Free Motion in Limine - District Court of Federal Claims - federal

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Case 1:03-cv-00600-EJD

Document 66-6

Filed 01/23/2008

Page 1 of 36

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS
CHEYENNE RIVER SIOUX
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CIVIL NO.

TRIBE, ET AL.,

03-600-L

PLAINTIFFS,
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) )

DEPOSITION OF

JEFF MCCLENATHA

VS.
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)
)

THE UNITED STATES OF
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)
")

AMERICA,
DEFENDANT.

TAKEN ON BEHALF OF

) ) )

PLAINTIFFS

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DEPOSITION OF JEFF MCCLENATHA taken before Susan M. McKenzie, General Notary Public within and for the State of Nebraska, beginning at 1: 20 p. m. on August 24, 2006, at the offices of the United States Corps of Engineers, 106 15th Street, Omaha, Nebraska.

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1 APPEARANCES
2 ON BEHALF OF PlANTFF:
MS. PAMELA SNYDER-VARNS
3 Gunderson, Palmer, Goodsell & Nelson, LLP

1 (Whereupon, the following proceedings were

2 had, to-wit:)

American Memorial Life Building
4 440 Mt. Rushmore Road

3 JEFF MCCLENATHAN
4 having been first duly sworn
5 was examined and testified as follows:

Rapid City, SD 57709
5 (605) 342-1078 Fax (605) 342-9503

and
6 MS. TRCEY FISCHER Cheyenne River Sioux Tribal Attorney
7 Box 1, Fort Pierre, SD 57532

6 DIRECT EXMINATION
7 BY MS. SNYDER-VARNS:

8 Q Would you stte your name for the record?
9 A Full name?

(605) 223-9099 Fax (605) 223-9199

8
ON BEHALF OF DEFENDANT:

9 MR. JAMES D. GET
U.s. Departent of Justice
10 Environment & Natural Resources Division 601 D Street NW
11 Washington D.C. 20004
(202) 305-1461 Fax (202) 514-8865

10 Q Please.
11 A Jeffrey Todd McClenathan. 12 Q Have you had your deposition taken before?

13 A No.
14 Q We just met a moment ago, Mr. McClenathan.
15 My name is Pam Snyder-Yarns. I represent the 16 Plaintiffs in this matter. I want to just go over a 17 few ground rules for depositions.

12 and MR. THOMAS J. INGRAM, N, Asistnt District Counsel 13 US Army Corps of Engineers 106 South 15th Street
14 Omaha, NE 68102

(402) 221-7599 Fax (402) 221-061
15

18 The court reporter here is the most
19 importnt person in the room. And

16 ALSO PRESENT: UNDA BURKE 17 18 19

if you could just

20 remember to stte your answers out loud as opposed to
21 shaking your head or shrugging your shoulders.

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22 The other thing would be -- and this is
23 more my problem than usually the witness' -- but if 24 you could just try to remember not to talk at the 25 same time as I'm talking. It's diffcult for her to
Page 3

2 CASE CAPTION. . . . . . . . . . . . .. Page 1 APPEARANCES. . . . . . . . . . . . .. Page 2
3 INDEX................. Page 3 STPULATIONS. . . . . . . . . . . . .. Page 5 4 TESTMONY............... Page 4
REPORTER CERTIFICATE. . . . . . . . .. Page 136

1 INDEX

Page 5

1 get down both of us when we're speaking at the same

2 time.

3

If you don't understand my question, just

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5

let me know and I will rephrase. And if you need a
break, just let me or Mr. Gette know and we'll take a break.

5 COST CERTIFICATE. . . . . . . . . . .. Page 137
READ &

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7 8

SIGN LETR........... Page 138

6 ERRATA SHEET. . . . . . . . . . . . .. Page 139
7 DIRECT EXAMINATION
By Ms. Snyder-Yarns ........ Page 4

What is your business address? A It's 106 South 15th Street, Omaha,
Nebraska, 68102.

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CROSS EXMINATION By Mr. Gette . . . . . . . . . . . . Page 122

Q And what is your profession? A I'm a Civil Engineer, but the title at the
Corp of Engineers

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is Hydraulic Engineer.

Q And what is your education? Can you run through that? A I graduated from Iowa State University in
1982 with a bachelor's of science degree in Civil Engineering, and then received my master's from

University of Nebraska at Lincoln in Water Resources
and Environmental Engineering in '96.

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Q Are you a certified engineer? A I'm a professional engineer in the State of
Nebraska.

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Q Registered I should say as opposed to
certified?

A Yeah.
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1

Q
A

And it looks from your bio that you're a

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the Hydraulic Section?

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member of ASCE and ASME.

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I'm a member of the American Society of Civil Engineers, and I used to mentor for the Society of Military Engineers. I was only a member one year

A It's to organize workload, oversee the work, review it, sometimes review contract with

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architect and engineers. And that's the gamut of

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I think.
Q
A

the work that we do. Q What does the section do?
A

Okay. And you're employed with the Corp of
Yes.

Its primary purpose -- this is kind of

Engineers?
Q

broad -- we support civil works project, miltary
and hazardous and toxic waste project as far as the hydraulic design of those project, which may include
design of culvert, bridges, floodplain modeling,

How long have you been with the Corps? Since 1982. So it's been 24 years. 12 Q So you went to work for them right out of 13 college?
A A

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Q
A

Yes. Okay. And when you went to work for them,

what did you do?
I started out on what was called the -what's called now the Department of Army Intern

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Program where I rotated around for two years before I got a full-time permanent position in the Hydraulic

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water surface profie determinations, ice jam modeling, design of structures, like drop structures, dams, spilways, we do floodways occasionally, things like that. Q What is Hydraulic Engineering? We basically model like the riverine A system with computer models usually and determine the water surface profile for given flood events.
Q When you say the riverine system, you mean both the ground and the water?
A

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Section.
Q So you've been with the Hydraulic Secion since 1984?
A

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Not groundwater, no.

Q
A

When you say riverine systemi I'm just
Yeahi the moving water. Yes.

Yes.

trying to understand, do you mean the water?

Q

What have you done within that section?
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A

You mean -- do you want a list of project
Well, more what positions have you held

Q
A

Okay. So it's water movement-Uh-huh.
-- that Hydraulics deals with?

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or -Q
A
within the section.

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Q
A

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Yes, primarily.

Oh, okay. I had various stff positions at

Q
A

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different grades. And then I was a technical specialist at one time. Now I've been converted over
to a Section Chief.

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What else? I guess I'm not sure what you mean.

Q
A

And you're the Chief of the Hydraulic
Yes.

Section?

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Q Well, when you said "primarily," that indicated there might be something else besides the

movement of water.
A Sometimes we'll do a little cross-training between sectonsi so there's a little overlap. Q With the other sections in the Hydrologic Engineering Branch? A Yes. Q Okay. Nowi I'm looking at your bio from

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Q . How many sections within the Engineering
Division are in the Omaha District?
A

Well, I don't know about the Engineering

Division. Q The Hydraulic Engineering division. A Oh, the Hydraulic Engineering, there's five.
Q
A

What are those sections?
There's the Hydraulic Section, the

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the website, the Omaha District website. And it
mentions that you do design of hydraulic stuctures including stillng basinsi outlet works, spilways, pen stocks, drop structures, levies and bank erosion protection. What is the purpose of these structures?

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Floodplain Management Section, the Channel Stabilzation and Sedimentation Section i the Water
Control Section, and then the Hydrology and

Meteorlogical Section. Q What are your responsibilties as Chief of

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Or do they have varying purposes? A They have varying purposes. Q What about stiling basins? A Stillng basins are primarily used a lot of

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1 times lik~ on dam structures. Or anywhere you have

1 protection. There's vegetation mats, concrete
2 cellular mats, Fabri-Form. And then that's prett

2 high velocity water that if you just let the water
3 go, it has tremendous energy and erodes the bank and
4 th,e channeL. And the stiling basin basically forms

3 much it for the programs.
4 What was the rest of your question?

5 what we call a hydraulic jump that causes the water
6 to dissipate the energy.

5 Q Well, I was asking about bank erosion
6 protectioni what does that consist of. And you said

7 Q Okay. What about outlet works?
8 A What was that?

7 it's really quite broad.

8 A Well, yeah. We're just trying to protect
9 the bank from erosion from the velocity of the moving

9 Q What are outlet works?
10 A Outlet works tend to include -- like on
11 damsi it would be the actual intakei the conduit 12 through the dam and the stiling basin.

10 water. 11 Q And you have a multitude of tools and
12 methodologies available to you to do that?

13 Q Spillways are part of a dam?
14 A Yes, every dam usually has a spillway to
15 help pass extreme events and not fail the dam.

13 A Yes.
14 Q And you utilize those in the course of your
15 work as a part of the Hydraulic Section?

16 Q What are pen stocks?
17 A Pen stocks are large pipes that lead into
18 the turbines in hydropower generation facilities on
19 dams.

16 A On an as-needed basis.
17 Q You also do hydraulic modeling. What is

18 that?
19 A That is primarily the modeling of a stream
20 system. Like usually we'll be asked to study say 21 like flood control in a town along a stream that's 22 been getting flooded in the past. And we'll do a 23 model of the existing conditions of the stream, set 24 various frequency water surface elevations to help 25 determine damages, and then we'll model various
.

20 Q And drop structuresi what are those? 21 A Drop structLJesare structures along a
22 stream bed. When -- say you've had some erosion or 23 downcutting of the stream and you don't want the 24 stream to deepen, you'll put in a structure that

25 props the water down and helps dissipate the energy.
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1 Q And levies and bank erosion protection,
2 those are -- are levies a means of bank erosion

1 proposed alternatives to protect the town and create
2 water surfaces for those so that economic benefits

3 protection?

3 can be calculatedi and then we'll use that
4 information to selec a plan.

4 A No. Levies are used to provide protecon
5 to areas that are in the floodplain. And so they're

5 Q What sort of data is inputted into your
6 modeling?

6 constructed to keep the water from flooding that

7 area. Bank protection is a means of preventing
8 erosion of a bank from riverine forces.

7 A The data that's typically put into our
8 model are geometric cross-sectionsi because the
9 primary model we use is a one-dimensional modeL. So

9 Q And you have various tools to do thati
10 don't you?

10 we collect cross-section data. We typically like to

11 A And various programs. Yes.

11 do it mapping if we can, but it can be pricey.

12 Q And what are those?
13 A Wow. You want the entire list?
14 Q Well, if you could run through it and then
15 summarize.

12 Q And cross-sectonal data is cross-sections
13 of the --

14 A The river and the floodplain. And then we
15 need to estimate roughness valuesi lost coeffcients
16 for expansion and contractioni and then we nee to

16 A There's actually a number of methods
17 besides erosion protection. We primarily use rock, .
19 to do that is based on one of our engineering

17 get input as far as the discharges to be modeled. 18 what we call riprap. And one of the programs we use 18 Q And is discharge basically the flow of the
19 water course?

20 manuals. I think It's 1110-2-1601, Hydraulic Design
21 of Flood Control Manuals. And there's a program that

20 A Yes. We usually measure it in cubic feet 21 per second.

22 one of our labs has developed that we use for that
23 called Channel Pro. A lot of times we'll also design

22 Q A flow rate? 23 A Yes.
24 Q Your section coordinates physical hydraulic
25 modeling as needed for individual project. What

24 it by hand as welL.

25 And then there are other types of channel

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does that mean?
A

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water modeli you're working your way back upstream.
Q
A

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On occasion when we get complex flow

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problems like a stilling basin or what we call rapid flow i we will go to a laboratory the Corps has in
Vicksburg, Mississippi, and they'll do a scale model of the problem for us that will help us better estimate the flow characteristics and water levels. Q And so you coordinate between the location within the Omaha District and the lab in Mississippi? A Yes.
Q
A

What is UNET modeling? UNET modeling is an unsteady flow model

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which looks at fully dynamic modelingi and it wil allow us to actually route the entire hydrograph and. look at how the riverine system does storage and
allows you to divert water and do various

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What's the lab called?

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It used to believe called Waterways Experiment Station i but now It's called ERDCI

Engineering Research and Development Center. And I
think it's referred to as the Vicksburg offce.
Q

And I think I interrupted you. You were

talking about coordinating between the lab and -A Yes. What we'll do if we feel like we have one of those situations -- a lot of times like with
the stilling basin

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applications with it. Q What is rating curve development for spilways? A For spilwaysi we would usually develop a rating curve to determine what the discharge would be
at a certin pool elevation. And the rating curve is

basically that if the pool is at this elevation, the

discharge for the spilway would be X cubic feet per second.
Q You've worked with wave reflection analysis at tainer gates. What is that?
A

We had some gUidelines that indicated that

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i it has special needs -- we'll prepare a request to do it. And we typically get

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when we were designing gatesi that the wave reflection would be twice the height of the incoming

approvali prepare all the information for them to do the modelingi go down and periodically oversee the
modelingi and work with them on the results and

perhaps what alternatives would be done, and then
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wave. But we had some tainer -- and that makes some
theoretical assumptions. And we thought we were overdesigning. So we worked with Vicksburgi the Waterways Experiment Stationi to do a model study to

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they'd prepare a final report, send it to us, and
he'd incorporate that data in our design.

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Q When did you say that lab does the modeling as opposed to the Hydraulic Section?

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Weili they actually do -- most of the time for us they do physical modeling where they actually set up an actual scale model, like a 1-to-25 scale model, which means one inch on the model is 25 feet in length, and then they'll run these test through
A

show what the actual wave reflection height would be. Q So that helped you with the design of what? A Weili actually we had existing gates that we weren't sure if they were adequate. So that helped us with the loading on that gatei and then the structure was resized for the gate accordingly.
Q
A

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On a particular dam? Yesi I think we did it on all six main
And you thought maybe the gates were too

stems that were checked. Yes.

that scale model so we can observe what happens. Q It looks like you have some experience with
softarei modeling softare.

Q

large?
A

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Weili it didn't have anything to do with

A

Yes.
What is HEC-2 and HEC-RAS?

Q
A

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HEC-2 is often referred to as a back water program. It was DOS based. And HEC-RAS is -- they

cali it the next generation of that softare. And it
is also a -- they call it a back water program, but it's a --I think the actual term is a steady stte
uniform model.

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the sizei just whether or not they met the factor of safety for the dynamic loading. So the result was we went in and added some steel to some of them to make
them meet those factors of safety.
Q
A
Okay. You've begun some work with FEMA?

Yeah, I've done some floodplain modeling

and some flood wave development. Yes.
Q And it looks from your bio that that was associated with the Lorna Prieta earthquake in 1989.
A

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Q Why do they call it a back water program? A Most of the time in a riverine system, your water is controlled by what's going on downsteam
from your area. And so we usually strt down there

and make calculations upsteam. So it's like a back

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Q

Oh, that is different. I'm sorry. Okay. So what is what you were talking
Weili sometimes when we do floodplain

about?
A

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1

2 3

modeling, we'd end up submitting like the revised floodplain for -- with the town being in place to
FEMA to get the flood insurance study updated. Q And FEMA does flood insurance studies
across the nation?

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rainfalli and Spirit Lake was unusually high. And

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there was a railroad embankment between it and East
Lake Okoboji that was seeping and looked like it was
on the brink of failng. So we looked at increasing

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They're responsible for those, yes. So you do modeling of floodplains for those studies?
A

Q

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the structure size through that embankment to help bring the lake down more quickly. Q What about flood support in '97 at Sioux Fallsi South Dakota; what did that consist of?

A A

Yes. The Loma Prieta was different.

A . That was another advanced measure. They
had a large snowpack upstream that indicated they

Q And you did some modeling for the 2002 flood insurance study within the Omaha District on the Indian reservations up in South Dakota. Do you recall that? A My section didn't do that. We also have a Floodplain Management Section that typically finalizes everyhing and submits it to FEMA. Q
A
So the Hydraulic Section did not do that

could have a large flood event at Sioux Falls. So we
went out and did some quick modeling and let some contract to raise the levies quickly to help try to contain that flow.
Q
A

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modeling?
No.

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What is Section 22? Section 22 is what we call our Planning

Assistance to States Tribes Authority where we're allowed to go out and do analysis with a sponsor at a

SO/50 cost sharei whether it be floodplainsi
environmentali whatever, but we're usually restricted

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Q
A

The Floodplain Management Sèction did? Yeah. The way the division is is we'll

from doing design.
Q
A

And you've worked on numerous Section 205

usually do a lot of that workup on the design
project we do, but they will also just get work from FEMA or states or under their floodplain authorities
Page 19

project. What are those?

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Those are -- they're called small flood

control project. And those would be like the
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and do other floodplain studies. Q What was the Lorna Prieta earthquake work

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2
3

Hamburg, Iowa, we've just done one at Penderi and we're looking at one at Fremont. Just flood

that you did?
A
That was emergency response work. You

protection for small communities. They're determined
by the amount of money you can spend on the fix. Q And then also general investigations

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might know it as the Oakland earthquake. We went out and did an individual assistance for FEMA in the Santa Cruz cruise area. Q What do you mean by individual assistnce? A We went out to individual homes that had

studies. What does that mean?
A Those are the larger studies. They can even be as big as basin-wide studies. And they require a congressional authorization and local sponsor support and cost share as welL. Q These are all things that the Hydraulic

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asked for damage assistance and did an assessment as
to the damage of the home and potential cost and
fixes for that.

Section does?
A

Q
A

Q
A

You did flood support in 1993 -Yes. -- at the Iowa Great Lakes in Hamburg,
Yes. What was that?

Q
A

Yes. Are you a member of any Corps committees
No.
Have you ever heard of CERL?

within the Corps of Engineers?
Q
A

lowai locations I guess?
Q
A

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Is that the Civil Engineering Research Lab?

We wil periodically during floods be

Q
A

I believe so.
Yes.

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called out to provide technical assistance. And in '93 -- we actually have another authority that allows us to do advanced measures. If we know flooding is

eminenti and we can show thati we can go out and put
measures on the ground to help reduce that impact. In '931 there was a large amount of

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Q
A

I take it you don't work with them on a
Not the civil engineering one, no.

regular basis?

You did say CERL¡ right?
Q

I did. Is that the one in Vermont?
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1 A No.
2 Q Okay. John Remus testified yesterday about
3 CERL. It's in his -4 MR. INGRAM: That's CRREL, Cold
5 Regions Research & Engineering Lab.

1 A I've had quite a bit. I've had training in
2 HEC-2, HEC-1, SAM, I've had a class on hydraulic
3 design of flood control channels, a class on
4 hydraulic design of outlet works, class on hydraulic

5 design of spilways.

6 MS. SNYDER-VARNS: Oh, CRREL.
7 THE WITNESS: Yeah. There's two. 8 MS. SNYDER-VARNS: Sorry about that. 9 MR. INGRAM: There is a CERL.
10 BY MS. SNYDER-VARNS:

6 Q So you've had training in softare,
7 training in hydraulic design?

8 A Yes.
9 Q And what other categories? It's okay to 10 categorize them.

11 Q What are these labs around the country that
12 the Corps has? There's the one in Mississippi and 13 then the one in Vermont and then --

11 A Oh, okay. I'm sorry.
12 Q. I don't need every last one. 13 A I've had quite a bit of technical training,
14 but also supervisory training, I've had some other 15 training like effective meetings and presentations 16 and--

14 A Yeah, there's actually a number of them.
15 And they're all kind of research type oriented labs
16 that look at long-range solutions, usually help

17 maintain our softare and provide assistnce as
18 needed to the district.

17 Q So the technical training is what I'm more
18 interested in. Anything other than what you've

19 Q And the one that you tend to work with is
20 in Mississippi?

19 already told me about?

20 A I've attended I know an ice jam -- or an
21 ice workshop in Wisconsin offered by Wisconsin
22 University Extension. I've had RAS on Study Flow

21 A We work both with the one in Mississippii
22 the one in Hanover, and the one in Davis, California.

23 Q What is the one in Hanover?
24 A Hanover is the Cold Regions Research and

23 Modeling, I've had some -- boy.

24 Q Do you have a list of the training that

25 Engineering Lab. We wil work with them on ice jams 25 you've had somewhere?
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Page 25

1 and ice jam modeling.

1 A Yeahi I have it somewhere. If you want, I
2 can provide it for you.

2 Q How often do you work with that lab?

3 A It's kind of on an as-needed basis. So
4 just whenever we have a project where ice jams are a
5 problem and we need to model those for -- usually for
6 the design or identifying potential problems with the

3 Q I would appreceiate that. 4 A Okay.
5 Q Nowi the web page gives us a list of the
6 services provided by the Hydraulic Section. And when

7 studies we're requested to do.

7 I took a look at thati I noticed that the list for
8 the Hydraulic Section was identical to that of the 9 Sedimentation and Channel Stabilization section; is

8 Q Does that tend to occur a couple times a
9 year, every couple years? Can you give me an

10 estimate?

10 that correct?

11 A It's kind of sporadic. You know, we might
12 get a couple studies at once. Like I think we had

11 A Yes. We had the same person post thosei
12 and I think they got confused. We've been meaning to 13 change it and haven't done it yet.

13 two studies in Montana that we were kind of doing
14 that on, and then we won't have anything for awhile.

15 Q For a period of months or years --

16 A It could even be years.
17 Q Okay. What about the one in Davis,
18 California?

14 Q So the list are not actually the same? 15 A We'll sometimes work on the same projecti 16 yes.
17 Q What services does the Hydraulic Section
18 provide? If the list was correcti what would it be?

19 A Davis, California, is the Hydrologic
20 Engineering Center. And they write most of the
21 softare that we use, any of the HEC softare comes

19 A It would list a lot of those things we've
20 talking abouti sizing of hydraulic structuresi flood 21 works, spilways, floodplain studies as far as 22 riverine modelingi ice jam analysis.
.

22 out of there, and they provide support to us on that 23 as well as training.

24 Q What training have you had since you've
25 been with the Corp of Engineers?

23 Q For whom do you perform these services? 24 A We perform them for people that request
25 them from us. We're kind of like a mini firm inside

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1 the Corps. We only work when people ask us to work.

1 Q James Riveri South Dakota?

2 Q So you provide the services within and
3 without the Corps?

2 A We're doing a general investigation study
3 therei and we're basically modeling the entire James

4 A We primarily provide them within the Corps.
5 But occasionally, like under the Section 221 it would
6 be at the request of a local sponsori as well as with

4 River in South Dakota for the James River Water

5 Commission.

6 Q And when you model the entire riveri what
7 does that consist of?

7 the civil works project. There's usually a local

8 sponsor that actually initiates those project.

8 A In conjunction with them, we received
9 mappings, so we've setup a HEC-RA steady state

9 Q The Omaha District website also has a list
10 of current project for the Hydraulic Section, and

11 that also was the same as for the Sedimentation and

10 model and provided flood profies and flood 11 boundaries for -- well, flood profies for the ten-,
12 50-1 hundred- and 500-year event and flood boundaries

12 Channelization Section.

13 A We've been meaning to do that.
14 Q If that list under the Hydraulic Section
15 isn't an accurate list, what current project does
16 the Hydraulic Section have going?

13 for the hundred- and 500-year event. 14 Q So it's a general investigation that is
15 focused on flooding?

16 A Most of the work we do is focused on
17 flooding. 18 Q And Livingstoni Montana, what are you doing

17 A We're stil working on Sioux Falls, South
18 Dakotai although it's kind of in construction, some
19 of it. Perry Creek is kind of finishing up. Perry

20 Creeki Iowa, and Sioux Cityi lowai is finishing up 21 construction hopefully this year. We're doing some 22 studies at Fremont, Nebraskai Denveri Coloradoi the 23 Yellow Stone River in Montana, the James River in 24 South Dakota, we're doing some work at Livingstoni 25 Montana, doing some work in Greeley, Coloradoi and
Page 27
1 then we're doing some work at Fort Carsoni the base
2 of Fort Carson in Colorado, and Schuyler, Nebraska.

19 there? 20 A It's another Section 205 where the city has
21 some areas that may be flood pronei and we've
22 finished up the existing conditions and we're looking

23 at alternatives.
24 Q And Greeleyi Coloradoi and Fort Carson?

25 A Greeleyi Colorado is another -- I think
Page 29

3 Q When you say "studies/, what do you mean? 4 A Most of these are all what we would deem as
5 civil works studies. They're a mix of the general

1 it's a Section -- I can't remember if that's a 205 2 OSHA GI, but once again, it's focused on flooding. 3 They've had a history of flooding in the area. But
4 that one is also going to be combined with

5 environmental restorations.

6 investigation, the GIs and the Secion 205s.

6 Q When you do environmental restoration, what
7 is that usually? What can that or does that consist

7 Q What is Denver?

8 A In Denver we're actually working on a
9 couple different things. The main one is we're

8 of?

10 looking at reallocting storage in Chatvile Dam for 11 water supply, and we're doing some of the hydraulic 12 analysis for that to determine the impact of that
13 downstream.

kind of 10 changes to the stream, and we'll try to help restore
9 A We'll try to -- there's been some

11 it back to a more native habitat. Like in Greeley,
12 it's been straightened and channelized, and we didn't

13 do it.

14 Q Anything else at Denver? 15 A We're actually doing a Section 206 at
16 Boulder, which is an environmental restoration, on 17 Goose Creek. And we're kind of in the midst of a dam 18 safety study at Cherry Creek in Denver at welL.

14 Q 15 A
16 17 18 19

Sure.
Sorry .

And so we're going to try to help them -at their requesti try to help them find some kind of environmental alternative to help restore some of

19 Q What about Fremont -- is that Minnesota?

20 A No, Nebraska.
21 Q Sorry. What is that? 22 A We're doing a Section 205. They would like
23 to provide flood protection to the southern part of 24 Fremont. We're looking four alternatives assoiated

25 with that.

20 21 22 23 24 25

that. Q And what about Fort Carson?

A Fort Carson, at the request of the basei
we're doing some updated studies on the Teller Dam up

there. Q Schuyler, Colorado? A Again, that's Nebraska. That's another

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1

Section 205 where part of the city is in the
floodplain and they want us to look at alternatives to take them out. Q Nowi you direct the Hydraulic Section
within the Hydrologic Engineering Division or Branch.

1

surveyed.
Why? To get the most updated information. Q Who determined which cross-sections to survey? A I think that was the Channel Stabilization and Sedimentation Section. Q The ones who went out and actually did the surveys?
Q
A
A Yeah. I don't think they had enough funding to do them alii so they had to select which ones they thought were most important.

2 3

2 3

4
5

4
5

6 7 8 9 10
11 12 13 14 15

Is that prett much an independent section or -- or I guess -- what is the organizational structure between
your section and the rest of the Hydrologic Engineering Branch? A We all report to the Chief of Hydrologic Engineering Branch, which is Larry Bussi and so they each have a section chief. So we kind of are all

along the same leveli and we tend to work together
and exchange workload if it's too heavy or too slow. Q So you do work for other sections within
the branch?

16 17 18 19 20 21 22 23 24 25

A

Occasionally, yes.

Q Ifthere's another section that you work with more than others, what would that be? A I think it -- it's probably a tie between the Floodplain Management Section and the Channel Stabilzation and Sedimentation Section. Q Jeff, I'm going to show you what's been marked as Exhibit No.7. Can you tell me whatthat
is?

Okay. So it would have been John that made the decisions as to which cross-sections to survey? A I think that might have been made before he 20 21 went out in the field, but I'm not sure. 22 Q So it might have been made by somebody 23 above him like John Remus? A Yeah, I guess -- I'm not sure. 24
Q

6 7 8 9 10 11 12 13 14 15 16 17 18 19

Q

And are you aware of who actually went out

and did the surveys? A I know Neal Voll helped John Garrison with some of them. I don't remember if anybody else did
the others.

25
Page 31

Q

What generated this study?
Page 33

1

A

That is a report that we prepared for a

1

A

We had a request to do the study, and they
Who is "they"?

2 3

aggradation study on the Moreau Riveri South Dakota.
Q
A

2
3

provided funding, so we did that.
Q
A

And I understnd you performed this study?

4
5

No. I supervised it. Neal Voll in my section actually did most of the actual work.
Q
A
So Neal would be considered the author of
the report?

4
5 6 7

The liaison we had for doing this study was John Remus. He did most of the other coordination

6 7 8 9 10
11 12

He prepared it and I revised it as needed.
Who is Neal Voii? He is a Civil Engineer in the Hydraulic

8
9 10
11 12 13

Q
A

with I believe -- well, I think it was Operations, but I'm not sure. Q When you say "they provided funding/, what sort of funding are we talking about? A The amount?
Q
A

Section.
Q
A

Yeah.

Did anybody else contribute to this
We obtained the cross-section information

Okay. I think including -- and this isn't

13 14 15 16 17 18 19

aggradation study?

an exact number. I think including Neal's time in

from the Channel Stabilzation and Sedimentation Section -- or the survey information -- or the information they had surveyed.
Q
A

And who specifically in that section?

I believe most of it was obtained by John

14 15 16 17 18 19

the field, it was about $15,000.
Q And the funding came from Operations you believe?
A Yeah, I think probably it came from the Oahe project. And there's prett strict funding

20
21 22 23

Garrisoni and Neal Voll assisted him in the field in
obtaining the surveys.

20
21

rules, so -Q But you don't know specifically where the

Q

So you obtained both existing data and then

24 25

went out and did more surveys to get more data? A They -- I think we had them resurvey some
of the cross-sections that they historically

22 23 24 25

funding came from? A It should have came from the Oahe project,
Operations Maintenance funds. Q Why? A That's kind of the way the rules are, that

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1 we can't use Oahe money to study like Garrison Dam or
- 2 vice versa.

1 A Our liaison for this was John Remus. 2 Q What were the design parameters for this
3 study?

3 Q So if a project or a study involves a
4 particular project, then the funding for the study

4 A When you say "design parameters," what do
5 you mean specifically?

5 would come from that project?

6 A For something concerning something like
7 this, Operations and Maintenance, yes.

6 Q What was the breadth of this study?
7 A You mean the --

8 Q So this is considered an Operations and
9 Maintenance type study or implicates Operations and 10 Maintenance -- explain to me what you mean by that.

8 Q i know that's it's a reconnaissance level
9 study. I know it's not real thick. So in other 10 words, it's not a detailedi in-depth kind of study. 11 So what were the limits of the structurei I guess you 12 would say, of the study?

11 A I'm not a funding guru. But the study came
12 about because of the presence of the dam. And as a
13 result, it is kind of considered to be -- our only 14 funding source is to get the funding from Operations 15 and Maintenance. It's called O&M. That's one of the 16 pots of money we'd get every year. It's to help

13 A Limits of the structure?
14 Q Would it help just to go through the study
15 and talk about the input and the variables that you
16 used in the modeling?

17 operate and maintain the dam and the associated

17 A That might be -- well, you want me to just
18 talk about it or do you want to ask questions?

18 structures. 19 Q And issues that arise concerning that
20 particular dam?

19 MR. GETE: No.
20 BY MS. SNYDER-VARNS:

21 A Yes.
22 Q How else would a study like this be funded
23 if not from O&M money from Oahe?

21 Q Why don't you answer my question beforei
22 and then we wil go into the study itself and I wil

23 ask you some questions about it.

24 A Typically it depends on how it's
25 requested. You know, we might get a request from a
Page 35
1 local sponsor. It usually has to be some type of

24 A Can you stte your question again?
25 MS. SNYDER-VARNS: Would you read
Page 37
1 back my question, please?

2 taxing authority or governing authority like a city, 3 county, state. Sometimes it's a congressional ad in
4 the funding bils. And that's usually how these

2 (Pending question read back

3 by the reporter).
4 THE WITNESS: I'd have to say that it 5 was -- that we were going to take the most readily
6 available data and do the best study we could with

5 types of -6 Q So if it's not from an O&M budget, it's
7 specific authorization on the congressional

level?

7 that and the funding we were provided.

8 A Well, Section 205 doesn't have to have a
9 specific, but

8 BY MS. SNYDER-VARNS:

a GI does. And those require a cost

9 Q What kind of data?
10 A Well, typically we need the cross-sections.
11 And so -- and we only had surveyed sections 12 historically over timei just selected points. And

10 share as well with a sponsor. 11 Q Did you design this study?
12 A What do you mean by "design"?

13 Q Well, who decided what to study and what
14 data to gather and how to report it?

13 then we would need to assess the roughness values for
14 the HEC-RAS modeli and any bridge data that we could 15 readily get and any flow data that we could readily

15 A Our instructions were that we were going to
16 basically do kind of a reconnaissance thing, which 17 means we usually try to use readily available

16 get.
17 Q Now, when you look at the first page. of the
18 report and you look at what your available data was, 19 can you just tell me what it was?

18 information. So we -- I think we felt it was

19 importnt -- and I don't know exactly who made all of
20 these decisions, but we thought some updated

21 cross-sections were needed where we had historic
22 cross-seions. And then just decided to model as

20 I can see that it involves some topographic 21 maps and some survey data. Can you explain to me
22 what data that you found to -- what data you found 23 that was readily available?

23 far upstream as we could with the money allotted. 24 Q And the instructions that you got came from 25 whom?

24 A Weili the data that was readily available
25 was we had,the seven-and-a-half-minute USGS

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1

topographic quad maps. And then we had some older

1

2 3

War Department maps that were -- and both of those were ten-foot contour maps.
Q
A

2 3

On the second page, that second paragraph. It discusses contraction and expansion coeffcients or valuei at .1 and .3 respectively except at the
A

4
5 6

How many maps are we talking?
Boyi I'd have to guess at that. I don't

4
5

know if I'd be close. But it's a fair number.
Q
A

6

7 8
9

Like hundreds or less than a hundred?

Q
A

It would be less than a hundred. But more than 50?
Probably

10 11 12
13

less than 50.

7 8 9 10
11 12 13 14 15 16 17 18 19

bridge restriction where they were raised to .3 and .5. Q So why were those coeffcients raised at the bridge restriction?
A It's a standard -- those are standard modeling bridge coeffcients of -- the expansion is .5 and the contraction is .3. So we used those on

Q

Okay. So you had both USGS survey maps and

the new Promise Bridge.

War Department maps did you say? A Yeah. They were older. They were dated
around the 1945 to '47 time frame. Q What other data did you find readily available? A Then we had the sediment range lines that

14
15

Nowi it's my understnding this is not just a bridge but an actual -- it's a railroad embankment that extends out into the floodplain of the Moreau, and then there's an opening in this causeway. Is
Q

16 17 18
19

that considered a typical bridge?

MR. GmE: Objection.
You can answer. THE WITNESS: Okay. On the new

have been periodically surveyed over time. And then
I believe Neali when he was out surveying thosei

20 21 22 23 24 25

picked up some bridge information on the new Promise
Bridge when he was out therei measured some pier widths and things. Q So you got technical or physical

20
21 22 23 24 25

Promise Bridge, when we model bridges like that, we wil model the embankments as part of the
cross-section. We usually have the special secton to address that, and we put the piers and the bridge decks in to help also show that that area has been

information about the new Promise Bridge? A Yesi just general type information. Yes.
Page 39

removed from the cross-section.
Page 41

1

Q

What did that consist of?

1

BY MS. SNYDER-VARNS:

2 3

4

s
6 7 8 9 10 11 12 13

A Mostly like the span lengths, the depth of the structure and the bridge pier width. Q Why did you get bridge information? A We were going to use it in the HEC-RAS

2

Q

So you modeled the Promise Bridge and the

3

railroad embankment in some detail?
A Actually, we did not model the railroad bridge; we just modeled the new Promise Bridge. Q Why didn't you model the railroad bridge? A Well, the superstructure had been removed, and we would have had to really estimate the pier

4
5

modeL.

6

Q
A

Did you use it in the model?

Q model?
A

Yes, we did. And why is bridge information part of the
Usually bridges tend to have a loss

7 8 9 10
11 12 13 14

widthsi so -Q

But you didn't model the embankment part

associated with them

i so you get a rise in the water

of that bridge? A I do not believe we did, no.
Q
A

surface as you go upstream through the bridge.
Q

How come?

14
15 16 17 18 19

Why?

Because it was kind of a reconnaissance

A Because the bridge -- depending -- this is kind of generally. But depending on how the bridge is constructed, it can sometimes cause a contraction

15
16 17 18 19

on the floodplain flows. Q Did you find that to be true with the

study. A lot of times when the bridges are that close to each other, sométimes we'll lump them together as one bridge. And we just did .not do that. We just did not model the railroad bridge. Q So you went with the road bridge as oppose

20
21

Promise Bridge on the Moreau? A Yes, there is some head loss through it; in

22 23 24 25

other words,the water surface increases through the
bridge. Q Where in the report, if anywhere, is that

discussed -- or included I should say?

20 to the railroad bridge because they were close 21 together? A Yes, I think so. 22 23 Q Now, had you modeled the railroad briccge, 24 would that be significantly different from modeling 25 the road bridge?

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1

2

MR. GETE: Objection. THE WITNESS: What do you mean I

1 of the superstructure of the bridge.

2 Q And you testified earlier that he didn't
3 get a cross-section of the railroad bridge?

3 guess? 4 BY MS. SNYDER-VARNS:

4 A No. I think our -- actuallyi our first
5 cross-section I think is just downstream from the

5 Q Weili if you just look at them from a
6 layman's perspectivei you can see that the bridge has
7 piers that wouldn't impede the flow of the river or

6 bridge.

7 Q Getting back to the data that was inputted
8 into the modelingi it says that ''The survey data of

8 anything else significantly from a layman's

9 perspective. With the railroad causeway, you have a

10 continuous embankment of land coming out into the 11 floodplain with a small gap where the river channel
12 goes through. It would seem they woul~ be

9 sediment range lines didn't fully cover the region 10 under investigation."

11 A Where is that one at?
12 Q That's in the first paragraph under
13 "Available Data."

13 significantly different as far as their effect on the 14 flow of the river or movement of water in that basin. 15 So that's what I'm asking, is from a layman's 16 perspective, it would seem that there would be a 17 significant difference in including data about the

14 A I think the intent of that sttement is
15 that on a lot of the upper range linesi the survey 16 was only in the channeli and we didn't have the
17 overbank survey.

18 bridge for the road as opposed to data about the
19 railroad embankment in your hydraulic modeling for

18 Q What determines whether you have overbank
19 survey included in the cross-section as opposed to
20 just channel; do you know?

20 this study.
21 MR. GETE: Objection. That wasn't a

21 A As far as for the range lines?
22 Q Weili with these cross-sectionsi if you
23 have just the channel but not the overbank, why would

22 question.
23 24 25
MS.SNYDER-VARNS: Let's go back and read my original question then.

(Pending question read back
Page 43

24 that be? 25 A Because the range lines were set there to
Page 45

1 by the reporter).
2 MR. GETE: I'm going to continue my
3 objection.

1 measure aggradation and not to actually perform 2 modeling. And I think they thought -- and I'm kind
3 of guessing at this. I'm thinking that they thought

4 You can answer that.
5 THE WITNESS: Well, and I'm still not 6 sure -- you mean that we wOI,ld model it differently

4 at that time that the aggradation would remain in the

5 channel of the upper range lines.

6 Q So is it your experience that range lines
7 upstream on tributaries don't always take into
8 account the overbank?

7 or -8 BY MS. SNYDER-VARNS:

9 Q Had you included the railroad bridge as a
10 variable or factor in your modeling as opposed to the 11 road bridge, would that have made a difference in the
12 modeling that you performed?

9 A Yes.
10 Q And it's your understanding or thinking -11 and I understnd that you didn't install the range 12 lines -- that the focus of those who did was the
13 channel as opposed to complete bank?

13 A It may have. But my recollection at the
14 time was I think that the bridge openings were
16 openings.

14 A I guess maybe I need to clarify. When I
16 portion of the floodplain porton where the flows 17 arei so that would sometimes include the banks of the 18 channeL. But they didn't necessarily go out in what 19 we call the floodbank or the overbanks.

15 similar on the embankments as far as the embankment 15 talk about the channel, that's the primary inside

17 Q What information did you have about those
18 bridges when you inputted them into your model?

19 A We had the USGS quad maps and the

20 information that Neal had picked up in the field was 21 all we had found at that time.

20 Q Okay. I was asking about the fact that
21 the survey data didn't fully cover the region under 22 investigation to generate a continuous comparison. 23 And you explained that the range lines didn't include 24 the overbank upstream. So what did you do with the 25 data given that situation?

22 Q What information did he pick up in the
23 field that you're referring to?

24 A That was when he measured the spans of the
25 new Promise Bridge and the pier widths and the depth

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1

A

We supplemented the channel cross-sections

1

2

at the range lines with either the quad map or the

2
3

this March '97 flood eventi "was the largest on record and can possibly be a source of some of the

3

War Department maps depending on whether we were
working on the model that we were trying to use to

4
5

4
5

changes visible today." What do you mean by that?
A Typcially when you have large flood events that exceed what you normally see in the recent

6
7 8

model prior to the construction of the Oahe versus the model-to-modeli what we call post-Oahe.
Q
A

6
7 8

So you filled in the survey information

record, they will tend to physically change through
erosion and deposition, the floodplain.
Q
A

with the maps?
Yes. Q How did those coincide? A You mean -Q How do you do that? A How do we do that? Well, we get the range locations from Channel Stabilzation and

9 10
11

9 10
11

In one flood event?

12
13 14 15

12 13

Yes. Q And you go on to say, "Flooding at that time developed as a result of high runoff flows as

well as ice jam conditions."
A Yesi that's what was told us, there were some ice jam conditions there as welL. Q What's the source of that information?

Sedimentation. And they have those because they go
out and survey them. And then we would try to locate

16 17 18 19

as closely as we can on the appropriate quad map.
And then we would extend out the cross-section trying to be perpendicular to what we think the overbank

14 15 16 17 18
19

A

I believe -- I don't remember who called

flow wil be. And then we'll pull those points off 21 where that line crosses the contours on the map -22 Q The topographic map? 23 A -- on the topograph map and place those in
20 24 25
the modeL.

20
21

Q

You also looked at the flow data from the
Page 47

22 23 24 25

Roger Kaye. But he got a call that they were having ice jam flooding during the '97 event at that time. So -Q Who is Roger Kaye? A He works in the Hydrology Section.

And who called him; do you know? I don't know who called him. He used to work with CRREL on the ice jam data, so his name is
Q
A
Page 49

1

2002 flood insurance study?
Yes. Q What records from the u.s. Geological Survey indicated a flood event in March of '977 A That would be their historic gauge data.
A

1

2

2
3

out there as the person to call to report that for the database.
Q

3

So you talked to him about ice jam

4
5

4
5 6

6 7 8 9 10 11 12 13 14 15

Q
A

Would that be the White Horse galJge?
Yes, that's the closest gauge. Yes. Any other gauge data that you're aware of? There's I believe a Faith gauge thats

Q
A

7 8
9 10 11

conditions for this report -- did you talk to him? A Yes, I talked to Roger. Yes. Q When did you talk to him? A It would have been probably during this to see if he had any information on the ice jami the
location itelf. And he didn't have any specific

farther upstream. And then there was a discontinued
gauge at the old Promise Bridge. Q Did you use data from those gauges to the

information if I remember correctly.
Q
A

What information did he have?

12
13

extent it was available?
A At the time we didn't find that data readily available.

16 17 18 19

20 21 just took that off this. I'm not sure where we got 22 that. It must have been through USGS records either 23 written or on the web. 24 24 Q The study report goes on to say in that 25 paragraph on page one of 25 the report, "This event,"

Q So the records that you're talking about here consist of what from the U.S. Geologic Survey indicating the flood event? A I think what we did, we just -- they list the annual peak flood events in '97, and I think we

14 15 16 17 18 19 20 21 22 23

Just that he had gotten a cali that there was some ice jams reported on the Moreau River during the '97 flood. Q Do you know who called him? Was.it a Corps individual or was it somebody else?
A

I don't remember that.
You would have talked to him sometime

Q

before two thousand -- in facti October of 2003 then,
wouldn't you, because that's the date of this report?
A
I guess I'm not -- I don't really remember

the timing on thati but -Q You mentioned here that detailed ice jam information was not recorded from this event, so a

detailed ice analysis was not possible.
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1

Is ice jam information recorded?
A

1

2 3

Q

4
5

For this event? For flood events or other events. You indicate that it can be recorded when

2 3

look of the CRREL database, and there wasn't any specifics as far as ice thickness, and then just

general descriptions of ice jams. But we were really
looking for thicknesses at that time. Q Why would you be looking for ice

4
5 6

you say that it wasn't for this event?
A

6
7

Yeah. We've had other studies where we've

had people measure the thickness of the icei the
location of the ice jam, and given us pictures of the

7
8 9

8 9 10
11

thicknesses? A That is one of the major input parameters into the model for ice jam analysis.
Q
A

ice jam. And that helps when you do the modeling of
the ice jams.
Q
A
You've had people do that? What people?

10
11

What does an analysis consist of? It knd of depends on the level of detaiL.

If we were doing an ice jam analysisi we would try to
find out historically where all the ice jams were locatedi what the thickness of the ice was at the time of the jam, what the flow conditions were if we could find that, and then the length of the jam and

12 13 14 15 16 17 18 19

It would usually be people local to the
rapidly.

areai because ice jam events can happen very

Q
A

Did you get any information like that for
No.

this report?
Q
A

Did you request it from anybody? I think -- what I remember is that we

quickly checked the CRREL ice jam database, and there

12 13 14 15 16 17 18 19

if it was across the channeL. Or sometimes they even get what we call a grounded jam where the jam might
actually be grounded in the bed of the channeli and

then it helps us better with estimating parameters to
try to match results of that ice jam. The other thing we'll try to usually get is high water marks, but those are sometimes hard to come by. Q So where does this information typically come from? A A lot of time on our studiesi if it's not
Page 53

20
21

was flow specific information as to ice thicknesses
on that.
What is the CRREL ice jam database? It's a web address where they allow you to submit ice jam data, and they provide it to people that are interested in ice jams.
Q
A

20 21

22 23 24 25

22 23 24
25

Page 51
1

Q
A

2 3
it.

Who runs it or makes it? I think -- weili the CRREL kind of operates

1

2
3

available in the ice jam databasei we'll get it from our sponsor or local residents or newspaper artcles.

I think Kate White's familiar with that. She
Q
A

And sometimes even state offcials -- like Nebraska
has a stte ice jam network. Q So would you consider the ice condition information a significant component of an aggradation
study like this? A Only because it was reported there was ice

4
5

has some people that help her with it.
And that is the lab in Vermont?

4
5

6
7

Q

It's actually in New Hampshire. New Hampshire. Excuse me.

6
7

8
9

THE WITESS: Can we take a quick
break?
MS. SNYDER-VARNS: Sure.

8
9

jams during this flood. And sometimes they happen in
pool areas.

10
11

12 13 14 15 16 17 18 19

(2:20 p.m. - Recess taken) (At 2:35 p.m., with all parties present as before, the following proceedings were hadi to wit:)
BY MS. SNYDER-VARNS:

Q Before the break, we. were talking about ice jam or ice analyses and the fact that the laboratory

-- the Corps lab in -- if I say New Hampshire, it's going to be Vermont I'm sure -- New Hampshire, they
do some ice

analyses. And I was asking about the

10 11 12 13 14 15 16 17 18 19

Q So in the Omaha District, if ice jam information was availablei where would it bei and in
what form?

A

Like I said, if we -- we have colleced

some ice jam data, but not a lot. It would be in our
high watermark database. If it wasn'ti then we would quickky collect the CRREL database. After thati it's

not very ready availablei so we wouldn't have gone
any further. Q Who within the Omaha District maintains

20
21

fact that a detailed ice analysis was not possible here on the Moreau. And that was because you hadn't
been -- or hadn't obtained detailed ice jam
information for that 1997 flood event. Is that

20
21

22 23 24 25

basically what we were talking about?
A
Yes. I think what we did, we did a quick

22 23 24 25

the high water database? A It's our section.
Q
A

Who specifically handles that database?

I kind of oversee iti but I have a

technician in my secion that's been responsible for

14 (Pages 50 to 53)
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Page 15 of 36
Page 56

1

2 3

going back through all the high water marks and putting them in the database.
Q
A

1

What is that database used for?

2 3

i believe I may have asked you about an ice analysis. You say that a detailed ice analysis
Q

was not possible. Did you already testify about what
a detailed ice analysis is?

4
5

6 7 8 9 10 11 12 13 14 15

We wil use it to look for high water marks to try to calibrate our models. Q Yesterday John Remus testified about
periodically reviewing report about ice jams in the

4
5

A

I guess I don't remember.

6
7

Omaha District. Do you know who generates those

report?
A

8 9
10 11 12 13 14 15 16 17 18 19

i don't recall it. I kind of remember describing that we'd want to -- you would try to calibrate your RAS model
Q
A

Noi I don't.
Have you seen those report?

Q
A

Q
A

No, I haven't. Excuse me? No, I haven't.
You never heard of them?

that has an ice routine in it. So you'd want to have like high water marks and ice thicknesses and other information so that you could calibrate the model to show that you're kind of reflecting actual conditions

out there and you try to duplicate actual ice
events. Otherwise the model wil theoretically

Q
A

estimate ice jamsi but you don't know how accurate it
is.
Q
A

16 17 18 19 20 21 22 23 24 25

Now that you mention it, I remember hearing

about an ice jam report in Montana, maybe looking

So ideally what parameters or what data is

through that. But -Q
A

inputted into an ice analysis?

Q can recall?
A

About how long ago was that? It's probably been three or four years. And that's the only one like that that you

That's the only one that I can recalL.

Q

But that has nothing to do with the high

water database?
Page 55

20 21 22 23 24 25

Q
A
ice

Into the RAS model? Yeah.

The parameters are the ice thickness, the location of the jam and the height roughness, the
Q
A

of the jam, or the primary parameters.
Location of the jam relative to what? To where historically the ice jam is
Page 57

1

A

No. Actually, most of the high watermark

1

formed.
Q Are you talking about the reserviors or tributaries or where in the Omaha District? MR. GETE: Objection.

2 3

points we have in our database are open water ice

2
3

effect.
Q And those report don't have anything to do with the ice information that your secion gathers?

4
5

4
6 7

5 "BY MS. SNYDER-VARNS:

6 7 8 9 10 11 12 13 14 15 16 17 18 19

MR. GET: Objection. THE WITESS: Can you ask that again?
BY MS. SNYDER-VARNS:

8
9 10
11

Q
A

Well, you said that you and your section

gather ice information. How do you do that?
When we gather the ice information, we wil

You say the location of the ice jam. Well, what goes on with RAS is it has an ice jam parameter you can turn on where it wil calculate ice jams. But it's been prett well proven that unless an ice jam has actually formed at that locationi we can't rely that an ice jam wil form
Q
A

either -- the high water marks we do have in the database are the ones we have gone out and colleced
ourselves. And then at that time we've either had them surveyed or had like a local sponsor on the

study survey them for us. Q Other than the high water databasei where would ice information be kept or recorded?
Most òf it would be on the CRREL ice jam database that I know of that's readily available.
A

12 13 14 15 16

17
18 19

there based on the model parameters. So typically we need to have information that a jam has formed there historically to have faith that it's even close to giving us a reasonable answer. Q So when you say location of the ice jam, what you're really talking about is whether it's

actually occurred?
A Yeahi the location would be where the ice has basically piled up and blocked the stream is what

20
21

20
21 22 23

Q
A

Is it maintained in any other form, the ice
" gather?

we call the ice jam locations. So typically, not
always, but typically it would be like open water

22 23 24 25

information that you

Q
A

Oh, that we gather? (Nods head). Those would be the only two places.

below an ice blocking the river jam.
Q But I take it you're not talking about where on a water course or a lake that the ice jam

24
25

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1 actually occurred. You're talking more --

1 cover.

2 MR. GETE: Objection.
3 BY MS. SNYDER-VARNS:

2 Q So the ice cover would be more conservative
3 than an ice jam type -- if you can't do the analysis
4 of an ice jam and you model an ice cover, are you
5 going to see as great -- see changes in the water
6 surface elevations that are as great as with an ice

4 Q I'm stil not understnding you. That's
5 why I'm trying to understand.

6 MR. GETE: Ask a question.
7 BY MS. SNYDER-VARNS:

7 jam analysis?

8 Q What do you mean by ice jam location?

8 A No.
9 Q And is that reflected in Table 2 attched
10 to this aggradation study, the ice cover condition?

9 A Let's say like on the Platte River we've
10 done a study for ice jams. We would look to see 11 where ice jams have historically formed. Like 12 they'll form like upstream of the Highway 6 bridge, 13 at the confluence with the Elkhorn tributary and near
14 the Fremont bridge. And we have those documented --

11 A The table reflect the ice cover condition
12 we modeled

i yes.

13 Q And the table, when you look at the
14 hundred-year flood event on both Table 1, which is a 15 open water condition, and Table 2, which is an ice

15 those locations are documented as to where they're 16 at, and then we'd know in our model that that's 17 typically where ice jams have formed historically, 18 and that's where we would place the ice jam in our 19 model to try to duplicate that or calibrate that.

16 cover condition, it appears that the difference seems 17 to be a few feet for each sttion under the columns
18 "Normal DEP" and "WS 1620." Isthat a fair 19 summarization of the differences between the two --

20 QSo you're talking about actual historical
21 locations of ice jams?

20 those columns and the two tables?
21 MR. GETE: Objection. The table 22 tells us what it tells us. 23 But go ahead. You can answer. 24 THE WINESS: Weili when we do a
25 floating ice cover, basically what we do is we're
Page 59
Page 61

22 A Yes.
23 Q And apart from having that kind of
24 informationi it's diffcult for you to do an ice jam

25 analysis?

1 A Weili there's other factors on the Moreau
2 like the cross-section space in this. If they're
3 prett far aparti then and we wouldn't be able to do
4. a very detailed ice jam. But without having ice
5 thickness, it would

1 just adding that additional roughness. So it wil

2 vary from section to section depending.on how wide
3 the ice cover is in the channel at that time. So

4 generally you can probably summarize thàt there's a
5 difference between the two, but it's probably more
6 specific by section to section.

just be kind of a shot in the

6 dark for us. Basically we would have a mode) that
7 wòuldn't be calibratedi so we wouldn't have -- there

7 BY MS. SNYDER-VARNS:

8 would be a large amount of uncertainty with the

8 Q And when you say "section to secton," what
9 do you mean?

9 results. 10 Q So what is the difference between a
11 detailed ice analysis and modeling of a floating ice
12 cover?

10 A The cross-secton. I'm sorry. Like 32,
11 240, M-4.1 is one cross-section or section in the
12 modeL.

13 A The difference is in RAS, with the floating
14 ice cover, you basically look historically at what

13 Q So because you were unable to do a detailed
14 ice analysis, you did a floating ice cover -- you 15 modeled a floating ice cover throughout the part of 16 the Moreau River that were under review. Is that 17 what you'~e saying in this part of the report?

15 the thicknesses are and you put that thickness in as
16 a model parameter, and that adds wetted perimeter to
17 the modeL.

18 Q It adds -- excuse me -- what?
19 A Wetted perimeter to the model, which means
20 it adds resistance to the water and tends to increase
21 the water surface profie and elevation.

18 A What we did for both pre-dam and post-dam
19 was to model a floating ice cover to try to attempt 20 to look at what the impact of the ice would be to 21 the model surface profiles.

22 With an ice jam, we're actally talking
23 about chunks of ice actually blocking, not just 24 floating, but potentially blocking, where you can get

22 Q What did that component of the modeling 23 tell you?

24 A Prett much that floating ice cover gives
25 you higher water surface stages than open water.

25 substntially higher stages of the jam versus an ice

16 (Pages