November 10, 2025 Planning Board Special Meeting - WEHI Transcript

01/05/2026 03:19:18 PM Page 53 to 56 of 112 14 of 28 sheets 53 find it.1 But just to clarify. You were not able to search2 Q. for it at the survey because they closed?3 No, we did consult with the New Jersey Geological4 A. Society, I think the USGS did it for the New Jersey5 Geological survey and the New Jersey office didn't have6 the report, that the mapping was based on.7 Based on the map you have is it indicating as to8 Q. a hazard?9 It just said it's a Class B3 weakly cemented soil10 A. or rock with a slope of 15 degrees. That's what it11 says.12 And who wrote that map? Who created that map.13 Q. I think the -- I think it was done by the US14 A. Geologic Society for the New Jersey, and not society15 survey, and for the New Jersey. But I'm really, I16 haven't been able to find the background of that.17 Do you have any reason -- let me go further then.18 Q. What would the Class B hazard mean or amount to,19 assuming that's correct, since you have the document at20 least in front of you, what would that mean, a Class B21 hazard?22 That's what I'm trying to find out.23 A. You mean there's no -- as an engineer does the24 Q. word Class B hazard have meaning to you?25 54 Not to me. It's the first time I've seen it in1 A. my practice.2 What does it mean that the sand is weakly3 Q. cemented, can you explain that?4 Well, it means that there's two components of5 A. strength, there's cohesion and there's friction and it6 has a little cohesion and that, that could dissipate.7 In the presence of groundwater that cohesion could8 dissipate.9 So that begins liquefaction and then --10 Q. Well, I don't know about liquefaction for sure,11 A. but it would just a bond between the particles.12 So if they're weakly bonded water can infiltrate13 Q. and further separate the bonds?14 Further weaken it.15 A. Thank you.16 Q. Have you -- strike that.17 In your report at Page 9, this may be something18 different from the way it sounds, so I want to find out19 what it means. You refer to a fault that is20 approximately 2000 feet from the site. It's in the21 first full paragraph. Can you explain what that refers22 to?23 Okay, that's in the Langan report.24 A. Okay.25 Q. 55 It's on the map in the Langan report and it1 A. refers to a geologic fault, that in which there was a2 significant amount of movement but that would have3 likely occurred ions ago. You know, back in the, at the4 time

in the Langan report and it1 A. refers to a geologic fault, that in which there was a2 significant amount of movement but that would have3 likely occurred ions ago. You know, back in the, at the4 time the earth separated and resulted with the injection5 of these volcanic rock and there was a shift, a6 movement. You can see it on the map that Langan has7 there.8 Why -- does it have any significance in your9 Q. report or is it only noted as a fact of the site?10 It was noted in the Langan report. It's, and11 A. they described it as being -- in other words, it's not12 like the San Andreas Fault that's still active. It's13 not categorized as being an active fault.14 Thank you. I just wanted to clarify.15 Q. Now, you mentioned that your firm was not16 retained to do an independent analysis of the stability17 of the slope in the area of the study. Who gave you18 your instructions?19 The instruction came from our engineer. Our20 A. engineering representative. The Planning Board, the way21 it was explained, we have two opposing reports, can you22 explain to us what the difference is between the two23 reports.24 So you have essentially compared the two25 Q. 56 discussions from the two consultants?1 Correct.2 A. And you addressed them in some way?3 Q. Well, we looked to it as had they touched the4 A. standards of care. Were they using methods of analysis5 to the slope that are in accordance with the standard --6 the current standards of practice and you had, you have7 one engineer who's trying to come up with stability8 results that indicate instability and the results, at9 least as presented in the report, don't, in our opinion,10 indicate instability.11 And you based that on Langan's engineer who wants12 Q. to show stability, isn't that correct?13 Sorry, no. I based it on the safety factors that14 A. were produced by the methods and in accordance with15 standards of practice for evaluation of a slope. Just a16 slope that I got 1.5 is the standard criteria and we17 thought that the criteria proposed by Princeton Hydro18 was not reasonable for this application.19 And your view was that the section of the Army20 Q. Corps of Code dealt with --21 It's not a code, it's an engineering manual.22 A. The Army Corps of Engineering. Your feeling was23 Q. that the 2.0 factor -- let me just get to that section.24 Give me a moment, please. Your feeling was that section25