Attachment 1-Risk Analysis.docx

(Attachment 1) Veterans’ Health Administration (VHA) Risk Analysis for Internal Piping Condition and Obstruction Investigation January 2020 This risk analysis is to establish the frequency for performing an assessment of the internal condition of piping of water-based fire protection systems for the presence of foreign organic and inorganic material in accordance with the National Fire Protection Association (NFPA) standard NFPA 25 (2020 edition), section 14.2.1.2, shown below.

14.2 Assessment of Internal Condition of Piping.

14.2.1 * An assessment of the internal condition of piping shall be conducted on a frequency determined by 14.2. I .1 or

14.2. I .2 for the purpose of inspecting for the presence of foreign organic and inorganic material.

14.2.1.1 An assessment of the internal condition of piping shall be conducted at a minimum of every 5 years or in accordance with 14.2.1.2 for the purpose of inspecting for the presence of foreign organic and inorganic material.

14.2.1.2* Where an assessment frequency has been established by an approved risk analysis, the assessment shall be performed at a frequency determined by the approved risk analysis.

Risk of Concern The risk of concern is a condition that would prevent the successful operation of a water-based fire protection system (e.g., a fire sprinkler system). For the purposes of this analysis, that condition would be that the piping is obstructed such that not enough water would be delivered by the sprinkler system when called upon for a fire.

Risk Analysis Statistics:

· NFPA statistics l for SPRINKLER OPERATION, EFFECTIVENESS AND PROBLEMS are shown below:

· Sprinklers operated in 92% of the fires in which sprinklers were present and the fire was considered large enough to activate them.

Only one sprinkler activated in four out of five fires in which sprinklers of any type (79%) or wet pipe sprinklers (80%) operated.

· In 97% of the fires in which one sprinkler operated, it was effective.

In three of every five (59%) incidents in which sprinklers failed to operate, the system had been shut off.

· In half (51%) of the fires in which sprinklers were ineffective, the water did not reach the fire. The above NFPA statistics cover all sprinkler hazard types and the percentages would likely be more favorable for VHA facilities since most VHA facilities are light hazard sprinkler designs. The risk to a property protected by a light hazard sprinkler system is less than the risk to a property protected by an ordinary hazard sprinkler system or an extra hazard sprinkler system because light hazard sprinkler systems require less water for successful operation upon demand than ordinary hazard or extra hazard sprinkler systems. The NFPA data also shows that when a sprinkler system did not operate, or was not effective after operation, it is not likely that the problem was due to piping that was internally obstructed.

· Since its inception in 2007, the VHA Fire Incident Data system 2 has recorded over fifty fires that activated automatic suppression systems. Of these fires, there were only three fires where more than one sprinkler operated. This included two fires where three sprinklers operated and one fire where two sprinklers operated. VHA data is consistent with the NFPA data.

Hydraulics/System Design:

· Most sprinkler systems are hydraulically designed in accordance with NFPA 13, which requires the piping to be sized large enough to have five or more sprinklers operate to control a fire. The pipe sizes required to meet the NFPA 13 design requirements to provide for a typical hydraulically designed system are much larger VHA Risk Assessment for Internal Piping Condition and Obstruction Investigation January 2020 than what would be necessary for a sprinkler system where less than five sprinklers would operate, which is typical in 97% of the fires as identified in the NFPA statistics. Thus, even where sprinkler piping might be partially obstructed by foreign debris or corrosion, the likelihood that there is enough water and pressure available for a light hazard sprinkler system is very good so long as the piping is not totally blocked. VHA sprinkler systems are typically designed to be electrically supervised 3 and report alarms to a remote supervision station or fire department. This ensures that sprinkler control valves that are partially closed will be reported to the fire alarm system, which will notify staff to provide prompt attention. In addition, if water flows from a single sprinkler, a water flow alarm connected to the fire alarm system will automatically call for the fire department to respond to the site. This will provide a quick response with backup manual firefighting resources to assist with suppression activities for any sprinkler system activation including a sprinkler system that might have partially obstructed piping.

Inspection Process:

· The requirements of NFPA 25, 14.3.2.2 mandate an internal examination be performed at not less than four points, which include the system valve, riser, cross main, and branch line. Conducting an examination at these four points will provide a view of the internal condition at those points, but will not provide an understanding of the internal condition of the entire system.

· Through the nonrecurring maintenance (NRM) program, VHA facilities are routinely renovated in order to update the facilities to maintain a high level of quality healthcare. As a result, the internal condition of sprinkler system piping is routinely observed during renovation activities by VHA facility personnel, as well as sprinkler contractors, allowing piping problems to be identified.

Other Tests/lnspections:

· VHA healthcare sprinkler systems are typically segregated into many zones. Each zone is provided with a control valve and water flow switch. The semi-annual water flow alarm testing that is required by NFPA 72 demonstrates that water sufficient for at least one sprinkler is reaching each zone and verifies that piping is not fully obstructed prior to the flow switch in each of the zones in the building. This routine testing of each water flow alarm switch provides a better indication that the sprinkler piping is not fully obstructed than what is required by the inspection requirements in Chapter 14.

· Routine annual and quarterly main drain testing that is required by NFPA 25 would identify fully blocked piping leading into buildings protected by sprinkler systems.

Other considerations:

· Routinely draining and refilling piping systems is known to be detrimental to black iron piping by introducing new oxygen into the system. The actual internal inspection could be more detrimental than helpful for VHA systems.

· The safety provided by the sprinkler systems remaining in service for the occupants and property protected by the systems would be reduced by removing the sprinkler systems from service to perform a routine assessment of the internal piping condition.

· VHA is required to address piping problems where there is cause to do so. NFPA 25, 14.3.1 identifies numerous triggers that require a facility to perform an obstruction investigation as follows:

(1) Defective intake for fire pumps taking suction from open bodies of water

(2) The discharge of obstructive material during routine water tests

(3) Foreign materials in fire pumps, in dry pipe valves, or in check valves

(4) Foreign material in water during drain tests or plugging of inspector's test connection(s)

(5) Unknown materials are heard in the system piping during draining, refilling, or otherwise flowing water through the system

(6) Plugged sprinklers VHA Risk Assessment for Internal Piping Condition and Obstruction Investigation January 2020

(7) The presence of sufficient foreign organic or inorganic material is found in the pipe

(8) Failure to flush yard piping or surrounding public mains following new installations or repairs

(9) A record of broken public mains in the vicinity

(10) Abnormally frequent false tripping of a dry pipe valve(s)

(11) A system that is returned to service after an extended shutdown (greater than 1 year)

(12) There is reason to believe that the sprinkler system contains sodium silicate or highly corrosive fluxes in copper systems

(13) A system has been supplied with raw water via the fire department connection

(14) Pinhole leaks

(15) A 50 percent increase in the time it takes water to travel to the inspector's test connection from the time the valve trips during a full flow trip test of a dry pipe sprinkler system when compared to the original system acceptance test Conclusion In accordance with NFPA 25, 14.2.1.2 and based on the analysis above, VHA will perform obstruction investigations where required by NFPA 25, 14.3.1, but will not routinely perform internal piping obstruction investigations in the absence of one of the triggers identified in NFPA 25, 14.3.1 noted above.

Peter A. Larrimer Larrimer 162861 Date: 2020.01.23162861

Peter A. Larrimer, PE VHA Fire Protection Operations Manager Approved:

for Operations and Management Veterans Health Administration

1 U.S. Experience with Sprinklers, Marty Ahrens, National Fire Protection Association, July 2017 2 VA Fire Incident Data is available through an internal VA intranet web site at http:llvaww.ceosh.med.va.gov/01FS/Pages/FirelncidentReporting.shtml 3 The Life Safety Code generally requires new sprinkler systems to be electrically supervised. In addition, it is VA practice to provide electrical supervision for sprinkler systems even when electrical supervision is not required.

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