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TLC has provided the Owner notice of delays both verbally in meetings and in writing as evidenced by <br />language in each of the change orders stating," with the current supply chain delays that have been <br />discussed in the project meetings it is difficult to quantify the additional time required to quote this <br />change. TLC is therefore reserving our rights to additional time for the project that will be determined at <br />a later date." <br />An important point that needs to be relayed before discussing the delays and remedies to them, is the <br />sequencing of different interconnected systems that are specific and re -occurring on this project. Each <br />of these systems are hypersensitive to any delays, critical shutdown requests or out of sequence work. <br />The work activities on this Oslo Road project were intentionally designed to be performed in series and <br />not in parallel in order to maintain potable water delivery to customers in sufficient quantity and quality <br />without interruption. As a result, any delay in any part of the project affects the entire series of activities <br />on the entire project. For example: <br />The New HSP pumps #4 and #5 had to be installed and operational before the existing HSP <br />pumps 1,2,3 could be taken offline and renovated. <br />Only one of four R/O skids can be taken offline and completely replaced including the initial <br />demolition of the existing skid and related instrumentation and electrical work. <br />Only one feedwater pump out of five can be taken off line at any given time including the <br />demolition of the existing connecting 8" feedwater manifolds that selectively feed each of the four <br />existing R/O skids. <br />- The R/0 permeate and concentrate stainless piping in the pipe trenches require complete <br />demolition and then require a completely new larger stainless piping system installed in specific <br />sequences in order to tie in the new R/0 systems while keeping the existing R/0 systems and entire plant <br />operational. <br />There are many other areas with these requirements, but we only want to point out that work <br />throughout this Contract must happen in specific sequences. <br />Adding more people does not necessarily allow for more work to progress. For instance, TLC <br />cannot go in and demo all of the existing R/O skids. <br />- Please note that TLC offered suggestions that would allow the Contractor to build uninhibited by <br />the phasing constraints which would allow for much faster progress. Each of these requests were not <br />acceptable to the Owner. <br />TLC utilized specified companies on this project and expected nothing short of on time and complete <br />deliveries followed by the timely installation of each of the materials. We instead have continued to face <br />delays beyond the control of not only the General Contractor but also to each of our suppliers and <br />subcontractors. <br />Being specific to your request, <br />TLC provided a Finishing Schedule with a request for an extension of time for reasons delineated above. <br />These re -scheduled activities rely on all predecessors to be completed before the next activity can begin <br />143 <br />