Attch 8 - PSDM Mission Critical Waiver Response - Draft Final.pdf

Department of Veterans Affairs

April 2, 2020

Healthcare Engineering Oversight Committee on Physical Security and Resiliency (10NA5E)

Physical Security Compliance Project 667-086, Expand SPS & Radiology

Office of Healthcare Engineering (10NA5E)

1. Overview: The Overton Brooks Health Care System in Shreveport, Louisiana is requesting a variance from certain provisions of the 2015 Mission Critical Physical Security Design Manual (PSDM) for the minor construction project 667-086, Expand SPS and Radiology. The project will construct a 2-story vertical expansion over an existing 3-story Outpatient Mental Health Service building.

2. Project Scope: The facility has an approved project to construct a vertical expansion of the existing South Wing of the main building to add a third and fourth floor for SPS functions. The project does not include any renovation of the lower levels, interior or exterior of the South Wing. The lower levels (basement, first and second floors) of the South Wing house Outpatient Mental Health services. A new chiller will be placed in the existing mechanical building located at ground level on the east side of the South Wing to support the new SPS addition AHU cooling needs. No modifications to the existing mechanical structure will be necessary to allow for the addition of the new chiller unit.

3. Facility’s Executive Summary of Variance Request: The project is programmed to be constructed as a vertical expansion of an existing structure that was not designed with the above considerations for Mission Critical facility physical security requirements.

Incorporating these requirements for the addition design and construction will inflate cost while not fully mitigating the issues due to the underlying structural deficiencies.

Expanding the scope of the current project to include the necessary upgrades will negatively impact patient care by necessitating the closure of clinical space and pulling funding away from other projects. The current project cannot incorporate additional structural upgrades to the underlying building within the limits of the Minor construction program.

4. Variance Request: The facility is requesting a variance from the requirements of the 2015 Mission Critical PSDM identified below, with the identified physical limitations as described by the facility:

i. Requirement: Section 3.1 Stand-Off Distance – No vehicle shall be parked closer than 50 feet (15.2 m) to any side of a Mission critical VA facility, regardless of the building height. No unscreened vehicle shall be permitted to travel closer than 50 feet (15.2 m) and no screened vehicle shall be permitted to travel within 5 feet (1.5 m) of any Mission critical VA facility.

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Physical Limitations: Providing the necessary building standoff, building entranceways and patient drop off locations will be difficult given the footprint of the campus. Alternative locations for the building are not available that provide the necessary adjacencies for the required departments. To alter the existing roadways and parking to meet the 50’ requirement would necessitate moving a parking garage and roadway.

ii. Requirement: Section 6.1.1 Non-load Bearing Walls - Non-load bearing walls shall be designed such that they have some permanent deformation but are generally repairable in response to the calculated peak pressures and impulses resulting from the design level vehicle threat.

Physical Limitations: The cost to design and construct non-load bearing walls to accommodate permanent deformation while remaining repairable will put the project outside the programmed budget limitations. Since the lower level structure is not designed to remain operable after a design level vehicle threat (W1). Due to the underlying structural deficiencies for the lower 3 floors, there would be little benefit from designing and constructing the walls at the 3rd & 4th floor level to meet the PSDM criteria.

iii. Requirement: Section 6.2 Fenestration and Doors - All façade fenestration shall be designed to crack but remain in the frame in response to the calculated peak pressures and impulses resulting from the design level vehicle threat.

Physical Limitations: The required adjacencies for project departments require construction on an underlying structure within the 50 foot standoff distance required in section 3 of the PSDM. The cost to design and construct façade fenestrations to remain in the frame in response to the calculated peak pressures and impulses resulting from the design level vehicle threat (W1) at minimum standoff distance of 50 feet (15 m), but no greater than GP2, or the use of laminated glass, or floating curtainwall framing attachments will not effectively mitigate the effects of a W1 threat.

iv. Requirement: Section 6.4.1 Roof Structure - Roof structure (including metal deck, composite deck, concrete slabs, beams, joists, and girders) shall be designed to withstand the calculated peak incident pressures and impulses resulting from the design level vehicle threat.

Physical Limitations: The underlying structure has been expanded vertically through 2 different projects. Penthouses enclosing critical elevator equipment would be constructed on an underlying elevator and stair structure that was not designed with the W1 or W2 threat requirements. Upgrading the penthouse structure would not mitigate the effects of those threats.

v. Requirement: Section 6.5.1 Air Intakes and Exhausts Servicing Critical Equipment - Air intakes and exhausts shall be designed to minimize the blast over pressure applied to critical mechanical equipment due to the design level vehicle threat. The design shall deny a direct line of sight from the design level vehicle threat (W1) located at the standoff distance to the critical infrastructure within.

Physical Limitations: No physical limitations.

vi. Requirement: Section 7.1 Blast Resistance – Structures shall be constructed to withstand the actual pressures and corresponding impulses produced by the design level vehicle threat.

Physical Limitation: The underlying building is not designed to withstand the W1 and W2 threats without collapse and the cost and impact to upgrade the underlying building will be prohibitively expensive verses an economically repairable cost. The disruption to patient care to perform structural upgrades to lower floors would have significant impacts on the VA’s ability to carry out its mission.

Programmatic Limitation: Radiology and SPS are required to be located adjacent to surgical and patient care areas which limit where the construction project can be located. The programmed location on top of the 2nd floor level of the South Wing provides the only viable adjacencies for these departments.

There is neither the budget or the available space to provide care while renovating the underlying structure.

vii. Requirement: Section 7.2 Progressive Collapse –Two story structures shall be designed to minimize the potential for progressive collapse using the Tie Force Method...All structures, greater than two stories, shall be designed to minimize the potential for progressive collapse using the Tie Force Method, enhanced local resistance and the Alternate Path Method.

Physical Limitation: The underlying structure was not designed to prevent progressive collapse. As OBVAMC is in a region of low seismic activity and given the lower building structure would experience a greater impact by a VBIED, it is likely the underlying structure is the controlling factor for progressive collapse.

viii. Requirement: Section 7.3 Column Protection - Columns and load bearing walls exposed to blast loading shall be hardened or isolated to resist the effects of the design level vehicle threat. The design shall provide a level of protection for which progressive collapse will not occur, the building damage will be economically repairable, and the space in and around damaged area can be used and will be fully functional after cleanup and repairs.

Physical Limitation: The underlying structure was not designed to accommodate blast loading due to W1 and W2 risks. Designing this project with hardened columns will not mitigate the risk of column failure at lower floor levels.

5. Proposed Alternative Method: Given the required adjacencies for the project departments, in order to mitigate the risk, where possible, the station is planning an expansion to the existing parking garage to direct parking away from the existing structure to better control vehicle access. The station is also proposing to reduce the overall risk by preparing emergency action plans to allow for road closures and parking restrictions as well as vehicle screening in response to a significant threat to the campus. Increased VA police patrols around the perimeter will help to enforce no parking restrictions. The facility feels that these measures provide additional levels of protection to the concentric levels already in place. This increased level of protection reduces the overall risk (reducing both likelihood/probability as well as the potential loss) associated with vehicle borne improvised explosive devices (VBIED) for which these design guidelines are intended to resist.

6. Committee Review: The Oversight Committee on Physical Security and Resiliency has conducted a thorough assessment of the request. The following data summarizes the key points of the review, clarifications and recommendations:

i. Parking Garage Expansion: The facility noted the design of a Minor Construction Project, 667-087 “Expand Parking Garage” has been approved and funded. The design plans to horizontally expand to the south and west the existing parking structure, which is located across the roadway on the south side of the South wing. This project also plans to include a new drive to run on the south side of the parking structure expansion to offer another route to the west surface parking lot. It appears the parking garage itself currently meets the 50-foot mission critical standoff and will be required to continue to meet the mission critical standoff with the new design.

ii. Vertical Expansion: The committee would like to clarify that the hardening of the expansion to mission critical requirements does and will provide additional safety to occupants and should not add significant weight to the expansion to be supported by the existing structure below. Since the SPS addition is a mission critical function, the new third and fourth floor addition design must meet the following PSDM requirements: Section 6.1 Walls, Section 6.2 Fenestrations and Doors, Section 6.4 Roofs, and Section 6.5 Air Intakes and Exhausts serving Critical Equipment. The committee does not recommend waiving these requirements as requested. Section 7.1 Blast Resistance is related to new construction of a building structure and is not applicable to this vertical expansion.

iii. Work in Existing Space: Since there is no renovation of the lower levels included as part of the vertical building addition, Sections 7.2 Progressive Collapse and 7.3 Column Protection will not be required to be addressed within this project. No waivers are required at this time, but compliance with existing building requirements will need to be addressed when the areas are renovated.

iv. Standoff Requirements: Although the facility has considered possible options, currently there are no plans to limit access to the existing drive that runs between the South Wing and the existing parking structure nor the lot to the west. The facility must have in place an approved facility master plan to bring the site into compliance with the requirements of the PSDM. This need not be addressed as part of the subject project, as it is not part of the current scope. However, the facility must have a plan to address it through project(s) or other means or a combination thereof. The Committee feels that the standoff is achievable while still accommodating patient access and will not recommend approval of a waiver on the mission critical standoff requirements. As part of the plan, the following must be addressed:

i. Since the drive running between the South Wing and the parking structure is less than 50 feet to the South Wing, it must be addressed by restricting access to authorized VA vehicular traffic, be blocked off or removed.

ii. The west side parking drive nearest the South Wing is less than 50 feet from the building and therefore must be modified to meet the 50-foot standoff distance.

v. Based on this the committee does not recommend waiving the requirement as requested.

7. Questions can be directed to Vincent Rizzo (716-238-5587) or James Carter (727-403-

8334), Committee Co-chairs.

Signed Concur / Non-Concur

Co-Chair, Healthcare Engineering Oversight Committee on Physical Security and

Resiliency

Oleh Kowalskyj Acting Director Healthcare Engineering

(10NA5E)

Cc: Director, Capital Asset Management (10NA5F) Co-Chairs, Healthcare Engineering Oversight Committee on Physical Security and Resiliency (10NA5E)