Appeal 33668

OSSC 403

403.1 Applicability. High-rise buildings shall comply with Sections 403.2 through 403.6.

Request for relief from some OSSC 403 high rise building provisions as noted in the proposed design.

The Pepsi B will be an 8-story apartment building with 5 stories of Type IIIA construction over 3 stories of Type IA construction. The two construction types are separated by a 3-hour horizontal fire rated assembly and protected throughout with an NFPA 13 automatic sprinkler system.

While the top occupied story of the building will be located less than 75 feet above the lowest level of fire department access, the building will have an occupied roof deck, which will be located 8 feet above this height. The occupied roof area will be for the private use of owners, residents and guests only, with no access to the general public.

The proposed design will mitigate the increased risk to occupants on this roof deck by including some high-rise building provisions that add value plus other fire and life safety provisions that provide direct relief to those on the terrace in an emergency. The intent is to be provide equivalent safety to the roof terrace occupants without burdening the project with cost that does not provide value to these small number of occupants or the rest of the building occupants.

The key elements proposed are those that provide protected access to the emergency personnel and safe egress to the roof level occupants. This responds directly to the additional distance each group has to travel in an emergency. Additional measures increase the overall safety level for this building, even though it may not be directly related to the occupants on the roof. This will reduce the probability of a serious fire event at the roof level and make this design even more robust.

A comparison against all of the high-rise provisions is included in the “reason for the alternative” section so that the appeal board can compare this proposal against a standard high-rise building. We are requesting relief from the following high-rise requirements:

• SFRM bond strength of 430 psf.
• Secondary water supply.
• Manual wet standpipe system is provided in lieu of automatic standpipe system.
• Emergency voice alarm communication system
• Emergency phone communication shall be provided only in Stair #1 going to the roof.
• Oregon Electrical Specialty Code Article 330 requirement to use MC Cable in high rise buildings.
• Fire command closet provided at the entrance lobby as shown on Exhibit A in lieu of a Fire Command Center. The Fire Command Closet will be separated from the remainder of the building by 1-hr fire barrier construction and 45-minute opening protection. The following systems/equipment will be provided: fire detection and alarm system annunciator, fire alarm control panel complying with NFPA 72, sprinkler valve and waterflow detector display panels, emergency and standby power status indicators, telephone with controlled access, fire pump status indicators,
• Smoke removal is not provided
• We are also requesting relief for the non-pressurized stair from the requirements for stairway door unlocking, smokeproof enclosures for exit stairs, pressurization of elevator shafts, and luminous egress path markings.
• Access to fire pump room will not be through a fire rated passageway from an exit stair as required by NFPA 20 in high rise buildings.
• Any other code provisions triggered by the high-rise classification and not specifically listed below as being provided are exempted from the design.

The proposal will meet the following high-rise requirements:
• The building will be equipped throughout with an automatic sprinkler system in accordance with (NFPA 13) as required by Section 903.2.1.6.
• A fire pump will be provided, in a pump room separated from the rest of the building by 2-hour rated fire barrier;
• Smoke detection will be provided throughout the building.
• An emergency generator will be provided and separated from the rest of the building by a 2-hour fire barrier.
• Fuel line piping protection for generator fuel piping shall be provided as required by section 403.4.8.2.
• Generator shall be sized to support standby and emergency back-up loads.
• Exit stairways will be at least 30 feet from each other.
• The exit stair providing access to the roof (Stair #1) will be pressurized as required for a smoke proof enclosure.
• Two-way communication shall be provided in Stair #1 providing access to the roof.
• An enclosed elevator lobby shall be provided at the hoistway on all floors except the discharge level. Elevator hoistway doors shall be smoke and draft control rated at the 2nd floor, where no lobby is provided, meeting section 3006.3 requirements.
• The pressurized exit stairway doors will be smoke and draft control rated with an “S” label.

The proposal will provide these additional measures to provide safer access and egress from the terrace:
• The means of egress corridor connecting the two exit stairs at the 8th floor shall be upgraded to a 1-hour rated fire partition with 45-minute rated doors, see Exhibit A attached.
• The portion of the 8th floor corridor from the amenity space to Stair #1 shall be upgraded to 1-hour fire barriers with 60-minute rated doors.
• The internal stair connecting the amenity space to the occupied roof deck (Stair #3) will be 5 feet wide.
• Vertical standpipe will be extended to the landscaped occupied roof.
• The doors into the exit stair #1 providing access to the roof shall have panic hardware on the roof and 8th floor levels.
• Two accessible means of egress, including an elevator, per Section 1009.2.1;
• Two elevators serving as the accessible route connecting each accessible story and the occupied roof per Section 1104.4;
• Satisfying the 2021 Portland Fire Code section D105.7 Alternate to aerial fire apparatus roads. In this instance the stair will be enclosed in a 3-hour enclosure at the bottom of the building, which will exceed the prescriptive requirements for aerial access.

RECONSIDERATION TEXT:
The proposed design will meet the requirements for a high-rise per OSSC Section 403 except as follows:
• SFRM bond strength of 430 psf will not be provided.
• Secondary water supply will not be provided.
• Emergency voice alarm devices will only be provided in public corridors and public spaces.
• The fire pump room will be accessible in the parking garage will be in compliance with Building Official Determination 21-02.
• Automatic standpipe will not be provided. A manual wet standpipe system to provide pressure to all sprinklers will be provided.
• Fire command closet will be provided at the entrance lobby as shown on Exhibit A in lieu of a Fire Command Center. The Fire Command Closet will be separated from the remainder of the building by 1-hr fire barrier construction and 45-minute opening protection. The following systems/equipment will be provided: fire detection and alarm system annunciator, fire alarm control panel complying with NFPA 72, sprinkler valve and waterflow detector display panels, emergency and standby power status indicators, telephone with controlled access, fire pump status indicators.
• Emergency Escape and Rescue openings will only be provided on the second floor, due to only having one means of egress. Not a high-rise requirement, but included for clarity.
• Smoke removal will not be provided.

With a height approximately 83 feet above the lowest level of fire department access, the occupied roof exceeds the high-rise threshold of 75 feet. The proposed design includes a base of Type I-A construction with 3-hour separation from the upper structure. The code does not provide a nuanced code path to the OSSC 403 high-rise requirements, so this appeal is for a customized approach based on compliance with many of the requirements, exceeding some, and requesting relief from others:

• 403.1 Applicability – High-rise buildings shall comply with Sections 403.2 through 403.6.

• 403.2 Construction – No reduction in fire resistance rating requested. Building exceeds.

• 403.2.2 Seismic Considerations – All buildings fall under Category-II; no special requirements apply. Building complies.

• 403.2.3 Structural Integrity of Interior Exit Stairways and Elevator Hoistway Enclosures – Not applicable. Building complies.

• 403.2.4 Sprayed Fire-Resistant Materials (SFRM) – The bond strength of the SFRM installed throughout the building shall be in accordance with Table 403.2.4. Relief is requested from SFRM bond strength requirement of Table 403.2.4.

• 403.3 Automatic Sprinkler System – Building will be fully sprinklered per Section 903.3.1.1. Building complies.

• 403.3.3 Secondary Water Supply – A standpipe is provided at each of the stairs, and adequate water is available. Relief is requested from Section 403.3.3 for secondary water supply.

• 403.3.4 Fire Pump Room – A fire pump is not required but is provided in a fire pump room separated from the rest of the building by a 2-hour fire barrier. Building exceeds.

• 403.4.1 Smoke Detection – Provided throughout the building. Building complies.

• 403.4.2 Fire Alarm System – Provided throughout the building. Building complies.

• 403.4.3 Standpipe System – Provided throughout in all enclosed exit stairs of the building. Building complies.

• 403.4.4 Emergency Voice/Alarm Communication System – Audio-visual fire alarm notification will be provided. Relief is requested from Emergency Voice/Alarm Communication System.

• 403.4.5 Emergency Responder Radio Coverage – A Public Safety Distributed Antenna System (DAS) will provide enhanced two-way radio service, ensuring that first responders can maintain wireless communications within the building. Relief is requested from Emergency Responder Radio Coverage.

• 403.4.6 Fire Command – The building will be provided with a Fire Operations Room, located near the west entrance, to allow the incident command officer to effectively manage resources. Relief is requested from Fire Command Center complying with Section 911.

• 403.4.7 Smoke Removal – Relief is requested from smoke removal.

• 403.4.8 Standby and Emergency Power – Emergency generator and tank is provided inside the building. The generator room is separated from the rest of the building by 2-hour fire barrier. Building exceeds.

• 403.5.1 Remoteness of Interior Exit Stairways – Two exit stairs are located more than 30 feet apart. Additional exit stair is not required and not provided. Building complies.

• 403.5.3 Stairway Door Operation – Stairway door unlocking to be provided at the enclosed stair extending to the occupied roof. Relief is requested from stairway door unlocking requirement for the second egress stair.

• 403.5.3.1 Stairway Communication System – Stairway communication system is provided at the enclosed stair extending to the occupied roof. Relief is requested from stairway communication system for the second egress stair.

• 403.5.4 Smokeproof Enclosures – Stair pressurization is provided at the enclosed stair extending to the occupied roof. The elevators are protected with a smokeproof lobby and smoke curtains on the hoistway enclosure. Relief is requested from smokeproof enclosures and shaft pressurization for the second exit stair.

• 403.5.5 Luminous Egress Path Markings – Luminous egress markings are provided at the pressurized stair to the roof. Relief is requested from luminous egress markings for the second egress stair.

• 403.5.6 Emergency Escape and Rescue – Emergency Escape & Rescue openings will be provided. Relief is requested from Emergency Escape and Rescue

• 403.6 Elevators – Elevator hoistway door opening shall be protected per section 3006.3. Two-way communication is provided at elevators per section 3008.6.6. Building complies.

• 403.6.1 Fire Service Access Elevator – Fire service access elevator is not required and not provided. Building complies.

Equivalent and additional protection is provided by enhanced fire-resistive construction due to podium building and not taking advantage of available fire-resistive reductions. We are providing 2-hour protected stairs with a 3-hour base, standpipes provided in all stairs, fire pump provided and located in a room separated by a 2-hour fire barrier, smoke detection and fire alarm throughout the building, emergency responder radio coverage, emergency generator separated by 2-hour fire barrier, emergency escape and rescue openings, and smoke protection at elevator door openings. Additionally we are providing an enhanced means of egress corridor connecting the two exit stairs at the 8th floor as described in the proposed design section and including a 5 feet wide exit access stair from the roof level to the amenity room as shown on the attached plans.

These additional mitigations, combined with the robust building construction as designed, provide protection and reduce the overall risk similar to a mid-rise building. Therefore, we urge you to approve this appeal.

RECONSIDERATION TEXT:
The proposed design is a high-rise, but only the occupied roof deck is above 75’. Code requirements for high rise life safety will include both pressurized stairs, luminous egress markings, a fire pump to provide pressure for all sprinklers, structural integrity for stairways and elevators, smoke detection and fire alarm throughout, emergency responder radio coverage, and elevator hoistway protection with communication device at each elevator landing.

The proposed design is to not provide, based on discussions, the bond strength of SFRM, secondary water supply, and smoke removal. The proposed design will provide alternative protection measures to the following, the fire pump room will be accessible in the parking garage will be in compliance with Building Official Determination 21-02, manual wet standpipes providing pressure for all sprinkler operations, emergency voice alarm devices provided in public corridors and public spaces, fire command closet provided at the entrance lobby in lieu of a Fire Command Center, and emergency escape and rescue openings will only be provided on the second floor.

The proposed design provides equivalent protection based on all interior floors are less than 75’ above lowest level of firefighter access and request approval of this appeal.