Southeastern Transportation Authority 1234 Market Street Safety • Service • Continuous Improvement , PA 19107-3780 ~ "

June 18, 2015

Mr. Robert Lauby Associate Administrator for Safety Chief Safety Officer Federal Railroad Administration, Mail Stop 25 1200 New Jersey Avenue, SE. Washington, DC 20590

Subject: V Air Brake Maintenance: Petition for Special Approval of Alternate Standard to 49 CFR 238.309 (b)(2)

Reference: 49 CFR 238.309 (b)(2)- Periodic Brake Equipment Maintenance 49 CFR 238.21 (b)- Special Approval Procedure

Dear Mr. Lauby:

Pursuant to the requirements of 49 CFR 238.21 -Special Approval Procedure, the Southeastern Pennsylvania Transportation Authority (SEPTA) requests consideration for special approval of an alternate standard to that specified in 49 CFR 238.309(b)(2)- Periodic Brake Equipment Maintenance, for the Silverliner V MU locomotive air brake equipment Currently, 49 CFR 238.309(b)(2) stipulates that brake equipment and brake cylinders of each MU locomotive shall be cleaned, repaired, and tested at intervals of every 1,104 days if the MU locomotive is part of a fleet that is 100 percent equipped with air dryers, and has a brake system using RT-5A-style valves (among others). The RT-5A+ brake system in use on the Silverliner V MU fleet employs a microprocessor based control system, and utilizes active and passive diagnostics to monitor brake performance. Currently, other air brake systems that incorporate microprocessor controls are subject to overhaul intervals of 1,840 days (for example, 238.309 (b)(3) and 238.309 (e)(l)). SEPTA therefore submits the alternate proposal to increase the periodic brake equipment maintenance interval for the Silverliner V air brake system to a minimum of 1,840 days.

In support of this petition for approval of an alternate standard to 49 CFR 238.309(b )(2), SEPTA provides the following data and analysis for support that an equivalent level of safety will be maintained by increasing the periodic brake equipment maintenance interval to 1,840 days:

A. Background Information:

1. RT-5A+ System and Air Supply Functional Description and Operation

The SEPTA Silverliner V RT-5A+ brake equipment is supplied by Wabtec Passenger Transit (WPT). The System Functional Description (SFD) document (WPT Document E-A0698653-5 10 REV. E) is

1 appended to this petition as Attachment 1. The SFD provides a detailed overall description of the brake equipment operation for the RT-5A+ system.

The Silverliner V RT-5A+ brake control system provides fully electronic control of service friction braking with an all-pneumatic back-up service brake. The fully electronic service friction brake has load weigh braking and continuous blending with the electric brake, while the all-pneumatic back-up has cutoff load weigh and no blending. The complete RT-5A+ equipment is comprised of Disc and Tread Actuators, Cab Brake Control Handle Unit (BCHU), Air Compressor Unit, Brake Cylinder Control (BCCU) with backup Emergency function for brake cylinder pressure control on each truck, a car level Brake Pipe Control Unit (BPCU) to manipulate Brake Pipe (BP) pressure, and a Friction Brake Control Unit (FBCU) for the electronic controls. Service friction brake control includes blending friction brake forces with the electric braking system and a backup service brake control provided by an MC-30A Control Valve. Emergency braking can be initiated through pneumatic or electrical manners, via components including the BCHU, vent valves, brake pipe pressure switches, and emergency train lines. Additional detail regarding the service and emergency braking methodology can be found in the SFD.

The Silverliner V fleet consists of self-propelled Electric Multiple Unit (EMU) car types both of single and married pair configurations with a cab at each end. Each car has an air compressor with an integral air dryer. The cars may be coupled in various combinations up to twelve cars for normal operation; although the normal train consist will not exceed six cars. A continuous main reservoir pipe is provided within each train to provide equalization of main reservoir air pressure within the train. A continuous brake pipe is provided within each train to provide friction brake control within the train. In service brake applications, the friction brakes normally apply in a blended combination with the electric brakes to decelerate the vehicle. In emergency brake applications, the friction braking equipment provides all of the deceleration force without the added application of the electric brakes.

The air compressor supplied on the Silverliner V fleet is a D-4-AS model. The unit is comprised of a "2CY3MD" air compressor portion, an electrical control box, an E-lA Twin Tower Air Dryer, a LX air filter, an aftercooler assembly, and a 230 VAC motor. Air delivery from the air compressor portion is cooled by the aftercooler assembly and dried by the twin tower air dryer. Compressor and air dryer maintenance is conducted on a yearly basis to ensure consistency of air quality; an extended maintenance cycle for the air compressor unit is not to be considered in regards to this petition.

2. RT-5A+ System Monitoring and Diagnostics Description

Diagnostics, both passive (tests performed automatically during normal operation) and active (user driven), are provided by the Friction Brake Control Unit (FBCU) on the SEPTA Silverliner V RT-5A+ brake system. The FBCU provides friction braking, blended braking with propulsion, and friction brake wheel slide control. TheWAB-LINK Interface software works with the FBCU Application to provide user interfacing. The FBCU also interfaces with Propulsion Neuron software to communicate with the propulsion system through an additional Lon Works network.

The FBCU provides indications of diagnostic malfunctions. The unit provides the status to the display, an event count value, and the date and time stored in RAM for retrieval by the W AB-LINK Interface when a change in condition effecting normal operation of the equipment occurs. In most operational diagnostic events, an associated data log is also stored that contains data prior to and after the event was determined. Responses of the FBCU may include placing the unit in a safe state or setting outputs to an application state, for example.

The user interface enables users to interact with the Application software for the unit. Visual displays and LEDs, along with a CPU pushbutton, allow users to provide limited input to the Application software.

2 Diagnostic and maintenance action codes are provided on the FBCU, as events are encountered during operating service (passive diagnostics). A user driven self-test allows the technician to conduct an automated self-test that will exercise the complete brake control system to verify proper functionality (active diagnostics). Unexpected performance during the self-test will result in a code provide direction to the technician. Additional data can be retrieved from the FBCU via a laptop connection, providing more details to the number and timing of event occurrences. Full details of the LED and Fault Codes are available in Attachment 2, Software User Document (WPT document E-El-52543-504, Rev. FI).

B. Data and Analysis

I. Subsystem Hazard Analysis I Fault Tree Analysis

The Railroad has included the Friction Brake Subsystem Hazard Analysis (SSHA), WPT document E­ S0698653-105, Rev. G, appended to this petition as Attachment 3. The SSHA identifies the safety aspects of critical tasks performed by personnel in the process of testing, operating, and maintaining Friction Brake System equipment. The SSHA is being presented as part of the Petition in lieu of the Preliminary Hazard Analysis (PHA), as the SSHA provides more detailed safety analysis of the elements within the Friction Brake Subsystem. The SSHA has been performed in accordance with MIL-STD-882, which is recognized as an appropriate methodology for evaluating risks and identification of the associated mitigation measures. Categorizations for Hazard Severity, Probability, and Risk Acceptance Criteria have been defined by SEPTA and are referenced in the SSHA document.

A total of eighteen hazards were identified in the SSHA. Mitigations exist in all hazard cases to reduce either the severity and/or the probability of the given hazard. Seven of the hazards were identified as Safety Critical Hazards, having a Severity level of I or II. A Fault Tree Analysis (FTA), WPT document E-S0698653-107, Rev. D, appended to this petition as Attachment 4, was performed to further assess events that result in a Category I or II Severity level. The results of the FTA reveal extremely low probability of total loss in emergency or service braking on the RT-5A+ system used on the Silverliner V fleet.

2. Failure Modes and Effects Analysis

A Failure Modes Effects and Criticality Analysis (FMECA) has been performed on the RT-5A+ Friction Brake System equipment, to demonstrate compliance with reliability requirements, and is appended to this petition as Attachment 5 (WPT document E-R0698653-l 02, Rev. C). The FMECA provides additional detail, to a component level, of hazards identified in the SSHA and FTA. Mitigations for failure modes with critical severity levels are fully described.

3. Maintainability I Reliability Analysis

The Maintainability Analysis, WPT Document E-M0698653-103 Rev. Fl, and the Reliability Analysis, WPT Document E-R0698653-101, Rev. E, for the complete friction brake system are provided as Attachments 6 and 7, respectively. The Maintainability Analysis has been performed considering a 60 month I 5 year overhaul schedule for the brake control equipment subject to overhaul in 49 CFR 238.309. Reliability predictions for the friction brake equipment exceed the allocation required by the Silverliner V specifications.

3 4. In-Service History ofRT-5A+ Components Subject to Overhaul

The periodic brake equipment maintenance requirements set forth in 49 CFR 238.309 (a)(l) state that "all of the equipment's brake system pneumatic components that contain moving parts and are sealed against air leaks be removed from the equipment, disassembled, cleaned, and lubricated and that the parts that can deteriorate with age be replaced". The internal components of the RT-5A+ system that are subject to this requirement are in use on other Wabtec air brake systems in service at other railroads, some of which overhaul brake components at intervals greater than or equal to 5 years. For example, the New York City Transit Authority (NYCTA) R-160 series fleet utilizes a similar WPT RT-5A+ brake system as the SEPTA Silverliner V system; NYCTA currently overhauls the brake control equipment components of the RT-5A+ system on a 7 year schedule. While operating conditions may differ between rail transportation systems, the in-service history of brake components operating at overhaul periods equal to or greater than 60 months I 5 years provides another supporting data point for this petition.

5. Condition of Material@ 1,104 Day Overhaul Interval

To date, 91 cars ofthe 120 car fleet in the Silverliner V fleet have undergone the required 1,104 day brake overhaul. The components that were replaced during the overhauls from Cars 855 and 856 (performed at the SEPTA Wayne Junction maintenance facility) were retained. Components from Car 856 were sent to the Wabtec Passenger Transit facility in Spartanburg, SC for inspection and analysis. The findings of this inspection have been documented by WPT (Document E-A0695653-520) are included as Attachment 8. All removed components were in very good condition. There were no instances of torn or worn through rubber components, or broken springs. Following the review of the removed internal components, Wabtec Passenger Transit affirms that no unexpected wear was discovered, and that the useful life of the components had not been reached. For further reference, components from Car 856 have been retained at the SEPTA Wayne Junction.

In summary, SEPTA submits the alternate proposal to increase the periodic brake equipment maintenance interval for the Silverliner V air brake system to a minimum of I ,840 days. The technical documents attached, which review the RT-5A+ system functional description, safety and maintainability analyses, and inspection of components in use, are submitted in support of the petition. SEPTA attests that the supporting information establishes that the alternative interval proposed will provide at least an equivalent level of safety.

In accordance with 49 CFR 23 8.21 (b )(1 ), SEPTA identifies the primary person to be contacted with regard to review ofthe petition as:

Mr. Sherman Shreves Manager Engineering, Regional Rail 1234 Market St., 14th Floor Philadelphia, PA, 19107 215.580.8021 sshreves@.org

4 In accordance with 49 CFR 238.21(b)(4), SEPTA affirms that the railroad has served a copy ofthe petition to the designated representatives of its employees whose names and addresses are listed in Attachment 9:

As a final note, it should be noted that the attached documents to this petition are considered proprietary by Wabtec Passenger Transit, and therefore it is requested that they are not published as part of the public docket.

Sincerely, ~=~(~)

Chief Engineering Officer, Rail Vehicle Engineering cc: R.Hopkins S. Shreves S. Sauer

5 Attachments:

I. WPT Document E-A0698653-510 REV. E, System Functional Description, SEPTA Silverliner V Friction Brake System

2. WPT Document E-El-52543-504, Rev. FI, SUD- Software User Document

3. WPT Document E-S0698653-105, Rev. G, Subsystem Hazard Analysis, SEPTA Silverliner V Cars, Friction Brake Equipment

4. WPT Document E-S0698653-107, Rev. D, Fault Tree Analysis, SEPTA Silverliner V Cars, Friction Brake Equipment

5. WPT Document E-R0698653-102, Rev. C, Failure Modes Effects and Criticality Analysis, SEPTA Silverliner V Cars, Friction Brake Equipment

6. WPT Document E-M0698653-103 Rev. FI, Maintainability Analysis- Extended, SEPTA Silverliner V Cars, Friction Brake Equipment

7. WPT Document E-R0698653-101, Rev. E, Reliability Analysis, SEPTA Silverliner VCars, Friction Brake Equipment

8. WPT Document E-A0695653-520 Rev. A, Analysis I Inspection of RT-5A+ Components, SEPTA Silverliner V, 3 Year Interval

9. SEPTA Designated Representative Contact List

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