SEM_Survey_Report_for_Frances_Perkings_Building_(DC1166ZZ).pdf

FACILITY AND FIRE SAFETY SURVEY

OF THE

FRANCES PERKINS BUILDING

(DC0116ZZ)

200 CONSTITUTION AVENUE, NW

WASHINGTON, DC

Prepared by:

6755 Business Parkway, Suite 405 Elkridge, MD 21075

Order No. GS-P-11-12-DC-0105 Inspection Experts Job No. 5307-004

NCR Historic Building: No Lease Expires: Unknown

Survey Performed By: Skanda Abeyesekere, MS, CIH, CSP, Brian Rhodes P.E., & Christine Sauer P.E.

FSES ANALYSIS RESULTS

Provided Required Equivalency Fire Control 14.5 7.5 Yes Egress 7.5 5.0 Yes General Fire Safety 16.0 6.0 Yes

NEW FINDINGS BY Risk Assessment Code LEVEL

RAC 1 0

RAC 2 0

RAC 3 7

RAC 4 6

RAC 5 6

Facility and Fire Safety Survey France Perkins Building (DC0116ZZ)

200 Constitution Avenue NW, Washington, DC ii

Table of Contents

1.0 EXECUTIVE SUMMARY

2.0 INTRODUCTION

3.0 SURVEY METHODOLOGY

3.1 Opening Conference

3.2 Applicable Standards

3.3 Inspection Procedures

3.4 Sampling of Drinking Water Sources

3.5 Description of Facilities

3.6 Assignment of Risk Assessment Codes (RAC)

4.0 RESULTS

4.1 Findings - Facility Safety and Health

4.1.1 Walking/Working Surfaces

4.1.2 Electrical Systems

4.1.3 Machine Guarding

4.1.4 Emergency First Aid Equipment

4.1.5 Material Handling and Storage

4.1.6 Noise

4.1.7 Illumination

4.2 Findings - Fire Safety Survey

4.2.1 Means of Egress

4.2.2 Sprinkler and Standpipe System

4.2.3 Fire Separations

4.2.4 Fire Extinguishers

4.2.5 Emergency Lighting and Power

4.2.6 Exit Signs

4.2.7 Alarm System

4.2.8 Documentation of Testing

4.2.9 Storage of Flammable Material

4.2.10 Fire Safety Summary

4.3 Findings - Environmental Management

4.3.1 Air Pollution Control

4.3.2 Asbestos Management

4.3.3 Water Pollution Control

4.3.4 Lead in Drinking Water

4.3.5 Nonhazardous Waste Management

4.3.6 Hazardous Waste Management

4.3.7 Underground Storage Tanks

4.3.8 PCB Management

4.3.9 Pesticide Control

4.3.10 Special Occupancies

4.3.11 Environmental Management Summary

4.4 Findings - Indoor Air Quality

4.4.1 Ventilation

4.4.2 Complaints

4.4.3 Potential Contamination Source

4.4.4 Maintenance

4.4.5 Measurements, Instrumentation and Calibration

France Perkins Building (DC0116ZZ) iii

APPENDIX A: RAC 1 THROUGH 4 FINDING

ABATEMENT REPORT FINDINGS AND RECOMMENDATIONS

Fire Protection Safety Environmental Management Indoor Air Quality

APPENDIX B: MINOR FINDINGS REPORT

APPENDIX C: LEAD-IN-WATER LABORATORY ANALYTCIAL RESULTS

APPENDIX D: SKETCH OF WATER SAMPLING LOCATIONS

APPENDIX E: BUILDING PROFILE

BUILDING PROFILE: GENERAL BUILDING INFORMATION

FIRE PROTECTION INFORMATION

GENERAL SAFETY AND HEALTH DOCUMENTATION

DETAILS OF SPECIAL OCCUPANCIES:

ENVIRONMENTAL MANAGEMENT

INDOOR AIR QUALITY

APPENDIX F: FSES ANALYSIS

FIRE SAFETY EVALUATION SYSTEM

APPENDIX G: SURVEYOR CERTIFICATIONS

Frances Perkins Building (DC0116ZZ)

1.0 EXECUTIVE SUMMARY

The Frances Perkins Building, located at 200 Constitution Avenue, NW in Washington, DC generally provides a working environment that is consistent with GSA policy regarding fire protection risks exposing Federal employees and does satisfy the requirements of the Federal Fire Safety Act. The facility was inspected on March 15, 2013, by Inspection Experts, Inc. and Hughes Associates, Inc.

The Frances Perking Building is a six (6)-story building with one (1) occupied below grade level and four (4) below grade parking levels. The building is primarily used for office space with building support spaces located on the Service level, and below grade parking.

There are six (6) fire safety findings in the IRIS database that remain open. There were two (2) new fire safety findings with a RAC of 3, two (2) new RAC 4 findings and five (5) new RAC 5 findings identified during this survey. The level of fire safety was shown to be equivalent to the life safety requirements prescribed by NFPA 101, Life Safety Code for the business occupancy.

There was one (1) facility safety finding in the IRIS database that remains open. There were four

(4) new facility safety findings with a RAC of 3, three (3) new findings with an RAC of 4 and one

(1) RAC 5 minor finding identified during the survey.

There were no environmental findings in the IRIS database that remain open. However, there was one (1) new environmental finding with a RAC of 3 and one (1) new RAC 4 finding identified during the survey.

Fire protection, facility safety and health, environmental management, and indoor air quality findings were identified and are addressed in the body of the report as well as in Appendix A and Appendix B.

2.0 INTRODUCTION

Under Contract Number GS-11P-11-YA-D-0019IEI with the GSA Safety, Environmental and Fire Protection Branch (SEFB), Inspection Experts Incorporated (IEI), was tasked to perform Safety, Environment and Fire Protection Branch surveys, hereafter referred to as a “SEM survey” of federally occupied buildings in the National Capital Region (NCR).

This report details the results of the SEM Survey of the GSA-owned Frances Perkins Building, (DC0116ZZ) located at 200 Constitution Avenue NW, Washington, DC that was conducted as Item Number 5307-004 of Task Order Number GS-P-11-12-DC-0105. The SEM survey was conducted on March 15, 2013, by Safety Professional Mr. Skanda Abeyesekere, MS, CIH, CSP, of IEI (Safety and Environmental), and by Fire Protection Engineers Mr. Brian Rhodes, P.E., and Ms.

Christine Sauer, P.E., of Hughes Associates, Inc. (Fire and Life Protection).

OPEN FINDINGS SUMMARY:

There were nine (9) Fire and Life Safety findings and one (1) facility safety finding provided in the IRIS database for this building. Seven (7) of these findings remain open.

STATUS OF OPEN FINDINGS

Finding Number Description Current Status

The fire rated door for the fire control room is broken.

And, there is an open wall penetration between the fire control room and a mechanical room. Both allow the fire control room to be exposed by fire and smoke conditions from adjacent occupancies.

Open

Due to renovations, the fitness center office and the men’s locker room are not fitted with fire sprinkler heads.

Open

No current documentation was provided concerning the annual testing of the building fire pump. The last tag is dated 2001.

Closed

There are coffee pots, toasters, microwaves, refrigerators and other heat producing appliances located in office spaces and not in designated pantry/lounge locations. These devices can cause preventable fires.

Open

200 Constitution Avenue NW, Washington, DC

STATUS OF OPEN FINDINGS

Finding Number Description Current Status

There is no smoke detector located over the fire alarm control panel. A fire or smoke event at or near the panel could damage the panel and prevent it from providing building-wide alarm notification.

Open

There is open plan systems furniture that has corridors and aisles of less than 36 inches in width in Suite N5623.

Occupants could be delayed negotiating through these narrow aisles during an emergency.

Closed

There are several confined spaces identified that are not posted as to the potential hazard. Open

Several Fire Protection Features For The Building's Elevators Are Inadequate Or Non-existing. Closed

9 The building does not have a voice fire alarm system. Open

The building has recalled O-ring sprinklers on the 2nd floor. Open

Findings with a RAC of 1, 2, 3 or 4 are recorded in Appendix A. Findings with a RAC of 5 are recorded as Minor Findings and are included in Appendix B. Lead in Water, Laboratory Analytical Results and Chain of Custody Forms are included in Appendix C. Diagrams of Water Sampling Locations are included in Appendix D. The building profile is included in Appendix E.

The FSES analysis for the building is included in Appendix F, and the Surveyor Certifications are included in Appendix G.

3.0 SURVEY METHODOLOGY

3.1 Opening Conference

The SEM survey was coordinated with Frances Perkins Building Manager, Mr. Paul Flick. IEI and Hughes Associates survey representatives arrived on site at the Frances Perking Building on March 15, 2013, and held opening conferences with Mr. Flick and Maintenance Engineer Mr.

Phillip Jones. During each opening conference, IEI and Hughes Associates representatives reviewed the purpose of the visit and the procedures to be used during the conduct of the survey effort. Mr. Jones accompanied IEI through the mechanical spaces and also served as the escort through the federally occupied areas. For the fire protection survey, Mr. Doug Harper (Facilities Engineer) accompanied the Hughes Associates engineers.

3.2 Applicable Standards

During the conduct of the inspection, the following standards and guidelines were used to evaluate the fire protection, facility safety and health, environmental management, and indoor air quality conditions at the aforementioned facility.

National Fire Protection Association (NFPA) Codes (latest editions).

Code of Federal Regulations, 29 CFR 1910 - General Industry Standard.

International Building Code IBC (2012).

PBS-P100 Facilities Standards for the Public Building Service- Chapter 7- “Fire Protection

Engineering.”

Code of Federal Regulations, 49 CFR – Environmental Regulations.

U.S Environmental Protection Agency (US EPA) National Primary Drinking Water

Regulations (NPDWR).

Leadership in Energy and Environmental Design (LEED) guidance for new construction and major renovation (Version 2.2, 2006).

ANSI/American Society for Heating Refrigeration and Air Conditioning (ASHRAE)

Standard 62.1 – 2010, Ventilation for Acceptable Indoor Air Quality.

3.3 Inspection Procedures

The actual walk-through surveys consisted of observing the condition of the facility, inspecting the condition of equipment, the storage of materials, and any operations in progress that may affect the physical facility or GSA owned or leased equipment, plus the layout of the equipment/ materials in the facilities as they relate to fire protection, facility safety and health, environmental management, and indoor air quality.

In addition, a review of the building's fire protection features, e.g., fire detection/ alarm systems, fire suppression systems (both fixed and portable), fire divisions and doors, emergency lighting and exit signs, and means of egress was conducted. Where potential hazards were identified, these were brought to the attention of the appropriate facility personnel and discussions of possible remedies were held. Photography was limited to the working areas.

3.4 Sampling of Drinking Water Sources

IEI collected potable water samples from 33 drinking water sources located throughout the building. First and second draw samples were collected from the cold water lines of select drinking water fountains, and kitchenette sinks. Each water source (point source) was flushed for 15-minutes on the afternoon prior to the day of the survey, and was allowed to sit in the hard plumbed water lines overnight for a minimum of six (6) hours as outlined by the EPA protocols for sampling lead in water.

The first draw water samples were taken prior to any use, and the second draw water samples were taken midstream or after flushing the water at each source for approximately 30 seconds.

A total of 66 samples were collected and submitted for the analysis of lead in water. The sample collection, delivery, and analysis were conducted according to federal, state, and local regulations including the EPA Safe Drinking Water Act (SDWA). The EPA National Primary Drinking Water Regulations (NPDWR) regulate lead (Pb) concentrations in drinking water, as documented in 40 CFR 141. The EPA Primary Drinking Water Standards designate maximum contaminant levels (MCLs) for organic, inorganic, and biological contaminants. The MCL for lead-in-water is 0.015 milligrams per liter (mg/L), which is equivalent to 0.015 parts per million (ppm). The federal action level pertains to public drinking water supplies and is legally enforceable.

The collected water samples were delivered to Gascoyn Analytical Laboratories, Inc. (Gascoyn), located in Baltimore, Maryland. The potable water samples were analyzed for Lead via EPA Method 200.9. Gascoyn is a State of Maryland-certified drinking water laboratory. Their American Association for Laboratory Accreditation (A2LA) Environmental Number is 410.01.

3.5 Description of Facilities

The Frances Perkins Building located at 200 Constitution Avenue NW, in Washington DC was constructed in 1974. The building is a six (6)-story building with one (1) occupied level situated below grade and four (4) below grade parking levels. The building features the Cesar Chavez Auditorium, Wirtz Library, and the Labor Hall of Honor. The Main Department of Labor (DOL) occupies the entire building.

The building has approximately 100 million square feet of usable space with around 200,000 square feet per floor divided into North, Central, and South subdivisions. The service level center subdivision spans over the I-395 tunnel. The building is approximately 134 ft in height measured to the top of the penthouse. The building is classified as a Group B and S-2 mixed separated use occupancy by IBC and as a business and enclosed parking garage mixed separated occupancy by NFPA 101. The building structural system is reinforced concrete. The construction appears to be minimum Type II(222) construction as defined by NFPA 220 and Type IB by the IBC.

The building is protected by automatic sprinklers and fire alarm system. Emergency power is provided by two diesel generators located at the 6th floor.

3.6 Assignment of Risk Assessment Codes (RAC)

The RAC is derived as follows:

1. Hazard Severity - The hazard severity is an assessment of the worst potential consequence, defined by degree of injury, occupational illness or property damage which is likely to occur as a result of a deficiency. Hazard severity categories shall be assigned a Roman numeral according to the following criteria:

a. Category I - Catastrophic: The hazard may cause death, or property loss greater than $1,000,000.

b. Category II - Critical: May cause severe injury, severe occupational illness, or property loss greater $100,000.

c. Category III - Marginal: May cause minor injury, minor occupational illness, or property loss greater than $10,000.

d. Category IV - Negligible: Probably would not affect personnel safety or health, but is, nevertheless, in violation of a standard, or property loss less than $10,000.

2. Mishap Probability - The mishap probability is the probability that a hazard will result in a mishap, based on an assessment of such factors as location, exposure in terms of cycles or hours of operation, and affected population. Mishap probability shall be assigned an Arabic letter according to the following criteria:

a. Subcategory A - Likely to occur immediately or within a short period of time.

b. Subcategory B - Probably will occur in time.

c. Subcategory C - May occur in time.

d. Subcategory D - Unlikely to occur.

3. Risk Assessment Code - The RAC is an expression of risk which combines the elements of hazard severity and mishap probability. Using the matrix shown below, the RAC is expressed as a single Arabic number that can be used to help determine hazard abatement priorities.

RISK ASSESSMENT CODE (RAC) MATRIX

Severity Of The Hazard Probability Of Occurrence Categories

Categories A B C D

I RAC 1 RAC 1 RAC 2 RAC 4

II RAC 1 RAC 2 RAC 3 RAC 4

III RAC 2 RAC 3 RAC 4 RAC 5

IV RAC 4 RAC 4 RAC 5 RAC 5

4.0 RESULTS

Highlights of the facility and fire safety survey are contained in this section. Section 4.1 highlights the facility safety and health findings, Section 4.2 highlights the fire safety findings, Section 4.3 highlights the environmental management findings, and Section 4.4 highlights the indoor air quality findings. Many of the findings associated with these categories are described here as well as in Appendix A and Appendix B.

4.1 Findings - Facility Safety and Health

There was one (1) open facility safety finding in the IRIS database. This finding remains open.

There were four (4) new facility safety findings with a RAC of 3, three (3) new findings with an RAC of 4, and one (1) RAC 5 minor finding identified during the survey.

4.1.1 Walking/Working Surfaces

Walking and working surfaces in the federally occupied spaces consisted of carpeting in the office areas, a combination of carpeting and vinyl tiles in the hallways, vinyl tiles in the kitchenettes, and bathrooms, concrete flooring in mechanical rooms and stairwells, and marble flooring in the lobby areas. All surfaces inspected were in good condition. However, one (1) finding was identified during the survey:

• First Floor N 1649: OSHA Director’s Office (Nicke Godgeson): Excess wiring was observed running across the floor creating a trip hazard (RAC 4).

4.1.2 Electrical Systems

The building is equipped with a standard three wire grounded electrical system and the continuity of the ground was confirmed during the survey by random testing of outlets. Over current protection is provided by breakers located in an electrical closet on each floor. In addition, all electrical panel boxes observed were properly sized and labeled. All electrical outlets within six (6) feet of sinks were provided with ground fault circuit interrupter (GFCI) protection. There were no findings pertaining to the buildings’ electrical systems identified as a result of this audit.

4.1.3 Machine Guarding

Fixed machinery in this facility is associated with the HVAC equipment located in the mechanical rooms on the ground floor through to the sixth floors and maintained by Lessor’s maintenance personnel. All such equipment was either inaccessible to federal personnel and/or was properly guarded at the time of the survey. A machine shop and carpentry shop are located in the basement. Appropriate machine guarding was in place in all equipment.

4.1.4 Emergency First Aid Equipment

Water treatment chemicals that are potentially hazardous to the eyes are used in the water treatment chemical testing area of the basement mechanical room. A battery room is located in the basement which is used to store used and new batteries. Furthermore, battery-powered forklifts are used in the loading dock area located on the 2nd Street side of the building.

Six (6) findings pertaining to emergency first aid equipment were identified as a result of this survey.

• Basement Mechanical Room, water treatment chemical testing area:

- A plumbed eyewash station capable of providing a continuous 15-minute supply of water in a “hands-free” manner has not been installed (RAC 3).

• Basement, battery storage room:

- The saline solution in the secondary eyewash station has expired and needs replacement (RAC 4).

• Loading Dock Area (2nd Street Side): Forklift Battery Charging Area

• Basement, Machine Shop:

- The saline solution in the secondary eyewash station needs replacement; and inspection records are not up to date (RAC 4).

• Basement, Machine Shop:

- The supplies in the First Aid Kit have expired (RAC 5).

4.1.5 Material Handling and Storage

Storage throughout most of the building is incidental to an office occupancy and consisted of paper and office supplies stored in cabinets and on shelves. Contractors utilize hand carts, pallet jacks and forklifts for operations in the loading dock. A number of federal employees whose tasks required it also utilize hand carts and dollies. Pallet Jack and forklift operators were reported to have current training certificates.

One (1) finding pertaining to material handling and storage were identified as a result of this survey.

200 Constitution Avenue NW, Washington, DC

• Basement, Mechanical Room: Batches of unsecured compressed gas cylinders were located in several areas in the basement mechanical room which supposedly contained refrigerants. If these cylinders are inadvertently knocked over, they have the potential to rupture with explosive force. The unstrapped cylinders should be secured to prevent inadvertent movement. Furthermore, all empty cylinders should be stored in a designated storage area (RAC 3).

4.1.6 Noise

According to Mr. Flick, the 6th floor generator room, and basement south end mechanical room have been identified as having noise levels in excess of the action level of 85 dBA established by Occupational Safety and Health Administration (OSHA) during the operation of generators and chiller respectively. Hazardous noise signage indicating that hearing protection is required to be worn was posted in both areas. Furthermore hearing protection (disposable earplugs and earmuffs) was available for use at the entrance to the generator room and the basement mechanical room.

In addition, random noise level measurements were made in select mechanical rooms located throughout the building. The noise levels measured in all mechanical rooms were below the action level of 85 dBA established by OSHA. However, it should be noted that the generators were not in operation in the generator room at the time of the survey.

4.1.7 Illumination

The lighting criteria were obtained from 41 CFR 102-74-180, Energy Conservation Rule, Federal Property Management Regulations. The required light levels are:

50 Foot candles for work surfaces, measured at a height of 30 inches above floor level, during working hours (for visually difficult or critical tasks, additional lighting may be authorized by the Federal agency buildings manager);

30 Foot candles for work areas, measured at 30 inches above floor level (taken to mean areas not requiring reading)

10 Foot-candles, but not less than 1 foot-candle, in non-work areas, during working hours (normally this will require levels of 5 foot-candles at elevator boarding areas, minimum of 1 foot-candle at the middle of corridors and stairwells as measured at the walking surface, 1 foot-candle at the middle of corridors and stairwells as measured at the walking surface, and 10 foot-candles in storage areas)

5 Foot candles for walking surfaces.

Levels essential for safety and security purposes, including exit signs and exterior lights.

Lighting in the common areas consisted of ceiling-mounted, triple-tube and double-tube fluorescent light fixtures equipped with opaque diffusers in the office spaces. Lighting levels were considered adequate at the time of the survey. Light measurements were made in selected areas throughout the building and are included in section 4.4.5, Table 3.

4.2 Findings - Fire Safety Survey

There are six (6) fire safety findings in the IRIS database that remain open. There were two (2) new fire safety findings with a RAC of 3, two (2) new RAC 4 findings and five (5) new RAC 5 findings identified during this survey.

4.2.1 Means of Egress

The second through fifth floors are served by 18 exit stairs. All of the exits are accessed from the exit access corridors on each floor. The sixth floor is served by 12 exit stairs accessed directly from the dining area or the corridors. The first floor is provided with numerous exits to grade. The service level is provided with four exit stairs, which also serve the parking garage.

Each stair has a nominal width of 56 in. and is accessed via a 33 in. clear width exit door.

Scaled, detailed floor plans were not available to perform detailed occupant load calculations.

The sixth level has the highest occupant load. Based on the approximate area of the sixth level, the calculated occupant load is estimated at 1,884 persons based on the business and assembly uses (dining areas and terraces occupied for dinning simultaneously). The 12 enclosed exits each consists of a door with a clear width of approximately 33 in. and a 56 in.

stair width. The exit stairs provide capacity for approximately 1,980 persons, which is adequate for the calculated occupant load. It should be noted that the occupant load of the Terrace Level could vary depending on the use of the outdoor terrace area. If the terraces are used for concentrated assembly events, such as viewing the fireworks, parties, or similar functions, the occupant load of the floor is estimated to increase to 2,753 persons, with approximately 1,629 persons on the terrace, and sufficient egress capacity would not be provided. It is not anticipated that the terrace is used for events. Any such events should be further evaluated to ensure adequate egress capacity.

The calculated occupant loads of the upper floors are estimated as follows:

• Fourth and fifth floor - 1,636 persons based on the business use (approximately 163,530 SF @ 100 SF/person).

• Third floor - 1,619 persons based on the business use (approximately 161,900 SF @ 100 SF/person).

• Second floor - 1,592 persons based on the business use (approximately 159,181 SF @ 100 SF/person).

The eighteen enclosed exits serving these floors, each consisting of a door with a clear width of approximately 33 in. and a 56 in. stair width, provide capacity for approximately 2,970 persons, which is adequate for the calculated occupant load.

The first floor is served by exits directly to the outside; including the main building entrance along 3rd Street, as well the direct exits to 2nd Street, Constitution Ave, and D Street. Detailed occupant load calculations could not be performed, but based on the floor area and observed uses the calculated occupant load for the first floor is estimated to be not more than 1,500 persons including the auditorium and museum. The available exits provide capacity for roughly 3,600 persons.

Based on the floor area and observed uses the calculated occupant load for the service level is estimated at 300 persons. The available exits provide capacity for roughly 660 persons.

All of the exit stairs discharge to the interior of the building. Most of the stairs discharge into lobbies or other exit corridors that provide access to exterior exits. None of the discharge paths qualify as exit passageways per NFPA 101 due to non-fire-rated separations, unprotected penetrations, and openings to normally unoccupied spaces.

Exits serving all floors are remotely located in accordance with NFPA 101. Travel distance to an exit is less than 250 feet. There are no excessive dead-end corridors and the maximum common path of travel distance is less than 100 ft.

The following issue was identified concerning the means of egress:

• All exit stairs discharge to the interior of the building (RAC 3).

4.2.2 Sprinkler and Standpipe System

The building is protected by an automatic sprinkler system throughout. A wet pipe sprinkler system is provided for the interior offices and dining area, and in the four heated levels of the parking garage. The roof mounted cooling towers are provided with a deluge system activated by a pilot head air system. The AT&T roof structure and loading dock are also provided with a deluge sprinkler system.

The sprinklers were retrofitted in 1994 and are supplied by a combined sprinkler/ standpipe system. There are six zones per floor and waterflow detection is provided for each zone. The sprinkler/ standpipe system is controlled by a combination of OS&Y valves and butterfly valves.

All valves are electrically supervised by the fire alarm system.

Standpipe risers are 6-inches in diameter and are located in each of the building exit stairs.

The standpipes are provided with 2-1/2-inch hose connections on each floor.

An electric motor driven, vertical centrifugal fire pump is located in the basement chiller room and supplies the building standpipe and sprinkler system. The pump is manufactured by Aurora and is rated at 750 gpm @ 90 psi. The pump is provided with secondary power by the emergency generator system.

Fire department connections are provided on the 2nd Street side at the southeast corner and on the 3rd Street side at the center section by the fountain. Fire hydrants are adjacent at each block.

Kitchen range hoods and cooking equipment in the sixth floor cafeteria are protected by Kitchen Knight II wet chemical systems, which are connected to the building fire alarm system.

The following findings were noted related to the automatic sprinkler system:

• The following areas are not provided with sprinkler protection due to renovations

(RAC 3):

o Fifth Floor: Two offices in S5015 o Fourth Floor: Copy room in N4611, two offices in N4408 o Men’s and women’s shower area in fitness locker rooms

• The following areas are not provided with adequate sprinkler coverage protection

(RAC 4):

o Fifth Floor: Room N5623 back office area, N56090 conference/library, N5608 pantry, S4519 entry area o Fourth Floor: Room N4121 entry corridor, Room S4325 entry corridor, and Room S4316 entry corridor o Fitness center entry way and men’s and women’s locker room entrances

• The standpipe hose connection provided in Stair 8 is missing a cap at the sixth floor landing (RAC 5).

The following IRIS findings remain open related to the automatic sprinkler system:

• Due to renovations, the fitness center office is not fitted with fire sprinkler heads

• The building has recalled O-ring sprinklers on the 2nd floor.

4.2.3 Fire Separations

Fire separations in the building primarily include floor-to-floor horizontal assemblies, utility shafts and hoistways, exit enclosures, elevator lobby enclosures, and separation of hazardous areas such as elevator machine rooms and electrical areas. The stairways, elevator hoistways and utility shafts appear to be enclosed in 2-hour fire-rated construction with fire rated protected openings.

The following findings were observed related to fire separations in the building:

• The following fire rated doors for stair enclosures did not latch properly (RAC 4):

o Sixth Floor: Stairs 2 and 20 o Fifth Floor: Stair 3 o Fourth Floor: Stair 10 o Third Floor: Stairs 1, 3, 6, and 21

• The doors provided for the elevator lobby serving elevator 27/28 do not latch properly on the sixth floor (RAC 5).

• Open penetrations were observed in the enclosure of the generator rooms on the sixth floor (RAC 5).

An open IRIS finding addresses the fire rated door for the fire control room which is broken. In addition, open wall penetrations between the fire control room and a mechanical room exist.

4.2.4 Fire Extinguishers

Fire extinguishers are located in the corridors leading to the exit stairs and generally along the center pathways of the open office areas. The number and spacing appear to be in accordance with NFPA 10. Several carbon dioxide units having a rating of 10BC were observed in the elevator machine rooms. Type K extinguishers having a 2AK rating were installed near grill and cooking areas that are protected by fixed wet chemical systems.

The last annual service of the fire extinguishers was completed on November 2012. Monthly visual inspections have not been completed and documented on the extinguisher tags.

One finding was identified concerning the fire extinguishers:

• Documentation of monthly inspections of the fire extinguishers has not been conducted (RAC 5).

4.2.5 Emergency Lighting and Power

Emergency lighting is provided by a combination of dedicated fixtures and wall mounted battery units. The dedicated fixtures are provided with secondary power by two emergency diesel generators located on the sixth floor. These generators have a capacity of 400 kW each.

The LED exit signs are provided with secondary power by the emergency generators. The generators also provide back-up power for the fire pump, fire alarm system, and one elevator per elevator bank.

200 Constitution Avenue NW, Washington, DC

There was one finding identified concerning the emergency lighting/power system:

• No documentation was provided to demonstrate full load testing of the emergency generator system (RAC 5).

4.2.6 Exit Signs

Internally illuminated exit signs are provided to direct occupants to the exit stairs, exterior exit discharge locations, and within corridors and larger office areas. The exit signs are connected to the emergency power supply (generators). The exit signs were observed to be, for the most part, readily visible, properly illuminated and adequately located in the building.

There were no findings identified regarding exit signs.

4.2.7 Alarm System

An automatic fire alarm system is provided for the building. An Edwards IRC-3 fire alarm control panel is located in the fire alarm control room which is on the mid level parking garage.

The fire alarm panel is provided with a battery back-up power source and is also connected to the emergency generator system. The fire alarm system is monitored by the GSA MegaCenter and the onsite continuously staffed guard station. The fire alarm system sounds a general building alarm using horns and strobes.

Manual fire alarm stations are located near the exit stair enclosures and entrances/exits at the level of exit discharge. Smoke detectors are provided in the elevator lobbies, elevator machine rooms, and data centers. The fire alarm system supervises waterflow devices and tamper switches for the automatic sprinkler systems. Waterflow switches are provided for each wet pipe sprinkler system and standpipe riser. Tamper switches are provided for all fire protection control valves. The fire alarm system also monitors the kitchen hood suppression systems.

The elevators are equipped with Phase I emergency recall operation and Phase II emergency in-car operation.

The computer rooms/ data centers in the building are provided with Pyrotinics Pyr-A-Larn CTZ-2 fire alarm control panels and are provided with smoke detection at the ceiling and below the raised floor.

No new findings were identified related to the fire alarm system.

A previous IRIS finding addresses the lack of a voice fire alarm system for the building. This finding still exits. The existing fire alarm system is antiquated and does not include an emergency communication system (voice) as required by GSA. A previous IRIS finding also identified that there is no smoke detector located over the fire alarm control panel. This condition still exists.

4.2.8 Documentation of Testing

The records for the inspection, testing and maintenance of the fire protection systems are maintained in the facility engineering office. System maintenance is performed by in-house contractors (weekly) with quarterly and annual testing conducted by Kinetix. Records were reviewed for the systems as part of the survey. All records were up to date and no significant issues were noted.

4.2.9 Storage of Flammable Material

No flammable or combustible liquids were observed in the building with the exception of the fuel tank in the generator room.

4.2.10 Fire Safety Summary

The fuel loading and fire hazards in the building are typical of mid- and high-rise office buildings. No unusual or significant fire hazards were observed. The non-combustible building construction and provision of automatic sprinkler protection improves the level of fire safety.

Egress in the building consists of enclosed exit stairs and direct exits to the exterior for general compliance with NFPA 101 exiting requirements. However, all of the exit stairs discharge to the interior of the building, which increases the risk to occupants if a fire event occurs on the first floor. This issue should be addressed to improve the level of fire safety to occupants.

In general, required fire separations appear to be maintained with appropriately protected openings. A few issues were observed related to the maintenance of fire doors serving hazardous areas and an exit stair enclosure.

The fire protection systems in the building are regularly inspected, tested and maintained. A few issues were noted regarding improper sprinkler coverage and inadequate fire alarm notification (no voice alarm).

4.3 Findings - Environmental Management

There were no open environmental management findings from the IRIS database for this building. However, there was one (1) new RAC 3 and (1) new RAC 4 finding identified.

4.3.1 Air Pollution Control

No air pollution control devices such as incinerators were identified during the audit and none are deemed necessary based upon observations made during the audit.

No operations that might emit contaminants to the atmosphere were identified during the audit. The building and its operations appear to be in compliance with the Clean Air Act of 1990.

4.3.2 Asbestos Management

Asbestos-containing building materials have been identified within this circa 1974 facility.

According to Mr. Jones, the majority of ACM is in the form of duct sealant and vinyl floor tiles and associated mastic. No damaged or friable ACM were noted during the survey.

One (1) finding was noted as a result of this survey:

• The Asbestos Operations and Maintenance (O&M) Plan for this building was last updated in 1998 and may need to be reviewed and updated (RAC 4).

4.3.3 Water Pollution Control

This facility is connected to a municipal wastewater system and does not treat any of the discharge from the building. The facility only discharges sanitary wastewater, which is treated by the municipal treatment plant. There was no potential for water pollution from the operations conducted in the facility.

In addition, storm water discharge was also evaluated during the audit. Storm water pollution is controlled by the Clean Water Act Amendments of 1987 (CWAA). These amendments allowed the EPA to expand the National Pollutant Discharge Elimination System (NPDES) program to cover storm water discharges. NPDES storm water discharge permits are required for construction sites that disturb five or more acres of land; storm drain systems of large municipalities; and industrial activities with the potential to produce storm water. Title 40 CFR Part 122.26(b)(14) lists the types of industrial activities that require NPDES permits.

These include, but are not limited to: storage facilities, especially hazardous wastes materials or material storage, maintenance or repair shops, printing shops, motor pools, construction sites that disturb five or more acres of land, steam-generating facilities, transportation facilities, marina operation, and most manufacturing facilities. As a general rule, if there are any activities at the site that may be classified as industrial, then a storm water permit may be required. Activities that may pollute the storm water at this building include the parking lot and any other paved surface where fluids have leaked, hazardous materials have been spilled, or litter, particles, or sediments have accumulated. No evidence of such leaked materials was observed in the parking lot, which appeared to be fairly clean and free of debris at the time of the audit.

No findings pertaining to water pollution control were identified as a result of this audit.

4.3.4 Lead in Drinking Water

The EPA action levels for lead in water (subpart I) is any concentration greater than 0.015 mg/L.

According to 40 CFR 141.80, the Treatment Technique Action Level (TTAL) is exceeded if the concentration of lead is greater than 0.015 mg/L. The lead analytical laboratory results are summarized in Table 2 below. Copies of the analytical laboratory reports and chain of custody forms including sampling times are included in Appendix C of this report. A diagram indicating water sampling locations are included in Appendix D of this report.

TABLE 2 – Lead-in-Water Sample Analysis Results

Sample ID Location Manufacture’s Name

Model #/ Serial #

Lead (mg/L)

Exceeded EPA Action

Level?

FP-1 (1st) 6th floor, Drinking Water Fountain near N6433A (1st draw)

ELKAY with Flexi-Guard

EDFP14C

000937856 ND No

FP-1 (2nd) 6th floor, Drinking Water Fountain near N6433A (2nd draw)

ELKAY with Flexi-Guard

EBFP14C

0000937856 ND No

FP-2 (1st) 5th floor, Drinking Water Fountain near N5640A (1st draw)

ELKAY with Flexi-Guard

EDFP14C

000937863 ND No

FP-2 (2nd) 5th floor, Drinking Water Fountain near N5640A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

000937863 ND No

FP-3 (1st) 5th floor, Drinking Water Fountain near N5708A (1st draw)

ELKAY with Flexi-Guard

EDFP14C

000937868 ND No

FP-3 (2nd) 5th floor, Drinking Water Fountain near N5640A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

000937868 ND No

FP-4 (1st) 5th floor, Drinking Water Fountain near N5449A (1st draw)

ELKAY with Flexi-Guard

EBFP14C

000937859 ND No

FP-4 (2nd) 5th floor, Drinking Water Fountain near N5449A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

000937859 ND No

FP-5 (1st) 4th floor, Drinking Water Fountain near N4449A (1st draw)

ELKAY with Flexi-Guard

EDFP14C

000937861 ND No

FP-5 (2nd) 4th floor, Drinking Water Fountain near N4449A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

000937861 ND No

200 Constitution Avenue NW, Washington, DC

Sample ID Location Manufacture’s Name

Model #/ Serial #

Lead (mg/L)

Exceeded EPA Action

Level?

FP-6 (1st) 4th floor, Drinking Water Fountain near N4435A (1st draw)

ELKAY with Flexi-Guard

EDFP14C

000937891 ND No

FP-6 (2nd) 4th floor, Drinking Water Fountain near N4435A (2nd draw)

ELKAY with Flexi-Guard

EBFP14C

0000937891 ND No

FP-7 (1st) 4th floor, Drinking Water Fountain near N4113A (1st draw)

ELKAY with Flexi-Guard

EDFP14C

000937892 ND No

FP-7 (2nd) 4th floor, Drinking Water Fountain near N4113A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

000937892 ND No

FP-8 (1st) 3rd floor, Drinking Water Fountain near N3435A (1st draw)

ELKAY with Flexi-Guard

EDFP14C

NA ND No

FP-8 (2nd) 3rd floor, Drinking Water Fountain near N3435A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

NA ND No

FP-9 (1st) 3rd floor, Drinking Water Fountain near N3640A (1st draw)

ELKAY with Flexi-Guard

EBFP14C

NA ND No

FP-9 (2nd) 3rd floor, Drinking Water Fountain near N3640A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

NA ND No

FP-10 (1st) 3rd floor, Drinking Water Fountain near N3449A (1st draw)

ELKAY with Flexi-Guard

EDFP14C

000937865 ND No

FP-10 (2nd) 3rd floor, Drinking Water Fountain near N3449A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

000937865 ND No

FP-11 (1st) 2nd floor, Drinking Water Fountain near N2708A (1st draw)

ELKAY with Flexi-Guard

EDFP14C

000937864 ND No

FP-11 (2nd) 2nd floor, Drinking Water Fountain near N2708A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

000937864 ND No

FP-12 (1st) 2nd floor, Drinking Water Fountain near N2449A (1st draw)

ELKAY with Flexi-Guard

EDFP14C

NA ND No

FP-12 (2nd) 2nd floor, Drinking Water Fountain near N2449A (2nd draw)

ELKAY with Flexi-Guard

NA ND No

200 Constitution Avenue NW, Washington, DC

Sample ID Location Manufacture’s Name

Model #/ Serial #

Lead (mg/L)

Exceeded EPA Action

Level?

FP-13 (1st) 2nd floor, Drinking Water Fountain near N2111A (1st draw)

ELKAY with Flexi-Guard

EDFP14C

000937883 ND No

FP-13 (2nd) 2nd floor, Drinking Water Fountain near N2111A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

000937883 ND No

FP-14 (1st) 1st floor, Drinking Water Fountain near N1433A (1st draw)

ELKAY with Flexi-Guard

EBFP14C

NA ND No

FP-14 (2nd) 1st floor, Drinking Water Fountain near N1433A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

NA ND No

FP-15 (1st) 1st floor, Drinking Water Fountain near N1502A (1st draw)

ELKAY with Flexi-Guard

EBFP14C

NA ND No

FP-15 (2nd) 1st floor, Drinking Water Fountain near N1502A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

NA ND No

FP-16 (1st) 6th floor, Drinking Water Fountain near N6210A (1st draw)

ELKAY with Flexi-Guard

EBFP14C

NA ND No

FP-16 (2nd) 6th floor, Drinking Water Fountain near N6210A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

NA ND No

FP-17 (1st) 5th floor, Drinking Water Fountain near S5208A (1st draw)

ELKAY with Flexi-Guard

EDFP14C

000937876 ND No

FP-17 (2nd) 5th floor, Drinking Water Fountain near S5208A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

000937876 ND No

FP-18 (1st) 5th floor, Drinking Water Fountain near S5023A (1st draw)

ELKAY with Flexi-Guard

EDFP14C

000937866 ND No

FP-18 (2nd) 5th floor, Drinking Water Fountain near S5023A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

000937866 ND No

FP-19 (1st) 5th floor, Drinking Water Fountain near S5009A (1st draw)

ELKAY with Flexi-Guard

EBFP14C

000937857 ND No

FP-19 (2nd) 5th floor, Drinking Water Fountain near S5009A (2nd draw)

ELKAY with Flexi-Guard

000937857 ND No

200 Constitution Avenue NW, Washington, DC

Sample ID Location Manufacture’s Name

Model #/ Serial #

Lead (mg/L)

Exceeded EPA Action

Level?

FP-20 (1st) 4th floor, Drinking Water Fountain near S4009A (1st draw)

ELKAY with Flexi-Guard

EDFP14C

000937870 ND No

FP-20 (2nd) 4th floor, Drinking Water Fountain near S4009A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

000937870 ND No

FP-21 (1st) 4th floor, Drinking Water Fountain near S4023A (1st draw)

ELKAY with Flexi-Guard

EDFP14C

000937895 ND No

FP-21(2nd) 4th floor, Drinking Water Fountain near S4023A (2nd draw)

ELKAY with Flexi-Guard

EBFP14C

0000937895 ND No

FP-22 (1st) 4th floor, Drinking Water Fountain near S4224A (1st draw)

ELKAY with Flexi-Guard

EDFP14C

000937867 ND No

FP-22 (2nd) 4th floor, Drinking Water Fountain near S4224A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

000937867 ND No

FP-23 (1st) 3rd floor, Drinking Water Fountain near S3208A (1st draw)

ELKAY with Flexi-Guard

EDFP14C

000937886 ND No

FP-23 (2nd) 3rd floor, Drinking Water Fountain near S3208A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

000937886 ND No

FP-24 (1st) 3rd floor, Drinking Water Fountain near S3023A (1st draw)

ELKAY with Flexi-Guard

EBFP14C

980533155 ND No

FP-24 (2nd) 3rd floor, Drinking Water Fountain near S3023A (2nd draw)

ELKAY with Flexi-Guard

EBFP14C

980533155 ND No

FP-25 (1st) 3rd floor, Drinking Water Fountain near S3009A (1st draw)

ELKAY with Flexi-Guard

EBFP14C

000937885 ND No

FP-25 (2nd) 3rd floor, Drinking Water Fountain near S3009A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

000937885 ND No

FP-26 (1st) 2nd floor, Drinking Water Fountain near S2009A (1st draw)

ELKAY with Flexi-Guard

EDFP14C

000937881 ND No

FP-26 (2nd) 2nd floor, Drinking Water Fountain near S2009A (2nd draw)

ELKAY with Flexi-Guard

000937881 ND No

200 Constitution Avenue NW, Washington, DC

Sample ID Location Manufacture’s Name

Model #/ Serial #

Lead (mg/L)

Exceeded EPA Action

Level?

FP-27 (1st) 2nd floor, Drinking Water Fountain near S2023A (1st draw)

ELKAY with Flexi-Guard

EDFP14C

000937887 ND No

FP-27 (2nd) 2nd floor, Drinking Water Fountain near S2023A (2nd draw)

ELKAY with Flexi-Guard

EBFP14C

0000937887 ND No

FP-28 (1st) 2nd floor, Drinking Water Fountain near S2224A (1st draw)

ELKAY with Flexi-Guard

EDFP14C

000937860 ND No

FP-28 (2nd) 2nd floor, Drinking Water Fountain near S2224A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

000937860 ND No

FP-29 (1st) 1st floor, Drinking Water Fountain near S1208A (1st draw)

ELKAY with Flexi-Guard

EDFP14C

000937888 ND No

FP-29 (2nd) 1st floor, Drinking Water Fountain near S1208A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

000937888 ND No

FP-30 (1st) 1st floor, Drinking Water Fountain near S1026A (1st draw)

ELKAY with Flexi-Guard

EBFP14C

000937882 ND No

FP-30 (2nd) 1st floor, Drinking Water Fountain near S1026A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

000937882 ND No

FP-31 (1st) 1st floor, Drinking Water Fountain near S1008A (1st draw)

ELKAY with Flexi-Guard

EDFP14C

000937893 ND No

FP-31(2nd) 1st floor, Drinking Water Fountain near S1008A (2nd draw)

ELKAY with Flexi-Guard

EDFP14C

000937893 ND No

FP-32 (1st)

Basement South, Drinking Water Fountain near C0032 (1st draw)

Halsey Taylor® HRFSB 08810622 ND No

FP-32 (2nd)

Basement South, Drinking Water Fountain near C0032 (2nd draw)

Halsey Taylor® HRFSB 08810622 ND No

FP-33 (1st)

Basement, North Drinking Water Fountain near C0066 (1st draw)

NA NA ND No

200 Constitution Avenue NW, Washington, DC

Sample ID Location Manufacture’s Name

Model #/ Serial #

Lead (mg/L)

Exceeded EPA Action

Level?

FP-33 (2nd)

Basement, North Drinking Water Fountain near C0066 (2nd draw)

NA NA ND No

*NA- Not Applicable, *ND – Analyte NOT DETECTED at or above the reporting limit.

The lead analytical results indicated that lead was not detected at or above the EPA Action level of 0.015 mg/L in any of the water samples obtained from the facility.

4.3.5 Nonhazardous Waste Management

Title 40 Code of Federal Regulations (CFR) 243.200 states that all solid wastes shall be stored in such a manner that they do not constitute a fire, health or safety hazard or provide food or harborage of vectors. No accumulation of trash was noted during the survey. The contractor R&R Inc. provides office trash removal twice a week. The building currently has recycling programs in effect for high grade waste paper, cardboard, glass, and aluminum cans.

No findings pertaining to nonhazardous waste management were identified as a result of this survey.

4.3.6 Hazardous Waste Management

The building, with minor exceptions, does not house any of the following potential generators of hazardous substances and wastes: large scale printing or reproduction operations, laboratories, pest control, electroplating, chemical manufacturing, large scale photo labs, painting operations, welding operations, firing ranges, or dry cleaners.

Cleaning and maintenance supplies located on site appeared to be of low usage and did not constitute a threat to human health or the environment. Supplies are used in their entirety prior to their disposal.

Facility fluorescent light bulbs may contain small amounts of mercury. RCRA regulates disposal of mercury containing light bulbs as hazardous waste if more than 100 kilograms of bulbs are disposed of in one month. Used light bulbs are stored in the basement. The ballasts are placed in are shipped out in pallets for recycling once every 2 months. Discussions with building management and observations indicated that less than 100 kilograms of bulbs are disposed of monthly, via recycling as a universal waste. RCRA allows conditional exemption from hazardous disposal requirements for this amount of disposal. The facility pays an annual hazardous waste generator fee and also maintains hazardous waste manifests for used batteries and CFL bulbs.

A health unit is located on the 3rd floor which is maintained by the Department of Health. A contract is in place for medical waste to be removed on a quarterly basis. The nurse maintains all medical waste manifests issues by the contractor.

No findings pertaining to hazardous waste management were identified as a result of this audit.

4.3.7 Underground Storage Tanks

The General Services Administration (GSA) Underground Storage Tank (UST) Technical Guide requires all property management centers and field offices where the GSA owns or operates USTs to develop a UST Management Plan. The UST Management Plan should include a list of all USTs at GSA owned, leased and delegated buildings, and an up-to-date inventory of all GSA USTs. Records should be kept of any tank notification sent to the regulating authority, and an explanation of the reporting procedures for notification for releases from tanks should be included in the management plan.