“ Vv. va ; y - - STATE OF FLORIDA "FLORIDA ENGINEERS MANAGEMENT. CORPORATION MANAGEMENT CORPORATION, ~ Petitioner, oe | 00° -7 7 7° FEMC Case No. 99-00067 RONALD S. TULINO, P.E,, oo Respondent. , ey I L T COMES NOW the Florida Engineers Management Corporation, hereinafter referred to as “Petitioner,” and files this Administrative Complaint before the Board of Professional Engineers against Ronald S. Tulino, PE. hereinafter referred to as “Respondent”. This Administrative Complaint is issued pursuant to Sections 120.60 and 471.038, Florida Statutes. Any Proceeding concerning this complaint shall be conducted pursuant to Section 120. 57, Florida Statutes. In support of this complaint, Petitioner alleges the following: ith providing administrative, se Bae and asin a8 gee eS ) Florida Statutes aie The Board of Professional “i Bnginoer is is charged thet MAR ; ly restated herei 32931 -2620, 3. Respondent was the Threshold Inspector for a project hereinafter referred to as the “Towers Ten Condominium” project. 4. Respondent also signed and sealed drawings for the structural, electrical, and mechanical engineering. 5. The Towers Ten Condominium project is a twenty-story, one hundred and fourteen-unit, multi-family residential condominium project located in Daytona Beach Shores, Florida. . 6. Respondent submitted the Towers Ten Condominium project plans to the City of Daytona Beach Shores Building and Codes Division for permitting 7. The Towers Ten Condominium project plans are Incomplete, contain " serious errors : and omissions, and do not meet the standard of due care in the practice of engineering. 8. Petitioner realleges and incorporates paragraphs one through seven as if me of the upper shearwalls ends at the third floor on the 3” slab and will not adequately support the shearwall. ) | ad b. Two of the main shearwalls are insufficient to withstand their intended loads. The shearwalls as designed are less than 50% of the required capacity. 11. Based on the foregoing, Respondent is charged with violating Section 471.033(1)(g), Florida Statutes, by engaging in negligence in the practice of engincering. COUNT TWO 12. Petitioner realleges and incorporates paragraphs one through seven as if fully restated herein this Count Two. 13. Respondent’s structural drawings are deficient in that the drawings fail to indicate in sufficient detail how the masonry was attached to the columns to provide lateral resistance in the upper floors. 14. In addition, the soils report Jacks the spacing requirements for the augercast piles. The industry standard is three times the diameter, which is four feet for a 16-inch diameter pile. All of the piles are spaced less than four feet. 15. Based on the foregoing, Respondent is charged with violating Section 471.033(1)(g), Florida Statutes, by engaging in negligence in the practice of engineering. COUNT THREE 16, _ Petitioner Tealleges and Incorporates Paragraphs one thrcugh seven as if fully restated herein this Count Three, - 17. ~ Respondent? s ‘structural drawings are deficient in that the foundation under the main shearwall has insufficient capacity to withstand its intended loads. . 18: 7 Based on the foregoing, Respondent is charged with violating Section “47 033(1)(g), Florida Statutes, by engaging in negligence in the practice of engineering. reer Serene Snr unit feeders from meter center to panelboards are not sized. ro) : Nd COUNT FOUR 19. Petitioner realleges and incorporates paragraphs one though seven as if fully restated herein this Count Four. 20. In or about March 1999, Respondent signed and sealed electrical engineering plans for the project. 21. The electrical drawings contain several deficiencies including but not limited to the following. a. In the design of the emergency power system, no starting capacity controls are indicated for the emergency generator. There is no indication that the generator has the capacity to start the elevators, fans and fire pump simultaneously. b. Additional electrical loads that are required to be on emergency have not been shown or accounted for. co In the design of the normal power system, source and distribution system fault currents are not shown. | | d. The utility transformer location and the medium voltage fe eder conduit are not shown on the electrical plans. e. Living unit load calculations are based on erroneous unit sizes. Living In the design of the lighting system, exit and egre lighting in stair wells rs is not shown and lighting fixtures are not selected. nce, voltage, light output, and lamp type are not shown. There is no indication of which fixtures are connected to emergency circuits to Sota aici naa eo scopieiniaicanth Sore Bees okey produce minimum egress lighting levels required by code. ns) v h Inthe e design of the alarm system, locations of the fire alarm control unit and fire command center, as required by code, are not indicated. th foregoing, Respondent i is charged with violating Section i : 471 033( De, Florida Statutes, by engaging | in negligence i in the practice Petitioner realleges and incorporates paragraphs one through seven as if of engineering. fully restated herein this Count Five. 24.00 Respondent’s electrical drawings are deficient in that many systems . system Panels and controls, fire department two-way telephone communication service ; panels and controls, fire detection and fire alarm system annunciation panels, elevator floor location and operation annunciators, sprinkler valve and water flow annunciators, 25. Respondent failed to provide the design for a lightning prctection system. 26. _ The design of the grounding system is not complete. Grounding conductors are not sized, Grounding of the separately derived generating system is not MR eel om MRR ee shown. Other ‘grounds required by code a are not shown. 27, ; Based « on the foregoing, Respondent is charged with violating Section 47] 033(1)(8), Florida Statutes, , by engaging in " negligence i in the practice of engineering. me! ealleges and incorporates paragraphs one through seven as if + 30. The Plmbing cravings contain several deficiencies including but not limited to the following: following Penalties: permanent _ revocation or suspension of the: Respondent's s license, restriction of the Respondent’s practice, imposition of an administrative fine, issuance of a reprimand, placement of the _ Respondent on Probation, the assessment of costs related to the investigation and ; prosecution of this case, other than ¢ costs associated with an attomey’s time, as provided . Fs fori in Section 455. 227(3), F lorida Statutes, and/or any other relief that the Board deems » appropriate. Dennis Barton - Executive Director Depastment of EL L [Dane Raguiation Wa t, J CQprree : _ DEPUTY CLERK — ona oe : Natalie Lowe : 7 Prarder Mi Prosecuting Attorney . DATE _ : 2. Ae 2000" “ “FILED Florida Engineers Management Corporation Clerk COUNSEL FOR FEMC: ida Board o of Professional Engineers Street

Docket for Case No: 00-000997

Issue Date	Proceedings
Jan. 19, 2001	Order Closing File issued. CASE CLOSED.
Jan. 18, 2001	Motion to Relinquish Jurisdiction (filed by D. Sunshine via facsimile).
Jan. 17, 2001	Status Report (filed by Petitioner via facsimile).
Dec. 18, 2000	Order Continuing Case in Abeyance issued (parties to advise status by January 15, 2001).
Dec. 15, 2000	Status Report (filed by Petitioner via facsimile).
Nov. 02, 2000	Order Continuing Case in Abeyance issued (parties to advise status by December 15, 2000).
Oct. 31, 2000	Notice of Appearance (filed by D. Sunshine via facsimile).
Oct. 31, 2000	(Petitioner) Status Report (filed via facsimile).
Sep. 01, 2000	Order Continuing Case in Abeyance issued (parties to advise status by November 1, 2000).
Aug. 25, 2000	(Joint) Status Report Unsigned (filed via facsimile).
Jul. 12, 2000	Order Continuing Case in Abeyance sent out. (parties to advise status by August 25, 2000.)
Jun. 29, 2000	Status Report (Petitioner) filed.
May 12, 2000	Order Granting Continuance and Placing Case in Abeyance sent out. (Parties to advise status by June 30, 2000.)
May 01, 2000	(Petitioner) Motion to Abate filed.
Mar. 31, 2000	(Petitioner) Notice of Filing Discovery Response (filed via facsimile).
Mar. 30, 2000	Order of Pre-hearing Instructions sent out.
Mar. 30, 2000	Notice of Hearing sent out. (hearing set for May 25 and 26, 2000; 9:00 a.m.; Viera, FL)
Mar. 17, 2000	(Petitioner) Response to Initial Order (filed via facsimile).
Mar. 16, 2000	Order sent out. (respondent`s motion to dismiss is denied)
Mar. 16, 2000	(R. Dykes) (unsigned) Interrogatories to Petitioner (filed via facsimile).
Mar. 14, 2000	(R. Dykes) (unsigned) Motion to Dismiss (filed via facsimile).
Mar. 09, 2000	(Petitioner) Response to Respondent`s Motion to Dismiss (filed via facsimile).
Mar. 07, 2000	Initial Order issued.
Mar. 02, 2000	Motion to Dismiss filed.
Mar. 02, 2000	Election of Rights filed.
Mar. 02, 2000	Administrative Complaint filed.
Mar. 02, 2000	Agency Referral Letter filed.