** 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 88-1886-CIV-HOEVELER UNITED STATES OF AMERICA, et al, ) ) Plaintiffs, ) ) vs. ) ) SOUTH FLORIDA WATER MANAGEMENT ) DISTRICT; JOHN R. WODRASKA, ) EXECUTIVE DIRECTOR, SOUTH FLORIDA ) WATER MANAGEMENT DISTRICT; FLORIDA ) DEPARTMENT OF ENVIRONMENTAL REGU- ) LATION; AND DALE TWACHTMANN, ) SECRETARY, FLORIDA DEPARTMENT OF ) ENVIRONMENTAL REGULATION, et al, ) ) Defendants. ) ___________________________________) - - - - - - - - CONTINUED DEPOSITION OF KEVIN RODBERG, THE WITNESS, TAKEN ON BEHALF OF THE PLAINTIFFS - - - - - - - - DATE: August 23, 1990 PROFESSIONAL REPORTING SERVICE Suite 303, 324 Datura Street West Palm Beach, Florida 33401 (407) 659-4046 ** 2 I N D E X August 23, 1990 DIRECT CROSS KEVIN RODBERG By Ms. Nash (continued) 5 By Mr. Richards 28 ** 3 The continued deposition of KEVIN RODBERG, the witness, in the above-entitled and numbered cause, was taken before me, DONNA McCALLEY, Registered Professional Reporter, and Notary Public for the State of Florida at Large, at Suite 110, 324 Datura Street, in the City of West Palm Beach, County of Palm Beach, in the State of Florida, beginning at the hour of 10:02 a.m., on Thursday, the 23rd of August, 1990, pursuant to the Notice in said cause for the taking of said deposition, which is annexed to the court file herein, on behalf of the Plaintiffs in the above-entitled action pending in the above-named court. The appearances at said time and place were as follows: UNITED STATES DEPARTMENT OF JUSTICE Room 868, 601 Pennsylvania Avenue, N.W. Washington, D.C. 20044-0663 Attorneys for the Plaintiffs, U.S.A. By BEVERLY SHERMAN NASH, ESQ. PEEPLES, EARL & BLANK, P.A. Suite 3636, Two South Biscayne Boulevard Miami, Florida 33131 Attorneys for the Cities of Belle Glade and Clewiston By JOSEPH RICHARDS, ESQ. SKADDEN, ARPS, SLATE, MEAGHER & FLOM 1440 New York Avenue, N.W. Washington, D.C. 20005-2107 Attorneys for the South Florida Water Management District By KATHARINE STOLLMAN, ESQ. ALLISON BURDETTE, ESQ. ** 4 APPEARANCES CONTINUED: SOUTH FLORIDA WATER MANAGEMENT DISTRICT 3301 Gun Club Road West Palm Beach, Florida 33416-4680 By JACQUELYN L. WATERS, ESQ. ALSO PRESENT: Ray Roberts Robert Johnson ** 5 THEREUPON: KEVIN RODBERG, having been first duly sworn, as hereinafter certified, testified as follows: DIRECT EXAMINATION CONTINUED BY MS. NASH: Q. Good morning, Mr. Rodberg. In the prior session of your deposition, you were discussing the chemical analyses archives system, and you testified that external laboratories submitted water quality data to that system; do you recall that? A. Yes. Q. Do you know what were the names of the external labs that submitted the data? A. Ch2M Hill, University of Miami. I can't remember any others. Q. Are there others whose names you don't remember? A. Possibly. Q. In that prior session, you were discussing plotting or graphing of water quality data on the computer. You mentioned display time series plots. Can you explain what that is? A. Time series plot is a X-Y plot. One axis ** 6 is date and time. The other axis would be the value of the parameter that you're plotting against time. Q. Can you give me examples of some of those other parameters that you would be plotting? A. Total nitrogen, total phosphorous, conductivity. MS. STOLLMAN: Could you explain the relevance of this line of questioning? MS. NASH: Encompassed by the request of what the data is on the computer. BY MS. NASH: Q. In that prior session when you were discussing plotting or graphing, you also mentioned mapping products. What are mapping products? A. I consider AUTOCADD a graphic tool used to map a contour package, similar to Instu's contour would also be considered a mapping product, the way I described. Q. What were these contouring packages you also mentioned? A. Instu and-- Q. I'm sorry? A. Instu-- Q. Instu. A. --and AUTOCADD. ** 7 Q. In your prior session, you also were discussing pesticide data that you had transferred to floppy disks that you have. Do you know of other pesticide data maintained by the water management district on computer other than that? A. No, I don't. Q. When you were in Resource Planning, did you design any data base systems? A. Yes. Q. Describe what those systems were. A. The groundwater ambient water monitoring data base, the chemical analysis archive data base, sample analysis contract tracking data base, started work on the plan management system. I think that's the majority of the systems I developed. Q. What did the groundwater ambient system do? A. Stored groundwater quality analysis as required for the DER's Water Quality Assurance Act. Q. And for whom did you design that data base? A. John Shaw and Jeff Hare. Q. Where is that data base located? A. Jeff Hare's now responsible for it. Q. Do you know what format the data base is ** 8 in? A. Yes. It's written in Data Flex. Q. Do you know in what directory it would be located? A. No, I don't. Q. You next mentioned a chemical analysis data base. A. Yes. Q. What was the purpose of that data base? A. It was intended to archive the district's water quality data and other chemical analysis information to centralize the data in the relational data base system. Q. And for whom did you do the chemical analysis data base? A. Tony Federico. Q. Where's the chemical analysis data base located? A. The Britten Lee. Q. In what format is that data base? A. Brit--the Britten Lee's relational data base management system. Q. You also mentioned a sample analysis tracking system-- A. Yes. ** 9 Q. --that you designed. And what was the purpose of that system? A. It was to tract the contracts for the water quality division's external laboratories' quality analysis. Q. And for whom did you develop that data base? A. Richard Fieve. Q. And where is that data base located? A. The Britten Lee. Q. And what is the format of that data base? A. Britten Lee's relational data base management system. Q. And while you were in Resource Planning, did you design a data base to retrieve water quality data by the various structures? A. Yes. Q. What is that data base called? A. Chemical analysis archive system. Q. Is that data base also capable of retrieving water quality data by various parameters? A. Yes, it is. Q. What is the nature of the parameters? A. I don't understand. Q. What would those parameters be? ** 10 A. Any of them. Q. Can you give me examples? A. You can retrieve data by discharge code, by station name, by any--any of the water quality parameters themselves, retrieve them based on certain values, ranges of values, any combination of the above. Q. And how--how does one access that data base? A. By which software, is that what you mean? Q. Yes. A. We use a software package called EM 220, connect to the--one of the VAX systems, do a second connection to WMD3, and utilize some DCL menus to access Free Form's menu system that I developed to run the various reports. There is an alternate method which you can access from the PC's using what is called IDL or SQL. Q. And how do you access the groundwater ambient system that you described? A. Access it from a PC, the data can be stored on the internal hard disk or a vernouli cartridge system, or on a PC server, you access it through Data Flex's menuing system. Q. And the sample analysis tracking system, how do you access that? ** 11 A. Exactly the same way as you access the CAS system. Q. Is there any documentation that exists to show someone else how to utilize or access your chemical analysis archives system? A. Yes, it is. Q. Does that documentation have a name? A. Yes. It's called user documentation for the chemical analysis archive system and it's labeled "Draft." Q. Where is that documentation located? A. I have multiple copies stored in my office, as well as on disk in Word Perfect format. Q. Is there documentation to assist in accessing the groundwater ambient data base? A. Nothing formally written. Q. And what about the sample analysis tracking system, is there documentation to assist in accessing that system? A. Nothing formally written. Q. When you were in Resource Planning, did you use any software packages other than those that were made available to you by the water management district's Computer Management Division? A. No. ** 12 Q. When you were in resource planning, were backups done on the programs or analyses you worked on? A. Yes. Q. Who did those backups? MS. STOLLMAN: Could you specify for what programs or systems? MS. NASH: He can answer for the programs and systems he worked on. A. The chemical analysis archives system and the sample analysis contract tracking system are backed up on a regular basis by the Computer Operations staff. Frequent backups were made of the groundwater ambient water monitoring base by myself, Jeff Hare, or when it's stored on the PC servers, is back up by the Computer Operations staff. The plan management system that I'd work on in Resource Planning was backed up on a regular basis by the computer operations staff from the VAX 6310. Q. What do you mean by "regular basis"? A. There are scheduled backups, the mainframes and mini computers, as well as the PC servers. Q. And the groundwater ambient system you said you backed up, how often would you back that up? ** 13 A. Before major changes were made. Q. What was the procedure for doing the backup? A. We'd copy everything in the subdirectory to a vernouli cartridge. Q. For the backups that you did, do you know how long they were maintained--they are maintained? A. They're maintained until the next backup run. Q. And for the backups done by computer management, do you know how long those backups are maintained? A. No, I don't. Q. When you were in Resource Planning, do you recall developing a water quality violation flagging system? A. Yes. Q. Was that system developed? A. It was never implemented and it's only partially developed. Q. Do you know why it wasn't implemented? A. Yes. Q. Why was that? A. They, various professionals, did not have the necessary time to enter the particular flagging ** 14 standards that they'd required. In addition to that, some of the aspects of the system were not thought to be practical because of the actual analysis scheduling, the time frames when samples are actually analysized and when they are released from the lab. Q. Any other reasons? A. One more reason, I would guess. The limit-- MS. STOLLMAN: Do you know or are you guessing? A. Oh, I know. The LIMS system is going to be upgraded or changed out for a new system, and the various staff had felt that it was more practical to wait to implement something along that lines (sic) for in the new system. BY MR. NASH: Q. Do you know what this new system will be that is going to replace the LIMS? MS. STOLLMAN: Objection. I don't think a new system that's not in existence at this point is relevant to this deposition. MS. NASH: You can answer the question. MS. STOLLMAN: Well, could you explain where in this notice systems that are not in existence are requested? I mean, I--I haven't ** 15 seen any questions here that relate to new systems. MS. NASH: Well, I'm not going to debate you. It is a system that is in the process of being implemented in the foreseeable future while this litigation is going on. We're entitled to know what changes are being made so that if we ask for something three months down the road on the LIMS system, we are told it doesn't exist anymore because of this new system, we're entitled to know that new contemplated system. MS. STOLLMAN: If we have a new system, we'll update any information. MS. NASH: If he knows what the new system is going to be, he can answer the question. MS. STOLLMAN: Is there a new system that is definitely going to be put in place? THE WITNESS: I can't say definitely. Things can change any time. There are plans for a new system. I don't know the exact specifications of the new system. It is supposed to be compatible with Oracle, that's all I know. MS. STOLLMAN: I don't want the witness to ** 16 speculate about something he doesn't know. MS. NASH: That's fine. BY MS. NASH: Q. Mr. Rodberg, were there any other programs that analyze water quality parameters that you developed other than the ones you've previously mentioned? A. There may be, but I--are there any other--no, I'm sorry. Can you rephrase, repeat or rephrase it, I don't care. MS. NASH: Reread the question. (Thereupon, the question was read by the Reporter as recorded above.) BY MS. NASH: Q. Any other programs that analyze water quality parameters. A. There may be other programs at the district that analyze water quality parameters written by other people that I'm not fully aware of. Q. But there are none other that you operated or maintained or designed that you can recall at this time. A. No. Q. Did you do any data analysis for the SWIM process? ** 17 A. What aspects of the SWIM process? Q. Any aspect. A. Any aspect, yes, I did. Q. Describe what data analysis you did for the SWIM process. MS. STOLLMAN: Can you narrow that question? MS. NASH: Any data he did on the computer analysis for the SWIM process. A. I did some analysis of--or programming work, I'd rather phrase it, for the prioritization of water bodies, and occasional requests that may or may not have been related to the SWIM process requested by professionals working on it. I'm not always given the exact reasons why a professional is requesting information. SWIM process has been encompassing a majority of water quality and Environmental Planning's work. Q. For whom did you do this programming work for prioritization? A. Tony Federico, Mike Cullem. I'm not--I'm not certain who else was involved with the actual process. I think those were the key people. Q. And where are the results of that programming work located? ** 18 A. I think they're documented in the prioritization of water bodies section for the SWIM process. Q. In what directory or on what computer would we find the programs that you just mentioned working on the prioritization of water bodies? A. Prioritization of water bodies was generated on the Britten Lee in some temporary tables which were lost during a disk crash a couple years ago. Q. When was this disk crash? A. I don't remember the exact time. It was some time in the last two years. Q. Was any of the data lost in that disk crash restored? A. A great deal of work was done trying to restore it, and we found that it was not possible. Q. Have you done any data analysis on in-flow water quality data? A. In-flow to where? Q. To the water structures, to the water conservation areas, to Everglades National Park. A. I'm not certain which stations are involved as in-flows. It's possible. MS. STOLLMAN: I'd like to object to the line of questioning, asking him what kind of ** 19 in-flow analyses he's done for different purposes. The scope of this deposition is limited to what types of information are located where, not what types of analyses he's performed. MS. NASH: Well, I can't find out what's located where until I know what there is, Katharine. BY MS. NASH: Q. Do you know what kind of data analyses on computer are done by the Environmental Sciences Division on water quality? A. No, I don't. Q. Do you know what kind of data analysis on computer are done by the Research and Evaluation Department-- A. Division-- Q. --on water quality? A. I'm not certain if anything has changed from when it was Resource Planning's water quality division. It does have a new director now, so it is possible that they are doing things differently than when I was with them. Q. Do you know what kind of data analysis on computer on water quality are being done by the Water ** 20 Quality Division? A. I am sorry, I must have misunderstood your last question. That's--I was answering for the Water Quality Division when you asked for--what was it, DRE? Q. Research and Evaluation. A. Right. I had misunderstood your question. The answer is the same for DRE and Water Quality. Q. Do you know whether the Water Quality Division has any computers that that division utilizes by itself? MS. STOLLMAN: What do you mean by "by itself"? MS. NASH: What the question says, without other divisions utilizing the same computer. A. Their personal computers. BY MS. NASH: Q. Any others? A. Not that I'm aware of. Q. Do you know where, on what computer, the water management district maintains its rainfall chemistry data? A. Yes. Q. Where is that? A. It's stored or archived on the chemical ** 21 analysis archive system, and it's also stored in the Perkin Elmer's LIMS. There may be other places that it's stored afterwards, but that is the primary location for where it's supposed to be stored. Q. Did you do any analyses when you were in Resource Planning on the rainfall data? A. Yes, I did. Q. And what analyses did you do? A. I did some graphics displays of rainfall, water quality information using Symphony and AUTOCADD. I did some min-max averages, some standard deviation calculations, some work related to loadings using the rainfall chemistry data. Q. And for whom did you do the graphic displays that you've mentioned? A. Allen Hall and Nagendra Khanal and George Shih. Q. Do you know where the results are of the graphic displays on rainfall data that you did? A. No, I don't. Q. In what format did you provide the results of your analyses to the people you mentioned? A. The graphic information was the Symphony graphics were provided in hard copy. The AUTOCADD work could be either distributed on floppy disks on the ** 22 server or just a hard copy. Q. The--and the min-max averages and standard deviation work, who did you do that work for? A. Primarily George Shih. Q. And do you know where the results of those analyses are? A. No, I don't. Q. And what format did you provide Mr. Shih with those analyses? A. Occasionally it was just a hard copy. Other times it was transferring to the Cyber or on floppy disks or to the PC servers. Q. Are there specific names by which one could access the analyses on rainfall data that you did? A. None that I can think of. Q. Did you do any trend or statistical analyses on computer specifically for any water conservation areas? A. Yes, I think I have. Q. What is the analyses that you did on the water conservation areas? A. It would-- MS. STOLLMAN: I object to that question. You can ask him where those analyses are ** 23 located, but the content of the analyses, I don't think, is appropriate here. MS. NASH: Katharine, read the deposition notice. MS. STOLLMAN: Well, could you point me to exactly what you're referring to? MS. NASH: The types of information contained in each of these systems, number five. MS. STOLLMAN: So you want him to tell you in the context of the analyses whether it contained statistics or graphics, whether he performed modeling, remote sensing, vegetative mapping, et cetera. MS. NASH: It says, "including but not limited to." The question is very clear. MS. STOLLMAN: Could you repeat the question. (Thereupon, the question on page 21, line 21 through 22 was read by the Reporter as recorded above.) A. I have done some trend analysis runs with various parameters or water quality parameters for the conservation areas, frequently producing graphs of the data utilizing the Symphony graphics package; some statistics as min-max averages; some screening of the ** 24 data using SAS routines and different retrieval techniques from the CAS system itself. Q. For whom did you do these trend or statistical analyses for the water conservation areas? A. Tony Federico and George Shih. Specifically other than that, it could have been most anyone in the Water Quality Division. Q. Where are the results located presently; do you know? A. No, I don't. Q. Do you know under what name someone would access the analyses that you did? A. I never named them anything specific. Q. Did you do any trend or statistical analysis on computer specifically on Everglades National Park? A. It's possible some of the parameters--or some of the stations in Everglades National Park were included in some of the requests that were given to me. I'm not familiar with all the stations' exact locations. A number's a number to me. Q. Are you familiar with the term ONRW? MS. STOLLMAN: Only if you know. A. Outstanding Natural Resource Waters, or something. ** 25 BY MS. NASH: Q. Did you do any data analysis relating to ONRW? A. Not that I'm aware of. Q. Mr. Rodberg, did you attend a meeting at the water management district in October of '89 with representatives of the district and Everglades National Park on the--on computer information? A. Yes, I think I was at that meeting. Q. What was your role at that meeting? A. I was the representative to describe water quality data that's stored at the district. Q. Did you describe all the water quality data stored at the district at that time, or were you--well, answer that question first. A. The information that I'm responsible for, yes, that's what I described. Q. Were you told to limit your discussions in any way? MS. STOLLMAN: Excuse me, could you explain the relevance of what he discussed at the computer meeting in 1989 is to this deposition? MS. NASH: He can answer the question. THE WITNESS: Could you reread it? ** 26 (Thereupon, the previous question was read by the Reporter as recorded above.) MS. STOLLMAN: Told by whom? MS. NASH: Anyone. A. I don't recall that anything was specifically said to limit the conversations at the meeting. I think it was brought up during the meeting that it was most practical to talk about the raw data. Everyone that was there had the same information as far as limiting the conversation. Data at the district, it gets very broad, and I think it was decided that the information that we could provide to these other agencies as requested would be limited to the raw data. BY MS. NASH: Q. Mr. Rodberg, were you asked to prepare at any time a list of the files on water quality that you have on computer? A. Yes, I think so. Q. I'm gonna show you a list and ask if this is the list you prepared. MS. STOLLMAN: You can take your time to review that. A. Most of this is my writing. The third page isn't. ** 27 BY MS. NASH: Q. Do you have any computer files related to water quality that are not listed there? A. Yeah, the chemical analysis archives system isn't listed. And the groundwater ambient data base isn't listed, either. Q. Any other files that you can think of that are not contained on that list of your files? A. Not specifically, no. MS. NASH: I have no further questions. MS. STOLLMAN: Do you want to take a break now? MR. RICHARDS: I would like to get a copy of that list, if I could. MS. NASH: I can show it to you for the moment and we can provide you a copy later. MS. STOLLMAN: Are you going to make that an exhibit to the deposition? MS. NASH: No. MS. STOLLMAN: I'd like to get a copy of it, as well. Kevin, would you like to take a break before we start? THE WITNESS: Yeah. (Short break.) ** 28 CROSS EXAMINATION BY MR. RICHARDS: Q. Mr. Rodberg I'm Joe Richards. I represent the Cities of Belle Glade and Clewiston. I want to get something straight before I get going. You--what division did you work in when you first came to the district? A. Worked in Technical services in, I guess it was called, Computer Management. I don't know the exact name it was called then. Q. Did you work in the Water Quality--Quality Division? A. Yeah, I worked as a four-month temporary in tech services, and then I moved to the Water Quality Division in Resource Planning. Q. How long were you in the Water Quality Division? A. From December 12th of '83. Q. And you're still in the water-- A. Well, the reorganization occurred, I think, six, seven, eight months ago, somewheres in there where. They split the research--or Resource Planning Department, and I was moved to the Environmental Planning Division of the Planning Department. ** 29 Q. Did your duties change when that switch occurred? A. My title remained the same. My duties changed slightly to encompass more departmental types of programming. Q. In reference to the chemical analysis archive system, is there a data base administrator for that system? A. That's me. Q. That's you. How long have you served as--in that capacity? A. I originally developed the system, so I have been administrator of the system from its start. Q. And are you familiar with the term "period of record"? A. Yes, I am. Q. What is the period of record of the data contained on the CAS system? A. The closest I can remember, the oldest data available is from some time in 1974. Q. And is that data updated on a regular basis? A. Yes, it is. Q. How often is it updated? ** 30 A. I archive data from the LIMS system on a weekly basis. Q. What are the sources of the data in this chemical archive system? MS. STOLLMAN: What do you mean by "sources"? MR. RICHARDS: Where the data originates from. A. Most of the data originates from the LIMS system. Some data does come from external laboratories and is transferred into the CAS system. BY MR. RICHARDS: Q. And before the data is on the LIMS system, where does it come from? A. To the best of my knowledge, it's from internal analysis in our laboratory. Q. Who at the district would be most knowledgeable as the origin of the data that ends up on the LIMS system? A. Tom Raishe. Q. Are there procedures that govern the transfer of data from the internal analysis to the LIMS system? A. I'm not familiar with the workings of the LIMS system. ** 31 Q. Who would--who would know that? A. Tom Raishe. Q. Are there procedures for the transfer of data from the LIMS to the CAS system? A. Yes, there are. Q. Are you familiar with those procedures? A. Yes, I wrote them. Q. Could you explain those procedures? A. Yes. The data is dumped on a weekly basis to a file prefixed by BR and then the date of the data dump. You then transfer this file using Cross Talk to a PC. I run a program I called LINE NUM 2 to reformat the data into various files that get transferred to the Britten Lee using a program called IDMF COPY and some assorted IDL routines that move them to the specific tables that they reside in. Q. Are there procedures to protect the integrity of the data during this transfer? A. Yes, there are. Q. Could you explain those procedures? A. The program itself, LINE NUM, checks for specific inconsistencies, makes sure the line numbers aren't duplicated or blank lines aren't included that would shift the file in any way. The actual IDL ** 32 routines that transfer the data into the specific columns make sure that the specific types of data they get merged into the file--or into the tables is consistent with what the data base was designed for. Q. Do you know who developed these programs? A. I did. Q. And once the information is in the CAS system, are there procedures to protect the integrity of the data while it is being used by individuals within the district? A. Yes, there are. Q. Could you explain those procedures? A. All of the data is write-protected. I have the only password that will allow any modifications or changes to the data. All the users have is read permission only. Specifically, there's three levels of passwords that have to be entered to get into the system. Q. What are those three levels? A. The first would be to access the first VAX. There is another password to get into the--the front end VAX, which is WMB3, and the third is the individual's actual name for the third level. Q. And these three levels provide read-only access to those users? ** 33 A. Yes. Q. And for the CAS system, is access provided to individuals or agencies outside the district? A. Yes. Q. And what type of access is granted to those users? A. Read-only. Q. Do you know what agencies or individuals currently have access to this system? A. The only agency would be the DER. Q. Are you aware of other agencies that have been granted access in the past? A. No, I'm not. Q. Are you aware of any individuals or agencies that have requested access to this system? A. Yes. Q. Who were they? A. Herb Zebis with the DER. Q. Any others? A. No. Q. Who at the district would make the decision whether outside access would be granted? A. I would actually be the person that would grant the permission. As far as whether someone would be approved or turned down would be decided by Bill ** 34 Hall, I would assume. Q. Are you aware of any agencies that have been denied access? A. No. Q. Does anyone at the University of Florida have access to the CAS system? A. I haven't provided a specific password to them. If someone has given them the actual user password the district employees use, they may have access. Q. Is there a normal procedure within the district for requesting access by an outside party? A. To which system? Q. To the CAS system. A. There's no formal procedure, no. Q. What, is there an informal procedure? What would someone do? A. The DER actually wrote a letter, I think, to John Wodraska, and it was transferred to my division director. Q. And DER has read-only access; is that correct? A. Yes. Q. Is this chemical archive system, the data contained on there, ever changed? ** 35 A. Yes. Q. Who would be the person that would make those changes? A. I would. Q. Anyone else? A. No. Q. Do you recall specific instances when you did change data? A. Yes. Q. Could you explain those to me? A. Project manager for a particular sample may decide that an analysis was incorrect, and the correct data value would be given to me to be entered. Q. Who has the authority to order a change to the data in the CAS system? A. The project manager of a sampling event. Q. Are there any guidelines within the district set up regarding the change of data once it's in the CAS system? A. There's no formal policy, no. Q. Do you have authority to change data? A. I only change data if a project manager requests it. Q. Have these changes to the data occurred on any regular basis? ** 36 A. No. Q. How often did these changes occur? (Short break.) THE WITNESS: What was the question again? MR. RICHARDS: Could you read it back, the question. (Thereupon, the question was read by the Reporter as recorded above.) A. Once or twice a month. BY MR. RICHARDS: Q. For the users within the district, do individual users have their own password, or is there passwords identical for different users? A. They are group passwords. Q. How are those group passwords assigned, by division or-- A. There is one group password for all district employees. There is another password for the DER. There is my own password into the system as administrator. And there's two other passwords for the sample analysis contract tracking system. Q. Is this one password all that's needed to access the system? MS. STOLLMAN: Which system? MR. RICHARDS: The CAS system. ** 37 A. The first two levels require one set of passwords. BY MR. RICHARDS: Q. And the third level? A. That is just an individual's name. Q. Who within the district is allowed direct access to the CAS system? A. What do you mean by "direct"? Q. Access. A. Oh, access in general? Q. Yeah. A. Everyone with a PC or terminal. Q. So that's anyone in the district. A. Yes. Q. They have to go through you to gain this access? A. Yes. Q. And is there guidelines that you employ to grant this access? A. No, there's not. To actually clarify, another person could tell another individual at the district what the password is to access the system. Q. Is access within the district ever limited? ** 38 A. No, it isn't. Only read--read access. Q. How many users can a system handle at any one time? A. By logging into the Micro VAX or WMD3 is restricted to eight simultaneous users. MS. STOLLMAN: Is this limited to the CAS system, again? MR. RICHARDS: Yes. A. The Britten Lee itself is capable of handling something like--in theory, it can handle over a hundred users. It's never been tested, though, at the district. BY MR. RICHARDS: Q. So what's the highest number of users that can presently use the CAS system at one time? A. By accessing it through the Micro VAX, eight is the limit. Q. Is there other ways to access besides through the Micro VAX? A. Through a PC. And we have a site license for another software package that will allow access to the Britten Lee. There's only two systems at the district that have access through this means. Q. So through PC's, you have a total of two people, through the Micro VAX you have eight? ** 39 A. Yes. Q. So am I correct in assuming that those ten different users can use the access to the CAS at one time? A. It could be transferred, the PC software could be transferred to as many PC's as I chose to do, so ten or more. Could I include one other thing? The actual reporting programs that make up the user interface to the CAS system are only available on the VAX, which is limited to eight users. Q. Is it possible to gain access to this CAS system at night or on weekends? A. Yes, it is. Q. Do people at the district typically use the CAS system at night or on weekends? A. Occasionally. Q. There's no regular users or night shift that would be using the CAS system at night on a regular basis? A. Weekly backups are done in the evenings, but there's no schedule or night crew that would be accessing it. Q. Do you think that additional outside access would cause a problem for the district if it was ** 40 limited to evening or weekends? MS. STOLLMAN: You can answer if you know. A. The major impact would be if the additional people were generating output files to be stored on the VAX, which would reduce the amount of available disk space to our district users. Viewing of data would not cause any problem, though. BY MR. RICHARDS: Q. Can the size or quantity of output files be limited? MS. STOLLMAN: Limited to what? BY MR. RICHARDS: Q. Do you understand the question? A. Yes, I do understand the question. It is possible that the size of the output files could be limited. The actual report that would be ran would probably abort if it exceeded the quotas that would be set. The software isn't actually installed to do that particular function, but it could be. Q. Would you be the person that would generate computer data for someone if it was requested, someone requested the data files from the CAS system? A. Occasionally I am asked to do that, yes. Q. Is there a set procedure for providing the ** 41 data files? A. Providing them to-- Q. To someone outside the district who requested the data set. A. We sent data to Mr. Roberts--and let's see, who else is there. Various external agencies. There's a pricing system that's developed to pay for the processing charges. But as far as procedures, I use myself to generate the reports. I am typically told by a supervisor to provide the report. The decisions are not made by me or whether it is provided or not. Q. So there is a set pricing guideline for-- A. Yes. Q. --this data? A. (Witness nods.) Q. Is the format in which data would be provided restricted in any way? A. I'm sorry? Q. Is the format in which you would provide this data restricted? A. Data that we would provide to other agencies is limited to straight reports of the data. No analysis is actually done to provide the statistics of any kind when we provide data. ** 42 Q. Do you generally provide the data in a format that it is requested? A. We have consistent reports that we use for data requests. Q. Who would be--at the district would be the most familiar with the formula used to generate the charges for data retrieval? A. For the CAS system, I have--did the actual calculations to decide on the prices. Q. What goes into those calculations, what an outside person would be charged for? A. It is--the cost figure is actually based on CPU time, man hours to generate the request, and the price per CPU second is calculated based on the machine size, processing speed type things. Q. Is anything else? A. No. Oh, I'm sorry. The media that it gets put on. Q. Do you charge for input and output time? A. Input? Q. From the disk to the tape or whatever media? A. Okay, I'm sorry. We charged for the time that it takes to generate the report, which is stored ** 43 on the disk, and then the amount of time it takes to transfer to a floppy or magnetic tape. Q. You mentioned that the CAS system also contains data from outside labs; is that correct? A. Yes. Q. Is there guidelines, procedures to guarantee the quality of that data? A. Quality of the data that comes from external labs that would be stored in the system would be checked or verified by the project manager of the analysis. Q. In reference to the backup procedures for the CAS system, do you know how long a backup is retained? A. Yes, I do. Q. How long? A. We use a grandfather system. Three sets of tapes are rotated. Backups are done every other week. Transaction dumps are done on a daily basis. And I'm not sure how long transaction dump cycle--I don't know how many tapes are actually included in that cycle, but the data base dumps are maintained approximately--I guess it would be six weeks. Q. Are backups performed after you make a change to that data? ** 44 A. I make the changes to the data on a weekly basis--or I add data on a weekly basis. Archives are done every other week--or not archives, but data base dumps. Transaction dumps are done on a daily basis. So yes, backups are done after data is changed. Q. Would this be true for the changes that we talked about earlier when the project manager would come to you and say that the data is incorrect? A. Yes. Q. And you mentioned--is there a different schedule for archiving the data, as opposed to backing it up? A. Archiving happens every Tuesday evening or Wednesday during the day. The archival is the transfer of data from the LIMS. The backup itself is done every other Friday in the evening. Q. Is there a different procedure for retaining this archive? A. The archive is the CAS system. Q. Are you familiar with the term "discharge code"? A. Yes, I am. Q. Could you explain to me what they are? A. There's three codes for discharge. One is upstream, down--well-- ** 45 MS. STOLLMAN: Are these codes used on the computer that you're referring to? A. Yes, they are. The district--I'm sorry. The discharge code isn't upstream-downstream. It's flow, no flow, or backflow, I think. BY MR. RICHARDS: Q. Are there any other codes just besides those three? A. For discharge code? Q. Um-hum. A. No. Q. Is the flow discharge code referred to as normal? A. Normal? Not that I'm aware of. Q. Are there a number assigned to these different-- A. Yes. Q. --these three? A. Zero, one and two. Q. Which is which? A. I couldn't tell you. Q. No? And there's no others? ** 46 A. Discharge, no. Q. In reference to the groundwater ambient system you referred to earlier today, is there a period or period of record for the data contained on this system? A. Yes, there is. Q. Do you know what that is? A. I can't give you a specific date. It would be when the Water Quality Assurance Act started. Q. Who would be most familiar with this at the district? A. Jeff Hare. Q. Do you know the size of this data base? A. I don't have a good feel for how large it has gotten since I trans--transferred control of it to Jeff Hare. Q. He would be the one to ask? A. Jeff Hare. Q. Yes? A. Yes. Q. In reference to the district's rainfall chemistry data, is that located on the CAS system? A. Yes. Q. And is it also located on the Perkin Elmer LIMS system? ** 47 A. Yes. Q. Is there any difference between the data, rainfall chemistry data contained on the CAS versus the Perkin Elmer? A. No, there isn't. There may be additional data on the CAS system. Q. When you create--you mentioned creating graphic information, such as time series for rain and water quality; is that true? A. Yes. Q. Did you keep copies of this information on your personal file-- A. There may be some-- Q. --in your personal records? A. There may be some of those files still in my diskettes or hard disk. I couldn't tell without looking for them. Q. Do you have a procedure usually you follow for retaining copies of analyses performed? A. No, I don't. Q. So for a particular analysis, you would just have to check your files to see whether you had that-- A. Yes. Q. --a copy of that. ** 48 A. I typically rerun the analysis rather than try and track down old ones. Q. Can the CAS system be accessed by a BT 100 terminal? A. Yes. Q. Do you know the telephone number for gaining access to the CAS system? A. No, I don't. Q. Who would know that? A. David Sweet. Q. In reference to the CAS chemical analysis data, is this data transferred to other agencies on a routine basis? A. Yes, it is. Q. What agencies? A. The Everglades National Park for one. I know the Miccosukee Indians get some data on a regular basis. I think the DER gets some of it on a regular basis, also. I'm not aware of any others. It's possible there are. Q. Do you know who performs these transfers? A. Guy Germain and Kathy Pietro are two of the people that would know. There may be additional people, though. ** 49 Q. Are there any other archives of water quality data besides the CAS system and the Perkin Elmer or LIMS? A. The groundwater ambient data base also stores water quality data. Q. Any others? A. I think some types of water quality analysis are stored in the DB Hrdro. Q. Does DB Hrdro have a data base administrator? A. Yes. Q. Do you know who that person is? A. I'm not sure if--exactly who it is. I know one--one person that is somewhat responsible for the system is Brian Turcotte. Q. Last Friday when we--the first portion of your deposition, you mentioned you had some pesticide data that you took from an outside lab and put on your computer for Mr. Fieve; is that correct? A. Yes. Q. Were there any steps taken to catch input errors from that transferring data? A. It was simply copying data files from a floppy onto the hard disk using dos' copy command. Q. Where did that data come from? ** 50 A. I don't know the name of the lab. Q. Is there a procedure set up for the CAS system to prevent the infection of bad--with bad data? A. Pardon me? Q. Is there a procedure in the CAS archive system to prevent the infection with bad data? MS. STOLLMAN: Do you understand the question? THE WITNESS: No, not really. BY MR. RICHARDS: Q. Is there a system to prevent the infection of a computer virus? A. No, there's nothing that I'm aware of at the district that prevents that. Q. You stated that you are the only person that has read/write access to the CAS system? A. That's correct. Q. Has there been any other person at any time that's had that access? A. Yes. Q. Who are those people? A. Karen Marsil and David Sweet. Q. Do you know for what purpose these two individuals were granted the write access? A. They were alternate data base ** 51 administrators. Q. When did that occur; do you know? A. Karen Marsil was an alternate when the system was first purchased, and David Sweet was assigned to alternate after she left the district. Q. David Sweet's presently the alternate on this system? A. Yes. Q. And under what circumstances would this alternate access this system in a write mode? A. He never has. Q. He never has, okay. Is there anyone else that--under any circumstances, that has had write access to the CAS system? A. There's a subset of the CAS system for the Indian River Lagoon project which Guy Germain enters data. It is not--he does not have access to any other tables other than what he's responsible as his data. Q. So he has access to the Indian River Lagoon data only? A. Yes. Q. Is there anyone else? A. No. Q. Are you aware of any accidental loss of ** 52 data from the CAS system? A. Currently, no. Q. Are you aware of any time in the past where data has been lost on the CAS system? A. The system did have a complete crash a couple of years ago, but it was completely rebuilt. Q. There was no data lost from the period of record that you're aware of? A. No. Q. Is anyone able to access the CAS system from their home, any district employees? A. If they have a modem and a personal computer or a terminal in their house. Q. That would be read-only access? A. That's correct. Q. Do you ever access the CAS system from your home? A. Yes. Q. Would that be read-only access? A. No. Q. When you access the computer from your home, do you--by what method do you access the computer? A. I currently don't have a phone, so I'm--I don't do it now. In the past, I would dial in to the ** 53 district's central modems to the network and access as if I was in the building. MR. RICHARDS: That's all I have. Thank you. (Thereupon, the deposition was concluded at 11:33 a.m.)