GSBCA 13244 GRANTED IN PART; GSBCA 13331 DENIED; GSBCA 13534 GRANTED IN PART AS TO ENTITLEMENT: October 24, 1996 GSBCA 13244, 13331, 13534 ENVIRONMENTAL DATA CONSULTANTS, INC., Appellant, v. GENERAL SERVICES ADMINISTRATION, Respondent. Claude R. Simpson, White Plains, NY, counsel for Appellant. Kevin S. Anderson and Sharon J. Chen, Real Property Division, Office of General Counsel, General Services Administration, Washington, DC, counsel for Respondent. Before Board Judges DANIELS (Chairman), DEVINE, and HYATT. DANIELS, Board Judge. The contract at issue here, between Environmental Data Consultants, Inc. (EDC), and the General Services Administration (GSA), was for the replacement of underground fuel oil storage tanks at a federal office building in Brooklyn, New York. In this decision, we consider three claims that arose under this contract. First, GSA demanded a $171,217 credit for work not performed due to contract modifications. Second, the contracting officer terminated the contract for default. Third, EDC sought $918,341.41 from the Government, primarily to cover what the contractor calls "extra costs and materials not covered under the base contract"; the contracting officer denied this claim in its entirety. EDC appealed all three contracting officer decisions. We grant in part the contractor's challenge to the Government's monetary claim (GSBCA 13244); our calculations show that GSA is entitled to a credit which is $20,612.69 less than the agency demanded. We deny the appeal of the default termination (GSBCA 13331); in our view, the agency's action was justified. The parties have presented evidence regarding the contractor's claim which goes only to entitlement. We grant a very small part of this claim (GSBCA 13534). Government's monetary claim (GSBCA 13244) The contract required EDC to excavate soil from the job site, and then to construct a cofferdam -- a structure to keep the walls of the excavation from collapsing -- seventy-nine feet long, thirty-nine feet wide, and eighteen feet deep. The contractor had to install steel sheeting, and brace it, to form the walls of the cofferdam. EDC was then to install three new oil storage tanks within the area enclosed by the cofferdam. Appeal File, Exhibit 1 at 02160-1 to -3, 02200-6, dwgs. 9M1, 9M2. We reject both of EDC's positions which are in opposition to our finding as to the planned size of the cofferdam. EDC first suggests that because a contract drawing shows a "proposed . . . line" for the steel sheeting with which the cofferdam was to be constructed, the size of the cofferdam was not specified. This argument fails to account for the remainder of the instruction: "Locate for tank removal and installation. Probe to determine location of concrete pad under existing tanks -- position sheeting to clear the concrete pad obstruction." Appeal File, Exhibit 1 at dwg. 9M2. Clearly, the line is "proposed" only in the sense that the cofferdam may be placed in an appropriate spot slightly different from the one shown; the size of the cofferdam is not optional, however. That size is mandated by the notation of a scale on the drawing. Id. EDC's second position is that the dimensions on the drawing of "minimum 48'-0"" and "minimum 40'-0"" apply to the cofferdam. This is plainly not true; these dimensions are for the concrete apron slab to be placed at grade, above the installed oil storage tanks. Id. EDC's excavation subcontractor, Soil Solutions, Inc., engaged Maybey Bridge, Inc., to supply materials for the cofferdam construction. Maybey Bridge could not build a cofferdam to the Government's specifications; had it done so, its bracing would have interfered with placement of the tanks. Transcript at 129-31, 157. EDC consequently asked to be allowed to build a smaller cofferdam than specified -- only 50' by 40' by 18'. Roy Feinzig, the engineer who designed the project, and whose firm (Rose, Beaton & Rose) was hired to review shop drawing submittals, approved the modification. Id. at 16, 177-78, 181, 186-87; Supplemental Appeal File, Exhibit 15. Mr. Feinzig recognized that although EDC's alternative design was acceptable, it would result in the contractor's removing less soil (including oil-impacted soil) from the site, and using less sheeting, bracing materials (called "whalers"), and backfill. Transcript at 190, 195. The contract provided that if the contracting officer made changes in the work within the general scope of the contract, a corresponding adjustment to the contract price would be made. Appeal File, Exhibit 1 at 27-28 of GSA form 3506. The contracting officer asked EDC to propose a deduction in the contract price, consequent to the change in the size of the cofferdam. Specifically, she asked EDC to price reductions in (a) the labor and materials needed to build the cofferdam itself; (b) the backfill and compaction required; and (c) the contaminated soil to be removed. Id., Exhibits 11, 21. EDC proposed a deduction only for construction of the cofferdam, and while it gave a figure of $8,000, it did not explain the derivation of this amount. Id., Exhibits 13-14; Transcript at 18-19. The contract also required EDC to remove and dispose of existing pavement on the entire construction site, and later to install new asphalt paving consisting of a five inch thick sub-base course, a 3-1/2 inch asphalt base course, and a 1-1/2 inch asphalt wearing course. Appeal File, Exhibit 1 at dwgs. 9M1, 9M2. The contract includes a soil borings report which shows blacktop and concrete to a depth of one foot below grade. Id. at 02200-3, Appendix D. GSA directed EDC not to remove the concrete at the northeast corner of the site, and to pave over that concrete only an asphalt wearing course. Transcript at 51-52, 91. The contracting officer asked EDC to propose a price for a contract modification relating to these changes as well. Appeal File, Exhibit 21. EDC returned the request unsigned. Transcript at 19. The contracting officer then asked her technical representative, Peter Pavlounis, and the agency's construction quality manager for this project, Heery International, to estimate the fair and reasonable value of the work deducted from the contract. Transcript at 20. Mr. Pavlounis made measurements of the affected areas and otherwise collected relevant information. Id. at 46. He gave his findings to Heery, whose Gregory Ridgely, using a computer program which applies a database of cost estimates by R. S. Means, calculated values for the work. Id. at 55, 326, 330-32; Supplemental Appeal File, Exhibit 24; Respondent's Exhibit A. The amounts established by Mr. Ridgely form the basis for the unilateral change order and subsequent Government claim in the amount of $171,217. Transcript at 20; Appeal File, Exhibit 29; Supplemental File, Exhibit 31. "As a general proposition, the Government is entitled, when it deletes clearly required work from a contract, to impose a deductive change, decreasing the contract price to reflect the reduced cost to perform the work." Plaza Maya Limited Partnership, GSBCA 9086, 91-1 BCA  23,425, at 117,500. The Government has the burden of proving the extent of the downward adjustment in the price. P. J. Dick Inc. v. General Services Administration, GSBCA 11783, 94-3 BCA  27,172, at 135,402. The proper measure of the change is the reasonable cost to the contractor of performing the deleted work. P. J. Dick; Plaza Maya. The facts related above demonstrate that the Government is entitled to a deductive change as a result of the modifications in the size of the cofferdam and the paving requirements. We analyze below the extent of the downward price adjustment consequent to that change with regard to each of the five elements of the Government's claim. (1) Construction of cofferdam. As specified in the contract, the cofferdam was to be 79' by 39' by 18' in size, and thus to require a total of 4248 square feet of steel sheeting. As constructed, the cofferdam was 50' by 40' by 18', and thus needed 3240 square feet of sheeting. The difference between the two figures is 1008 square feet. Mr. Ridgely calculated the cost of installing a square foot of sheeting as $23.81. Transcript at 330- 35; Respondent's Exhibit A at 7, 11-12. At this price, the cost of installing 1008 square feet is $24,000.48. Mr. Ridgely calculated a higher figure of $31,572, principally because he, perhaps following Mr. Pavlounis' advice, believed that the cofferdam as originally designed was to have been twenty, rather than eighteen, feet deep. See Transcript at 56-59; Respondent's Exhibit 35 at 1. We have been unable to find support for this theory, and in its posthearing brief, GSA asserts that the correct figure is eighteen. Respondent's Posthearing Brief at 9, 52. EDC has suggested two different ways of valuing the cost of installing sheeting. One is contained in EDC's proposal for an increase in the contract price resulting from the installation of more sheeting -- a matter that is discussed in the context of GSBCA 13534, the contractor's monetary claim. EDC maintains there that the cost is $35.73 per square foot. Appeal File, Exhibit 13 at 5. This price is based on sheeting of a considerably greater depth than used here, and is therefore not applicable. Id. at 6. EDC also offers a general rejoinder to all the cost figures advanced by Mr. Ridgely: we should use figures contained on a GSA form 184-A completed by the contractor and provided to GSA. This form establishes a payment schedule for the contractor's completion of various items of work; it does not establish the value of any particular item. Transcript at 22, 322. EDC presented no evidence in support of Mr. Chance's assertion that he used figures from the R. S. Means book to compile the numbers on the form; Mr. Chance admitted that he could produce no worksheets in support of this contention. See Transcript at 369-70, 412-13. We accept Mr. Ridgely's per unit prices as to the cofferdam's steel sheeting and other elements of the Government's claim. The sheeting had to be kept in place by whalers. Messrs. Pavlounis and Ridgely determined that the amount of whalers needed was 210 pounds per linear foot of sheeting. Transcript at 58; Respondent's Exhibit A at 7. The reduction in the size of the structure decreased the number of linear feet of sheeting by 56, and thus the amount of whalers by 11,760 pounds or 5.88 tons. Mr. Ridgely calculated that the cost of installing a ton of whalers is $306.78. Respondent's Exhibit A at 11-12. Consequently, $1,803.87 was saved in whaler costs by building the smaller cofferdam. The total amount saved in costs of sheeting and whalers was $25,804.35. (2) Backfill and compaction. The contract required EDC generally to backfill the area excavated for the cofferdam and compact the backfill material. Three feet, three inches of depth at the bottom of the cofferdam, and eight inches near the top, were to be filled with concrete. Appeal File, Exhibit 1 at 02200-8, dwg. 9M4. Only about fourteen of the eighteen feet of depth therefore had to be backfilled with soil. Considering this space alone, the change in the size of the cofferdam reduced the amount of space within that structure by 560 cubic yards. Mr. Ridgely calculated the cost of backfilling the space to be $51.66 per cubic yard. Respondent's Exhibit A at 13-14; Transcript at 336. Multiplying the last two figures by each other, reducing the size of the cofferdam saved $28,929.60 in backfill costs. (3) Removal of contaminated soil. The contract noted that some of the soil to be removed from the job site was expected to be impacted with oil. The document stated, "The Contractor[']s base bid shall include the removal, transportation and proper disposal of 4000 cubic yards of oil-impacted soil (non-hazardous). If less than 4000 cubic yards are impacted then a credit shall be issued for the difference at 80% of the price submitted with the Separate Price Item Schedule." Appeal File, Exhibit 1 at 02200-14, 2 of solicitation amendment 2. EDC provided to GSA manifests which show that EDC's excavation subcontractor, Soil Solutions, Inc., removed 1,944.47 tons of oil- impacted soil and had that material transported to Soil Safe Incorporated in Baltimore, Maryland. Supplemental Appeal File, Exhibits 16, 17. Soil Safe verified to Mr. Pavlounis that the manifests correctly represent the material it received from this site. Transcript at 48-49. EDC maintains that it actually removed 4,008.337 tons of oil-impacted soil. Complaint, GSBCA 13534,  15; Transcript at 462. In support of this position, EDC presented copies of additional manifests which were allegedly from Soil Solutions and testimony that another firm, PJS Construction, removed more oil-impacted soil after EDC discharged Soil Solutions from the job. Supplemental Appeal File, Exhibit 21; Transcript at 396-97. Each of the additional manifests contains Soil Solutions' name and address at the top, the legend "Falsification Or Misrepresentation Of Any Of The Information On This Bill of Lading is A Violation of State Laws And Is Subjected To Appropriate Statutory Or Regulatory Penalties" at the bottom, and is signed by Mr. Chance. Supplemental Appeal File, Exhibit 21. Vincent DeJana, Soil Solutions' vice-president, testified convincingly that each of the additional manifests bearing his company's name "is a phony." It is in a different print, and is completed in a different way, from the real manifests. Transcript at 141-43; see also id. at 132-38, Supplemental Appeal File, Exhibits 16, 17. Mr. Chance admitted that EDC has no manifests from PJS or any other form of documentation that more soil was removed by that firm. Transcript at 449, 462-64, 895. Mr. Pavlounis testified that the successor subcontractor did not remove any contaminated soil. Id. at 121-22. We have no basis for concluding that EDC removed more than 1,944.47 tons of oil-impacted soil from the site. As noted, according to the contract, a credit for the cost of removing less than four thousand cubic yards of impacted soil is to be calculated in accordance with a price submitted with a separate price item schedule. We have been unable to find such a schedule in the contract, and neither party has mentioned one. We have two guides to an appropriate credit, however. Mr. Ridgely, using his computerized model, calculated the total credit as $81,710. Mr. Ridgely assumed in making his calculations that EDC removed 1,944.21 tons of contaminated soil -- 2,055.79 tons less than 4,000. Transcript at 337-38; Respondent's Exhibit A at 15. Thus, his figure is $39.75 per ton. EDC maintains, in its own monetary claim, that it is entitled to additional payment of $870.38 for removing 8.337 tons of contaminated soil in excess of the 4,000 on which the contract price was based. Complaint, GSBCA 13534,  45A. This comes to $104.40 per ton. We do not know how EDC derived its figure, and in any event find Mr. Ridgely's determination to be soundly based. Making a tiny adjustment to Mr. Ridgely's number to account for his minuscule error as to the amount of contaminated soil removed, the appropriate credit to the Government for this item is $81,699.66. (4) Asphalt modification. Mr. Pavlounis measured the area in which EDC was directed to provide only an asphalt wearing course, but no sub-base or asphalt base courses, as 360 square yards. Transcript at 63-66. Mr. Ridgely thought that the contract drawing showed 591 square yards, so he rounded Mr. Pavlounis's number up to 400. Id. at 341-42. The two men agree that the labor rates, person-hours, markups, and adjustments used by Mr. Ridgely are correct. Id. at 68, 341-42. Mr. Ridgely determined that the value of the asphalt work EDC was required by the contract to perform in this area, but which was deleted at GSA's direction, was $23.62 per square yard. Respondent's Exhibit A at 16-17. We apply this figure to the actual measured area, which we find to be more accurate than the area assumed by Mr. Ridgely, and consequently conclude that the appropriate credit to the Government for this item is $8,503.20. (5) Concrete modification. According to Mr. Pavlounis, GSA's direction to EDC not to remove some of the pavement at the job site affected about 250 square yards of concrete. The remainder of the area was occupied by an old oil storage tank, which had to be removed (as, consequently, did the concrete immediately above it). Transcript at 53, 66-67. Mr. Ridgely's calculations show a value for concrete removal as $22.67 per square yard. Id. at 342-44; Respondent's Exhibit A at 18. This amount multiplied by 250 square yards yields a credit to the Government for this item of $5,667.50. The total credit to which GSA is entitled, as a consequence of the reduction in the size of the cofferdam and the deletion of certain pavement work, is the sum of the five items above -- $150,604.31. GSA claimed a credit of $171,217. EDC's appeal of the contracting officer's decision asserting this credit is granted in part, because our determination is $20,612.69 less than the contracting officer's. Termination for default (GSBCA 13331) The contract contained a standard default termination clause, FAR 52.249-10--Default (Fixed-Price Construction) (APR 1984), which provides in relevant part: If the Contractor refuses or fails to prosecute the work or any separable part, with the diligence that will insure its completion within the time specified in this contract including any extension, or fails to complete the work within this time, the Government may, by written notice to the Contractor, terminate the right to proceed with the work (or the separable part of the work) that has been delayed. Appeal File, Exhibit 1 at 38 of GSA form 3506. The clause precludes the Government's exercise of this right if the delay in completing the work arises from unforeseeable causes beyond the control and without the fault or negligence of the contractor, and the contractor timely notifies the contracting officer in writing of the causes of the delay. Id. The contract required the work to be complete not later than 365 days after the contractor received GSA's notice to proceed. Appeal File, Exhibit 1 at 00800-3. EDC received this notice on February 1, 1994. Id., Exhibit 2 at 1. Thus, the job had to be complete by February 1, 1995. On that date, GSA declared that EDC's work was substantially complete. Id., Exhibit 8; Transcript at 489. Mr. Pavlounis explained that this determination was based on a finding that the power plant building was able to get oil through installed pipes from a single, new storage tank. Transcript at 490, 504. According to the contracting officer, GSA has never reconsidered its conclusion that the contract was substantially complete. Id. at 673. At the same time that GSA found the project substantially complete, however, it also told EDC that it would give the contractor a punch list of items which remained to be completed. Transcript at 491, 515. The agency issued a preliminary punch list on February 15 and a final list on May 4. Appeal File, Exhibits 9, 11. Both lists noted incomplete work regarding piping containment chambers and underground piping. Id. The contract required EDC to install a piping containment chamber on top of each of the three oil storage tanks. Appeal File, Exhibit 1 at 15590-9, dwgs. 9M3, 9M4. The chamber allows access to all piping connections for testing. Each chamber has a bolt-down lid which allows the chamber to remain watertight throughout its life. Above the lid is a highway-load rated manhole cover. Transcript at 201-03. Keeping the chamber watertight is extremely important to the proper operation and lifespan of the tanks. The chamber contains an electronic transmitter which sends continuous signals to a control panel inside the power plant, indicating the amount of fuel remaining in the tank and giving alerts as to the amount of water in the tank. The transmitter is not designed to function in a wet environment, and water can damage it. Water can also damage the steel connections inside the chamber; rust and corrosion, over time, can shorten the life of the fittings and cause leaks in the chamber. Water could enter the tank through leaks in the chamber. Transcript at 204-05, 298, 301-04. EDC proposed using piping chambers other than the ones specified in the contract. Transcript at 209; Supplemental Appeal File, Exhibit 1 at 4. Mr. Feinzig, the designer of the project, approved the use of a particular alternative product, provided that the item was installed in accordance with the manufacturer's instructions. Transcript at 209-12, 219; Supplemental Appeal File, Exhibit 1 at 14. In February 1995, Mr. Feinzig visited the site and noticed that the components of the chambers were not installed properly. Transcript at 215-26. GSA included as a punch list item the failure of the chambers to be watertight; the agency required EDC to work with Mr. Feinzig's firm to solve this problem. Appeal File, Exhibits 9, ll; Supplemental Appeal File, Exhibit 7 at 4; Transcript at 517-18. EDC constructed a jerry-built sheet metal enclosure around each chamber, but did not coordinate with the engineering firm or follow the manufacturer's instructions. Supplemental Appeal File, Exhibit 24 at 2; Transcript at 553-54. The other punch list item which was mentioned in the default termination pertained to underground piping. The contract required EDC to "[r]emove underground piping in its entirety" insofar as such piping was connected to three old tanks which were to be removed from the site. Appeal File, Exhibit 1 at dwg. 9M1. EDC's Mr. Chance told GSA officials on February 1, 1995, that this task had not been performed. Transcript at 497. GSA listed it on both punch lists. Appeal File, Exhibits 9, 11. According to Mr. Chance, on May 10, 1995, he cut a hole in the pavement outside the power plant, removed the underground piping through the hole, and patched the pavement. Supplemental Appeal File, Exhibit 21; Transcript at 549-51. He then sent GSA a letter stating that EDC had finished all items on the punch list. Supplemental Appeal File, Exhibit 22. The contracting officer remained unconvinced that the punch list items regarding the piping containment chambers and the underground piping had been completed, however. As to the underground piping, she thought the asphalt patch was too small to cover a hole big enough to allow a man to work within it, and Steven Frasca, the Heery inspector for the project, said he had not observed any removal of pipes. Transcript at 554, 649; Supplemental Appeal File, Exhibit 24 at 2. On June 2, she told EDC that the agency had not accepted these items and warned that if within ten days, the work was not completed and EDC had not provided evidence that it would be able to submit the manifests for oil-impacted soil it contended it had removed from the site, she would have grounds for terminating the contract for default. Supplemental Appeal File, Exhibit 27 at 1-2. (The contract required EDC to provide the manifests as part of a closure report, since oil-impacted soil is considered "regulated soil material." Appeal File, Exhibit 1 at 02200-14 to -15.) Mr. Chance then did some work, which was not approved by Mr. Feinzig's firm or in accordance with manufacturer's instructions, intended to make the piping chambers watertight. Appeal File, Exhibit 17; Transcript at 558-59, 561-65. He also gave more written assurances that the underground piping had been removed. Supplemental Appeal File, Exhibits 27 at 3-4, 28. GSA, Heery, and EDC representatives visited the site on the afternoon of June 15 to assess the state of the work. The piping chambers were dry. Transcript at 816. The reason, however, was not related to any correction of their construction. That morning, Mr. Chance had visited the site alone and emptied liquid from the chambers into a bucket. Although Mr. Chance maintains that he spent the morning helping a lady from his church arrange for construction work to her house, id. at 823, 884-85, we do not believe his testimony. We credit instead the testimony of the fleet manager of the GSA motor pool located next to the site, a disinterested witness who observed Mr. Chance at the site, using a cup to remove the liquid. Id. at 1053-67. This testimony is buttressed by the contemporaneous notes of the fleet manager and Mr. Frasca, the Heery inspector. Appeal File, Exhibits 20, 21. EDC did not call as a witness the woman whom Mr. Chance allegedly helped. On July 5, 1995, the contracting officer issued a decision terminating the contract for default. She based this decision on EDC's failure to complete the punch list items with respect to the piping containment chambers and underground piping, and also on EDC's failure to keep fuel oil tank number one from taking on water and the contractor's failure to provide manifests for the removal and disposition of contaminated soil. Appeal File, Exhibit 25. At hearing, the contracting officer suggested that the fact that Mr. Chance misrepresented that he had removed the underground pipes from the site is an additional reason justifying the default termination. Transcript at 660. A default termination is a drastic sanction which should be imposed only for good grounds and on solid evidence. The Government has the burden of demonstrating that ending a contract in this way is proper. Sierra Tahoe Mfg., Inc. v. General Services Administration, GSBCA 12679, 94-2 BCA  26,771, at 133,157 (citing, among other decisions, Lisbon Contractors, Inc. v. United States, 828 F.2d 759, 763-65 (Fed. Cir. 1987), and J. D. Hedin Construction Co. v. United States, 408 F.2d 424, 431 (Ct. Cl. 1969)). We hold that GSA has met this burden here. EDC maintains that "[i]t is axiomatic that Substantial completion of the work prior to termination will preclude a termination for default." Appellant's Posthearing Brief at 14. Even if this were true, it would not help the contractor in this case, because the contracting officer's statements notwithstanding, we conclude that the project was never substantially complete. "Whether a construction contract is substantially complete is determined by whether the facility in question is occupied and used by the Government for the purposes for which it was intended." Thermodyn Contractors, Inc. v. General Services Administration, GSBCA 12510, 94-3 BCA  27,071, at 134,909 (citing several other decisions). GSA bargained here for a complex of three oil storage tanks, which, with associated piping, would supply a power plant with necessary fuel. The record contains numerous readings of high water during June 1995 in one of the three tanks EDC installed. Appeal File, Exhibits 18-20; Appellant's Exhibit 13. The parties have stipulated that this tank has not been used because it has consistently had a high level of water in it; if the tank were used, water, rather than fuel oil, would be drawn into the heating system. Oil has to be ordered on a more frequent basis than standard to ensure that it is available for the system. Stipulations (Mar. 20, 1996). Thus, GSA has only two-thirds of the storage capacity that it anticipated receiving through this contract. EDC maintains that it is not responsible for this situation. According to Mr. Chance, before EDC connected the power plant's return line pipes to the new tanks, these pipes contained much water. Transcript at 762-63; "Explanation of Water in Tank Claim by GSA" (appellant's filing, Mar. 21, 1996). Mr. Chance says that he asked the contracting officer for authorization to install cut- off valves on the supply and return lines for each tank, and elsewhere, to assist in isolating the source of the water, but the contracting officer denied his request. Transcript at 774-80. Mr. Feinzig, the designer of the project, visited the site for the purpose of appraising the validity of these assertions. He found no water lines of any type or source connected to the fuel lines. He concluded that EDC's theory that water was coming from the power plant's plumbing through the return lines "is not true." Id. at 1071-78. In Mr. Feinzig's judgment, installing cut-off valves, as proposed by EDC, "wouldn't be a cure. It would actually create more problems than it does solve, and it wouldn't address the problem at all." Id. at 1078-80. Mr. Feinzig believed that the only conceivable source of water in the return lines could be water in the tanks themselves. Id. at 1080-82. We found Mr. Feinzig to be a highly knowledgeable and credible witness, and adopt his findings as our own. We reject EDC's attempt to blame GSA for the lack of substantial completion of the project. Even if we had agreed with EDC's defense, however, or otherwise agreed that the project was substantially complete at the time of termination, there would remain good cause for the default termination. EDC's contention as to the effect of substantial completion is overbroad. As the Veterans Administration Board of Contract Appeals explained in a study of this issue, a project can be suitable for its intended purpose, but not complete in the sense of providing the recipient with the benefits of its bargain. R. M. Crum Construction Co., VABCA 2143, et al., 85-2 BCA  18,132, at 91,006-09. "[E]ven after use commences, . . . [w]hen completion of a facility is unduly prolonged, or even when only the correction of punch list items is unduly prolonged, so as to indicate a lack of diligence, or when effective progress of correction action ceases, a termination for default is legally justified, for the correction of punch list items is also a contractual obligation." Two State Construction Co., DOT CAB 78-31, et al., 81-1 BCA  15,149, at 74,938; accord R. M. Crum, 85-2 BCA at 91,009. The record is clear that despite many opportunities over several months, EDC did not complete at least two significant punch list items. It did not install the piping containment chambers in accordance with the terms of the modification agreed to by Mr. Feinzig, on behalf of GSA -- the chambers were not watertight and were not installed in accordance with their manufacturer's instructions. Mr. Chance's attempt to mislead the agency as to the watertightness of the chambers was to no avail. Testimony also established that in March 1996, during the course of an underground survey conducted by EDC's bonding company to determine the extent of remaining work, the Government secured conclusive proof that EDC never removed the underground piping. GSA and Heery employees found that the piping was still in place, and that Mr. Chance's patch over what he alleged was the hole from which he removed the pipes covered only the asphalt wearing course; the concrete below the asphalt remained intact. Transcript at 582-91, 650-53, 900-01; Respondent's Exhibits 14-18. EDC's alleged failure to provide GSA with manifests for all the oil-impacted soil it removed could not serve, however, as a ground for defaulting the contract. It is true that failure to comply with important reporting standards, even when those standards are not related to contract performance, may justify a default termination. Kelso v. Kirk Brothers Mechanical Contractors, Inc., 16 F.3d 1173, 1176 (Fed. Cir. 1994). GSA has not established the importance of the manifests, however. The New York State statutes which the agency says contain requirements pertaining to these documents relate to hazardous waste, whereas the contract identifies oil-impacted soil as non-hazardous; and the state regulations GSA points to relate to permits for activities in state parks. Letter from GSA Counsel to Board (July 30, 1996) and accompanying declaration; Appeal File, Exhibit 1 at 02200-14. Furthermore, the record contains no proof that EDC removed from the site more contaminated soil than is described in the manifests which GSA now has. Indeed, we granted the Government's monetary claim as to the removal of contaminated soil precisely because of this lack of proof. We therefore cannot find that EDC did not provide manifests for soil it removed. GSA suggests that Mr. Chance's misrepresentations as to the removal of the underground piping constitute fraud and form an independent basis for the default termination. In support of this theory, GSA cites two decisions of the Court of Appeals for the Federal Circuit, Joseph Morton Co. v. United States, 757 F.2d 1273 (Fed. Cir. 1985), and Daff v. United States, 78 F.3d 1566 (Fed. Cir. 1996). In Morton, the Court acknowledged that "there is support for the argument that any fraud warrants termination for default as a matter of law," 757 F.2d at 1279, but it did not expressly adopt this proposition or rest the holding on it. Instead, the Court held only that a specific representation by the contractor, which had been the basis of a criminal conviction, was sufficient to justify the Government's default termination. In Daff, the Court did not need to reach the issue because it found that the contracting officer had a separate basis for the termination. We have identified misrepresentations made by Mr. Chance, EDC's owner, as to Soil Solutions' removal of oil-impacted soil, the watertightness of the piping containment chambers, and the removal of underground piping. In light of our conclusion that other, valid reasons support the default termination of the contract, we need not examine whether any of these misrepresentations constitute fraud or analyze whether the law should be extended into an area in which the Court of Appeals has not yet tread. Contractor's monetary claim (GSBCA 13534) EDC claims that GSA owes it $918,341.41 for a myriad of items pertaining to performance of this $989,754 contract. The parties presented evidence as to the contractor's entitlement to be paid for each of these items; they agreed to address the extent of recovery at a later date, when it would encompass only those items for which we have found entitlement. Further proceedings in this case will be very short, since we are able to find for EDC on only one of these items. As to this matter, called "unpaid balance on monitoring wells" and valued by EDC at $4,189, GSA concedes entitlement. Transcript at 914. As to all other items listed by EDC in its complaint, the contractor has not convinced us that it is entitled to any additional compensation. We discuss these below, using the headings employed by the contractor and noting for each the amount sought. All aspects of work required under the contract for which payment has not yet been made ($87,994.14). EDC presented no particular evidence as to this matter. As explained in our discussion of the default termination of the contract, the contractor did not fulfill contractual requirements to provide a third watertight oil storage tank, to install piping containment chambers properly, and to remove underground piping. Thus, all aspects of contractual work have not been completed. Removal and disposal of 8.337 tons of contaminated soil (beyond the requirements of the base contract), including overhead and profit ($870.38). As explained in our discussion of the Government's claim for an adjustment to the contract price consequent to EDC's removing from the site less than four thousand tons of contaminated soil, we are not persuaded that the contractor removed more than the amount of oil-impacted soil shown in the manifests provided to GSA. There is no credible basis for concluding that EDC removed 4,008.337 tons, as the contractor contends it did. Install and repair electric utilities ($54,419.34). The contract warned EDC that underground utility lines were present on the site, and that GSA did not know their exact locations. EDC had the "sole responsibility to notify the appropriate utilities, etc. and to locate and mark the underground lines prior to opening up an excavation." In fulfillment of this responsibility, the contractor had to notify Dig Safe, Inc., and retain a private independent firm specializing in locating and marking the lines. EDC had to protect the lines and relocate, remove, or support them "as necessary or as directed by the Contracting Officer." Appeal File, Exhibit 1 at 02200-3 to -4, 02160-2, dwg. 9M1. Before EDC began its excavation work, GSA reminded the contractor of the need to identify the underground utility lines before digging. Transcript at 1185-86. EDC did not employ Dig Safe or a private independent firm to mark the specific location of underground utility lines; instead, it told GSA that "[w]hen the utilities are uncovered, EDC will look for utilities that may not be shown on any of the drawings." Supplemental Appeal File, Exhibit 13 at 3; see also Transcript at 917-18, 1106-07 (containing general statements by Mr. Chance which are not inconsistent with this conclusion). EDC excavated the area with a backhoe, and in the process, some of the utility lines fell apart. Transcript at 915, 921-23; Appellant's Exhibit 3 at 86. EDC proposed that the contract be modified to provide that the contractor relocate the lines from the area and bring them up to code. Transcript at 925-28, 1187-88; Appellant's Exhibit 3 at 86. EDC priced this work at $54,419.34 and purchased materials to perform it. Transcript at 932-33; Appellant's Exhibits 3 at 97-98, 12 at 14. Because GSA considered the price too high and a design for the relocation lacking, it rejected the proposal and directed EDC simply to repair the damaged lines. Transcript at 929, 933-34, 1189. EDC performed the repair work, the extent of which was enlarged because more lines became damaged while the contractor was excavating for the installation of steel sheeting and was tardy in backfilling the excavation. Id. at 934, 1190-93; Supplemental Appeal File, Exhibit 34. The contract obligated EDC to relocate, remove, or support the utility lines, as necessary or as directed. Thus, performance of this work was encompassed within the contract price. The record demonstrates that EDC's failure to comply with contract requirements for marking utility lines before digging, the contractor's use of large machinery prior to learning the location of the lines, and the contractor's approach to sheeting installation and backfilling all contributed to the need for repair of the lines. EDC has not demonstrated that any action by GSA contributed to the need for repairs or that the work was in addition to contract requirements. Furthermore, because GSA never authorized relocation of the lines, the price EDC quoted for relocation has no relevance to the cost of repairs and any purchases the contractor made in anticipation of receiving such authorization were its own responsibility. Work done beyond the scope of the Contract to provide additional sheeting, materials, supplies, equipment rental, engineering, administration and overhead ($36,441.17). This is the matter, referenced in footnote 2, for which EDC sought an adjustment to the contract price in response to GSA's request for a price decrease resulting from the change in the size of the cofferdam. To ensure that during excavation, soil would not collapse away from underground utility lines, EDC installed approximately thirty-five linear feet of steel sheeting in the area to the east of the cofferdam. (Mr. Chance testified that the sheeting was as long as the width of the cofferdam (forty feet); Soil Solutions' Vincent DeJana, who supervised the installation, estimated the length as thirty to thirty-five feet.) Transcript at 155-56, 398-99, 930-31. EDC maintains that it had to install the sheeting "as a result of differing site conditions." Complaint  45A. The differing site condition asserted is the deteriorated condition of the utility lines. Appellant's Posthearing Brief at 18-19. Neither the location nor the condition of the lines is shown or described in the contract. EDC has provided no evidence that the state of these lines, or the surrounding soil, was unusual or unexpected. Mr. DeJana testified that the sheeting had to be installed as a precautionary measure because the wires were not rerouted. Transcript at 155. As we have found, GSA could not approve rerouting because EDC never completed a plan for such action. We conclude that installation of the sheeting was necessitated not by any differing site conditions, but rather, by EDC's ill-advised approach to dealing with the underground utility lines. Extra concrete demolition due to differing site conditions ($32,000). According to Mr. Chance and EDC, a concrete slab was discovered under the construction site during the course of excavation. The slab, depending on the time Mr. Chance and EDC were describing it, was eight, ten to twelve, or twelve to sixteen inches thick. Supplemental Appeal File, Exhibit 15 at 1; Transcript at 945, 1116. Mr. Chance maintained that the slab was not shown on the drawings, and that concrete is usually only two to four inches thick under asphalt pavement. Transcript at 945, 950- 51. EDC contends that it is entitled to additional payment for removal of the exceptionally thick slab. As the contracting officer noted in response to this contention, the contract directs EDC to remove and dispose of existing pavement, and it shows that the pavement (blacktop and concrete) extends to a depth of one foot below grade. Supplemental Appeal File, Exhibit 34 (referencing Appeal File, Exhibit 1 at 02200-3, Appendix D); see also Appeal File, Exhibit 1 at dwg. 9M1; Supplemental Appeal File, Exhibit 37 at 3. In removing the thick concrete slab, EDC was doing nothing more than the contract required. EDC also maintains that it is due an additional payment for removing concrete pile caps -- blocks which were driven into the ground to add structural stability and support to buildings -- which it encountered but which were not shown on the contract drawings. Transcript at 956-57. Mr. Pavlounis testified that there were only four or five pile caps on the site, and that EDC's backhoe was able to scoop them up routinely along with ordinary soil. Id. at 1205. EDC has not demonstrated that the removal of the pile caps entailed any additional work. Demolition of concrete for removal of gasoline tank ($7,000). The contract drawings noted that work on two of the underground tanks which had to be removed involved removal of "concrete anchor pads and appurtenances thereto," but that work on the gasoline tank would additionally involve removal of a "platform." Appeal File, Exhibit 1 at dwg. 9M1. When the gasoline tank was uncovered, it was found to be encased in a layer of concrete. Transcript at 1014, 1214. GSA maintains that the surrounding layer was a "platform," as described in the drawing. See id. at 1214. This makes little sense; a "platform" is "a horizontal flat surface usually higher than the adjoining area, as an elevated ledge or shelf used especially for the reception or transfer of materials." Webster's Third New International Dictionary 1735 (1986) (definition 2f). We agree with EDC that the concrete encasing the tank was not described in the contract. EDC has not demonstrated that removing the concrete involved any extra work, however. Mr. Chance testified that the concrete was two and one-half to three feet thick in some places, and that demolishing it required special equipment. Id. at 1014, 1016. More persuasive evidence is to the contrary, however. A construction report prepared contemporaneously, in the normal course of business, by Heery inspector Mr. Frasca notes that the tank had "[m]inimal additional concrete casing." Supplemental Appeal File, Exhibit 18. Mr. Pavlounis, who observed the tank being removed, testified that after only three or four whacks with EDC's backhoe, the casing "broke like an eggshell." Transcript at 1215. Removing the tank in its entirety took just half an hour. Id. Disposal of 12 drums of contaminated soil left by previous contractor ($5,000). Drums which contained oil-impacted soil were near the job site, but outside it, when EDC began its work. Transcript at 1194-95. Mr. Chance alerted GSA to the presence of these objects. Id. at 939; Appellant's Exhibit 4 at 107. GSA gave EDC permission to move the drums, but did not direct the contractor to dispose of them. Transcript at 1195-96. If EDC actually disposed of the drums and their contents, it has presented no evidence, such as a manifest, demonstrating that this soil was in addition to the truckloads of contaminated soil whose removal and disposal has already been noted in our discussion of the Government's monetary claim. Further, because the disposal (if any) was not at GSA's direction, EDC undertook it as a volunteer and is therefore not entitled to compensation for this effort. Gilroy-Sims & Associates, Ltd., GSBCA 9405, 91-1 BCA  23,406, at 117,444. Redesign dewatering system ($14,000). The contract called for provision of "an adequate system to lower and control groundwater in order to permit excavation, construction of structures, and placement of fill materials under dry conditions." Appeal File, Exhibit 1 at 02140-2. The dewatering system originally proposed and installed by EDC did not work properly, so it had to be replaced. Mr. Chance asserted that an unusually heavy contamination of oil in the ground was the reason for the failure of this system. Transcript at 984-89. Mr. Feinzig, on the other hand, concluded that the amount of oil had no effect on the success of the first dewatering system or on the need for a new design. Id. at 230. We give more credence to the testimony of the project's designer. EDC has not established that there was any reason for replacing the original system other than the fact that the system did not work properly. Extra pressure test requested by GSA ($1,000). The contract required EDC to perform three kinds of pressure tests on the tanks and piping: one on each tank (at five pounds per square inch, or psi), one on the piping, isolated from the tanks (at 100 psi); and one on the tanks together with the piping (at 30 psi). Appeal File, Exhibit 1 at dwg. 9M4, 15990-2 to -4. EDC maintains that Mr. Frasca required two different tests on the piping alone -- one at 30 psi, and a second, which necessitated different gauges, at 100 psi. Transcript at 991-93. Messrs. Frasca and Pavlounis agree that EDC was directed to conduct a second test, which was successful, but maintain that the reason was that EDC conducted the first test at the wrong pressure. Id. at 683, 689, 901-02. The record does not contain any credible evidence that the incorrect test was made at Mr. Frasca's direction. There is no proof that a second test had to be made for any reason other than EDC's own negligence in conducting the first test at a lower pressure than required by the contract. Emergency repair to parking lot and smoke stack lights ($5,000). While EDC was performing its work on this contract, lights at the adjoining parking lot and the power plant's smokestack failed. Transcript at 994-98. According to Mr. Chance, EDC's electrical subcontractor did a considerable amount of work to find the cause of this problem, which turned out not to be related to anything EDC had done. Id. at 996-1001. Then, Mr. Chance continued, either GSA's Rashid Mattoo or Heery's Richard Conklin orally directed EDC to repair the lights. Id. at 1125. EDC did not call Mr. Mattoo or Mr. Conklin as a witness, however, so the record contains no corroboration of this alleged direction. Mr. Pavlounis testified that GSA's files contain no authorization for any repair of the lights by EDC. Id. at 1207-08. We conclude that EDC has not met its burden of proving that GSA is liable for whatever repairs the contractor may have made. Extra work in relation to Maybey Bridge ($4,150). EDC maintains that after it discharged its original excavation subcontractor, Soil Solutions, it incurred additional costs in dealing with Maybey Bridge, the company whose products had been installed in the cofferdam under Soil Solutions' supervision. Apparently, EDC believes that GSA should reimburse EDC for these costs because GSA's actions caused EDC to discharge Soil Solutions. Transcript at 1011-13. EDC has not produced convincing evidence as to the cause of its decision to replace Soil Solutions on this job, however. Extra equipment required as a result of changes ordered by GSA -- monitoring probes, warning panel, etc. ($5,000). The oil storage tanks required by the contract were double-walled. Appeal File, Exhibit 1 at 15590-5, dwg. 9M4. A probe had to be placed between the walls of each tank, to detect the presence of a liquid, and the probe had to be connected to a control panel which was capable of registering an alarm. Id. at 15590-13 to -17. Mr. Chance recognized that the contract specifications allowed the provision of either discriminating probes, which can distinguish between water and oil, or non-discriminating probes, which cannot. Transcript at 759. According to Mr. Chance, he originally ordered non-discriminating probes, but Mr. Frasca told him to exchange them for discriminating instruments, and there followed a series of misadventures in which control panel modules and probes were replaced until finally, EDC had in place non-discriminating probes and control panel modules which would function with them. Id. at 761-62, 1018-20. EDC never questioned Mr. Frasca on this matter at the hearing, however; nor did it present any evidence other than Mr. Chance's testimony which would indicate that GSA or its agents were in any way responsible for the misadventures. Mr. Feinzig, on the other hand, testified that in reviewing a contractor submittal, he had explained to EDC that non-discriminating probes were more appropriate for this project, since they were less expensive and an alarm as to any liquid in the space between the tank walls should prompt an investigation of potential problems. Id. at 238-39. We conclude, based on the totality of this evidence, that EDC's replacements of probes and associated equipment were not made at the direction of GSA or its agent. Delay in installation of surface slab caused by GSA ($3,500). This part of the claim is buttressed only by Mr. Chance's vague testimony that concrete could not be poured for the slab below the tanks on the day EDC desired because GSA and Heery representatives left the site early on that day and were consequently unable to inspect the preparations for the pour. Transcript at 1004-08. EDC did not call any witnesses from the concrete subcontractor; nor did it call (or even identify) the GSA and Heery employees who were allegedly involved. EDC did not present any critical path analyses to show the effect of the alleged delay. The appellant has not met its burden on this item. Winter blankets for concrete supplied by Island Concrete ($768); joint sealer material supplied by Island Concrete ($140). Island Concrete was EDC's concrete subcontractor. These items both relate to costs incurred because the concrete was poured in January 1995, rather than in September or October 1994, as EDC had allegedly planned. The weather was colder in January, and additional precautions had to be taken and different materials used because of the difference in temperature. Transcript at 1008-10. EDC has not demonstrated that the delay in pouring the concrete was attributable to any actions of GSA or its agents, however. Extra work required by Island Concrete due to delays caused by GSA ($4,631.40). EDC has not explained what matters this item includes that have not already been addressed in the two preceding paragraphs. Emergency redesign of rigging and hoisting ($15,000). The contract required EDC to engage a professional engineer licensed by New York State, for the purpose of assuming various responsibilities regarding hoisting and rigging needed to remove existing tanks and install new ones. The engineer was to submit a rigging procedure plan to the contracting officer for approval, and also to be present during all of the hoisting and rigging work, to ensure that the rigging operation followed the plan. Appeal File, Exhibit 1 at 02210-1 to -2, dwg. 9M4. In August or September 1994, EDC brought a crane onto the site and used it to remove the old tanks. There is no indication in the record that GSA objected to this work. Transcript at 1033-34. In late September, however, and again on December 6, the contracting officer reminded EDC to have a full-time professional engineer on site during future hoisting and rigging operations. Supplemental Appeal File, Exhibits 26, 43 at 2. And on December 8, Mr. Pavlounis and the contracting officer both told Mr. Chance that because EDC had no hoisting and rigging plan on file with GSA, the contractor would not be permitted to install the new tanks. Transcript at 1211-12. Notwithstanding the warning, on December 9, EDC brought a crane to the site and began to lower a new tank into the excavated area. The contracting officer immediately issued a stop work order because of the lack of a plan and the absence from the site of a professional engineer. Transcript at 715, 1039-41; Supplemental Appeal File, Exhibit 46 at 4-5. EDC was not allowed back onto the site until December 21. Supplemental Appeal File, Exhibit 50 at 2- 3; Transcript at 1046. Mr. Chance maintained in December 1994, and again at hearing, that in March 1994, EDC had filed a hoisting and rigging plan which had been approved by a professional engineer. According to Mr. Chance, he had submitted the plan in March to Joseph Bailey, a GSA engineer who was then the contracting officer's technical representative for this project, and Mr. Bailey had orally approved it. Transcript at 723-24, 1034-38, 1044; Supplemental Appeal File, Exhibit 47. The evidence is to the contrary. Mr. Chance's engineer, Andrew Mireku, gave inconsistent testimony on this matter. On direct examination, he said that he had approved a document which EDC maintains was its March 1994 hoisting and rigging plan. Transcript at 724; Appellant's Exhibit 1 at 15-21. On cross- examination, he said that he approved only the rating of the cable to be used, and not the other parts of the document. Transcript at 730, 734, 736. Mr. Mireku appeared thoroughly confused on the witness stand -- as, for example, in this exchange with Government counsel: Q Do you recall reviewing the contract drawings on this project, Drawings 9M1 to 9M4, that are sitting here next to you? A Yes, I remember them. There is my seal on them, right. Q I don't think so, Mr. Mireku. [The seal is clearly that of Daniel Beaton of Rose, Beaton & Rose.] A No. Oh, okay. Id. at 735-36. Mr. Mireku admitted that he did not inspect the rig and equipment that was to be used for the rigging and hoisting operations on this project, and did not understand that the contract required such an inspection. Id. at 737-38. Furthermore, Mr. Bailey cautioned Mr. Chance by letter on April 1 that EDC had not yet submitted the mandated hoisting and rigging plan. Supplemental Appeal File, Exhibit 3 at 1. This letter adds credibility to Mr. Bailey's testimony that he never received such a plan. Transcript at 1157. We also credit Mr. Bailey's testimony that the document Mr. Chance called a hoisting and rigging plan is so sketchy that it could in no way qualify as a plan fit for approval. Id. at 1158-59. All in all, the record makes clear that EDC was entirely responsible for the problems with hoisting and rigging which occurred in December 1994. Transportation of steel for new bracing ($900). In issuing the stop work order in December 1994, GSA required EDC to stabilize the cofferdam by replacing cross-bracing it had removed to make additional space for the tanks. Supplemental Appeal File, Exhibit 46 at 4. Mr. Chance asserts that he had steel for new bracing trucked to the site, but that because the tanks fit within the cofferdam, EDC did not have to use this material and had to return it to the supplier. Transcript at 1001-03. Why he wanted the steel is unclear, since GSA's order was to put back in place what had been removed, not to provide any new bracing. Id. at 1209-10. Mr. Chance's testimony that GSA directed him to have the steel on site is not convincing; he could not remember whether the direction was written or oral, or which GSA employee gave it. Id. at 1003. There is no reason why the agency should have to pay the transportation costs for this material. Additional administrative costs ($138,000). The only specific allegation made by EDC which appears to fit under this heading is that GSA prescribed confusing arrangements for the submittal of shop drawings. The contract required EDC to submit various shop drawings to the contracting officer or an individual designated by her. Work on items involved could proceed only as approved. Appeal File, Exhibit 1 at 7-8 of GSA form 3506,  01300. When the project began, Joseph Bailey, the contracting officer's representative at the time, told Mr. Chance that if he needed to submit shop drawings immediately, he should send them to GSA; after a contract with Roy Feinzig's firm (Rose, Beaton & Rose) for shop drawing review had been completed, however, the drawings should go to that firm. Transcript at 372, 958-60, 1156-57, 1167-68. The contract with Rose, Beaton & Rose was completed on March 29, 1994, and by EDC's admission, within the next six weeks, the contracting officer on three occasions directed EDC to send its shop drawings to that firm. Supplemental Appeal File, Exhibit 15. Mr. Chance maintains that he was confused as to where to send his submittals, and that because of his confusion, "I was spending 15 times the amount of time on submissions as I would normally spend" and had to make extra payments to at least one supplier. Transcript at 981, 983. Even if EDC had to spend extra time and money in submitting shop drawings, the record does not establish that any GSA action caused this state of affairs. Mr. Feinzig's testimony suggests a more likely reason: Some of EDC's submittals showed a poor understanding of what the project design was intended to accomplish; many extra submittals were necessitated by EDC's changes in suppliers and proposed design; and many submittals were just plain incorrect. Id. at 307, 309-10. Although Mr. Feinzig went out of his way to expedite the work, such as by accepting submittals by facsimile transmission and discussing modifications (sometimes more than one during a day) over the phone, EDC's inability to produce acceptable drawings was a constant problem on the project. Id. at 246-49. Excess costs incurred as a result of canceled deliveries, absence of crucial GSA personnel during normal scheduled work hours, denied access to work site, stop work orders, differing site conditions, etc. ($299,876.10). According to Mr. Chance, work on the project was delayed on December 23, 1994, because Heery inspector Steven Frasca had left the site early that day. EDC's owner testified that he had planned to put gravel around the tanks as backfill that afternoon, but had to refuse delivery of the gravel since the tanks had not yet been inspected. Transcript at 1021-25; Appellant's Exhibit 1 at 62. The record shows, however, that backfill could not have been placed on the site on December 23 for reasons having nothing to do with Mr. Frasca's absence. Some work remained to be performed on the tanks; it was not completed until December 27. Further, EDC did not have on the site on December 23 any of the machinery which was necessary for putting the gravel into the cofferdam. Supplemental Appeal File, Exhibit 51 at 3. In addition to this event, and the other matters discussed above which relate to this particular element of the claim, EDC's presentation of evidence as to this item can be described most kindly as impressionistic. Mr. Chance asserted in his testimony that EDC was improperly barred from the site on numerous occasions, that GSA's failure to perform timely inspections caused many delays in the work, and that differing site conditions resulted in delays. Transcript at 1026, 1029-33, 1144-45. He and EDC presented virtually no specifics in support of these contentions, however. They provided us with almost no dates, documentation, or analyses of impact on the critical path. EDC has failed to carry its burden of proof on this item. Machine and equipment rental ($4,998.09); extra engineering costs ($16,890.44); total other indirect costs ($25,052.40); total overhead and profit ($135,629.60). EDC presented no evidence specific to any of these categories of alleged extra costs. To the extent that GSA is obligated to compensate EDC for any of them, the costs must be encompassed within one of the categories for which we have found entitlement. Interest on unpaid balance as of April 1995 ($15,891.35). Although this item involves interest which had accrued up to April 1995, EDC's claim was not dated until August 29 of that year, and the claim was not received by GSA until September 6. Appeal File, Exhibits 88 at 1, 89 at 1. Interest does not begin to accrue under the Contract Disputes Act until the date on which the contracting officer receives the claim. 41 U.S.C.  611 (1994). This Act thus does not authorize payment of interest which accrued on any item covered by the claim earlier than September 6, 1995. EDC has cited no other authority for the payment of accrued interest on any element of its claim. Decision GSBCA 13244 is GRANTED IN PART. The contract price is reduced by $150,604.31, rather than the larger sum claimed by the Government, as a consequence of the reduction in the size of the cofferdam and the deletion of certain pavement work. GSBCA 13331 is DENIED; the contract was justifiably terminated for default. This opinion concludes the Board's consideration of these two appeals. GSBCA 13534 is GRANTED IN PART AS TO ENTITLEMENT. GSA is obligated to pay EDC for the item which EDC has labeled "unpaid balance on monitoring wells." Within thirty days of the date of this decision, the parties shall jointly submit to the Board a proposed schedule for further proceedings relating to the amount of money GSA owes for this item. _________________________ STEPHEN M. DANIELS Board Judge We concur: _________________________ _________________________ DONALD W. DEVINE CATHERINE B. HYATT Board Judge Board Judge