HomeMy WebLinkAboutCC AG PKT 2001-12-10 Supplemental Information - Correspondence re: Project 820; Confidential agenda reportDecember 11, 2001
Mr. B. Tilden Kim
Richards, Watson 6 Gershon
355 South Grand Avenue, 60`" Floor
Seal Beach, California 90071
Dear Mr. Kim,
Pursuant to your letter of November 26" to City Manager
John Bahorski, forwarded are two fully executed copies of
the Mutual Release and Settlement Agreement relating to the
Main Street Alley Improvement Project, Project Number 820,
entered into by and between Southern California Grading,
Inc. and the City of Seal Beach, as well City of Seal Beach
check number 35796 in the amount of $79,000, the settlement
amount.
From your letter it is understood that
copy of the executed Release and check
counsel for Southern California Grading
the Agreement is for your file.
Very truly yours,
Joanne M. Yeo, City Clerk
City of Seal Beach
Encl.
you will forward a
number 35796 to legal
The second copy of
THE CITY OF
SEAL BEACH
35796
Final settlement
paymenL
for the sewer main street alley project.
35796
BANK OF AMERICA
THE CITY OF SEAL BEACH SEAL BEACH BRANCH 0139
211 STH STREET 20B MAIN STREET
SEAL BEACH, CA 90740
SEAL BEACH, CA W740.079
220
(562)431-2527 (582) 3
1
18 BB -0220
Pay: ***Seventy nine thousand dollars 6' Zero cents
Date Amount
12/11/01 $79,000.00
To the order of:
SOUTHERN CALIFORNIA GRADING, INC.----//7�p/I_"_�'/"�-//��_�,
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INRICHARDS I WATSON I GERSHON
ATTORNEYS AT LAW -A PROFESSIONAL CORPORATION
355 South Grand Avenue, path Floor, Los Angeles, Cali(omia 90073-3101
Telephone 313.626.8484 Facsimile 333.626.0078
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IACSIMILE 714-9906230
John B. Bahorski
City Manager
City of Seal Beach
211 8" Street
Seal Beach, CA 90740
ATTORNEY WORK PRODUCT
ATTORNEY-CLIENT PRIVILEGE
Reference: Southern California Grading Claim
Dear Mr. Bahorski:
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Enclosed is an executed Mutual Release and Settlement Agreement for the above -
referenced claim. We have approved it as to form. Upon your approval, please
have the settlement agreement executed, and return to our offices a copy of the
executed original, along with the $79,000 settlement draft made payable to
"Southern California Grading, Inc." We will then forward it to the claimant's
counsel. In the meantime, please do not hesitate to call me if you have any
questions or comments.
Very truly yours, se &Owwt If."000"
/
B: Tilde/ n Kim '
Enclosure r _-u ✓i
cc: Doug Dancs, Director of public Works (w/enclosure) 41,RC1
S7296\0001\676322.1
CONFIDENTIAL
THIS MATERIAL IS SUBJECT TO THE ATTORNEY CLIENT ANO/OR THE
ATTORNEY WORN PRODUCT PRIVILEGES. 00 NOT DISCLOSE THE
CONTENTS HEREOF. DO HOT FILE WITH PUBLICLY ACCE SSIBLE RECORDS,
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Confidential
AGENDA REPORT
DATE:
November 13, 2001
TO:
Honorable Mayor and City Council
THRU:
John B. Bahorski, City Manager
FROM:
Doug Dancs, P.E., Director of Public Works/City Engineer
SUBJECT:
RESOLUTION OF THE SO CAL GRADING CLAIM
AGAINST THE CITY REGARDING MAIN STREET
ALLEY IMPROVEMENTS, PROJECT 820
SUMMARY OF REOUEST:
The proposed action will approve settlement between the claimant Southern California
Grading, Inc. and the City regarding the Main Street Alley Improvements, Project 820
BACKGROUND:
Attached is an analysis from the City Attorney's office regarding the claims for
additional monies made by Southern California Grading during the Main Street Alley
project.
Both the Engineering Division and the City Attorney's office worked together once there
was a potential of a claim during construction. The original claim was for $182.132.
After a long claims evaluation process, a proposed settlement of $79,000 amount was
reached between staff and the Contractor. The City Attorney's and City Engineer's office
agree that this appears to constitute a successful and cost-effective compromise as
opposed to litigation.
Each project has an associated risk factor. No project is immune from claims no matter
how many precautions are taken. Often the measures taken to produce the investigations,
design, and contract documents to prevent all risks would be cost prohibitive.
There were many factors that interacted to contribute to these events and will be
addressed on future work. One of the major factors involved that prevented staff from
adjusting cost overruns during the process was the inexperience of the contractor
performing work for public agencies. This contractor had never worked before as a
general contractor for a public agency and the contractor's forces comprised of less than
50% of the work with the majority of the work performed by subcontractors. This was the
Agenda nem$
primary factor for the Contractor reporting claims well after the fact of their occurrence
and it prevented staff from making field adjustments.
Staff is working with the City Attorney's office to use the newly state approved pre -
qualification process in our major contracts to hire more qualified contractors. Also, the
specifications have been adjusted to not allow for any Contractor to be awarded the work
that does not have at least 50% of the work performed by its own forces.
Another factor that contributed to the increased amount of the project was the discovery
of old abandoned utility lines not shown on the plans. Our engineering records are
incomplete since much of the original utility work was constructed over 50 years ago. It
would actually take excavating the entire alley to discover all the myriad of either
abandoned or undocumented locations of lines and laterals. In future projects the
Engineering Division has required additional pot -holing to locate lines to minimize such
events however there will always be a risk for underground conflicts.
FISCAL IMPACT:
Since this was a utility project, the claim for additional funds for this project will be
appropriated from the water and sewer enterprise funds. Funds are available in approved
CIP Project 50072 Water System Infrastructure Improvements/Reserve ($39,500) and
from the Sewer Certificates of Participations for the Master Plan capital improvement
program ($39,500) due to potential savings of eliminating the Aquatic Park force main by
diversion into the Huntington Beach sewer system.
RECOMMENDATION:
Staff recommends that the City Council approve the settlement offer and direct the City
orks/City Engineer
Agenda Item _ _
ATTORNEY WORK PRODUCT
ATTORNEY-CLW,NT PRIVQ.EGE
John B. Bahroski
City Manager
City of Seal Beach
2118"' Street
Seal Beach, CA 90740
Re: Recommendation on Resolution of So Cal Grading Claim
Regarding Main Street Alley Improvements, Project 820 (the "Projeco
Dear Mr. Bahroski:
This letter outlines the results of recent settlement discussions between claimant Southern
California Grading, Inc. ("SCG'), City staff, and the City Attorney's office. SCG was the general
contractor on the Project. In short, SCG submitted a claim against the City totaling in excess of
$182,132.00 for various claimed change order and delay damages arising out of the Project. After
several significant settlement discussions, SCG has agreed to settle and compromise its claims for
$79,000, subject to City Council approval. Set forth below is an analysis of SCG's claim, and our
recommendation for the City's approval of this hard-fought settlement.
1. Background Facts
The Project consisted of certain public works improvements in the alleys adjacent to Main
Street. SCG was the lowest bidder, bidding $318,342.58 for the Project. The original start date was
March 27, 2000, and the original completion date was June 26, 2000. SCG requested 56 additional
working days; in contrast, the City granted only I I working days, and reserved its rights to assert
liquidated damages. The City had claimed 28 delay days.
CONFIDENTIAL
THIS MATERWL IS SUBJECTTO THE ATTORNEY CLIENT
AND/OR THE ATTORNEY WORK PRODUCT PRMLEGES. DO
NOT DISCLOSE THE CONTENTS HEREOF. DO NOT FILE
WRH PUBLICLY ACCESSIBLE RECORDS
RICHARDS, WATSON & GERSHON
ATTORNEYS AT LAW
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October 26, 2001RANKS
ANUMIERRRA
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ATTORNEY WORK PRODUCT
ATTORNEY-CLW,NT PRIVQ.EGE
John B. Bahroski
City Manager
City of Seal Beach
2118"' Street
Seal Beach, CA 90740
Re: Recommendation on Resolution of So Cal Grading Claim
Regarding Main Street Alley Improvements, Project 820 (the "Projeco
Dear Mr. Bahroski:
This letter outlines the results of recent settlement discussions between claimant Southern
California Grading, Inc. ("SCG'), City staff, and the City Attorney's office. SCG was the general
contractor on the Project. In short, SCG submitted a claim against the City totaling in excess of
$182,132.00 for various claimed change order and delay damages arising out of the Project. After
several significant settlement discussions, SCG has agreed to settle and compromise its claims for
$79,000, subject to City Council approval. Set forth below is an analysis of SCG's claim, and our
recommendation for the City's approval of this hard-fought settlement.
1. Background Facts
The Project consisted of certain public works improvements in the alleys adjacent to Main
Street. SCG was the lowest bidder, bidding $318,342.58 for the Project. The original start date was
March 27, 2000, and the original completion date was June 26, 2000. SCG requested 56 additional
working days; in contrast, the City granted only I I working days, and reserved its rights to assert
liquidated damages. The City had claimed 28 delay days.
CONFIDENTIAL
THIS MATERWL IS SUBJECTTO THE ATTORNEY CLIENT
AND/OR THE ATTORNEY WORK PRODUCT PRMLEGES. DO
NOT DISCLOSE THE CONTENTS HEREOF. DO NOT FILE
WRH PUBLICLY ACCESSIBLE RECORDS
RICHARDS, WATSON a GERSHON
John B. Bahroski
October 26, 2001
Page 2
CONFIDENTIAL
THIS MATERIAL IS SUBJECT TO THE ATTORNEY
CLIENT ANOIOR THE ATTORNEY WORK PRODUCT
PRIVILEGES . DO NOT DISCLOSE THE CONTENTS
HEREOF. DO NOT FILE WITH PUBLICLY
ACCESSIBLE RECORDS.
Contrary to the normal course of business in public works projects, SCG was untimely in
many of its change order requests, and had failed to properly and timely document many of its
claimed additional work. It appears that SCG was fairly inexperienced in public works projects, and
thus, unfamiliar with procedures and protocols with respect to claiming extra work. Instead, at various
times near the conclusion of the Project, and after work was completed on the Project, SCG submitted
12 claimed items of additional work totaling $182,132.00.
Enclosed is City staffs summary of each of these 12 claims. After reviewing SCG's
documentation, City staff calculated that SCG had demonstrated an entitlement to only $16,900.00
additional monies in satisfaction of its claimed extra work totaling $182,132.00. Thus, in a letter
dated May 14, 2001, the City "closed out" the SCG contract by positing that the final contract amount
would be $340,570.58 (including the $16,900.00 claimed extra).
Several months later, SCG retained legal counsel, and in a letter dated August 16, 2001, SCG
submitted a clam against the City in an unspecified amount in excess of $100,000, i.e., presumably
the $182,132.00 minus $16,900 already paid by the City. Thus, SCG tendered a claim against the City
in a minimum amount of $165.232.00.
11. Settlement Analysis
In late September, 2001, City staff with counsel, as well as various representatives of SCG and
its counsel participated in an informal mediation in an attempt to resolve this claim. A survey of each
of the 12 claims reveals that the sheer majority of the claims were relatively low figures. However, 3
of the 12 claims totaled roughly $79,000 were the major "big-ticket" items: (1) Claim No. 4
(Condition of Existing Water Main, SCG claiming $17,398.77); (2) Claim No. 9 (Gas Main In Sewer
Trench, SCG claiming $39,603.90); and (3) Claim No. 10 (Sewer Encasement, SCG claiming
$23,066.66).
After the conclusion of several face-to-face discussions, City staff and its counsel determined
that, if litigated, SCG would be able to present credible evidence and testimony to substantiate many
of its claims. At the settlement conferences, SCG, for the first time, presented viable factual and legal
theories to substantiate many of their previously undocumented claims. Moreover, the City's potential
technical and proceduml defenses (such as untimeliness of their requested change orders, and non-
adherence to "Greenbook" procedures for submitting and documenting additional work claim), both
City staff and its counsel believed that SCG would nevertheless present compelling testimony and
documentation to seek additional compensation based upon "quantum meruit" theories, i.e., an
equitable doctrine allowing an aggrieved party's recovery for the reasonable value of the benefits
provided to another party.
For example, as to Claim No. 4, SCG demonstrated its ability to provide credible evidence
and testimony that the poor condition of the existing water main had significantly contributed to the
claimed additional work. Next, SCG and its subcontractor (Kennedy) submitted credible testimonials
to justify the magnitude of claimed extra work caused by the unforseen gas main in the sewer trench.
Finally, SCG demonstrated sufficient ambiguity in the plans and specifications to justify its claim for
additional compensation for concrete encasement of the sewer lines.
RICHARDS. WATSON a GERSHON
CONFIDENTIAL
THIS MATERIAL IS SUBJECT TO THE ATTORNEY -
John B. Bahroski CLIENT ANDIOR THE ATTORNEY WORN PRODUCT
PRMLEGES. DO NOT DISCLOSE THE CONTENTS
October 26, 2001 HEREOF. DO NOT FILE WITH PUBLICLY
ACCESSIBLE RECORDS
Page 3
Significant settlement negotiations resulted in SCG agreeing to compromise its claim by more
than 50%, and accept a settlement in the amount of $79,000.00. This figure roughly equates to an
acceptance of the three major clams (i.e., Claim Nos. 4, 9 and 10), and a rejection of the remaining 9
claims.
In short, if accepted by the City, it appears this settlement would constitute a successfiJl and
cost-effective compromise of legitimate claims of extra work. If the settlement proposal is approved
by the City Council, we recommend that this dispute resolution be memorialized in a formal
settlement agreement as SCG had presented the City With a formal claim. In the meantime, please call
me if you have any questions or comments.
Veryyours,
/Q�Ifden
Assistant City Attorney for
the City of Seal Beach
Enclosures
S729610WIW71179.1
cc: Quinn Barrow, City Attorney;
Doug Danes, Director of Public Works
CLAIM # 1
Alley Alignment
Project:
Main Street Alley, Project 820
Claim 01:
Alley Alignment
Contractor's Statement from Request
"There was an alignment conflict between the plans and survey stakes. Our
surveyor staked the job correctly in accordance with the plans. After survey was
completed it was obvious that the plans were drawn incorrectly. This resulted in
additional concrete removal, and one day delay to the schedule, and additional
costs over and above revenues earned by unit prices"
What was the amount of
$1,213.75 (Originally submitted $1,564.00)
the claim?
When did the claim occur?
June 27, 2000
When was the City
June 27, 2000
Notified?
Has the Contractor
Yes, extra work billing was submitted.
supplied the proper back
up documentation in
accordance with Section 3-
3 Extra Work and Section
3.5 Disputed Work of the
"Greenbook" ?
Engineering Division Analysis and Discussion:
As stated in January 11, 2001 letter to Southern California Grading, the
Engineering Division would process payment for the claim providing the
Contractor supplied the appropriate Extra Work Reports and back up
documentation as provided for in the "Greenbook" and Contract Documents.
Extra work bills were properly submitted. However, there were two workers and
a backhoe that did not show up on the construction manager's daily reports or
the contractors daily reports. Also, the contractor was including a subcontractor
mark-up which is not permissible when work is completed by his own forces. For
these reasons the allowable payment for this request was approved at $800.81.
Payment for this work has already been processed through City Council. A letter
was written to the Contractor dated March 15, 2001 approving payment for
$800.81.
CLAIM # 2
Broken Water Services
C
Project:
Main Street Alley, Project 820
Claim 92:
1 Broken Water Services
Contractor's Statement from Request
"During our demolition of the asphalt alley, our grinder hit a water services that
was abandoned improperly. This service was within inches of existing finished
service. This is not within code. We are requesting 1 day to the contract, plus
associated costs for Kennedy Pipeline's repair."
What was the amount of
$486.26. (Originally submitted $577.50)
the claim?
When did the claim occur?
June 27, 2000
When was the City
June 27, 2000
Noted?
Has the Contractor
Yes, extra work billing was submitted.
supplied the proper back
up documentation in
accordance with Section 3-
3 Extra Work and Section
3-5 Disputed Work of the
"Greenbook" ?
Engineering Division Analysis and Discussion:
As stated in January 11, 2001 letter to Southern California Grading, the
Engineering Division would process payment for the claim providing the
Contractor supplied the appropriate Extra Work Reports and back up
documentation as provided for in the "Greenbook" and Contract Documents.
The contractor submitted the proper paperwork. However, the hourly rate for the
foreman was too high. When comparing the certified payroll hourly rate from the
subcontractor, the construction manager noticed that the additional employer
payments for insurance, vacation... added to the foreman's wage was not as
high as that shown on the extra work bill. The construction manager added the
appropriate benefits amount to the hourly wage from the certified payroll for a
revised hourly rate acceptable to the City. Also the rental rate for the truck was
higher than that specified in the Caltrans Rental rate book. Total amount
approved for this work is $380.97. This amount has been processed through
City Council for payment.
A letter was written to the contractor, dated March 15, 2001 approving $380.97
forthiswork. i
CLAIM #3
Cable TV too High
Project:
Main Street Alley, Project 820
Claim #3:
Cable N to High
Contractor's statement from Request
"During work period from 6/24/00 we encountered cable N consisting of (3) 2"
conduits. These conduits were exposed as we excavated down to the subgrade.
These utilities should have been relocated prior to our work. We informed
Comcast and they proceeded to relocate their utilities. This resulted in a delay of
3 days to the construction schedule, and cost impact as shown above. See
attached letter dated 6/26/00."
What was the amount of
$4,336.61 ( Originally submitted $5,308.40)
the claim?
When did the claim occur?
June 24, 2000
When was the City
June 26, 2000
Notified?
Has the Contractor
Yes, extra work billing was submitted.
supplied the proper back
up documentation in
accordance with Section 3-
3 Extra Work and Section
3.5 Disputed Work of the
"Greenbook" ?
Engineering Division Analysis and Discussion:
It is our understanding, that at the comer of Main Street Alley and Electric
Avenue, the existing cable line was shallow and needed to be relocated deeper.
We understand that state law provides provisions to compensate the contractor
for the costs of locating, and repairing damage not due to the failure of the
contractor to exercise reasonable care, and removing or relocating such utility
facilities not indicated in the plans and specifications with reasonable accuracy,
and for equipment on the project necessarily idled during such work.
Our construction manager received a letter dated June 26, 2000 from Anthony
Cerisano, Southern California Grading, requesting two additional working days.
The letter states these two additional working days were to cover delays caused
not only by the cable line relocation but also a gas line conflict. The construction
manager granted the two additional working days per the letter to allow the Cable
Company to relocate facility.
When your back up for the claim was reviewed, it was noticed that the Contractor
is now claiming 3 working days for the Cable N relocation alone. This differed
significantly from what was granted according to your previous letter.
According to our inspector records and observations, contractor crews
proceeded in other parts of the job with no apparent crews remaining idle.
Therefore the City is not willing to pay for this claim since the Contractor retained
production in other parts of the job and additional days were granted for the
completion of the work.
No additional compensation will be made for this item.
*w yr
CLAIM #4
Condition of Existing Water
Main
Project:
Main Street Alley, Project 820
Claim ff4:
Condition of Existing Water Main
Contractor's Statement from Request
"The condition of the existing water main was such that continual seepage
deteriorated the subgrade and our trench backfill to the point that we were
required to export this over saturated material and stabilize the subgrade with
fabric and additional base rock. This is an unforseen existing condition beyond
our control. Total delays for this work is 8 days."
What was the amount of
$17,398.77 (Originally submitted $28,093.35)
the claim?
When did the claim occur?
March 30, 2000
When was the City
July 7, 2000
Notified?
Has the Contractor
Yes, extra work billing was submitted.
supplied the proper back
up documentation in
accordance with Section 3-
3 Extra Work and Section
3-5 Disputed Work of the
"Greenbook" ?
Engineering Division Analysis and Discussion:
The Contractor claims that the existing water main's continual seepage
deteriorated the sub -grade and this caused extra work to achieve the necessary
compaction.
As mentioned in from this report in Claim #11:
"The Contractor claims that the existing water line was 2" to 6" below sub -grade or
approximately 24" below the original grade. Most waterlines back in the 1920's were
often installed at a shallow depth and vary. The contractor's backup claims that the
contract documents indicate that this line would be found at the same elevation as the
proposed water main.
Addendum it4, of the contract documents, show a cross section of existing and proposed
water, sewer, and gas lines. The drawing is clearly labeled "Not to Scale." The dimension
called out for the water line is designated that the new line be installed at a minimum
depth of 3'. No "leader" line corresponds or references to the existing water line.
Accordingly, the Contract Documents do not indicate that these lines are at the same
depth but rather they are in the same general vicinity. Therefore, the Engineering Division
does not concur with your statement that this is an unforeseen and changed condition"
The area was dry. During the sewer work, no pockets of poor soil were
encountered. Accordingly, this was not a condition that existed prior to the project
except in the area adjacent to the Bank of America where the sprinklers were left
on.
The following is an analysis of the individual extra work bills submitted for this
claim:
4a: No work was performed on this day, 7/22/00. This is evident in the daily
work reports and the certified payroll. No payment will be made.
4b: The contractors daily report states that extra work was required due to
poor compaction by the sub -contractor. No payment will be made.
4c: This bill is acceptable with the exception of the subcontractor mark-up.
Material invoices must be submitted for the base rock material. The total
amount of money that will be approved is $5,138.26 upon receipt of
corresponding material invoices.
4d: Work shown on this extra work bill is contract item work. No additional
compensation will be made to the contractor for this bill.
4e: Work shown on this extra work bill is contract item work. No additional
compensation will be made to the contractor for this bill.
4f: Work shown on this extra work bill is contract item work. No additional
compensation will be made to the contractor for this bill.
4g: Work shown on this extra work bill is contract item work. No additional
compensation will be made to the contractor for this bill.
Total compensation for this extra work will be $5,138.26
CLAIM # 5
Existing Tie Ins
Project:
Main Street Alley, Project 820
Claim #5:
Existing Tie Ins
Contractor's Statement from Request
"The water main tie ins required significant modification because the existing
water main was not deep enough to match the new water main elevation. We
were required to stop work and wait for design change as described in the
attached CRSS letter 6/15/00. The modification delayed the job 3days in
addition to the associated cost shown above."
What was the amount of
$3,766.95 (Originally submitted $2,625.00)
the claim?
When did the claim occur?
June 27, 2000
When was the City
June 27, 2000
Notified?
Has the Contractor
Yes, extra work billing was submitted.
supplied the proper back
up documentation in
accordance with Section 3-
3 Extra Work and Section
3-5 Disputed Work of the
"Greenbook" ?
Engineering Division Analysis and Discussion:
As stated in January 11, 2001 letter to Southern California Grading, the
Engineering Division would process payment for the claim providing the
Contractor supplied the appropriate Extra Work Reports and back up
documentation as provided for in the "Greenbook" and Contract Documents.
The contractor submitted the proper paperwork. However, the foreman's hourly
rate was incorrect as was the hourly rate for the truck. The rates were
established as per the explanation in Claim number 2. A total of $3,755.95 is
approved as long as the contractor submits material invoices for verification. The
submittal of material invoices was expressed in the March 15, 2001 letter sent to
the contractor.
The amount of $3,755.95 was processed through City Council for payment. No
material invoices have been submitted as of yet.
CLAIM #6
Existing Utilities at Manhole
Project:
Main Street Alley, Project 820
Claim p6:
Existing Utilities at Manhole
Contractor's Statement from Request
"We request an additional 6 days added to the Contract"
What was the amount of
$0
the claim?
When did the claim occur?
March 3, 2000
When was the City
June 7, 2000
Notified?
Has the Contractor
No claim for cost was made.
supplied the proper back
up documentation in
accordance with Section 3-
3 Extra Work and Section
3.5 Disputed Work of the
"Greenbook" ?
Engineering Division Analysis and Discussion:
The Contractor is claiming additional 6 working days. Payment for claims was
dropped. The inspector job diaries do not reflect 6 working days but rather 2
working days.
Two additional working days are granted. No monetary compensation will be
made.
CLAIM # 7
Extra Services Added
Project:
Main Street Ailey, Project 820
Claim 97:
1 Extra Services Added
Contractor's Statement from Request
"City added (1) Fire Service, (5) 1 '/z" Water Services, and (4) 2" water services.
We are requesting 5 working days to the contract. Backup for Kennedy's work is
forthcoming."
What was the amount of
$9,450
the claim?
When did the claim occur?
•"
When was the City
•'•
Notified?
Has the Contractor
No, the paperwork supplied is not in accordance
supplied the proper back
with the provisions. There are no daily work
up documentation in
reports.
accordance with Section 3-
3 Extra Work and Section
3-5 Disputed Work of the
"Greenbook" ?
••• Early on in the project the City Water Dept notified the Inspector that there are
several meters in the Alley that are larger than 1" as the plans call out. The City
and Contractor were aware and it was understood that the Contractor would only
get reimbursed for the additional material size.
Engineering Division Analysis and Discussion:
This request entails the upsize of water services from what was noted on the
plans. According to the contractors backup, the City added one fire service, five
1 V water services, and four 2" water services. According to the contract
documents, all water services were to be 1" services. The fire service was
designated to be a 4" which was then upgraded to a 6" fire service.
Therefore, the Engineering Division will only allow costs for the difference in
material prices between five 1" services and five 1 %:" services and the difference
between four 1" services and four 2" services. Also, the Engineering Division will
only allow for the difference in material prices between 4" fire service in the
contract documents to 6" fire service installed. No labor costs should be added
since these were not additional services but rather services that were only
upgraded.
No back up information has been received from the contractor as of this time.
CLAIM # 8
Gas Lines above grade
C�
Project:
Main Street Alley, Project 820
Claim #8:
Gas Lines above Grade
Contractor's Statement from Request
"During the work period from 6/24/00 through 6128/00 we hit 4 gas lines. The
first line was hit at station 7+85 on 6/24, the second was hit at 8+80 on 6/26, the
third was hit at 7+40 on 6/24 and the last was hit at 6+00 on 6/28. The existing
elevations of these gas lines was higher than the elevation of our subgrade. The
condition was unforseen and resulted in delay of two working days plus
associated costs above."
What was the amount of$4,513.58
( Originally submitted$4,977.20)
the claim?
When did the claim occur?
June 24, 2000
When was the City
June 26, 2000
Notified?
Has the Contractor
Yes, extra work billing was submitted.
supplied the proper back
up documentation in
accordance with Section 3-
3 Extra Work and Section
3-5 Disputed Work of the
"Greenbook" ?
Engineering Division Analysis and Discussion:
As stated in January 11, 2001 letter to Southern California Grading, the
Engineering Division would process payment for the claim providing the
Contractor supplied the appropriate Extra Work Reports and back up
documentation as provided for in the "Greenbook" and Contract Documents.
The proper paperwork was submitted. However, the subcontractor mark-up was
improperly applied. Total amount approved for this work is $4,103.26. This
amount was expressed to the contractor in a letter dated March 15, 2001 and
was also submitted to the City Council for payment.
CLAIM # 9
Gas Main in Sewer Trench
Project:
Main Street Alley, Project 820
Claim #g:
Gas Main in Sewer Trench
Contractor's Statement from Request
"Trenching and excavating existing abandoned
gas line (Existing water services
were lying directly over the top of existing abandoned gas line, therefore, we
were not able to rip the 2" gas line out as we were excavating. NOTE: Gas line
was centered directly over the new sewer main which caused 3 hours per day
for 43 days (sewer installation only):"
What was the amount of
$39,603.90
the claim?
When did the claim occur?
March 21, 2000
When was the City
May 9, 2000
Notified?
Has the Contractor
Yes, extra work billing was submitted,
supplied the proper back
up documentation in
accordance with Section 3-
3 Extra Work and Section
3.5 Disputed Work of the
"Greenbook" ?
Engineering Division Analysis and Discussion:
The City was not notified of any additional cost until well over a month from the
start. Had the City been given the opportunity, it could have had the Gas
Company remove the abandoned line at no extra charge or could have had City
forces perform the work.
No extra work reports were supplied so it is difficult to calculate the time delay
damages. It seems excessive for removal of approximately 830' of abandoned
gas line. If this work was done separately, it should have only taken 2 to 3
working days.
Per section 3-3.3 of the Greenbook:
Failure to submit the dally report by the close of the next working day may waive any
rights for that day.'
Additionally, section 201.5.11 of the Contract Documents:
"The Contractor shall not do any extra work except upon prior written order form the
Director of Public Works. Compensation for such extra work shall be agreed upon in
writing by the Contractor and the Director of Public Works prior to the commencement of
the work.'
Since the Contractor did not give the City the opportunity to monitor and or
decide on cost for this item, it should be responsible for its entire cost.
What is even more perplexing, is that in Kennedy Pipelines' April 21, 2000 letter,
the subcontractor states:
"The problem isn't necessarily the gas line, but the existing water services were installed
directly over the top of the abandon line gas line, with no sand, causing quite a bit more
in locating the water service."
The City's construction manager responded in writing, that this is not a changed
condition in regards to the surrounding material around the existing water
services and no additional compensation would be made.
In correspondence, the Contractor is first claiming for locating water service lines
but then well after claims for gas line causing delayed production.
No additional compensation will be granted for this claim. The City's stance is
that the contractor did not follow the proper procedures established in Section 3-
3.3 of the Greenbook and Section 201.5.11 of the project specifications.
r %0
CLAIM # 10
Sewer Encasement
V 0
Project:
Main Street Alley, Project 820
Claim #10:
Sewer Encasement
Contractor's Statement from Request
The Contractor does not believe the price for encasement for the sewer was
included in the contract.
What was the amount of
$23,066.66 ( Originally submitted $37,518.00)
the claim?
When did the claim occur?
April 5, 2000
When was the City
April 5, 2000
Notified?
Has the Contractor
Yes, extra work billing was submitted.
supplied the proper back
up documentation in
accordance with Section 3-
3 Extra Work and Section
3-5 Disputed Work of the
"Greenbook" ?
Engineering Division Analysis and Discussion:
Early on in the project, the Contractor argued that the encasement for the sewer
was not included in the project. The City's construction management firm
responded in writing on April 10, 2000 that :
-notes 2 on sheet C5 and 7 on sheet C6 call out for the sewer line to be encased per
standard plan S-10. Second, the sentence of paragraph 20 of Section 204.7, Installation
of Gravity Sewer Pipelines, cleady call out for encasement to be per standard drawing S-
10, Type A."
Kurt Cutler, Southern California Grading, responded in writing on April 13, 2000:
.you neglect to mention Note #1 of Detail S-10 which says encasement shall be used
when cover is under 4' or over 20'. Pipe depths vary from 4.5' to 8' in depth, therefore,
not requiring any encasement. Neither the drawings no the specification modify this detail
to reflect specific requirements."
We direct you to section 201.5.8 Contract Documents: Conflict of Terms which
states:
With reference to the Drawings the order of precedence shall be as follows:
1. Figures govern over scaled dimensions;
2. Detail drawings govern over general drawings;
3. Addenda/Change Order drawings govern over Contract Drawings;
4. Contract Drawings govern over standard drawings; (Bolded for emphasis).
4
The design engineer calls out on the plan (contract drawings) specifically to
encase the sewer line. It was the design engineer's clear intention that the line be
encased and he called out a standard drawing to show the method of
encasement.
Therefore, this price should have been included in the Contractor's bid. As a side
note, similar specifications and plans were used on a previous project and the
Contractor performed the work without any claim for additional cost.
No additional compensation will be approved for this encasement work
CLAIM # 11
Shallow Water Main
Project:
Main Street Alley, Project 820
Claim #11:
Shallow Water Main
Contractor's Statement from Request
"The above referenced delay of 5 days are a direct result of the existing water
main elevation founded 2" to 6" below subgrade elevation. The contract
documents indicated this line would be found at the same elevation as the
proposed water main. This is an unforseen and changed changed condition. All
construction activities were effected by this condition, but only the above cost
have been submitted for review"
What was the amount of
$9,577.24 ( Originally submitted $19,351.70)
the claim?
When did the claim occur?
"
When was the City
"
Notified?
Has the Contractor
Yes, extra work billing was submitted.
supplied the proper back
up documentation in
accordance with Section 3-
3 Extra Work and Section
3-5 Disputed Work of the
"Greenbook"7
"" Each time a leak occurred, the contractor was informed if the City would
reimburse them or not. There would be no lag time here except for the days
when the foreman said no extra cost would be bome by the City, which the
Contractor is now claiming for extra payment.
Engineering Division Analysis and Discussion:
The Contractor claims that the existing water line was 2" to 6" below sub -grade or
approximately 24" below the original grade. Most watedines back in the 1920's
were often installed at a shallow depth and vary. The contractor's backup claims
that the contract documents indicate that this line would be found at the same
elevation as the proposed water main.
Addendum 94, of the contract documents, show a cross section of existing and
proposed water, sewer, and gas lines. The drawing is clearly labeled "Not to
Scale." The dimension called out for the water line is designated that the new line
be installed at a minimum depth of 3'. No "leader" line corresponds or references
to the existing water line. Accordingly, the Contract Documents do not indicate
that these lines are at the same depth but rather they are in the same general
vicinity. Therefore, the Engineering Division does not concur with your statement
that this is an unforeseen and changed condition.
L
Additionally, on many occasions the failure of the contractor to exercise
reasonable care around the existing water line caused many of the problems.
Therefore, the Engineering Division will only pay for costs associated with
Kennedy ticket numbers 7419, 7571, 7675 and 7576. All these will need to be
changed to reflect the proper filing instructions as mentioned in this letter in
accordance with the Contract Documents and the "Greenbook."
As a side note, the Engineering Division did not receive the attached letter for
which the Contractor is claiming $11,241.50. It is perplexing because on the last
submittal, the Engineering Division did receive the attached letter but then the
Contractor was only claiming $5,040. Nevertheless, all claims must be
substantiated by proper documentation to be considered.
The following is an analysis of the daily extra work reports for this claim:
11.1: City is willing to compensate labor for Manuel Lopez, 4 hours, Joe
Valenzuela and Jamie Baez for 2 hours each. These hours and workers
are from the construction managers daily reports. Pump and hose costs
will also be covered. No other items will be paid for. It is the City's stance
that the other time spent making repairs is due to the contractor's
negligence. Total $363.99
11.2: Labor hours and workers and equipment types do not match construction
managers daily reports. Also, material invoices are required prior to
payment. Total $962.83.
11.3 Denied. There is no extra work ticket #7692 from Kennedy.
11.4 Labor hours and rates are somewhat incorrect, as are equipment rates
and hours. Material invoices are required prior to approval of payment.
Total $693.37.
11.5 The majority of the time and all the material on this report is due to
contractor negligence. Total $220.33.
11.6 Denied. Damage was by contractor while installing sewer.
11.7 Denied. Damage was by contractor due to negligence.
11.8 Denied. What is this material for?
11.9 Denied. The contractor is required to make the proper connection per the
contract. The connection of the new meter to existing home owner's pipe
was not adequate and it leaked. This work is to repair the leak. The
construction manager did request this to be done because it is within the
contract requirements and there was a possibility of a rupture in the home
owners line.
11.10 Denied. Kennedy was not on site today.
The total additional compensation the City is willing to pay is $2,240.52.
CLAIM # 12
Water Services Changed
to J
Project:
Main Street Alley, Project 820
Claim #12:
Water Services Changed
Contractor's Statement from Request
"Water Department changed water meters from 1" to %". This resulted in a delay
of 1 day to the schedule and the above cost impact. See attached letter from
Kennedy Pipeline."
What was the amount of
$1,626.90 ( Originally submitted $1,679)
the claim?
When did the claim occur?
June 19, 2000
When was the City
June 19, 2000
Notified?
Has the Contractor
Yes, extra work billing was submitted.
supplied the proper back
up documentation in
accordance with Section 3-
3 Extra Work and Section
3-5 Disputed Work of the
"Greenbook" ?
Engineering Division Analysis and Discussion:
It is our understanding, that this claim was caused because the 32 meters
supplied by the City Water Department had 3/4" connections rather than 1"
connections. Consequently, the Contractor had to purchase fittings to connect
the 1" service lines to the City supplied meters. According to the paperwork
provided, the Contractor is claiming extra work and that it took a total of 21
person hours to attach the fittings or 40 minutes per fitting.
The Engineering Division discussed this matter with its Water Operations
personnel. In their experience, it would only take 1 to 3 minutes per meter to
install the necessary fitting to make the proper connection. This would total to a
maximum of 96 minutes of extra work time.
It was the Contractor's responsibility to install the original meters therefore the
only allowable claim in time is the difference to install the fitting.
Recommendation:
No explanation was documented for the additional time. Although on premise, we
agree that some compensation is due, we believe the claim is grossly inflated.
Therefore, we recommend that the claim be decreased accordingly.
The City is willing to compensate the contractor for 2 hours of the foreman's time,
2 hours of the equipment time, and the cost for the material. Material invoices
must be submitted prior to approval of the additional compensation. Also, the
foreman's rate and truck rate are in excess of the allowables. Total
compensation is $424.10.
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m of
RICHARD B. ANDRADE, ESQ., CSB NO. 075702 3 I^ L
ANDRADE S ASSOCIATES
A PROFESSIONAL LAW CORPORATION
Jeffrey Corporate Centre AAkW0
5510 Trabuco9 � �'
Irvine, CA 92620
Telephone: 999-553-1951
Facsimile: 949-553-0655
Attorney for Claimant
SOUTHERN CALIFORNIA UNDERGROUND CONTRACTORS, INC.
CLAIM AGAINST PUBLIC ENTITY
SOUTHERN CALIFORNIA UNDERGROUND
CONTRACTORS, INC.,
Claimant,
V.
CITY OF SEAL BEACH,
Respondent.
Case No.:
GOVERNMENT CODE CLAIM
TO CITY CLERK, CITY OF SEAL BEACH:
Claimant SOUTHERN CALIFORNIA UNDERGROUND CONTRACTORS, INC.
("SOCAL") hereby presents this claim pursuant to California
Government Code § 910 against THE CITY OF SEAL BEACH (hereinafter
"CITY") and makes the following statements in support of its
claim:
1. Name and address of the Claimant is as follows
Southern California Underground Contractors, Inc., P.O. Bo
1747, Brea, California 92622-1747.
GOVERNP
0 NATAWUIIffAM. CA. IM"FJICAgMp. 1O B�m
I
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2. The address to which Claimant desires response to thi;
claim to be sent is as follows: Richard B. Andrade, Andrade t
Associates, Jeffrey Corporate Centre, 5510 Trabuco, Irvine,
California 92620, Telephone Number: (949) 553-1951; Facsimile
Number: (949) 553-0655.
3. SOCAL was the successful bidder on the project knowr
as "Seal Beach Blvd. Rehabilitation, Project No. 49991 & 49757",
City of Seal Beach, California (the "PROJECT") and entered intc
a written agreement with CITY for the construction of the
PROJECT.
4. The contract between the CITY and SOCAL provides in
pertinent part as follows:
113-3 EXTRA WORK.
"3-3.1 funeral. New or unforeseen work will be
classified as extra work' when the Engineer
determines that it is not covered by Contract Unit
Prices or stipulated unit prices.
"3-3.2 Payment.
113-3.2.1 General. When the price for the extra
work cannot be agreed upon, the Agency will pay for
the extra work based on the accumulation of costs as
provided herein."
5. The circumstances giving rise to this claim are as
follows:
(A). On or about July 3, 2001, SOCAL notified CITY that th
removal of base was not shown as a work item within the contrac
between the parties. SOCAL further advised the CITY that i
-2-
GOVERNMENT C
6:\MTA\Rp11tp.G.VMRWIIpIpp-, [Ol1\4,1 lucp\plop\pwecltl n. Gec
1 order to meet finished grade prior to placing 5" of AC on 14" c
2 base, 1 to 2 vertical feet of existing soil and base would b
3 required to be removed and disposed of. Again, SOCAL advise
4 CITY that the contract between the parties did not contain a Bi
5 Item covering the removal and disposal of existing soil.
6 (B). SOCAL requested CITY to remove the soil and base o
7 alternatively, pay SOCAL to perform the work as Extra Work unde
8 the contract. The anticipated cost to perform this work is $3
9 per ton.
10 (C) . The CITY has refused to remove the soil and base an,
11 has further refused to pay SOCAL for the cost of performing sai,
12 work, in violation of the contract between the parties.
13 (D). CITY has directed SOCAL to perform the removal of th4
14 soil and base and SOCAL is presently performing this work under
15 protest.
16 6. The name of the public employees causing claimant';
17 damages and interfering with payment to SOCAL under the contract
18 referenced above are: Gary Tomasetti, Bill Zimmerman, Doug Dane:
19 and Ron Brust.
20 7. The CITY has refused and continues to refuse to pal
21 SOCAL for the cost of performing the EXTRA WORK associated with
22 the removal of the soil and base, in the approximate amount of
23 $300,000.00. The refusal of the CITY to pay all sums owed is a
24 breach of the contract between the parties.
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-3-
GOVERNMENT CODE CLAIM
s �x.uvavrxxo.u.wwxwowo-e.onv.a e..=mx, ee�a=•.=..... m=
U
8. The claim as of this date is in an amount in excess
$300,000.00, and will place this action within the jurisdict
of the Superior Court.
Dated: July 16, 2001 -ANDRA� & AS C RTES
By:
RICHARD B. ANDRADE
Attorneys for Claimant
SOUTHERN CALIFORNIA
UNDERGROUND CONTRACTORS, INC.
_q_
GOVERNMENT C
c:�nxeuaorxeex.u.vmeewwun-eemm.a s..�m,�aa�se.em.�..a.�
PROOF OF SERVICE
2 STATE OF CALIFORNIA )
3 ) ss
COUNTY OF ORANGE )
4 1 am employed in the County of Orange, State of California. 1 am over the age of I a years and
5 nota party to this action. My business address is Jeffrey Corporate Centre, 5510 Tmbuco, Irvine,
California, 92620.
6
On July 17, 2001,1 served the following document(s): GOVERNMENT CODE CLAIM
7 on the interested parties in this action as follows and by the method listed below:
8 CITY CLERK
9 CITY OF SEAL BEACH
2118"' Street
10 Seal Beach, CA 90740
11 _ (Service By Mail) I caused such envelope, thereon, fully prepaid, to be placed for deposittelt55 01 Trabuco Irry return
California, ee in thsted eoUged
12 States Postal Service. 1 am familiar with the regular mail collection androcesit
Andrade & Associates that the mail would be deposited with the United States Postal Service
sn of
13 that same day � In the ordinary course of business, and that the envelope was sealed and deposited
19 for collection and mailing on the above date following ordinary business practices.
15 — (Service By Federal Express or overnight delivery) 1 caused such envelope to be placed for
deposit at5510 Tmbuco, Irvine, California,. I= familiar with the overnight delivery collection
16 and processing practices of Andrade & Associates that the mail would be deposited with Federal
Express or overnight delivery service that same day in the ordinary course of business, and that
17 the envelope was sealed and deposited for collection and mailing on the above date following
18 ordinary business practices.
19CLX (Personal Service) I caused such envelope to be delivered by hand to the addressee(s).
20 — (Via Facsimile) By faxing copies to the person(s) and fax numbers listed above named.
21 XX (STATE) 1 declare under penalty of perjury, under the laws of the State of California and the
22 United States of America, that the foregoing is true and correct.
_ (FEDERAL) I declare that I am employed in the office of a member of the bar of this Court at
23 whose direction the service was made.
29 1 declare under penalty of perjury under the laws of the State of Cali 'a that the foregoing is
25 true and correct. Executed July 17, 2001 at Irvine, Cali mia.
26
27 RICHARD B. ANDRADE
28
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UWr1D STATES POSTAL SMWICE ►► ►► ► Mei
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ees Paka"
• Pdrn your name, address, and ZIP Code In this box
L --Wen, Tieder, Heller d PitrjmEld, LLP.
3 Park Plaza, Suite 1300
Irv* CA 92614
WATT, l 1EDER, HOFFAR
& RTZGERALD, LLP
ATTORNEYS AT UAW
August16,2001
Via Certified Mail/Return Receipt Requested
Ms. Joann Yeo
City Clerk
City of Seal Beach
211 Eighth Street
Seal Beach, California 90740
Darold Peiper, Esq.
Richards, Watson & Gershon
333 S. Hope Street, 38"' Floor
Los Angeles, California 90071-1469
Re: Claim Submitted by Southern California Grading, Inc.
Main Street Alley Improvements, Project 820
Dear Ms. Yeo and Mr. Pieper:
3 Rae Raza
Suite 1800
ImM, CWllornla 82816
Tabplvial 9r&e52-0100
Fe Mle: BIF281-0111
vww.w8i1 com
This office represents Southern California Grading, Inc. ("Claimant") in
connection with its work to construct the work of improvement known as Main
Street Alley Improvements, Project 820 ("Project") for the City of Seal Beach
("City'). This claim for money damages is being submitted by Claimant against
City pursuant to California Government Code Section 900 at seq. Additionally,
Claimant requests an opportunity to meet with Deputy City Engineer Doug Dancs
and any other necessary individuals in hopes of resolving this dispute prior to
litigation.
Claimant's name and post office address is as follows:
Southern California Grading, Inc.
16291 Construction Circle East
Irvine, California 92606
McLean, Mrglnla Washington, D.C. Florence. Italy
Ms. Joann Yeo
Darold Peiper, Esq.
August 16, 2001
Page 2
2. Claimant requests that notices regarding this claim be sent as
follows:
Joseph C. McGowan, Esq.
Watt, Tieder, Hoffar & Fitzgerald, LLP
3 Park Plaza, Suite 1500
Irvine, Califomia 92614
3. The date, place and other circumstances of the occurrence which
give rise to the claim are set forth in the attached letter from Mr.
Dancs dated May 14, 2001, which is attached hereto and
incorporated herein. Said letter from Mr. Dancs addresses the
twelve separate claims of Claimant, agreeing to some in part,
disagreeing with some in part and disagreeing with some of the
claims altogether. Claimant hereby makes a claim with respect to
those decisions of the City of Seal Beach Engineering Division that
are contrary in full or in part to the claims Claimant submitted to
City. Additional detail on each of these claims was submitted by
Claimant to City in the form of "Daily Report/Bill for Extra Work"
sheets for CCO #1 through CCO #12. These sheets are
incorporated herein by reference.
4. A general description of the indebtedness to Claimant is also
included in the above-described letter of May 14, 2001 from Mr.
Dancs, and the above-described Daily Report/Bill for Extra Work
sheets.
5. The persons responsible for the Claimant's loss are those involved
in denying the change order requests of Claimant, including Mr.
Dancs and others working within the City Engineering Division and
representatives of CRSS/Sverdrup, the construction managers for
the Project.
6. The amount sought exceeds $10,000, and is subject to the
jurisdiction of the Superior Court.
Although Mr. Robert Cutler, Claimant's President, is willing to make
compromises to settle the numerous disputed issues, he believes the City has
taken unreasonable positions in the above-described letter of May 14, 2001. He
also believes that many of these decisions contradict agreements made by the
City representatives during negotiations of these claims. Finally, he hopes that
this dispute could be resolved as the result of a final meeting to discuss the City's
"conclusions."
Ms. Joann Yeo
Darold Paper, Esq.
August 16, 2001
Page 3
I will contact the office of Mr. Peiper during the week of August 20, 2001. 1
would appreciate it if Mr. Peiper could contact Mr. Dancs prior thereto to
determine his availability for such a meeting.
Very truly yours,
WWTT, TIEDER, HOFFAR & FITZGERALD, L.L.P
Jol eAfi C. McGowa
JCM/Iml \/
Enclosure
cc: Mr. Robert R. Cutler (without enclosure)
Robert C. Niesley, Esq. (without enclosure)
38219 v1
May 14, 2001 to—A,
Bob Cutler, President my 2001Southern California Grading Sa:
16291 Construction Circle East \p .. Ct_
Irvine CA 92606 \1c
Dear Mr. Culler, �_
SUBJECT: Final Claims Decision by the Director of Public Works/City
Engineer
The Engineering Division and our construction managers, CRSS/Sverdrup, have
extensively reviewed all of Southern California Grading's claims for this project
and prepared the attached final claims analysis.
A check in the amount of $41,081.22 will be issued, upon approval by Council, to
the Contractor and will be full compensation for all remaining retention and any
claims. The original contract amount was $318,342.58 and the final contract
amount is $340,570.58. A copy of the final progress pay is attached.
Please understand that Director of Public Works/City Engineer made this
decision only after careful consideration of all the documentation. We believe it to
be a fair and equitable conclusion to this matter.
We hope this matter is settled but if you desire to pursue legal remedies, all
further communications must be made attention to our City Attorney's office:
Darold Peiper
Richards, Watson 8. Gershon
333 S. Hope Street 38th Floor
Los Angeles CA 90071-1469
Telephone: (213) 626-8484, Facsimile: (213) 626-0078
Thank you for your cooperation during the claim process phase.
TDancougs,
P.E.
Deputy City Engineer
cc:
John Bahorski, City Manager
Steve Badum, P.E., Director of Public Works, City of Seal Beach
Gary Tomaseti, Contract Construction Manager, City of Seal Beach (CRSS)
Darold Peiper, City Attorney, City of Seal Beach, (Richards, Watson & Gershon)
B. Tilden Ktm, City Attorney, City of Seal Beach, (Richards, Watson 8 Gershon)
Project File
Letter File
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Gary Tomaseti, Contract Construction Manager, City of Seal Beach (CRSS)
Darold Peiper, City Attorney, City of Seal Beach, (Richards, Watson d Gershon)
B. Tilden Kim, City Attorney, Coy of Seal Beach, (Richards, Watson & Gershon)
Project File
Letter File
DD
CLAIM # 1
Alley Alignment
Project:
Main Street Alley, Project 820
Claim #1:
Alley Alignment
Contractor's Statement from Request
"There was an alignment conflict between the plans and survey stakes. Our
surveyor staked the job correctly in accordance with the plans. After survey was
completed it was obvious that the plans were drawn incorrectly. This resulted in
additional concrete removal, and one day delay to the schedule, and additional
costs over and above revenues earned by unit prices"
What was the amount of
$1,213.75 (Originally submitted $1,564.00)
the claim?
When did the claim occur?
June 27, 2000
When was the City
June 27, 2000
Notified?
Has the Contractor
Yes, extra work billing was submitted.
supplied the proper back
up documentation in
accordance with Section 3-
3 Extra Work and Section
3-5 Disputed Work of the
"Greenbook" ?
Engineering Division Analysis and Discussion:
As stated in January 11, 2001 letter to Southern California Grading, the
Engineering Division would process payment for the claim providing the
Contractor supplied the appropriate Extra Work Reports and back up
documentation as provided for in the "Greenbook" and Contract Documents.
Extra work bills were properly submitted. However, there were two workers and
a backhoe that did not show up on the construction manager's daily reports or
the contractor's daily reports. Also, the contractor was including a subcontractor
mark-up which is not permissible when work is completed by his own forces. For
these reasons the allowable payment for this request was approved at $800.81.
Payment for this work has already been processed through City Council. A letter
was written to the Contractor dated March 15, 2001 approving payment for
$800.81.
CLAIM # 2
Broken Water Services
Project:
Main Street Alley, Project 820
Claim #2:
Broken Water Services
acor's Statement from Request
g our demolition of the asphalt alley, our grinder hit a water services that
rbat
ndoned improperly. Thisservice was within inches of existing finished
e. This is not within code. We are requesting 1 day to thecontract, plus
iated costs for Kennedy Pipeline's repair."
What was the amount of
$486.26. (Originally submitted $577.50)
the claim?
When did the claim occur?
June 27, 2000
When was the City
June 27, 2000
Notified?
Has the Contractor
Yes, extra work billing was submitted.
supplied the proper back
up documentation in
accordance with Section 3-
3 Extra Work and Section
3-5 Disputed Work of the
"Greenbook" 7
Engineering Division Analysis and Discussion:
As stated in January 11, 2001 letter to Southern California Grading, the
Engineering Division would process payment for the claim providing the
Contractor supplied the appropriate Extra Work Reports and back up
documentation as provided for in the "Greenbook" and Contract Documents.
The contractor submitted the proper paperwork. However, the hourly rate for the
foreman was too high. When comparing the certified payroll hourly rate from the
subcontractor, the construction manager noticed that the additional employer
payments for insurance, vacation... added to the foreman's wage was not as
high as that shown on the extra work bill. The construction manager added the
appropriate benefits amount to the hourly wage from the certified payroll for a
revised hourly rate acceptable to the City. Also the rental rate for the truck was
higher than that specified in the Caltrans Rental rate book. Total amount
approved for this work is $380.97. This amount has been processed through
City Council for payment.
A letter was written to the contractor, dated March 15, 2001 approving $380.97
for this work.
CLAIM # 3
Cable TV too High
roject:
Main Street Alley, Project 820
Claim #3:
Cable N to High
Statement from Request
eriod from 6/24/00 we encountered cable N consisting of (3) 2"
rwork
e conduits were exposed as we excavated down to the subgrade.
should have been relocated prior to our work. We informed
they proceeded to relocate their utilities. This resulted in a delay of
3 days to the construction schedule, and cost impact as shown above. See
attached letter dated 6/26/00"
What was the amount of
34,336.67 (Originally submitted $5,308.40)
the claim?
When did the claim occur?
June 24, 2000
When was the City
June 26, 2000
Notified?
Has Contractor
the
Yes, extra work billing was submitted.
supplied the proper back
up documentation in
accordance with Section 3-
3 Extra Work and Section
3-5 Disputed Work of the
"Greenbook" ?
Engineering Division Analysis and Discussion:
It is our understanding, that at the comer of Main Street Alley and Electric
Avenue, the existing cable line was shallow and needed to be relocated deeper.
We understand that state law provides provisions to compensate the contractor
for the costs of locating, and repairing damage not due to the failure of the
contractor to exercise reasonable care, and removing or relocating such utility
facilities not indicated in the plans and specifications with reasonable accuracy,
and for equipment on the project necessarily idled during such work.
Our construction manager received a letter dated June 26, 2000 from Anthony
Cerisano, Southern California Grading, requesting two additional working days.
The letter states these two additional working days were to cover delays caused
not only by the cable line relocation but also a gas line conflict. The construction
manager granted the two additional working days per the letter to allow the Cable
Company to relocate facility.
When your back up for the claim was reviewed, it was noticed that the Contractor
is now claiming 3 working days for the Cable N relocation alone. This differed
significantly from what was granted according to your previous letter.
According to our inspector records and observations, contractor crews
proceeded in other parts of the job with no apparent crews remaining idle.
Therefore the City is not willing to pay for this claim since the Contractor retained
production in other parts of the job and additional days were granted for the
completion of the work.
No additional compensation will be made for this item.
CLAIM # 4
Condition of Existing Water
Main
Project:
Main Street Alley, Project 820
Claim #4:
Condition of Existing Water Main
Contractor's Statement from Request
"The condition of the existing water main was such that continual seepage
deteriorated the subgrade and our trench backfill to the point that we were
required to export this over saturated material and stabilize the subgrade with
fabric and additional base rock. This is an unforseen existing condition beyond
our control. Total delays for this work is 8 days.'
What was the amount of
$17,398.77 (Originally submitted $28,093.35)
the claim?
When did the claim occur?
March 30, 2000
When was the City
July 7, 2000
Notified?
Has the Contractor
Yes, extra work billing was submitted.
supplied the proper back
up documentation in
accordance with Section 3-
3 Extra Work and Section
3-5 Disputed Work of the
"Greenbook" ?
Engineering Division Analysis and Discussion:
The Contractor claims that the existing water main's continual seepage
deteriorated the sub -grade and this caused extra work to achieve the necessary
compaction.
As mentioned in from this report in Claim #11:
'The Contractor claims that the existing water line was 2' to 6' below sub -grade or
approximately 24' below the original grade. Most waterlines back in the 1920's were
often installed at a shallow depth and vary. The contractor's backup claims that the
contract documents indicate that this line would be found at the same elevation as the
proposed water main.
Addendum #4, of the contract documents, show a cross section of existing and proposed
water, sewer, and gas lines. The drawing is clearly labeled "Not to Scale.- The dimension
called out for the water line is designated that the new line be installed at a minimum
depth of 3'. No 'leader" line corresponds or references to the existing water line.
Accordingly, the Contract Documents do not indicate that these lines are at the same
depth but rather they are in the same general vicinity. Therefore, the Engineering Division
does not concur with your statement that this is an unforeseen and changed condition."
The area was dry. During the sewer work, no pockets of poor soil were
encountered. Accordingly, this was not a condition that existed prior to the project
except in the area adjacent to the Bank of America where the sprinklers were left
on.
The following is an analysis of the individual extra work bills submitted for this
claim:
4a: No work was performed on this day, 7/22/00. This is evident in the daily
work reports and the certified payroll. No payment will be made.
4b: The contractors daily report states that extra work was required due to
poor compaction by the sub -contractor. No payment will be made.
4c: This bill is acceptable with the exception of the subcontractor mark-up.
Material invoices must be submitted for the:base rock material. The total
amount of money that will be approved is $5,738.26 upon receipt of
corresponding material invoices.
4d: Work shown on this extra work bill is contract item work. No additional
compensation will be made to the contractor for this bill.
4e: Work shown on this extra work bill is contract item work. No additional
compensation will be made to the contractor for this bill.
4f: Work shown on this extra work bill is contract item work. No additional
compensation will be made to the contractor for this bill.
4g: Work shown on this extra work bill is contract item work. No additional
compensation will be made to the contractor for this bill.
Total compensation for this extra work will be $5,138.26.
CLAIM # 5
Existing Tie Ins
Project:
Main Street Alley, Project 820
Claim 85:
Existing Tie Ins
Contractor s Statement from Request
"The water main tie ins required significant modification because the existing
water main was not deep enough to match the new water main elevation. We
were required to stop work and waft for design change as described in the
attached CRSS letter 6/15/00. The modification delayed the job 3days in
addition to the associated cost shown above." ,
What was the amount of
$3,766.95 (Originally submitted $2,625.00)
the claim?
When did the claim occur?
June 27, 2000
When was the City
June 27, 2000
Notified?
Has the Contractor
Yes, extra work billing was submitted.
supplied the proper back
up documentation in
accordance with Section 3-
3 Extra Work and Section
3-5 Disputed Work of the
"Greenbook" ?
Engineering Division Analysis and Discussion:
As stated in January 11, 2001 letter to Southern California Grading, the
Engineering Division would process payment for the claim providing the
Contractor supplied the appropriate Extra Work Reports and back up
documentation as provided for in the "Greenbook" and Contract Documents.
The contractor submitted the proper paperwork. However, the foreman's hourly
rate was incorrect as was the hourly rate for the truck. The rates were
established as per the explanation in Claim number 2. A total of $3,755.95 is
approved as long as the contractor submits material invoices for verification. The
submittal of material invoices was expressed in the March 15, 2001 letter sent to
the contractor.
The amount of $3,755.95 was processed through City Council for payment. No
material Invoices have been submitted as of yet.
CLAIM # 6
Existing Utilities at Manhole
Project:
Main Street Alley, Project 820
Claim Fb: I
Existing Utilities at Manhole
Contractor's statement from Request
"We request an additional 6 days added to the Contrail"
What was the amount of
$0
the claim?
When did the claim occur?
March 3, 2000
When was the City
June 7, 2000
Notified?
Has the Contractor
No claim for cost was made.
supplied the proper back
up documentation in
accordance with Section 3-
3 Extra Work and Section
3-5 Disputed Work of the
"Greenbook" ?
Engineering Division Analysis and Discussion:
The Contractor is claiming additional 6 working days. Payment for claims was
dropped. The inspector job diaries do not reflect 6 working days but rather 2
working days.
Two additional working days are granted. No monetary compensation will be
made.
CLAIM # 7
Extra Services Added
Project:
Main Street Alley, Project 820
Claim #?: 1
6dra Services Added
Contractors Statement from Request
"City added (1) Fire Service, (5)1 'h" Water Services, and (4) 2" water services.
We are requesting 5 working days to the contract. Backup for Kennedy's work is
forthcoming."
What was the amount of
$9,450
the claim?
Whan did the claim occur?
"'
When was the City
""
Notified?
Has the Contractor
No, the paperwork supplied is not in accordance
supplied the proper back
with the provisions. There are no daily work
up documentation In
reports.
accordance with Section 3-
3 Extra Work and Section
3-5 Disputed Work of the
"Greenbook" ?
""" Early on in the project the City Water Dept notified the Inspector that there are
several meters in the Alley that are larger than 1" as the plans call out. The City
and Contractor were aware and it was understood that the Contractor would only
get reimbursed for the additional material size.
Engineering Division Analysis and Discussion:
This request entails the upsize of water services from what was rated on the
plans. According to the contractors backup, the City added one fire service, five
1 Y:" water services, and four 2" water services. According to the contract
documents, all water services were to be 1" services. The fire service was
designated to be a 4" which was then upgraded to a 6" fire service.
Therefore, the Engineering Division will only allow costs for the difference in
material prices between five 1" services and five 1 'h" services and the difference
between four 1" services and four 2" services. Also, the Engineering Division will
only allow for the difference in material prices between 4" fire service in the
contract documents to 6" fire service installed. No labor costs should be added
since these were not additional services but rather services that were only
upgraded.
No back up information has been received from the contractor as of this time.
CLAIM # 8
Gas Lines above grade
Project:
Main Street Alley, Project 820
Claim $e: I
Gas Lines above Grade
Contractor's statement from Request
"During the work period from 6/24/00 through 6/28/00 we hit 4 gas lines. The
first line was hit at station 7+85 on 6/24, the second was hit at 8+80 on 6/26, the
third was hit at 7+40 on 6/24 and the last was hit at 6+00 on 6/28. The existing
elevations of these gas lines was higher than the elevation of our subgrade. The
condition was unforseen and resulted in delay of two working days plus
associated costs above."
What was the amount of
$4,513.58 ( 31Iginaly sub mitted$4,977.20)
the claim?
When did the claim occur?
June 24, 2000
When was the City
June 26, 2000
Notified?
Has the Contractor
Yes, extra work billing was submitted.
supplied the proper back
up documentation in
accordance with Section 3-
3 Extra Work and Section
3.5 Disputed Work of the
"Greenbook" ?
Engineering Division Analysis and Discussion:
As stated in January 11, 2001 letter to Southern California Grading, the
Engineering Division would process payment for the claim providing the
Contractor supplied the appropriate Extra Work Reports and back up
documentation as provided for in the "Greenbook" and Contract Documents.
The proper paperwork was submitted. However, the subcontractor mark-up was
improperly applied. Total amount approved for this work is $4,103.26. This
amount was expressed to the contractor in a letter dated March 15, 2001 and
was also submitted to the City Council for payment.
CLAIM # 9
Gas Main in Sewer Trench
Project:
Main Street Alley, Project 820
Claim #9:
I Gas Main In Sewer Trench
Contractor's Statement from Request
"Trenching and excavating existing abandoned gas line (Existing water services
were lying directly over the top of existing abandoned gas line, therefore, we
were not able to rip the 2" gas line out as we were excavating. NOTE: Gas line
was centered directly over the new sewer main which caused 3 hours per day
for 43 days (sewer installation only):"
What was the amount of
$39,603.90
the claim?
When did the claim occur?
March 21, 2000
When was the City
May 9, 2000
Notified?
Has the Contractor
Yes, extra work billing was submitted.
supplied the proper back
up documentation in
accordance with Section 3-
3 Extra Work and Section
3-5 Disputed Work of the
"Greenbook" ?
Engineering Division Analysis and Discussion:
The City was not notified of any additional cost until well over a month from the
start. Had the City been given the opportunity, it could have had the Gas
Company remove the abandoned line at no extra charge or could have had City
forces perform the work.
No extra work reports were supplied so it is difficult to calculate the time delay
damages. It seems excessive for removal of approximately 830' of abandoned
gas line. If this work was done separately, it should have only taken 2 to 3
working days.
Per section 3-3.3 of the Greenbook:
- Failure to submit the dally report by the close of the next working day may waive any
rights for that day.'
Additionally, section 201.5.11 of the Contract Documents:
'The Contractor shall not do any extra work except upon prior written order form the
Director of Public Works. Compensation for such extra work shall be agreed upon in
writing by the Contractor and the Director of Public Works prior to the commencement of
the work'
Since the Contractor did not give the City the opportunity to monitor and or
decide on cost for this item, it should be responsible for its entire cost.
What is even more perplexing, is that in Kennedy Pipelines' April 21, 2000 letter,
the subcontractor states:
"The problem Isn't necessarily the gas line, but the existing water services were installed
directly over the top of the abandon line gas line, with no sand, causing quite a bit more
in locating the water service."
The City's construction manager responded in writing, that this is not a changed
condition in regards to the surrounding material around the existing water
services and no additional compensation would be made.
In correspondence, the Contractor is first claiming for locating water service lines
but then well after claims for gas line causing delayed production.
No additional compensation will be granted for this claim. The City's stance is
that the contractor did not follow the proper procedures established in Section 3-
3.3 of the Greenbook and Section 201.5.11 of the project specifications.
CLAIM # 10
Sewer Encasement
Project:Main
Street Alley, Project 820
Claim #10:
1 Sewer Encasement
ContractoPs Statement from Request
The Contractor does not believe the price for encasement for the sewer was
included in the contract.
What was the amount of
$23,066.66 (Originally submitted 37,518.00)
the claim?
When did the claim occur?
April 5, 2000
When was the City
April 5, 2000
Notified?
Has the Contractor
Yes, extra work billing was submitted.
supplied the proper back
up documentation in
accordance with Section 3-
3 Extra Work and Section
3-5 Disputed Work of the
"Greenbook" 7
Engineering Division Analysis and Discussion:
Early on in the project, the Contractor argued that the encasement for the sewer
was not included in the project. The City's construction management firth
responded in writing on April 10, 2000 that:
'notes 2 on sheet C5 and 7 on sheet C6 call out for the sewer line to be encased per
standard plan S-10. Second, the sentence of paragraph 20 of Section 204.7, Installation
of Gravity Sewer Pipelines, clearly call out for encasement to be per standard drawing S-
10, Type A.'
Kurt Cutler, Southern California Grading, responded in writing on April 13, 2000:
.you neglect to mention Note k1 of Detail S-10 which says encasement shall be used
when cover is under 4' or over 20'. Pipe depths vary from 4.5' to 8' in depth, therefore,
not requiring any encasement Neither the drawings no the specification modify this detail
to reflect specific requirements. -
We direct you to section 201.5.8 Contract Documents; Conflict of Terms which
states:
With reference to the Drawings the order of precedence shall be as follows:
1. Figures govern over scaled dimensions;
2. Detail drawings govern over general drawings;
3. Addenda/Change Order drawings govern over Contract Drawings;
4. Contract Drawings govem over standard drawings; (Bolded for emphasis).
The design engineer calls out on the plan (contract drawings) specifically to
encase the sewer line. It was the design engineers clear intention that the line be
encased and he called out a standard drawing to show the method of
encasement.
Therefore, this price should have been included in the Contractors bid. As a side
note, similar specifications and plans were used on a previous project and the
Contractor performed the work without any claim for additional cost.
No additional compensation will be approved for this encasement work.
CLAIM # 11
Shallow Water Main
Project:
Main Street Alley, Project 820
Claim #11:
Shallow Water Main
Contractor's Statement from Request
"The above referenced delay of 5 days are a direct result of the existing water
main elevation founded 2" to 6" below subgrade elevation. The contract
documents indicated this line would be found at the same elevation as the
proposed water main. This is an unforseen and changed changed condition. All
construction activities were effected by this condition, but only the above cost
have been submitted for review"
What was the amount of
$9,577.24 ( Originally submitted $19,351.70)
the claim?
When did the claim occur?
"
When was the City
Notified?
Has the Contractor
Yes, extra work billing was submitted.
supplied the proper back
up documentation in
accordance with Section 3-
3 Extra Work and Section
3-5 Disputed Work of the
"Greenbook" ?
" Each time a leak occurred, the contractor was informed if the City would
reimburse them or riot. There would be no lag time here except for the days
when the foreman said no extra cost would be bome by the City, which the
Contractor is now claiming for extra payment.
Engineering Division Analysis and Discussion:
The Contractor claims that the existing water line was 2" to 6" below sub -grade or
approximately 24" below the original grade. Most waterlines back in the 1920's
were often installed at a shallow depth and vary. The contractor's backup claims
that the contract documents indicate that this line would be found at the same
elevation as the proposed water main.
Addendum q4, of the contract documents, straw a cross section of existing and
proposed water, sewer, and gas lines. The drawing is clearly labeled "Not to
Scale." The dimension called out for the water line is designated that the new line
be installed at a minimum depth of 3'. No "leader" line corresponds or references
to the existing water line. Accordingly, the Contract Documents do not indicate
that these lines are at the same depth but rather they are in the same general
vicinity. Therefore, the Engineering Division does not concur with your statement
that this is an unforeseen and changed condition.
Additionally, on many occasions the failure of the contractor to exercise
reasonable care around the existing water line caused many of the problems.
Therefore, the Engineering Division will only pay for costs associated with
Kennedy ticket numbers 7419, 7571, 7675 and 7576. All these will need to be
changed to reflect the proper filing instructions as mentioned in this letter in
accordance with the Contract Documents and the "Greenbook."
As a side note, the Engineering Division did not receive the attached letter for
which the Contractor is claiming $11,241.50. It is perplexing because on the last
submittal, the Engineering Division did receive the attached letter but then the
Contractor was only claiming $5,040. Nevertheless, all claims must be
substantiated by proper documentation to be considered.
The following is an analysis of the daily extra work reports for this claim:
11.1: City is willing to compensate labor for Manuel Lopez, 4 hours, Joe
Valenzuela and Jamie Baez for 2 hours each. These hours and workers
are from the construction managers daily reports. Pump and hose costs
will also be covered. No other items will be paid for. It is the City's stance
that the other time spent making repairs is due to the contractor's
negligence. Total $363.99
11.2: Labor hours and workers and equipment types do not match construction
manager's daily reports. Also, material invoices are required prior to
payment. Total $962.83.
11.3 Denied. There is no extra work ticket #7692 from Kennedy.
11.4 Labor hours and rates are somewhat incorrect, as are equipment rates
and tours. Material invoices are required prior to approval of payment.
Total $693.37.
11.5 The majority of the time and all the material on this report is due to
contractor negligence. Total $220.33.
11.6 Denied. Damage was by contractor while installing sewer.
11.7 Denied. Damage was by contractor due to negligence.
11.8 Denied. What is this material for?
11.9 Denied. The contractor is required to make the proper connection per the
contract. The connection of the new meter to existing home owners pipe
was not adequate and it leaked. This work is to repair the leak. The
construction manager did request this to be done because it is within the
contract requirements and there was a possibility of a rupture in the home
owner's line.
11.10 Denied. Kennedy was not on site today.
The total additional compensation the City is willing to pay is $2,240.52.
CLAIM # 12
Water Services Changed
Project:
Main Stre=82020Claim
#12:
Water Se[Kennedy
ntractoris Statement from Request
ater Department changed water metershis resulted in a delay1
day to the schedule and the above cottached letter from
Pipeline."
What was the amount of
$1,626.90 ( Originally submitted $1,679)
the claim?
When did the claim occur?
June 19, 2000
When was the City
June 19, 2000
Notified?
Has the Contractor
Yes, extra work billing was submitted.
supplied the proper back
up documentation in
accordance with Section 3.
3 Extra Work and Section
3-5 Disputed Work of the
"Greenbook" ?
Engineering Division Analysis and Discussion:
It is our understanding, that this claim was caused because the 32 meters
supplied by the City Water Department had 3/." connections rather than 1"
connections. Consequently, the Contractor had to purchase fittings to connect
the 1" service lines to the City supplied meters. According to the paperwork
provided, the Contractor is claiming extra work and that it took a total of 21
person hours to attach the fittings or 40 minutes per fitting.
The Engineering Division discussed this matter with its Water Operations
personnel. In their experience, it would only take 1 to 3 minutes per meter to
install the necessary fitting to make the proper connection. This would total to a
maximum of 96 minutes of extra work time.
It was the Contractor's responsibility to install the original meters therefore the
only allowable claim In time is the difference to install the fitting.
Recommendation:
No explanation was documented for the additional time. Although on premise, we
agree that some compensation is due, we believe the claim is grossly Inflated.
Therefore, we recommend that the claim be decreased accordingly.
The City is willing to compensate the contractor for 2 hours of the foreman's time,
2 hours of the equipment time, and the cost for the material. Material invoices
must be submitted prior to approval of the additional compensation. Also, the
foreman's rate and truck rate are in excess of the allowables. Total
compensation is $424.10.