L MYCEL

General Consultants
KMRCL, Munshi Premchand Sarani, Kolkata - 700 021 Kolkata East West Metro
Telephone: +91 33 22314553 Fax: L _

Our Ref: UG2-22-4500-

Your Ref:
Date: 3rd November 2022

ITD-ITD Cem Joint Venture

46, Suren Sarkar Road, Subhaas Sarobar, Beliaghata, Kolkata - 700010

Attention: Mr. Rupak Sarkar- Project Director

Kolkata Metro East West Line UG2.

Subject: UG2: Uncontrolled Ingress of water at CP-2 on 14th October 2022

Ref:

1. Jv’s Letter#UG2-GC/4.1/JV/2038/22 dated 26th October 2022

2. GC’s Letter#UG2-22-4500-09437 dated 18th October 20222
3. JV's Letter#UG2-GC/4.1/JV/2036/22 dated 16th October 2022
4. JV's email dated 16th October 2022

Dear Sir,

This has reference to your letter# UG2-GC/4.1/JV/2038/22 dated 26th October 2022 on the subject of Uncontrolled Ingress of
water at CP-2 on 14th October 2022.

We start by totally refuting the Contractor’s position that the sudden ingress of water was unpredictable and due to
unforeseeable ground conditions and contest the continual use of such wording, including the use the wording
“unpredictable/unforeseeable’ on the JICA JSSS form submitted following the incident.

This is the third serious incident on UG2 involving the ingress of water and soil into the works, following the 31 August 2019
TBM 1 incident and 11/12 May 2022 Bow Bazar Shaft incident. Following each different ingress, the Contractor has claimed
that ground conditions were unforeseen and that it’s execution of the works was not at fault, therefore attempting to absolve
itself of any responsibility for the failure of the works designed and executed by the Contractor. The Contractor has in 2019 and
May 2022 claimed the ground as unforeseen but has to date, despite producing numerous reports, never produced any factual
evidence showing how conditions varied from those presented in the GIR, relying instead on hearsay and newspaper articles
written by non-experts.

Other unproven excuses previously put forward by the contractor, for the lack of progress at CP2, have included a direct
connection to the River Hooghly 2km away, a tidal effect on the ground water pressure (despite data submitted by the
Contractor showing no evidence of any such effect) and water ingress from the sewer above.

The Contractor also used the excuse of unforeseen ground conditions at IVS when abandoning the Eastbound tunnel, after
being unable to control the settlement during excavation. Even during the excavation of the revised scheme, suggested by the
Contractor, on numerous occasions the Contractor referred again to unforeseen ground conditions.

The data from BH20, nearest CP2, clearly shows a very fine particle distribution curve, low cohesion and a water table very
close to the surface. These are all properties that make the occurrence of piping and boiling in such soils highly likely. Holes
drilled during PU grouting of the benching area in August and September 2022 recorded water ingress of up to 100l/min and it
was clear that the benching excavation would be more technically challenging than the heading and the increased groundwater
pressure due to the greater depth below the surface would make piping more likely.
 The Contractor’s claim to have deployed teams who ‘are the best in the industry’ is not borne out by the experience of the GC.
ITD’s management have always focused heavily on commercial aspects of the contract and are reluctant to engage new and
specialized resources as witnessed by the unreasonably protracted process to appoint a chemical grouting agency, and the
repeated reluctance to perform proper grouting operations from the EB tunnel, claiming access was difficult, instead using hand
held drills. The Contractor’s team has limited NATM experience in soft ground and has to be constantly reminded to follow basic
procedures, like ensuring minimum 50m shotcrete sealing layer on face. At site level there was lack of understanding of the role
and importance of the Daily Review Meeting and even a refusal to partake in the DRM, viewing it as a waste of time. This is not
the attitude of an experience soft-ground NATM team. This lack of participation was brought up in KMRC/GC/ITD management
meeting on 18/8/22 and again in MD-KMRC and MD-ITD meeting on 22/8/22, where it was agreed that a daily DRM had to be
carried out. GC has gone as far as to hold these meeting in the tunnel at CP2 to facilitate and ensure ITD could attend with no
disruption to works.

At the time of the incident the face had been open 23 hours, giving ample time for pathways for water ingress to develop in the
bands of silt as the overburden was removed, increasing the permeability of the silt layers, previously compressed by the grout.
This extended period taken for excavation is contrary to the NATM principle that time is a support element and the longer the
face is open the greater the risk to the integrity of the tunnel. The use of small handheld electric breakers to excavate a bench
that was full of cement and PU grout was inappropriate, as witnessed by the breakdown of 3 breakers and the ensuing delay
whilst replacements were brought from Sealdah and is yet another example of the Contractor refusal to deploy appropriate
resources on such a major contract.

The ITD supervisor on nightshift did not have suitable or sufficient experience to be responsible for such a technically
challenging excavation in soft ground, as witnessed by the need for the GC nightshift engineer to step in and manage the initial
response to the ingress. No chemical grouting specialist was available on site or in Kolkata, despite previously, in the heading,
excavation only been carried out with a grouting expert present. Following the unfortunate and untimely death of Ingemar
Norbert and the resulting lack of cover, the Contractor should have made sure that 24/7 cover was available before
commencing the benching. Had the expert been present and sufficient quantities of PU grout been on site, it is certain that the
magnitude of the incident could have been greatly reduced.

For avoidance of doubt, the Employer/Engineer rejects the claim of any cost and time under GCC clause 4.23 on
the grounds that the Contractor has not provided any proof that the ground conditions encountered at CP2 were
unforeseen and therefore any risk, time and cost arising from the Contractor's delay shall be borne by the
Contractor only.

This is issued as per the various provisions of the Contract.

Thanking You
Yours faithfully,

For MYCEL Consortium

Pallab Pal
Jt. Project Manager UG2

KMRC: Director (P& P), GM Civil

MYCEL: APO, JPM(UG), Tunnel Manager, Contract Expert