Mar 26 200? 10:47 Fax sent by : 8585218521 FL BOARD 63-26-87 69:35 Py: # STATE OF FLORIDA ' FLORIDA BOARD OF PROFESSIONAL ENGINEERS FLORIDA ENGINEERS MANAGEMENT CORPORATION, Petitioner, v. FEMC Case No. 2006067898 ANDREW J. MORGAN, P-E., Respondent. : 4 H ADMINISTRATIVE COMPLAINT | COMES NOW‘ the Florida Engineers Management Corporation, hereinatt referred to as “Petitioner,” and files this Administrative Complaint before the Board of Professional Engineers against Andrew J. Morgan, P.E., hereinafter referred to as “Respondent”. ‘This: iAdministrative Complaint is issued pursuant to Sections 120.60 and 471.038, Florida Statutes. Any proceeding conceming this complaint shall be conducted pursuant to Section 120.57, Floi ida Statutes, ~ In support of this complaint, Petitioner alleges the following: | i. Petitioner’ is charged with providing administrative, investigative, and prosecutorial services to the Board of Professional Engineers pursuant to Section 471.938, Florida Statutes (1997). The Board of Professional Engineers is charged witty ‘regulating the practice of engineering pursuant to Chapter 455, Florida Statutes. | 2. Respondent is, and has been at all times material hereto, a licensed professional engineer in the State of Florida, having been issued license number PE $7171. Réspondent’s last known address is 713. Nighthawk Way, North Palm Beach, FL 33408. vide atm hea AUR NE UM TREN 2/12 3 Mar 26 200? 10:47 Fax sent by : 9585218521 FL BOARD 63-26-87 69:36 Py: @ S 3. In ‘a: Final Order Approving Settlement Stipulation dated July " 2005, FEMC Case Number 2004038064, The Respondent agreed to submit to the Board for consultant review, a list of all projects completed by the Respondent at six (6) and cightden (18) month intervals from the date that the Final Order adopting the Stipulation was filed. | 4, Pursuant: fo the Final Order, a Board consultant selected and reviewed the i Respondent’s Golden Bear Plaza North Tower Tenant Improvement ("Goldeh Bear Plaza”) project. COUNT ONE 5, Petitioner tealleges and incorporates paragraphs one (1) trough four (4) as if fully set forth in this Count One. | 6. On July 20, 2005, a Final Order approving Settlement Stipilation in case 2004038064 was filed. As part of the stipulation, the Respondent, Andrew. i Morgan, P-E., submitted a set of calculations and plan drawings for the Golden Bear Plaza project, one of two job submissions for his First Project Review. Board Consultant Michael Dristol, PLE. noted deficiencies in beth the calculations and drawings, including but not limited to: | a. A service load of 6.55 k. was used for the design of the chmponents. The American Institute of Steel Construction, Load and Resistance Factor Design Specification A4-2, states the ultimate factored bbad of 9.5 kips mo b. The % inch plate thickness indicated for the beam support bracket. is should be used in all bolt connector design calculations. inadequate. A bending analysis of this bracket shows that: the plate should 1 bea minimum of % inch thick. | $ H { i i FEMC v Andrew Morgan, PLE. 2 1 Case No, 2006067898 seg NCARBRELS 1 vs oy cr 3412 Mar 26 200? 10:47 Fax sent by : 9585218521 FL BOARD 63-26-87 69:36 Pg: 4/712 * c. The tength used to calculate the moment deriving the tensibn load on the concrete anchors is 7 itches which is indicated on the! sketch as: the distance: between the A325 bolts. The actual length between the concrete ‘anchors as given on the fabrication drawing is 8 inches. d. No callout was found on the drawings referring to the torque to be applied to. the’ % inch diameter bolts used. In lieu of a specifis torque, bolts tightened only to the snug tight condition should be clearly identified on design and erection drawings. | | e There is no indication of how the beam support bracket is attached to the shear plate. . f. There: isa dimension missing that would located the bots in the shear plate. | g. ‘There is no indication in the calculations or installation deowing, to show | that the torsion has been addressed. An analysis shows it the induced torque exceeds the torque capacity of an unreinforced concete beam. 7, Based‘ on’ the foregoing, Respondent is charged with vidloting Section 471.033(1)(g), Florida Statutes, by engaging in negligence in the practice of cing WHEREFORE, the Petitioner respectfully requests the Board of Professional Engineers to enter an order imposing one or more of the following penalties: permanet revocation or suspension of the Respondent’s license, restriction of the Respondent's practice, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent ol probation, the assessment of costs related to the investigation and prosecution of this case, other than costs | associated with an atfonicy’s time, as provided for in Section 455.227(3), Florida Statutes, and/or FEMC v Andrew Moigan, PE. 3 Case No. 2006067898 Mar 26 2007 10:48 Fax sent by : 9585218521 FL BOARD 63-26-87 69:36 Pg: 5/412 @ oe > any other relief that the Board deems appropriate. SIGNED ihis om day of Danan , 2007. Y: Patrick Creehani f Prosecuting Attorney COUNSEL FOR FEMC: | Patrick Creehan F { L E p Chief Prosecuting Attorney Oopartinent of Busine Florida Engineers Management Corporation prc Yount min 2507 Callaway Road, Suite 200 Tallahassee, Florida 32303: crn Leer Florida Bar No. 0063540 MM Reichods PCijt DATE ~ [=~ PCP: January 18, 2007 PCP Members: Matthews, Seckinger, and Hogenkamp FEMC y Andrew Morgan, PE. 4 Case No, 2006067898 4

Docket for Case No: 07-001421PL