__________________________
                       DENIED:  November 22, 1995
                       __________________________
                              GSBCA 12741
                POWER CONTRACTING AND ENGINEERING CORP.,
                                           Appellant,
                                   v.
                    GENERAL SERVICES ADMINISTRATION,
                                           Respondent.
        Paul Hansfield of Fuchs & Roselli, Chicago, IL, counsel  for
   Appellant.
        Gerald  L. Schrader,  Office  of  General  Counsel,  General
   Services Administration, Washington, DC, counsel for Respondent.
   Before Board Judges DANIELS (Chairman), VERGILIO, and DeGRAFF.
   DeGRAFF, Board Judge.
        The  General   Services  Administration   (GSA)  and   Power
   Contracting  and Engineering Corp. (PCEC) entered into a contract
   for the  renovation of a  building.  A dispute  developed between
   the parties concerning fireproofing material, and PCEC  requested
   that  GSA  adjust  the  contract  price.   GSA  decided  that  no
   adjustment was warranted, and this  appeal followed.  We deny the
   appeal, for the reasons set forth below.
                            Findings of Fact
        Part of  each floor deck  of the Everett M.  Dirksen Federal
   Building in  Chicago, Illinois is  divided by steel beams  into a
   grid containing  7' x  28' sections.   The structural  framing of
   each  of these  sections consists  of a  metal deck  covered with
   concrete.   Exhibit 91.   The metal  deck is made  up of  rows of
   hollow cells which  are used as passageways for  wires and cables
   for electrical, telephone, and other systems.  Penetrations exist
   in  the cells of the deck and  the concrete so that the wires and
   cables  can run  up out of  the cells  to where they  are needed.
   Exhibit 90.  A lined penetration is called an insert.  An unlined
   penetration is a hole.  Usually, a  fitting can be attached to an
   insert  either to complete an electrical  device, for example, or
   to serve as  a cap to close  the penetration.  A  "classified" or
   "rated" insert  is  one  which has  been  rated  by  Underwriters
   Laboratories (UL)  for fire  resistance and  which has  a fitting
   attached.   An unclassified insert  is any other type  of insert.
   Inserts can  be either preset, which  means they are made  at the
   time the deck  is constructed, or afterset, which  means they are
   made after the deck is constructed and the concrete  is poured on
   top of the deck.  Complaint, Attachment 3.  The Dirksen  Building
   is  thirty  years  old  and  has been  altered  many  times,  and
   penetrations in the deck  are normal and to be expected.  Exhibit
   87.
        On January 28, 1991, GSA issued  solicitation GS-05P-91-GBC-
   0048  for the  second  phase  of the  renovation  of the  Dirksen
   Building.  Exhibit 1.  According to the technical specifications,
   the   second  phase  contractor   would  be  required   to  spray
   fireproofing material onto  the underside of  the floor decks  in
   whatever  thickness  was   needed  to   achieve  specified   fire
   resistance  ratings.  The solicitation required the contractor to
   provide a letter  from UL stating  UL's recommended thickness  of
   the  contractor's   fireproofing  material.     The  solicitation
   provides,  "Only letters  provided  by Underwriters  Laboratories
   referencing this project are acceptable."  Exhibit 1 at  1504-05,
   1511.  Most  of the work required  by the solicitation was  to be
   performed   on   the  second,   third,  fourth,   fifth,  eighth,
   fourteenth, fifteenth, and sixteenth  floors, although some  work
   was required on  several other floors as well.  Exhibit 1 at 115.
        The thickness of  fireproofing material needed to  achieve a
   particular  fire resistance rating  is affected  by the  types of
   penetrations  found in a floor deck.   Exhibit 1 at 1705; Exhibit
   18.  The  thickness of fireproofing within a grid  section has to
   be  uniform.  The  presence of a single  unclassified insert in a
   grid  section requires either  applying the maximum  thickness of
   fireproofing  material over the  entire section, or  installing a
   classified  insert and applying a thinner coating of fireproofing
   material.  Exhibits 87, 88, 91.
        The solicitation contains many  requirements in addition  to
   those for sprayed-on  fireproofing material.  The  contractor was
   to perform  demolition, asbestos  removal, plumbing,  electrical,
   mechanical, and construction work.  The technical  specifications
   provide that the contractor  would be required to  coordinate the
   work of different subcontractors.  Exhibit 1.
        L.B.  Hall  Enterprises,  Inc. (Hall)  was  the fireproofing
   subcontractor  for  the  first  phase  of  the  Dirksen  Building
   renovation.   Hall  applied sprayed-on  fireproofing material  to
   decks on two floors of the building.  Exhibit 90.  The contractor
   who performed  the first phase of the Dirksen Building renovation
   installed  rated inserts  into holes  found in  the decks,  which
   meant that Hall was  able to apply a thinner coat of fireproofing
   material than  would have  been required if  no inserts  had been
   installed.  Exhibit 87.
        On April 15, 1991,  Hall submitted a bid to  PCEC to provide
   sprayed-on  fireproofing  material   manufactured  by  Structural
   Coatings, Inc.  (SCI) for  the  second phase  of the  renovation.
   Exhibit 77.  When Hall submitted its bid to PCEC, GSA had not yet
   awarded a contract.  Accordingly, no demolition had begun and the
   floors were covered with carpet,  which meant that Hall could not
   inspect the decks  to determine where penetrations  were located.
   Exhibits 88, 89.
        On May 6,  1991, UL wrote to a product manager at W.R. Grace
   &  Company  (Grace).    Grace  is  a manufacturer  of  sprayed-on
   fireproofing   material.    In   its  letter,  UL   made  certain
   assumptions about the construction  of the floor deck units,  and
   provided Grace  with an opinion  concerning the work  required to
   achieve the fire ratings specified  in the solicitation.  In UL's
   opinion,  the   thickness  of  Grace's   sprayed-on  fireproofing
   material would depend upon the  type of penetrations in the deck.
   Sections  with  unclassified penetrations  would  require thicker
   material  than areas  with classified  penetrations.   On May  7,
   1991,  the  Grace  product manager  wrote  to  Grace's sprayed-on
   fireproofing specialist in the Chicago area.  The product manager
   concluded that, in order to  provide the fire rating specified in
   the   solicitation,   the   greatest  thickness   of   sprayed-on
   fireproofing material mentioned in  UL's letter would have  to be
   applied to the  project's decks.  These letters  were provided to
   GSA by Grace.  Exhibits 72, 73.
        Amendment 7 to the solicitation, which was issued on May 15,
   1991,  provides information concerning existing conditions at the
   Dirksen Building.   Among  the existing conditions  is this:   "A
   combination  of  unclassified  electrical  insert  [sic]  and  UL
   Classified Walker Type 446X afterset  inserts."  Amendment 7 also
   states that UL had  determined that the required  fire resistance
   ratings  could be achieved  by applying different  thicknesses of
   fireproofing  material  depending  upon whether  a  grid  section
   contained  no  inserts,   classified  inserts,  or   unclassified
   inserts.   The information concerning the thicknesses of material
   was  taken  directly from  UL's  May  6,  1991 letter  to  Grace.
   Exhibit  1 at 1705;  Exhibit 72.   No drawings were  available to
   show  the  location  of the  inserts  described  in  Amendment 7.
   Exhibit 90.
        Hall assumed that the inserts mentioned in Amendment  7 were
   shown on the  solicitation's telephone  and electrical  drawings,
   and that additional openings or  holes would be filled by someone
   other than Hall.  Hall also assumed that approximately two-thirds
   of each  floor had no  inserts and  that one-third of  each floor
   would require  an additional thickness  of fireproofing material,
   due to the presence of inserts.   Exhibits 24, 51.  Hall  planned
   to apply 3/4 inch of fireproofing in areas with no inserts.  Hall
   made  some unspecified  allowance for  applying  13/16 inches  of
   material to cover areas with classified inserts.  Exhibit 90.
        GSA awarded the second phase renovation fixed price contract
   to PCEC on June  19, 1991.  Exhibit 2.   GSA also entered into  a
   contract with  Lohan  Associates, Inc.  (Lohan) to  serve as  the
   architect-engineer  for  the  contract.   Lohan  was  supposed to
   observe  PCEC's work  and  to  advise GSA  whether  PCEC and  its
   subcontractors  were complying with  the contract; to  respond to
   questions from PCEC and its subcontractors which could readily be
   answered  by referring  to  contract  requirements,  but  not  to
   interpret  the   contract;  to   make   recommendations  to   the
   contracting officer concerning change orders and time extensions;
   and to review PCEC's submittals.  Complaint, Attachment 1.
        On August 13,  1991, Hall entered into a  contract with PCEC
   to apply  sprayed-on fireproofing  on six  entire floors  (third,
   fourth, fifth,  fourteenth, fifteenth, and sixteenth  floors) and
   parts of eight  other floors.   Exhibits 49, 51.   On August  20,
   1991, Hall sent PCEC a letter proposing to install SCI's SprayDon
   Standard JN Mineral Fiber  sprayed-on fireproofing material,  and
   to  apply that  material in  accordance  with the  manufacturer's
   recommendations and  in a thickness  of 3/4-inch under  the floor
   deck.  Exhibit 83.
        On August  23, 1991,  PCEC notified  Lohan  that there  were
   numerous holes in the concrete  floor extending into the cellular
   deck,  and that  these holes  did  not have  outlets or  afterset
   inserts and  could not be  capped.  PCEC  asked Lohan what  to do
   about these holes.  On September 13,  1991, PCEC told Lohan that,
   on  the third  and fourth  floors, there  were  sixty-seven holes
   without inserts  and sixty-two "holes  with parts missing."   The
   record  is  unclear  as  to what  constitutes  "holes  with parts
   missing."  On December 16, 1991, Lohan recommended to GSA that it
   adjust the contract price and direct PCEC to provide the required
   electrical  component  materials  to  seal  the  cellular  floor.
   Exhibit 75.
        In  January 1992, the  parties signed CE5002,  in which they
   agreed to a contract modification addressing several items.  Item
   5  adds work  which  is  described as,  "Provide  metal caps  and
   inserts for floor duct system.  Unforseen conditions only."  Item
   5 lists  the quantities as sixty-seven holes  without inserts and
   sixty-two  holes  with  parts missing  on  the  third  and fourth
   floors.  Exhibit 62.
        Over a period of several  months, UL provided letters to SCI
   concerning  the thickness  of SprayDon  that  would be  needed to
   achieve fire resistance ratings in decks of the type found in the
   Dirksen Building.   UL's letters, however, assume  that the decks
   would contain only classified inserts.  Lohan rejected several of
   PCEC's fireproofing submittals because, among other things,  PCEC
   provided   no   information  addressing   unclassified   inserts.
   Exhibits 7, 13, 14, 16, 18, 20.
        On February 10,  1992, a meeting was held  to discuss PCEC's
   fireproofing   submittals.     The   meeting   was  attended   by
   representatives of GSA, PCEC, Hall,  SCI, and Lohan.  Lohan asked
   for  clarification of  the thickness  of  material required  when
   unclassified abandoned inserts were present.  Hall stated that it
   had not  addressed this issue  and would seek  clarification from
   UL.  Exhibit 21.
        On February  13, 1992, UL  responded to a question  posed by
   SCI.  According to  UL, SCI stated that the floor decks contained
   afterset  inserts, which  could  be  "activated"  by  screwing  a
   fitting  into the threads  of the insert.   UL concurred with SCI
   that, in these areas, 1-1/4 inch of SCI's sprayed-on fireproofing
   material would be needed to  maintain the fire rating required by
   the specifications.   According to UL, SCI also  stated that some
   of the penetrations would be  filled with concrete.  UL concurred
   with SCI that,  in these  areas, 3/4  inch of  material would  be
   needed to  maintain the  required fire rating.   On  February 13,
   1992, Hall transmitted this UL letter to PCEC.  Exhibit 77.
        On March 17, 1992, Hall wrote to PCEC.  Hall stated that the
   fourth   floor  deck  contained  many  openings  in  addition  to
   "specified"  electrical inserts,  and that  a  PCEC employee  had
   directed Hall  to apply fireproofing material on the fourth floor
   deck at  a uniform thickness  of 1-1/4 inch.   Hall advised  PCEC
   that  this  order would  result  in  an  added cost  of  $13,300.
   Exhibit 24.   On April 1, 1992,  Hall again wrote to  PCEC.  Hall
   stated that it "took exception  to" holes and openings which were
   disclosed after demolition.   Hall pointed out that UL's February
   13, 1992  letter permitted PCEC  to fill all openings  and holes,
   and that  this would  have permitted  Hall to apply  3/4 inch  of
   fireproofing material instead  of 1-1/4 inch  of material.   Hall
   asked that PCEC  submit a claim to GSA for its additional cost of
   applying  added fireproofing material  to the fourth  floor deck.
   Exhibit 25.  Work on the third and fourth floors was completed by
   PCEC in June 1992.  Exhibit 87.   Both the March 17 and April  1,
   1992 letters show  that copies were supposed to be sent to Lohan.
   Exhibits 24, 25.
        A field report prepared by Lohan on September 22, 1992, says
   that PCEC was  to begin demolition on the  fourteenth floor soon,
   and that  Lohan looked at the cellular deck and verified that all
   signal,  power, and  telephone covers  were  in place.   A  field
   report prepared  by Lohan on  September 24, 1992, says  that PCEC
   was  to begin work  on the fifteenth  floor soon,  and that Lohan
   verified that  all signal,  power, and telephone  covers were  in
   place in the cellular deck.  Exhibit 26.
        A GSA employee  and a Lohan employee had  the opportunity to
   view some of the  fourth and all of the fourteenth  and fifteenth
   floors after  the carpet was  removed and before  demolition work
   was  performed  by  PCEC.     They  observed  nothing  that  they
   considered  to  be  a  differing  site   condition.    All  items
   documented in  the Lohan field  reports were in place.   Exhibits
   87,  92.   When  PCEC  installed floor  coverings  on the  third,
   fourth,  fifteenth, and sixteenth floors, Lohan observed that the
   floors were level  and that there were no  penetrations.  Exhibit
   59.
        According to  Hall, as a  result of demolition,  hundreds of
   openings were  made in the  floor decks.   This caused  to appear
   abandoned  inserts which  were not  in existence  at the  time of
   bidding.   Exhibit 90.   A former  Lohan employee  explained that
   PCEC's  demolition   subcontractor  removed  and   discarded  the
   classified  and  unclassified inserts  which had  capped existing
   penetrations  in the  deck, although  this  was not  part of  the
   contract's demolition requirements.  By the time  Hall arrived to
   perform its  work, the  previously existing  conditions had  been
   changed  radically   by  the  demolition   subcontractor.     The
   electrical subcontractor  installed inserts after  Hall completed
   its work.  Exhibit 92.
        On December  1, 1992, PCEC  wrote to Lohan and  requested an
   adjustment to the contract price to compensate for the additional
   material   and  labor  required  to  increase  the  thickness  of
   fireproofing material on the decks  of the fourth, fifth,  sixth,
   fifteenth, sixteenth, and  seventeenth floors.  PCEC  stated that
   this work was  necessary because of the existence  of hundreds of
   holes and unclassified  inserts.  PCEC claimed  that the presence
   of  these  holes   and  inserts  constituted  a   differing  site
   condition.  Exhibit 27.  Before this appeal was filed, Lohan told
   GSA  that it  received PCEC's  letter on  December 2,  1992, that
   Hall's March 17 and April 1, 1992 letters were attached, and that
   this  was  the   first  notice  Lohan  received   that  Hall  had
   encountered  what it believed  to be a  differing site condition.
   Exhibit 59.  A  Lohan employee and a former Lohan employee signed
   affidavits affirming that Lohan  first received the March 17  and
   April 1, 1992 letters on December 2, 1992.  Exhibits 91, 92.
        Lohan replied  to PCEC's December  1 letter on  December 10,
   1992.  Lohan stated that PCEC had documented a number of holes on
   the third and  fourth floors, and that CE5002 was  issued to take
   care  of  those holes.   Lohan  noted that  the third  and fourth
   floors had been covered with carpet since June 1992.   Lohan also
   stated  that  PCEC  provided  no  documentation   concerning  the
   conditions on the other floors.  Exhibit 28.
        On February 11, 1993, Hall wrote  to PCEC and stated that it
   had inspected  the sixteenth floor  ceiling.  Hall was  unable to
   determine  the  location of  classified and  unclassified inserts
   because the  seventeenth floor  was not  vacant and because  Hall
   could not tell  what holes might appear during  demolition on the
   seventeenth floor.   Hall  advised that, if  PCEC wanted  Hall to
   begin work  immediately, Hall  would  have to  apply the  maximum
   thickness   of  fireproofing  material   at  an  added   cost  of
   approximately $13,300.   Exhibit 29.  On February  15, 1993, PCEC
   asked Lohan whether  Hall should apply  the maximum thickness  of
   fireproofing material to  the ceiling above the  sixteenth floor.
   Exhibit 30.   Lohan responded on February 17,  1993, stating that
   it would not direct PCEC's construction activities.  Exhibit 32.
        On March 10, 1993, Hall wrote to PCEC and enclosed a drawing
   of the  locations of penetrations in the  fifteenth and sixteenth
   floor  decks,  and  a drawing  of  the  locations  of electrical,
   telephone,  signal, and unknown outlets on the seventeenth floor.
   Exhibit 38.  On March 15, 1993,  PCEC sent Hall's letter to Lohan
   and asked Lohan  to adjust the contract price  because the amount
   of  fireproofing material  was adjusted  from  3/4 inch  to 1-1/4
   inch, due  to the fact that  the contract documents did  not show
   the  presence of  all of  the penetrations  encountered by  Hall.
   Exhibit 40.   Also  on March 10,  1993, PCEC  wrote to  Lohan and
   enclosed  a  March  1,  1993  letter  from  Hall  concerning  the
   seventeenth floor which, according to PCEC, documented conditions
   found  on that  floor.   PCEC  again asked  Lohan  to adjust  the
   contract price.  Exhibit 39.
        On May 12, 1993, an attorney for Hall and PCEC submitted  to
   the  contracting officer  a claim on  behalf of PCEC.   The claim
   states  that  PCEC is  entitled  to  an equitable  adjustment  of
   $103,917.68  to the  contract price,  based  upon the  contract's
   differing site  conditions clause.  The claim  explains that Hall
   could not inspect  the decks at the  time it bid, so  Hall relied
   upon the  specifications and drawings  in preparing its  bid, and
   that  the  specifications  and drawings  did  not  show the  true
   conditions  of the building.  Hall  first observed numerous holes
   in  the fourth  floor deck  in January  1992, when  carpeting and
   fixtures were  removed from  that floor.   The claim  also states
   that GSA "obviously"  had superior knowledge of  the locations of
   the penetrations in the decks  and that GSA's failure to disclose
   its knowledge constitutes a breach of contract.  The claim states
   that Hall and PCEC were  directed to treat all electrical inserts
   as  unclassified, even  though  a majority  of  the inserts  were
   classified, and that  Hall was  directed to  treat areas  without
   holes  and inserts  as  if  those  areas  contained  unclassified
   inserts.   The claim requests  payment for work performed  on six
   entire floors (third,  fourth, fifth, fourteenth,  fifteenth, and
   sixteenth floors), and for work performed on parts of eight other
   floors.  Exhibit 51.  PCEC supplemented its claim on September 3,
   1993.  Exhibit 60.
        On October 22,  1993, the contracting officer  denied PCEC's
   claim  for the  third  and  fourth floors  because  PCEC did  not
   promptly  notify  GSA  of  the  existence  of  a  differing  site
   condition, and this denied GSA the opportunity to investigate and
   evaluate  the conditions that  existed.  The  contracting officer
   stated that,  if conditions had  been as PCEC alleges,  GSA would
   have  addressed  those conditions  as  it  did  in CE5002.    The
   contracting  officer also denied PCEC's claim for the fourteenth,
   fifteenth, and sixteenth  floors because there were  no differing
   site conditions on those floors.   The contracting officer stated
   that  no  decision would  be  issued concerning  the  fifth floor
   because work  had not yet begun  on that floor.   The contracting
   officer's  decision does not mention the claim for work performed
   on parts of eight other floors.  In the decision, the contracting
   officer states that the deck  system contains Walker header duct.
   Header duct is  a sheet metal enclosure that  is installed across
   the  cells  of  a  cellular  floor  deck  system.    Header  duct
   manufactured  by Walker meets  fire standards established  by UL.
   Exhibit 62.   There is  no evidence  in the  record to  establish
   whether, in fact, the deck system contains header duct.
        PCEC  filed this appeal  on January 21,  1994, requesting an
   equitable adjustment of $185,000.   In its notice of appeal, PCEC
   says  that the  specifications  identify  some  of  the  existing
   project conditions  that  might require  "special  treatment"  to
   preserve the fire  rating of the  structure, and that  additional
   openings were  "caused by  or uncovered by  demolition."   At the
   time of contracting, PCEC says  that Hall could not determine the
   various  thicknesses  of  fireproofing  material  that  would  be
   required  because demolition had not yet  occurred.  According to
   PCEC,  UL standards permit  preserving the fire  rating either by
   increasing  the  thickness  of the  fireproofing  material  or by
   treating the openings.  PCEC says that, after demolition, GSA did
   not  respond to  Hall's  inquiries as  to how  to  deal with  the
   openings  it found in  the deck.  According  to PCEC, it directed
   Hall  to apply  the maximum  thickness  of fireproofing  material
   throughout the  project in order  to expedite the work.   Exhibit
   66.
        Clause 24 of the contract reads, in part:
        DIFFERING SITE CONDITIONS
        (a)   The  Contractor shall  promptly,  and before  the
        conditions  are disturbed, give a written notice to the
        Contracting  Officer   of  (1)  subsurface   or  latent
        physical conditions at the site which differ materially
        from those indicated  in this contract, or  (2) unknown
        physical  conditions at the site, of an unusual nature,
        which   differ   materially   from   those   ordinarily
        encountered  and generally  recognized  as inhering  in
        work of the character provided for in the contract.
        (b)  The Contracting Officer shall investigate the site
        conditions promptly after receiving the notice.  If the
        conditions  do  materially  so   differ  and  cause  an
        increase  or decrease in  the Contractor's cost  of, or
        the  time required for, performing any part of the work
        under this contract, whether or not changed as a result
        of the  conditions,  an equitable  adjustment shall  be
        made under  this clause  and the  contract modified  in
        writing accordingly.
   Exhibit 1 at 23.
                               Discussion
        PCEC argues  that an  equitable adjustment  to the  contract
   price  is  required  because  it  encountered  a  differing  site
   condition and  because GSA  possessed superior  knowledge of  the
   conditions  in  the Dirksen  Building  and failed  to  share that
   knowledge  with  PCEC.   PCEC  has  not  established that  it  is
   entitled to recover under either of these theories.
        In order  to  prove  that  an equitable  adjustment  is  due
   according  to paragraph (a)(1)  of the differing  site conditions
   clause, PCEC must establish that the contract contains reasonably
   plain  or  positive  indications  of  what  conditions  would  be
   encountered,  and that it  encountered different conditions which
   were reasonably unforeseeable.  PCEC must also establish that  it
   reasonably relied upon  a reasonable interpretation of  the terms
   of the  contract,  and that  it  was damaged  as  a result  of  a
   variation between  the expected  conditions  and the  encountered
   conditions.   Stuyvesant Dredging Co. v.  United States, 834 F.2d
   1576 (Fed.  Cir. 1987);  P.J. Maffei Building  Wrecking Corp.  v.
   United States, 732 F.2d 913 (Fed. Cir. 1984).
        PCEC  has not established that it encountered any reasonably
   unforeseeable  conditions.  Amendment  7 to the  solicitation put
   offerors  on  notice  that they  would  encounter  classified and
   unclassified  inserts.    The  contract  does  not  identify  the
   location  of  such inserts  and does  not contain  an approximate
   number  of inserts which might be  encountered.  Hall encountered
   classified  and   unclassified  inserts,  just  as   Amendment  7
   anticipated.    The  existence  of  classified  and  unclassified
   inserts  was  reasonably  foreseeable,   given  the  language  of
   Amendment  7.    Hall  also  encountered  holes,  which  are  not
   mentioned  in  Amendment  7.    The  record  does  not establish,
   however,  whether any  of  the holes  were  latent conditions  or
   whether  all  of the  holes  were  created by  PCEC's  demolition
   subcontractor.   The differing  site conditions clause  makes GSA
   responsible  only for latent  conditions, and not  for conditions
   created by one of PCEC's subcontractors.
        PCEC has  not established that  it reasonably relied  upon a
   reasonable interpretation of the terms of the contract.  Instead,
   PCEC, through Hall, relied upon several  unreasonable assumptions
   when it agreed to perform the fireproofing work.  It is normal to
   find penetrations  in the cellular  floor decks of  a thirty-year
   old building.  At the time  bids were submitted, the building was
   occupied and the parties could  not see the location or the  type
   of penetrations that existed.   Even though Amendment 7 warned of
   unclassified  inserts, even though the  contract did not show the
   location of such  inserts, and even though the  existence of just
   one such insert  in a grid section would  require the application
   of the maximum thickness of fireproofing material over the entire
   section, neither PCEC nor Hall made an allowance for encountering
   or replacing  unclassified inserts.   In fact,  it was  not until
   after GSA  awarded the contract  to PCEC that Hall,  through SCI,
   asked  UL  what  thickness  of  material  would  be required  for
   unclassified  inserts.  The basis for Hall's assumption that only
   one-third   of  each   floor   would   require  some   additional
   fireproofing material  is not apparent  from the facts,  and this
   assumption  has  no  support  in  the  contract  or  the  record.
   Finally,  Hall  assumed  that  PCEC  would  convert  unclassified
   inserts into  classified inserts, as  had the contractor  for the
   first phase of  the renovation of the Dirksen  Building, and that
   PCEC  would then  require  Hall  to apply  a  thinner coating  of
   fireproofing material.   This assumption  is not  based upon  any
   interpretation of the terms of the contract.
        In  summary, PCEC  is not  entitled to  recover pursuant  to
   paragraph  (a)(1) of the  differing site conditions  clause.  The
   conditions encountered by PCEC were reasonably foreseeable except
   for the holes, and PCEC did  not establish that any of the  holes
   were latent  conditions.  In addition,  PCEC did not rely  upon a
   reasonable interpretation  of the  contract when  it reached  its
   conclusion concerning  the number and  type of  inserts it  might
   encounter.
        In  order  to prove  that  an  equitable adjustment  is  due
   according  to paragraph (a)(2)  of the differing  site conditions
   clause,  PCEC must establish  that the conditions  it encountered
   were unusual and different  from those a contractor would  expect
   to find when performing  the work required by the  contract.  The
   Dirksen Building  is thirty years  old and has been  altered many
   times.  Penetrations  in the deck are normal and  to be expected.
   Thus, PCEC  is  not entitled  to  recover pursuant  to  paragraph
   (a)(2).
        In addition  to the fact  that PCEC has not  established the
   existence of a differing site  condition, PCEC is not entitled to
   recover  for the  third  and  fourth floors  because  it did  not
   provide  the  notice required  by  the  contract.   The  contract
   provides  that  PCEC  was obligated  to  provide  the contracting
   officer with prompt, written notice if it encountered a condition
   which  differed materially from  that indicated in  the contract.
   Work on the  third and fourth floors was completed  in June 1992.
   PCEC waited until December 1992  to notify Lohan of the purported
   differing site condition.  Although copies of Hall's March 17 and
   April 1, 1992 letters to PCEC were  supposed to have been sent to
   Lohan, there is  no evidence that copies were  actually sent, and
   Lohan states  that it first  received copies of these  letters in
   December 1992.   PCEC notes  that GSA  placed the letters  in the
   appeal file,  but this does  not establish when the  letters were
   sent  to  Lohan.    Because  the third  and  fourth  floors  were
   completed  approximately six months before PCEC notified Lohan of
   the  purported differing site condition, Lohan was prevented from
   investigating  conditions on these  floors.   The lack  of timely
   notice  of  conditions  on  the  third  and  fourth  floors   was
   prejudicial to  GSA because it  prevented GSA from  verifying the
   existing conditions and  from choosing a procedure  for remedying
   whatever conditions existed, as it had  done previously for these
   two floors when the parties agreed to CE5002.
        PCEC's  superior knowledge arguments  fail as well.   First,
   PCEC  argues  that  GSA  knew   of  the  number  or  location  of
   unclassified inserts.  PCEC provided no evidence  to support this
   argument.   Second, PCEC  argues that GSA  knew that  the maximum
   thickness of fireproofing  material would be needed  because this
   was the conclusion reached by  Grace's product manager in his May
   7,  1991 letter.   The  information  that Grace  provided to  GSA
   establishes that, in UL's opinion, it was not always necessary to
   apply the maximum  thickness of fireproofing material.   Instead,
   it was possible to apply less material if classified inserts were
   present.  The May 7,  1991 letter establishes only what Grace,  a
   fireproofing material manufacturer, would have anticipated  if it
   had submitted a bid to  perform the fireproofing work required by
   the contract.   The  May 7  letter does  not  establish that  the
   maximum thickness  of fireproofing material was  always required.
   Finally, PCEC  argues that  GSA knew of  the existence  of Walker
   header duct.   There is  no evidence in  the record  to establish
   whether  the floor  decks contain  Walker  header duct,  and PCEC
   never  submitted this superior knowledge claim to the contracting
   officer.
                                Decision
        PCEC has not  established the existence of  a differing site
   condition and  has not  established that  GSA possessed  superior
   knowledge which it failed to share with PCEC.  For these reasons,
   the appeal is DENIED.
   _______________________________
                                      MARTHA H. DeGRAFF
                                      Board Judge
   We concur:
   ________________________________
   _______________________________
   STEPHEN M. DANIELS                 JOSEPH A. VERGILIO
   Board Judge                        Board Judge