December 3, 2025 Regular Meeting - WEHI Transcript

01/05/2026 02:58:16 PM Page 61 to 64 of 68 16 of 17 sheets 61 functions, do they?1 No, but in other references they reference 1.5 as2 A. adequate for slopes.3 Yes, but in Section 8-13A it says, Where the4 Q. failure of a slope will have severe consequences, the5 appropriate standard is 2.0. Isn't that what it says,6 "yes" or "no"? Isn't that what the Army Corps Manual7 says.8 That's what it says for the structures that you9 A. are talking about and this is not what they're talking10 about.11 Well, I am going to hand this to you and take a12 Q. look at 8.13, does it have any reference to limitation13 to dams and things of that nature. And if you could14 find it please show it to me.15 I brought the wrong pair of glasses today, do you16 A. want to read it to me.17 I am not going to read 8 paragraphs. Well, you18 Q. know, let me get back to that.19 You know the Army Corps, right?20 Sorry.21 A. You know the Army Corps Manual, right?22 Q. I know it exists. I can't quote it chapter and23 A. verse. I don't know what you mean, do I know. Yes, I24 downloaded it, I looked through it and your references25 62 for situations that we are in 1.5 is adequate.1 And you're not in a position to dispute that2 Q. because you don't have your glasses, that Section 8-13A3 3G does not refer to specialized projects such as dams4 and things like that?5 I believe it does.6 A. 8-13A, "For major rock slopes where the7 Q. consequence of failure is severe, the minimum required8 calculated factor of safety is 2.0."9 This is not a rock slope to begin with. It's a10 A. soil slope for the most part.11 Well, we have been analyzing the rock strength12 Q. all along, now you tell us it's not a rock slope?13 None of the failure surfaces that were referenced14 A. as significant in the reports were passing through rock.15 They were passing through soil.16 Well, we have analyzed rock repeatedly in your17 Q. presentation and in your report and you made the point,18 you made the point that there could be joints that we19 don't know about and you say there are thousands of20 smaller joints and it seems to me the purpose of talking21 about that was because failure of that rock could have22 severe consequences. Isn't that why you talked about it23 in your report? Isn't that why you talked about it in24 your report.25 63 I talked about it as a precaution that you would1 A. usually take into account in your

s. Isn't that why you talked about it23 in your report? Isn't that why you talked about it in24 your report.25 63 I talked about it as a precaution that you would1 A. usually take into account in your design. You always --2 it could occur, I don't know that it does occur.3 None of us have that skill to predict the future4 Q. and engineering is designed to take into account things5 we may not expect to happen but may very well, isn't6 that correct?7 Very well. But for this case the safety factor8 A. of 1.5 is adequate, in my opinion.9 And you would agree however your report focuses10 Q. on rock safety, doesn't it?11 Sorry.12 A. And you would agree that your report focuses13 Q. almost entirely on the safety and structure of the rock,14 isn't that true?15 We do reference in a number of areas precautions16 A. that should be taken when you have rock underlining a17 slope.18 Almost all of your report deals with quality and19 Q. structure and safety of the rock, isn't that true?20 Well, it's true but the stability analyses of the21 A. rock, the rock does not come into play that were done by22 both engineering firms.23 I'm simply asking if this slope where rock is a24 Q. major feature, not the failure of it, would fall under25 64 Section 8-13?1 But the stability analyses don't exist, don't2 A. indicate that there would be a failure.3 Well, 8-13 doesn't say only if the stability4 Q. analyses indicates a likelihood. It simply says, "Where5 the consequence of failure is severe the minimum6 required factor is 2.0."7 What you're referencing is a design manual for8 A. heavy-duty engineering projects and this is not. That's9 not applicable, in my opinion, to this particular10 situation.11 And you're saying that Section 7-12, which refers12 Q. to safety factor 1.5 for other kinds of buildings is --13 strike that.14 You would agree that Section 7-12, which refers15 to the 1.5 safety factor, is in this same section of the16 manual, isn't it? They're in the same section of the17 manual, aren't they? You want my glasses.18 CHAIRMAN BAGOFF: Mr. Afran, last question.19 THE WITNESS: Okay. From the same manual20 there's, I think 7.12 and what it says, for retaining21 walls ordinary type structures a safety factor of 1.5 is22 adequate.23 I know. And that's the same section as 8-13 that24 Q. refers to places where it can be major consequences the25