2 Broadway Andy Byford Now York, NY 10008 President (46, 252-5800 Tol (646-252-5815 Fax D New York City Transit October 10, 2019 Carolyn Pokorny Inspector General Metropolitan Transportation Authority 1 Penn Plaza, 11" Floor New York, NY 10119 Re: Borough Hall Ceiling Collapse and the Flaws in NYCT Underground Structural Inspections - MTA/OIG #2019-17 Dear IG Pokomy: ‘This information is being provided in response to the MTA/OIG report on the Borough Hall Ceiling Collapse (#2019-17). New York City Transit (NYCT) has carefully reviewed the report and offers the following comments: Response to Findings: A. MOW Engineering Lacks the Ability to Reliably Assess Defects in Terra Cotta. Structural inspections are taken very seriously by NYCT, and are performed annually by trained personnel, with special attention to issues that may pose a safety concem. The Borough Hall station was constructed over 100 years ago (in 1908), and the terra cotta ceiling treatment was part of the original construction. The underlying structural elements of concrete and steel, in this case, were covered by the terra cotta block incorporated for aesthetic purposes, serving as a base for the plaster and paint finish. The historical as-built drawings do not provide accurate details of these outer coverings nor how they are affixed to the actual structure. The issue in this case was not a lack of understanding of the technical properties of terra cotta, rather the absence of specific architectural detail regarding uncommon construction. Based upon the information available, Maintenance of Way (MOW) Engineers, as per NYCT policy, performed visual inspections and initiated more comprehensive testing, such as “sound and tap,” an accepted exploratory practice for many masonry structures, when a suspect condition is observed. Since this incident, MOW Engineering revised procedures to be followed when inspection personnel encounter structures, construction types, materials, configurations or other conditions that they are unable to assess using the Structural Inspection Policy Instruction or their own experience and expertise. MTA New York Gity Transits an agency of the Metropoltan Transportation Authority, State of New YorkMs. Carolyn Pokomy Re: Borough Hall Ceiling Collapse and the Flaws in NYCT Underground Structural Inspections ~ Draft Report MTA/OIG #2019-17 October 10, 2019 Page 2 of 5 After the initial collapse of a portion of the ceiling at Borough Hall, MOW Engineering worked with in-house forces to remove loose material and assess the historic construction and stability of the terra cotta ceiling through an extensive program of sound and tap over the platforms and right of way. During this period, additional failures of sections were observed including some sections of block that dislodged with structural concrete adhered to them. It became apparent that immediate intervention was required and there were two options, either remove all the terra cotta block or shield the entire station until the capitally funded station rehabilitation project begins December 2021. The shielding method was chosen to ensure safety and as the most cost- effective and expeditious option available. Complete removal of the terra cotta tiles will be performed as part of the station rehabilitation project (that will also address water intrusion and steel repairs) and, since the contractor who would erect the shield was already on board, this option was also the most expedient, For the other 12 stations with terra cotta ceilings, MOW Engineering is following the same policy. If defects are identified similar to those at Borough Hall, the recommended course of action will be to completely remove the terra cotta block from the affected “bay” from structural support to structural support. If that cannot be quickly accomplished, then that bay must have shielding installed until the removal of the terra cotta can be scheduled. Capital Program Management (CPM) has a consultant currently studying this issue and may suggest alternative approaches when that study is completed. B. MOW Did Not Know Which Stations Have Terra Cotta, As noted in the report, after the ceiling collapse MOW Engincering, and a CPM consulting firm worked alongside the agency's in-house forces to survey stations. A total of 13 stations have been documented with terra cotta ceilings in their construction, C. NYC Transit Failed to Act on 2010 OIG Recommendation, ‘The use of consultants for special inspections of suspended ceilings and high brick and masonry arch structures is already included in the Structural Inspection Policy Instruction, with the inspections performed on a 5-year cycle. As a result of the collapse, Station Condition Surveys, also done by consultants on a 5-year cycle, will be modified to include identification and documentation of each type of ceiling material found throughout the stations. MOW Engineering is also currently working with CPM to have a consultant perform pull tests at all known locations where terra cotta tile is found in NYCT station ceilings to determine the stability of the existing tile. The report cites previous OIG recommendations that CPM’s specialty consultants should assist MOW engineers with assessments of unusual structures and situations. Per policy, contractors are being used for special inspections. During the interviews, representatives of MOW Engineering did indicate that using consultants through CPM’s “On-Call” consultant selectionMs. Carolyn Pokorny Re: Borough Hall Ceiling Collapse and the Flaws in NYCT Underground Structural Inspections ~ Draft Report MTA/OIG #2019-17 October 10, 2019 Page 3 of 5 process can be cumbersome and time consuming. This process requires that bids from more than one of the pre-qualified consultants be received and evaluated before the consultant is engaged. MOW Engineering is working with CPM to expedite access to consultant experts when unusual or unfamiliar construction details are encountered that require evaluation of structural integrity that MOW and CPM staff cannot provide. D. — MOW Engineering Missed Some Conditions that Required Timely Action. The report notes that, in response to the OIG’s findings, MOW Engineering has made improvements to its defect reporting process. Additional detail is found in the “responses to recommendations” section below. E. MOW Engineering has a plan for improved interim inspections at Borough Hall Station. The report mentions the MOW Engineering inspection plan for the newly installed shield at Borough Hall, during which MOW engineers will accompany the contractors on their periodic visits to maintain the shield. This plan includes a conservative approach to any signs of distress, dictating that for areas where active leaks are identified, contractor personnel will be instructed to remove panels from the shielding to allow engincers to evaluate the ceiling’s condition directly. Regarding the OIG finding that when “we asked MOW Engineering managers how they would conduct the required annual visual inspections of the ceiling during the additional two years that the temporary shielding will obstruct it, the managers initially told us they planned only to inspect the shield’s underside, where any staining or water damage would indicate a potentially significant defect in the ceiling above the shield,” MOW Engineering management believes this statement may have been miscommunicated or misunderstood during the interview process. Although looking for signs of deterioration on the underside of the shielding will be used as a method of inspection, this method was never intended to be used as the only method of inspection. In fact, MOW Engineering directed the contractor who installed the shield to remove specific sections so it could be determined if any further material had fallen in April 2019, Responses to Recommendations: Recommendation 1: MOW inspectors, maintenance supervisors, and engineers should be trained to identify and document non-typical types of construction and materials found during inspections. NYCT Response: MOW Engineering has a formal training program for its inspectors (including both classroom instruction and on-the-job training) to ensure that they are familiar with inspection policies and procedures, and to ensure they have acquired the skills necessary toMs. Carolyn Pokorny Re: Borough Hall Ceiling Collapse and the Flaws in NYCT Underground Structural Inspections — Draft Report MTA/OIG #2019-17 October 10, 2019 Page 4 of 5 identify, classify, and report structural defects. After the ceiling collapse, MOW Engineering bolstered this program: © A positive compliance directive was issued on 9/13/19 to all engineering personnel involved in the inspection process to pay special attention to ceilings at all 13 stations with terra cotta imbedded in the ceiling cover. Station department supervisors have been notified as well. The directive details procedures to be followed when inspection personnel encounter structures, construction types, materials, configurations or other conditions that they are unable to assess using the Structural Inspection Policy Instruction or their own experience and expertise. ‘* Specific practices with respect to uncommon construction materials will be incorporated into training sessions beginning in the fourth quarter of 2019. Compliance with the new Policy Instruction will be monitored through newly initiated quarterly internal audits performed by MOW Engineering to visually reinspect areas of NYCT structure recently inspected by the Structural Inspections Group. These audits will commence in the fourth quarter of 2019 and will ensure adherence to the new instructions and provide a quality control check on the accuracy of defect reporting. Recommendation 2: MOW personnel conducting inspections should be required to disclose when they are not able to provide an accurate assessment of any type of construction or material, particularly non-steel and non-concrete structures. In such cases, MOW Engineering should use outside consultants with specialized training to assess the condition of the non-standard construction or material. NYCT Response: As stated above, the positive compliance directive details procedures to be followed when inspectors are not able to provide an accurate assessment of non-standard construction or material. Also, as noted in the response to Finding C, MOW Engineering will utilize outside consultants with specialized training to provide this assessment, Recommendation 3: MOW Engineering periodically should review a report to identify instances of severe corrosion across three consecutive structural columns or beams that might meet the criteria for an IA condition NYCT Response: MOW Engineering is in the process of modifying its defect report to include a specific section to certify that adjacencies and aggravating factors have been considered, explicitly identifying instances of severe corrosion across three consecutive structural columns or beams that might meet the criteria for an IA condition, The modified report will also note conditions found that are outside the inspection team’s competence to allow for timely referral to supervision/management for follow-up.Ms. Carolyn Pokorny Re: Borough Hall Ceiling Collapse and the Flaws in NYCT Underground Structural Inspections — Draft Report MTA/OIG #2019-17 October 10, 2019 Page 5 of 5 In addition, MOW engineering is currently in the process of transitioning its structural inspection databases into the EAM Infor format, which will bolster current database capabilities. One such enhancement will be a “three-in-a-row” defect identification report that will automatically elevate the priority of these defects to immediate action, Recommendation 4: MOW Engineering should assess how quickly any newly identified IA defects need to be repaired, arrange for their timely repair, track these IA defects in a list or database, and monitor the progress of the repairs to ensure their timely completion. NYCT Response: MOW Engineering personnel performing inspections have been instructed to call the MOW Control Desk immediately upon finding an IA condition. This will ensure a timeline is established for the identification and remediation of the condition. MOW Engineering will begin to report on status of any reported IA conditions in a monthly Structural Defect Summary Report that will be provided to the Vice President and Chief Maintenance Officer, and the Chief Infrastructure Officer. Long term, there are plans to include subway inspection findings in the EAM Infor system, which will provide a combined timeline of both inspection and repair activities which will facilitate scheduling and compliance with time limits. MOW Engineering has also developed a process to provide a quality assurance check on the accuracy of defect reporting and compliance with all Policy Instruction procedures. Infrastructure Engineering has been instructed to begin performing quarterly internal audits using structural engineers from the Civil-Structural subdivision to visually reinspect structural areas recently inspected by the Structural Inspections Group. Thank you for your team’s work on this critical subject. Andy Byford President ce: Sally Librera Janno Lieber Alok Saha