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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 )
REGULATION; AND DALE TWACHTMANN, )
SECRETARY, FLORIDA DEPARTMENT OF )
ENVIRONMENTAL REGULATION, et. al., )
)
Defendants. )
/
DEPOSITION OF RUDI VYHNANEK
TAKEN ON BEHALF OF THE PLAINTIFF
***
DATE: August 28, 1990
PROFESSIONAL REPORTING SERVICE
Commerce Center
324 Datura Street, Suite 303
West Palm Beach, Florida 33401
(407) 659-4046
** 2
INDEX
August 28, 1990 DIRECT CROSS REDIRECT RECROSS
RUDI VYHNANEK
By Ms. Beverly Nash 5
By Mr. Joe Richards 18
** 3
The deposition of Rudi Vyhnanek, in the
above-entitled and numbered cause, was taken before
me, KAREN BAUER FRY, C.S.R., Court Reporter and
Notary Public for the State of Florida at Large, at
Professional Reporting Service, Commerce Center,
324 Datura Street, in the City of West Palm Beach,
Palm Beach County, in the State of Florida,
beginning at the hour of 11:30 o'clock a.m., on
August 28, 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
Plaintiff in the above-entitled action pending in
the above-named court.
The appearances at said time and place were
as follows:
Beverly Sherman Nash, Esquire
U.S. Department of Justice
Environmental and Natural
Resources Division
P. O. Box 663
Washington, D.C. 20044-0663
Attorney for Plaintiff
Joseph Richards, Esquire
Peeples, Earl & Blank, P.A.
Two South Biscayne Blvd.
One Biscayne Tower, Suite 3636
Miami, Florida 33131
Attorney for Cities of Belle Glade
and Clewiston
** 4
Katharine Stollman, Esquire
Allison Burdette
Skadden, Arps, Slate, Meagher, & Flom
1440 New York Avenue, N.W.
Washington, D.C. 20005
Attorney for South Florida Water
Management District
Jackie Waters, Esquire
So. Florida Water Management District
Box 24680
3301 Gun Club Road
West Palm Beach, FL 33416
ALSO PRESENT: Toni Lafuente
Mike Rose
David Buker
Ray Roberts
** 5
THEREUPON,
RUDI VYHNANEK
being by me first duly sworn to tell the whole truth,
as hereinafter certified, testified as follows:
DIRECT EXAMINATION
BY MS. NASH:
Q. Mr. Vyhnanek, I'm Beverly Nash, counsel
for the United States in this litigation.
We're here at this deposition because the
United States wants to understand the Water
Management District's computer systems, how
they're used, what the data is on them, how the
data is formatted.
You have been presented as a
representative of the Water Management District
having knowledge of one or more areas that we are
interested in.
Have you been shown the list of
categories?
A. Yes, I have. I've seen it on my subpoena.
Q. And do you know which categories you're
able to respond?
A. I'm not 100 percent sure.
** 6
Q. I'll show you the list and you can see if
you can tell me which ones you believe you have
knowledge?
A. Some in Category 2, possibly. Maybe a
little bit in 3. Possibly -- well, I guess not
really Item D, but of 9, that's probably about it.
Q. What is your present title or position?
A. I'm a control systems supervisor.
Q. In what position or department?
A. It's the operations division, department
of operations and maintenance.
Q. What are your job responsibilities?
A. Basically, I have the responsibility for
staff that's responsible for maintaining our
communication and control system computers.
Q. And how long have you been a control
systems supervisor?
A. That's -- I don't exactly know -- several
years.
Q. Have you had other positions with the
Water Management District?
A. Yes, I have.
Q. What have those positions been?
A. Let's see. I believe programer analyst
and systems programer.
** 7
Q. In what division were you a programer
analyst?
A. That was -- at that time technical
services.
Q. And how long were you a programer analyst
in technical services?
A. Let's see. Approximately two years. I
believe, I transferred approximately 1980 to
operations and maintenance.
Q. And what were your responsibilities as a
programer analyst in tech services?
A. I was originally working on a data base
project that was later canned by the district. It
was an unsuccessful development effort.
Q. Any other work where you were a programer
analyst?
A. Let's see. I did a project for -- I guess
it was the chemistry lab at one point in time.
Q. What was the nature of that project?
A. Let's see. It was to do an analysis of
phosphates and total Kjeldahl nitrates.
Q. And when was that analysis done?
A. There wasn't really an analysis that was
done. It was just a software package that was
developed at their request, which has later than
** 8
been replaced by the LIMs System.
Q. What's your educational background?
A. Okay. I have got an associates degree in
data processing; and then, I have a bachelor's
degree in management sciences.
Q. Who are your supervisors in the operations
division?
A. George Hwa and Ron Mierau, the director.
Q. What is Mr. Hwa's title?
A. He is the assistant chief of operations.
Q. Are there employees within the operations
division who work for you?
A. Yes, there are.
Q. How many?
A. Right now, two.
Q. And what are their names and positions?
A. Okay. One position has just been filled.
It's been vacant. The new employee to take that
position's name is Dean Corry, and he will be
coming on board the 20th of September.
Q. And what will his title be?
A. Control systems engineer.
Q. And the other position?
A. Paul Ryan.
Q. And what is his job?
** 9
A. Senior systems analyst.
Q. You indicated that your job is to oversee
the maintenance of the control system computers?
A. A hardware and software, maintenance
development.
Q. Which computers are those?
A. The Modcomp computers.
Q. And what's the operating system on the
Modcomp computers?
A. Max Four.
Q. And what software packages are utilized on
Modcomp?
A. It's a custom supervisory control and
data acquisition system.
Q. Who developed this custom system?
A. DBA Associates.
Q. Did they develop it uniquely for the Water
Management District?
A. Yes.
Q. And what does this software package do?
A. It acquires data from remote sites.
Q. What is the nature of that data that it's
acquiring?
A. Stage levels, gate positions, and
rainfall, and conductivity and various sensors that
** 10
are used for electronic diagnosis of the hardware
functionality out in the field.
Q. What is the hardware that's out in the
field that provides this data?
A. I'm not sure I understand the question.
Q. What is it that's out in the field that
provides the stage level data?
A. The sensors.
Q. Where are those sensors located?
A. We have 53 remote sites connected to our
network.
Q. Is there a map or other listing of where
those remote sites are?
A. Yes, there is.
Q. Does that map or listing have a name?
A. Not that I'm aware of.
Q. Where is that map or listing?
A. It's on the wall.
Q. Where, in your office?
A. In the control center, yes.
Q. Are there any other software packages that
you utilize?
A. Yes.
Q. What other software?
A. We use -- on the PCs, they use Symphony,
** 11
Picture Perfect, some communication software
packages. Let's see. On the Micro VAX, we use
Wollongong, TCP/IP, Interconnect, and the Oracle
data base.
Q. Which PCs are utilized by the division?
A. Each member has their own PC.
Q. Do you know which brand or model?
A. They're IBM.
Q. What does the Picture Perfect software
package do?
A. They use that to prepare monthly reports.
Q. What's the nature of these monthly
reports?
A. I don't know 100 percent what they're used
for.
Q. Who would know?
A. The assistant director or the director of
my division.
Q. And that was Mr. Mierau or Mr. Hwa?
A. That's correct.
Q. You indicated that there are communication
software packages also used on the PC?
A. Yes.
Q. And what are they?
A. There are two. One is a custom developed
** 12
package. It's a Pascal program that accesses
remote sites in the Kissimmee Valley, and it's
called the HITS System for Hydrologic Interim
Telemetry System.
Q. Any other?
A. Yes. I'm not 100 percent sure what the
name of the package is, but it's a communications
packages that -- the name of it I'm not sure of
that -- it's a communications package that also has
the capability of retrieving data from several
remote sites.
Q. Who developed these communications
packages?
A. The HITS was developed by a contractor to
our electronics division.
Q. Do you know the name of the contractor?
A. I believe his first name is Wesley, but I
do not know his last name.
Q. And do you know who developed the other
communications package?
A. Rod Mierau.
Q. And you indicated that a software package
called Wollongong is utilized on the Micro VAX?
A. That's correct.
Q. What does that software package do?
** 13
A. We're using that for -- to give the Micro
VAX the capability of using the TCP/IP for a --
Q. And what does the TCP/IP do?
A. It's an industry standard. It's a
Department of Defense communication standard.
Q. What is the nature of the work being done
on the Micro VAX?
A. It's collecting the real time acquired data
from the Modcomp computer systems as an interim
storage.
Q. Where does the data that's being collected
go for permanent storage?
A. Data management.
Q. Do you know on what computer?
A. I'm not 100 percent sure. I know it's a
DEC computer.
Q. Is any processing done in your division on
this real time acquired data before it goes to data
management?
A. None.
Q. Is any processing of the data done between
the Modcomp computer and the Micro VAX?
A. I'm sorry. I didn't hear that. I was
talking about getting some more water.
Q. Do you want to take a break to --
** 14
A. Just a second to get some water.
(Short break.)
Q. (By Ms. Nash) You indicated that the data
from the remote sites that's acquired is acquired
via the Modcomp computer, and then, it goes to the
Micro VAX; is that correct?
A. That's correct.
Q. Is there any processing done between the
Modcomp -- or on the Modcomp computer or between
the Modcomp computer and the Micro VAX on the data?
A. No.
Q. Do you know the name of the data base that
the data is in when it gets to data management?
A. No, I do not.
Q. Do you know who would know?
A. I'm sure someone in data management.
Q. Is there any documentation or manuals that
assist you in utilizing the Modcomp computers?
A. There is an operator's manual.
Q. Does that operator's manual have a name?
A. I could not give you a specific name on
that.
Q. Are there any documentation or manuals
** 15
that assist you in utilizing the Micro VAX
computer?
A. Yes.
Q. What?
A. It's a pretty poor state of documentation
on that. It was left by the previous programer.
Q. Do offices outside the operations division
have access to the data on the Modcomp computers?
A. The real time data over the network, they
do, if they have proper security.
Q. Do you know which offices of the Water
Management District access the data on the
Modcomp?
A. I know the field stations do.
Q. Are you aware of any other offices or
divisions that access the data on the Modcomp?
A. Let's see. I couldn't tell you. I'd have
to look at the security password file to give you an
accurate answer on that.
Q. Is the security password file just for the
Modcomp computer?
A. That's correct.
Q. Do you know whether there are entities
outside your division that have access to the data
on the Micro VAX?
** 16
A. That, again, is on the network and would
require proper security. If I said, "Modcomp," I
meant "Micro VAX."
Q. Do you know whether there are any entities
outside the Water Management District that have
access to the data on the Modcomp?
A. Not at the present time.
Q. Have any entities in the past had access
to --
A. The Corps of Engineers expressed interest
years and years ago, but they didn't have the
proper equipment on their end to make the
connection.
Q. Any other entities that you're aware of?
A. None that I'm aware of.
Q. What about on the Micro VAX, are there any
entities outside the Water Management District
that of have access?
A. No.
Q. Have there ever been any?
A. No.
Q. Are there procedures for backing up the
data on the Modcomp?
A. Let's see. At midnight every night, the
previous 24 hours work of historical data is backed
** 17
up to magnetic tape as a precaution, should it not
be loadable from the Micro VAX.
Q. What is the retention period for those
back-up tapes?
A. I do not know.
Q. Who would know?
A. That again would be data management.
Q. Are there procedures for backing up the data
on the Micro VAX?
A. No, we don't back-up the data.
Q. Is there anywhere where permanent record
of the data received from the remote sites is
maintained?
A. That would be in data management.
Q. Do you know how far back the data is
maintained?
A. Not exactly. No, I don't.
Q. Who would know?
A. Data management.
Q. Is any analysis done on the data in the
operations division?
A. Not that I deal with. Not that I am aware
of.
Q. You indicated that you had some knowledge
on (9) d., which is the use of remotely sensed data
** 18
to prepare vegetation maps. What is the extent of
your knowledge?
A. Well, when I thought about that a little
bit more, I got that confused with our accessing
remote data, because our data is not used to
prepare vegetation maps.
Q. Do you know what use is made of the data
on the Modcomp computer?
A. We use it in our division as an aid in
making operational decisions.
Q. What is the nature of these operational
decisions?
A. Those would be gate controls.
MS. NASH: I have no further
questions.
CROSS-EXAMINATION
QUESTION BY MR. RICHARDS:
Q. Mr. Vyhnanek, I'm Joe Richards. I
represent the cities of Belle Glade and Clewiston.
You just stated that you utilized remote
data to aid in making operational decisions. What
information do you obtain from this data to help
you in making those decisions?
** 19
MS. WATERS: Is this related to
computer data that you're asking him?
MR. RICHARDS: Yes.
MS. WATERS: If you know, you can
answer that question.
A. I don't make the decisions. That's done
by the chief of operations. The information
provided by the system includes water levels, gate
positions, pump rpm, and conductivity.
Q. (By Mr. Richards) Are you familiar with
the process by which data is transferred from the
field sensors to the computer?
A. Yes, I am.
Q. Could you explain that process, please?
A. Yes. We have a private microwave network
that was built by General Dynamics in the mid
Seventies, and we go out from our computer over the
microwave network to a master unit, and that master
unit in turn initiates VHF communications to remote
sites on the canals.
Q. Is there a process by which the accuracy
of the data so transmitted is checked?
A. No. It's real time data.
Q. How frequently do the remote sensors
transmit data to the control center?
** 20
A. The remote sensors do not transfer data to
the control center.
Q. How often is information of chain obtained
from the remote sensors?
A. At various rates. Some of the coastal
structures are pulled at 1 minute intervals. Some
of the inland structures are pulled at 5 to
15-minute intervals. Some of the solar sites are
pulled at 1 hour intervals.
Q. What type of data would be obtained that
way?
A. That's the same data I gave you before.
Probably I omitted rainfall.
Q. When the data is transmitted to data
management, is that raw data or average data
values?
A. It's the raw data.
Q. What department is data management located
in?
A. I believe in planning. They change so
often.
Q. And the individuals who access the data on
the Modcomp computers, do they have read only
access?
A. With the exception of the chief of
** 21
operations and his assistant, they have -- they can
actually do gate controls, all accesses read only.
Q. And for the Micro VAX, do they have read
only access, also?
A. It depends on the application.
Q. Could you explain that?
A. Yes. In addition to the Micro VAX
collecting the real time data from the Modcomp,
there are two Oracle data bases set up for manual
data entry.
Q. So other than the individuals making this
manual data entry, the others would have read only
access?
A. That's correct.
Q. Does your division deal with any water
quality data other than the conductivity that you
mentioned?
A. No.
Q. Does your division generate discharge
values for the different structures?
A. We generate discharge in real time to
assist the assistant director and director, but
those aren't the official archival discharge
values.
Q. They aren't or are?
** 22
A. They are not.
Q. Who performs these discharge
calculations?
MS. WATERS: Is this related to
discharge calculations on the computers?
MR. RICHARDS: Yes.
A. I'm not 100 percent sure of that. I know
it's not within our division.
Q. (By Mr. Richards) The discharge values
that are conducted in real time within your
division, who does that?
A. That's done by the software.
Q. Which software is that?
A. That's the SCADA software I mentioned
earlier.
Q. Are these real time discharge values
retained?
A. They go to the historical archive.
Q. And that would be in data management?
A. I'm referring to the magnetic tape. I do
not know if that particular data value is used by
data management. I believe they have their own
set, which is the official district's way of
computing discharge down there.
Q. What computer is this real time discharge
** 23
calculated?
A. That's on the Modcomp.
Q. So the values would be retained on the
back-up tapes for the Modcomp?
A. That's correct.
Q. Do you know how long these back-up tapes
are retained?
A. No, I don't, that's data management again.
Q. In what format is the data provided to the
data management division?
A. It's output from the Oracle data base.
Q. There's two Modcomp computers; is that
correct?
A. That's correct.
Q. How do you distinguish between the two?
A. One runs prime, and the other one is a hot
back-up, A and B.
Q. Which is which?
A. It depends on which is prime that day.
All I can give you is by physical location, the one
on the right is A, and the one on the left is B.
Q. Does your division make use of any
satellite imagery?
A. We have a GOES Satellite Tape, that is
used by our meteorologist. That is the same thing
** 24
that you see on the weather reports on television.
Q. Does your division make use of any aerial
photography?
A. No.
Q. Is any of the data utilized by your
division manually inputted?
A. Would you repeat that, please?
Q. Is there any manual input of data utilized
by your division?
A. Yes, it is. I've got to mention, though,
that the way we're using it, our manual data does
not go to data management, only the real time
telemetry data that's on the Micro VAX. The system
that we have on the Micro VAX is a prototype data
base. I believe all the official data that's used
for reporting within our division is obtained from
data management.
Q. What is the nature of the manually
inputted data?
A. Stage readings on water levels that are
phoned in from the field.
Q. Is there a guideline for the input of this
data?
A. I don't understand your question.
Q. Is there quality assurance or quality
** 25
control guidelines for the input of this data?
A. These are just the readings that are
gotten by the water readers that are phoned in or
radioed into the control center. There are no
software checks of limits or rates of change on any
of the data.
Q. Is there any manual checks of the accuracy
of this data?
A. There is, but I'm not familiar with that
procedure.
Q. Who would be?
A. The chief of operations.
Q. Ron Mierau?
A. That's correct, or his assistant George
Hwa.
Q. How frequently are the remote sensors
calibrated?
A. I'm not familiar with that procedure.
Q. Who would be?
A. That, again, would be the director of the
division.
MR. RICHARDS: Okay. Thank you. I
have no further questions.
** 26
(The deposition was concluded at
12:20 o'clock p.m.)
