continue to be occupied pursuant to its use and occupancy, provided that the building or structure shall be maintained by the Owner in accordance with IBC (IBC §102.6.2).

+ Existing Means of Egress, Lighting and Ventilation – Means of egress, lighting, and ventilation in existing buildings, whether or not undergoing repairs, alterations, changes of occupancy, are subject to the provisions of IBC §116. When applicable, the following conditions of (IBC §116) are susceptible to citation from the Building Official and should be corrected in all existing buildings.

Inadequate number of means of egress;

Egress components with insufficient width or so arranged to be inadequate, including signage and lighting;

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Inadequate lighting and ventilation.

Where full compliance is not practical, the Building Official may accept compliance alternatives, engineering, or other evaluations that adequately address the deficiency.

JENSEN HUGHES is not aware of any outstanding Abatement Orders or Notices of Violation issued against the building therefore the existing conditions are assumed to have been acceptable to the Building Official upon their last inspection.

+ Maintenance of Existing Buildings and Structures – All buildings and structures and all parts thereof, both existing and new, and all systems and equipment therein which are regulated by the IBC or IEBC shall be maintained in a safe, operable and sanitary condition. All service equipment, means of egress, devices and safeguards which are required in a building or structure, or which were required by a previous statute in a building or structure, when erected, altered or repaired, shall be maintained in good working order as specified by the International Property Maintenance Code (IBC §101.4.4). The owner shall be responsible for compliance with IBC (IBC §105.1).

JENSEN HUGHES is not aware of any outstanding preventative or corrective maintenance items for life safety systems other than those identified in this report. The working condition of existing life safety systems including automatic sprinkler and standpipe systems, fire alarm systems, means of egress components and fire-rated compartmentalization should be maintained in proper working condition.

3.3 APPLICABILITY TO EXISTING BUILDINGS

The provisions of IBC and IEBC apply to the repair, alteration, change of occupancy, addition and relocation of all existing buildings, regardless of occupancy (IBC §101.2, IEBC §101.2). Such repair, alteration, change of occupancy, addition or relocation of an existing building should comply with one (1) of the following methods not in combination with each other selected by the applicant (IEBC §301.1): Prescriptive

Compliance Method, Work Area Compliance Method, Performance Compliance Method, and Compliance

Alternative Method.

The Work Area Compliance method has been selected for the proposed renovations. All repairs, alterations, additions, changes in occupancy, and relocated buildings should comply with the applicable requirements of

Chapters 6 through 12 of IEBC.

3.3.1 Classification of the Project Work

Based on our understanding of the goals of the proposed project, the project may involve the following work which has been classified by type according to the Work Area Compliance Method of IEBC Chapter 6.

Based on the definition of “work area”, the table below also identifies whether that work item creates a “work area”.

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Table 1: Classification of Work

Description of Work Classification of Work Creation of

Work Area?

Removal and replacement or covering of existing materials, elements, equipment, or fixtures using new materials, elements, equipment, or fixtures that serve the same purpose. (i.e. replacing interior finishes, furniture, equipment, and “refresh” type scope)

Level 1 Alterations

(IEBC §602)

No

Scope of work limited to the removal and installation of mechanical systems, electrical systems, fire protection systems, and abatement of hazardous materials.

Level 2 Alterations

(IEBC §603, §801.3)

No

The addition or elimination of any door / window, the reconfiguration or extension of any system, or the installation of any additional equipment. This assumes that the area where this work is being performed is equal to or less than 50% of the total building area.

Level 2 Alterations

(IEBC §603, §801.3)

Yes

This assumes that the area where this work is being performed is greater than 50% of the total building area.

Level 3 Alterations

(IEBC §604)

Yes

Addition of new holding and interview rooms to the back side of the building and an addition to the east side of the building for entry and a restroom.

Addition

(IEBC §606)

No

Additional notes regarding the application of the Work Area Compliance Method to the project scope include:

+ The resulting Work Area equals 100% of the building area based on approximate area measurements.

Therefore, the project is classified as a Level 3 Alteration.

+ Level 2 is being converted from a Group S-1 (conservatively identified as storage of combustible materials) to a Group B (office space). While the uses within the existing building are being relocated and refinished, the proposed uses and occupancies already exist within the building.

+ All new construction associated with the additions and new structures must comply with new construction requirements.

+ It is our understanding that the building is a listed historic building.

+ The building will not be relocated.

3.3.2 Means of Egress

NFPA 101 is required to be used in lieu of the IBC for the technical requirements for the means of egress.

NFPA 101 contains specific chapters for new construction and existing construction. The chapters for existing construction are created to establish a minimum criterion that existing buildings must provide. NFPA

101 Chapter 43 provides scoping requirements for building rehabilitation, which includes renovations and modifications. Definitions of note (NFPA 101 §43.2.2):

+ Renovation – The replacement in kind, strengthening, or upgrading of building elements, materials, equipment, or fixtures, that does not result in a reconfiguration of the building spaces within.

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+ Modification – The reconfiguration of any space; the addition, relocation, or elimination of any door or window; the addition or elimination of load-bearing elements; the reconfiguration or extension of any system; or the installation of any additional equipment.

+ Reconstruction – The reconfiguration of a space that affects an exit or a corridor shared by more than one occupant space; or the reconfiguration of a space such that the rehabilitation work area is not permitted to be occupied because existing means of egress and fire protection systems, or their equivalent, are not in place or continuously maintained.

In renovations, all new work must comply with the requirements of NFPA 101 applicable to existing buildings

(NFPA 101 §43.4.1.3). The work cannot make the building less conforming with other sections of NFPA 101, or with any previously approved alternative arrangements, than it was before the renovation was undertaken, unless otherwise specified in NFPA 101 §43.4.1.5 (NFPA 101 §43.4.1.4).

In modifications, newly constructed elements, components, and systems shall comply with the requirements of other sections of this Code applicable to new construction (NFPA 101 §43.5.1.3). The modification of an entire building or an entire occupancy within a building is required to be considered as a reconstruction and must comply with the requirements of NFPA 101 §43.6 for the applicable occupancy, unless otherwise specified in NFPA 101 §43.5.2.2.

A reconstruction, as defined in NFPA 101 §43.2.2.1.4, in other than historic buildings, must comply with all of the following:

+ NFPA 101 §43.6

+ NFPA 101 §43.5, except that any stairway replacing an existing stairway are permitted to comply with

7.2.2.2.1.1(3)

+ NFPA 101 §43.4

Where a change of occupancy classification occurs to an occupancy classification of a higher hazard classification category (i.e., a lower hazard category number), as addressed by NFPA 101 Table 43.7.3, the building must comply with the requirements of the occupancy chapters applicable to new construction for the occupancy created by the change (NFPA 101 §43.7.2.3). Change from a Group S-1 (ordinary hazard) storage to Group B (business) is to the same hazard classification category.

4.0 Uses & Occupancy

This section outlines the specific methodology for code compliance related to various existing or proposed features of fire protection, means of egress, and accessibility.

4.1 USE AND OCCUPANCY

The existing occupancy of the building appears to be non-separated mixed use (per IBC §508.3) consisting of the uses shown in the table below.

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Table 2: Occupancy Classification

Occupancy Classification Uses

Group B, Business Offices, Meeting rooms for counselling <750 sq.ft. / 50 people

Group S-1, Storage Storage of Combustible Materials

Group S-2, Storage Storage of Non-Combustible Materials, and

MEP spaces

There could be ancillary storage of combustible materials. Such spaces are considered accessory to the main occupancy, Group B, and are classified as part of that occupancy (IBC §311.1.1).

There will be a location to secure people under restraint. This space will hold five or less people, as such, it is not considered a Group I-3 per IBC §308.4. Instead, it is classified as a Group B occupancy. The space will not hold people for more than 24 hours. The space will be designed in accordance with NFPA 101 for lockups.

5.0 Building Code Compliance Overview

The following sections provide a high-level overview of the significant building code compliance of the building. This is focused on fire protection and life safety requirements.

5.1 CONSTRUCTION CLASSIFICATION AND BUILDING HEIGHT AND AREA

The construction type of a building is regulated by IBC and NFPA 101 based upon its occupancy classification, building height, and area with consideration given to the buildings open exterior perimeter and automatic fire suppression systems (or lack thereof in this case) (IBC §503, §504, §506). Provided documentation of the existing structure suggests that the structure most closely resembles Type VB construction consisting of unprotected wood construction. The existing building does not have an automatic sprinkler system. Given that the building consists of non-separated occupancies including Group B, the height and area limitations of the occupancy with the most restrictive limits (Group B) apply to the overall building. Existing buildings undergoing a repair, Level 1 Alteration, Level 2 Alteration, or Level 3 Alteration, are not required to comply with the current IBC requirements regarding allowable building height and area and can remain as-is. However, the scope of work includes an addition, which requires the overall building’s height/area would need to be analyzed (IEBC §1102.2).

The existing building has a footprint of approximately 820 square feet. Multi-story Group B occupancy buildings of Type VB construction without a fire sprinkler system are permitted to have a maximum building footprint of 9,000 sq.ft (IBC §506.2, §508). Even without utilizing the frontage increase allowance, the building area will comply with new construction requirement limitations. The existing building is two stories above grade with an unoccupied attic space. Group B occupancy buildings of Type VB construction without a fire sprinkler system are permitted to have up to 2 stories above grade and be up to 40 feet in height.2

Two or more buildings on the same lot can be regulated as separate buildings or considered as portions of one building where the building height, number of stories of each building and the aggregate building area of

2 Group S-2 is allowed to be slightly larger buildings. Group S-1 occupancies can be up to 9,000 square feet and one story above grade plane.

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All Rights Reserved.T0123 the buildings are within the limitations specified in IBC §504 and §506 (IBC §503.1.2). The main building and garage are considered as a single building for the purposes of height and area.

The existing buildings are permitted to remain as is from a maximum building height and area standpoint (IBC §504.3, §504.4) as it complies with the requirements for new construction as an addition to the building is proposed.

5.2 FIRE RESISTANCE RATINGS

Existing structural members comply with the fire resistance rating requirements for the construction type of the building (IBC §601). The following table summarizes the Fire Resistance Rating (FRR) requirement for

Type VB construction (IBC Table 601).

Table 3: Structural Fire Resistance Ratings

Building Element Type VB FRR (Hours)

Primary Structural Frame 01

Exterior Bearing Walls 01,2

Exterior Non-Bearing Walls and Partitions (Refer to Section 5.2.2)

Interior Bearing Walls 0

Interior Non-Bearing Walls and Partitions 01,3

Floor Construction and Secondary Members 0

Roof Construction and Secondary Members 0

Note 1: Not less than the rating required for supported elements (IBC §704.10).

Note 2: Not less than the fire resistance rating required based on the fire separation distance.

Note 3: Not less than the fire resistance rating required by other areas of the code.

These fire resistance ratings of the existing building (or lack thereof) are proposed to remain as is and must be repaired / replaced where impacted by the proposed renovation.

5.2.1 Vertical Openings

The Basement, First Floor, and Second Floor are connected via a multi-story vertical opening. The existing condition has the stair to the basement. The stair is then separated from Level 1 by doors. The rating of the doors or the enclosure is unknown. The proposed condition has similar conditions with the stair to the basement.

Vertical openings are required to comply with the IBC, and IEBC. Where a change of occupancy classification is made to a higher-hazard category as shown in Table 1011.5, interior stairways are required to be enclosed as required by the International Building Code (IEBC §1011.8.2). The space is being converted from a Group S-1 to Group B, which is the same hazard category in IEBC Table 1011.5. As such, enclosure of the shaft is not necessary.

Per IEBC §802.2.1, all existing interior vertical openings connecting two or more floors are to be enclosed with approved assemblies having a fire-resistance rating of not less than 1 hour with approved opening protectives; however, IEBC §802.2.1 Exception 5.1 permits unprotected vertical openings connecting not more than three stories where the building does not exceed 3,000 square feet per floor. The vertical opening is permitted to remain as-is by the IEBC.

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5.2.2 Exterior Wall Fire Resistance Ratings

Existing exterior wall assemblies are permitted to remain without updates because a change of use is not anticipated for this project (IBC §1012.6). New or altered exterior walls shall comply with the below requirements.

Exterior wall rating requirements, except as otherwise required by IBC Table 601, and opening percentages are based on the fire separation distance for each wall segment (IBC Table 602, Table 705.8). The fire separation distance is measured perpendicular to the exterior wall to the centerline of a public street, an interior lot line, or an imaginary lot line between two buildings on the same lot (IBC §202.1). The following table outlines the minimum required exterior wall ratings and opening limitations per story.

Table 4: Exterior Wall Fire Ratings and Opening Limitations

Occupancy Fire Separation

0 to <3 3 to <5 5 to <10 10 +1

Fire Ratings (Group B) 1 hour 1 hour 1 hour 0 hour

Fire Ratings (Group S-1) 2 hours 2 hours 1 hour 0 hour

Max Area of Unprotected

Openings

Not

Permitted

Not

Permitted 10% 15%

Max Area of Protected

Openings

Not

Permitted 15% 25% 45%

Note 1: Buildings whose exterior bearing walls, exterior nonbearing walls, and exterior primary structural are not required to be fire-resistance rated are permitted to have unlimited unprotected openings (IBC §705.9.1 Exception 2).

5.2.3 Fire Resistance Rated Enclosures & Separations

Where they exist, the rooms and spaces listed in the table below are required to be enclosed / separated with fire-resistance rated (FRR) fire barriers (FB), smoke barriers (SB), smoke partitions (SP), fire partitions

(FP), or “construction capable of resisting the passage of smoke” (smoke-tight). These are the current requirements for new construction. Requirements for existing rooms and spaces should be specifically reviewed.

Where there is an accessible concealed floor, floor-ceiling or attic space, fire walls, fire barriers, fire partitions, smoke barriers and smoke partitions or any other wall required to have protected openings or penetrations must be effectively and permanently identified with signs or stenciling in the concealed space according to IBC §703.5.

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Table 5: Fire Resistance Rated Enclosures & Separations

Room / Space or Occupancy Required Enclosure

Shafts connecting less than 4 stories (IBC §712.1.1) 1-hour FB1

Violator Area to public waiting/ queuing areas (LPOE 16.2.4 D) 1-Hour FB

Refrigerant machinery rooms (IBC Table 509) 1-Hour FB

Exit access corridors – Groups B, S 0-hour2

Electrical Room containing a Transformer or Transformer Vault (NFPA 70):

• Transformer < 112 ½ kV

• Transformer > 112 ½ kV3

Non-combustible

1-hour FB

Note 1: No less than the floor penetrated.

Note 2: Within existing spaces, or within a space occupied by a single tenant.

Note 3: Except transformers with Class 155 or higher insulation systems and completely enclosed except for ventilation openings

(NFPA 70 §450.21(B) exception no. 2.)

Fire barriers must be supported by the same fire-resistance rating which they are provided (IBC §707.5.1).

Supporting construction for 1-hour fire barriers required by Table 509.1 in buildings of Type VB construction is not required to be fire resistance rated unless required by other sections of the IBC (IBC §707.5.1

Exception 2).

Fire barriers, shafts, and most fire-rated assemblies are required to be listed in accordance with ASTM E119 or UL 263 (IBC §703.2.2). IBC §703.2.2 allows fire-resistance ratings to be determined by:

+ Fire-resistance designs documented in approved sources.

+ Prescriptive designs of fire-resistance-rated building elements, components or assemblies as prescribed in §721.

+ Calculations in accordance with §722.

+ Engineering analysis based on a comparison of building element, component or assemblies designs having fire-resistance ratings as determined by the test procedures set forth in ASTM E119 or UL 263.

+ Fire-resistance designs certified by an approved agency.

+ By an alternative protective method in accordance with §104.2.3 (per IBC §703.2.3).

Duct systems constructed of approved materials in accordance with the International Mechanical Code that penetrate non-fire-resistance-rated floor assemblies shall be protected by any of the following methods (IBC

§717.6.3):

+ A shaft enclosure in accordance with IBC §713.

+ The duct connects not more than two stories, and the annular space around the penetrating duct is protected with an approved noncombustible material that resists the free passage of flame and the products of combustion.

+ In floor assemblies composed of noncombustible materials, a shaft shall not be required where the duct connects not more than three stories, the annular space around the penetrating duct is protected with an approved noncombustible material that resists the free passage of flame and the products of combustion and a fire damper is installed at each floor line.

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In one location, duct wrap is used in lieu of a shaft. The duct wrap does not comply with ASTM E119. As such, an alternative in accordance with IBC §104.2.3 has been requested. This has been accepted by GSA.

Fire and smoke dampers installed in air distribution systems must be installed in accordance with the requirements of NFPA 90A (PBC-Interim CBS).

5.3 MEANS OF EGRESS

NFPA 101 contains requirements for new, and existing elements. All new elements should comply with requirements for new construction. The requirements for new construction are generally referenced. The project will comply with the following egress requirements.

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Table 6: NFPA 101 General Egress Requirements

Exit Element Code Requirement – NFPA 101

Number of Exits Two Exits: Required from every floor and room with more than 50 occupants.

Three Exits: Occupant Load between 500 to 1000

Egress Capacity

Width Factors

Stairways 44 inches or less in width: 0.3 inches per person

Level Components and Ramps: 0.2 inches per person

Minimum Exit

Width Required

Corridor:

Business and assembly:

44 inches for corridors serving ≥ 50 occupants, 36 inches for corridors serving < 50 occupants.

Other occupancies: 36 inches

Stairs:1

Cumulative Load < 50 occupants: 36 inches (Section 7.2.2.2.1.2)1

Cumulative Load < 2000 occupants: 44 inches (Section 7.2.2.2.1.2)

Doors:

Not less than 36 inches of door leaf width and not less than 32 inches of clear width.

Means of Egress

Door Separation

The minimum separation distance between 2 exits or exit access doors is not less than one-half the maximum overall diagonal of the area to be served. The separation is to be measured between the nearest edge of the exits, exit accesses, or exit discharges (Sections 7.5.1.3.2).

Existing Stair

Details

Maximum Height of Risers: 8 inches (Table 7.2.2.2.1.1(b))

Minimum Tread Depth: 9 inches (Table 7.2.2.2.1.1(b))

Minimum Headroom: 6 feet 8 inches (Table 7.2.2.2.1.1(b))

Stair

Dimensional

Variation

Variation between adjacent risers or treads: 3/16 inch (Section 7.2.2.3.6.1)

Variation between the largest and smallest riser to tread depth: 3/8 inch (Section

7.2.2.3.6.2).

Winder Stairs

In existing business occupancies - existing winders are permitted to be continued in use, provided that they have a tread depth of not less than 6 inches and a tread depth of not less than 9 inches at a point 12 inches from the narrowest edge

(Section 7.2.2.2.4.3).

Door Swing

Door swing in the direction of egress travel for doors serving ≥ 50 occupants, or in an exit enclosure, or serving a high hazard contents area.

Doors opening onto path of egress or landings do not reduce the required width to less than one-half at any time and do not project more than 7 inches into the required width when fully open.

Note 1: Minimum width clear of all obstructions, except projections not more than 4.5 inches at or below handrail height on each side

Note 2: Existing stairway widths narrower than those required for non-historic buildings are permitted provided that at least one of the following criteria are met (NFPA 101 §43.10.4.3): 1) In the opinion of the authority having jurisdiction, sufficient width and height exists for a person to pass through the opening or traverse the exit, and the capacity of the egress system is adequate for the occupant load;

2) Other operational controls to limit the number of occupants are approved by the authority having jurisdiction.

5.3.1 Overall Configuration

The building was previously served by two stairs adjacent to each other, that discharged to the interior of the building. These stairs were in sections, with one set going from the Basement to Level 1. The other section

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All Rights Reserved.T0123 going from Level 2 to Level 1. The proposed configuration is to remove one of the stairs and have a single interior discharge stair from the basement and Level 2. The stairs serve as the sole means of egress from the respective floor (the basement also has use of a bulkhead). Level 1 is provided with doors directly to the exterior.

In existing business occupancies, means of egress must comply with all of the following, except as otherwise permitted by NFPA 101 §39.2.4.2 through §39.2.4.6 (NFPA 101 §39.2.4.1):

+ The number of means of egress must be in accordance with 7.4.1.1 and 7.4.1.3 through 7.4.1.6.

+ Not less than two separate exits must be provided on every story.

+ Not less than two separate exits must be accessible from every part of every story.

A single exit is permitted from a room or story where the total occupant load does not exceed 100 and the following criteria are met (NFPA 101 §39.2.4.3):

+ The exit shall discharge directly to the outside at the level of exit discharge for the building.

+ The total distance of travel from any point, including travel within the exit, shall not exceed 100 feet. The total distance of travel must be on the same story, or, if traversing of stairs is necessary, such stairs cannot exceed 15 ft and both of the following also shall apply:

Interior stairs shall be provided with complete enclosures to separate them from any other part of the building, with no door openings therein.

A single outside stair in accordance with 7.2.2 shall be permitted to serve all stories permitted within the 15 ft (4570 mm) vertical travel limitation.

Similarly, in ordinary-hazard storage occupancies, a single means of egress is permitted from any story or section, provided that the exit can be reached within the distance permitted as a common path of travel

(NFPA 101 §42.24.1 Item 2).

Stairways are permitted to be unenclosed in a historic building where such stairways serve only one adjacent floor (NFPA 101 §43.10.4.7.1). The approach to egress is to comply with NFPA 101 §39.2.4.3 /

NFPA 101 §42.24.1 Item 2 but use NFPA 101 §43.10.4.7.1 to omit the enclosure requirements. It is noted that the open exit stair is not at the exterior of the building.

The approach has been reviewed and accepted by GSA. GSA has requested area smoke detection throughout the Main Building to help ensure fast detection for a fire on Level 1.3

5.3.2 Occupant Load and Egress Capacity

The means of egress is sized to accommodate the anticipated occupant load, calculated in accordance with

NFPA 101 Table 7.3.1.2 and Table 7.1. The calculated occupant load for the building is based on all areas being occupied simultaneously. Table 7 lists the occupant load factors for this project.

3 As stated via email from Blake Cornachini on October 1, 2024.

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Table 7: Occupant Load Factors

Use of Space Occupant Load Factor

(ft2 / person)

Assembly, less concentrated use, without fixed seating

15 net

Collaboration room/space (<450 ft2)1 30 gross

Break room and/or Pantry area (<450 ft2) 30 gross

Kitchens 100 gross

Business use (where such spaces are not covered by other portions of this table)

150 gross

Concentrated business use2 50 gross

Storage (other than storage occupancies) 500 gross

Note 1: This also applies to quiet rooms, focus rooms, huddle rooms, team rooms, and similar use spaces.

Note 2: This occupant load factor is not anticipated to be used for this project. Examples of concentrated business use areas are call centers, trading floors, and data processing centers (IBC §1004.8).

5.3.3 Exit Travel Distance, Common Path of Travel

NFPA 101 identifies the maximum exit access travel distance, maximum common path of travel, and maximum dead-end corridor length for the occupied areas of the building, based upon occupancy classification. The project will comply with the travel distance requirements shown in Table 8 below.

Table 8: Travel Distance Requirements1

Occupancy Code Requirement

Business

Travel Distance 200 feet (§38.2.6.2)

Maximum Dead-End Corridor 20 feet (§38.2.5.3.2)

Common Path of Travel 100 feet (§38.2.5.2.2)

Storage (Ordinary Hazard)

Travel Distance 200 feet (§42.2.6)

Maximum Dead-End Corridor 50 feet (§42.2.5)

Common Path of Travel 50 feet (§42.2.5)

Note 1: Based on the building not being protected throughout with an automatic sprinkler system.

5.3.4 Doors

All door assemblies installed in the means of egress will meet the requirements of the NFPA 101 Section

7.2.1 (PBS-Interim CBS).

Exit devices for delayed egress should comply with NFPA 101 §7.2.1.6.1. Approved, delayed-egress electrical locking systems are permitted to be installed on door assemblies serving low- and ordinary-hazard contents in buildings protected throughout by an approved, supervised automatic fire detection system in accordance with Section 9.6 or an approved, supervised automatic sprinkler system in accordance with

NFPA 101 §9.7, and where permitted in Chapters 11 through 43, provided that all of the following criteria are met:

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+ The delay of the delayed-egress electrical locking system shall deactivate allowing unobstructed egress upon actuation of one of the following:

Approved, supervised automatic sprinkler system in accordance with NFPA 101 §9.7.

Not more than one heat detector of an approved, supervised automatic fire detection system in accordance with NFPA 101 §9.6.

Not more than two smoke detectors of an approved, supervised automatic fire detection system in accordance with NFPA 101 §9.6.

+ The delay of the delayed-egress electrical locking system shall deactivate allowing unobstructed egress upon loss of power controlling the lock or locking mechanism.

+ An irreversible process shall release the electrical lock in the direction of egress within 15 seconds, or

30 seconds where approved by the authority having jurisdiction, upon application of a force to the release device required in 7.2.1.5.3 under all of the following conditions:

The force shall not be required to exceed 15 lbf (67 N).

The force shall not be required to be continuously applied for more than 3 seconds.

The initiation of the release process shall activate an audible signal in the vicinity of the door opening.

Once the electrical lock has been released by the application of force to the releasing device, rearming the delay electronics shall be by manual means only.

+ A readily visible, durable sign that conforms to the visual characters requirements of ICC A117.1, Accessible and Usable Buildings and Facilities, shall be located on the door leaf adjacent to the release device in the direction of egress, and shall read as follows:

PUSH UNTIL ALARM SOUNDS, DOOR CAN BE OPENED IN 15 SECONDS, for doors that swing in the direction of egress travel.

PULL UNTIL ALARM SOUNDS, DOOR CAN BE OPENED IN 15 SECONDS, for doors that swing against the direction of egress travel.

+ The egress side of doors equipped with delayed-egress electrical locking systems shall be provided with emergency lighting in accordance with NFPA 101 §7.9.

+ Door electromechanical or electromagnetic locking hardware for new installations shall be listed in accordance with UL 294, Access Control System Units, or UL 1034, Burglary-Resistant Electric Locking

Mechanisms.

5.3.5 Egress Lighting

Illumination of means of egress will be provided in accordance with the requirements in NFPA 101 Section

7.8 and will be continuous during the time that the conditions of the occupancy require that the means of egress be available.

5.3.6 Exit Signs

Exit signs will meet the requirements in NFPA 101 Section 7.10 and be energy efficient and environmentally friendly products (e.g., light emitting diodes (LED type), photoluminescent type.

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5.3.7 Places of Confinement (Lockups)

The project will have places of confinement, which are considered Group B occupancies by the IBC. Such rooms/areas are required to comply with the requirements of NFPA 101 for lockups. Since the aggregate number of detainees is not more than 50 and no individual is detained for more than 24 hours (NFPA 101

§22.4.6.1.3). The lockups are permitted to comply with the egress requirements of the predominant occupancy, provided that the criteria in one of the two options below is met (NFPA 101 §22.4.6.1.3).

+ NFPA 101 §22.4.6.1.4:

Doors and other physical restraints to free egress by detainees can be readily released by staff within 2 minutes of the onset of a fire or similar emergency and

Staff is in sufficient proximity so as to be able to affect the 2-minute release whenever detainees occupy the lockup.

Staff is authorized, trained, and practiced to affect the release required above.

Where the release required above is affected by means of remote release, detainees are not to be restrained from evacuating without the assistance of others.

+ NFPA 101 §22.4.6.2 Alternate Provision:

Requirements applicable to the predominate occupancy in which the lockup is placed should be met.

Where security operations necessitate the locking of required means of egress, detention-grade hardware meeting the requirements of ASTM F 1577 should be provided on swinging doors within the required means of egress and sliding doors within the required means of egress shall be designed and engineered for detention and correctional use and lock cylinders should meet the cylinder test requirements of ASTM F 1577.

The lockup should be provided with a complete smoke detection system in accordance with

NFPA 101 §9.6.2.9.

Where the requirements of the predominate occupancy do not mandate a fire alarm system, the lockup should be provided with a fire alarm system meeting the criteria of NFPA 101

§22.4.5.2.4.

5.4 INTERIOR FINISH

The interior wall and ceiling finishes for the building are classified as shown in the Table 9 below

(classifications per ASTM E84) based on the occupancy classification and the building not being protected with an automatic sprinkler system (IBC Table §803.11).

Requirements for rooms and enclosed spaces are based on spaces being enclosed by partitions. Where a fire-resistance rating is required for structural elements, the enclosing partitions must extend from the floor to the ceiling. Partitions that do not comply are considered as enclosing the rooms and spaces on both sides, which are to be considered as one room or space. In determining the applicable requirements for rooms and enclosed spaces, the specific occupancy thereof is the governing factor regardless of the group classification of the building or structure (IBC §803.1.2, Table 803.13).

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Table 9: Interior Finish Requirements

Occupancy Classification

Exit Enclosures & Exit Passageways

Exit Access Corridors & other

Exit ways

Rooms & Enclosed Spaces

B Class A Class A or B Class A, B, or C

S Class A or B Class A or B Class A, B, or C

ASTM E84, Test Methods for Surface Burning Characteristics of Building Materials classifies the burning characteristics of building materials using flame spread and smoke development properties. Performance characteristics and classifications are developed in accordance with Table 10 below (IBC §803.1.2).

Table 10: Interior Finish Requirements

Interior Finish Classification Flame Spread Rating Smoke Developed Rating

Class A 0-25 0-450

Class B 26-75 0-450

Class C 76-200 0-450

Decorative materials and trim will comply with the applicable requirements in IBC Section 806.

Combustible materials installed on or embedded in floors will comply with the applicable interior finish requirements in IBC Section 804.

6.0 Fire Protection Systems

The following section provides an overview of the proposed fire protection systems at the building.

6.1 FIRE ALARM SYSTEM

The Building will have a fire alarm system provided in accordance with the IBC, NFPA 72 and the PBS-

Interim CBS. It is proposed to provide occupant notification via horns and strobes. The fire alarm system will not be integrated with other building systems (e.g., building automation, energy management, security, etc.);

it will be a stand-alone and self-contained and will be able to function independently of other building systems.

The primary method of fire alarm system activation will be via manual fire alarm boxes and spot-type smoke detection. Smoke detection will be provided throughout unless ambient conditions necessitate the use of heat detection. Manual fire alarm boxes and notification appliances will be provided throughout the main building, garage, and within the inspection booth.

The FACU will automatically transmit alarm, supervisory and trouble conditions to a UL listed supervising station via two different communication paths (currently proposed to be a combination of cellular and internet protocol via a GSA approved communicator).

The fire alarm system will be provided with integral backup batteries sized for a minimum of 24 hours of standby operation followed by 5 minutes of alarm operation. 20% of the spare capacity will be included for circuits, power supplies, and batteries.

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The new signaling line circuits (SLC) and notification appliance circuits (NAC) will be designated as NFPA

72 Class B.

6.2 AUTOMATIC SPRINKLER SYSTEMS

The existing building is on well water, therefore, in order to provide sprinkler protection throughout, a dedicated onsite fire water storage tank with a pump would be required, which would be cost prohibitive. As such It has been determined by the GSA that neither an automatic sprinkler system nor a standpipe system will be provided at the building.

6.3 OTHER FIRE PROTECTION SYSTEMS

The following is a summary of other fire protection systems (or lack-there-of):

+ Mass Notification System – The proposed fire alarm system will feature tone-based notification. As such, mass notification is not planned for the building.

+ Emergency Responder Communications Enhancement System – Such systems must be provided where there is insufficient radio coverage within an existing building in accordance with IFC §1103.2. It is understood that sufficient radio coverage is provided, and emergency responder communication enhancement is not included in the building.

+ Gas Detection – Gas detection may be required based on the equipment provided (i.e. CO detection at fuel fired boilers or refrigerants). No gas detection is included for the building.

+ Kitchen Hood Suppression – A Type I or Type II hood with special suppression may be required based on the type of kitchen equipment provided. No Type I or Type II hood is anticipated. No special suppression is included in the project.

7.0 Accessibility

The new work of the Alburg Springs, VT LPOE buildings will comply with the most restrictive requirements of

Architectural Barriers Act Accessibilities Standard (ABAAS), which includes 36 CFR §1191: ABA Chapters

1-10 and Appendices C and D, or Chapter 11 of the IBC and ICC A117.1. At the Office of Field Operation’s

(OFO’s) direction, accessibility requirements for some spaces may be waived based on access limited to able bodied CBP officers. Accessibility should be provided except where the requirements conflict with the security or mission critical functions of CBP controlled spaces (LPOE §1.6.12).

All public entrances provided in accordance with ABAAS F206.4.1 must have at least one entrance door complying with ABAAS §F404.

In existing buildings, at least one accessible route must be provided within the site from accessible parking spaces and accessible passenger loading zones; public streets and sidewalks; and public transportation stops to an accessible entrance serving the addition. If the only accessible entrances serving the addition are provided in the existing building or facility, the accessible route must connect at least one existing entrance to all accessible spaces and elements within the addition (ABAAS §F202.2.1).