36E77620R0010-004.pdf

Station:

MERCED CBOC - 570

FRESNO

Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building:

Address: 340 E Yosemite Ave, Merced, CA 95340

Leased: YES

Deficiency Information

Deficiency ID: B-MECD-3.1-1-1

PSDM Subset: Standoff Distance

Exterior/Interior: Exterior

Question: Is all parking located more than 25 feet from any side of a life safety protected VA facility or permanent structure regardless of the building height?

Results: No

Issue Comment: Vehicles are parking within 25 feet of the south side of the building. Parking immediately adjacent to the building could be closed to obtain the 25 foot separation.

Risk Level: High

Recommended Corrective Action:

Bollards, large (ram rated) planters, or similar anti-ram rated elements should be installed to protect columns and all entrance.

A combination of passive anti-ram barriers, landscaping and hardscape should be in place between all parking and the facility.

For areas where the roadway conflicts with the standoff distance, these areas should also be clearly marked (pavement treatment, signage, etc.) as “no parking/standing” zones. (This includes policies and procedure for monitoring for and proper handling of violations) All windows/glazing facing areas of standoff conflict should be fitted with anti-fragmentation film, particularly in patient drop offs and entrance vestibules.

Project Group: 570-OS-MECD-R

45% Submittal VA Comments

Facility Response: NCR

Facility Comments: NCR

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: NCR

VISN Comments: NCR

Images:

Site No. FRL-MECD - Deficiency: B-MECD-3.1-1-1

FOR OFFICIAL USE ONLY (FOUO)

1 I P a g e

FRESNO

Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building:

Address: 340 E Yosemite Ave, Merced, CA 95340

Leased: YES

Deficiency Information

Deficiency ID: B-MECD-3.1-2-1

PSDM Subset: Standoff Distance

Exterior/Interior: Exterior

Question: Are unscreened vehicles restricted from traveling within 25 feet of any side of a life safety protected VA facility?

Results: No

Issue Comment: Vehicles can travel within 25 feet of the building. There are not gates and limited fencing so all vehicles are unscreened.

Risk Level: High

Recommended Corrective Action:

Bollards, large (ram rated) planters, or similar anti-ram rated elements should be installed to protect columns and all entrance.

A combination of passive anti-ram barriers, landscaping and hardscape should be in place between all parking and the facility.

For areas where the roadway conflicts with the standoff distance, these areas should also be clearly marked (pavement treatment, signage, etc.) as “no parking/standing” zones. (This includes policies and procedure for monitoring for and proper handling of violations) All windows/glazing facing areas of standoff conflict should be fitted with anti-fragmentation film, particularly in patient drop offs and entrance vestibules.

Project Group: 570-OS-MECD-R

45% Submittal VA Comments

Facility Response: NCR

Facility Comments: NCR

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: NCR

VISN Comments: NCR

Images:

Site No. FRL-MECD - Deficiency: B-MECD-3.1-2-1

2 I P a g e

FRESNO

Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building:

Address: 340 E Yosemite Ave, Merced, CA 95340

Leased: YES

Deficiency Information

Deficiency ID: B-MECD-4.2-56-1

PSDM Subset: Patient Drop-offs

Exterior/Interior: Exterior

Question: Are patient drop-offs located at primary building entrances or other locations that provide convenient access to services without hindering the flow of traffic?

Results: No

Issue Comment: There is no patient drop off. The area in front of the building (currently parking spaces) could be modified to create a patient drop off area.

Risk Level: Low

Recommended Corrective Action:

Bollards, large (ram rated) planters, or similar anti-ram rated elements should be installed to protect columns and all entrance.

A combination of passive anti-ram barriers, landscaping and hardscape should be in place between all parking and the facility.

For areas where the roadway conflicts with the standoff distance, these areas should also be clearly marked (pavement treatment, signage, etc.) as “no parking/standing” zones. (This includes policies and procedure for monitoring for and proper handling of violations) All windows/glazing facing areas of standoff conflict should be fitted with anti-fragmentation film, particularly in patient drop offs and entrance vestibules.

Project Group: 570-OS-MECD-R

45% Submittal VA Comments

Facility Response: NCR

Facility Comments: NCR

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: NCR

VISN Comments: NCR

Images:

Site No. FRL-MECD - Deficiency: B-MECD-4.2-56-1

3 I P a g e

FRESNO

Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: SITE

Address: 340 E Yosemite Ave, Merced, CA 95340

Leased: YES

Deficiency Information

Deficiency ID: S-MECD-3.2.4-14-1

PSDM Subset: Perimeter Fences

Exterior/Interior: Exterior

Question: Is there standoff between gates and public streets to provide the security force with early warning of approaching pedestrians or vehicles?

Results: No

Issue Comment: There is no opportunity to establish a standoff area the building is accessed through a shared parking lot.

Risk Level: Medium

Recommended Corrective Action:

Considering the first point of control (site perimeter barrier) is not practical/possible for this site, hardening of the second point of control should take place. This consisting of doors and other openings protected as appropriate to the level of protection needed with or without the first point of control. This includes access control hardware, intrusion detection, surveillance, and, at selected entrances at various times, personnel for control and screening.

Project Group: 570-OS-MECD-R

45% Submittal VA Comments

Facility Response: NCR

Facility Comments: NCR

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: NCR

VISN Comments: NCR

Images:

Site No. FRL-MECD - Deficiency: S-MECD-3.2.4-14-1

4 I P a g e

FRESNO

Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: SITE

Address: 340 E Yosemite Ave, Merced, CA 95340

Leased: YES

Deficiency Information

Deficiency ID: S-MECD-3.2-5-1

PSDM Subset: Perimeter Fences

Exterior/Interior: Exterior

Question: Is there a continuous barrier of fences walls and gates?

Results: No

Issue Comment: There is no perimeter fencing or gates.

Risk Level: Medium

Recommended Corrective Action:

Considering the first point of control (site perimeter barrier) is not practical/possible for this site, hardening of the second point of control should take place. This consisting of doors and other openings protected as appropriate to the level of protection needed with or without the first point of control. This includes access control hardware, intrusion detection, surveillance, and, at selected entrances at various times, personnel for control and screening.

Project Group: 570-OS-MECD-R

45% Submittal VA Comments

Facility Response: NCR

Facility Comments: NCR

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: NCR

VISN Comments: NCR

Images:

Site No. FRL-MECD - Deficiency: S-MECD-3.2-5-1

5 I P a g e

OAKHURST CBOC - 570

FRESNO

Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: OAKHURST CBOC

Address: 40595 Westlake Dr, Oakhurst, CA 93644

Leased: YES

Deficiency Information

Deficiency ID: B-OKRT-3.1-1-1

PSDM Subset: Standoff Distance

Exterior/Interior: Exterior

Question: Is all parking located more than 25 feet from any side of a life safety protected VA facility or permanent structure regardless of the building height?

Results: No

Issue Comment: Vehicles are parking within 25 feet of the building. Parking immediately adjacent to the building could be closed to obtain the 25 foot separation.

Risk Level: High

Recommended Corrective Action:

Bollards, large (ram rated) planters, or similar anti-ram rated elements should be installed to protect columns and all entrance.

A combination of passive anti-ram barriers, landscaping and hardscape should be in place between all parking and the facility.

For areas where the roadway conflicts with the standoff distance, these areas should also be clearly marked (pavement treatment, signage, etc.) as “no parking/standing” zones. (This includes policies and procedure for monitoring for and proper handling of violations) All windows/glazing facing areas of standoff conflict should be fitted with anti-fragmentation film, particularly in patient drop offs and entrance vestibules.

Project Group: 570-OS-OKRT-R

45% Submittal VA Comments

Facility Response: Reconcile comment to "Risk Management Process: An Interagency Securiity Committee (ISC) Standard", dated August, Facility Comments: Reconcile comment to "Risk Management Process: An Interagency Securiity Committee (ISC) Standard", dated August, VISN Comments: RCC please confirm that ISC security standards apply to these leased buildings versus PSDM standards. This comment applies to all similar comments on leased buildings. Are these buildings GSA leases which uses the ISC standard or do they fall under VA's PSDM? Overall VISN comments for CCHCS (Fresno) are for RCC to please explain why the CLC and mental Health buildings

Images:

Site No. FRL-OKRT - Deficiency: B-OKRT-3.1-1-1

6 I P a g e are held to the MC standard for offsets and not MC. VISN concurs with all other RCC and facility comments.

65% Submittal VA Comments

Facility Comments:

VISN Comments:

7 I P a g e

FRESNO

Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: OAKHURST CBOC

Address: 40595 Westlake Dr, Oakhurst, CA 93644

Leased: YES

Deficiency Information

Deficiency ID: B-OKRT-3.1-1-2

PSDM Subset: Standoff Distance

Exterior/Interior: Exterior

Question: Is all parking located more than 25 feet from any side of a life safety protected VA facility or permanent structure regardless of the building height?

Results: No

Issue Comment: Vehicles are parking within 25 feet of the building. Parking immediately adjacent to the building could be closed to obtain the 25 foot separation.

Risk Level: High

Recommended Corrective Action:

Bollards, large (ram rated) planters, or similar anti-ram rated elements should be installed to protect columns and all entrance.

A combination of passive anti-ram barriers, landscaping and hardscape should be in place between all parking and the facility.

For areas where the roadway conflicts with the standoff distance, these areas should also be clearly marked (pavement treatment, signage, etc.) as “no parking/standing” zones. (This includes policies and procedure for monitoring for and proper handling of violations) All windows/glazing facing areas of standoff conflict should be fitted with anti-fragmentation film, particularly in patient drop offs and entrance vestibules.

Project Group: 570-OS-OKRT-R

45% Submittal VA Comments

Facility Response: Reconcile comment to "Risk Management Process: An Interagency Securiity Committee (ISC) Standard", dated August, Facility Comments: Reconcile comment to "Risk Management Process: An Interagency Securiity Committee (ISC) Standard", dated August, VISN Comments:

65% Submittal VA Comments

Facility Comments:

VISN Comments:

Images:

Site No. FRL-OKRT - Deficiency: B-OKRT-3.1-1-2

8 I P a g e

FRESNO

Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: OAKHURST CBOC

Address: 40595 Westlake Dr, Oakhurst, CA 93644

Leased: YES

Deficiency Information

Deficiency ID: B-OKRT-3.1-2-1

PSDM Subset: Standoff Distance

Exterior/Interior: Exterior

Question: Are unscreened vehicles restricted from traveling within 25 feet of any side of a life safety protected VA facility?

Results: No

Issue Comment: Unscreened vehicles can travel within 25 feet of the building.

Risk Level: High

Recommended Corrective Action:

Bollards, large (ram rated) planters, or similar anti-ram rated elements should be installed to protect columns and all entrance.

A combination of passive anti-ram barriers, landscaping and hardscape should be in place between all parking and the facility.

For areas where the roadway conflicts with the standoff distance, these areas should also be clearly marked (pavement treatment, signage, etc.) as “no parking/standing” zones. (This includes policies and procedure for monitoring for and proper handling of violations) All windows/glazing facing areas of standoff conflict should be fitted with anti-fragmentation film, particularly in patient drop offs and entrance vestibules.

Project Group: 570-OS-OKRT-R

45% Submittal VA Comments

Facility Response: Reconcile comment to "Risk Management Process: An Interagency Securiity Committee (ISC) Standard", dated August, Facility Comments: Reconcile comment to "Risk Management Process: An Interagency Securiity Committee (ISC) Standard", dated August, VISN Comments:

65% Submittal VA Comments

Facility Comments:

VISN Comments:

Images:

Site No. FRL-OKRT - Deficiency: B-OKRT-3.1-2-1

9 I P a g e

FRESNO

Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: SITE

Address: 40595 Westlake Dr, Oakhurst, CA 93644

Leased: YES

Deficiency Information

Deficiency ID: S-OKRT-3.2.4-14-1

PSDM Subset: Perimeter Fences

Exterior/Interior: Exterior

Question: Is there standoff between gates and public streets to provide the security force with early warning of approaching pedestrians or vehicles?

Results: No

Issue Comment: There is no opportunity to establish standoff between the site and the public street Westlake Drive. Vehicles turn directly from the street into the parking lot.

Risk Level: Medium

Recommended Corrective Action:

Considering the first point of control (site perimeter barrier) is not practical/possible for this site, hardening of the second point of control should take place. This consisting of doors and other openings protected as appropriate to the level of protection needed with or without the first point of control. This includes access control hardware, intrusion detection, surveillance, and, at selected entrances at various times, personnel for control and screening.

Project Group: 570-OS-OKRT-R

45% Submittal VA Comments

Facility Response: Reconcile comment to "Risk Management Process: An Interagency Securiity Committee (ISC) Standard", dated August, Facility Comments: Reconcile comment to "Risk Management Process: An Interagency Securiity Committee (ISC) Standard", dated August, VISN Comments:

65% Submittal VA Comments

Facility Comments:

VISN Comments:

Images:

Site No. FRL-OKRT - Deficiency: S-OKRT-3.2.4-14-1

10 I P a g e

FRESNO

Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: SITE

Address: 40595 Westlake Dr, Oakhurst, CA 93644

Leased: YES

Deficiency Information

Deficiency ID: S-OKRT-3.2-5-1

PSDM Subset: Perimeter Fences

Exterior/Interior: Exterior

Question: Is there a continuous barrier of fences walls and gates?

Results: No

Issue Comment: There is no perimeter fencing or gates at this location.

Risk Level: Medium

Recommended Corrective Action:

Considering the first point of control (site perimeter barrier) is not practical/possible for this site, hardening of the second point of control should take place. This consisting of doors and other openings protected as appropriate to the level of protection needed with or without the first point of control. This includes access control hardware, intrusion detection, surveillance, and, at selected entrances at various times, personnel for control and screening.

Project Group: 570-OS-OKRT-R

45% Submittal VA Comments

Facility Response: Reconcile comment to "Risk Management Process: An Interagency Securiity Committee (ISC) Standard", dated August, Facility Comments: Reconcile comment to "Risk Management Process: An Interagency Securiity Committee (ISC) Standard", dated August, VISN Comments:

65% Submittal VA Comments

Facility Comments:

VISN Comments:

Images:

Site No. FRL-OKRT - Deficiency: S-OKRT-3.2-5-1

11 I P a g e

VET CENTER - 570

FRESNO

Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: FRESNO VET CENTER

Address: 1320 E Shaw Ave Fresno, CA 93710

Leased: YES

Deficiency Information

Deficiency ID: B-VTCR-3.1-1-1

PSDM Subset: Standoff Distance

Exterior/Interior: Exterior

Question: Is all parking located more than 25 feet from any side of a life safety protected VA facility or permanent structure regardless of the building height?

Results: No

Issue Comment: Vehicles are parking within 25 feet of the building. Parking immediately adjacent to the building could be closed to obtain the 25 foot separation.

Risk Level: High

Recommended Corrective Action:

Bollards, large (ram rated) planters, or similar anti-ram rated elements should be installed to protect columns and all entrance.

A combination of passive anti-ram barriers, landscaping and hardscape should be in place between all parking and the facility.

For areas where the roadway conflicts with the standoff distance, these areas should also be clearly marked (pavement treatment, signage, etc.) as “no parking/standing” zones. (This includes policies and procedure for monitoring for and proper handling of violations) All windows/glazing facing areas of standoff conflict should be fitted with anti-fragmentation film, particularly in patient drop offs and entrance vestibules.

Project Group: 570-OS-VTCR-R

45% Submittal VA Comments

Facility Response: NCR

Facility Comments: NCR

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: NCR

VISN Comments: NCR

Images:

Site No. FRL-VTCR - Deficiency: B-VTCR-3.1-1-1

12 I P a g e

FRESNO

Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: FRESNO VET CENTER

Address: 1320 E Shaw Ave Fresno, CA 93710

Leased: YES

Deficiency Information

Deficiency ID: B-VTCR-3.1-1-2

PSDM Subset: Standoff Distance

Exterior/Interior: Exterior

Question: Is all parking located more than 25 feet from any side of a life safety protected VA facility or permanent structure regardless of the building height?

Results: No

Issue Comment: Vehicles are parking within 25 feet of the building. Parking immediately adjacent to the building could be closed to obtain the 25 foot separation.

Risk Level: High

Recommended Corrective Action:

Bollards, large (ram rated) planters, or similar anti-ram rated elements should be installed to protect columns and all entrance.

A combination of passive anti-ram barriers, landscaping and hardscape should be in place between all parking and the facility.

For areas where the roadway conflicts with the standoff distance, these areas should also be clearly marked (pavement treatment, signage, etc.) as “no parking/standing” zones. (This includes policies and procedure for monitoring for and proper handling of violations) All windows/glazing facing areas of standoff conflict should be fitted with anti-fragmentation film, particularly in patient drop offs and entrance vestibules.

Project Group: 570-OS-VTCR-R

45% Submittal VA Comments

Facility Response: NCR

Facility Comments: NCR

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: NCR

VISN Comments: VISN to review Leases renewal options

Images:

Site No. FRL-VTCR - Deficiency: B-VTCR-3.1-1-2

13 I P a g e

FRESNO

Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: SITE

Address: 1320 E Shaw Ave Fresno, CA 93710

Leased: YES

Deficiency Information

Deficiency ID: S-VTCR-3.2.4-14-1

PSDM Subset: Perimeter Fences

Exterior/Interior: Exterior

Question: Is there standoff between gates and public streets to provide the security force with early warning of approaching pedestrians or vehicles?

Results: No

Issue Comment: There is no standoff area at this location vehicles enter the site directly from the surrounding public streets.

Risk Level: Medium

Recommended Corrective Action:

Current fencing should be considered an equivalency. Hardening of the second point of control should also take place. This consisting of doors and other openings protected as appropriate to the level of protection needed with or without the first point of control. This includes access control hardware, intrusion detection, surveillance, and, at selected entrances at various times, personnel for control and screening.

Project Group: 570-OS-VTCR-R

45% Submittal VA Comments

Facility Response: NCR

Facility Comments: NCR

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: NCR

VISN Comments: VISN to review Leases

Images:

Site No. FRL-VTCR - Deficiency: S-VTCR-3.2.4-14-1

14 I P a g e

FRESNO

Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: SITE

Address: 1320 E Shaw Ave Fresno, CA 93710

Leased: YES

Deficiency Information

Deficiency ID: S-VTCR-3.2-5-1

PSDM Subset: Perimeter Fences

Exterior/Interior: Exterior

Question: Is there a continuous barrier of fences walls and gates?

Results: No

Issue Comment: There is a partial perimeter fence at this location (north and west sides) but no gates at any entrance.

Risk Level: Medium

Recommended Corrective Action:

Current fencing should be considered an equivalency. Hardening of the second point of control should also take place. This consisting of doors and other openings protected as appropriate to the level of protection needed with or without the first point of control. This includes access control hardware, intrusion detection, surveillance, and, at selected entrances at various times, personnel for control and screening.

Project Group: 570-OS-VTCR-R

45% Submittal VA Comments

Facility Response: NCR

Facility Comments: NCR

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: NCR

VISN Comments: VISN to review Leases

Images:

Site No. FRL-VTCR - Deficiency: S-VTCR-3.2-5-1

15 I P a g e

570 FRESNO MEDICAL

CENTER

Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: SITE

Address: Enter address here

Leased: NO

Deficiency Information

Deficiency ID: S-570-3.2.4-14-1

PSDM Subset: Perimeter Fences

Exterior/Interior: Exterior

Question: Is there standoff between gates and public streets to provide the security force with early warning of approaching pedestrians or vehicles?

Results: No

Issue Comment: There is no opportunity to establish a stand-off area at the main entrance off East Clinton Ave.

Risk Level: Very High

Recommended Corrective Action:

Perimeter Barrier – Using a series of fencing, gates, bollards, and other active and passive barriers establish a perimeter barrier along the north property boundary (E. Harvard Ave.), including the northwest parking lot.

Project Group: 570-VAMC-N1

45% Submittal VA Comments

Facility Response: The Issue Comment rcomendation is incomplete. What is reccomended early warning approach distance between gates and public streets/ways and how could this be accomodated on the Fresno site.

Facility Comments: The Issue Comment rcomendation is incomplete. What is reccomended early warning approach distance between gates and public streets/ways and how could this be accomodated on the Fresno site.

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: Does not address questions, what is the intent? ***Too much copy & paste, no due dilligence!****

VISN Comments: NCR

Images:

Site No. 570 - Deficiency: S-570-3.2.4-14-1

16 I P a g e

CENTER

Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: SITE

Address: Enter address here

Leased: NO

Deficiency Information

Deficiency ID: S-570-3.2.4-14-2

PSDM Subset: Perimeter Fences

Exterior/Interior: Exterior

Question: Is there standoff between gates and public streets to provide the security force with early warning of approaching pedestrians or vehicles?

Results: No

Issue Comment: There is no standoff between the public street and this entrance to the site.

Risk Level: Very High

Recommended Corrective Action:

Perimeter Barrier – Using a series of fencing, gates, bollards, and other active and passive barriers establish a perimeter barrier along the north property boundary (E. Harvard Ave.), including the northwest parking lot.

Project Group: 570-VAMC-N1

45% Submittal VA Comments

Facility Response: Concur, however what is the recommendation to achieve?

Facility Comments: Concur, however what is the recommendation to achieve?

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: ***Too much copy & paste, no due dilligence!****

VISN Comments: AF reviewed - SCIP VHA21-570-2013-10068 his project will install fencing, security bollards, additional security cameras, lighting and guard/entry stations throughout the 24 hour acess entry points at the facility.

Images:

Site No. 570 - Deficiency: S-570-3.2.4-14-2

17 I P a g e

CENTER

Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: SITE

Address: Enter address here

Leased: NO

Deficiency Information

Deficiency ID: S-570-3.2.4-14-4

PSDM Subset: Perimeter Fences

Exterior/Interior: Exterior

Question: Is there standoff between gates and public streets to provide the security force with early warning of approaching pedestrians or vehicles?

Results: No

Issue Comment: There is no standoff between the public street and entrance to the campus off North Fresno Street.

Risk Level: Very High

Recommended Corrective Action:

Perimeter Barrier – Using a series of fencing, gates, bollards, and other active and passive barriers establish a perimeter barrier along the north property boundary (E. Harvard Ave.), including the northwest parking lot.

Project Group: 570-VAMC-N1

45% Submittal VA Comments

Facility Response: Concur, however what is the recommendation to achieve?

Facility Comments: Concur, however what is the recommendation to achieve?

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: Duplicate of s-3.2.4-1.2. ***Too much copy & paste, no due dilligence!****

VISN Comments: NCR

Images:

Site No. 570 - Deficiency: S-570-3.2.4-14-4

18 I P a g e

CENTER

Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: SITE

Address: Enter address here

Leased: NO

Deficiency Information

Deficiency ID: S-570-3.2-5-2

PSDM Subset: Perimeter Fences

Exterior/Interior: Exterior

Question: Is there a continuous barrier of fences walls and gates?

Results: No

Issue Comment: There is no fencing present on the side of campus along East Clinton Ave and there is no gate present at the main entrance.

Risk Level: Very High

Recommended Corrective Action:

Perimeter Barrier – Using a series of fencing, gates, bollards, and other active and passive barriers establish a perimeter barrier along the north property boundary (E. Harvard Ave.), including the northwest parking lot.

Project Group: 570-VAMC-N1

45% Submittal VA Comments

Facility Response: Concur

Facility Comments: Concur

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: Requires manned station for access control. Are there any other strategies we can utilize? (E. Harvard Ave) is a copy and paste error.

VISN Comments: AF reviewed - SCIP VHA21-570-2013-10068 his project will install fencing, security bollards, additional security cameras, lighting and guard/entry stations throughout the 24 hour acess entry points at the facility.

Images:

Site No. 570 - Deficiency: S-570-3.2-5-2

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Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: SITE

Address: Enter address here

Leased: NO

Deficiency Information

Deficiency ID: S-570-3.3.1-22-2

PSDM Subset: Vehicle and Pedestrian Screening

Exterior/Interior: Exterior

Question: Are pedestrian and vehicle perimeter entrances provided with enclosed guard houses for guard personnel gate operation vehicle inspection and information?

Results: No

Issue Comment: There is no guard house at the main entrance located on East Clinton Ave.

Risk Level: High

Recommended Corrective Action:

Perimeter Barrier – Using a series of fencing, gates, bollards, and other active and passive barriers establish a perimeter barrier along the north property boundary (E. Harvard Ave.), including the northwest parking lot.

Project Group: 570-VAMC-N1

45% Submittal VA Comments

Facility Response: Concur, however this must be integrated with space for vehicle screening and turn around and will have a major space impact.

Facility Comments: Concur, however this must be integrated with space for vehicle screening and turn around and will have a major space impact.

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: Does not address questions or issues, item was copied and pasted.

VISN Comments: AF reviewed - SCIP VHA21-570-2013-10068 his project will install fencing, security bollards, additional security cameras, lighting and guard/entry stations throughout the 24 hour acess entry points at the facility.

Images:

Site No. 570 - Deficiency: S-570-3.3.1-22-2

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Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: SITE

Address: Enter address here

Leased: NO

Deficiency Information

Deficiency ID: S-570-3.3.1-22-4

PSDM Subset: Vehicle and Pedestrian Screening

Exterior/Interior: Exterior

Question: Are pedestrian and vehicle perimeter entrances provided with enclosed guard houses for guard personnel gate operation vehicle inspection and information?

Results: No

Issue Comment: There is no guard house at the entrance off North Fresno Street.

Risk Level: High

Recommended Corrective Action:

Perimeter Barrier – Using a series of fencing, gates, bollards, and other active and passive barriers establish a perimeter barrier along the north property boundary (E. Harvard Ave.), including the northwest parking lot.

Project Group: 570-VAMC-N1

45% Submittal VA Comments

Facility Response: Concur, however this must be integrated with space for vehicle screening and turn around and will have a major space impact.

Facility Comments: Concur, however this must be integrated with space for vehicle screening and turn around and will have a major space impact.

VISN Comments: Concur with all comments

65% Submittal VA Comments

Facility Comments: Does not address questions or issues, item was copied and pasted.

VISN Comments: AF reviewed - SCIP VHA21-570-2013-10068 his project will install fencing, security bollards, additional security cameras, lighting and guard/entry stations throughout the 24 hour acess entry points at the facility.

Images:

Site No. 570 - Deficiency: S-570-3.3.1-22-4

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Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: SITE

Address: Enter address here

Leased: NO

Deficiency Information

Deficiency ID: S-570-3.3.2.4-32-2

PSDM Subset: Vehicle and Pedestrian Screening

Exterior/Interior: Exterior

Question: Is there a turn-around lane present on the exterior of entrance gates to permit vehicles to be sent away without interfering with traffic?

Results: No

Issue Comment: There is no turn around area present at the main entrance off East Clinton Ave. With no ability to control access and/or screen vehicles entering campus there is no ability to escalate access control during times of escalated threats.

Risk Level: Very High

Recommended Corrective Action:

Vehicle Screening – Consider waiver for main campus entry guardhouse - Reason for waiver: lack of space, daily screening would interfere with site operations, cost, and specific sections of campus have been recommended to have guard houses installed.

The station should obtain the resources to strictly control and screen access onto campus in response to an increase in the threat level. Policy implementation/Response Plan/Resource Allocation – While a “main” guard house (controlling all access onto campus) is not being recommended, it is being recommended that the station obtain the resources (passive anti-ram devices, temporary guard houses, active anti-ram barriers, screening equipment, etc.) with the capabilities to deploy a screening process on campus in the event of an increased threat level (either nationally or as a result of a credible threat to the campus itself).

Project Group: 570-VAMC-N1

45% Submittal VA Comments

Facility Response: The Issue Comment recommendation is incomplete.

Facility Comments: The Issue Comment recommendation is incomplete.

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: Needs discussion

VISN Comments: NCR

Images:

Site No. 570 - Deficiency: S-570-3.3.2.4-32-2

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Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: SITE

Address: Enter address here

Leased: NO

Deficiency Information

Deficiency ID: S-570-3.3.2.4-32-3

PSDM Subset: Vehicle and Pedestrian Screening

Exterior/Interior: Exterior

Question: Is there a turn-around lane present on the exterior of entrance gates to permit vehicles to be sent away without interfering with traffic?

Results: No

Issue Comment: There is no turn around area present at the entrance off North Fresno Street. With no ability to control access and/or screen vehicles entering campus there is no ability to escalate access control during times of escalated threats.

Risk Level: Very High

Recommended Corrective Action:

Vehicle Screening – Consider waiver for main campus entry guardhouse - Reason for waiver: lack of space, daily screening would interfere with site operations, cost, and specific sections of campus have been recommended to have guard houses installed.

The station should obtain the resources to strictly control and screen access onto campus in response to an increase in the threat level. Policy implementation/Response Plan/Resource Allocation – While a “main” guard house (controlling all access onto campus) is not being recommended, it is being recommended that the station obtain the resources (passive anti-ram devices, temporary guard houses, active anti-ram barriers, screening equipment, etc.) with the capabilities to deploy a screening process on campus in the event of an increased threat level (either nationally or as a result of a credible threat to the campus itself).

Project Group: 570-VAMC-N1

45% Submittal VA Comments

Facility Response: The Issue Comment recommendation is incomplete.

Facility Comments: The Issue Comment recommendation is incomplete.

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: Needs discussion

VISN Comments: NCR

Images:

Site No. 570 - Deficiency: S-570-3.3.2.4-32-3

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Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: SITE

Address: Enter address here

Leased: NO

Deficiency Information

Deficiency ID: S-570-3.4.1-35-1

PSDM Subset: Anti-ram Rated Vehicle Barriers

Exterior/Interior: Exterior

Question: Are active barriers anti-ram rated hydraulic or electric wedges plate beam or retractable bollards recessed into the pavement for a flush condition when not deployed?

Results: No

Issue Comment: There are no active barriers.

Risk Level: High

Recommended Corrective Action:

Perimeter Barrier – Using a series of fencing, gates, bollards, and other active and passive barriers establish a perimeter barrier along the north property boundary (E. Harvard Ave.), including the northwest parking lot.

Project Group: 570-VAMC-N1

45% Submittal VA Comments

Facility Response: Identify the necessary utilities to support portable barriers

Facility Comments: Identify the necessary utilities to support portable barriers

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: NCR

VISN Comments: AF reviewed - SCIP VHA21-570-2013-10068 his project will install fencing, security bollards, additional security cameras, lighting and guard/entry stations throughout the 24 hour acess entry points at the facility.

Images:

Site No. 570 - Deficiency: S-570-3.4.1-35-1

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Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: SITE

Address: Enter address here

Leased: NO

Deficiency Information

Deficiency ID: S-570-3.4.1-35-2

PSDM Subset: Anti-ram Rated Vehicle Barriers

Exterior/Interior: Exterior

Question: Are active barriers anti-ram rated hydraulic or electric wedges plate beam or retractable bollards recessed into the pavement for a flush condition when not deployed?

Results: No

Issue Comment: There are no active barriers.

Risk Level: High

Recommended Corrective Action:

Perimeter Barrier – Using a series of fencing, gates, bollards, and other active and passive barriers establish a perimeter barrier along the north property boundary (E. Harvard Ave.), including the northwest parking lot.

Project Group: 570-VAMC-N1

45% Submittal VA Comments

Facility Response: Identify the necessary utilities to support portable barriers

Facility Comments: Identify the necessary utilities to support portable barriers

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: NCR

VISN Comments: AF reviewed - SCIP VHA21-570-2013-10068 his project will install fencing, security bollards, additional security cameras, lighting and guard/entry stations throughout the 24 hour acess entry points at the facility.

Images:

Site No. 570 - Deficiency: S-570-3.4.1-35-2

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Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: MAIN HOSPITAL

Address: Enter address here

Leased: NO

Deficiency Information

Deficiency ID: B-1-4.3.1-86-1

PSDM Subset: Building Exits and Life Safety Considerations

Exterior/Interior: Exterior

Question: Do all means of egress that lead to loading docks or other service areas direct users away from hazardous and pathological waste storage mailrooms and other areas that maybe the source of injury or contamination?

Results: No

Issue Comment: Emergency exit from building 1 basement level goes right by bio waste storage.

Risk Level: Medium

Recommended Corrective Action:

consider waiver due to life safety standards prohibiting changing or eliminating this route. Efforts should be made to prohibit patient care services from being provided in an area that this route would be their primary means of egress from the care space.

Project Group: 570-VAMC-N2

45% Submittal VA Comments

Facility Response: Please expand on the recommendation. This emergency egress route cannot be changed or eliminated.

Facility Comments: Please expand on the recommendation. This emergency egress route cannot be changed or eliminated.

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: NCR

VISN Comments: AF Reviewed - VHA21-570-2013-10068 - Improve Site Access and Physical Security Deficiencies

Images:

Site No. 570 - Deficiency: B-1-4.3.1-86-1

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Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: MAIN HOSPITAL

Address: Enter address here

Leased: NO

Deficiency Information

Deficiency ID: B-1-5.1.3.1-101-1

PSDM Subset: Agent Cashier

Exterior/Interior: Interior

Question: Are the partitions and walls of agent cashier spaces reinforced slab-to-slab with 9-gauge expanded metal? (Note: The expanded metal shall be spot welded every 6 inches to vertical and horizontal metal supports of 16-gauge or greater thickness that has been solidly and permanently attached to the true floor and true ceiling.)

Results: No

Issue Comment: The space is converted office space that has a drop ceiling renovation has extended the wall through the drop ceiling but walls are not reinforced. Current construction of this space is insufficient for an area handling cash.

Risk Level: High

Recommended Corrective Action:

Agent Cashier – Reinforce the surrounding partitions as well as pass through devices or move the service to a more appropriately designed space.

Project Group: 570-VAMC-N2

45% Submittal VA Comments

Facility Response: FROM FISCAL: Concur

Facility Comments: FROM FISCAL: Concur

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: NCR

VISN Comments: NCR

Images:

Site No. 570 - Deficiency: B-1-5.1.3.1-101-1

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Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: MAIN HOSPITAL

Address: Enter address here

Leased: NO

Deficiency Information

Deficiency ID: B-1-5.1.3.1-102-1

PSDM Subset: Agent Cashier

Exterior/Interior: Interior

Question: Are the agent cashier space pass through devices of UL 752 Level 3 ballistic construction and 15-minute forced entry construction?

Results: No

Issue Comment: Current construction does not meet this standard and is insufficient for an area handling and storing cash.

Risk Level: High

Recommended Corrective Action:

Agent Cashier – Reinforce the surrounding partitions as well as pass through devices or move the service to a more appropriately designed space.

Project Group: 570-VAMC-N2

45% Submittal VA Comments

Facility Response: FROM FISCAL: Concur

Facility Comments: FROM FISCAL: Concur

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: NCR

VISN Comments: NCR

Images:

Site No. 570 - Deficiency: B-1-5.1.3.1-102-1

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Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: MAIN HOSPITAL

Address: Enter address here

Leased: NO

Deficiency Information

Deficiency ID: B-1-5.1.3.1-98-1

PSDM Subset: Agent Cashier

Exterior/Interior: Interior

Question: Are the partitions and teller windows of the agent cashier spaces facing the public corridor of UL 752 Level 3 ballistic construction and 15-minute forced entry construction including partitions doors glazed openings teller windows and transaction trays?

Results: No

Issue Comment: Facility representatives were unsure but do not think partitions meet this standard the windows and partitions are of sturdy construction but are not ballistic resistant. The window is old and may be due to be replaced.

Risk Level: High

Recommended Corrective Action:

Agent Cashier – Reinforce the surrounding partitions as well as pass through devices or move the service to a more appropriately designed space.

Project Group: 570-VAMC-N2

45% Submittal VA Comments

Facility Response: Issue Comment is truncated FROM FISCAL: Concur

Facility Comments: Issue Comment is truncated FROM FISCAL: Concur

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: NCR

VISN Comments: AF Reviewed - VHA21-570-2013-10068 - Improve Site Access and Physical Security Deficiencies

Images:

Site No. 570 - Deficiency: B-1-5.1.3.1-98-1

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Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: MAIN HOSPITAL

Address: Enter address here

Leased: NO

Deficiency Information

Deficiency ID: B-1-5.1.4.1-105-1

PSDM Subset: Agent Cashier

Exterior/Interior: Interior

Question: Are all of the agent cashier spaces and the transaction windows monitored by VASS?

Results: No

Issue Comment: There is no fixed camera on that window but there is a PTZ camera that can be pointed there. The camera typically faces the travel/pay window because there are more complaints there and that space is less protected. Agent cashier space needs its own dedicated VASS camera.

Risk Level: High

Recommended Corrective Action:

Security Cameras (VASS) – Campus wide project of upgrading existing cameras and increasing camera coverage in accordance with PSDM standard including Appendix A and B. Choice of camera technology is related to system integration with other security subsystems. VASS and security subsystems should have their own dedicated IT network, separate from other IT networks (i.e. patient care, etc.). Should record to an NVR and monitored by the SCC.

Project Group: 570-VAMC-N2

45% Submittal VA Comments

Facility Response: FROM FISCAL:Concur

Facility Comments: FROM FISCAL:Concur

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: NCR

VISN Comments: NCR

Images:

Site No. 570 - Deficiency: B-1-5.1.4.1-105-1

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Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: MAIN HOSPITAL

Address: Enter address here

Leased: NO

Deficiency Information

Deficiency ID: B-1-5.1.4.3-107-1

PSDM Subset: Agent Cashier

Exterior/Interior: Interior

Question: Are all agent cashier space entrance doors controlled and monitored?

Results: No

Issue Comment: Locked with key but not monitored. IDS or other alarm system (either through PACS or motion activated VASS) should monitor the agent cashier space and notify the SCC in the event of forced entry, especially due to the general office construction of the space.

Risk Level: High

Recommended Corrective Action:

Door Monitoring – All building perimeter doors and all other man passable openings should be monitored by door contact (magnetic switch) or otherwise part of the PACS system. Doors defined as “egress only” should have all exterior hardware removed and have localized audible alarms. Device and system selection should be made ensuring systems can be integrated with other security subsystem. Related to other security subsystems as they all are to be integrated into an overall ESS operated/monitored from the Security Control Center (SCC)

Project Group: 570-VAMC-N2

45% Submittal VA Comments

Facility Response: FROM FISCAL Concur - NOTE: There is also an issue of the door that leads from the main corridor to the office space the Agent Cashier utilizes for entry, no longer automatically locking.

Facility Comments: FROM FISCAL Concur - NOTE: There is also an issue of the door that leads from the main corridor to the office space the Agent Cashier utilizes for entry, no longer automatically locking.

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: NCR

VISN Comments: NCR

Images:

Site No. 570 - Deficiency: B-1-5.1.4.3-107-1

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Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: MAIN HOSPITAL

Address: Enter address here

Leased: NO

Deficiency Information

Deficiency ID: B-1-5.2.4-120-1

PSDM Subset: Caches

Exterior/Interior: Interior

Question: Are all entrance doors to the cache and vault doors within the cache monitored by VASS controlled by physical access control and monitored by intrusion detection system (both boundary and volumetric)?

Results: No

Issue Comment: Space is monitored by IDS and PACS not VASS.

Risk Level: High

Recommended Corrective Action:

Security Cameras (VASS) – Campus wide project of upgrading existing cameras and increasing camera coverage in accordance with PSDM standard including Appendix A and B. Choice of camera technology is related to system integration with other security subsystems. VASS and security subsystems should have their own dedicated IT network, separate from other IT networks (i.e. patient care, etc.). Should record to an NVR and monitored by the SCC.

Project Group: 570-VAMC-N2

45% Submittal VA Comments

Facility Response: concur

Facility Comments: concur

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: NCR

VISN Comments: NCR

Images:

Site No. 570 - Deficiency: B-1-5.2.4-120-1

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Task Order No:

VA261-16-J-0762

Project:

VISN 21 - PHYSICAL SECURITY DESIGN

COMPLIANCE SURVEY

Project No:

612-16-108

Submittal: 100%

Submittal

Building Information

Building: MAIN HOSPITAL

Address: Enter address here

Leased: NO

Deficiency Information

Deficiency ID: B-1-5.4.2-127-1

PSDM Subset: Main Computer Room

Exterior/Interior: Interior

Question: Are all entrance doors to the main computer rooms and other computer rooms controlled and monitored?

Results: No

Issue Comment: The door is controlled via PACS and keypad biometric on the interior door. The door is not actively monitored but police can pull a report. The area should be actively monitored providing real time information tot he SCC in the event the door is breached (forced open). The ability to pull reports will not stop a network penetration.

Risk Level: Very High

Recommended Corrective Action:

Door Monitoring – All building perimeter doors and all other man passable openings should be monitored by door contact (magnetic switch) or otherwise part of the PACS system. Doors defined as “egress only” should have all exterior hardware removed and have localized audible alarms. Device and system selection should be made ensuring systems can be integrated with other security subsystem. Related to other security subsystems as they all are to be integrated into an overall ESS operated/monitored from the Security Control Center (SCC)

Project Group: 570-VAMC-N2

45% Submittal VA Comments

Facility Response: concur

Facility Comments: concur

VISN Comments: NCR

65% Submittal VA Comments

Facility Comments: NCR

VISN Comments: NCR

Im…