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Construction Management

©Taiwan High Speed Rail Corporation

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Taiwan High Speed Rail Corporation Prepared by: Val Republica

100, Hsin Yi Rd, Sec 5 For: REO 215

Taipei, 110 Taiwan, R.O.C. Date: 18 July 2006



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S215 Taoyuan Station – Time Impact Analysis SC1, SC2, and SC3

1. Introduction

1.1 The purpose of this report is to analyse the impact of primary delaying events on the Section

Completion Dates (SC1, SC2, and SC3) of Contact S215.

1.2 The details of achieved dates for the Key Date Schedule and Sectional Completion dates are

presented in Appendix 1.

1.3 The JV has submitted several extensions of time claims against the Section Completion dates in addition to several Variation Order (VO) issues by THSRC. The Contractor has identified

several critical delay events that caused a delay impact to the Sectional Completion Dates, and THSRC have identified several Variation Orders that have had an impact as well. Since

all the Key Dates were achieved the events were only reviewed in respect of their impact on the Section Completion dates. The review indicated that 15 events had an impact on the

Section Completion dates. While some events that affected SC1 or SC2 had knock-on effects

to SC3, most events primarily affected only SC1, SC2, or SC3. See Appendix 2 for a full

listing of events/claims against the respective Section Completion date. The 15 events are:

1.3.1 Event 1) VO 31 Modifications to IT Centre in OMC.

1.3.2 Event 2) Claim T-116 Additional Fire Dampers.

1.3.3 Event 3) Claim T-110 (166) Handrail Design Change.

1.3.4 Event 4) Claim T-138 28 Additional Smoke Vents resulting from 1st Fire Inspection.

1.3.5 Event 5) VO 76 Supply and Installation of Signage Brackets.

1.3.6 Event 6) Claim T-167 Eastern Type Toilet Installation.

1.3.7 Event 7) Claim T-170 Revise Car Park Design Drawings to 4 Levels.

1.3.8 Event 8) Claim T-188 Car Park OP including Canopies and Ancillary Buildings.

1.3.9 Event 9) Claim T-247 Additional Smoke Barriers (Station for Car Park FSD).

1.3.10 Event 10) Claim T-259 VO 29 Supply and Installation of Pump Facilities.

1.3.11 Event 11) Claim T-247 FSD Total Area Calculation OP for Car Park.

1.3.12 Event 12) Claim T-220 VO 140 Installation of S507 Signage and Graphics.

1.3.13 Event 13) Claim T-267 VO 147 Modifications to OMC Training Rooms.

1.3.14 Event 14) Claim T-247 Additional FSD Requirements for Canopies/Ventilation Shafts.

1.3.15 Event 15) Claim T-252 VO 149 Finishes to Pressure Relief Shafts.

1.4 The following exercise is an independent analysis of the time impact of the above primary

events on the Section Completion dates by the RE/SPE. The purpose of this analysis is to

identify with reasonable accuracy; based on the available information, to what extent these



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events have delayed completion of SC1, SC2, and SC3 and what EOT should be recommended for award.

2. Basis of Analysis

2.1 The approach adopted is by determining an extension of time for the 'net' delay effect of the

Employer-initiated primary events or any events beyond the control of the Contractor, which

are the Client’s liability, notwithstanding the concurrent effect of other events. The

Contractor remains liable for his own delays.

2.2 The Contractor is not entitled to any prolongation costs for delay concurrent with Employer-initiated events.

2.3 This approach is consistent with internationally accepted principles incorporated in the

Malmaison Principle and the American Approach.

2.4 The analysis is based primarily on the latest Baseline Programme (Version 2) (BLP) (TYB2) data date 1 January 2004 but Version 1 (TYB1) is used as well.

2.5 The analysis uses the same logic links as in the BLP and does not consider any acceleration

work that requires additional manpower.

2.6 The JV-caused concurrent delays have been recognized by utilizing as-built information in

the analysis, at the time of impact of each primary event (the trigger date).

2.7 This analysis principle also recognizes any mitigation measures implemented.

3. Time Impact Analysis Approach

3.1 Sectional Completion dates with a time over-run have been identified.

3.2 Primary events that are related to or have impacted the critical path of the Section

Completion dates have been reviewed.

3.3 Actual progress status at the time of the event has been determined.

3.4 Employer-initiated primary events have been combined with activities in the BLP to

determine the impact of the delays.

3.5 The programme output is a record of the relative difference between the updated BLP and the

impacted programme’s Section Completion date. This delay is attributable to the Employer

(See Bar Charts in Appendix 5).

3.6 From all the claims submitted by the JV, only the following six were analysed in detail and of these only four are considered critical and significantly delay Section Completion 2.

4. Events Primarily Affecting Section Completion 1

4.1 Time Impact Analysis of VO 31 Modifications to IT Centre in OMC. (Event 1)

VO 31 was issued on 12 January 2004. It was for major modifications to the IT Centre in the

OMC and resulted in structural changes to the generator room on the first floor and the

special order of roof top air conditioning units. The issue consisted of nearly 200 drawings

and increased the complexity of the works, which caused a substantial increase in the as-built



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durations of the relevant activities in the Baseline Programme. The delay analysis was done by impacting TM14, the Monthly Update of the Baseline Programme (BLP) TYB1 from

December 2003. The results of the impact are presented in programme TI14 in Appendix 5.

Chronology of Main Events (Event 1)

1/12/2004 THSRC issue VO 31.

03CZNS00441

7/21/2004 THSRC approve generator room drawings.

04S215S01826

1/15/2005 Delivery of roof top air conditioners

4.2 Time Impact Analysis of Claim T-116 Additional Fire Dampers. (Event 2)

THSRC issued the findings of the ICE/ISE “Report of Site Inspection” on 12 May 2004. One

of the findings was that several fire dampers required for the fire rated walls were missing on

the SONOed shop drawings. This necessitated the submission of several RFIs by the

contractor to clarify the design for fire dampers and fire compartmentalization, the final

clarification letter being issued by THSRC on 22 November 2004. This was the impacting

event and the results of the impact are presented in programme T24I (Impacted T24A Data

Date October 2004) in Appendix 5.


Date Description Reference

3/29/2004 IREG carry out site inspection of Station E & M services.

Findings state that the Contractor should submit an RFI for

clarification.

5/12/2004 THSRC issue letter of findings from the IREG Report of Site

Inspection Reference ICE-SG-S215-M-IR-004.

04S215S01149

7/30/2004 FOJV RFI requesting clarification of JV’s revised design that

follows NFPA 130 as directed by IREG.

RFI-FOJV-

THSR-0214-04

8/30/2004 THSRC response to RFI-0214-04 confirming the JV’s

statement that the requirements for the fire dampers specified

in NFPA130 clause 2-2.3 shall be followed as a minimum

requirement for the project.

04S215S02232

10/09/2004 FOJV RFI requesting final clarification of JV’s revised

design that incorporates all of THSRC comments.

RFI-FOJV-

THSR-0302-04



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11/22/2004 THSRC letter confirming previous responses to RFIs and

Technical Design Meetings held on 2, 8, and 19

November 2004 encompassing all comments regarding

revised fire damper design. Final SONO given.

04S215S03107

4.3 Time Impact Analysis of Claim T-110 (166) Handrail Design Change. (Event 3)

In April of 2004 FOJV discovered that there was a discrepancy between the design drawings

and the specification with regard to handrail and guardrail height and load requirements. A THSRC directive increased the handrail heights from 1.2 to 1.3 meters for falling distances

above 3 meters. The specifications require concurrent uniformly distributed (UDL) and point

loads. If this is applied to the detail in the drawings, the members are overstressed. This

affects the guardrails in the Station void area, handrails P-ST1-12 running adjacent to the

escalators from the Station level down to the Platforms, and escape handrails S-ST7-10.

The Contractor submitted RFI S215.00425 JV reference RFI-FOJV-THSR-0091-04 dated 20 April 2004 regarding the clarification of Handrail Heights. This was the first RFI in a long

series of correspondence. Design workshops were held and correspondence exchanged for nearly a year and consequently, FOJV did not get all of the necessary design information

until 17 March 2005.

The delay analysis was done by impacting T28A, the Monthly Update of the Baseline

Programme (BLP) TYB2 from February 2005. Shop drawing/fabrication information that

was not in the BLP was extracted from FOJV Claim S215-T-166 reference S215-LTR-FOJV-

THSR-1103-05 dated 15 October 2005. This was impacted by confirmation of all the design information from Technical Design Meeting No. 78 dated 17 March 2005. The results of the

impact are presented in programme T28J in Appendix 5. Please note that the programme (T28I) has the cumulative effect of 2 events because it was also impacted by T-138,

Additional Smoke Vents in the OMC Building.



4/20/2004 RFI from FOJV requesting clarification of Handrail design.

RFI-FOJV-THSR-0091-04

5/17/2004 THSRC first response to RFI-0091-04. 04S215S001194

6/14/2004 Second RFI from FOJV requesting additional clarification

to THSRC response.

RFI-FOJV-

THSR-0151-04

6/15/2004 THSRC clarification of response to RFI-0091-04. 04S215S01474

6/23/2004 RFI requesting full marked up drawings for handrail height change and necessary additional guardrail details.

RFI-FOJV-THSR-0165-04

6/29/2004 THSRC response to RFI 0165-04 stating that Technical Design meetings are a venue for resolving design issues.

7/23/2004 THSRC response to RFI 0151-04 further clarifying design

issues.

04S215S01834



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THSRC second response to RFI 0151-04 further clarifying

design issues.

04S215S01951

THSRC third response to RFI 0151-04 further clarifying

design issues.

04S215S02038

9/21/2004 RFI requesting clarification of sufficiency of concentrated

load based on Taiwan practice.

RFI-FOJV-

THSR-0283-04

10/04/2004 THSRC response to RFI 0283-04 confirming JV shall

follow design criteria under Specification 05500 and

05720.

04S215S02552

10/13/2004 RFI requesting resolution of contradictory clauses within

the specification.

RFI-FOJV-

THSR-0308-04

10/20/2004 THSRC response to RFI 0308-04 for clarification of

handrails in the OMC.

04S215S02726

10/27/2004 RFC requesting a change to the concurrent loading

requirement.

RFC-FOJV-

THSR-0018-04

11/16/2004 RFI requesting urgent decision with regard to RFC-FOJV-

THSR-0018-04 dated 27 October 2004 requesting a

change to the concurrent loading requirement.

RFI-FOJV-

THSR-0348-04

11/18/2004 THSRC response to RFC 0018-04. Response clarifies

that an amendment to the details shown on the W

drawings will be needed. RFI clarifies basic details will

be provided to the JV so that they can prepare their

shop drawings.

04S215S03080

11/22/2004 THSRC issues letter to HSIEC requesting AEC review sketches and make design amendments as necessary.

12/01/2004 FOJV submits letter referencing GCC Clause 44.1 giving notice that the requirement to undertake to design change

is likely to cause delay.

S215-LTR-FOJV-THSR-

1412-04

12/8/2004 RFI requesting design clarification for handrails in non-

public areas.

RFI-FOJV-

THSR-0377-04

12/9/2004 FOJV under GCC Clauses 44.2 and 53.3 submitting

detailed particulars for Claim T-110. The contractor is claiming 71 days to Section Completion 1.

S215-LTR-

FOJV-THSR-1453-04

12/15/2004 FOJV letter proposing Special Measures to mitigate the delays.

S215-LTR-FOJV-THSR-

1487-04

12/20/2004 THSRC letter responding to claim letter S215-LTR-FOJV-

THSR-1453-04.

04S215S03414

12/28/2004 Letter from THSRC stating that handrails and guardrails

are not a prerequisite for obtaining Fire Certificate. States

Special Measures may not be needed.

04S215S03473

1/5/2005 FOJV letter confirming their proposal to use Special

Measures and THSRC’s statement that guardrails are not a

prerequisite for obtaining Fire Certificate.

S215-LTR-

FOJV-THSR-

0026-05



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1/7/2005 THSRC letter issuing amended details/drawings of

Handrails, Balustrades, and Guardrails to be used in the public areas of the Station and Car Park.

05S215S00067

1/10/2005 THSRC letter responding to S215-LTR-FOJV-THSR-

0026-05. Letter states that THSRC will review whether or

not unfinished permanent handrails can be included as

outstanding works.

05S215S00073

1/12/2005 FOJV letter requesting further clarification. S215-LTR-

FOJV-THSR-

0057-05

1/13/2005 THSRC response to RFI 0377-04 confirming the details

on the W drawings are to be followed for the fabrication

and installation of handrails in the non-public areas of the

Station and OMC Building.

05S215S00111

1/18/2005 THSRC letter giving further clarification to S215-LTR-

FOJV-THSR-0057-05.

05S215S00194

1/28/2005 THSRC letter issuing working drawings for Handrails,

Balustrades, and Guardrails to be used in the public areas

of the Station and Car Park.

3/11/2005 FOJV requesting resolution of items 6 and 7 in their letter

reference S215-LTR-FOJV-THSR-0057-05. Letter states

items were discussed during Technical Design Meetings

Nos. 73-77 (27 January 2006 – 3 March 2006) and HSIEC

were to resolve them. Letter claims items still not

resolved.

S215-LTR-

FOJV-THSR-

0303-05

3/15/2005 RFI requesting confirmation of the use of chemical

anchors for support base at Car Park perimeter guardrail.

RFI-FOJV-

THSR-0050-05

3/17/2005 Meeting Minutes (3/21/2005) for Technical Design

Meeting 78. Item 1.2 states that THSRC have clarified

all requirements with FOJV and will issue updated

drawings formally.

05S215S00609

3/18/2005 FOJV letter updating Delay Analysis Programme. S215-LTR-

FOJV-THSR-

0316-05

3/30/2005 THSRC response to RFI-FOJV-THSR-0050-05.

4/6/2005 FOJV letter clarifying locations that they are unable to

complete as a result of the handrail/guardrail installation

delays. Drawings indicate Guardrails in Station void area,

Handrails in stairs S-ST7-10, and Handrails in stairs P-

ST1-12.

S215-LTR-

FOJV-THSR-

0378-05

4/9/2005 Interim account of delay cost based on Delay Analysis

Programme issued under letter reference S215-LTR-

FOJV-THSR-0316-05 dated 18 March 2005.

S215-LTR-

FOJV-THSR-

0401-05

4/15/2005 THSRC letter providing additional resolution of queries in

respect of handrails/guardrails.



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4/18/2005 THSRC letter providing additional resolution based on

structural review by AEC of queries in respect of handrails/guardrails.

5/5/2005 Summary of correspondence. S215-LTR-

FOJV-THSR-

0521-05

7/1/2005 Claim T-166 claiming for 72 days to Section Completion 2

caused by delays to Public Escape Stair handrails in the

Car Park.

S215-LTR-

FOJV-THSR-

0687-05

10/15/2005 Claim T-166 claiming for 143 days to Section Completion

1, 87 days to Section Completion 2, and 54 days to Section

Completion 3. Letter effectively combines Claims T-110

and T-166.

S215-LTR-

FOJV-THSR-

1103-05

4.4 Time Impact Analysis of Claim T-138 28 Additional Smoke Vents resulting from 1st Fire

Inspection. (Event 4)

The 1st fire inspection held on 5 February 2005 resulted in the addition of 28 Smoke Vent Windows. This is considered to be an oversight on the part of the AEC. The Contractor

submitted several letters to THSRC listing the remedial works required by the Fire

Department. They eventually submitted an RFI on 10 March 2005 and THSRC instructed the

Contractor to procure the additional Smoke Vents via letter reference 05S215S00611 dated

21 March 2005. This was the impacting event and the results of the impact are presented in

programme T28I (Impacted T28A Data Date February 2005) in Appendix 5. Please note that

this programme (T28I) has the cumulative effect of 2 events because it was also impacted by

T-110(166) Handrail Design Change.



2/5/2005 First Fire Inspection held for OMC Building.

2/15/2005 FOJV letter enclosing defects list from first fire inspection. S215-LTR-

FOJV-THSR-

0189-05

2/16/2005 FOJV letter enclosing defects list from first fire inspection.

Letter further states that Item 25 (Smoke Vents) is a design

matter and requests THSRC advise/instruction on the matter.

S215-LTR-

FOJV-THSR-

0190-05

2/18/2005 FOJV letter stating joint meeting was held on 18 February to discuss design matters. Letter states that rectifications works

will have a cost and time impact.

S215-LTR-FOJV-THSR-

0178-05

2/23/2005 FOJV letter giving notice of their intention to claim

additional payment for additional work resulting from the fire inspection.

S215-LTR-

FOJV-THSR-0227-05

2/23/2005 THSRC letter issuing meeting minutes from 18 February 2005 defects meeting. Item 3.1 details Smoke Vents.

05S215S00398



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3/1/2005 THSRC letter instructing FOJV to maintain proper records. 05S215S00421

3/2/2005 FOJV letter stating solution to rectifying defects is a joint

effort requiring input from Taoyuan Fire Brigade, THSRC,

and the AEC.

S215-LTR-

FOJV-THSR-

0243-05

3/7/2005 THSRC letter noting FOJV’s comments on time and cost

implications of defects.

05S215S00485

3/10/2005 RFI requesting confirmation of rectification works related to

design matters in the OMC after the first fire inspection.

RFI-FOJV-

THSR-0049-05

3/10/2005 FOJV letter submitting particulars for time claim. Letter

claims 53 days.

S215-LTR-

FOJV-THSR-

0294-05

3/10/2005 FOJV letter submitting particulars for time claim. Letter

claims 53 days.

S215-LTR-

FOJV-THSR-

0295-05

3/15/2005 THSRC administrative letter. 05S215S00557

3/15/2005 THSRC administrative letter. Mistakenly uses number

S215-T-141.

05S215S00558

3/21/2005 Response to RFI0049-5 agreeing with JV’s proposed

rectification works.

05S215S00611

4/7/2005 FOJV letter submitting particulars for time claim. S215-LTR-

FOJV-THSR-

0391-05

4.5 Time Impact Analysis of VO 76 Supply and Installation of Signage Brackets. (Event 5)

In August 2004 THSRC issued VO 76 for the supply and installation of support brackets to

Signage and Graphics enclosures. Some revised drawing were issued in October 2004 and

January 2005. There was also an issue with regard to design responsibility and this was

resolved through technical design meetings and correspondence. The final clarification letter

being issued by THSRC on 18 May 2005 reference 05S215S01156. This was the impacting

event and the results of the impact are presented in programme T30I (Impacted T30A Data

Date April 2005) in Appendix 5.


8/18/2004 THSRC issued VO 76.

04CZNS00982

10/21/2004 THSRC issued modified drawings for VO 76.

04CZNS01204

1/12/2005 THSRC issued further information in the form of “Tender

Set “Drawings”.

05CZNS00007

3/25/2005 FOJV letter commenting on S507’s programme. S215-LTR-

FOJV-THSR-

0338-05



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5/2/2005 THSRC letter responding to FOJV-THSR-0338-05.

05S215S00985

5/9/2005 FOJV letter clarify their position on VO 76 structural design. S215-LTR-FOJV-THSR-

0526-05

5/18/2005 THSRC letter further clarifying issues from FOJV-

THSR-0526-05.

05S215S01156

4.6 Time Impact Analysis of Claim T-167 Eastern Type Toilet Installation. (Event 6)

The basis of this claim is the that Architectural design drawing requirement stipulating that

eastern type toilets be encased in concrete did not allow for the E&M department maintenance requirement. In April 2004 FOJV’s E&M department proposed a frame type

system that was ultimately approved by THSRC E&M department. It was approved based on

concerns about maintenance, however the Architectural department still insisted on a

concrete system out of concerns about sanitary leakage into the frame system. Alternatives

were proposed to try to satisfy both sanitary and maintenance concerns and ultimately a

frame type mock-up was approved on 1 July 2005 that was amiable to both parties. This was

the impacting event and the results of the impact are presented in programme T32I (Impacted

T32A Data Date June 2005) in Appendix 5.



2/19/2004 JV letter referencing Constructed Mock-Ups of Plumbing

Fixtures as per requirements of Volume 9, Section 15410

Part 1.7.

S215-LTR-

FOJV-THSR-

0147-04

4/20/2004 THSRC letter stating that the E&M Mock-Up presented on

19 February 2004 was acceptable to the E&M department

but removable panels required further submission for

architectural review.

04S215S01149

10/8/2004 FOJV Method Statement Submission reference S215R2004-

03035-2 for Plumbing Fixture Mock-Up. MST-3030.

S215-LOT-

FOJV-THSR-

0790-04

11/3/2004 THSRC letter rejecting the Method Statement MST-3030.

04S215S02888

1/28/2005 FOJV Drawing Submission for Lining Layouts at Toilets.

S215-LOT-

FOJV-THSR-

0042-05

3/7/2005 THSRC response giving SONO to drawing submission.

05S215S00460



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3/17/2005 Technical Design meeting 78 THSRC Architectural staff

advise that MS information submitted by FOJV is incorrect in that it does not relate to concrete construction shown on

Architectural contract drawings and the some provision should be made to avoid encasing flexible connection within

concrete.

3/24/2005 Technical Design meeting 79 THSRC advise that both

departments (C/A and E/M) of both parties (THSRC and

FOJV) review contract requirements relating to the E&M

installation.

4/7/2005 Technical Design meeting 80 THSRC instruct FOJV to raise

an RFI related to the contractual requirements of the Eastern

Type Toilet installation.

4/21/2005 Technical Design meeting 81 noted that the mock-up has been completed based on a frame support system.

4/27/2005 FOJV submit RFI requesting confirmation of whether the

Eastern Type Toilet should be cast-in concrete or installed with framing.

RFI-FOJV-

THSR-0079-05

5/3/2005 FOJV raises RFI confirming use of frame type mock-up but

expresses concerns about water leakage into frame system that will cause odour and rust.

RFI-FOJV-

THSR-0080-05

5/10/2005 THSRC response to RFIs instructing FOJV to complete the

existing mock-up ensuring that an effective seal is provided between the cement board substrate and toilet rim.

05S215S017072

5/17/2005 Technical Design meeting 83 advises that the mock-up

should included a sloped tile surface to drain water away from the wall.

05S215D00240

6/3/2005 Notice of mock-up inspection.

S215-FOJV-

THSR-0603-05

7/1/2005 THSRC approves mock-up.

05S215S01579


5.1 Time Impact Analysis of Claim T-170 Delays to Car Park Fire Inspection. (Event 7)

The basis of this claim is that the original design drawing submission to Taoyuan County

included the future phase of the Car Park, which consists of two additional levels. In June of



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2005 FOJV began holding joint meetings with the Taoyuan County Fire Department in preparation for the Fire Inspections on the Car Park. On 13 June 2005 a joint meeting was

held and Taoyuan County informed FOJV that the design drawings would have to be re-submitted showing only the 4 levels that are to be completed with the current phase. This

was so that they would match the as-built drawings. The drawings had to be prepared by

HSIC, the AEC. Once these were resubmitted, Taoyuan City took two months to review

them. After they were approved, FOJV then submitted the as-built drawings. Only after

these were reviewed could the application for the fire inspections be submitted. This did not

occur until 17 September 2005.

The delay analysis was done by impacting T31A, the Monthly Update of the Baseline

Programme (BLP) TYB2 from May 2005. Activities for FSA Fire Control Inspections including follow on Commissioning activities to Section Completion 2 were used from

T31A. As a result of the resubmission of the design drawings by HSIC and the review process by Taoyuan County, the Fire Inspection process could not commence until 17

September 2005. The early finish variance resulting from this impacted analysis is 66 days

for Section Completion 2 and 49 days for Section Completion 3. See attached programme

T31I in Appendix 5 for results of the impact.



6/3/2005 Letter informing THSRC that E/M drawings for Car Park

Fire Inspection Application will need to be revised to clearly

define Phase I portion of work only

S215-LTR-

FOJV-THSR-

0604-05

6/13/2005 Fire Inspection meeting with FOJV. FOJV informed

THSRC that Taoyuan County requires design drawings

be changed to 4 levels to match as-builts.

05S215D00272

6/20/2005 Letter informing THSRC of possible delay as a result of

revising design drawings.

S215-LTR-

FOJV-THSR-0643-05

6/22/2005 THSRC letter responding to S215-LTR-FOJV-THSR-0643-05.

05S215S01496

7/18/2005 FOJV giving formal notice of delay. S215-LTR-FOJV-THSR-

0736-05

5.2 Time Impact Analysis of Claim T-188 Car Park OP to include Canopies and Ancillary

Buildings. (Event 8)

In Sectional Completion Documentation Meeting No. 25 held on 11 August 2005, THSRC informed FOJV that Car Park OP submission also requires completion of bus canopies and

ancillary buildings. This was based on discussions THSRC had with the Taoyuan County Government officials. The delay analysis was done by impacting T34A, the Monthly Update

of the Baseline Programme (BLP) TYB2 from August 2005. The programme assumes that

FOJV will have to submit additional as-built drawings for the canopies to Taoyuan County

after completion of the canopies. The early finish variance resulting from this impacted



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analysis is 29 days for Section Completion 2 and 2 days for Section Completion 3. See attached programme T34I in Appendix 5 for results of the impact.



8/11/2005 Sectional Completion Documentation Meeting No. 25. 05S215S01880

5.3 Time Impact Analysis of Claim T-247 Additional Smoke Barriers (Station for Car Park

FSD). (Event 9)

Fire Inspections for the Car Park were held on 20 September 2005, 24 October 2005, and 17 November 2005. After each inspection FSD required additional smoke barriers to be

installed on the Platform, the Concourse, and finally the Station Hall. This was outside the

scope of the Car Park Section Completion 2 requirements but FSD kept making these request

because they wanted the additional smoke barriers in the Station area. This clearly delayed

Section Completion 2 and was beyond the control of FOJV. The delay analysis was done by

impacting T35A, the Monthly Update of the Baseline Programme (BLP) TYB2 from

September 2005. The programme assumes that FOJV will only get the fire certificate after

the installation of the smoke barriers in the Station Hall. The early finish variance resulting

from this impacted analysis is 43 days for Section Completion 2 and 43 days for Section

Completion 3. See attached programme T35I in Appendix 5 for results of the impact.



10/18/2005 Comments from the first Fire Inspection for the Car Park

carried out on 20 September 2005. Letter explains that FSD

require a smoke barrier at Platform level in the Station to be

installed to get the fire certificate for the Car Park.

S215-LTR-

FOJV-THSR-

1109-05

11/28/2005 Comments from the second Fire Inspection for the Car Park

carried out on 24 October 2005. Letter explains that FSD

verbally stated they require a smoke barrier at Concourse

level in addition to the Platform level to be installed to get the fire certificate for the Car Park.

S215-LTR-

FOJV-THSR-

1224-05

11/28/2005 Comments from the third Fire Inspection for the Car

Park carried out on 17 November 2005. Letter explains

that FSD required a smoke barrier in the Station Hall to

be installed to get the fire certificate for the Car Park.

S215-LTR-

FOJV-THSR-

1224-05

5.4 Time Impact Analysis of Claim T-247 FSD Total Area Calculation OP for Car Park. (Event

11)



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The third Fire Inspection for the Car Park was carried out on 17 November 2005. FSD confirmed that Canopies and Tunnel Ventilation Shafts must not be part of the Car Park but

must be included with the Station in terms of total area figures. The AEC had included these items with the Car Park based on Event 2. FOJV had to revise the design drawings and as-

built drawings. FSD also indicated that they would require a fourth fire inspection and a

fourth separate fire certificate for the Canopies and Ancillary Buildings. This would be a

requirement for the Occupation Permit for the Car Park. The impacting event was the third

fire inspection and the results of the impact are presented in programme T36I (Impacted

T36A Data Date October 2005) in Appendix 5.



11/10/2005 At Section Sectional Completion Documentation Meeting

No. 37 FOJV indicate that FSD may require that Canopies

and Tunnel Ventilation Shafts be included with the Station in

terms of total area figures.

11/28/2005 Comments from the third Fire Inspection for the Car

Park carried out on 17 November 2005. FSD confirm

that Canopies and Tunnel Ventilation Shafts must be

included with the Station in terms of total area figures,

but will require a fourth fire inspection and require a

fourth separate fire certificate. This is a requirement for

the Occupation Permit for the Car Park

S215-LTR-

FOJV-THSR-

1224-05

12/21/2005 Letter confirming the previous statement. S215-LTR-

FOJV-THSR-

1292-05

5.5 Time Impact Analysis of Claim T-247 Additional FSD Requirements for Canopies and

Ancillary Buildings (22 Fire Extinguishers, 3 Exit Lights, 2 Fire Hydrant Boxes). (Event 14)

After the third fire inspection of the Car Park where FSD confirmed the Canopies and

Ancillary Building would require a fourth separate fire certificate, discussions were held with FSD to decide on new fire system requirements. As Event 4 indicated this was required to

get the Occupancy Permit for the Car Park. They finally agreed on 22 Fire Extinguishers, 3 Exit Lights, and 2 Fire Hydrant Boxes. FOJV submitted their revised design to FSD on 18

January 2006 and FSD approved the design on 24 January 2006. The impacting event was the design submission and the results of the impact are presented in programme T38I (Impacted

T38A Data Date December 2005) in Appendix 5.





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1/18/2006 FOJV submit revised fire system design for Canopies and

Ancillary Buildings based on previous discussions with

FSD.

S215-LTR-

FOJV-THSR-

0083-06

1/24/2006 FSD approve revised design.

S215-LTR-

FOJV-THSR-

0083-06

2/8/2006 Fourth Fire Inspection. FSD inspect Canopies and Ancillary

Buildings.


6.1 Time Impact Analysis of Claim T-259 VO 29 Supply and Installation of Pump Facilities.

(Event 10)

In August 2004 VO 29 was issued for the Supply and Installation of Pump Facilities in the

Approach Tunnels. Several meetings were held regarding commencement of the works and THSRC finally issued a letter in September 2005 stating that FOJV would be held

responsible for any claims THSRC received from Interfacing Parties as a result of FOJV’s failure to commence the works. FOJV responded with letter reference S215-LTR-FOJV-

THSR-0745-05. This was used as the impacting event and the results of the impact are presented in programme T35J (Impacted T35A Data Date September 2005) in Appendix 5.



8/11/2004 THSRC issued VO 29. 04CZNS00952

2/03/2005 THSRC letter clarifying claim issue with respect to works to be included with VO 29.

05S215S00321

7/05/2005 THSRC issue drawings related to the Pump Stations. FOJV are requested to check the drawings and the requested

architectural works against the current site condition.

05S215S01602

7/19/2005 FOJV letter stating work scope in drawing issue is not

clearly defined.

S215-LTR-

FOJV-THSR-0745-05

9/28/2005 THSRC letter instructing FOJV to carry out the works

without any further delay.

05COBS00272

10/15/2005 FOJV letter stating their position with regard to THSRC

letter 05COBS00272. Letter states they are coordinating

closely with TSCIC and will commence the works as soon

as possible. Works to commence on 18 October 2005.

S215-LTR-

FOJV-THSR-

0745-05



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6.2 Time Impact Analysis of Claim T-220 VO 140 Installation of Signage and Graphics. (Event 12)

In August 2005 VO140 was issued to instructing FOJV to take delivery of, store, install, and

provide post installation protection of Signage and Graphics provided by the S507 contractor.

The first signs were delivered on 10 November 2005 and the final signs were delivered on 24

May 2006. The impacting event was the initial delivery and the results of the impact are

presented in programme T36J (Impacted T36A Data Date October 2005) in Appendix 5.



8/4/2005 THSRC issued VO 140.

05CZNS00868

11/10/2005 First delivery of Signage and Graphics from the S507

contractor.

5/24/2006 Final delivery of Signage and Graphics from the S507

contractor.

6.3 Time Impact Analysis of Claim T-267 VO 147 Modifications to OMC Training Rooms.

(Event 13)

Several discussions had taken place between THSRC and FOJV regarding modification to three OMC training rooms. In October 2005 THSRC gave written notice to commence the

modification works. This was the impacting event and the results of the impact are presented in programme T36K (Impacted T36A Data Date October 2005) in Appendix 5.



10/26/2005 THSRC letter instructing FOJV to carry out

modifications to training rooms O251, O252 and O253 in

the OMC.

05S215S02455

4/21/2006 THSRC issues VO 147. 06COBS00693

6.4 Time Impact Analysis of Claim T-252 VO 149 Finishes to Pressure Relief Shafts. (Event 15)

Several discussions had taken place between THSRC and FOJV regarding installation of

Architectural Finishes to the Pressure Relief Shafts. Limited correspondence was transferrd

in January 2006 THSRC gave written notice to commence the works along with

specifications and drawings. This was the impacting event and the results of the impact are presented in programme T38J (Impacted T38A Data Date December 2005) in Appendix 5.




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9/13/2005 FOJV letter expressing concerns over reduction in price

quotation.

S215-LTR-

FOJV-THSR-0967-05

12/28/2005 FOJV letter submitting revised quotation for the captioned

work.

S215-LTR-

FOJV-THSR-

1300-05

1/04/2006 THSRC letter issuing written instruction to proceed with

the works as well as specifications and drawings.

06S215S00057

7. Summary of EOT Entitlement

7.1 A summary based on the above analyses presented in Sections 4 through 6 can be found in

Appendix 4. The result of the EOT Entitlement Summary is that the Contractor is entitled to an excusable non-compensable EOT of 156 calendar days to 3 October 2005 for Section

Completion 1, 210 calendar days to 28 March 2006 for Section Completion 2, and 271 calendar days to 30 June 2006 for Section Completion 3.

8. Contractor’s Concurrent Delay

8.1 This exercise is to assess the delays of the Contractor’s own making. The analysis is based

on the Baseline Programmes (TYB1 and TYB2), the updated (progressed) programmes

submitted monthly, the 3-month rolling programmes, site observations and review of daily

records. With regards to Section 1 Completion, the impact of the Contractor’s concurrent

delay is actually greater than 156 days, but since the Section 1 Completion was granted on 3

October 2005, delays beyond this point have not been analysed and the Contractor’s

concurrent delays affecting Sectional Completion 1 should be considered as 156 days. With

regards to Section 2 Completion, the impact of the Contractor’s concurrent delay is equal to

210 and therefore the Contractor’s concurrent delays affecting Sectional Completion 2 should be considered as 210 days.

8.2 No prolongation costs should be considered as the Contractor’s own concurrent delays have

necessitated the need for him to remain on site with a full contingent of staff. The EOTs for each Section Completion date should be considered for reduction of liquidated damages only.

9. Conclusions

9.1 A comparison of the overall time impact analysis produced by the contractor and by the REO

are summarised in the table below:

S215 Contractor S215 REO

Section 1 222 days 156 days



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10. Recommendations

10.1 The RE recommends that a Final EOT be awarded for the following Section Completion

Dates:

10.1.1 Section 1 – 156 days (Revised date 3 October 2005)

10.1.2 Section 2 – 210 days (Revised date 28 March 2006)

10.1.3 Section 3 – 271 days (Revised date 30 June 2006)

11. Appendix 1 – Schedule of Key Dates and Section Completion Dates

12. Appendix 2 – Items Influencing Completion of the Works

13. Appendix 3 – As-Built Programme VO and Claims

14. Appendix 5 – Summary of EOT Entitlement

15. Appendix 5 – Impacted Programmes



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Appendix 1 – Schedule of Key Dates and Section Completion Dates



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Appendix 2 – Items Influencing Completion of the Works



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Appendix 3 – As-Built Programme VO and Claims



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Appendix 4 – Summary of EOT Entitlement



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Appendix 5 – Impacted Programmes

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