Rawley McCoy & Associates, PLLC

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1 , PLLC ARCHITECTS AND INTERIOR DESIGNERS 1908 N.laurent St. Suite 540 Victoria, Texas P(361) F(361} The Honorable Kevin Janak Victoria County Commissioner, Precinct N. Bridge#102 Victoria, TX August 11, 2015 Re: Juvenile Detention Center Dear Commissioner Janak, As you recall, some time ago you contacted my firm to look at and advise you as to ways the County might make the Juvenile Detention facility more energy efficient. You at the time were concerned that perhaps the building did not have adequate insulation. When initially meeting with you at the facility I determined that the walls did have some insulation inside the tilt-up concrete panels and roof insulation was present. When I looked above the ceiling in portions of the building, I did notice that one could see daylight along the perimeter of the building because of gaps between the top of the tilt-up panels and steel eave struts. This could be a source of air infiltration, which could allow excess humid air into the building plenum and tax the capacity of existing A/C units to deal with it. At that meeting I was also told by staff that the building had a high negative pressure because they could feel air rush into the building any time certain doors were opened. When I realized that the building's A/C (negative pressure) issues were more of a Mechanical Engineering issue than an Architectural issue, I recommended bringing in Stridde, Callins and Associates, Inc. (SCA), to analyze the situation and provide a report before moving forward with my recommendations to you and the Court. A study of the building was done with heavy involvement of Danny Hiller who lives here in Victoria, but works for SCA. After review of the facility's plans and performing their fieldwork, they sent me a report of their findings along with their recommendations. A copy of that report is attached. It was during their assessment of the building that the issue of the absence of a smoke evacuation system was raised. My position and professional opinion after reading their report has always been that the best solution to this discovered deficiency in the building was to add an "engineered smoke control system" to the facility, which is one of four options available under Chapter of the Life Safety Code (LSC) which by the way is now applicable to all such facilities state-wide. In my conversations with you and with our previous County Judge, I have always said I don't know how the facility can operate without such a system and that I wasn't sure if you were "grandfathered". What I did know, and what I have always stated to everyone that I have talked to about this situation, is that you have juveniles (children) who are locked behind doors who can only be let out by someone getting to that door with a key and manually unlocking it if a fire should break out. And with my knowledge of other codes and standards, such as the State Jail Standards, this would not be acceptable and smoke evacuation systems are always required. And any Fire Marshall or Fireman will tell you that children do not react to emergency situations like adults do. So, why have a less stringent requirement for smoke evacuation in a juvenile facility than a jail would? I can tell you also that Rawley McCoy: rmccoy@suddenlinkmail.com Billy Berger: b-berger@suddenlinkmail.com

2 the Life Safety Code is a very ambiguous code compared to the International Fire Code and the International Building Code. I can also tell you that the Life Safety Code, or any other code for that matter, simply establishes the "absolute minimum requirements" for safety. I have an obligation under my license as an Architect in the State of Texas to "protect the health, safety and welfare" of the people of this State. That obligation requires that I take into account all of my knowledge of codes, my years of experience and yes my common sense when rendering my professional opinion in such matters. And my opinion in this matter, given my knowledge of the Juvenile Detention Center in its totality and in addition to the report and opinions rendered by my engineering consultants is that the safest way to protect the lives of the children in that facility is to add an "engineered smoke control system" in addition to remedying the other HVAC and architectural issues with the facility. Sincerely, Rawley McCoy, AlA - President cc: Ronald W. Pray - Victoria County Fire Marshall Scott Stridde, President SCA Dan Hiller, SCA

3 Stridde, Callins & Associates, Inc. 342 S Navigation Blvd. Corpus Christi, TX Phone (361) Fax (361) Mr. Rawley McCoy, A.I.A N. Laurent, Suite 540 Victoria, TX f / Fo328 RE: Victoria County Regional Detention Center Dear Mr. McCoy, This report is in response to a request to evaluate the mechanical systems, identify deficiencies, recommend solutions to deficiencies discovered and render an opinion of probable construction cost to correct such deficiencies. INFORMATION, OBSERVATIONS AND DISCOVERIES: 1. The staff reports that the facility is regulated by the State of Texas in accordance with 37 TAC Chapter All original package units have been replaced. All condensing units have been replaced. Only one indoor unit has been replaced. The units operate using R-22 refrigerant which is being phased out because of its purported global warming potential. No reason exists to take action to replace these units prior to their mechanical failure as R-22 will be available for a length of time that exceeds the service life of the equipment. The cost of the refrigerant will increase as its availability decreases. Unit serial numbers reveal replacements occurred from 2005 to It is reported that all HVAC unit fans are operated so that the fan cycles with the cooling and heating cycles in all areas. 4. It is reported that outside air intakes have been disabled for all units except the Kitchen. The disabled outside air intake dampers for the split systems may be inoperable due to disuse. At the time the packaged units were replaced, it was reported that outside air intakes were not included with the new units. This was observed to be correct. This is a violation of the International Mechanical Code (IMC). 5. The nine (9) exhaust fans serving public rest rooms and individual toilet rooms in the Administration section of the complex were designed to be interlocked with Macintosh HD:Users:rmaccoy:Library:Conlainers.com. apple.mail: Data: Library; Mail Downloads:6D D4-D4C6-40C2-A21 E E27A46C5EC3E:Report_ doc

4 Mr. Rawley McCoy, A.I.A. Page 2 of 6 air handling units in their respective areas. lt is reported that they are interlocked with the lights in the areas they serve. When the exhaust fans are operating, 1,540 CFM may be exl1austed. Since there is no makeup air thru the unit, a negative pressure is created in the space when any fan or fans are energized allowing untreated outdoor to entire thru any opening in the building. 6. It is reported that the Kitchen staff uses the exhaust hood only when prompted by the Administration. The kitchen exhaust fan and supply fan are interlocked. The supply fan is designed to make up 80% of the air exhausted by the hood fan. The hood is a short circuit type which is the most inefficient hood type in regard to removal of heat and cooking odors. When the exhaust/supply hood system is off, the unit serving the kitchen continues to provide 1000 CFM of outside air to the building when its supply blower is on. However, this outside air is likely confined to the kitchen area and does not contribute to building pressurization due to the wall structure. 7. The six (6) wall exhaust fans serving the dormitory area operate continuously to exhaust 2,520 CFM. Air conditioning units serving the dorms were originally designed to provide OA at a rate of 360 CFM each, for a total of 2,160 CFM. The original design intended to produce a slight negative pressure (-360 CFM) in relation to the outdoors. Currently, the deficit of 2,520 CFM creates a large negative pressure. When unit fans cycle off, the area served by that unit will be in a deep negative pressure. The continuous exhaust is a requirement of the IMC. 8. It is unlikely that the air quantities being delivered, returned and exhausted are in compliance with the original Contract Documents. lt is reported that testing, adjusting and balancing (TAB) documentation does not exist. The original specifications do not require TAB by an independent agency, which is a standard requirement for final completion of a great majority of commercial projects. The return air grilles for the HVAC units serving the Detention area are undersized. 9. The control room in the Detention Area is repor1ed to be very warm. This was verified during the walk thru. There is a large amount of electronic equipment in the space. Additionally, there were three (3) detention officers working therein when the observer was present. 10. Each HVAC unit in the detention area is supplied with a power circuit for the refrigeration cycle and a separate power circuit for the blower motor. This allows only the blowers to operate when the emergency generator is operating. 11. There is an automatic fire alarm system that shuts down all HVAC equipment if fire is detected. The dormitory area has an automatic fire sprinkler system. Smoke detectors are installed in the return air duct of each packaged unit and air Macintosh HD Users rmaccoy Library:Containers com.apple.maii:data Library:Mail Downloads 601D C6 40C2 A21E E27A46C5EC3E:Report_ doc

5 Mr. Rawley McCoy, A.I.A. Page 3 of 6 handling unit which stop the units if smoke is detected in the air stream. The fire hatches above the Day Rooms in the cell pods are reported to be inoperable. 12. Electric power usages for the facility were furnished by the County for years 2005 thru COMMENTS AND RECOMMENDATIONS: 1. The HVAC requirements described in 37 TAC Chapter 343 are limited. The statement contained therein "The facility shall provide fully functioning heating, cooling and ventilation systems adequate for the square footage of the facility" creates concern as to what is actually required. The International Mechanical Code (IMC) and the Life Safety Code, NFPA 101 (LSC) are applicable to this facility, particularly Chapters 9 and 23 of the LSC dealing with Existing Detention and Correctional Facilities. A review of the original Contract Documents and the aforementioned codes reveal systems in the facility meeting IMC and LSC requirements and systems which do not meet such requirements. Some systems, such as outdoor air make up in each unit, were designed into the project but have been abandoned. The greatest concern in regard to the IMC is the absence of outside air introduced through the HVAC system. The chief concern in regard to the LSC is the absence of a mechanical smoke removal system that is capable of evacuating smoke from the cells in the time required by state agencies. 2. The electrical usage for this facility has decreased over the last two years. HVAC unit replacement (and subsequent abandonment of providing outside air) and lighting retrofit have likely contributed to this. However, code compliance has been compromised. A summary for the usage from 2005 thru 2013 is attached. 3. In the Administrative area, HVAC unit supply fans should be operated continuously during occupied hours in order to maintain a positive pressure inside the building. 4. Outside air intakes should be provided for each unit not having such an apparatus. Existing devices that are inoperable or systems that lack adequate controls should be refurbished or replaced. The intended result of removing the outside air (OA) intakes was to eliminate the OA load. It is reported that large openings to the outside are present above the ceiling. Since the space between the ceiling and the structure is used as a return air plenum, an uncontrolled quantity of OA enters the system through these openings. Increased infiltration of untreated outdoor air can lead to high humidity, comfort, moisture and Macintosh HD:Users:rmaccoy: Libra ry:containers:com. apple.mail: Data:Library:Mail Downloads : C6-40C2-A21 E. E27A46C5EC3E:Report_ doc

6 Mr. Rawley McCoy, A.I.A. May Page 4 of 6 increased equipment energy usage issues. This quantity probably exceeds the amount of OA required by the code. If the openings are tightly sealed and the OA function is restored, the OA quantity can be controlled and minimized with the use of C02 detectors. The minimum outside air supplied can be balanced to provide only sufficient air to maintain a positive pressure. Upon detection of higher levels of C02, the OA damper will open to provide a larger OA quantity only for such period as is required to lower the C02 content to an acceptable level. When the proper C02 level is achieved, the OA controls will revert to the minimum quantity. 5. Operation of public restroom and toilet room exhaust fans should be limited to times when the HVAC units serving their respective areas are in operation. HVAC blowers should operate continuously during occupied times to prevent the building being negative in relation to the outdoors. Restore outdoor intake apparatus for Administration HVAC units with demand control ventilation cycle to provide outdoor air quantity sufficient to maintain a positive pressure in the building or maintain acceptable C02 levels. De-energizing the exhaust fans may be accomplished using the existing time clock and adding a circuit incorporating a relay wired in series with the light switch interlock circuit. Alternatively, the building operator may manually shutdown fans. 6. Tile kitchen exhaususupply system should be utilized at all times when cooking operations are performed. The kitchen exhaususupply appears to be functioning (in general) as intended. The correct air quantities should be established by a firm specializing in air balance and verification. The kitchen air conditioning system can be balanced to provide a minimum amount of outside air to maintain building pressurization or the minimum ventilation rate. The air handling unit can be interlocked with the kitchen hood system to provide the scheduled amount of outside air only when the fans are energized. 7. Restore outdoor intake apparatus for Dormitory HVAC units and provide demand control ventilation cycle to provide outdoor air quantity sufficient to maintain a positive pressure in the building or maintain acceptable C02 levels. 8. The entire HVAC system needs to undergo an air balance by a reputable Test, Adjust and Balance firm and a formal report should be provided. The return air grilles for the HVAC units serving the Detention area should be replaced with larger air devices. 9. A small supplementary HVAC unit may be installed in the Control room. 10. The duct mounted smoke detector shutdown of the HVAC systems is proper procedure. Macintosh HD:Use rs:rmaccoy: Library. Contain a rs:corn.apple. ma ii:data :Library: Mail Downloads : D4C6-40C2-A21 E E27A46C5EC3E:Report_ doc

7 Mr. Rawley McCoy. AI.A Page 5 of The LSC Chapter lists four acceptable methods for smoke removal: (1) Operable windows. (2) Manual or automatic smoke vents. (3) Engineered smoke control system. (4) Mechanical exhaust system providing not less than 6 air changes per hour. Operable windows do not exist in the building. The heat operated fire hatches in the day room (even if in operating condition) do not communicate with the cells. Therefore, there is no provision for smoke removal from the cells. The code required continuous ventilation delivered by the six wall fans serving the cells provides only 3 air changes per hour and therefore falls short of the six air changes per hour required for smoke removal. There is no effective method of smoke removal from the Detention area. While there is a provision in the LSC for "Grandfathering", it is our opinion that the absence of a smoke removal system constitutes a life safety hazard. 12. See attachment for historical electrical power usage. 13. The addition of smoke purge fans will introduce additional load on the emergency generation/transfer system. Generator!Transfer Switch capacity (based on estimated existing loads and estimated additional smoke purge fan loads) does not appear to be sufficient. The existing emergency generation/transfer system may be utilized to serve the additional loads if and only if sufficient system capacity is available to serve such loads. The estimated cost to provide electrical senices for Items No. 1 and No. 2 have been included within the following respective Opinions of Cost. The cost of a new emergency generator and transfer switch has been separately categorized as Item No. 6. This Opinion of Cost is applicable if and only if required by design phase electrical load calculations. 14. The existing intelligenuaddressable fire alarm control panel (Notifier AFP 200) is capable of initiating required fire alarm control sequences associated with the smoke evacuation system. SUMMARY OF PROPOSED MODIFICATIONS AND AND ADDITIONS AND OPINION OF PROBABLE COST: 1 Re-establish outside air intake for units and install demand ventilation controls (C02 sensors) to limit outside air quantity. Construction Cost: $ 40, Macintosh HO:Users.rmaccoy :Library.Containers:com. apple.maii:data:library: Mail Downloads : C6-40C2-A21 E. E27 A46C5EC3E:Report_ doc

8 Mr. Rawley McCoy, A.I.A. Page 6 of 6 2 Install a mechanical smoke evacuation system to serve each cell and the day rooms. Construction Cost: $202, Perform air balance for the entire building. Construction Cost: $ 27, Increase size of return grilles for units serving cells. Construction Cost: $ 6, Install security type return air transfer grilles from cells to day rooms. Construction Cost: S 39, Replace existing 50[kw] generator and transfer switct1 with new?o(kw] generator and transfer switch (if required by design phase electrical load calculations). Construction Cost: $ 30, TOTAL $304, (Excluding Item No. 6) $334, (Including Item No. 6) Projects are listed in order of perceived importance at this time. No.1, No. 2 and No. 3 are of equal concern. STRIDDE, CALLINS & ASSOCIATES, INC. F-6328 R. David Morales, P.E. DM/pg Macintosh HD:Users:rmaccoy:Library:Conta1ners.com.a pp!e. mail: Data :Library: Mail Down!oads:6D D4C6-4 OC2-A21 E E27A46C5EC3E Report_ doc