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Deposition from United States v. SFWMD, et al., Case No. 88-1886-CIV-HOEVELER |
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Deposition from United States v. SFWMD, et al., Case No. 88-1886-CIV-HOEVELER |
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THEREUPON:
BILL HALL,
having been first duly sworn, as hereinafter certified,
testified as follows:
DIRECT EXAMINATION
BY MS. NASH:
Q. Okay, we are here for what is called a
30(b) deposition. This is a deposition where we are
inquiring about certain categories of information that
the water management district has to understand how the
water management district's computer systems operate,
how people communicate with each other in the district
using computers, what kind of data is stored on the
computers, and how that data is formatted.
Mr. Hall, you've been submitted as a
representative of the water management district having
knowledge concerning one or more of nine categories of
inquiry that we have submitted to your attorneys on the
South Florida Water Management District computer
systems and their comments. Have you been shown that
list of categories?
A. Yes, I have.
Q. For which categories are you being
submitted as the knowledgeable person; do you know?
A. I have some knowledge in almost all of the
6
categories. I don't really know which in particular
I'm designed to be the only representative for.
Q. Then we'll go through all of the
categories.
What is your present title or position?
A. Director of computer management.
Q. Is that in a particular division or
department?
A. It is a division, the division of computer
management, of which I am the director.
Q. What is your job description?
A. To obtain, acquire, set up, operate and
maintain all computer systems within the South Florida
Water Management District, including training,
applications, development, and interoperability of all
district computer systems.
Q. What was that last term?
A. Interoperability.
Q. Would you explain what "interoperability"
means, please.
A. The ability to make different vendors'
computer systems operate across a network to exchange
data and produce common results.
Q. How long have you been in the role of
director of computer management?
7
A. Ah, I was appointed to the position June
1st, 1984.
Q. Have you had other positions at the water
management district?
A. I have had--have had other positions, yes.
Q. What positions have those been?
A. Starting approximately June 1973, I was
hired as a night computer operator part-time. In
approximately July of '75, I was promoted to
applications programmer I.
In approximately 1976, I was promoted to
the systems programmer I. And somewhere between there
and 1983, was promoted to a systems programmer II, and
finally, systems programmer III.
Q. What is a systems programmer I?
A. It's a position responsible for the
development and installation of operating systems and
communications problems on multiple computer systems.
Q. How does that differ from a systems
programmer II?
A. A systems programmer II position has the
same, as well as additional, requirements placed on it
for being a high level--higher level position requiring
more experience and supervision.
Q. Is the job function the same?
8
A. Yes.
Q. And what about system programmer III?
A. Again, additional responsibilities of a
systems programmer II, additional years of experience
required.
(Whereupon, Ms. Waters entered the
deposition room.)
A. (continuing) And additional supervisory
responsibilities added.
MS. NASH: Note for the record an addition
to the room, please.
BY MS. NASH:
Q. Mr. Hall, what's your educational
background?
A. High school degree, bachelor's degree in
computer systems with the business and scientific
option from Florida Atlantic University.
Q. What year was that?
A. 1975.
Q. Have you had any additional formal
education in the computer area?
A. Other than continuing education on
specialized products, the answer is no.
Q. To whom do you report in the water
management district?
9
A. To the director of technical services.
Q. Who is the director?
A. John T. Lynch, Jr.
Q. How many employees of the district do you
have working for you?
A. There are 29 employees within my division
directly or indirectly responding to me.
Q. Generally what are their job descriptions?
MR. FROST: You mean--what do you mean by
"generally"?
BY MS. NASH:
Q. Well, I don't need a description--if there
are six computer operators, I don't need each one
described separately. Just by category, if there are
categories of employees within your division.
A. Okay, we have an assistant division
director.
Q. Who is that?
A. Robert Mann, M-a-n-n. Two supervising
senior systems analysts, one application supervisor,
one senior systems analyst, two systems analysts, one
mainframe data base analyst, one technical instructor,
one micro computer applications developer.
I'm not certain of the counts here, but I
believe three applications developers, one senior
10
computer systems technician, four computer system
technicians, one senior electronics engineer. I'm not
positive if that title includes the word "engineer."
One electronic technician--and excuse me, the previous
title didn't include "engineer." It was senior
electronic technician, not engineer.
One operations supervisor, and four
mainframe computer operators, one administrative
assistant, and one administrative secretary.
That's the best I can recall at this
point.
Q. What are the computers that are used at
the water management district, starting with the
mainframe?
MR. FROST: You're directing this to the
mainframe, this first question?
MS. NASH: This first question is directed
to the mainframe or frames.
MR. FROST: Okay.
A. There's a slight gray area on what is the
mainframe and what is a smaller system. I'm
categorizing two of our systems as mainframes, and
those are an IBM 4361 Model 5MO, IBM mainframe, and a
Cyber--that's spelled C-y-b-e-r, 830 mainframe.
11
BY MS. NASH:
Q. Do you have additional systems that you
would not call mainframes other than mini computers or
micro computers and PC's?
A. No. I don't have any other systems that I
would call mainframes that are not one of those.
Q. What operating system or systems do you
use on the IBM 4361?
A. IBM VSE/SP Version 4.1.
Q. Any others?
A. On the IBM?
Q. On the IBM.
A. No.
Q. And what operating system or systems do
you use on the Cyber 830?
A. Two operating systems: CDC NOS, spelled
N-O-S, and I do not know the current release, and CDC
NOS, NOS/VE. Again, I do not know the current release.
Q. What are the various software packages
that are used on the IBM 4361?
A. There are system utilites acquired from
IBM to make the system functional, and outside of
those, we have MSA software performing our financial
business for the district, as well as a number of
third-party software packages designed to maintain the
12
financial data files' backups and performance of the
system.
Q. Can you name those third-party software
packages?
A. Yes. We have four modules from
Goals--that's G-o-a-l-s, Systems, designed to help tune
VCN files. I believe the names are VSAM--that's
V-S-A-M, AIDS, A-I-D-S. I believe the second one's
called HYPER, H-Y-P-E-R. Third one is called FAVOR.
And I can't remember the name of the fourth one. All,
again, are related to backing up or file tuning.
We also have computer associates DUN M/T.
I believe the spelling is D-U-N M/T, or close to it.
Q. And what is that software package used
for?
A. That software package is used to compress
data files for backup to magnetic tape--or excuse me, I
described the previous package. That package--
MR. FROST: Can you clarify which package
you're talking about?
BY MS. NASH:
Q. The DUN M/T.
A. The DUN M/T is used to keep track of all
the magnetic tapes and IBM 3480 cartridges being used
on the IBM system.
13
Q. And which package were you describing when
you said one was used to compress data files?
A. That was FAVOR that compresses data files
when they're being backed up to magnetic tape or
cartridges, and, of course, depresss them when they're
copied back down.
Q. What input and output peripherals are
there on the IBM 4361?
MR. FROST: I object. That's a compound
question. Can we do it--do one or the other?
BY MS. NASH:
Q. What input peripherals are there on the
IBM 4361?
A. A series of IBM S and A terminals
operating through several communications controllers,
as well as a number of 3370 disk drives from IBM, and
one controller and disk drive from Storage Tek,
S-t-o-r-a-g-e T-e-k, that is IBM 3380 compatible.
There are tape drives used for input that
are the medium speed inches per second, quantity two,
and--
Q. What model tape drives?
A. I can't recall the model number, but it's
a medium speed nine-track 1600 CPI, 6250 CPI phase
encoded group encoded tape drive capable of reading and
14
writing EBCDIC, E-B-C-D-I-C, data.
In addition--
MR. FROST: I don't believe we have a
question.
THE WITNESS: I'm still doing the input
devices.
MS. NASH: He's going through the input
peripherals.
MR. FROST: You're asking him now to
continue?
MS. NASH: Just continue, yes.
MR. FROST: Okay.
A. In addition, we have an IBM 3490 cartridge
tape system composed of two drives with IDRC
capability.
BY MS. NASH:
Q. Explain what IDRC capability is.
A. The initials IDRT--I--excuse me, IDRC
stand for improved data recording capability. And it
is a compression/decompression capability for
compressing the 200 megabytes of data that would
normally fit on a 3480 cartridge up to approximately
one gigabyte, G-i-g-a-b-y-t-e.
Q. You indicated a number of IBM S and A
terminals. What is that number?
15
A. I believe we have 39 IBM terminals, most
of which are IBM 3191 models.
Q. Are those 39 IBM terminals located in one
location or throughout offices in the water management
district?
A. The terminals are located in multiple
offices within our headquarters building, as well as
within two trailers at the headquarters' location.
Q. Are there particular divisions or
departments that have these IBM terminals?
MR. FROST: Can you ask for division or
departments?
BY MS. NASH:
Q. Yes.
Either, either special divisions or
departments, that have these IBM 3191 terminals.
A. Yes.
Q. Which divisions and departments are those?
MR. FROST: Can you break that in two
questions?
BY MS. NASH:
Q. Which divisions are those?
A. There are terminals located in the
division of computer management, the division of
procurement and contract administration, the division
16
of financial services, the division of accounting, and
the division of personnel.
Q. Are there departments within the water
management district that have some of these IBM 3191
terminals?
A. I'm sorry, I didn't hear the question.
Q. Are there departments that also have some
of these IBM terminals you've been describing?
A. Yes, divisions are part of departments, so
the division--excuse me, the department of finance and
administration has terminals, and the department of
technical services has terminals.
Q. You testified that these terminals operate
through several communications controllers. What model
are those and how--well, first, what model are those?
A. An IBM 3274 communications controller, and
an IBM 3174 communications controller, as well as the
communications adapter located on the IBM 4361.
Q. You testified to a number of 3370 IBM disk
drives. How many 3370 IBM disk drives are there?
A. I believe the count is five. It could
possibly be six, but I am pretty sure it's five.
Q. Are there any other input peripherals that
you've not yet described for the IBM 4361?
A. Yes.
17
Q. What are those?
A. There is a protocol converter incorporated
1076 device hanging off the IBM 4361, as well as a DEC
NET--that's D-E-C N-E-T, /SNA gateway attached to the
IBM 4361.
Q. What is the function of the protocol
converter 1076 device?
A. It allows asynchronous terminals to
operate through an SDLC line from the communications
adapter on the 4361.
Q. What is a SDLC line?
A. That is an IBM term for the type of
communications line that they handle in their S and A
definition. I'm not certain of the exact words that
are associated with SDLC.
Q. What function does the DEC NET/SNA gateway
serve?
A. It permits devices that have connected to
an IBM--excuse me. It--it permits devices connected to
the DEC--that's D-E-C, 6310 to connect to the IBM 4361
as a terminal circuit. In addition, it permits the
routing of batched jobs called RJE to the IBM 4361, and
accepts printouts from the IBM 4361 to the DEC 6310.
Q. Are there other input peripherals that
you've not yet described?
18
MR. FROST: Can you clarify that as far as
what system we're talking about?
BY MS. NASH:
Q. On the IBM 4361.
A. No, there's no other devices for doing
input to the IBM system other than unused SDLC lines.
Q. What are the output peripherals for the
IBM 4361?
A. There are a series of hard copy devices.
An IBM 3262 printer, quantity two. There's two of
those. A Xerox 4050 lazer printer. And all the
previous input devices are also capable of being output
to that we mentioned previously. Plus, there is one
4224 dot matrix printer from IBM, as well.
Q. Where are the printer devices located?
A. One 3262 is located in the computer room
where the 4361 is located. The other 3262 is located
in the division of financial services. The Xerox 4050
is located in the computer room with the IBM 4361. The
IBM 4224 dot matrix printer is located in the division
of procurement and contract administration.
Q. What communications capabilities does the
IBM 4361 have?
A. The 4361 has a communications adapter
capable of handling synchronous lines up to 9600 bytes
19
per second. I believe it can be expanded up to eight.
At present, I believe we have three.
MR. FROST: I object.
Are you--do you know that it can be
expanded to eight?
THE WITNESS: No, I do not.
MR. FROST: Oh.
A. (continuing) We have a IBM--an IBM,
rather, 3720 communications controller that is channel
attached capable of driving devices at up to 56,000
bytes per second, and our 3174 and 3274 IBM
communications controllers are connected to that
device.
In addition, the DEC NET/SNA gateway is
attached directly to the communications adapter and to
the IBM 3720 communications controller, terminal lines
connected to the 3174, 3274, as well as to the
communications adapter on the 4361.
Q. What data is stored or processed through
the IBM 4361?
A. The data stored on the IBM 4361 is
financial in nature only, containing information on
general lev--general ledger, accounts payable,
inventory, budget, and fixed assets.
Q. Whose decision was it to use the IBM 4361
20
just for financial data?
A. It was part of the recommendation of the
consultant Quad, Q-u-a-d, Corporation to acquire and
use the predecessor of the IBM 4361 for financial
information only.
Q. When was this recommendation made?
MR. FROST: Object to this line of
questioning. What's the relevance to this
lawsuit of who made determinations of what
computer system should be used for financial
information?
MS. NASH: It's brief background
information, will not go on.
You can answer the question.
A. In the fourth calendar quarter of 1983,
the IBM 4331 computer system was acquired as a result
of the Quad recommendation.
BY MS. NASH:
Q. When was the IBM 4361 acquired?
A. I'm sorry, could you repeat the question?
Q. When was the IBM 4361 acquired?
A. The IBM 4361 was actually upgraded from a
4331 in approximately 1987.
Q. Moving now to the Cyber 830 mainframe.
What operating--what software is used on
21
the Cyber 830?
A. There is a series of three GL development
tools, namely COBOL, Fortran, DMS 170 preprocessor
available for use by any of the users.
In addition, there are a number of
application and statistical packages available for any
user. These include SPSS, BMDP, SIR, IMSL, SCA, Plot
10 Graphics Libraries, Techtronics Graphics Libraries,
and I can't recall any other general application
packages available at this time.
There is also other development tools from
Control Data Corporation, including DMS 170 data base,
and utilites for driving the appropriate communications
devices attached to the Cyber 180/830 system.
Q. What does SBSS (sic) do?
A. SPSS is a statistical package that accepts
tabular data and allows you to perform statistics and
aggression analysis on the sample data.
Q. And what does VMDP do?
A. I'm sorry, I am not familiar with VMDP.
Q. I believe that was the second package
mentioned.
A. Excuse me, BMDP.
Q. I'm sorry, was it B?
A. Biomedical--
22
Q. BM, okay.
A. I believe the term, the name for the
package, though everybody knows it as BMDP, I believe
that it's an acronym for Biomedical Data Processing,
though I'm not positive that's the exact title.
BMDP is a statistical package, also
capable of accepting tabular text data and performing
certain curve-fitting and random analysis testing on a
given set of data.
Q. What does SIR do?
A. SIR is a data storage and statistical
analysis package, also. It accepts data from a tabular
form into the SIR, which is S-I-R, data base format,
and then permits analysis on that data.
Q. IMSL package, what does that do?
A. IMSL is a series of subroutines for--for
performing statistical analysis and must be called from
a Fortran program.
Q. What does SCA do?
A. SCA is also a statistical analysis sub
system commonly referenced from Fortran by setting up a
set of data and submitting it for analysis.
Q. What does the Plot 10 Graphics Library do?
A. It's used from Fortran calls to represent
data in a graphical form on an output device.
23
Q. And the Techtronics Graphics Library, what
does that do?
A. It's a series of Fortran COBOL subroutines
used to display data in a graphics form on terminals.
Q. What are the input peripherals on the
Cyber 830?
A. The Cyber has a single front end called
CDC NET that handles all input communications used for
both synchronous and asynchronous data. That's the
only input device external to the computer system.
Q. What output peripherals are on the Cyber
830?
A. Internal to the machine, it has a data
channel converter, commonly known as DCC, that permits
lower 3,000 peripheral devices to be operated. Running
off the DCC, we have one CDC 580-12 chain line printer
for output.
In addition, the CDC NET drives output
devices, typically terminals. I'm repeating that,
typically terminals.
Q. How many terminals are driven off the CDC
NET on the Cyber 830?
A. The CDC NET is wired to Ungermann-Bass,
U-n-g-e-r-m-a-n-n B-a-s-s, network interface units
that can be attached from any PC or terminal anywhere
24
along the network within the district.
Forty-eight lines are provided, and
normally all forty-eight are hooked up. From time to
time, we reduce that--excuse me, 32 lines are normally
driven, and we reduce that from time to time. When the
net--network interface units are required elsewhere, we
borrow them from the system and reduce it by eight
lines for each network interface unit. If all are
available, it has 32 lines.
Q. Where are the terminals or PC's located
that connect along this network you've been describing?
A. Throughout pretty much all divisions and
departments, terminals or PC's are located, as well as
anywhere the network goes, which includes our field
stations.
Q. You mentioned network interface units that
might be required elsewhere. Would you describe those
network interface units?
A. The network interface unit, normally
referred to as NIU 180, from Ungermann-Bass Corporation
has eight asynchronous ports and can be hung anywhere
along the Ethernet network where it is needed, and then
up to eight devices can be attached to the NIU 180.
Most district employees simply refer to the device as
an NIU.
25
Q. What are some of the locations or what are
the locations where these--you indicated these--the
network interface units might be required elsewhere.
Where is--would you define "elsewhere"?
MR. FROST: Could you repeat the question?
MS. NASH: Yes. He indicated in his
previous testimony that these network interface
units could be required elsewhere and that would
reduce the number of lines by eight, and I'm
inquiring as to what, where "elsewhere" is.
MR. FROST: Okay.
A. Occasionally, due to malfunction or
lightening strikes, an NIU will be in need of repair
within the district's headquarters, and due to the fact
that there's 32 lines on the Cyber, we borrow NIU's
while one is being repaired to supplement the terminals
that are down as a result of an NIU malfunction. We
have them located in our headquarters' building, as
well as at a building we refer to at Congress--as
Congress Park, and a building we refer to as Congress
Avenue. At present, that is the only locations where
NIU 180's are located.
Excuse me, there may be one in the Fort
Myers district office. I know we had located one there
on the network. I don't know if it's still there or
26
if--or if it's returned to the headquarters building.
Q. What areas outside of headquarters are
included on the network that can access the Cyber 830?
A. I'm sorry, could you repeat the question?
Q. Yes.
What locations outside of headquarters are
on the network that can access the Cyber 830?
MR. FROST: Are you asking him which ones
are on the network or one which one they can
access?
BY MS. NASH:
Q. I'll make it two questions, then.
What locations outside of headquarters are
on the network?
A. Okay.
The locations outside the district that
are networked, "networked" being defined as Ethernet,
are: Congress Avenue, Congress Park, Homestead field
station, Miami field station, Fort Lauderdale field
station, Clewiston field station, Okeechobee field
station, Kissimmee field station, Big Cypress field
station, S5A pump station, Fort Myers office, Kissimmee
office, and Okeechobee SWIM office.
Those are all the locations that are
networked with Ethernet outside of the headquarters
27
complex.
Q. What computer capabilities does being on
the Ethernet network give the various locations that
you mentioned?
MR. FROST: Could we break that up?
BY MS. NASH:
Q. Let me ask first, is--do the various--you
mentioned approximately a dozen locations. Do those
locations have different computer capabilities from the
Ethernet network, or is the--are the capabilities all
the same?
A. The capabilities at all of those locations
are that they are networked, and any device at that
location can communicate with any other device at the
headquarters or on the network.
And you had a second question, but I don't
quite recall it.
Q. Would be the more specific question then
is: What then is the computer capability at each of
the locations? I guess we'll go through them one by
one. At Congress Avenue?
MR. FROST: So your question is--what is
your specific question now?
BY MS. NASH:
Q. What is the computer capabilities at the
28
Congress Avenue location?
MR. FROST: Okay.
A. At Congress Avenue, there are
approximately 50 personal computers and some number of
terminals. I don't know exactly how many. As well as
some NIU's that--excuse me, those terminals are
attached by NIU's, but as well as at least one Xerox
word processing unit.
BY MS. NASH:
Q. Through the PC's at Congress Avenue, can
district employees access the Cyber 830 computer?
A. Yes, they can access it.
Q. What computer facilities or capabilities
are there at Congress Park?
MR. FROST: Didn't you already ask that
question?
THE WITNESS: No, she said Congress
Avenue.
19 MR. FROST: Okay.
A. At Congress Park, there is very much the
same computer equipment as Congress Avenue:
Approximately 40 personal computers, approximately
eight Xerox word processing work stations, and a number
of terminals, period.
29
BY MS. NASH:
Q. What make and model are the PC's at
Congress avenue?
A. They can be IBM XT's, IBM XT 286, IBM AT
PS 2-30/286, IBM PS2 Model 60, PS2 IBM Model 70, or IBM
PS2 Model 80.
Q. What make and model of PC's are there at
Congress Park?
A. The same as Congress Avenue.
Q. What computers are there at the Homestead
field station?
A. Normally IBM XT's only at present, though
if a system were to break, sometimes we would
substitute with one of the other IBM machines during
repair.
Q. Do you know how many?
A. Quantity two at present.
Q. What are the computer devices at the Miami
field station?
A. The same, quantity two IBM XT's, though
substitutes occur from time to time on a temporary
basis.
Q. What computer facilities are there at the
Fort Lauderdale field station?
A. Two IBM XT's with occasional substitutes.
30
Q. And at the Clewiston field station?
MR. FROST: What is the question?
BY MS. NASH:
Q. What are the computer devices at the
Clewiston field station?
A. Two IBM XT's.
Q. What are the computer devices at the
Okeechobee field station?
A. I believe they have three IBM personal
computers. Two, I know, are IBM XT's. I don't know if
the third machine is an XT or a faster machine.
Q. What are other computer devices at the
Kissimmee field station?
A. Two IBM XT's.
Q. And what are the computer devices at Big
Cypress field station?
A. It was one IBM XT, but they may have
expanded already to two.
Q. What computer devices are at the S5A pump
station?
A. Two IBM XT's.
Q. What computer devices are at the Fort
Myers office?
A. At present, I believe there's six personal
computers. Five, I believe, are IBM XT's, and one is
31
an IBM AT. There was and I still believe is an NIU 180
device that drives several terminals.
Q. What are the make and model of those
terminals?
A. DEC 320 asynchronous terminals.
Q. What computer devices are at the Kissimmee
office?
A. In the Kissimmee office, I believe there's
either three or four IBM XT's, as well as an IBM AT
personal computer.
Q. What computer device are at the Okeechobee
SWIM office?
A. At the Okeechobee SWIM office, there's a
Xerox word processing unit with an output device, and
approximately three or four IBM PS2 Model 30's.
Several of these numbers I'm having to
tell you approximately, because on a daily base--basis,
they change.
Q. For what reasons do the numbers change?
A. Typically--typically someone is moved to
the office or from the office or an additional
responsibility is transferred from one office to
another and a form submitted to say that we've--I
should say they have moved the personal computer to a
new location.
32
Q. Are there any other locations outside of
headquarters where the water management district has
computer facilities?
A. Yes.
Q. Where would those be?
A. Some asynchronous cables are extended from
the district's NIU at Congress Avenue to some
non-district devices located in the DER facility at the
same location.
In addition, the district owns some
statistical multiplexors and CSU/DSU's that extend
communications lines from the district's headquarters
to USGS in Miami.
In addition, there are some personal
computers located at department directors' or executive
off--office personnels' homes with modems for
connecting in to the district's computer network.
Also, there is a terminal device located
at some of the opera--excuse me, operations and
maintenance departments' hydrologists for purposes of
calling in to district's telemetry system.
Q. Where are the locations of those
operations and maintenance departments?
A. The operations and maintenance department
is located at the district's headquarters complex, and
33
the selected hydrologists that are on call for
regulating the gate positions have terminals at their
homes. I believe we're talking two terminals here.
Q. Back to the--
MR. FROST: You okay? Do you need to take
a break for anything?
MS. NASH: You want to take a break? I
could actually use a pit stop, so--
MR. FROST: Okay.
(Short break.)
(Whereupon, Ms. Waters left the deposition
room.)
BY MS. NASH:
Q. Mr. Hall, does the Cyber 830 have other
communications capabilities that allow access by
outside users besides the network that you've been
describing?
A. Ah, that's a difficult question to answer
the way you worded it. I can't answer yes or no.
MR. FROST: Can you go ahead and try to
clarify what you're asking?
BY MS. NASH:
Q. What I am--let me rephrase that.
A researcher doing work for the water
management district, if they were not part of the
34
Ethernet network that you've been describing, could
they still access data on the Cyber 830?
MR. FROST: I would object to that as
being speculative, unless you can answer to the
extent that it happened or that system is
capable of that.
MS. NASH: Well--
A. The system is not capable of being
accessed other than through the CDC NET.
BY MR. NASH:
Q. Are there networks other than the Ethernet
through which you can access the Cyber 830?
A. Yes.
Q. What are those other networks?
A. Any device that can interface to the CDC
NET is capable of accessing the Cyber.
Q. What data is stored on the Cyber 830?
A. It would take a long time to attempt to
describe all the data, and some of the data is really
only known by selected users. But to answer in a
general fashion: Water level data, rainfall data,
water conductivity data, discharge data--referring to
quantities--are stored on the Cyber, as well as data
that individuals elect to put under their user numbers
on the Cyber.
35
There's a lot of data that it would take
the individual running that system to be able to
properly describe. But there is probably 500, maybe
more, accounts, and those have an allocation of disk
space for that particular user to store the data that's
relative to their work.
Also, there's mag tapes used by the Cyber
that can contain historical data. And again, the owner
of those tapes would know the content data. I or
individuals in our division would simply know the owner
of the tape and whatever description they decide to
call their data.
That's about the best description I
give--can give for the data on the Cyber other than to
say it's where a majority of the historical data is
stored.
Q. Are there any logs or other form of
documentation that would indicate--for example, the
lists of magnetic tapes and who the owner of the tapes
is or are and what's on those tapes, as well as what's
stored directly on the computer?
MR. FROST: That--I'm confused at what
question you're actually asking.
BY MS. NASH:
Q. Is there a log or other documentation that
36
would contain information relating to what is on the
computer and the tapes that Mr. Hall has been
describing?
A. Okay. The question's becoming a little
bit too broad to answer. There are logs referring to
data stored on tapes.
Q. Do those logs have a name or a way of
referencing it? What is that name?
A. The--
MR. FROST: Go ahead and answer the first
question. You can answer it verbally.
A. Could you repeat the question?
BY MS. NASH:
Q. My first question is do--does the log have
a name?
A. Yes.
Q. And what is that name?
A. Mag tape user list for the Cyber system.
Q. Is there a comparable list for what is
stored directly on the Cyber 830?
A. Yes.
Q. Does that list have a name?
A. Yes.
Q. What is its--what is that name?
A. There is a list that is maintained of the
37
backup of all files currently located on the Cyber
disks. I'm trying to give a precise name to it here.
The PF DUMP listing for any given week of
Cyber users sorted in user number order contains a list
of the files that were backed up to magnetic tape and
are maintained for a minimum of three months.
Q. Are any--is any of the data on the Cyber
or its disks or tapes password protected or otherwise
protected?
MR. FROST: Will you break that up?
BY MS. NASH:
Q. That's a general question first, and then
I will break it down.
A. Yes.
Q. Is the historical data you've been
describing that's on the magnetic tapes password
protected?
A. I can't really say yes or no, so I'm gonna
say sometimes. Or I guess I should say in some cases,
yes.
Q. Do you know the nature of the material
that's password protected?
MR. FROST: What do you mean by "nature"?
Do you understand what--what you're being
asked?
38
THE WITNESS: No, the question doesn't
relate to the passwords at all.
BY MS. NASH:
Q. Do you know which files on magnetic tapes
are password protected?
A. Yes.
Q. What files are those?
A. All files that are in labeled format may
have a password, and you don't know they do or do not
until you reference it.
Q. You indicated the data on the Cyber disks,
that some of that data is also password protected; is
that correct?
A. I'm gonna try to answer that, not
answering your question, but just saying all data on
the Cyber disks is password protected.
Q. Let' move on for the moment to the mini
computers that are located at the--or that are utilized
by the water management district.
Can you describe what mini computers there
are?
A. Okay. We have a VAX--that's V-A-X, 8820
computer system, a VAX 6310 computer system. We have a
Perkin Elmer mini computer. We have a Computer Vision
mini computer. We have two micro VAX II--excuse me,
39
three micro--Micro VAX II mini computers. And that's
all the mini computers we presently have at the
district.
Q. Are there other mini computers used or
accessible to water management district employees that
are not located at the district?
A. I'm sorry, can you repeat?
Q. Are there other mini computers that are
used by water management district employees--
A. Yes.
Q. --that are not in the seven mini computers
you've described?
A. Yes.
Q. Where are those other mini computers
located?
A. There are computer systems located in
Tallahassee that are referenced by individuals at the
district for obtaining information. They are not owned
or anything by the district. There are mini computers
owned by USGS that contain data that the district
accesses and copies down to its own systems.
There are legal systems from West
Publishing and other firms that the district buys time
on for doing legal research.
There are commercially-available computer
40
systems that the district subscribes to to get
information on products available by other companies.
They're computer systems used for
biological--excuse me, bibiological--I can't say that
word, bibliography research that are accessed from our
reference center, commercially available systems.
I cannot think of any other--oops, we also
references--reference Barnett Bank's computer system
for check-clearing data.
We also access University of Miami's
satellite data for satellite images. We also have
individuals that access University of Florida and
Florida State's computer system for accessing data.
That's all the outside computer systems
that I can think of that the district references. Some
may or may not be mini computers.
Q. The computer system located in Tallahassee
that you mentioned as referenced, where is that system
located?
A. I do not know.
Q. By what device or devices is that system
in Tallahassee re--referenced?
MR. FROST: Referenced?
BY MS. NASH:
Q. Yes, or accessed. Accessed or referenced.
41
A. A phone number was obtained from our legal
department to call up and get information on
leg--legislation, and we access it by phone calls from
the district.
Q. What is the operating system on the VAX
8820?
A. VMS 5.O at present.
Q. I'm sorry, what is that?
A. VMS 5.0 at present.
Q. And what is the--what are the software
packages available on the VAX 8820?
MR. FROST: Could you identify what you
mean by "software packages," what you're
looking for?
MS. NASH: I believe Mr. Hall, if he
understood the question, can answer it.
A. Are you talking about
commercially-available software packages?
BY MS. NASH:
Q. No, what software is utilized--
A. Okay, utilized.
Q. --on the VAX 8820?
A. Oracle software, system utilites software,
communications software, and external device drivers
software. There are also language tools for program
42
development available to users.
Q. Please describe the Oracle software.
A. We have purchased Oracle software from
Oracle Corporation to store tabular data in a data base
format under VMS and have the forms utility,
report-writer utility, report utility, SQL*PLUS
utility, EASY*SQL utility, and data dictionary facility
from Oracle Corporation.
Q. What is the function of the systems
utilites software?
A. To--to allow maximum resource utilization
of the DEC system's memory by capturing selected pages
of memory to and from disks.
Q. And the communications software, what is
its function?
A. The communications software from multiple
vendors permits different types of devices on the
network to access and copy files to and from the VAX
system.
Q. Which vendors do you have communication
software for on the VAX 8820?
A. DEC, D-E-C, an abbreviation for Digital
Equipment Corporation, and Interconnections
Corporation. That's all.
Q. Who's the vendor for the systems utilites
43
software that you described that's on the 8820?
A. I'm not sure whether it's the vendor's
name or the vendor's product name, but we refer to it
as IO Express. That may be the name of the company.
I'm pretty certain it's the name of the product.
Q. What is the function of the external
device driver software that you described on the VAX
8820?
A. To drive DEC lazer printers and
Hewlett-Packard lazer printers throughout the complex.
Let me see if there's any other.
And that's all on the VAX 8820.
Q. You mentioned there are language tools for
program development available on the VAX 8820. Can you
describe those language tools?
A. Yes. Fortran C, Pro Fortran, and Pro C,
and I guess that's all.
Q. What are the input peripherals for the VAX
8820?
A. A console and an Ethernet interface board,
and that's all.
Q. What are the output peripherals on the VAX
8820?
A. The console, the Ethernet network board,
as well as an LPS 20 lazer printer accessed through the
44
Ethernet board.
That's all.
Q. What's the memory capacity on the VAX
8820?
A. 128 megabytes of real memory.
Q. What are the network capabilities of the
VAX 8820?
A. It is networked through a single Ethernet
controller board driving two protocols from DEC
interconnections.
That's all.
Q. Do you know the number of terminals that
can access data on the VAX 8820 through the Ethernet
network?
A. There's really not a physical limit except
eventually with too many users, the response time would
become unbearable. But the Ethernet board does not
limit how many terminal sessions can simultaneously be
handled.
Q. What are the data files that are stored on
the VAX 8820?
A. Almost exclusively they are Oracle data
files containing tabular data that have been created by
the different divisions throughout the district.
Q. Who makes the decision whether data files
45
will be stored on the Cyber 830, for example, as
opposed to the VAX 8820 or one of the other mini
computers that we'll discuss?
A. Okay--
MR. FROST: I--what do you mean by "we'll
discuss"? I guess this is a compound question.
MS. NASH: Well, let him answer the
question if he can answer the question.
MR. FROST: Do you recall the question?
THE WITNESS: Why don't you restate it,
just so I make sure I'm answering correctly.
BY MS. NASH:
Q. Who makes the decision on what data files
are stored on the mainframe and the Cyber 830, as the
one you have described as having more--other than
financial files on it, as opposed to storing data files
on the VAX 8820 or one of the other mini computers that
you previously mentioned that we'll be discussing?
A. The district has recently acquired the VAX
8820 and is encourageing the users to store their data
in Oracle wherever possible. The Cyber system is much
older and is in the process of being phased out, and
data files are discouraged from being created there.
The user ultimately makes a decision where
they put the data and request permission in the form of
46
disk allocation for where they need to put their data.
And computer management grants the request if it's
considered reasonable. Computer management is a
division.
Q. Who heads the computer management
division?
A. Myself.
Q. Are you saying then that it would be your
decision--or your decision which computer, based on the
amount of disk space being requested as to which
computer somebody would store files?
A. No, I'm not saying that.
Computer management personnel grant
allocations of disk space, and the user ultimately
makes a decision as to how much space they need and
then where they put their data. Naturally they can't
put more than they have space for, and if we deny their
request for space, they won't be able to put it on that
particular system.
Q. What's the operating system on the VAX
6310 computer system?
A. At present, VMS 5.0.
Q. What are the software packages available
on the VAX 6310?
A. Again, that's a very generic question. I
47
guess my attempt to say the packages that can be
utilized by a user would be Oracle, system utilites,
communications software, language development tools,
and then any software somebody may have developed.
Q. Is there a standard set of software that's
supported for the mini computers or--let me stop there.
MR. FROST: What do you mean by--
BY MS. NASH:
Q. Is there a standard set of software that
is supported by computer management for the mini
computers?
MR. FROST: Do you understand what she
means by "supported by"?
THE WITNESS: I think I need to define
"support" here.
MR. FROST: Go ahead.
THE WITNESS: You want me to define
"supported by" or you define "supported by"?
BY MS. NASH:
Q. Let me rephrase the question, actually.
What I'm interested in is are users of the
mini computers allowed to utilize whatever software
package appeals to them, or are they restricted in any
fashion to a standard set of software packages?
A. There are no restrictions normally placed
48
on any software packages, but there are permissions
required to get to some of the software packages or to
access possibly somebody's user number that contains
software.
Q. Let me see if I understand your answer.
A user, under their own user number, can
utilize whatever software they choose from whatever
source; is that an accurate statement?
A. No. A user may access
commercially-available software on any mini computer
where it is located as long as they have sufficient
permissions, meaning resources not so much access to.
Q. That gets back to my initial question then
is do you support only a standard set of software
packages and not--
MR. FROST: Are you--
BY MS. NASH:
Q. --the computer management division, and
not allow researchers to--or other users to pull in
their own software packages from the hinterlands, from
wherever?
A. Okay. I'm gonna have to qualify the word
"support."
Computer management installs selected
software that it finds of use to the district or its
49
employees and assists with questions on it. The
district is in the process of developing a data and
security policy that is consistent with prior year's
practices for not allowing the use of pirated software.
If a user were to copy a program from an
external source to their user number and had sufficient
resource privileges to use it, we'd very possibly not
be aware of it.
I don't know if that is targeting in
answering your question.
Q. It does.
The software packages that can be utilized
on the VAX 6310, you mentioned Oracle, systems
utilites, a communications software and the language
development tools. Are those the same packages that
you previously describe as being utilized on the VAX
8820?
A. All the ones that exist on the VAX 8820
also exist on the VAX 6310.
Q. Are there additional software packages on
the VAX 6310 that are not on the VAX 8820?
A. Yes.
Q. What are those software packages?
A. It'll take a little time, excuse me.
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