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Transformer Replacement

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REPORT REGARDING
COST ESTIMATION OF REPLACEMENT TRANSFORMERS

FOR A 2000 AMP 240 VOLT THREE PHASE SERVICE
SUBJECT LOCATION: 3401 WEST PACIFIC AVE., BURBANK, CALIFORNIA
SUBMITTED TO: HAKOP STEPANYAN, ESQ.
DYKEMA GOSSETT PLLC
333 SOUTH GRAND AVENUE, SUITE 2100
LOS ANGELES, CALIFORNIA 90071
213-457-1774 DIRECT
PERTAINING TO: CRAIG HANRIOT, et al.;
Claimants
v.
NASMYTH TMF, INC., et al.;
Respondents

CASE NO.: 01-17-0005-0194
AMERICAN ARBITRATION ASSOCIATION
LOS ANGELES
The Honorable Louise LaMothe
PREPARED BY: JOSEPH PERRY, P.E.
JOSEPH PERRY P.E., LLC
PO BOX 141
PENNGROVE, CA 94951

Report Dated: May 10, 2019

INTRODUCTION:
After a building fire destroyed the electrical system of 3401 West Pacific Avenue the two electrical
services were removed, only one 400 amp, 120/240 volt, single-phase, service was replaced. The
other 2000 amp, 240 volts, three-phase, service was not replaced. The building owner paid a fee of
$8,296.88 to Burbank Water & Power (BWP) to reconnect the existing single transformer to the
single-phase service, provide and test an electric meter, and remove the three existing
transformers for the damaged three phase service.

SCOPE OF INVESTIGATION:
I was tasked with determining what the cost would be to reconnect utility power to the new 2000
amp, 240 volt three-phase service had the owner elected to replace the damaged service.
My investigation consisted of the following tasks:
a. I visited the site on May 2, 2019, and was met by with the building owner Craig Hanriot, I
went onto the roof, looked down into the fenced and secured utility yard that protects the
high voltage (HV) (12,000 volts) wiring and transformer(s) from public access. I took
pictures (Exhibit A) of this area, by the outline stains it was evident that four transformers
had previously been installed on the concrete pad.
b. While onsite I took pictures (Exhibits B & C) through the fenced gate of the single-phase
transformer, HV cable, HV parking stand, and the HV wire going into underground conduit.
c. While onsite I took pictures inside the building of the 400 amp, 120/240 volt, single phase,
service, and three distribution panels for future reference, even though these items are not
currently in question. No exhibit was created.
d. I read the Clients Statement of Claimed Damages.
e. I read the Amended Terms of Reference.
f. I read the BWP produced documents stamped BURBANK000001 through
BURBANK000147.
g. I read the deposition transcript of Riad Sleiman (BWP Responsible Electrical Engineer)
dated May 2, 2019 and examined the deposition’s exhibits 01 through 08.
h. I read the Claimants’ Responses to RESPONDENTS’ SPECIAL INTERROGATORIES,
SET TWO.

Description of Exhibits:

Exhibit A:
Picture from roof into the fenced and secured utility yard.

Exhibit B:
Picture through the fenced gate of the single phase transformer, HV cable, HV parking
stand, and the HV wire going into underground conduit.

Exhibit C:
Picture through the fenced gate of the single phase transformer, HV cable, HV parking
stand, and the HV wire going into underground conduit.

Exhibit D:
Property Owner, Craig Hanriot on Dec 3, 2015 sends an email to Scott Anderson (BWP).

Exhibit E:
BWP Electrical Engineer, Scott Anderson on November 13, 2018 sends an email response
to questions from Damion Robinson.

Exhibit F:
BWP Document RULES AND REGULATIONS GOVERNING ELECTRIC SERVICE, item
2.01 (j)

Exhibit G:
BWP Electrical Engineer, Scott Anderson confirms in an email to his supervisor Riad
Sleiman, that WAM # 1702838-01-04 (400 amp service single phase service) is complete
and that the actual AIC Charges have been itemized.

Exhibit H
BWP Electrical Crew group email discussing the existing high voltage (HV) cable, neutrals,
parking stands and customers future electrical growth.

Exhibit I
BWP production document Nasmyth Burbank Contract Reconciliation Document.

Exhibit J
Claimants Statement of Claimed Damages.

Exhibit K
Claimants Responses to Respondents’ Special Interrogatories, Set Two.

Conclusions and Opinions:
Exhibit D:
Property Owner, Craig Hanriot on Dec 3, 2015 confirms in an email to Scott Anderson
(BWP) that “The various engineers that are working on this project have told me that the
service that has been used at the property is 2000 amps 240 volts 3-phase, 3-wires and the
second is 400amps 120 / 240v. 1-phase, 3-wires. After speaking with all of the people that
needed to decide on this it was agreed that the service and transformers that have been
used in the past will be adequate for the future needs of the operation.”
This statement by Mr. Hanriot confirms to BWP that the three existing transformers
are large enough for future needs.
Opinion 1: There is no need to change the three existing transformers should the
new 2000 amp 240 volt, three phase, service be installed.
Exhibit E: first conclusion
BWP Electrical Engineer, Scott Anderson on November 13, 2018 responds in an email to
Damion Robinson’s questions that “the existing (3) 75 KVA customer station transformers
could handle the new tenants load.”
Opinion 2: BWP Electrical Engineer states the (3) 75 KVA customer station
transformers could handle the new tenants load. Replacement of the three
transformers that would serve the new 2000 amp 240 volt, three phase, service is not
required.
Note: Three existing single transformers (TUBS) together are electrically equivalent
to a 225 KVA pad mount (single enclosure) transformer.
Exhibit E: second conclusion
BWP Electrical Engineer, Scott Anderson on November 13, 2018 responds in an email to
Damion Robinson’s questions that replacing the 2000 amp service with a load schedule
that showed that the existing (3) 75 kVA customer station transformers could handle the
new tenants load would have been for the bussing to be inspected and or replaced by the
customer and the cables from the transformers to the bussing replaced by BWP and new
metering installed. Engineering, line crew and electrical equipment support costs would be
included in this scenario.
Opinion 3: No Primary high voltage cable or conduit would have to be replaced. This
minimizes the cost from BWP to reconnect the EXISTING transformers to the new
2000 amp 240 volt, three phase, service.
Exhibit E: third conclusion
BWP Electrical Engineer, Scott Anderson on November 13, 2018 responds in an email to
Damion Robinson’s questions that no load schedule provided or of a load schedule
provided that required the customer station transformers to be upgraded would have been
for the bussing to be inspected and or replaced by the customer and the cables from the
transformers to the bussing replaced by BWP, the (3) existing transformers removed and
replaced by BWP and new metering installed. Engineering, line crew and electrical
equipment support costs would be included in this scenario.

Opinion 4: Primary high voltage cable or conduit would not have to be replaced. This
minimizes the cost from BWP to reconnect the NEW transformers to the new 2000
amp 240 volt, three phase, service.

Exhibit F: first conclusion
BWP Document RULES AND REGULATIONS GOVERNING ELECTRIC SERVICE, item
2.01 (j) States that these Rules and Regulations are “guidelines” and that “Below 750KW
Load, BWP requires on-site transformation for all new three-phase services above 200A”.
Opinion 5: The Rules and Regulations do not state Pad Mount transformers are
required but that on-site transformation is required.
Opinion 6: Pole mounted transformers with the secondary wires run down the pole
or overhead secondary services are not allowed to be installed for three phase
services in excess of 200 amps.
Opinion 7: On-site transformation can be achieved with three TUBS or three separate
transformers that could be mounted on a pole, but could instead be mounted on a
concrete pad (like the original installation, see exhibit B) or a rectangular -all in oneenclosed pad mounted transformer could be used, either type of transformer
arrangement is allowed by BWP.

Exhibit F: second conclusion
BWP Document RULES AND REGULATIONS GOVERNING ELECTRIC SERVICE, item
2.01 (j) States “750 KW – 3 MW Any service above 750 KW requires a pad mount switch.
BWP requires two pad mount transformers.”
Opinion 8: The proposed 2000 amp rated service with the maximum allowed loading
of 80 % has a full load capacity of 1600 amps, at 240 volts, three phase, is rated at
665 KVA. The load of 665 KVA can be supplied by three 225 KVA TUBS.
Opinion 9: 665 KVA is less than 750 KVA, hence the BWP requirements of this
paragraph do not apply to a new 2000 amp service.

Exhibit G:
BWP Electrical Engineer, Scott Anderson confirms in an email to his supervisor Riad
Sleiman, that WAM # 1702838-01-04 (400 amp service single phase service) is complete
regarding the disconnect and reconnect of power and customer station work at 3401
Pacific. WAM Tasks
01, 02, 03, &. 04 have been set to “finished”.
The (Actual AIC) charges are as follows:
Details
Engineering $ 667.77
L &E Labor $ 5,966.57
Materials $ 457.60
Metering $ 530.00
Test Shop Labor $ 545.82
Equipment $ 129.12
Total $ 8,296.88

Opinion 10: The above actual BWP Aid In Construction (AIC) charges were for a
single phase transformer installation. A generous estimate of the actual BWP Aid In
Construction (AIC) charges for a three phase installation would be three times higher
for the three transformers to serve the new 2000 amp 240 volt, three phase, service
then one transformer serving a single phase service.
The BWP AIC cost would then be estimated at 3 x $8,296.88 = $24,890.64.

Exhibit H
BWP Electrical Crew group email discussing the existing high voltage (HV) cable, neutrals,
parking stands and future growth.
“I have a feeling that the new owner might request a 3-phase service sometime in the
future. Is there any way to keep what’s there and facilitate the addition of a three-phase
service in the future? can leave the three ways completely intact for future growth. as long
as Electric shop leaves the parking stands as is everything is fine,
All of the neutrals are tied together. When they are ready I’ll just energize A-Phase”

Opinion 11: The building owner, Craig Hanriot had already notified BWP that he had
decided NOT to install the new 2000 amp 240 volt, three phase, service. The email
demonstrates that the Electrical Crew Group that contributed to this email were in
agreement that the existing HV facilities could be left in place for a future three phase
service.

Opinion 12: There was no requirement to remove the electrical distribution
infrastructure at the time of connecting the 400 amp single phase service. The
electrical distribution infrastructure could be left completely intact, at no additional
cost to the utility or the customer. This is an indication that the TUB type
transformers mounted on the existing pad would still be acceptable to BWP in the
foreseeable future for three phase services.
Exhibit I
BWP production document “Nasmyth Burbank Contract Reconciliation Document”.
Opinion 13: This construction document made the owner aware that by not installing
the new 2000 amp 240 volt, three phase, service that $28,080,00 would be given as a
credit by the construction contractor.
There would be additional savings to the owner by the way of BWP AIC costs
generously estimated in Opinion 10 above, of $24,890.64. The total saving would be
approximately $52,970.64 to the owner by not installing the new 2000 amp, 240 volt,
three phase, service.

Exhibit J
Claimants’ Statement of Claimed Damages.
Page two, line 20, shows the cost to “Replace exterior transformers, engineering,
and installation” is estimated at $391,250.00. Page three has the breakdown of these
costs including overhead and profit by the contractor.

Opinion 14:
For the reasons stated above in Opinion 10, utilizing the existing (3) 75 KVA
transformers, I estimated the total BWP AIC cost to do this work to be $24,890.64.

Exhibit K
Claimants Responses to Respondents’ Special Interrogatories, Set Two.
Opinion 15:
Alternate 1 to opinion 14: A TUB type transformer was allowed and is what was
originally installed at this location. This opinion is supported by my previous
opinions 5, 6, 7, 8, & 9.
Assuming new transformers were installed, sized for the 2000 amp (which has a
maximum allowable load 1600 amps), 240 volt, three phase, new service, this would
require three 225 KVA TUB type transformers. The total installed cost is estimated to
be $61,658.64 for the TUB transformers and BWP AIC costs.
Alternate 2 to opinion 14: No pad mount transformer is required by the BWP Rules
and Regulations for this installation, only on-site transformation is required. The
claimant has made an error in believing that BWPs regulations would require a new
pad mount transformer due to “no load schedule being provided to BPW” for the
new 2000 amp, 240 volt, three phase, service. Assuming an all in one, pad mount
transformer was selected the total installed cost is estimated to be $77,073.30 an
increase of about 25%.

Joseph Perry Electrical Expert Witness Electrician Contractor EngineerCurriculum Vitae                  June 18, 2013

 

JOSEPH PERRY P.E. JPPE
P.O. Box 141
Penngrove, CA 94951
Mobile: 707‐477‐3862
Email: perryj4@JosephPerryPE.com
Website:http://www.JosephPerryPE.com
Personal Statement

33 years’ experience as a Professional Electrical Engineer and Licensed Electrical Contractor
provides an extensive background in Electrical Power and Controls Engineering. I am seeking Expert
Witness Work relating to losses or damages associated with the Water and Wastewater industry,
Industrial Electrical Controls/Processes. I have many years of construction experience in Municipal
Construction Projects and Interpreting Municipal Plans and Specifications and can provide
testimony as to the Standard of Care Provided by Electrical Engineers and Contractors.
Licenses
Professional Electrical Engineer
Licensed Contractor, Electrical, Plumbing,
HVAC

Skills
-SCADA and Telemetering Control & Design
Variable Frequency Motor Control &
Design
-Reduced Voltage Soft Start Control &
Design
-Flow and Blow‐off Control & Design
-Motor Control Center (MCC) Applications

CA# 9683E & HI# E12924
CA# 402494
Estimating, Project Management
Well, Storage Tank, Pumping Control & Design
Cellular and Radio Communications
Critical Load and Standby Generator Applications
Facility Automation, Programmable Logic Control
Energy Monitoring and Control Applications
Standard of Care, Forensic Analysis
Educational Foundation
Healds Engineering College, San Francisco
BS Electrical Engineering (Power and Control Systems Focus) BSEE May 1974

Current Employment
Independent Consulting Electrical Engineer Control Systems West, Inc.
June 2002 – Current.
My primary design duties are to design Power and Controls for Water and Wastewater Pump
Stations and medium size Wastewater Treatment Plant Control Panels. I am the responsible
Electrical Engineer for all Control Systems West, Inc. CA and HI projects that require an Electrical
Engineer’s design approval and engineering stamp. I am the Contract Administrator for most of the
Control Systems West, Inc. contracts to provide control panels, which are used by municipalities in
California and Hawaii. I am the Primary contact for Underwriters Laboratory (UL) certification of
Industrial Control Panels (UL508A and UL698) that are designed and built at Control Systems West,
Inc.
Reference Contact
Bruce Borders, President
Phone: 707‐763‐1108 x3011 Email: bruce.borders@controlwest.com

Work History
Owner California Energy Experts
June 2001 – June 2002
I was an Independent Engineering Consultant and Electrical Contractor for the City of Cotati
Department of Public Works Water and Wastewater Pump Stations. Also I worked for various
clients performing Electrical Contracting Services. Working with Control Systems West, Inc., with its
established volume of business, offered a superb opportunity to utilize my Engineering Design
talents in the Design of Industrial Control Panels dedicated to the Water and Waste Water Industry.

Investment Broker Edward Jones Investments
June 1998 – June 2001
After Passing the Securities and Exchange Commission Series 7 License, I opened an Edward Jones
Investment office in Rohnert Park, CA. I serviced my clients by selling Stocks, Mutual Funds, Bonds,
Annuities, Life and Long Term Care Insurance. I enjoyed helping my clients establish a safe and
secure financial future. I enjoyed the sales aspect of the business however this business was much
too distant from the finite business of Engineering that I love.

Outside Sales Cal Air, Inc.
April 1997 – May 1998
Outside Sales of Heating Ventilation and Air Conditioning (HVAC) Services, Cal Air purchased my
previous Electrical Engineering; Electrical, HVAC, Plumbing Contracting business, I agreed to stay on
in the sales capacity for one year to expand their presence in the Sonoma County area and provide
continuity with our existing client base. Cal Air was a business consolidator, purchasing contractor
shops in the Energy Management and HVAC industry.

President California Energy Experts, Inc., (CEE)
Nov 1984 – April 1997
We designed and built Facility Automation Systems totaling 7.6 million square feet of municipal,
school, commercial and light industrial building spaces in 15 states. Project makeup was
approximately 36% new & 64% retrofit installations. We Incorporated, programmed, and supported
dedicated technically advanced controllers for HVAC Systems. Our Lighting Control Systems
incorporated Day‐lighting and Time of Day Scheduling. Variable Frequency Drives (VFD) (AFD), were
used on cooling towers, pumps, supply and return fans to enhance the energy efficiency of HVAC
systems. Economizer Damper positioning and monitoring were an integral part of our control
designs which led to further energy reductions. Demand Control routines were incorporated in the
designs when advantages to the customer. All systems included remote communication abilities to
allow offsite monitoring and minor software revisions. We expanded our company’s expertise by
bidding and installing Well, Water, Wastewater, Flood Control, Power and Control Systems.
Designed and built Standby Generator Systems (up to 250KW) including single and multiple transfer
switches and isolation of critical/non‐critical loads, we incorporated Peak Shaving strategies into
the design when applicable. California Energy Experts was expanded by incorporating HVAC and
Plumbing contracting under our umbrella. California Energy Experts was sold to Cal Air, Inc. which
provided me an opportunity to explore Outside Sales without the stress of running the day‐to‐day
business of the Engineering / Contracting business.

Owner Energy Experts
May 1982 – Nov 1984
When Energy Experts was formed my goal was to design and install Control Systems dedicated to
Energy Management in Commercial Buildings; utilizing the most recent computerized
advancements in HVAC and Lighting Controls. I began by selling the concept to businessmen in our
county, then designing and installing the control system. After landing Energy Management System
Design and Installation contracts with a major Department Store chain, Energy Experts quickly grew
and earned the respect of the Facilities Managers for this chain. As the company volume grew
Energy Experts was incorporated and renamed to California Energy Experts, Inc.

Electrical Engineer P.E. RE Corp. Inc., DBA Reliance Enterprises
April 1979 ‐ April 1982
After obtaining Professional Engineer Status I was immediately moved to the office environment. I
soon began estimating Electrical Construction Projects and assisted in Contract Administration and
Purchasing materials that were required to complete the successfully bid projects. Our firm was the
Electrical Engineers for several Waste Water Treatment projects and I was responsible for
specifying the Electrical Devices that were to be used and minor design modifications. As time
progressed I began to design Water and Waste Water controls for many Pump Stations and Wells. I
also earned my Electrical Contractors License during this period. The Engineering & Contracting

foundation established at RE Corp afforded me the knowledge, experience and confidence to start
my own Engineering / Contracting business Energy Experts specializing in Control Systems.

Engineering Trainee EIT RE Corp. Inc., DBA Reliance Enterprises
June 1974 – April 1979
My first position at RE Corp placed me in the field for 5 years, this hands-on experience consisted of
troubleshooting and repairing HVAC Equipment and Control Systems, Fire Alarm Systems,
Communication and Electronic Clock Systems at schools and commercial customers. I was also
trained on the repair of Boiler Controls primarily for the commercial and Industrial business sector.
This practical field experience was a stepping stone to a better understanding of Applied
Engineering designed by others and allowed me the opportunity to learn to be a Practical Design
Engineer not just a Theoretical Engineer.

References
Dave Thomas P.E. Peer / Electrical Engineer specializing in the Water/ Waste Water Industry
Phone: 707‐769‐1410
Email: dthomas@dmtassociates.net
Bruce Borders Owner / Control Systems West Inc.
Phone: 707‐7631108 x 1011
Email: bruce.borders@controlwest.com
Dan Blanquie Insurance Loss Mitigation Trainer / Friend
Phone: 707‐338‐4003
Email: danb@dbclaims.com

Membership in Trade Associations
Institute of Electrical Electronic Engineers, (IEEE), my IEEE # 90393171
Senior Member Status
Forensic Expert Witness Association, (FEWA), San Francisco Chapter
Board of Directors, Membership Chair

Contact Me

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3141 Stevens Creek Blvd; Suite 40259 San Jose , CA 95117

707-477-3862