December 3, 2025 Regular Meeting - WEHI Transcript

01/05/2026 02:58:16 PM Page 53 to 56 of 68 14 of 17 sheets 53 is that fair to say?1 Concrete.2 A. Concrete.3 Q. Yes, that's what I am saying. That particular4 A. piece of core, I don't know about the rest of it.5 Right. And we don't have any other measures,6 Q. right?7 Right.8 A. So the one that we have shows that this rock base9 Q. is no better than a low to moderate concrete, is that10 fair so say?11 That's fair to say.12 A. Thank you.13 Q. Would you agree that this ridge formation in our14 area is a product of glacial action at some point?15 Sorry.16 A. Would you agree that this ridge formation is a17 Q. product of glacial action at some point?18 It's a product of, it was, it was a product19 A. before the glacier arrived.20 Igneous intrusion was much earlier, millions of21 Q. years earlier?22 Hundreds of millions.23 A. Hundreds of millions.24 Q. Years ago earlier glaciers though, tens of25 54 thousands of years ago, carved out ridges and left1 ridges, is that fair to say?2 There was a tremendous force of ice on top of the3 A. rock.4 Right. And so these ridges collapsed either5 Q. because -- well, ice or because the force of ice moving,6 is that fair to say?7 They didn't necessarily collapse. I don't know8 A. that they collapsed.9 Well, the ridge didn't exist naturally, like that10 Q. part was cut away from by glacial impact leaving the11 ridge, is that correct?12 I think the ridge is the end of the, of the13 A. volcanic flow, I am not sure. I am not a geologist.14 I don't want you to answer if you can't.15 Q. I can't. I am not, it's my impression that16 A. that's the end of the flow of the lava.17 You don't know really as a base of expertise?18 Q. No.19 A. Okay. Then I will not trouble you with these20 Q. questions.21 Now, we spoke last time and you said that in your22 view the 1.5 safety factor in the Army Corps Manual was23 appropriate for this project and that the 2.0 factor24 would normally be for projects like dams and things like25 55 that?1 Correct.2 A. And you said however, if the building were built3 Q. on a slope you would apply the 2.0 factor?4 Yes, that's what, that's what I would do. Not5 A. because it is required, but that's what I would do.6 As a matter of engineering practice that's what7 Q. you would do if it was built on a slope?8 Yeah, but the buildings aren't being built on a9 A. slope.10 But if a building was built on a slope it11

6 As a matter of engineering practice that's what7 Q. you would do if it was built on a slope?8 Yeah, but the buildings aren't being built on a9 A. slope.10 But if a building was built on a slope it11 Q. wouldn't be resting on the soils, it would be excavated12 into the bedrock that forms the ridge, right?13 I don't know. Depends on the design.14 A. MR. KLEIN: But it's not built on the slope.15 MR. AFRAN: The point I am raising, you16 don't want to build on topsoil. The question is, he17 would've given it a 2.0 safety factor if it was built on18 the slope, which means it is anchored into the bedrock,19 it is the same bedrock structure being anchored to on20 top.21 MR. PLOCKER: Bruce, you have an engineering22 degree? You're testifying as an engineer.23 MR. AFRAN: I am proposing a problem to a24 witness.25 56 So if in fact you build on the slope would it be1 Q. anchored into the same bedrock structure as that would2 be anchored when it is on top?3 Why would you give it a 2.0 only when it's4 anchored on a slope and not on top?5 We are not talking about stability of the6 A. structure. We are talking about the stability of the7 slope.8 I know. So why would you use a 2.0 safety factor9 Q. if anchored in bedrock on the slope but if not anchored10 in the same bedrock on soil?11 Because the forces would be much higher on it if12 A. it was on the slope than they would be if it was --13 where they're going to put it.14 Now, if the rock under this Building D were15 Q. fractured and not properly grouted and if there are16 other friable or destabilizing elements under that rock17 the entire structure collapses and with it part of the18 slope, isn't that fair to say?19 No, it is not fair to say.20 A. Well, the structure collapses on the rock under21 Q. the structure it would go down part on the slope,22 wouldn't it, it would have to?23 This is not an extremely heavy building and it's,24 A. and the condition of the rock and there are buildings25