BUILDING CODE COMMISSION

Transcription

1 Ruling Numbers and Application Numbers and BUILDING CODE COMMISSION IN THE MATTER OF Subsection 24 (1) of the Building Code Act, AND IN THE MATTER OF Sentence (1) and Articles , and of Regulation 403, as amended by O. Reg. 22/98, 102/98, 122/98, 152/99, 278/99, 593/99, 597/99 and 205/00 (the Ontario Building Code ). AND IN THE MATTER OF an application by Mr. Richard Cerny, V.P. Construction, Matthews Southwest Properties Inc., Mississauga, Ontario, for the resolution of two disputes with Mr. Agris Robeznieks, Chief Building Official, City of Mississauga, Ontario, to determine whether the building s proposed power system, that includes two independent supply connections to two separate street substations and one on-site co-generation plant, offered in lieu of a power supply system conforming with Article of the Ontario Building Code (OBC) provides sufficiency of compliance with Sentences (1) and (4) of the OBC, and also to determine whether the proposed sprinkler system design offered as an alternative to NFPA 13, Standard for the Installation of Sprinkler Systems, provides sufficiency of compliance with Sentence (1) of the OBC at the Bell Mobility Centre, 5099 Creekbank Road, Mississauga, Ontario. APPLICANT RESPONDENT PANEL PLACE Mr. Richard Cerny, V.P. Construction Matthews Southwest Properties Inc. Mississauga, Ontario Mr. Agris Robeznieks Chief Building Official City of Mississauga Dr. Kenneth Peaker, Chair Mr. John Guthrie Mr. Fred Barkhouse Toronto, Ontario DATE OF HEARING March 29 th, 2001 DATE OF RULING March 29 th, 2001 APPEARANCES Mr. Frank Verri, Agent Frank Verri and Associates Inc. Mississauga, Ontario Agent for the Applicant Mr. Greg Phelps Supervisor - Fire Prevention Department Mississauga, Ontario Designate for the Respondent

2 -2- RULING 1. The Applicant Mr. Richard Cerny, V.P. Construction, Matthews Southwest Properties Inc., Mississauga, Ontario, has received a building permit under the Building Code Act, 1992 and is currently constructing an office complex known as the Bell Mobility Centre, 5099 Creekbank Road, Mississauga, Ontario. 2. Description of Construction The Applicant is constructing a new office complex comprised of three separate oval-shaped towers, two of which will be six stories (the north and east towers) and one is to be four stories (the south tower). The ground floor, which is shared by all three towers, is to contain a call centre. The buildings are also connected at the lower ground floor (or concourse level). This space will be allocated for retail uses. Below this will be two levels of parking (referred to as floors P1 and P2) serving the entire complex with enough space for roughly 1,600 cars. A portion of the P1 level is to contain some amenity space that is to include washrooms, a lounge, internet stations and a games/arcade room. (The amenity portion of the P1 floor area was the subject of a different BCC hearing - BCC Ruling No ) The overall complex is classified as having a Group D - Business and Personal Services (office) occupancy with an ancillary Group E - Mercantile (retail) occupancy on the lower ground floor level. The building is described as six storeys in building height (not considered a high building under OBC ) and 79,247 m 2 (852,693 ft 2 ) in building area. It is of noncombustible construction and will be equipped with a full sprinkler system, a fully addressable fire alarm system and a standpipe and hose system complete with 38 and 63.5 mm (1 ½ and 2 ½ in) hose outlets. The construction in dispute involves two areas; the emergency power supply to the building and the design of the sprinkler system. Regarding power supply, it is the Applicant s intention not to maintain an on-site store of fuel to supply back-up generators nor to install individual battery packs throughout the building to provide emergency power. Instead, as an alternative source of normal and emergency power, he is proposing that the building be supplied by two independent 13.8 kv substations that will be connected to the local hydro utility. In addition, a co-generation plant is to be constructed that will generate power on-site and will be used primarily as a source of energy for the complex during daily peak demand power periods (when the hydro power rates are high). A switchboard system will automatically transfer electrical supply to the building between the two hydro substations and the co-generation plant. According to the Agent s (for the Applicant) submission, (t)he co-generation plant will be a separate, fire-rated structure attached to the building. The plant will contain four 1250 kw, 600V, 60 Hz generators driven by natural gas supplied by the local utility. They will be installed in accordance with requirements of CAN/CSA-C282-M89, Emergency Electrical Power Supply for Buildings with the exception of paragraph 6.4 Fuel Supply. As noted, an on-site fuel supply will not be provided as required by CAN/CSA-C282-M89. However, (t)he residual fuel supply available to the co-generation plant in the event that the main gas valve is closed at the street will allow engines to operate for 30 minutes. To provide the anticipated 400 kw of emergency power required for lighting, building services and fire alarms in the event of a sudden loss of utility power,

3 at least one generator will be kept running all the time so that it will be ready to pick up the life safety related loads within fifteen (15) seconds as required. -3- In essence, the Applicant s proposal is to provide a normal, daily power supply system that receives energy from a variety of sources which, in the Applicant s view, obviates the need for an independent, dedicated emergency back-up system. The second area of dispute involves the corridor and office configuration and the proposed sprinkler system design. In particular, the Applicant is proposing a unique interior design for the office floors of the north, east and south towers of the complex where the main corridors would rise the full height (3.48 m, 11 ft, 5 in) between the floor slab and the underside of the floor slab above. For the areas where the actual offices and work stations would be located the Applicant is proposing a typical drop ceiling installation fixed at 737 mm (2 ft, 5 in) below the underside of the ceiling slab. The construction in this ceiling cavity contains, in the Agent for the Applicant s words, virtually no combustible material. The perimeter walls, where the offices meet the corridors under this proposal, would not be extended to the underside of the floor slab above. Instead, these walls would terminate at the height of the drop ceiling. The Applicant is proposing to provide sprinkler heads in the ceiling of the office area, but not in the concealed space above. In addition, in the corridor near the opening where the upper portion of the corridor walls meet the ceiling cavity, the Applicant is also proposing to hang from the slab above (at the same height as the office ceiling) a 457 mm (18 in) wide noncombustible cable tray for the many communication wires, cables and fibre optics. The construction in dispute involves the opening where the corridors connect to the ceiling cavity and the lack of sprinklering in the concealed space above the offices. In more typical office interior design the drop ceiling would either cover the entire floor area or be fully enclosed. In other instances the drop ceiling may be omitted completely. As an alternative to either providing a fully enclosed ceiling space or sprinklering the ceiling cavity, the Applicant is proposing to protect the opening or connection between the corridor and the ceiling cavity by installing closely spaced, quick response sprinklers in the corridors near the underside of the ceiling slab (305 mm, 12 in or less) above the office perimeter walls. The Applicant is also proposing to construct a baffle that is attached to, and projects 584 mm (23 in) down from the ceiling slab so that it terminates within 152 mm (6 in) of the top of the drop ceiling. This baffle is to run the length of the opening and would be set back into the space above the drop ceiling by approximately 305 to 457 mm (12 to18 in), as measured from the outer side of the office perimeter wall and sprinkler head above. The Applicant is proposing this interior office design and sprinkler system installation because the building s occupant - a telecommunications corporation - will require nearly continuous access to the cable trays and hence the trays are intended to be put in the upper portions of the corridors. Extending the perimeter walls to the underside of the ceiling slab would not be feasible, in the Agent s opinion, due to the number of cables that would run from the cable trays to serve the adjacent office floor areas. In addition, the Agent notes that (i)nstalling sprinkler heads above the finished ceilings is also not feasible due to the number of obstructions located above the finished ceilings and the logistics of maintaining unobstructed sprinkler coverage. As well, the Agent notes that the full height corridors, with exposed floor slab, sprinkler lines and cable trays is the aesthetic the occupants desire.

4 -4-3. Dispute There are two issues at dispute between the Applicant and Respondent. The first dispute is whether the building s proposed power system, that includes two independent supply connections to two separate street substations and one power producing on-site co-generation plant, offered in lieu of a power supply system conforming with Article , provides sufficiency of compliance with Sentences (1) and (4) of the Ontario Building Code. Prior to examining the Code provisions in dispute it should be noted that Article pertains to the requirement for emergency power and how it is to be installed. In contrast, Sentences (1) and (4) discuss the emergency services, lighting and water supply for fire fighting respectively, and the performance thereof that are to be provided by the emergency power required in Article Similarly, Article , the provision requiring emergency power for fire alarm systems, is another service to be provided through the emergency power supply. Article of the OBC determines the installation requirements for an emergency power system. This Article states, with certain exceptions that are not applicable in the present instance, that an emergency electrical power system must be installed in accordance with CAN/CSA-C282-M, Emergency Electrical Power Supply for Buildings. Section of this standard requires that sufficient fuel supply shall be maintained on site at all times... for at least 2 h. Clause (1)(a) of Article sets out the requirements for an emergency power supply to provide for emergency lighting in the event that regular power supply is interrupted. Clause (1)(b) stipulates the length of time that the required emergency power system must provide emergency lighting. As the subject structure is not a high building nor a Group B occupancy, 30 minutes of emergency power is the required duration for lighting as mandated in Subclause (1)(b)(iii). Emergency water supply for fire fighting purposes is required by Sentence (4). In particular, this provision stipulates, with an exemption in Sentence (5) which is not applicable here, that for buildings not within the scope of Subsection (high buildings), an emergency generator capable of operating under a full load for at least 30 minutes must be provided. As noted above, the Applicant is proposing a power supply system for this complex that differs from the typical power supply hook-up for most buildings. The multiple electrical service connections and sources of power are offered as an alternative to providing two hours of fuel supply on-site. At issue is whether the Applicant s proposed power supply is equivalent, (i.e., provides sufficiency of compliance) or in fact is superior, to more typical power supply arrangements such as a single source hydro connection combined with on-site emergency back-up generators. In other words, are the engineered levels of power supply contingency the Applicant maintains has been designed into this system, adequate to permit the omission of the mandatory emergency power generation system, which is independent of the public utility grid and still meet the intent of OBC requirements? If the BCC determines that the proposed power system is an acceptable alternative, the associated question then becomes whether, in lieu of a dedicated, independent emergency back-up system, the power supply arrangement is adequate in terms of fulfilling the requirements of emergency power for lighting and water supply for fire fighting purposes. The second issue in dispute is whether the proposed sprinkler system design offered as an alternative to NFPA 13, Standard for the Installation of Sprinkler Systems, provides sufficiency of compliance with Sentence (1) of the OBC.

5 -5- This provision requires, with certain exemptions that are not applicable to the issue at hand, that sprinkler systems be designed, constructed, installed and tested according to NFPA 13, Standard for the Installation of Sprinkler Systems. As a referenced document in the OBC, in order to comply with Sentence (13), it is necessary to conform with the standards set out in NFPA 13. Again, similar to the above issue regarding the proposed emergency power supply system, the partially enclosed drop ceiling space combined with the sprinkler system configuration is not specifically addressed by the Code nor its referenced document - the NFPA 13 standard. The general rule of sprinkler protection under NFPA 13 is found in Sentence of that standard where it states that sprinkler protection is to be provided throughout the entire building unless it is specifically exempt. Section of NFPA 13 deals with concealed spaces. This Section does permit some exemptions to the requirement for sprinkler protection. Clause states that all concealed spaces enclosed wholly or partly by exposed combustible construction shall be protected by sprinklers. This provision is then followed by 10 exceptions that permit sprinklers to be waived in such spaces. This Clause and the exceptions to it, however, all deal with concealed spaces that contain at least some exposed combustible construction. As the space above the drop ceiling is comprised of non-combustible construction, the relevance of this Clause then is the corollary to it which is that a concealed space of noncombustible construction would not require sprinkler protection. Put another way, waiving sprinklers from a noncombustible concealed space may not be a specific exception under NFPA 13, but doing so is not prohibited according to that standard either. The Applicant and the Respondent appear to agree on the above reading of NFPA Where the issue arises between them, however, is whether omitting sprinklers is allowed for partially enclosed spaces as is proposed in this instance. On this matter NFPA 13 appears to be silent. The Applicant is also proposing the closely spaced sprinkler arrangement in conjunction with baffles as a method to protect the openings to the ceiling cavity. This configuration of sprinklers and baffles is permitted within NFPA 13 as a way to protect openings in floor assemblies in interconnected floor spaces. The Applicant, however, is offering this method as an alternative form of protection for an opening in a wall assembly. This method of protecting an opening in a wall assembly is not recognized by NFPA 13. At issue, therefore, is whether a concealed space constructed entirely of noncombustible construction for which no sprinklers are proposed is permitted to be only partially enclosed. In addition, do closely spaced, quick response sprinklers combined with baffles provide adequate protection for this opening to the concealed space above the drop ceiling? For the sake of convenience, since both aforementioned issues relate to the same project on the same site which is currently under construction, the Commission offered that the matters could be heard concurrently. The parties consented to a simultaneous hearing. Accordingly, the BCC s intention is to provide a single ruling document for the two items at issue. 1 The Designate submitted two Formal Interpretation documents from NFPA which described scenarios of fully concealed spaces containing near total noncombustible construction. The interpretations from NFPA indicate that no sprinklering is required in these situations.

6 -6-4. Provisions of the Ontario Building Code Sentence (1) Emergency Power for Lighting (1) An emergency power shall be (a) provided to maintain the emergency lighting required by this Subsection by a power source such as batteries or generators that continue to supply power in the event that the regular power supply to the building is interrupted, and (b) so designed and installed that upon failure of the regular power it will assume the electrical load automatically for a period of (i) 2 h for a building within the scope of Subsection , (ii) 1 h for a building of Group B major occupancy classification that is not within the scope of Subsection , and (iii) 30 minutes for a building of any other occupancy. (See Appendix A) Article Emergency Power Supply Installation (1) Except as required by Articles and , an emergency electrical power system shall be installed in conformance with CAN/CSA-C282-M, Emergency Electrical Power Supply for Buildings. (See Sentence (5) for emergency power supply for voice communication systems.) Sentence (4) Emergency Power for Building Services (4) Except as provided by Sentence (5), an emergency power supply capable of operating under a full load for not less than 30 minutes shall be provided by (an) emergency generator for water supply for fire fighting in conformance with Article , if the supply is dependent on electrical power supplied to the building, and the building is not within the scope of Subsection Sentence (1) Automatic Sprinkler Systems (1) Except as permitted by Sentence (2), (3) and (4), an automatic sprinkler system shall be designed, constructed, installed and tested in conformance with NFPA 13, Standard for the Installation of Sprinkler Systems. (See Appendix A.) 5. Applicant s Position On the issue of the emergency power supply, the Agent for the Applicant submitted that the proposed power arrangement was an alternative to that typically envisaged in the OBC. He stated that the proposal, which emphasizes multiple sources of power, is at minimum equivalent, and quite likely superior, to a conventional power supply for a building and, therefore, an emergency power system as specified under OBC Article is not necessary. And because this alternative power supply proposal provides multiple sources of energy, in essence, it negates the need to provide a separate emergency back-up system dedicated to supplying emergency power needs, including lighting and water supply for fire fighting. As such, the proposal, he asserted, provides sufficiency of compliance with the requirements of Sentences (1) and (4) of the OBC. The Agent continued that the size and nature of the building lends itself to the proposed alternate

7 -7- power arrangement. He explained that there are three sources of power, two power plants and a cogeneration plant, all of which switch back and forth using sophisticated switching equipment. In his view, this arrangement is completely adequate for the power requirements in both normal and emergency situations. The proposal aims to avoid single dependency situations that cause complete shut-downs as happened during the ice storm. However, in addition to these three sources of power, the Agent noted that they are also proposing to have 30 minutes of available natural gas fuel supply stored at the site. The Agent argued that standards other than the OBC allow more flexibility in terms of back-up power supply. The Code, he noted, does not provide alternatives. It assumes that there is only one source of power and that is from the street. The Code does not recognize that this building has two lines from the street direct to two substations and that power is actually produced on-site at the cogeneration plant. And it is because of this multiple power source arrangement, the Agent reiterated, that a dedicated emergency power system is not necessary. As support for this position the Agent submitted letters from Mulvey and Banani, his electrical engineers, stating: With two reliable sources of energy (Hydro and Gas), three different sources of power as mentioned above, including a total of four on-site generators, very sophisticated synchronizing and control switchgear arrangement, we trust the possibility of losing electrical power is essentially eliminated. We even opine that this proposed power supply arrangement will in reality provide a level of security of supply higher than that stipulated in CSA Standard C282, under which only two sources of power are provided and the diesel generator is required to cold start. The Agent noted that, as this is not a high building regulated under Subsection of the OBC, the complex is only required under Subclause (1)(b)(iii) to provide 30 minutes of emergency power to supply the light fixtures. He noted that this 30 minute supply could be possible with the installation of individual battery packs throughout the building. Nevertheless, his position was that the proposed electrical system for the project would provide normal and emergency power to all lighting fixtures throughout the building including elevators, public address systems, etc., subject to a major failure of both electrical service feeds and fuel supply to the building at the same time. The Agent further noted that for this project, again since it is not a high building within the scope of Subsection , where fire pumps are installed, (the Code) would require a minimum 30 minutes emergency power supply, provided by generators, where the fire pump is dependant (sic) on electrical supply to the building. He argued that, as with emergency lighting, the proposed electrical system, with its multiple sources of energy, would provide adequate normal and emergency power supply to satisfy the water supply for fire fighting Code requirement. The Agent also argued that NFPA 20, Standard for the Installation of Centrifugal Fire Pumps, allows more flexibility in providing emergency power to supply water for fire pumps than the OBC. He indicated that this standard permits, subject to the authority having jurisdiction, electric drive pumps to be fed from a single public or private utility, two independent public or private utilities, emergency generators, or a combination of both. As a summation of his position regarding emergency power supply, the Agent rebutted the Designate s comment that fire departments routinely cut off power sources to a property as part of their initial fire fighting strategies. He stated that the level of fire fighting pre-planning conducted by many fire departments today means that shut off of power supply is not automatic. He also reiterated that under his proposal the subject complex would receive an uninterrupted 24 hour a day power supply that would be available for emergency uses as well. In contrast, the Code only requires 30 minutes of emergency power for this building and its required emergency services.

8 -8- On the issue of sprinkler design, the Agent stated that he is proposing an alternative to the Code required NFPA 13 standard for sprinklers. His intention is to use this configuration for nearly all of the principle corridors throughout the office floors of the north, east and south towers. He said they are proposing this sprinkler configuration because they are attempting to design the building specific to its use, in this case, a high tech facility. As such, the building has countless communication wires, cables and fibre optics and in order to update, modernize and repair this equipment, they were looking for a design with maximum flexibility, referred to as a web cool approach. Their solution was to hang the cable trays in the upper portions of the corridors where they would be completely accessible with minimal disruption to the offices and the existing construction. The ceiling cavity under his proposal, the Agent noted, will be used as a plenum. The Agent provided the following rational as to why his sprinkler design proposal is acceptable as a compliance alternative : The majority of the area exposed to the ceiling (cavity) is a corridor with no combustible content. There is virtually no combustible materials located above the finished ceiling space. This alternative approach mirrors the design approach in NFPA 13 for protection of opening between floors. The proposed wall with closely spaced quick response sprinklers would prevent heat from migrating through to above the finished ceiling. The Agent noted that the baffles would be constructed throughout most of the corridors where the openings above the drop ceiling are present and in some parts of the ceiling cavity they would also provide sprinkler protection. He concluded by stating that, in his view, the proposal still meets the intent of NFPA 13 while also offering the flexibility of design and use his clients require in their building. 6. Respondent s Position Regarding the issue of emergency electrical power supply, the Designate for the Respondent submitted that the Applicant s proposal, in their view, does not comply with the OBC, nor other standards or authorizations. As they stated in their submission: Article of the OBC requires emergency electrical power to be installed in conformance with CAN/CSA-C282-M, Emergency Electrical Power Supply for Buildings. Emergency electrical power is required for this complex in the event of an interruption of the normal supply to the building. Neither the OBC nor the C282 standard appear to consider multiple electrical service connections to a building as an acceptable alternative to providing an emergency power generation system independent of the public utility grid. Under 6.4 of CAN/CSA-C282, a sufficient supply of fuel for the in-house generation of electrical energy shall be maintained on site, at all times, to operate the engine under full load for not less that (sic) two hours. BMEC authorization describes the specific terms and conditions for the use of a Natural Gas Emergency Standby Power system and the requirements for on site fuel storage.

9 The data currently submitted to this Corporation does not indicate that on site storage of fuel is included in the current design nor does it confirm that the emergency generator meets the requirements of CAN/CSA-C282-M or that it is a BMEC authorized system. -9- Consequently, we do not believe that it meets the minimum requirements of of the OBC. The Designate also added that NFPA 20 only applies to emergency power supply for fire pumps. Therefore, the flexibility the Agent claims that it provides in terms of back-up power supply is not particularly germane to the complete water supply requirements found in Sentence (4). To conclude this portion of their argument, the Designate stated that the Building Code requires two hours of fuel to be stored on-site. This is consistent with the Ontario Fire Code (which deals with the operation of buildings), specifically Part 6, which also requires two hours of emergency stored fuel. On-site storage of fuel, he argued, was necessary because fire fighters typically cut power to a property in order to reduce the risk when fighting a fire. He stated that it would be onerous on the fire department to create individual information about how each property is supplied with power. He asked that if this proposal is approved, a maintenance document for the property should be attached to the BCC decision. Lastly, the Designate commented that since this is new construction, he did not understand why the Applicant cannot meet Code. With respect to the issue of sprinkler design, the Designate submitted the following statement: Article of the OBC requires that the entire building be sprinkler protected in conformance with NFPA 13. NFPA 13 requires that the entire structure be protected with automatic sprinkler(s) unless specifically exempted. One case where protection would be exempt is within totally enclosed, noncombustible concealed spaces. To provide further clarification on the issue of spaces above suspended ceilings, we reference 1999 edition of NFPA 13, which indicates that protection is required unless the ceiling cavity is totally enclosed 2. The use of closely spaced quick response sprinklers to protect the opening into the ceiling space is not recognized by either the OBC nor NFPA 13. This type of design is typically used to augment the protection of openings through floor assemblies, such as inter-connected floor spaces, in which sprinkler protection is provided throughout both compartments, both above and below, and just at the interface. No documentation has been submitted such as an opinion or formal interpretation from NFPA to support this proposal and therefore, we are not satisfied that it provides the level of protection required by the OBC and its referenced standard. The Designate added that their opinion is based on the belief that a concealed space, in order to be a concealed space, must be totally enclosed, otherwise it cannot be defined as a concealed space. Consequently, if an area is required to be a concealed space in order to eliminate sprinklers under NFPA 13, then it should be completely enclosed. As a result, the corridor wall should be extended to the underside of the ceiling. He continued that he was concerned that the Technical Background Information memo produced by the Ministry s Housing Development and Building Branch for this particular hearing erred in concluding that a concealed space need not be totally enclosed. Because 2 The current version of the OBC (1997) references the 1996 edition of NFPA.

10 -10- of this, the Designate argued that the Ministry reached the wrong conclusion regarding the need for sprinkler protection in the ceiling cavity. He suggested that the Ministry obtain an interpretation directly from NFPA on the definition of a concealed space and the acceptability of the alternative approach. The Designate concluded by stating that the use of closely spaced, quick response sprinklers in conjunction with baffles is not described in any edition of NFPA 13 and therefore their position was that it is not an acceptable method of omitting the required sprinkler protection in the ceiling cavity. 7. Commission Ruling It is the decision of the Building Code Commission that the building s proposed power system, that includes two independent supply connections to two separate street substations and one on-site natural gas co-generation plant, does not provide sufficiency of compliance with Sentence (1) of the Ontario Building Code (OBC). It is also the decision of the Building Code Commission that the proposed sprinkler system design, which includes baffles and close-space sprinkler coverage employed to provide protection with respect to a partially enclosed concealed ceiling space, provides sufficiency of compliance with Sentence (1) of the OBC. 8. Reasons Re: Proposed Power Supply System i) Sentence (1) of the OBC, which references Article of CAN/CSA-C282-M89, requires that two hours worth of fuel be provided on-site for the purposes of operating an in-house generator. The proposed power system for the subject building provides, according to the Applicant, only 30 minutes of stored fuel supply. ii) iii) The necessary two hour fuel supply is a separate requirement articulated in the OBC than that required for the duration of emergency power for lighting, fire alarm systems and building services. The OBC (1) fuel storage requirement is irrespective of the length of time emergency power is required for services under Articles , and Indeed, the only exceptions to Sentence (1) and its referenced standard are the emergency power for hospitals and, under certain circumstances, the installation of fuel supply shut-off valves and exhaust pipes. Fire fighters routinely cut off natural gas supply to a site when approaching for fire fighting purposes. This practice would leave the proposed co-generation plant, and thereby the subject building, with far less than the required two hour fuel supply. Moreover, the lack of back-up fuel would also become an issue during calamitous weather conditions that may debilitate both near-by substations. Re: Proposed Sprinkler System i) OBC (1) references NFPA 13, Standard for the Installation of Sprinkler Systems. Subsection of NFPA 13 permits that the concealed space need not be fully enclosed.

11 -11- ii) iii) iv) The construction located in the ceiling space is noncombustible. A baffle and close-spaced sprinklers (located on the corridor side of the baffle) will be provided. The location of the close-spaced sprinkler heads will augment the protection provided by the baffle and will also protect the corridor.

12 -12- Dated at Toronto this 29 th, day in the month of March, in the year 2001 for application numbers and Dr. Kenneth Peaker, Chair Mr. John Guthrie Mr. Fred Barkhouse