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BCC Ruling No. 97-43-585

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BUILDING CODE COMMISSION DECISION ON B.C.C. #97-43-585

IN THE MATTER OF Subsection 24 (1) of the Building Code Act, 1992.

AND IN THE MATTER OF Sentence 3.2.1.4.(1) and 3.2.1.4.(2) of "the Building Code" (Ontario Regulation 419/89 as amended by Ont. Reg. 183/88, 581/88, 11/89 and 115/89).

AND IN THE MATTER OF an application by Mr. Robert Riddell, Senior Technical Specialist, Algoma Steel Inc., 105 West Street, Sault Ste. Marie, Ontario, for the resolution of a dispute with Mr. Maurice Kukoraitis, Director of Engineering, City of Sault St. Marie, Ontario, concerning whether the floor assemblies above the oil cellar and caster basement provide sufficiency of compliance with Sentences 3.2.1.4.(1) and (2) of the Ontario Building Code (OBC), whether the openings in the said floor assemblies provide sufficiency of compliance with Sentence 3.1.8.1.(2) of the OBC, and whether the number of exits from the caster basement provide sufficiency of compliance with Sentence 3.4.2.1.(2) at the Direct Strip Production Complex, Algoma Steel Inc., 105 West Street, Sault Ste. Marie, Ontario.

APPLICANT

Mr. Robert Riddell, Senior Technical Specialist
Algoma Steel Inc., 105 West Street
Sault Ste. Marie, Ontario

RESPONDENT

Mr. Maurice Kukoraitis, Director of Engineering
City of Sault St. Marie, Ontario

PANEL

Mr. Roy Philippe (Chair)
Mr. Rick Florio
Mr. Demir Delen

PLACE

Toronto and Sault Ste. Marie, Ontario

DATE OF RULING

Wednesday, September 24th, 1997

APPEARANCES

Mr. Robert Riddell
Senior Technical Specialist
Algoma Steel Inc.
The Applicant

Mr. Paul Tavares
Civil/Structural Eng
Hatch Associates
For the Applicant

Mr. Maurice Kukoraitis
Director of Engineering
City of Sault St. Marie
The Respondent

Syl Allard
Plan Examiner
City of Sault Ste. Marie
For the Respondent

RULING

  1. The Applicant

Mr. Robert Riddell, Senior Technical Specialist, Algoma Steel Inc, is a person who has been issued an order to comply under the Building Code Act, 1992 to bring the floor assemblies over the oil cellar and the caster basement of a recent addition in conformity with certain provisions of the Ontario Building Code at the Direct Strip Production Complex, Algoma Steel Inc., 105 West Street, Sault Ste. Marie, Ontario.

  1. Description of Construction

The existing building is a three and four storey industrial structure with an area of approximately 60,380 m2 (650,000 ft2). The addition, constructed between 1996 and 1997, has added another 32,520 m2 (350,000 ft2) to the structure making the current total building area 92,900 m2 (1,000,000 ft2).

The building is constructed of noncombustible construction. It is equipped with a fire alarm system. The building also has a partial sprinkler system, only in the oil cellar of the addition. It does not have a standpipe and hose system.

Within the addition there are two large depressed areas in the main floor. These areas are known as the oil cellar and the caster basement. They are located beneath the addition's major production and processing equipment and are used for servicing the machinery above and the accommodation of ancillary equipment. The floor assemblies above the oil cellar and caster basement are concrete slab supported with unprotected steel beams.

Both the existing building and the addition are considered to have a Group F, Division 3 (low hazard industrial) major occupancy. The structure, including the addition, is used to manufacture steel slabs.

  1. Dispute

There are three issues at dispute between the Applicant and the Respondent. The first is whether the floor assemblies above the oil cellar and the caster basement provide sufficiency of compliance with Sentences 3.2.1.4.(1) and (2). These provisions of the OBC require that a floor assembly above a basement must be constructed as a fire separation with a fire-resistance rating as determined in Subsection 3.2.2., but not less than 45 min. The supporting elements supporting the subject floor assembly are required to have the same fire-resistance rating as the floor. While the concrete slab floor above the oil cellar and caster basement in the Direct Strip Production Complex may provide the necessary 45 minute rating, the steel supporting beams for these floor assemblies are unprotected and therefore do not have a resistance rating.

The second dispute is whether the openings in the said floor assemblies provide sufficiency of compliance with OBC Sentence 3.1.8.1.(2), which requires that all openings in fire separations must be protected with closures. The openings at the oil cellar and the caster basement do not have closures. There are large numbers of pipes that access the mill stands, and in so doing create many openings between floor levels. As well, the steel production equipment in some areas of the complex forms part of the floor, and as it moves it periodically exposes the basement.

The last dispute is over whether the number of exits from the caster basement of the Direct Strip Production Complex provide sufficiency of compliance with Sentence 3.4.2.1.(2) of the Code. This provision allows a floor area in a Group F, Division 3 building less than two storeys in height to have a single exit if the area served is less than 200 m2, the travel distance does not exceed 25 m, and the occupant load is less than 60. Currently, the caster basement has only one exit.

  1. Provisions of the Building Code

3.2.1.4. Floor Assembly over Basement

(1) A floor assembly immediately above a basement shall be constructed as a fire separation having a fire-resistance rating conforming to the requirements for floor assemblies in Articles 3.2.2.16. to 3.2.2.62., but not less than 45 min. (2) All loadbearing walls, columns and arches supporting a floor assembly immediately above a basement shall have a fire-resistance rating not less than that required in Sentence (1) for the floor assembly.

3.1.8.1. Fire Separations and Closures

(2) Openings in fire separations shall be protected with closures, shafts or other means in conformance with Articles 3.1.8.4. to 3.1.8.17. and with Subsections 3.1.9. and 3.2.8.

3.4.2.1. Minimum Number of Exits

(2) In buildings not more than 2 storeys in building height, a floor area is permitted to be served by one exit provided the floor area and the travel distance requirements conform to Table 3.4.2.A. and the total occupant load served by the exit is not more than 60.

  1. Applicant's Position

The Applicant submitted that the building as constructed provides sufficiency of compliance with the relevant provisions of the OBC. With regard to the first dispute concerning the fire-resistance rating of the floor assemblies, including the supporting structures, the Applicant is of the opinion that hydraulic basements and oil cellars should be considered special structures under the OBC. Article 3.2.2.2. (Special and Unusual Structures) allows buildings that cannot be classified under Articles 3.2.2.16. to 3.2.2.62 to be constructed in accordance with good fire protection engineering practice as found in the NFPA Fire Protection Handbook. As they feel that the oil cellar and caster basement are special structures which have been built in conformance with NFPA practices, the Applicant believes that these areas should be exempt from the Article 3.2.1.4.

Regarding the openings between the oil cellar and the caster basement and the floor level above them, the Applicant uses the same argument as in the previous issue. Because they feel that these two areas should be classified as special structures, again the OBC provisions concerning protection of openings is not applicable. Without changing the much of the design of the equipment central to the production of steel, it would be difficult to provide closures for all the openings between these lower areas and the floor above. They point out that the oil cellar is sprinklered. They also note that they have blocked some of the openings at issue through the installation of doors as per their "closure agreement" with the city.

Concerning the number of exits from the caster basement, the Applicant again relies on the argument that this space should be considered a special structure. As they point out, since liquid steel is being processed on the west side of the basement, the only available locations to which a fire-rated exit could be built is the existing unrated stairs found in the north and south portions of the east wall. Both stairs do not exit to the exterior but rather to the mill floor as access to exits which affords each set of stairs three separate exit routes. In their opinion, constructing fire-rated stairs that lead directly to the outside in the caster basement would congest the area and would possibly confuse workers and thereby make the situation more dangerous.

  1. Chief Building Official's Position

The Respondent submitted that the Direct Strip Production Complex does not provide sufficiency of compliance with the aforementioned OBC provisions. They reject the Applicant's position that the oil cellar and caster basement should be viewed as special structures under OBC Article 3.2.2.2. The Respondent also indicated that it was not evident that a complete and adequate assessment of the entire facility according to the NFPA's good fire protection engineering practice had been carried out. Classifying the facility under Article 3.2.2.2. is not appropriate, they argue, since steel mills are specifically described under Article 3.2.2.59. Further, in their opinion, the sprinklering of the oil cellar only serves to alleviate the need for fire containment. It is not an adequate measure compensating the lack of appropriate fire-resistance rating for the subject floor assemblies, including protection of openings.

Regarding egress from the caster basement, the Respondent submitted that two exits must be provided in accordance with Sentence 3.4.2.1.(1). They feel that the exiting arrangement, as constructed, will considerably diminish the level of safety for the occupants on the caster basement level. They also believe the current travel distances are too far, and this heightens the potential danger.

  1. Commission Ruling

It is the decision of Building Code Commission that the direct strip production complex provides sufficiency of compliance with Sentences 3.2.1.4.(1) & (2), Sentence 3.1.8.1.(2) and Sentence 3.4.2.5.(1) of the building code provided that:

i) the caster basement is sprinklered.

  1. Reasons

i) The structural steel members supporting the first floor slab are very large in size and do not support the walls or roof assembly and the basement areas are sprinklered.

ii) The openings between the first floor and the main oil cellar and the caster basement are integral part of the process operation.

iii) The occupant load in the main oil cellar and the caster basement is low and only used for servicing as needed. The areas are similar to service spaces in many respects for exiting purposes.

iv) The building is ventilated to provide approximately 12 air changes/hour and would provide smoke venting in a fire emergency in excess of code standards.

v) An in-plant fire brigade with fire fighting equipment is the primary response in emergency. Training in fire safety and emergency evacuation is also provided for workers.

vi) A fire safety plan approved by the Chief Fire Official will be in place for this facility.

Dated at Toronto this 24th day in the month of September in the year 1997 for application number 1997-49.

Roy Philippe, Chair

Rick Florio

Demir Delen