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Why the Claim:

Construction delays and over runs / in millions of dollars.

Who did I represent?

Project Constructors / Project Manager

How did I get the project?

I did work for that law firm before and they asked me to help them.

What did the case consist of?

The project consisted of the construction of a twin turbine hydroelectric power plant. The new plant was designed with the same physical dimensions of an existing 20-year-old plant. The seismic code had changed dramatically since the existing plant was constructed. The design of the new plant had to incorporate the new seismic code requirements, which added excessive amounts of reinforcement steel to the same physical dimensions of the sister plant. The Power Authority (client) issued their own approved design drawings to the contractor, controlled the batch plant for all concrete mixtures and what type of vibrators to be used.

What was the responsibility of the contractor?

The contractor was to follow the approved contract drawings in the construction of the power plant and set up a working schedule for the duration of the project.

What happen?

Improper concrete mixtures and the use of large air vibratos (client's control) created adverse conditions which created the formation of concrete rock pockets and honeycombing. Extensive delays were incurred due to the process of correcting the rock pockets which had hampered the normal progression of work.

What did I do?

I reviewed all the documents, approved design drawings, the as planned schedule, the collapsed schedule, all RFI's (request for information) and the latest building code for that state. My background as a Civil Engineering Designer working on power plants and concrete reinforcing detailing experience permitted me to discover the many problems on the contract drawings. I worked closely with the rest of the team exchanging findings and information about the case. I attended team meetings at the law office where we developed the strategy for the case.

I created a computer three dimensional scale model showing all 198 separate concrete placements that made up the substructure. The concept was to animate the exact concrete placements in chronological order for both the "As Planned" and the "As Built" schedule. The "As Planned" model was placed alongside the "As Built" and sequenced to match the exact placement dates. The comparison clearly demonstrated the delays and showed the gaps of time between the two schedules.

Two major concrete placements with reinforcement steel were modeled to illustrate the problems that were typically encountered on the project. Field sketches and photographs were used to locate and place the rock pockets. Two intersecting geometric shapes, located at the turbine core, were modeled with a cross section detail taken directly from the contract drawing to illustrate errors on the approved contract drawings.

The computer model became an indispensable tool showing object both solid and transparent, views and details not capable with photographs or other means.

We went to trial with the "As Planned" and "As Built" sequence of events, animated detailed areas of reinforcement steel congestion and illustrations of concrete rock pockets and honeycombing. I presented the animated findings at trial and was accepted as an expert witness, where I pointed out numerous built in defects on the approved contract drawings.

We won eighty percent of the concrete claim.

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John Genuard has over 40 years of experience in the civil engineering field. Extremely well-versed in computer-aided design applications, he also specializes in the development of CAD training programs which enable the training of associated disciplines in basic and advanced usage of MicroStation and AutoCAD software.

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