CF-TownC CHR1-CS 980126 Coppell, Texas 75019
/,/~/~ The City With A Beautiful Future 972-462-0022
//__./ Box478
January 26, 1998
Mr. Pete Smith
Hichois, Jackson, Dillard, Hagar, & Smith, LLP
1800 Lincoln Plaza
~00N. Akard
Dallas, Texas ?$201
RE: Texas Department of Licensing & Regulation Inspection; Town Center Phase I Project
The TDLR representative visited Town Center on Thursday, January 22, 1998, to inspect the
Town Center Phase I.Renovation project performed in 1995. Some violations were noWd during
the inspection that we were anaware of (see attachment # 1). It wns our understanding from PSA
that the ~novstion design met state EAB requirements.
The inspector released to me a copy of TDLR's plan review worksheet datexi 8/20/95 which hsd
been sent to PSA and outlines the same violations ns noted during the walk-throush (see
attachment #2). The City never received this document. It was PSA's responsibility to
incorporate these changes into the construction contract, or file a variance request to the TDLR
during the construction period should an exemption be requested. According to TDLR, this did
not take place and therefore the City must comply.
TDLR will be submitting their report to the City outlining the requirements for compliance and
deadline for corrective action. Once this document is received, I would like to review this matter
with our legal counsel to see what recourse we may have with PSA.
Sheri Moino
Facilities Manager
cc: Clay Phillips, Deputy City Manager
~/Ken Griffin, Director of Engineering & Public Works
TDLR Inspection 1/22/98
Noted Violations During
1. No visual strobe in 2nd floor conference room and restrooms
2. All door hardware must be lever type including stairwell and
mechanical rooms
3. Drinking fountain on 2nd floor must have 2 varied height units or
remove existing one
4. 2nd floor breakroom sink must be lowered 2", cabinets underneath
sink need to be removed; pipes underneath sink must be insulated
5. Accessible stalls in all 4 restrooms must be 60" x 60" (existing is 48"
x 66"). This will require loss of 1 water closet in all 4 restrooms.
*PSA (Don Wertzberger) was notified verbally on 1/22/98 of these issues
and advised that PSA will review the inspection report to see if they have
any backup information in their records.
TEXAS DEPARTMENT OF LICENSING AND REGULATION
PLANS AND SPECIFICATIONS REVIEW WORKSHEET PROJECT NO.: EABPRJ95003327
Article 9102, T.C.S. REVIEW : EAB1995007276R
PAGE: 1
PROJECT: COPPELL TOWN CENTER RENOVATIONS
FACILITY: COPPELL TOWN CENTER
OWNER: CITY OF COPPELL
ARCHITECT: PHILLIPS SWAYER A~SOCIATES
REVIEWER: STERLING, TOM M. DATE: 08/20/95
4 ACCESSIBLE ELEMENTS AND SPACES: TECHNICAL RBQUIP. EM~NTS
APPLICATION - 4.1.6(2) ACCESSIBLE BUILDING: ALTERATIONS TO AN AREA
CONTAINING A PRIMARY FUNCTION
PROJECT - MAJOR RENOVATION OF THE SECOND FLOOR OF AN EXISTING TOWN
~ AND RENOVATIONS TO THE FIRST FLOOR FOR
ACCESSIBILITY. PARKING UNDETERMINED. PROJ~CT CONSISTS OF
OFFICES, RECORD/FILES, MAIL ROOM, COPY/WORK ROOM AND
CO1/FERENCE ROOM.
UNACCEPTABLE 4.3 ACCESSIBLE ROUTE
(1) Exterior Routes
At least one accessible route within the boundary of the site shall be
provided from public transportation stops, accessible parking and
accessible passenger loading zones, and public streets or sidewalks to
the accessible building entrance they serve. The accessible route
shall, to the maximum extent feasible, coincide with the route for the
general public unless that route would violate 4.3.2(5).
**NOTE: PLEASE'VERIFY THAT THE ACCESSIBLE ROUTE FROM THE ACCESSIBLE
PARKING SERVING THE RENOVATION TO THE ACCESSIBLE ENTRANCE TO
THE RENOVATION COMPLIES WITH THIS SECTION.
**PLEASE RESPOND.
(3) Interior Routes
At least one accessible route shall connect accessible building or
facility entrances with all accessible spaces and elements and with
all accessible dwelling units within the building or facility.
PLANS ,AND SPECIFICATIONS REVIF~WORKSHEET F"~PROJECT NO.: EABPRJ95003327
· ~rticle 9102, T.C.S. REVIEW : EAB1995007276R
PAGE: 2
PROJECT: COPPELL TOWN CENTER RENOVATIONS
FACILITY: COPPELL TOWN CENTER
REVIEWER: STERLING, TOM M. DATE: 08/20/95
UNACCEPTABLE 4.4 PROTRUDING OBJECTS
4.4.1 General
Objects projecting from walls (for example, telephones) with their
leading edges between 27 in and 80 in (685 n~n and 2030 m~) above the
finished floor shall protrude no more than 4 in (100 mm) into walks,
halls, corridors, passageways, or aisles (see Fig. 8(a)). Objects
mounted wi~h ~heir leading edges a~ or below 27 in (~85 mm) above ~he
finished floor may protrude any amount (see Fig. 8(a) and 8(b)).
Free-standing objects mounted on posts or pylons may overhang 12 in
(305 mm) maximum from 27 in to 80 in (685 mm to 2030 mm) above the
ground or finished floor (see Fig. 8(c) and 8(d)). Protruding objects
shall not reduce the clear width of an accessible route or maneuvering
space (see Fig. 8(e)).
**NOTE:i PLEASE VERIFY THAT ANY PROTRUDIN~ OBJECTS ALON~ THE
ACCESSIBLE ROUTE TO THE ACCESSIBLE ENTRANCE OF TH~
RENOVATION COMPLIES WITH THIS SECTION.
**PLEASE RESPOND.
**NOTE: THERE APPEARS TO BE NO PROTRUDING OBJECTS WITHIN THE
RENOVATION.
**OK.
UNACCEPTABLE 4.5 GROUND AND FLOOR SURFACES
4.5.1 General
Ground and floor surfaces along accessible routes and in accessible
rooms and spaces including floors, walks, ramps, stairs, and curb
ramps, shall be stable, firm, slip-resistant, and shall comply with
4.5. Soft or loose materials such as sand, gravel, bark, mulch or
wood chips are not suitable. Cobblestone and other irregular surfaces
having a texture that constitutes an obstacle or hazard, such as
improperly laid flagstone, shall not be a part of accessible routes,
spaces and elements.
**NOTE:I PLEASE VERIFY THAT GROUND SURFACES ALONG TH~ EXTERIOR
ACCESSIBLE ROUTE TO THE ACCESSIBLE E1TI~%NCE TO ~
RENOVATION COMPLY WITH THIS SECTION.
**PLEASE RESPO~TD.
**NOTE:2 FLOOR SURFACES WITHIN THE RENOVATION APPEAR TO COMPLY WITH
WITH THIS SECTION.
**OK.
UNACCEPTABLE 4.6 PARKING AND PASSENGER LOADING ZONES
4.6.1 Minimum Number
PLANS,AND SPECIFICATIONS REV?'~ WORKSHEET ~ PROJECT NO.: EABPRJ95003327
Article 9102, T.C.S. REVIEW : EAB1995007276R
PAGE: 3
PROJECT: COPPELL TOWN CENTER RENOVATIONS
FACILITY: COPPELL TOWN CENTER
REVIEWER: STERLING, TOM M. DATE: 08/20/95
Parking spaces required to be accessible by 4.1 shall comply with
4.6.2 through 4.6.5. Passenger loading zones required to be
accessible by 4.1 shall comply with 4.6.5 and 4.6.6.
**NOTE: PLEASE VERIFY THAT ACESSIBLE PARKING SPACES INCLUDING "VAN
ACCESSIBLE" AND SI~NAGE FOR ACCESSIBLE SPACES SERVING THE
RENOVATION COMPLY WITH THIS SECTION.
**PLEASE REPOND.
UNACCEPTABLE 4.7 CURB RAMPS
4.7.1 Locations
Curb ramps complying with 4.7 shall be provided wherever an accessible
route crosses a curb.
**NOTE: PLEASE VERIFY THAT ANY CURB RAMPS ALONG TH~ ACCESSIBL~ ROUTE
TO TH~ ACCESSIBLE ENTP~%NCE TO T~E RENOVATION COMPLY WITH
THIS SECTION.
**PLEASE RESPOND.
UNACCEPTABLE 4.8 RAMPS
4.8.1 C~eneral
(1) Any part of an accessible route with a slope greater than 1:20
shall be considered a ramp and shall comply with 4.8.
**NOTE:i PLEASE VERIFY THAT ANY RAMPS ALON~ THE ACCESSIBLE ROUTE TO
THE ACCESSIBLE ENTRANCE TO TH~ RENOVATION COMPLY WITH THIS
SECTION.
**PLEASE RESPOND.
BLANK
**NOTE:2 THERE APPEAR TO BE NO RAMPS WITHIN THE INTERIOR OF THE
RENOVATION.
**OK.
4.9 STAIRS
UNACCEPTABLE 4.10 ELEVATORS
4.10.1 General
(1) Accessible elevators shall be on an accessible route and shall
comply with 4.10 and with the ASME A17.1-1990, Safety Code for
Elevators and Escalators. Freight elevators shall not be considered
as meeting the requirements of this section unless the only elevators
provided are used as combination passenger and freight elevators for
the public and employees.
PLANS AND SPECIFICATIONS REVIF;~WORKSHEET ~ROJECT NO.: EABPRJ95003327
~rticle 9102, T.C.S. - . REVIEW : EAB1995007276R
PAGE: 4
PROJECT: COPPELL TOWN CENTER RENOVATIONS
FACILITY: COPPELL TOWN CENTER
REVIEWER: STERLING, TOM M. DATE: 08/20/95
**NOTE: PLEASE VERIFY THAT ELEVATOR ALONG INTERIOR ACCESSIBLE ROUTE
COMPLIES WITH THIS SECTION.
**PLEASE RESPOND.
NOT NOTED 4.11 PLATFORM LIFTS (Wheelchair Lifts)
NOT NOTED 4.12 WINDOWS
UNACCEPTABLE 4.13 DOORS
4.13.1 General
Doors required to be accessible by 4.1 shall comply with the
requirements of 4.13.
**NOTE: NO DRAWINGS OR REMARKS WEP, E FOUND TO DETERMINE IF NEW AND
ALTERED DOORS AND ACCESSIBLE ENTRANCE ARE BEIN~ PROVIDED WITH
DOOR HARDWARe, DOOR OPENING FORCE, DOOR SWEEP TIM~AND
THRESHOLDS THAT CO~PLY WTIH THIS SECTION.
**PLEASE RESPOND.
UNACCEPTABLE 4.14 EN~3%NCES
4.14.1 Minimum Number
Entrances required to be accessible by 4.1 shall be part of an
accessible route complying with 4.3. Such entrances shall be
connected by an accessible route to public transportation stops, to
accessible parking and passenger loading zones, and to public streets
or sidewalks if available (see 4.3.2(1)). They shall also be
connected by an accessible route to all accessible spaces or elements
within the building or facility.
**NOTE: NO DRAWINGS OR REMARKS WERE FOUND TO DETERMIN~ IF ENTRANCE
TO RENOVATED BUILDING COMPLIES WITH THIS SECTION.
**PLEASE RESPOND.
UNACCEPTABLE 4.15 DRINKING FOUNTAINS AND WATER COOLERS
4.15.1 General
(1) Drinking fountains or water coolers required to be accessible by
4.1 shall comply with 4.15.
**NOTE: IF ONE DRINKING FOUNTAIN IS TO BE PROVIDED FOR THE R~NOVATED
SECOND FLOOR THEN TWO MUST BE PROVIDE WITH OWE AT ACCESSIBLE
HEIGHT AND ONE AT STANDARD HEIGHT.
**PLEASE RESPOND.
PLANS AND SPECIFICATIONS REVI~WORKSHEET ~.~PROJECT NO.: EABPRJ95003327
' Arti~l~ 9102, T.C.S. REVIEW : EAB1995007276R
PAGE: 5
PROJECT: COPPELL TOWN CENTER RENOVATIONS
FACILITY: COPPELL TOWN CENTER
REVIEWER: STERLING, TOM M. DATE: 08/20/95
NOT NOTED 4.16 WATER CLOSETS
NOT NOTED 4.17 TOILET STALLS
NOT NOTED 4.18 URINALS
NOT NOTED 4.19 LAVATORIES AND MIRRORS
4.20 BATHTUBS
NOT ~ 4.21 SHOWER ST~T.T~
UNACCEPTABLE 4.22 TOILET ROOMS
4.22.1 Minimum Number
Toilet facilities required to be accessible by 4.1 shall co~ly with
4.22. Accessible toilet rooms shall be on an accessible route.
**NOTE: TOII2~T ROOMS ON THE RBNOVAT~D SECOND FLOOR DO NOT APPP~%R TO
B~ FULLY ACCESSIBLE AS RQUIP~D BY THIS SECTION.
**PLEASE SEE CO~4ENT BELOW.
4.22.2 Doors
Ail doors to accessible toilet rooms shall comply with 4.13. Doors
shall not swing into the clear floor space required for any fixture.
**NOTE: NO DRAWINGS OR REMARKS WERE FOUND TO DETERMINE IF DOORS TO
TOILET ROOMS REQUIRED TO BE ACCESSIBLE COMPLY WITH THIS
SECTION.
**PLEASE RESPOND.
4.22.3 Clear Floor Space
The accessible fixtures and controls required in 4.22.4, 4.22.5,
4.22.6, and 4.22.7 shall be on an accessible route. An unobstructed
turning space complying with 4.2.3 shall be provided within an
accessible toilet room. The clear floor space at fixtures and
controls, the accessible route, and the turning space may overlap,
however; the only turning space provided shall not be located within a
stall.
**NOTE: CLEAR FLOOR SPACE FOR LAVATORIES, URINAL AND TURN AROUND
APPEAR TO COMPLY WITH THIS SECTION.
**OK.
4.22.4 Water Closets
If toilet stalls are provided, then at least one shall be a standard
PLANS AND SPECIFICATIONS REVIF&~WORKSHEET ~PROJECT NO.: EABPRJ95003327
· ~rt~¢l~ 9102, T.C.S. REVIEW : EAB1995007276R
PAGE: 6
PROJECT: COPPELL TOWN CENTER RENOVATIONS
FACILITY: COPPELL TOWN CF/qTER
REVIEWER: STERLING, TOM M. DATE: 08/20/95
toilet stall complying with 4.17; where 6 or more stalls are provided,
in addition to the stall complying with 4.17.3, at least one stall 36
in (915 mm) wide with an outward swinging, self-closing door and
parallel grab bars complying with Fig. 30(d) and 4.26 shall be
provided. Water closets in such stalls shall comply with 4.16. If
water closets are not in stalls, then at least one shall comply with
4.16.
**NOTE: NO DRAWING OR REMARKS WERE FOUND TO DETERMINE IF THER~ ARE
ACCESSIBLE WATER CLOSETS, GRAB BARS AND 60" WIDE
PROVIDED IN ACCESSIBLE TOILET ROO~S ON T~ SECOND FLOO~.
**PLEASE P, ESPOND.
4.22.5 Urinals
If urinals are provided, then at least one shall com~)ly with 4.18.
**NOTE: URINAL PROVIDED FOR MEN'S TOILET ROOM ON TH~ SECOND FLOOR
APPEARS TO COMPLY WITH THIS SECTION.
**OK.
4.22.6 Lavatories and Mirrors
If lavatories and mirrors are provided, then at least one of each
shall comply with 4.19. Accessible lavatories and mirrors shall not
be located within toilet stalls unless other accessible lavatories and
mirrors are provided in the toilet room.
**NOTE:i NO REMARKS WERE FOUND TO DETERMINE IF FAUCETS FOR ACCESSIBLE
LAVATORIES COMPLY WITH THIS SECTION.
**PLEASE ENSURE COMPLIANCE.
**NOTE:2 LAVATORY RIM HEIGHT, BOWL DEBTH AND INSULATION APPEAR TO
COMPLY WITH THIS SECTION.
**OK.
4.22.7 Controls and Dispensers
If controls, dispensers, receptacles, or other equipment are provided,
then at least one of each shall be on an accessible route and shall
comply with 4.27.
**NOTE: NO DRAWINGS OR REMARKS WERE FOUND TO DETERMINE IF
CONTROLS, DISPENSERS RECEPTICLES COMPLY WITH THIS SECTION.
**PLEASE ENSURE COMPLIANCE.
NOT NOTED 4.23 BATHROOMS, BATHING FACILITIES, AND SHOWER ROOMS
UNACCEPTABLE 4.24 SINKS
PLANS.A/qD SPECIFICATIONS REV?'~ WORKSHEET ~"~ PROJECT NO.: EABPRJ95003327
Artiole 9102, T.C.S. -' REVIEW : F~AB1995007276R
PAGE: 7
PROJECT: COPPELL TOWN CENTER RENOVATIONS
FACILITY: COPPELL TOWN CENTER
REVIEWER: STERLING, TOM M. DATE: 08/20/95
4.24.1 General
(1) Sinks required to be accessible by 4.1 shall comply with 4.24.
**NOTE:i SINK IN ROOM 218 DOES NOT A~PEAR TOO HAVE OPEN KNeE SPACE
REQUIRED BY THIS SECTION.
**PLEASE RESPOND.
**NOTE:2 SINK DEBTH, FAUCET AND INSULATION MUST COMLY WITH THIS
SECTION.
**PLEASE ENSURE COMPLIANCE.
ACCEPTABLE 4.25 STORAGE
NOT NOTED 4.26 HANDRAILS, GRAB BARS, AND TUB AND SHOWER SEATS
UNACCEPTABLE 4.27 COITI~ROLS AND OPERATING MECHANISMS
4.27.1 General
(1) Controls and operating mechanisms required to be accessible by 4.1
shall comply with 4.27.
**NOTE: NO DRAWINGS OR R~MARES W~RE FOUND TO DETERMIN~ IF
TEL~PHON~ OUTLETS AND ANYOTHERNEWORALTBRED CONTROLS
MOUNTING HEIGHTS COMPLY WITH THIS SECTION.
**PLEASE ENSUR~ COMPLIANCE.
UNACCEPTABLE 4.28 ALAI~MS
4.28.1 General
Alarm systems required to be accessible by 4.1 shall courtly with 4.28.
At a minimum, visual signal appliances shall be provided in buildi~s
and facilities in each of the following areas: restrooms and any
other general usage areas (e.g., meeting rooms), hallways, lobbies,
and any other area for common use.
**NOTE: ALARMS, IF PROVIDED, MUST COMPLY WITH THIS SECTION.
**PLEASE ENSURE COMPLIANCE.
NOT NOTED 4.29 DETECTABLE WARNINGS
UNACCEPTABLE 4.30 SIGNAGE
4.30.1 General
Signage required to be accessible by 4.1 shall comply with the
applicable provisions of 4.30.
PLANS AND SPECIFICATIONS REV~ WORKSHEET ~PROJECT NO.: EABPRJ95003327
'o'Art~ele 9102, T.C.S. REVIEW : EAB1995007276R
PAGE: 8
PROJECT: COPPELL TOWN CENTER RENOVATIONS
FACILITY: COPPELL TOWN CENTER
REVIEWER: STERLING, TOM M. DATE: 08/20/95
**NOTE: ANY SIGNAGE PROVIDED TO IDENTIFY TOILET ROOMS AND OTHER
PERMANENT SPACES MUST COMPLY WITH THIS SECTION.
**PLEASE ENSURE COMPLIANCE.
UNACCEPTABLE 4.31 TELEPHONES
4.31.1 General
(1) Public telephones required to be accessible by 4.1 shall comply
with 4.31.
**NOTE: IF PUBLIC TELEPHONES ARE PROVIDED THEY MUST BE CONNECTED TO
THE ACCESSIBLE ROUTE AND CO~PLY WITH THIS SECTION.
**PLEASE ENSURE COMPLIANCE.
NOT NOTED 4.32 FIXED OR BUILT-IN SEATING AND TABLES
ACCEPTABLE 4.33 ASSEMBLY AREAS
4.33. S Access to Performing Areas
**NOTE: IT APPEARS THAT ACCESS BEING PROVIDED TO PERFOP~MIN~ AREA OF
COUNCIL CHAMBER COMPLIBS WITH THIS SECTION.
*OK.
NOT NO-r~,~ 4.34 AUTO~,%TED THT,T~R MACHINES
4.35 DRESSING AND FITTING ROOMS
NOT NOTED 5 RESTAURANTS, CAFETERIAS, SNACK BARS, AND VENDIN~ AREAS
5 i GE~-~RAL
5 2 COUNTERS AND BARS
5 3 ACCESS AISLES
5 4 DINING AREAS
5 5 FOOD SERVICE LINES
5 6 TABLEWARE AND CONDIMENT AREAS
5.7 RAISED PLATFORMS
5.8 VENDING MACHINES AND OTHER EQUIPMENT
5.9 QUIET AREAS (Reserved)
NOT NOTED 6 MEDICAL CARE FACILITIES
,PLANS.AND SPECIFICATIONS REVI/'~WORKSHEET ~"~,PROJECT NO.: EABPRJ95003327
'Article 9102, T.C.S. -REVIEW : EAB1995007276R
PAGE: 9
PROJECT: COPPELL TOWN CENTER RENOVATIONS
FACILITY: COPPELL TOWN CENTER
REVIEWER: STERLING, TOM M. DATE: 08/20/95
6.1 GENEP3%L
6.2 ENTI~3~NCES
6.3 PATIENT BEDR~
6.4 PATIENT TOILET RO(~
6.5 SIZE OF AREAS OF RESCUE ASSISTANCE
6.6 INFORMATION COUNTERS ~ NURSES STATI(INS
NOT NOTED 7 BUSINESS AND MERCANTILE
7.1 G]~ERAL
7.2 S~?.~S AND SERVICE COUNTERS, T~LLER WINDOWS, INFORMATION COI~TTERS
7.3 CHECK-OUT AISLES
7.4 SECURITY BOLLARDS ~ TURNSTILES
NOT NOTED 8 LIBP, a. RIES
8.1 GENB~AL
8.2 READING AND STUDY AREAS
8.3 CH~CK-OUT AREAS
8.4 CARD CATAI~D~S ~ MAC, AZIN~ DISPLAYS
8.5 STACKS
NOT NOTED 9 ACCESSIBLE TRANSIENT LODGING
9.1 HOTELS, MOTELS, INNS, BOARDING HOUSES, DORMITORIES, RESORTS, ETC
9.2 REQUIP,]'~-WENTS FOR ACCESSIBLE UNITS, SLEEPING ROOMS AND SUITES
9.3 VISUAL ALARMS, NOTIFICATION DEVICES AND TELEPHONES
9.4 OTHER SLEEPING ROOMS AND SUITES
9.5 SHELTERS, HALFWAY HOUSES, GROUP HOMES, OTHER ESTABLISHMENTS.
NOT NOTED 10 TRANSPORTATION FACILITIES
10.1 GENERAL
· LAAIS-AND SPECIFICATIONS REV~'~'WORKSHEET ~PROJECT NO.: EABPRJ95003327
~ArtiCle 9102, T.C.S. -- REVIEW : EAB1995007276R
PAGE: 10
PROJECT: COPPELL TOWN CENTER RENOVATIONS
FACILITY: COPPELL TOWN CENTER
REVIEWER: STERLING, TOM M. DATE: 08/20/95
10.2 BUS STOPS AND TERMINALS
10.3 FIXED FACILITIES ~ STATIONS
10.4 AIRPORTS
10.5 BOAT AND FERRY DOCKS (Reserved)