Chorro Creek Timber Bridge Repair
Appeal Brief
Appeal Letter
Appeal Analysis
PURPOSE: Respond to third appeal of the San Luis Obispo Community College District for repair of Chorro Creek Bridge.
DISCUSSION: During the 1995 winter storms (FEMA-1046-DR-CA), damages occurred to the Chorro Creek Bridge and the underlying embankment. Based on various inspections and technical evaluations, it has been the subgrantee's position that the disaster-related damages are extensive enough to warrant replacement of the existing 50+ year old timber bridge with a new reinforced concrete structure. FEMA review of pre-disaster bridge condition reports (Caltrans) has concluded, however, that some of the damages were present prior to the disaster, such that repairs associated with these damages are not eligible for FEMA assistance. To-date, FEMA has obligated a total of $128,516 (DSRs 94798 and 97362), to restore the pavement on the bridge deck, provide lateral bracing of the pile bents, and to repair the abutment slope protection. The third appeal asserts that the eligible scope of repair does not account for all disaster-related damages. The subgrantee is requesting funding for replacement of the bridge. It is again found that portions of the requested repair work pertain to components of the bridge structure which were damaged prior to the disaster. Considering only the disaster-related damages, it is found that DSRs 94798 and 97362 propose a reasonable scope of work. However, a supplemental DSR should be prepared to fund two additional scope items; pavement removal and concrete placement for utility foundation support. Other requested items, including repair to codes and standards, hazard mitigation items and the cost for the bridge replacement are found to be not eligible.
RECOMMENDED ACTION: Sign letter partially granting this appeal.
Following the severe winter storms and flooding that occurred during the FEMA-1046 winter storm event (February-March 1995), maintenance staff at San Luis Obispo County Community College, also known as Cuesta College District (subgrantee), reported storm-related damages to the Chorro Creek/Hollister Road bridge structure and the underlying embankment. The Hollister Road bridge across Chorro Creek is located at the rear entrance to Cuesta College on Hollister Road in the County of San Luis Obispo. The bridge is a heavy timber structure built during 1941 to 1946. It is approximately 34 feet wide and 120 feet long, with a 24-foot wide, 2-lane asphalt concrete roadway and 5-foot wide wood plank sidewalk on each side of the bridge. Various utilities are supported on the bridge.
A preliminary damage assessment (PDA) was conducted on March 27, 1995, by representatives of the Federal Emergency Management Agency (FEMA), the Governor's Office of Emergency Services (OES), and the subgrantee. It was concluded that an Architectural and Engineering (A&E) study would be necessary to determine the storm-related damages of the bridge. The A&E firm of John Wallace and Associates, in conjunction with Applied Engineering, completed an investigation and provided their recommendations in a May 1995 report. The FEMA inspector prepared DSR 19707 using the information presented in these reports. The recommendation of this DSR was to replace the timber bridge structure with a reinforced concrete structure and provide slope protection for a total cost of $831,027. During review of DSR 19707, the FEMA reviewer noted that "the bridge was not damaged structurally or functionally by the flood," such that repair of the bridge was determined not eligible. The eligible amount of the DSR was reduced to $1,080, limiting the scope to 30 square yards of concrete slope protection. DSR 19707 was subsequently suspended on July 29, 1995, for re-inspection of the bridge.
Re-inspection of the Hollister Road bridge was conducted on August 30, 1995. FEMA obtained the services of an independent contractor (Dr. Lin) to provide technical assistance during the re-inspection. Following the inspection, Dr. Lin prepared a report entitled, "Structural Investigation of Cuesta College Chorro Creek Bridge." Based on this report, the FEMA inspector voided DSR 19707 and replaced it with DSR 94798 for $286,969 to include repair of the cracked asphalt pavement surface and damaged bridge decking, and to provide grouted riprap and shotcrete embankment protection. However, during review, FEMA contended that some of the damages documented in Dr. Lin's report were not disaster-related, but that these damages occurred before the occurrence of storm. The eligible scope of work in DSR 94798 was reduced to include only the work necessary to restore the pavement on the bridge deck and the north and south abutment to their pre-disaster condition, estimated at a cost of $52,631.
First Appeal
The subgrantee's first appeal was transmitted by OES in a letter dated December 11, 1995. The subgrantee believed that the eligible scope did not include all disaster damages, and that replacement of the bridge should be eligible. The subgrantee asserted that lateral supports of the pile bents were recommended by the structural specialists. Upon reviewing the reports of Dr. Lin and John L. Wallace and Associates, the Regional Director agreed that lateral bracing was required as a result of the disaster. Supplemental DSR 97362 was prepared for $75,885, including lateral bracing. However, regarding the subgrantee's request for replacement of the bridge, the Regional Director stated that the total eligible cost for repair of the bridge is $128,516 (DSR 94798 plus DSR 97362), which does not exceed fifty percent of the estimated replacement cost ($620,720). Bridge replacement was found ineligible.
Second Appeal
OES's letter dated November 20, 1996, transmitted the subgrantee's second appeal of DSR 94798 to FEMA. The subgrantee's primary positions were, again, that the eligible repair does not address all disaster damages, and that replacement of the bridge is more cost effective. In response to the second appeal, the Executive Associate Director reviewed the available technical documentation regarding the condition of the bridge prior to the disaster, and again concluded that the documentation supported that portions of the damage were present prior to the disaster, and therefore, ineligible for repair. Regarding the subgrantee's request for replacement of the bridge, the Executive Associate Director again stated that the total eligible cost for repair of the bridge is less than fifty percent of the estimated replacement cost, such that bridge replacement is ineligible. The second appeal was denied.
Third Appeal
OES transmitted the subgrantee's third appeal in a letter dated March 4, 1998. The primary issues of the third appeal are associated with the scope of eligible repair and the denial of the request for bridge replacement. The subgrantee asserts that FEMA did not account for all storm related damages to the bridge, abutments and embankments in their recommended scope of repairs, and that the eligible scope of repair is unrealistic and does not conform to Caltrans standards. In support of their third appeal position, the subgrantee has requested their A&E consultants provide additional documentation regarding the project, further research the recommended repairs, and clarify all storm related damages. Reports of their findings are submitted in support of the appeal. The appeal letter further discusses the importance of the bridge for providing critical access to the college and other traffic, and for its support of several utilities.
DISCUSSION
The subgrantee is requesting FEMA re-evaluate the extent of disaster related damages and thus the eligible scope of repair. The subgrantee contends that the costs associated with accurately repairing all the disaster-related damages are greater than 50% of the estimated replacement cost, such that it would be more cost effective to replace the bridge rather than repair it. A review of the disaster-related damages and eligible scope of repair is provided below.
Disaster-Related Damages
The subgrantee's third appeal asserts that FEMA has disregarded the assessment of disaster-related damages as provided by FEMA's consultant Dr. Lin, and the reports of John Wallace & Associates and Applied Engineering. It is noted, however, that when describing disaster-related damages, these reports clearly identify old damage not related to the disaster. Specifically, Dr. Lin's report states "in general, damages on the deck structure and piles are consistent with those reported on January 12, 1993 by Caltrans." The John Wallace & Associates report includes statements such as "Although some of this damage is known to have existed prior to the recent storms ." and "Significant damage to the structure as a result of age was also noted during the examination." Each of the reports, including Dr. Lin's, goes on to provide recommendations for repair or replacement of the bridge based on the overall post-disaster condition of the bridge, not limiting the repair to only damages resulting from the disaster.
Considering the reference to pre-disaster damages of the bridge, FEMA, since review of the initial DSR, has relied not only on the post-disaster engineering assessments of the bridge, but also on the pre-disaster bridge inspection reports provided by the subgrantee to assess the pre-and post-disaster condition of the bridge. The Caltrans report dated April 5, 1994 (pre-disaster), clearly mentioned that the bridge was in poor condition. This report mentioned that approximately 50% of the timber deck had mdeort recommended replacing the timber deck and investigating the girders for deterioration. Due to the poor condition of the bridge, the bridge had a 10 ton load rating since 1990. The pre-disaster damages specifically identified by John Wallace & Associates included considerable deterioration of the outer ends of the deck material, and failure of numerous supports for the utilities. It was noted that the stringers supporting the utilities were buckling sideways near the midspan, and there was no apparent lateral support for the stringers supporting the utilities at the pile caps.
In response to the third appeal, a technical consultant to FEMA (FEMA consultant), specializing in bridge design, reviewed all the available documentation regarding this project, and found that the disaster-related damages are limited primarily to diagonal cracking of the asphalt wearing surface due to lateral movement of the substructure, erosion of the slopes at the abutments and failure of the existing slope protection, and minor undermining of utility support.
Eligible Scope of Repair
The subgrantee states that the eligible scope of repair is unrealistic and does not adequately repair the post-disaster condition of the bridge. Supplemental reports have been prepared by their A&E consultants providing additional documentation regarding the project and the recommended repairs. OES specifically states that FEMA has clearly overlooked the fact that the bridge has a 10-ton limit and that the recommended 38-tons of bituminous overlay would result in the collapse of the bridge.
Much of the discrepancy regarding the eligible scope of work is associated with the determination of what damages are eligible for repair. The FEMA consultant, upon review of the documentation, concluded that although the bridge is in poor condition and perhaps in need of replacement, this is primarily due to the deterioration it has endured throughout its life, and not the damage it received from the disaster. Pursuant to Title 44 of the Code of Federal Regulations (44 CFR) Section 206.223(a)(1), only disaster-related damages are eligible for assistance. Therefore, considering only the disaster-related damages as identified in the previous section of this analysis, it is found that DSRs 94798 and 97362 propose a reasonable scope of work. However, the FEMA consultant does recommend two additional scope items. These items are discussed below, along with comments regarding other scope item issues raised by the subgrantee.Repair to Bridge Structure
Disaster damages to the bridge itself are limited to diagonal cracking of the asphalt wearing surface. DSR 94798 includes placement of 38-tons of bituminous concrete overlay, but does not include removal of the existing surface material. OES asserts that since the bridge has a 10-ton load limit, placement of the 38-tons of overlay would result in collapse of the bridge. Although the placement of the overlay will increase the total dead load of the bridge, and thus reduce the allowable vehicle load, it is noted that the statement by OES is inaccurate. The 10-ton load limit refers to the maximum load permitted per span. As the bridge has six spans, only approximately 6.3 tons (38-tons/6 spans) would be applied to any single span. However, FEMA does agree that it would be appropriate to remove the existing asphalt surface prior to placing the new overlay material so as to not further restrict the load carrying capability of the bridge. Accordingly, a supplemental DSR will be prepared for pavement removal, consistent with the cost and quantities originally presented on DSR 94798 (FEMA Cost Code 3150, 382 sy, total cost $1,757).
The requested repairs to the timber decking or girders, including pressure washing and associated items, are not eligible scope items as they are not directly associated with repair of disaster damages. These items were noted as "water damaged" by Dr. Lin in his report. Water damage is generally long-term damage from repeated wetting, and cannot be specifically attributed to the disaster. Additionally, the 1994 Caltrans Supplemental Bridge Report identified these damages to the timber decking and called for further inspection of the girders.
Repair to Utility Supports
In general, the utility support system had been identified prior to the disaster as being in poor condition, with many failed supports and stringers buckling sideways at mid-span. Accordingly, repairs associated with these utility support conditions are not eligible. However, the narrative of DSR 94798 did reference some minor storm damage at one location of the utility support foundation, recommending placement of one cubic yard of concrete for repair. Therefore, the supplemental DSR should include a scope item for placement of one cubic yard of concrete (FEMA Cost Code 3210, 1 cy, total cost $530).
Lateral Bracing of Pile Bents
In response to the first appeal, FEMA concurred that lateral bracing was required as a result of the disaster, and included a line item on supplemental DSR 97362 to include this scope of work for a cost of $70,380. The scope of work and associated costs presented on this DSR are considered appropriate for this work. No additional work is eligible.
Repair to Abutments
Slope protection to the bridge abutments is eligible for repair. Although numerous methods of repair have been suggested, it is concluded that the scope of work presented on the DSRs is adequate for repair of the damaged bank sections. Funding for this work should be limited to that currently obligated.
Additionally, the subgrantee requests that the hazard mitigation measures as recommended by Dr. Lin be reconsidered. Although Dr. Lin states that these measures would increase the longevity of the bridge, it is noted that much of the work recommended by Dr. Lin is intended to prevent potential long-term water damage to the bridge deck and abutments. These measures are not specifically related to storm-related damage or repairs, and are, therefore, not eligible for hazard mitigation funding.
Codes and Standards
The subgrantee maintains that it will be necessary to bring the bridge up to current standards during any repair process and that applicable standards include AASHTO Standard Specifications for Highway Bridges as well as all Caltrans standards. In accordance with 44 CFR 206.226(b), to be applicable to a project scope of work, a code or standard must apply to the type of repair or restoration being performed. The documentation provided by the subgrantee indicates that any bridges which are constructed, or replaced, must be designed to these standards. However, no documentation has been provided to support that repairs to a facility must be in conformance with any specific standard. As the eligible scope of work pertains to repair of the facility, rather than new construction, such codes and standards do not apply.
Some of the items which the subgrantee suggests need to be upgraded include adding training walls to the bents, moving the utilities to the interior of the bridge, and upgrading the bridge to carry HS20 truck loads. Although the standards provided to support the need for these items have been determined not to apply to repair efforts, it is also noted that each of these items do not apply to damaged components of the bridge. Upgrades which are required by a particular code or standard must again be related specifically to disaster-related damages.
Repair versus Replacement
The subgrantee again asserts that replacement of the bridge should be found eligible for FEMA assistance. It is their position that if their requested scope of repair is found eligible, that the cost of such repair would exceed 50% of the reanceowever, in accordance with the above analysis, the eligible scope of work for this facility includes the work presented on DSR 94798 ($52,631), DSR 97362 ($75,885), and the additional scope of work recommended in this third appeal analysis (asphalt removal and concrete support repair, $2,287). Therefore, the total eligible funding obligated by FEMA is $130,803, which is only 21% of the estimated replacement cost of $620,720. Accordingly, replacement of the bridge structure is not eligible for FEMA assistance.
Improved Project
Should the subgrantee choose to replace the bridge, the project would be considered an Improved Project. Accordingly, it would be necessary for the subgrantee to apply to OES for an Improved Project in accordance with 44 CFR 206.203(d). Federal funding for improved projects is limited to the Federal share of the approved estimate of eligible costs as presented on the DSRs referenced herein ($130,803).
CONCLUSION
Review of the available documentation concludes that portions of the requested repair work pertain to components of the bridge structure which were damaged prior to the disaster. Considering only the disaster-related damages, it is found that DSRs 94798 and 97362 propose a reasonable scope of work. However, a supplemental DSR will be prepared by the Regional Director to fund two additional scope items; pavement removal and concrete placement for utility foundation support. Other requested scope items, including hazard mitigation items and the cost for the bridge replacement are found to be not eligible. Additionally, the subgrantee has not demonstrated that replacement of the bridge, nor any upgrades to the design of the bridge, are required by any applicable code or standard. Replacement of the bridge would constitute an Improved Project.
Appeal Brief
| Disaster | FEMA-1046-DR |
| Applicant | San Luis Obispo County Community College District |
| Appeal Type | Third |
| PA ID# | 079-91020 |
| PW ID# | 94798,97362 |
| Date Signed | 1998-08-18T04:00:00 |
DISCUSSION: During the 1995 winter storms (FEMA-1046-DR-CA), damages occurred to the Chorro Creek Bridge and the underlying embankment. Based on various inspections and technical evaluations, it has been the subgrantee's position that the disaster-related damages are extensive enough to warrant replacement of the existing 50+ year old timber bridge with a new reinforced concrete structure. FEMA review of pre-disaster bridge condition reports (Caltrans) has concluded, however, that some of the damages were present prior to the disaster, such that repairs associated with these damages are not eligible for FEMA assistance. To-date, FEMA has obligated a total of $128,516 (DSRs 94798 and 97362), to restore the pavement on the bridge deck, provide lateral bracing of the pile bents, and to repair the abutment slope protection. The third appeal asserts that the eligible scope of repair does not account for all disaster-related damages. The subgrantee is requesting funding for replacement of the bridge. It is again found that portions of the requested repair work pertain to components of the bridge structure which were damaged prior to the disaster. Considering only the disaster-related damages, it is found that DSRs 94798 and 97362 propose a reasonable scope of work. However, a supplemental DSR should be prepared to fund two additional scope items; pavement removal and concrete placement for utility foundation support. Other requested items, including repair to codes and standards, hazard mitigation items and the cost for the bridge replacement are found to be not eligible.
RECOMMENDED ACTION: Sign letter partially granting this appeal.
Appeal Letter
August 18, 1998
Mr. Gilbert Najera
Governor's Authorized Representative
Governor's Office of Emergency Services
74 North Pasadena Avenue, West Annex, 3rd Floor
Pasadena, California 91103-3678
Dear Mr. Najera:
This letter is in response to your March 4, 1998, submittal of the San Luis Obispo Community College District's third appeal of Damage Survey Reports (DSRs) 94798 and 97362 prepared for repair of the Chorro Creek Bridge damaged during the FEMA-1046-DR-CA disaster event. The subgrantee's third appeal asserts that the eligible scope of repair does not account for all disaster-related damages, and that the scope is unrealistic and does not conform to Caltrans standards. The subgrantee is requesting funding for replacement of the bridge.
Based on a review of the available documentation, I have concluded that portions of the requested repair work pertain to components of the bridge structure which were damaged prior to the disaster. Considering only the disaster-related damages, it is found that DSRs 94798 and 97362 propose a reasonable scope of work. However, by copy of this letter, I am requesting the Regional Director to prepare a supplemental DSR to fund two additional scope items; pavement removal and concrete placement for utility foundation support. Other requested items, including repair to codes and standards, hazard mitigation items and the cost for the bridge replacement are found to be not eligible. Please refer to the enclosed appeal analysis for further discussion.
Please inform the applicant of my determination, which constitutes the final level of appeal in accordance with 44 CFR 206.206(e).
Sincerely,
/S/
James L. Witt
Director
Enclosure
cc: Martha Z. Whetstone
Regional Director
FEMA Region IX
Mr. Gilbert Najera
Governor's Authorized Representative
Governor's Office of Emergency Services
74 North Pasadena Avenue, West Annex, 3rd Floor
Pasadena, California 91103-3678
Dear Mr. Najera:
This letter is in response to your March 4, 1998, submittal of the San Luis Obispo Community College District's third appeal of Damage Survey Reports (DSRs) 94798 and 97362 prepared for repair of the Chorro Creek Bridge damaged during the FEMA-1046-DR-CA disaster event. The subgrantee's third appeal asserts that the eligible scope of repair does not account for all disaster-related damages, and that the scope is unrealistic and does not conform to Caltrans standards. The subgrantee is requesting funding for replacement of the bridge.
Based on a review of the available documentation, I have concluded that portions of the requested repair work pertain to components of the bridge structure which were damaged prior to the disaster. Considering only the disaster-related damages, it is found that DSRs 94798 and 97362 propose a reasonable scope of work. However, by copy of this letter, I am requesting the Regional Director to prepare a supplemental DSR to fund two additional scope items; pavement removal and concrete placement for utility foundation support. Other requested items, including repair to codes and standards, hazard mitigation items and the cost for the bridge replacement are found to be not eligible. Please refer to the enclosed appeal analysis for further discussion.
Please inform the applicant of my determination, which constitutes the final level of appeal in accordance with 44 CFR 206.206(e).
Sincerely,
/S/
James L. Witt
Director
Enclosure
cc: Martha Z. Whetstone
Regional Director
FEMA Region IX
Appeal Analysis
BACKGROUNDFollowing the severe winter storms and flooding that occurred during the FEMA-1046 winter storm event (February-March 1995), maintenance staff at San Luis Obispo County Community College, also known as Cuesta College District (subgrantee), reported storm-related damages to the Chorro Creek/Hollister Road bridge structure and the underlying embankment. The Hollister Road bridge across Chorro Creek is located at the rear entrance to Cuesta College on Hollister Road in the County of San Luis Obispo. The bridge is a heavy timber structure built during 1941 to 1946. It is approximately 34 feet wide and 120 feet long, with a 24-foot wide, 2-lane asphalt concrete roadway and 5-foot wide wood plank sidewalk on each side of the bridge. Various utilities are supported on the bridge.
A preliminary damage assessment (PDA) was conducted on March 27, 1995, by representatives of the Federal Emergency Management Agency (FEMA), the Governor's Office of Emergency Services (OES), and the subgrantee. It was concluded that an Architectural and Engineering (A&E) study would be necessary to determine the storm-related damages of the bridge. The A&E firm of John Wallace and Associates, in conjunction with Applied Engineering, completed an investigation and provided their recommendations in a May 1995 report. The FEMA inspector prepared DSR 19707 using the information presented in these reports. The recommendation of this DSR was to replace the timber bridge structure with a reinforced concrete structure and provide slope protection for a total cost of $831,027. During review of DSR 19707, the FEMA reviewer noted that "the bridge was not damaged structurally or functionally by the flood," such that repair of the bridge was determined not eligible. The eligible amount of the DSR was reduced to $1,080, limiting the scope to 30 square yards of concrete slope protection. DSR 19707 was subsequently suspended on July 29, 1995, for re-inspection of the bridge.
Re-inspection of the Hollister Road bridge was conducted on August 30, 1995. FEMA obtained the services of an independent contractor (Dr. Lin) to provide technical assistance during the re-inspection. Following the inspection, Dr. Lin prepared a report entitled, "Structural Investigation of Cuesta College Chorro Creek Bridge." Based on this report, the FEMA inspector voided DSR 19707 and replaced it with DSR 94798 for $286,969 to include repair of the cracked asphalt pavement surface and damaged bridge decking, and to provide grouted riprap and shotcrete embankment protection. However, during review, FEMA contended that some of the damages documented in Dr. Lin's report were not disaster-related, but that these damages occurred before the occurrence of storm. The eligible scope of work in DSR 94798 was reduced to include only the work necessary to restore the pavement on the bridge deck and the north and south abutment to their pre-disaster condition, estimated at a cost of $52,631.
First Appeal
The subgrantee's first appeal was transmitted by OES in a letter dated December 11, 1995. The subgrantee believed that the eligible scope did not include all disaster damages, and that replacement of the bridge should be eligible. The subgrantee asserted that lateral supports of the pile bents were recommended by the structural specialists. Upon reviewing the reports of Dr. Lin and John L. Wallace and Associates, the Regional Director agreed that lateral bracing was required as a result of the disaster. Supplemental DSR 97362 was prepared for $75,885, including lateral bracing. However, regarding the subgrantee's request for replacement of the bridge, the Regional Director stated that the total eligible cost for repair of the bridge is $128,516 (DSR 94798 plus DSR 97362), which does not exceed fifty percent of the estimated replacement cost ($620,720). Bridge replacement was found ineligible.
Second Appeal
OES's letter dated November 20, 1996, transmitted the subgrantee's second appeal of DSR 94798 to FEMA. The subgrantee's primary positions were, again, that the eligible repair does not address all disaster damages, and that replacement of the bridge is more cost effective. In response to the second appeal, the Executive Associate Director reviewed the available technical documentation regarding the condition of the bridge prior to the disaster, and again concluded that the documentation supported that portions of the damage were present prior to the disaster, and therefore, ineligible for repair. Regarding the subgrantee's request for replacement of the bridge, the Executive Associate Director again stated that the total eligible cost for repair of the bridge is less than fifty percent of the estimated replacement cost, such that bridge replacement is ineligible. The second appeal was denied.
Third Appeal
OES transmitted the subgrantee's third appeal in a letter dated March 4, 1998. The primary issues of the third appeal are associated with the scope of eligible repair and the denial of the request for bridge replacement. The subgrantee asserts that FEMA did not account for all storm related damages to the bridge, abutments and embankments in their recommended scope of repairs, and that the eligible scope of repair is unrealistic and does not conform to Caltrans standards. In support of their third appeal position, the subgrantee has requested their A&E consultants provide additional documentation regarding the project, further research the recommended repairs, and clarify all storm related damages. Reports of their findings are submitted in support of the appeal. The appeal letter further discusses the importance of the bridge for providing critical access to the college and other traffic, and for its support of several utilities.
DISCUSSION
The subgrantee is requesting FEMA re-evaluate the extent of disaster related damages and thus the eligible scope of repair. The subgrantee contends that the costs associated with accurately repairing all the disaster-related damages are greater than 50% of the estimated replacement cost, such that it would be more cost effective to replace the bridge rather than repair it. A review of the disaster-related damages and eligible scope of repair is provided below.
Disaster-Related Damages
The subgrantee's third appeal asserts that FEMA has disregarded the assessment of disaster-related damages as provided by FEMA's consultant Dr. Lin, and the reports of John Wallace & Associates and Applied Engineering. It is noted, however, that when describing disaster-related damages, these reports clearly identify old damage not related to the disaster. Specifically, Dr. Lin's report states "in general, damages on the deck structure and piles are consistent with those reported on January 12, 1993 by Caltrans." The John Wallace & Associates report includes statements such as "Although some of this damage is known to have existed prior to the recent storms ." and "Significant damage to the structure as a result of age was also noted during the examination." Each of the reports, including Dr. Lin's, goes on to provide recommendations for repair or replacement of the bridge based on the overall post-disaster condition of the bridge, not limiting the repair to only damages resulting from the disaster.
Considering the reference to pre-disaster damages of the bridge, FEMA, since review of the initial DSR, has relied not only on the post-disaster engineering assessments of the bridge, but also on the pre-disaster bridge inspection reports provided by the subgrantee to assess the pre-and post-disaster condition of the bridge. The Caltrans report dated April 5, 1994 (pre-disaster), clearly mentioned that the bridge was in poor condition. This report mentioned that approximately 50% of the timber deck had mdeort recommended replacing the timber deck and investigating the girders for deterioration. Due to the poor condition of the bridge, the bridge had a 10 ton load rating since 1990. The pre-disaster damages specifically identified by John Wallace & Associates included considerable deterioration of the outer ends of the deck material, and failure of numerous supports for the utilities. It was noted that the stringers supporting the utilities were buckling sideways near the midspan, and there was no apparent lateral support for the stringers supporting the utilities at the pile caps.
In response to the third appeal, a technical consultant to FEMA (FEMA consultant), specializing in bridge design, reviewed all the available documentation regarding this project, and found that the disaster-related damages are limited primarily to diagonal cracking of the asphalt wearing surface due to lateral movement of the substructure, erosion of the slopes at the abutments and failure of the existing slope protection, and minor undermining of utility support.
Eligible Scope of Repair
The subgrantee states that the eligible scope of repair is unrealistic and does not adequately repair the post-disaster condition of the bridge. Supplemental reports have been prepared by their A&E consultants providing additional documentation regarding the project and the recommended repairs. OES specifically states that FEMA has clearly overlooked the fact that the bridge has a 10-ton limit and that the recommended 38-tons of bituminous overlay would result in the collapse of the bridge.
Much of the discrepancy regarding the eligible scope of work is associated with the determination of what damages are eligible for repair. The FEMA consultant, upon review of the documentation, concluded that although the bridge is in poor condition and perhaps in need of replacement, this is primarily due to the deterioration it has endured throughout its life, and not the damage it received from the disaster. Pursuant to Title 44 of the Code of Federal Regulations (44 CFR) Section 206.223(a)(1), only disaster-related damages are eligible for assistance. Therefore, considering only the disaster-related damages as identified in the previous section of this analysis, it is found that DSRs 94798 and 97362 propose a reasonable scope of work. However, the FEMA consultant does recommend two additional scope items. These items are discussed below, along with comments regarding other scope item issues raised by the subgrantee.
Disaster damages to the bridge itself are limited to diagonal cracking of the asphalt wearing surface. DSR 94798 includes placement of 38-tons of bituminous concrete overlay, but does not include removal of the existing surface material. OES asserts that since the bridge has a 10-ton load limit, placement of the 38-tons of overlay would result in collapse of the bridge. Although the placement of the overlay will increase the total dead load of the bridge, and thus reduce the allowable vehicle load, it is noted that the statement by OES is inaccurate. The 10-ton load limit refers to the maximum load permitted per span. As the bridge has six spans, only approximately 6.3 tons (38-tons/6 spans) would be applied to any single span. However, FEMA does agree that it would be appropriate to remove the existing asphalt surface prior to placing the new overlay material so as to not further restrict the load carrying capability of the bridge. Accordingly, a supplemental DSR will be prepared for pavement removal, consistent with the cost and quantities originally presented on DSR 94798 (FEMA Cost Code 3150, 382 sy, total cost $1,757).
The requested repairs to the timber decking or girders, including pressure washing and associated items, are not eligible scope items as they are not directly associated with repair of disaster damages. These items were noted as "water damaged" by Dr. Lin in his report. Water damage is generally long-term damage from repeated wetting, and cannot be specifically attributed to the disaster. Additionally, the 1994 Caltrans Supplemental Bridge Report identified these damages to the timber decking and called for further inspection of the girders.
Repair to Utility Supports
In general, the utility support system had been identified prior to the disaster as being in poor condition, with many failed supports and stringers buckling sideways at mid-span. Accordingly, repairs associated with these utility support conditions are not eligible. However, the narrative of DSR 94798 did reference some minor storm damage at one location of the utility support foundation, recommending placement of one cubic yard of concrete for repair. Therefore, the supplemental DSR should include a scope item for placement of one cubic yard of concrete (FEMA Cost Code 3210, 1 cy, total cost $530).
Lateral Bracing of Pile Bents
In response to the first appeal, FEMA concurred that lateral bracing was required as a result of the disaster, and included a line item on supplemental DSR 97362 to include this scope of work for a cost of $70,380. The scope of work and associated costs presented on this DSR are considered appropriate for this work. No additional work is eligible.
Repair to Abutments
Slope protection to the bridge abutments is eligible for repair. Although numerous methods of repair have been suggested, it is concluded that the scope of work presented on the DSRs is adequate for repair of the damaged bank sections. Funding for this work should be limited to that currently obligated.
Additionally, the subgrantee requests that the hazard mitigation measures as recommended by Dr. Lin be reconsidered. Although Dr. Lin states that these measures would increase the longevity of the bridge, it is noted that much of the work recommended by Dr. Lin is intended to prevent potential long-term water damage to the bridge deck and abutments. These measures are not specifically related to storm-related damage or repairs, and are, therefore, not eligible for hazard mitigation funding.
Codes and Standards
The subgrantee maintains that it will be necessary to bring the bridge up to current standards during any repair process and that applicable standards include AASHTO Standard Specifications for Highway Bridges as well as all Caltrans standards. In accordance with 44 CFR 206.226(b), to be applicable to a project scope of work, a code or standard must apply to the type of repair or restoration being performed. The documentation provided by the subgrantee indicates that any bridges which are constructed, or replaced, must be designed to these standards. However, no documentation has been provided to support that repairs to a facility must be in conformance with any specific standard. As the eligible scope of work pertains to repair of the facility, rather than new construction, such codes and standards do not apply.
Some of the items which the subgrantee suggests need to be upgraded include adding training walls to the bents, moving the utilities to the interior of the bridge, and upgrading the bridge to carry HS20 truck loads. Although the standards provided to support the need for these items have been determined not to apply to repair efforts, it is also noted that each of these items do not apply to damaged components of the bridge. Upgrades which are required by a particular code or standard must again be related specifically to disaster-related damages.
Repair versus Replacement
The subgrantee again asserts that replacement of the bridge should be found eligible for FEMA assistance. It is their position that if their requested scope of repair is found eligible, that the cost of such repair would exceed 50% of the reanceowever, in accordance with the above analysis, the eligible scope of work for this facility includes the work presented on DSR 94798 ($52,631), DSR 97362 ($75,885), and the additional scope of work recommended in this third appeal analysis (asphalt removal and concrete support repair, $2,287). Therefore, the total eligible funding obligated by FEMA is $130,803, which is only 21% of the estimated replacement cost of $620,720. Accordingly, replacement of the bridge structure is not eligible for FEMA assistance.
Improved Project
Should the subgrantee choose to replace the bridge, the project would be considered an Improved Project. Accordingly, it would be necessary for the subgrantee to apply to OES for an Improved Project in accordance with 44 CFR 206.203(d). Federal funding for improved projects is limited to the Federal share of the approved estimate of eligible costs as presented on the DSRs referenced herein ($130,803).
CONCLUSION
Review of the available documentation concludes that portions of the requested repair work pertain to components of the bridge structure which were damaged prior to the disaster. Considering only the disaster-related damages, it is found that DSRs 94798 and 97362 propose a reasonable scope of work. However, a supplemental DSR will be prepared by the Regional Director to fund two additional scope items; pavement removal and concrete placement for utility foundation support. Other requested scope items, including hazard mitigation items and the cost for the bridge replacement are found to be not eligible. Additionally, the subgrantee has not demonstrated that replacement of the bridge, nor any upgrades to the design of the bridge, are required by any applicable code or standard. Replacement of the bridge would constitute an Improved Project.
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