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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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** 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.)
