SEECO Consultants Inc.

Client:

Hunter Corporation/CNA Insurance Company

Scope Of Work

Mr. Collin W. Gray, S.E., P.E., a registered Professional/Structural Geotechnical Engineer licensed in Indiana with over 48 years of experience and Principal of SEECO performed a Liquefaction Failure Analysis Study at the Bailly Town Generating Station, Porter County, Indiana after two 14?foot circulating water pipes, intake and outfall structures, collapsed during construction and steel sheet pile driving at the plant.  He was an expert witness in this case and also gave his deposition.

The site is on the Lake Michigan shoreline near the Indiana Dunes National Lakeshore Park.  Liquefaction of the saturated loose sand fill overlying the circulating water pipes occurred during a sheet pile driving operation by Thatcher Engineering Company, a subcontractor to Hunter Corporation.  SEECO Consultants, Inc. and Mr. Gray were retained to perform a Forensic Engineering Study and act as the expert witness for CNA Insurance Company who insured Hunter Corporation on this project.  The Northern Indiana Public Service Company had a $100 million property damage and loss of income policy with Hartford Insurance Company.  Hartford Insurance Company paid NIPSCO $56 million in damages since the power plant was out of operation for approximately six months.  This included new construction of the circulating water pipes as well as loss of revenue.  The Hartford Insurance Company sued all of the contractors and engineers working on the site at the time of the failure.  The site investigation identified soils to consist of loose saturated dune sand fill material.  Based on the Forensic Engineering Study and the testimony and opinion of Mr. Gray and others and the facts related to the geotechnical specifications on historical documents, the courts found in favor of Hunter Corporation and its subcontractors.