Direct Steel, LLC

CourtArmed Services Board of Contract Appeals
DecidedAugust 2, 2024
Docket63838, 63839
StatusPublished

This text of Direct Steel, LLC (Direct Steel, LLC) is published on Counsel Stack Legal Research, covering Armed Services Board of Contract Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Direct Steel, LLC, (asbca 2024).

Opinion

ARMED SERVICES BOARD OF CONTRACT APPEALS

Appeals of - ) ) Direct Steel, LLC ) ASBCA Nos. 63838, 63839 ) Under Contract No. W9126G-21-C-0003 )

APPEARANCES FOR THE APPELLANT: Kendall Woods, Esq. Mark Noth, Esq. Laurie & Brennan, LLP Chicago, IL

Mr. Matthew D. Nagel Vice President

APPEARANCES FOR THE GOVERNMENT: Michael P. Goodman, Esq. Engineer Chief Trial Attorney R. Stephen Cheak, Esq. R. Lauren Horner, Esq. Engineer Trial Attorneys U.S. Army Engineer District, Fort Worth

OPINION BY ADMINISTRATIVE JUDGE MCLISH UNDER BOARD RULE 12.3

Appellant Direct Steel LLC (Direct Steel) appeals “deemed denials” of two claims submitted to the government’s contracting officer relating to a contract with the United States Army Corps of Engineers (USACE or government) to construct a warehouse at Fort Hood, Texas. We consolidated these appeals and Direct Steel elected to proceed under Board Rule 12.3, Accelerated Procedure. Both parties agreed to waive a hearing and submit their cases on the written record pursuant to Board Rule 11. Under Rule 12.3(c), the Board’s decision “will normally be short and contain only summary findings of fact and conclusions.” FINDINGS OF FACT 1

I. The Contract

1. USACE awarded Direct Steel Contract No. W9126G-21-C-0003 (Contract) on December 10, 2020. The Contract was a firm-fixed price contract under which Direct Steel would construct a Supply Support Activity Warehouse at Fort Hood (now Fort Cavazos), Texas. (JSF ¶¶ 2, 16-17)

II. Facts Relating to the Foundation Claim (No. 63838)

2. Among the structures to be provided was a pre-engineered metal building (PEMB). Direct Steel was to build the structural foundation to support the PEMB warehouse. (JSF ¶¶ 3-5)

3. The Contract set forth specific criteria for the PEMB. The drawings included a fully designed and dimensioned structural foundation for an “example” PEMB. The solicitation did not specify the brand or model of PEMB or covered storage structures to be constructed. (JSF ¶ 5)

4. Drawing S-002, under “Reinforced Concrete” at ¶ (C) n. 13 (Note (C)13), states:

THE FOUNDATION SYSTEM HAS BEEN DESIGNED BASED ON ASSUMED PEMB COLUMN REACTIONS. FINAL PEMB COLUMN REACTIONS FROM THE PEMB SUPPLIER ARE REQUIRED TO VERIFY THE FOUNDATION DESIGN IS ADEQUATE. THE CONTRACTOR SHALL OBTAIN THE SERVICES OF A LICENSED PROFESSIONAL ENGINEER TO VERIFY THE FOUNDATION SHOWN IS ADEQUATE FOR THE BUILDING SUPPLIED. ANY REVISIONS TO THE FOUNDATION SHALL BE AT NO

1 The parties submitted a 147-paragraph Joint Stipulation of Facts (JSF). We accept the stipulated facts as true, although we do not repeat all of them here. Our findings of fact rely upon the JSF as well as additional record evidence submitted by the parties, including documents in the Rule 4 file, affidavits, and expert reports. We commend counsel for working together to prepare the JSF, which has been helpful to the Board.

2 ADDITIONAL COST TO THE GOVERNMENT, AND SHALL BE SUBMITTED TO THE GOVERNMENT FOR APPROVAL.

(JSF ¶ 58)

5. Direct Steel’s president understood Note (C)13 of Drawing S-002 to mean that, if revisions to the foundation design were necessary, Direct Steel would provide them at no additional cost, but that Direct Steel would not be responsible for any increased cost of labor and material necessary to provide the foundation (app. br., ex. D (first aff. of R. Swierk) ¶ 12).

6. Direct Steel could not have determined whether and to what extent foundation revisions would be necessary until after contract award, when its selected PEMB supplier would complete the design of the PEMB building and provide column reactions (app. br., ex. D ¶¶ 5-9). In preparing its bid, Direct Steel assumed that the foundation design was adequate and did not include any contingency amount to account for the possibility that revisions to the foundation would prove necessary (app. reply, ex. 4 (second aff. of R. Swierk) ¶ 6). In light of the language in Note (C)13 of Drawing S-002, it was unreasonable for Direct Steel to assume that the foundation design was adequate.

7. USACE understood Note (C)13 of Drawing S-002 to mean that the contractor was responsible for all costs of providing a revised foundation if one became necessary because of the contractor’s selection of a particular PEMB design. The government’s administrative contracting officer’s affidavit indicates that Note (C)13 of Drawing S-002 is standard in USACE contracts for PEMB warehouses throughout the world. He also testifies that he is personally familiar with three other PEMB projects that used the same specification and states that the contractors on those projects did not encounter the same foundation issues as Direct Steel. In his experience, contractors account for the labor and material cost of potential foundation revisions by allocating a contingency for this expense in their bids. (Gov’t br., ex. B (aff. of C. Krause) ¶¶ 9-18)

8. A reasonably prudent contractor that decided to interpret Note (C)13 of Drawing S-002 as Direct Steel did would have recognized that the government could well interpret the language as requiring the contractor to absorb all costs, including construction costs, resulting from revisions to the foundation. Direct Steel did not seek clarification from USACE.

9. After contract award, Direct Steel selected a PEMB supplier and retained an engineer to assess whether the foundation set forth in the Contract would be adequate (JSF ¶¶ 80, 83). The engineer determined that the Contract-specified foundation

3 would require revisions to accommodate the PEMB Direct Steel had selected. The engineer concluded, and the government agrees, that the government’s foundation design was insufficient to support the selected PEMB and had to be re-designed to add additional concrete for larger footings and additional reinforcing. (JSF ¶ 84; app. br., ex. B (aff. of C. Reising) ¶¶ 11-12)

10. Specifically, as Direct Steel informed USACE, “at the main building, additional reinforcing/cages were added at the PEMB columns. Also, at the three covered storage areas, the spread footings were changed from 8’ square to 12’ square (6 each building, 18 total). Both of these revisions were necessitated by inadequate uplift (-33k in design, -40k required, a 21% increase)” (R4, tab 11 at 2193). According to Direct Steel, “[t]he design loads reflected on [Drawings] S-001 and S-610 are not consistent with the foundation design per S-111- S-113.” (R4, tab 13 at 2197)

11. Direct Steel paid for the preparation of the necessary revisions to the foundation design and the government approved them. (JSF ¶ 94; R4, tab 11 at 2193)

12. Direct Steel requested a modification to the Contract to increase the price to account for the additional costs of constructing the foundation made necessary by the revisions to the foundation design (JSF ¶¶ 86, 88, 91-92). The government declined to issue such a modification (JSF ¶ 88). Direct Steel successfully constructed the revised foundation and the PEMB (first R. Swierk aff. ¶ 19).

13. Direct Steel submitted a claim to the contracting officer seeking an equitable adjustment to the contract price to cover the additional costs of constructing the revised foundation. Direct Steel did not seek to be compensated for the cost of revising the foundation design. The contracting officer did not decide the claim and Direct Steel appealed the “deemed denial” of the claim to the Board. (JSF ¶¶ 95-98; R4, tab 13)

III. Facts Relating to the Framing Claim (No. 63839)

14. While Direct Steel was in the process of installing the interior framing of the PEMB, USACE alleged that Direct Steel’s framing installation did not conform to the Contract requirements in three respects:

Free access — add to your briefcase to read the full text and ask questions with AI

Related

General Electric Co. v. Joiner
522 U.S. 136 (Supreme Court, 1997)
States Roofing Corporation v. Winter
587 F.3d 1364 (Federal Circuit, 2009)
Teg-Paradigm Environmental, Inc. v. United States
465 F.3d 1329 (Federal Circuit, 2006)
Centex Corp. v. United States
395 F.3d 1283 (Federal Circuit, 2005)
Hercules Incorporated v. United States
292 F.3d 1378 (Federal Circuit, 2002)
Nvt Technologies, Inc. v. United States
370 F.3d 1153 (Federal Circuit, 2004)
Metcalf Construction Company v. United States
742 F.3d 984 (Federal Circuit, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Direct Steel, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/direct-steel-llc-asbca-2024.