Refineries, Petrochemical, and Chemical


Provided dispute resolution services in support of a chemical company that was defending against $150 million in impact claims made by a European EPC contractor on several polyethylene terephthalate plants. Participated in the document discovery, research, organization, and coding of over 500,000 project records into an Internet-based document repository. Assisted in answering interrogatories and prepared questions for fact witness depositions. Scrutinized the entitlement of alleged critical path schedule delays due to late and continuous changes, technology changes, late turnover package approvals, weather impacts, and slow agency reviews potentially affecting 15,000 schedule activities. Developed a comprehensive delay allocation model used to quantify and document critical path and concurrent delays affecting the schedules. Correlated issues to schedule activities. Employed a retrospective CPM schedule delay analysis methodology to correctly calculate entitlement for compensable delay costs and evaluate concurrent delays due to approved change orders, fact-based project issues, and weather impacts as supported by project records. Based on the findings, the contractor’s claims were grossly overstated and unsupported; the owner enjoyed a favorable settlement at a small fraction of the total dispute. Performed extensive schedule quality assurance review studies of the contractor’s contemporaneous EPC project schedules to determine if these schedules were fit for delay analysis including identification and resolution of open-end activities, overuse of constraints, incorrect as-built dates, missing as-built dates, missing original scope, and missing logic.


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