Appeal 33596

Fire Code Chapter 36 Section 3604.2 Standpipes

2022 Oregon Fire Code Chapter 36 Section 3604.2 Standpipes.
"Marinas and boatyards shall be equipped throughout with standpipe systems in accordance with NFPA 303. Systems shall be provided with hose connections located such that no point on the marina pier or float system exceeds 150 feet (15240 mm) from a standpipe hose connection."

Requesting to use the existing standpipe system and remove the permitted/proposed standpipe extension from the project scope, this modification would result in a maximum hose lay distance of 197 ft from existing standpipe hose connection to farthest section of float.

The existing 5ft x 65 ft timber float on site will not be modified with an attached 6" fire connection and supports to maintain its use and limit loading on the existing walkway. Fire protection for the existing and proposed floats within the project area will be provided by the nearest existing standpipe hose connection. This results in a maximum hose lay length of 197 ft from existing standpipe hose connection to farthest edge of float.

The existing floats are not capable of supporting the weight of a permanent fire line due to age and insufficient design. Modifying or replacing the aging timber float to meet this need is beyond the scope of Foss’s aquatic resources permits with the City of Portland, Corps of Engineers, Department of State Lands and Department of Environmental Quality. Specifically, all of these permits are conditioned such that new overwater structures in the Willamette River be offset by removing existing structures at a rate of 1:1.

The alternative design would involve using the existing standpipe system to serve the new floats. While the hose lay length is longer than the 150 ft distance required by NFPA 14, the project will maintain or slightly improve the status quo for fire-fighting operations at the site. Specifically, the current hose lay length at the facility is 288 feet. The proposed design will decrease this to 197 ft. The existing timber floats have also been replaced with more fire resistant steel floats.

Risk to fire fighting operations is also mitigated because the moorage is used exclusively for Foss tugboats, all of which are equipped with advance fire detection and response systems. Each vessel is outfitted with a 120gpm @ 60psi fire system on board with a minimum of 2 fire stations with 50ft hoses. Additionally, many vessels are also outfitted with a 1010gpm @ 160psi fire monitor. All crews preform fire drills weekly and are trained in the usage of different types of fire extinguishers to the STCW standard. The company also has a comprehensive company wide safety manual regarding fire safety at the facility.