2007
TRIENNIAL ON-SITE
SAFETY AND SECURITY REVIEW OF
SANTA CLARA VALLEY TRANSPORTATION AUTHORITY (VTA)
RAIL TRANSIT SAFETY SECTION
RAIL TRANSIT AND CROSSINGS BRANCH
CONSUMER PROTECTION AND SAFETY DIVISION
CALIFORNIA PUBLIC UTILITIES COMMISSION
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102
February 4, 2008
Final Report
Richard W. Clark, Director
Consumer Protection and Safety Division
2007 TRIENNIAL ON-SITE SAFETY AND SECURITY REVIEW OF
SANTA CLARA VALLEY TRANSPORTATION AUTHORITY (VTA)
ACKNOWLEDGEMENT
The California Public Utilities Commission's Rail Transit Safety Section staff, with the assistance of the Commission's Railroad Operations Safety Branch, conducted this system safety and security programs review. Staff members directly responsible for conducting safety and security review and inspection activities include:
Raed Dwairi, Lead Reviewer |
Mahendra Patel |
Joey Bigornia |
Noel Takahara |
Ni Liu |
Dain Pankratz |
Brian Yu |
Arun Mehta |
Anton Garabetian |
Vincent Kwong (Observer) |
Jimmy Xia (Observer) |
Rupa Shitole (Observer) |
TABLE OF CONTENTS
Page
1. EXECUTIVE SUMMARY 1
2. INTRODUCTION 2
3. BACKGROUND 3
VTA Rail System Description 3
2004 On-Site Safety Audit Result 5
4. REVIEW PROCEDURE 6
5. FINDINGS AND RECOMMENDATIONS 7
APPENDICES
A.TSA Executive Summary of VTA System Security Review 15
B. VTA 2007 Triennial Safety Review Checklist Index 18
C. VTA 2007 Triennial Safety Review Recommendations List 20
D. VTA 2007 Triennial Safety Review Checklists 22
1. EXECUTIVE SUMMARY
The California Public Utilities Commission's (Commission) Consumer Protection and Safety Division (CPSD), Rail Transit Safety Section staff (staff), with assistance from the Railroad Operations Safety Branch and Utilities Safety Branch staff (staff), conducted an on-site safety and security review of Santa Clara Valley Transportation Authority's (VTA) system safety program in October 2007.
The on-site review was preceded by a pre-review conference with VTA personnel on October 15, 2007. Transportation Security Administration (TSA) representatives conducted the review of VTA's system security program on October 9, 2007.
Staff conducted the 2007 VTA on-site safety and security review from October 15 to October 19, 2007. The review focused on verifying the effective implementation of the system safety and security program plans.
Staff held a post-review conference with VTA personnel following the on-site safety and security review on October 30, 2007. Staff provided VTA personnel with a synopsis of the preliminary review findings and possible recommendations for corrective actions. TSA representatives held a similar post-review conference with VTA security personnel after their review of VTA's system security program on October 9, 2007. TSA representatives utilized the Surface Transportation Action Review Checklist to review VTA system security internal processes, procedures, and policies. Appendix A provides the TSA Executive Summary.
The review results indicate that VTA has a comprehensive System Safety Program Plan (SSPP) and has effectively carried out that plan. VTA was also found to have a progressive and effective security program by TSA which was invited to act as CPUC "security agent" during this triennial review. However, exceptions were noted during the review. These are described in the Findings and Recommendations section of each checklist. Of the 32 checklists, staff made 14 recommendations for corrective action. These are distributed among the Way, Power & Signal, Risk Management, and Maintenance Engineering departments.
The Introduction for this report is presented in Section 2. The Background, in Section 3, contains a description of VTA rail system and the 2004 on-site safety review results. Section 4 describes the review procedure. The review findings and recommendations are depicted in Section 5. The 2007 VTA Triennial Safety Review Checklist Index and the Recommendations List are included, respectively, in Appendices B and C. The Review Checklists are presented in Appendix D.
2. INTRODUCTION
The Commission's General Order (GO) 164-D1, Rules and Regulations Governing State Safety Oversight of Rail Fixed Guideway Systems, and the Federal Transit Administration's (FTA) Rule, Title 49 Code of Federal Regulations (CFR) Part 659, Rail Fixed Guideway Systems: State Safety Oversight, require the designated State Safety Oversight Agencies to perform a review of each rail transit agency's system safety program and system security plan at a minimum of once every three years. The purpose of the triennial review is to verify compliance and evaluate the effectiveness of each rail transit agency's System Safety Program Plan (SSPP) and System Security Plan (SSP) and to assess the level of compliance with GO 164-D as well as other Commission safety requirements. The previous on-site safety review of VTA was conducted by staff in October 2004.
VTA General Manager was advised by staff in a letter dated September 14, 2007 that the triennial review would be scheduled for the week of October 15, 2007. The letter included 32 checklists that served as the basis for the review. Four of the 32 checklists outlined inspection of track, signals, electric power systems, and vehicles. The remaining 28 checklists focused on the verification of the effective implementation of the safety and security program plans.
On October 17 and 18, 2007 staff from the Commission's Rail Operations Safety Branch conducted inspections of VTA's track and signals. Vehicle inspections were conducted on October 25, 2007. Staff conducted a pre-review conference on October 15, 2007 with VTA executives and department managers. TSA representatives conducted a review of VTA's system security program on October 9, 2007. TSA representatives utilized the Surface Transportation Act Review Checklist to review the internal processes, procedures, and policies of VTA system security program.
Staff conducted the on-site safety review and records review from October 15, 2007 to October 19, 2007. At the conclusion of each review activity, staff provided VTA personnel a summary of the preliminary findings and discussed any preliminary recommendations for corrective actions.
On October 30, 2007, staff conducted a post-review exit meeting with VTA's executives and department managers. Staff provided the attendees a synopsis of the findings from the 32 checklists and discussed the need for corrective actions where applicable.
3. BACKGROUND
VTA is both a transit provider and a multi-modal transportation development organization of Santa Clara County. The governing Board of Directors have seventeen members and two ex-officio members, all of whom are elected officials appointed to serve on the Board by the jurisdictions they represent. Fourteen Directors are city council members and three are County Supervisors. Twelve Directors serve as voting members and five Directors serve as alternates. The ex-officio members are non-voting members and are Santa Clara County's representatives to the Metropolitan Transportation Commission.
VTA Rail System Description
VTA rail system consists of the Guadalupe, Tasman West, Tasman East, Capitol lines and Vasona Line with two other proposed extensions. The total operating system is about 42 miles with 62 Light Rail Stations. The average ridership of the system is approximately 26,000 per day in the year 2006.
Guadalupe Line
The 21-mile Guadalupe light rail line, in service since 1991, extends from south San Jose, into downtown and continues to employment centers of north San Jose and Santa Clara. The Downtown Center Plaza in San Jose serves as hub for rail/bus connections. It also links light rail and Caltrain service at Tamien Station in San Jose. It has 28 light rail stations.
The 7.6-mile Tasman West light rail line, in service since 1999, travels through four cites: San Jose, Santa Clara, Sunnyvale, and Mountain View serving major employment centers of Silicon Valley. It links with Caltrain in Downtown Mountain View. It has 16 light rail stations.
Tasman East Line
The Tasman East light rail line is a 4.8-mile extension from North First Street to Hostetter Road. The first phase, 1.9-mile extension from North First Street to I-880 along the median of Tasman Drive opened for revenue service in May 2001 and marked the first arrival of VTA light rail vehicles in the City of Milpitas. The second phase, a 2.9-mile segment from I-880 to Hostetter Road along the Capitol Avenue median opened for revenue service in June 2004. Approximately 7,200 feet of this segment is grade separated over two railroad crossings, Montague Expressway, and other cross streets. This line has 6 light rail stations.
Capitol Line
The Capitol light rail line, a 3.5-mile extension of the Tasman light rail line opened for revenue service in June 2004. It travels along Capitol Avenue from just south of Hostetter Road to Alum Rock Avenue, north of Capitol Expressway and operates in the median of Capitol Avenue, with two vehicles travel lanes and a bike lane in each direction paralleling the track way. It has 4 light rail stations.
Vasona Line Extension Project
The Vasona Light Rail Project is a 5.3-mile light rail extension to the existing VTA Light Rail system and operates primarily on the existing Union Pacific Railroad right-of-way. Revenue service began in 2005. It has 8 light rail stations.
Downtown East Valley Project
Current plans call for a 4.3-mile line extension from existing Alum Rock Station to Eastridge Mall. The alignment will be at grade as well as grade separated. This project is in the preliminary engineering phase.
BART Silicon Valley Project
The Silicon Valley project is a 16-mile extension of the BART system that would begin at the planned BART Warm Springs Station in the City of Fremont in Alameda County and proceed through the cities of Milpitas, San Jose, and Santa Clara in Santa Clara County. This fully grade separated project will add 6 stations and one future station in Milpitas. This project is in the preliminary engineering phase.
2004 On-Site Safety Audit Result
Staff performed the triennial on-site safety audit of VTA System Safety Program in October 2004. The 26 checklists resulted in 22 recommendations.
VTA developed corrective action plans to implement the recommendations. All 22 recommendations have been closed.
4. REVIEW PROCEDURE
Staff conducted the review in accordance with the Rail Transit Safety Section Procedure RTSS-4, Procedure for Performing Triennial Safety Audits of Rail Transit Systems.
Staff developed thirty-two (32) checklists to cover various aspects of system safety responsibilities, based on Commission and FTA requirements, VTA SSPP, safety related VTA documents, and the staff's knowledge of the transit system. The 32 checklists are included in Appendix D.
Each checklist identifies safety-related elements and characteristics that staff reviewed or inspected. Each of the checklists also references Commission, VTA, and other documents that establish the safety program requirements. The completed checklists include review findings, and recommendations if the review findings indicate deficiencies. The completed checklists may include comments and suggestions to improve VTA's system safety program. The methods used to perform the review include:
*0 Discussions with VTA management
*1 Reviews of procedures and records
*2 Observations of operations and maintenance activities
*3 Interviews with rank and file employees
*4 Inspections and measurements of equipment and infrastructure
The review checklists concentrated on requirements that affect the safety of rail operations and are known or believed to be important in reducing safety hazards and preventing accidents.
5. FINDINGS AND RECOMMENDATIONS
The reviewers and inspectors concluded that the VTA rail system has a comprehensive SSPP and has been effectively implementing the plan.
Review findings identify areas where changes should be made to further improve VTA system safety program. The review results are derived from activities observed, documents reviewed, issues discussed with management, and inspections. Overall, the review result confirms that VTA is in compliance with its SSPP. The review identified 14 recommendations from the 32 checklists. Following are the findings and recommendations for each checklist:
1. Vehicle Maintenance Inspection
Staff did not find any deficiencies.
2. Track and Switch Inspection
Staff did not find any deficiencies.
3. Gated Grade Crossings Warning Devices Inspection
Staff found the following deficiencies:
· Some crossings gate tips were not within the required 3'-6" from roadway as required by GO 75-D and FRA 234.223.05 and one pedestrian warning sign was blocked by vegetation (these were immediately corrected on October 18, 2007).
· Corrective actions pertaining to credible reports on the Vasona Line which are used to document repairs to correct activation failures were not documented properly.
Recommendation:
1. VTA should revise its appropriate grade crossing preventive maintenance procedures to add the requirements of ensuring crossing gate heights comply with General Order 75-D and pedestrian warning signs are not blocked by vegetation or other means.
2. VTA should develop controls to make certain that corrective actions pertaining to grade crossing credible reports are properly documented (CFR 49 Part 229.15).
4. Traction Power Inspection
Staff found the following deficiencies:
· At some locations, tree branches and/or foliages were within 18 inches from the energized wires. This condition is a violation of GO 95 Table 1 of Rule 37, Case 13 - Column 3, and Rule 35.
· At some locations, VTA is still in violation of GO 95 Rule 74.4-F despite the use of the Philistrand at OCS terminations.
Recommendation:
3. VTA should inspect the entire OCS and take necessary measures to ensure tree branches and/or foliage are in compliance with the requirements of GO 95 Table 1 of Rule 37, Case 13 - Column 3, and Rule 35, as well as, the system is constructed in compliance with GO 95 Rule 74.4-F.
5. Overhead Catenary System Inspections and Records
Staff found the following deficiency:
· Some OCS inspection records did not display supervisor's signature approving the inspection. A person should be designated to review and approve maintenance forms in the event a supervisor is not available.
Recommendation: (see recommendation #4 in checklist #6)
6. Substation Inspections and Records
Staff found the following deficiencies:
· Inspection forms were not updated for use with the new Impulse substations.
· An observation was made that some Yr 2006 inspection records did not display supervisor's signature approving the inspection. Staff suggested that VTA should designate a person to review and approve maintenance forms in the event a supervisor is not available.
Recommendation:
4. VTA should revise its current annual substation inspection procedure to include forms which pertain to the new Impulse Substations and add the requirement of designating a qualified person to review and approve substation and OCS inspection and maintenance records in the event a supervisor is not available to do so.
7. Internal Safety and Security Audits/Reviews
Staff found the following deficiency:
· Staff found that VTA auditors had several recommendations as a result of the 2007 internal audit; however, there were no corresponding corrective action plans and implementation schedules listed in the checklist to address these recommendations.
Recommendation:
5. VTA should ensure that a description of Corrective Action Plan; Implementation Schedule Date of the Corrective Action Plan; and Completion Status (Date and Action taken to correct noted items) is included in the checklist for each recommendation made by the VTA auditor as a result of the audit and tracked by RSSRB to ensure that the recommendations are implemented in a timely manner (GO 164-D Rule 5.5).
8. Right-of-Way Maintenance
Staff found the following deficiency:
· At some locations, fencing was found to be in need of repair.
Recommendation:
6. VTA should prioritize fencing installation/repair such that fencing in areas with likely pedestrian intrusions be repaired expediently (GO 143-B Rule 9.03).
9. Vital Relays Inspections, Maintenance and Records
Staff found the following deficiencies:
· Yr 2005 Biennial Vital Relay records for some relay cases were not found (VTA immediately started Biennial Relay PM's on October 19, 2007 which are scheduled for completion on October 28, 2007 for Cases 26 to 71 and 72 to 119).
· At locations, VTA had exceeded the maximum allowable pick-up voltage values and did not replace these relays as required. This also applied to some Vane Relays which were found to have drop away voltage values below required minimums.
Recommendation:
7. VTA should produce documentation that it replaced all relays not meeting prescribed voltage requirements and develop controls to make certain that vital relays are maintained to standards with appropriate supporting documentation (MTN-PR-6206).
10. Employee and Contractors Safety Program
Staff found the following deficiency:
· No documentation was found to show closure of identified deficiencies in the Maintenance Superintendent's Inspection and Monthly Safety Inspection Checklist for facilities inspection records.
Recommendation:
8. VTA should document the closure of identified deficiencies found during Maintenance Superintendent's and Monthly Safety Facilities Inspections and incorporate a sign-off section in the applicable inspection records.
11. Calibration of Measuring and Testing Equipment Program
Staff did not find any deficiencies.
12. Gated Crossing Maintenance
Staff did not find any deficiencies.
13. Accident/Incident Reporting and Investigation
Staff did not find any deficiencies.
14. Safety Certification
Staff did not find any deficiencies.
15. Configuration Management
Staff did not find any deficiencies.
16. Review Operating Rules and Procedures Manual
Staff did not find any deficiencies.
17. Hazardous Materials Programs / Environmental Management
Staff found the following deficiency:
· The process of FRS-RM-1801 was internally reviewed January 5, 2005. The next internal review was dated January, 2007. FRS-RM-1801 Section 4.8 prescribes annual review of confined space entries.
· Confined space entries for some Sump Pump locations were not recorded by some employees and despite the fact that certain Sump Pump locations are not considered confined space they are listed on the Confined Space List.
Recommendation:
9. VTA should conduct an annual audit of its confined space entries as prescribed by FRS-RM-1801 Section 4.8 as well as update and clearly define the Confined Space Entry List.
18. Emergency Response Planning, Coordination, Training
Staff did not find any deficiencies.
19. Light Rail Training and Certification
Staff did not find any deficiencies.
20. Light Rail Vehicle Maintenance
Staff did not find any deficiencies.
21. Drug and Alcohol Program
Staff found the following deficiency:
· There were 9 cases of unacceptable excuses for random testing during the years 2004, 2005, and 2006.
Recommendation:
10. VTA should develop controls to eliminate unacceptable excuses for drug & alcohol testing when randomly attempting to test its safety sensitive employees (CFR 49 Parts 40 and 655).
22. Operational Evaluation Records
Staff did not find any deficiencies.
23. Hours of Service - Train Operators, Train Controllers, and Supervisors
Staff did not find any deficiencies.
24. Way, Power, and Signal Internal Audit Program
Staff found the following deficiency:
· MTR-PR-6805 (Way, Power & Signal Internal Audit Program) is not being followed.
Recommendation:
11. VTA should ensure that WP&S preventive maintenance audits are conducted and all required records are prepared in accordance with MTN-PR-6805 requirements.
25. Bridges/Structures Inspections and Reports
Staff found the following deficiency:
· VTA has no Standard Operating Procedure (SOP) for the maintenance of its concrete structures that distinguishes between structural and maintenance defects and requires the development of a corrective action plan and implementation schedule to address identified defects.
Recommendation:
12. VTA should develop a Bridge/Concrete Structures Inspection SOP distinguishing between maintenance and structural defects including documentation of appropriate corrective action plan, department responsible for corrective actions and implementation schedule to address identified defects.
26. Procurement
Staff did not find any deficiencies.
27. Facility Inspections
Staff found the following deficiency:
· Platform preventive maintenance is not being performed at the required frequencies.
Recommendation:
13. VTA should either adhere to its Monthly Platform Preventive Maintenance Procedure (MTN-PR-6201) or revise it to reflect actual practice.
28. Track Components Inspection
Staff found the following deficiency:
· There exist a number of deferred maintenance items and no controls currently exist to alert management when noted defects found during preventive maintenance inspections are not being corrected in a timely manner.
Recommendation:
14. VTA should develop controls to ensure track defects found during inspections are not being deferred but rather corrected in a timely manner (MTN-PR-6408).
29. Security
Staff did not find any deficiencies.
30. Safety Data Collection and Analysis
Staff did not find any deficiencies.
31. Hazardous Management Process
Staff did not find any deficiencies.
32. System Modification
Staff did not find any deficiencies.
APPENDICES
A. TSA Executive Summary of VTA System Security Review
B. VTA 2007 Triennial Safety Review Checklist Index
C. VTA 2007 Triennial Safety Review Recommendations List
D. VTA 2007 Triennial Safety Review Checklists
APPENDIX A
TSA EXCUTIVE SUMMARY
October 31, 2007
U.S. Department of Homeland Security
EXECUTIVE SUMMARY
Ms. Georgetta Gregory
Supervisor Rail Transit Safety Section
State of California Public Utilities Commission
Consumer Safety and Protection Division
Rail Operations and Safety Branch
320 W. 4th Street, Room 500
Los Angeles, CA 90013
Re: State of California Public Utilities Commission (CPUC) Tri-ennial Safety and Security Audit of the Santa Clara Valley Transportation Authority (VTA)
Dear Ms. Gregory:
On behalf of the Surface Transportation Security Inspection Program (STSIP), the following reflects the results of our involvement with your organization and VTA system safety/security personnel during October, 2007 in San Jose as part of CPUC's Tri-ennial Safety and Security Audit process. Acting as your "security agent" in this process, we utilized the TSA Baseline Assessment and Security Enhancement (BASE) Review checklist to document and baseline the internal processes, procedures and policies inherent to the VTA system in light of the most recent CFR 49 Part 659 requirements.
Following our review of VTA documents and interviews of key personnel, we compared our findings with the Security Plan requirements contained in CPUC General Order No. 164-D, Sections 4 and 5. This letter provides a summary of our findings with respect to compliance with those sections.
The information collected reflects information contained in various documents including VTA's:
· System Security Plan (SSP),
· Emergency Operations Plan,
· Fire/Life Safety Program,
· Emergency response exercise after-action reports.
The System Security Plan was updated in July, 2007 and CPUC review of the document was confirmed by letter dated August 24, 2007.
Personnel interviews were also conducted with VTA security, operations, risk management and training personnel. In addition, STSIP personnel visited several VTA facilities and have observed operations.
Our findings of deficiencies are as follows:
· A process for conducting internal security reviews to evaluate compliance and measure the effectiveness of the Security Plan is not described in the SSP. (GO-164-D, Sec 4.3.d)
· A schedule of internal security audits to be performed during each calendar year has not been established. (GO-164-D, Sec 5.3)
· As a schedule for internal security audits has not been developed, annual security audits have not been performed nor documented. (GO-164-D, Secs. 5.1 and 5.5)
· Annual reports and formal letters certifying compliance with the SSP have not been submitted to CPUC. (GO-164-D, Secs. 5.5.a, 5.5.b and 5.5.c)
It should be noted that the deficiencies identified all relate to documentation required in the referenced sections of GO-164-D. While these deficiencies need remediation, it is also important to note that based on our overall review of documents, interviews and system observations, we found that VTA has a progressive and effective security program in place and is an active participant in emergency response exercises with police and fire departments in its service area.
Once again, we appreciate the opportunity to be of assistance to CPUC in conducting the security portion of the Tri-ennial Audits.
Sincerely,
Ken W. Dixon
Inspector
Transportation Security Administration
Surface Transportation Security Inspector Program
245 So. Spruce Avenue
South San Francisco, CA 94080
Cc: Mr. Raed Dwairi, CPUC
Ms. Cathy Hendrix - SC VTA
APPENDIX B
2007 VTA TRIENNIAL SAFETY REVIEW CHECKLIST INDEX
Checklist No. |
Department |
Element/Characteristics |
1 |
Vehicle Maintenance |
Light Rail Vehicle Inspection - CPUC INSPECTOR |
2 |
Way, Power & Signal |
Track and Switch Inspection - CPUC INSPECTORS |
3 |
Way, Power & Signal |
Gated Grade Crossings Warning Devices - CPUC INSPECTOR |
4 |
Way, Power & Signal |
Traction Power Inspection - CPUC INSPECTOR(S) |
5 |
Way, Power & Signal |
Overhead Catenary System Inspections and Records |
6 |
Way, Power & Signal |
Substation Inspections and Records |
7 |
Risk Management |
Internal Safety & Security Audits/Reviews |
8 |
Way, Power & Signal |
Right-of-Way Maintenance |
9 |
Way, Power & Signal |
Vital Relays Inspections, Maintenance and Records |
10 |
Risk Management |
Employee and Contractors Safety Program |
11 |
Quality Assurance |
Calibration of Measuring and Testing Equipment Program |
12 |
Way, Power & Signal |
Gated Crossing Maintenance |
13 |
Risk Management Transportation Maintenance Engineering |
Accident/Incident Reporting and Investigation |
14 |
Risk Management Engineering and Construction |
Safety Certification |
15 |
Records Management Rail Design and Construction Vehicle Maintenance Maintenance Engineering Risk Management |
Configuration Management |
16 |
Rail Operations |
Review Operating Rules and Procedures Manual |
17 |
Risk Management |
Hazardous Material Programs/Environmental Management |
18 |
Risk Management |
Emergency Response, Planning, Coordination, Training |
19 |
Rail Operations Tech. Training |
Light Rail Training and Certification |
20 |
Vehicle Maintenance |
Light Rail Vehicle Maintenance |
21 |
Administrative Services |
Drug & Alcohol Program |
22 |
Technical Training |
Operational Evaluation Records |
23 |
Operations |
Hours of Service - Train Operators, Train Controllers, and Supervisors |
24 |
Way, Power & Signal |
Way, Power & Signal Internal Audit Program |
25 |
Engineering |
Bridges/Structures Inspections & Reports |
26 |
Materials Mgmt. |
Procurement |
27 |
Way, Power & Signal |
Facility Inspections |
28 |
Way, Power & Signal |
Track Components Inspection |
29 |
Protective Services |
Security |
30 |
Risk Management Operations |
Safety Data Collection and Analysis |
31 |
Risk Management Operations |
Hazard Management Process |
32 |
Maintenance Engineering |
System Modification |
APPENDIX C
2007 VTA TRIENNIAL SAFETY REVIEW RECOMMENDATIONS LIST
No. |
Recommendation |
Checklist No. |
1 |
VTA should revise its appropriate grade crossing preventive maintenance procedures to add the requirements of ensuring crossing gate heights comply with General Order 75-D and pedestrian warning signs are not blocked by vegetation or other means. |
3 |
2 |
VTA should develop controls to make certain that corrective actions pertaining to grade crossing credible reports are properly documented (CFR 49 Part 225.19). |
3 |
3 |
VTA should inspect the entire OCS and take necessary measures to ensure tree branches and/or foliage are in compliance with the requirements of GO 95 Table 1 of Rule 37, Case 13 - Column 3, and Rule 35, as well as, the system is constructed in compliance with GO 95 Rule 74.4-F. |
4 |
4 |
VTA should revise its current annual substation inspection procedure to include forms which pertain to the new Impulse Substations and add the requirement of designating a qualified person to review and approve substation and OCS inspection and maintenance records in the event a supervisor is not available to do so. |
6 |
5 |
VTA should ensure that a description of Corrective Action Plan; Implementation Schedule Date of the Corrective Action Plan; and Completion Status (Date and Action taken to correct noted items) is included in the checklist for each recommendation made by the VTA auditor as a result of the audit and tracked by RSSRB to ensure that the recommendations are implemented in a timely manner (GO 164-D Rule 5.5). |
7 |
6 |
VTA should prioritize fencing installation/repair such that fencing in areas with likely pedestrian intrusions be repaired expediently (GO 143-B Rule 9.03) |
8 |
7 |
VTA should produce documentation that it replaced all relays not meeting prescribed voltage requirements and develop controls to make certain that vital relays are maintained to standards with appropriate supporting documentation (MTN-PR-6206). |
9 |
8 |
VTA should document the closure of identified deficiencies found during Maintenance Superintendent's and Monthly Safety Facilities Inspections and incorporate a sign-off section in the applicable inspection records. |
10 |
9 |
VTA should conduct an annual audit of its confined space entries as prescribed by FRS-RM-1801 Section 4.8 as well as update and clearly define the Confined Space Entry List. |
17 |
10 |
VTA should develop controls to eliminate unacceptable excuses for drug & alcohol testing when randomly attempting to test its safety sensitive employees (CFR 49 Parts 40 and 655). |
21 |
11 |
VTA should ensure that WP&S preventive maintenance audits are conducted and all required records are prepared in accordance with MTN-PR-6805 requirements. |
24 |
12 |
VTA should develop a Bridge/Concrete Structures Inspection SOP distinguishing between maintenance and structural defects including documentation of appropriate corrective action plan, department responsible for corrective actions and implementation schedule to address identified defects. |
25 |
13 |
VTA should either adhere to its Monthly Platform Preventive Maintenance Procedure (MTN-PR-6201) or revise it to reflect actual practice. |
27 |
14 |
VTA should develop controls to ensure track defects found during inspections are not being deferred but rather corrected in a timely manner (MTN-PR-6408). |
28 |
APPENDIX D
2007 VTA TRIENNIAL REVIEW CHECKLISTS
1 The FTA's latest revision of 49 CFR Part 659 became effective in May 2006. Subsequently, the Commission revised and adopted General Order 164-D which superseded 164-C on May 3, 2007. Until the Commission's adoption of GO 164-D, staff requested VTA to revise their SSPP according to the FTA's latest revision of 49 CFR Part 659 which would be, in essence, the requirements of GO 164-D. Since this audit covered the time period that GO 164-D requirements weren't applicable, the reviewers referred to GO 164-C for a portion of the review. However, the reviewers referred to GO 164-D where applicable.
