December 10, 2025, Planning Board Special Meeting - WEHI Transcript

15 of 55 sheets Page 57 to 60 of 144 01/14/2026 10:36:25 AM 57 MR. AFRAN: I assumed that's what he meant.1 Now --2 Q. No. No, I'm sorry. I meant the two engineers, I3 A. meant Princeton Hydro and Langan. I'm sorry.4 MR. PLOCKER: Right. That was my question.5 That's what I said. Thank you.6 Now, what type of storms were you concerned about7 Q. when we talk about this type of seepage parallel to the8 slope?9 Recently there was a storm in Plainfield where10 A. there was nine inches of rain in a few hours, which is a11 tremendous amount of rain.12 When did that happen?13 Q. I am not sure. It was about six weeks or two14 A. months ago. I am not exactly sure when.15 Recently. So obviously that's a big storm and16 Q. occasionally we do get storms with a lot of rain in17 short periods of time like that.18 Is there anything else that you defined as19 seepage in this context as referring to?20 Sorry.21 A. Is there anything else that you consider as22 Q. defining seepage parallel to the slope in this sentence,23 other than say the nine inch rain?24 It would be -- well, as we pointed out25 A. 58 infiltration seepage from the infiltration system in a1 heavy rainfall situation.2 Now, other than what you said, are you able to3 Q. define a heavy rainfall situation?4 It would, I would say at a minimum a 100-year5 A. storm and and/or greater. The recent event was greater6 than a 100-year storm.7 Well, 100-year storms occur with some degree of8 Q. frequency. Frequently, every few months, right?9 No.10 A. Well, they're not uncommon, are they?11 Q. There, there is a, the whole definition is a12 A. probability of occurrence. It means it has a one13 percent chance that it will occur.14 Now, why were you worried about that degree of15 Q. seepage?16 Sorry.17 A. Why is that degree of seepage a matter of18 Q. concern?19 It's a standard precautionary evaluation that's20 A. made for steep slope stability.21 You say that, "Would be an extreme event which22 Q. may justify a lower Factor of Safety upon review of23 relevant standards." Let me ask you about the24 substance --25 59 MR. AFRAN: Bear in mind Mr. Chairman, my1 engineers not seen it and I've not yet been able to2 consult with my engineer. I do want to get some3 background from Mr. Kleinberg on this point.4 When you say, extreme event, you mean a storm in5 Q. the order of a 100-year storm?6 Right. And it would also involve

my engineer. I do want to get some3 background from Mr. Kleinberg on this point.4 When you say, extreme event, you mean a storm in5 Q. the order of a 100-year storm?6 Right. And it would also involve previous7 A. rainfall, what they call a antecedent moisture and it8 would involve the presence of an actual groundwater9 level which was not apparent on this site.10 At that time?11 Q. In the variable subsurface data there was no12 A. precise determination of where the groundwater -- we13 described the groundwater situation in our report.14 Right. Is that referring to the evidence or lack15 Q. therefore of mottling?16 That's associated with that.17 A. And there was a discussion whether they used the18 Q. right standard in terms of the type of color chart the19 DEP used with respect to identifying mottling, correct?20 I think Langan indicated they did not see21 A. mottling.22 And he used a different method that you23 Q. acknowledged was not as rigorous as what Princeton Hydro24 used, is that correct?25 60 Well, in a sample description what they said is1 A. they didn't see any mottling.2 Based upon the color and coding that they3 Q. applied, isn't that correct?4 No, they said they didn't -- I don't know. They5 A. said they did not see mottling.6 And you don't know really what methodology they7 Q. used to reach that determination?8 No, I don't.9 A. So it is an issue if there's evidence of mottling10 Q. because that would show prior waterways, correct?11 It's -- that's what the conventional wisdom is.12 A. Now, what do you mean by "Upon review of relevant13 Q. standards." You don't say much in there about what14 you're referring to?15 Well, the 2908 or the one we're referencing 1902,16 A. Core of Engineers Manual.17 Why don't you cite the standards in there?18 Q. I just, this was an e-mail, you know, I am not,19 A. you know, pinning everything down. It's an e-mail.20 And you felt the lower factor of 1.5 was21 Q. appropriate because the seepage problem would likely22 only occur in extreme events?23 I don't know if it would even occur on this site.24 A. Well, then why talk about it?25 Q.