DR. QUALLS VOLUME II PAGE 289
MS. PONZOLI: ALL RIGHT. READY?
WITNESS: YES.
EXAMINATION BY MS. PONZOLI CONTINUES:
Q. OKAY, YOU'VE MADE SEVERAL REFERENCES TO THE DOSING
STUDY OF THE PARK, DR. QUALLS.
A. UH-HUH (YES).
Q. DO YOU UNDERSTAND IT TO HAVE BEEN DESIGNED TO
DETERMINE A THRESHOLD OF TOTAL PHOSPHORUS IN THE
WATER COLUMN ABOVE WHICH CHANGES IN THE FLORA AND
FAUNA WOULD OCCUR?
A. I WOULD -- I'M NOT QUITE SURE. BUT I KIND OF MORE
UNDERSTOOD IT AS A STUDY MEANT TO DETERMINE
WHETHER PHOSPHORUS WAS OR WASN'T, AND NOT
SPECIFICALLY A CERTAIN THRESHOLD.
Q. IS YOUR DOSING STUDY DESIGNED TO DETERMINE AN
ACTUAL THRESHOLD AT WHICH THERE ARE CHANGES?
A. YES, UH-HUH (YES).
Q. OKAY. WHY DO YOU GO SO HIGH?
A. OH, SO HIGH, UP TO ONE HUNDRED AND FIFTY?
Q. YES. UH-HUH (YES).
A. JUST IN CASE WE WANT TO SEE WHAT REALLY A WHOLE
LOT OF PHOSPHORUS WOULD DO. JUST IN CASE WE
DON'T SEE ANYTHING AT LOWER LEVELS, WE WANT TO
KNOW AT LEAST AT SOME LEVEL IS PHOSPHORUS EVER
DR. QUALLS VOLUME II PAGE 290
LIMITING. AND, NUMBER TWO, BECAUSE THERE HAVE
BEEN CONCENTRATIONS OF ORTHOPHOSPHATE AS HIGH AS A
HUNDRED AND FIFTY MICROGRAMS PER LITER REPORTED IN
THE CANALS THEMSELVES, BASED ON SOUTH FLORIDA
WATER MANAGEMENT DISTRICT DATA.
Q. WHAT IF THE -- WHAT IF THE THRESHOLD IS BELOW THE
THIRTY THAT YOU HAVE AS YOUR LOWEST EDITION?
A. THEN, IF IT'S BELOW THE THIRTY, THEN WE WOULD SEE
CHANGES IN ALL OUR TREATMENTS, AND WE WOULDN'T BE
ABLE TO SAY WHETHER IT'S, YOU KNOW, BETWEEN, SAY,
ZERO AND THIRTY---
Q. AND YOU'D---
A. ---RIGHT. AT THAT POINT, YOU KNOW, IF THE
THRESHOLD---
Q. ---YOU'D HAVE TO START ALL OVER?
A. ---IF THE THRESHOLD IS TEN, WE WOULD ONLY BE ABLE
TO SAY THAT IT'S UNDER THIRTY. BUT THE REASON WE
DECIDED ON THIRTY, WAS BECAUSE AT THE TIME WE
ORIGINALLY DESIGNED THE STUDY, THE PROPOSED
STANDARD, I BELIEVE IN ONE OF THE EARLIER DRAFTS
OF THE SWIM PLAN, WAS THIRTY MICROGRAMS PER LITER.
AND THEN I THINK SINCE THEN IT'S BEEN CHANGED TO
SOMETHING A LITTLE HIGHER THAN THAT, THE PROPOSED
STANDARD.
DR. QUALLS VOLUME II PAGE 291
Q. I'D LIKE TO TAKE A LOOK AT YOUR "GEOCHEMISTRY OF
DISSOLVED ORGANIC NUTRIENTS IN THE EVERGLADES OF
FLORIDA." I THINK THAT'S WHERE WE WERE BEFORE WE
BROKE. IS THAT RIGHT?
A. UH-HUH (YES).
MR. McCAUGHAN: IS THAT IN -- IT'S
NOT IN HERE. IT'S NOT.
WITNESS: NO, THAT'S NOT IN THERE.
OH, WELL, IT IS, IN THE SENSE IT'S A -- IT'S
BITS AND PIECES LIFTED FROM CHAPTER SIX,
BASICALLY.
Q. (BY MS. PONZOLI) OKAY. YOU KNOW, I'M GOING TO
ASK YOU A COUPLE OF QUESTIONS ABOUT A FEW
STATEMENTS YOU MAKE, AND I UNDERSTAND YOU'VE TOLD
US THAT THIS IS A SKELETAL DRAFT, SO IF YOU THINK
THESE STATEMENTS ARE -- WHATEVER YOU THINK THEY
ARE, IT IS YOUR OPPORTUNITY TO TELL ME. ALL
RIGHT?
A. UH-HUH (YES).
Q. I MEAN, WE HAVEN'T -- THAT'S FAIR?
A. UH-HUH (YES).
Q. ALL RIGHT. YOU'RE TALKING ABOUT DISSOLVED ORGANIC
MATTER IN THIS -- IN THIS DRAFT PAPER?
A. UH-HUH (YES).
DR. QUALLS VOLUME II PAGE 292
Q. ALL RIGHT. AT THE BOTTOM OF THE FIRST PAGE,
YOU'RE TALKING ABOUT THE SWIM PLAN AS "MANDATE
IMPROVEMENT IN WATER QUALITY AND THESE PROPOSED
STANDARDS ARE EXPRESSED AS TOTAL PHOSPHORUS AND
TOTAL NITROGEN."
A. RIGHT.
Q. "OUR PREVIOUS RESEARCH HAS SHOWN THAT
APPROXIMATELY ELEVEN TO THIRTY-TWO PERCENT OF THE
TOTAL PHOSPHORUS, AND OVER NINETY-FIVE PERCENT OF
THE TOTAL NITROGEN IS IN THE DISSOLVED ORGANIC
FORM IN SURFACE WATER." DO YOU BELIEVE THAT THESE
NUMBERS ARE STILL ACCURATE, BASED ON THE WORK THAT
YOU'RE PRESENTLY DOING?
A. BASED ON THE WORK THAT I'M PRESENTLY DOING -- I
THINK WHERE I HAD GOTTEN THOSE -- THOSE NUMBERS
FROM, IS PROBABLY FROM SOMEWHERE IN -- ALONG THE
GRADIENT STUDY. IN OTHER WORDS, IT SEEMS LIKE I
PROBABLY LOOKED AT THESE PIE DIAGRAMS. LET'S SEE
IF THAT JIBES.
Q. WHERE WERE THE PIES, AGAIN?
MR. McCAUGHAN: 268?
A. OH, PAGE 230. YEAH, IT SAYS "OUR PREVIOUS
RESEARCH HAS SHOWN THAT APPROXIMATELY ELEVEN TO
AROUND THIRTY-TWO PERCENT OF THE TOTAL PHOSPHORUS
DR. QUALLS VOLUME II PAGE 293
IS IN THE DISSOLVED ORGANIC FORM IN SURFACE
WATER," AND IF YOU'LL LOOK AT---
Q. SO, YOU'RE SAYING SIXTY-EIGHT TO EIGHTY-NINE
PERCENT, ROUGHLY, WOULD BE AN INORGANIC. IS THAT
WHAT IT MEANS?
A. OH, NO, BECAUSE THERE'S ALSO SUSPENDED PARTICULATE
PHOSPHORUS.
Q. OH, OKAY.
A. THAT'S STRICTLY TALKING ABOUT THE DISSOLVED
ORGANIC FORM.
Q. OKAY. BUT DO YOU THINK THOSE NUMBERS ARE RIGHT,
BASED ON YOUR PIES?
A. YEAH, WHAT I GOT THAT FROM IS IF YOU'LL LOOK AT
THE PIE IN THE LOWER RIGHT-HAND CORNER, THAT
PROBABLY REPRESENTS THE HIGH PERCENTAGE THERE,
WHICH IS ABOUT THIRTY-THREE PERCENT, IS IN THE
FORM OF DISSOLVED, ORGANIC PHOSPHORUS. AND THEN
IF YOU LOOK AT THE ONE IN THE UPPER -- UPPER
RIGHT-HAND CORNER, THAT'S APPROXIMATELY ELEVEN
PERCENT THERE IN THE HIGH NUTRIENT INPUT PLOTS,
WITH THE GATES OPEN. THAT'S APPROXIMATELY ELEVEN
PERCENT.
Q. OKAY. TURNING TO RESULTS AND DISCUSSION UNDER
"DISTRIBUTION OF DISSOLVED ORGANIC NUTRIENTS IN
DR. QUALLS VOLUME II PAGE 294
WATER CONSERVATION AREA 2A," SECOND FULL PARAGRAPH
OF YOUR DRAFT PAPER. I DON'T THINK THESE PAGES
ARE NUMBERED.
A. OH, RESULTS AND DISCUSSIONS, SORRY. YEAH, OKAY.
YEAH, PHYSICALLY, I THINK THAT'S PAGE NUMBER FOUR.
THEY'RE NOT NUMBERED, UNFORTUNATELY.
Q. OKAY. YOU'RE TALKING ABOUT, "DISSOLVED ORGANIC
CARBON AND NITROGEN DECREASE WITH DISTANCE ALONG
THE NUTRIENT GRADIENT AT WATER CONSERVATION AREA
2A BOTH IN SURFACE AND SOIL PORE WATER."
A. UH-HUH (YES).
Q. "THE CONCENTRATIONS IN SOIL PORE WATER TEND TO BE
ONE POINT FIVE TO TWO TIMES THOSE IN THE SURFACE
WATER."
A. UH-HUH (YES).
Q. I -- WHAT MY QUESTION IS, IS THAT THIS IS BASED ON
DATA COLLECTED WHERE?
A. ALONG THE GRADIENT STUDY.
Q. OKAY. ANY IN 3A OR 2B?
A. NO.
Q. OKAY. SO, THIS IS THE SAME DATA THAT WE'VE BEEN
TALKING ABOUT?
A. THAT'S RIGHT, YEAH, THE DATA THAT APPEARS IN
CHAPTER SIX, IN FIGURES 6-20, 6-21, AND 6-22. AND
DR. QUALLS VOLUME II PAGE 295
THOSE ARE PLOTS OF DISSOLVED ORGANIC CARBON AND
DISSOLVED ORGANIC NITROGEN, AS A FUNCTION OF
DISTANCE ALONG THE GRADIENT IN WATER CONSERVATION
AREA 2A.
(THEREUPON MS. PONZOLI AND MR. JONES CONFER.)
Q. (BY MS. PONZOLI) ALL RIGHT. I'D LIKE YOU TO TURN
BACK TO THE "BIODEGRADABILITY OF DISSOLVED ORGANIC
MATTER."
A. OKAY.
Q. IT'S JUST ABOUT THREE PAGES FROM THE END.
A. UH-HUH (YES).
Q. WHERE IT TALKS ABOUT "APPLICATION--DISSOLVED
ORGANIC NUTRIENTS?"
A. YEAH.
Q. ALL RIGHT. AND YOU'RE SORT OF LIKE HALFWAY DOWN
THE PARAGRAPH, YOU'RE SAYING "SUNLIGHT DEGRADES
THE FRACTION, WHICH IS THE ONE WHICH IS MOST
RESISTANT, PERHAPS INHIBITORY, TO MICROBIAL
DEGRADATION."
A. YES, AND THAT IS TALKING ABOUT THE HUMIC ACID
FRACTION.
Q. OKAY. NEXT, YOU SAY, "IN TERMS OF THE
EUTROPHICATION IN THE EVERGLADES, IT WOULD BE
CONSIDERED DESIRABLE IF THE DISSOLVED ORGANIC
DR. QUALLS VOLUME II PAGE 296
NUTRIENTS WERE NOT MINERALIZED AT ALL AND SIMPLY
FLOWED THROUGH THE SYSTEM." I THINK THAT SAME
SENTENCE APPEARS IN CHAPTER SIX, DOESN'T IT?
A. YES, IT IS. THAT -- IN FACT, IT'S JUST BASICALLY
CUT AND PASTED FROM CHAPTER SIX.
Q. OKAY.
A. YEAH.
Q. OKAY. WITHOUT LOOKING FOR IT THERE, LET'S JUST
DEAL WITH IT HERE. DO YOU THINK THIS ACTUALLY
HAPPENS? IS THIS THE WAY YOU BELIEVE IT HAPPENS?
A. OH, NO, I THINK THAT THERE IS SOME MINERALIZATION
OF THE DISSOLVED ORGANIC NUTRIENTS. I WAS SAYING,
YOU KNOW, TRYING TO SET UP, YOU KNOW, WHAT WOULD
BE A DESIRABLE SITUATION, WHAT ROLE WOULD THESE
DISSOLVED ORGANIC NUTRIENTS PLAY IF THEY WERE OR
WERE NOT AVAILABLE. AND SINCE WHAT WE'RE WORRIED
ABOUT HERE IS EUTROPHICATION, THEN IT WOULD BE
BETTER IF THEY SIMPLY FLOWED THROUGH THE SYSTEM
AND WENT OUT THROUGH THE CANALS TO THE OCEANS,
WITHOUT EVER HAVING BEEN MINERALIZED.
Q. IT WOULDN'T BE BETTER FOR FLORIDA BAY, WOULD IT?
A. NO, I GUESS IT WOULDN'T, AS LONG AS IT -- ASSUMING
IT WAS NOT MINERALIZED THERE, RIGHT. BUT MOST OF
THE WATER ACTUALLY GOES OUT THE OCEAN CANALS, I
DR. QUALLS VOLUME II PAGE 297
THINK, YOU KNOW.
Q. WELL, THAT'S A PROBLEM, TOO, BUT WE'RE NOT DEALING
WITH THAT ONE HERE.
A. RIGHT, YEAH.
Q. OKAY. ALL RIGHT. WE'RE MOVING RIGHT ALONG HERE.
I'D LIKE TO TURN TO WHAT I BELIEVE IS REALLY YOUR
CHAPTER NINE. I HAVE IT IN A DRAFT FORM, AND I
DEALT WITH IT -- OR NOT A DRAFT FORM, I THINK IT'S
ALMOST AN IDENTICAL FORM -- BUT IT'S FROM YOUR
MINI-PAPER ON YOUR DISK NUMBER 24. IT IS FOR MOST
PURPOSES CHAPTER NINE, FOR THOSE AT THE TABLE WHO
DON'T HAVE IT. YOU SHOULD -- YOU SHOULD DEAL WITH
THE PAPER WITH ME. I THINK IT WOULD BE EASIER FOR
YOU AND ME TO TALK ABOUT THE PAPER.
MR. GREEN: IS THAT A MINI-PAPER?
MS. PONZOLI: NUMBER 24.
(THEREUPON, THERE WAS AN
OFF-THE-RECORD DISCUSSION
WHICH WAS NOT REPORTED
BY THE COURT REPORTER.)
Q. (BY MS. PONZOLI) CAN YOU FIND IT?
A. RIGHT, I'VE GOT IT.
Q. OH, ALL RIGHT, GOOD. ALL RIGHT. IN YOUR SECOND
PARAGRAPH, YOU SAY, "IN AEROBIC ENVIRONMENTS, MOST
DR. QUALLS VOLUME II PAGE 298
ORGANIC MATTER IS EVENTUALLY MINERALIZED. IN
ANAEROBIC ENVIRONMENTS, SUCH AS THE PEATLANDS OF
THE EVERGLADES, A PORTION OF THE DEAD ORGANIC
MATTER IS MINERALIZED SO SLOWLY THAT THE NUTRIENTS
IT CONTAINS CAN BE STORED FOR THOUSANDS OF YEARS
AND REMOVED FROM THE NUTRIENT CYCLE." IS THIS
ESSENTIALLY, DR. QUALLS, DESCRIBING AN
OLIGOTROPHIC SYSTEM?
A. YES, UH-HUH (YES).
Q. OKAY. AND THEN WHEN YOU TALK ABOUT -- FURTHER
DOWN, WHERE YOU SAY, "WHEN AREAS OF THE EVERGLADES
PEATLANDS WERE DRAINED FOR AGRICULTURE, A GREAT
FLUSH OF AEROBIC MINERALIZATION RELEASED
NUTRIENTS, CAUSING CONDITIONS OF HIGH FERTILITY,
EXCEPT FOR CERTAIN MICRONUTRIENT DEFICIENCIES."
ARE YOU DESCRIBING, BASICALLY A EUTROPHIC SYSTEM
THERE?
A. RIGHT. THERE I WAS ACTUALLY DESCRIBING THE FIELDS
THAT THE SUGAR CANE AND VEGETABLES ARE GROWN ON
THEMSELVES.
Q. OH, OKAY. ALL RIGHT. AND IN THE MIDDLE, I ASSUME
THAT AS A CONTINUED DESCRIPTION OF OLIGOTROPHIC
SYSTEM, "IN THE PAST, THE SLOWNESS OF THE NUTRIENT
CYCLE IN MANY PORTIONS OF THE EVERGLADES LED TO
DR. QUALLS VOLUME II PAGE 299
CONDITIONS OF VERY LOW FERTILITY." IS THAT -- IS
THAT AN OLIGOTROPHIC SYSTEM?
A. YES, RIGHT, UH-HUH (YES).
Q. OVER ON THE NEXT PAGE, "CONDITIONS IN THE SURFACE
PEAT OF THE NATURAL AREAS OF THE EVERGLADES ARE
NOT ALWAYS ANAEROBIC." DO YOUR RESULTS SHOW THIS,
THAT THEY'RE NOT ALWAYS ANAEROBIC?
A. OH, YEAH. AT CERTAIN TIMES, YOU KNOW, DURING THE
DROUGHT IN 1990, WHEN THE WATER LEVELS GOT VERY
LOW, THERE WERE -- I THINK IN SOME PLACES AS MUCH
AS TWENTY OR TWENTY-FIVE CENTIMETERS BELOW THE
SURFACE -- THERE WERE SOME REDOX POTENTIALS THAT
INDICATED BORDERLINE AEROBIC CONDITIONS. THERE
WAS NOTHING THAT WAS REALLY INTENSELY AEROBIC, BUT
IN AREAS THAT WERE -- WHERE THE WATER TABLE WAS
WELL BELOW THE PEAT SURFACE, THEY DID BECOME
AEROBIC IN CERTAIN CIRCUMSTANCES---
Q. OKAY.
A. ---IN SOME PLOTS.
Q. I'D LIKE TO LOOK AT THE BOTTOM, WHERE THERE ARE
QUESTIONS THAT YOU BELIEVE THAT ARE GOING TO BE
ANSWERED. YOU SAY QUESTION ONE: "ARE THE ORGANIC
NUTRIENTS STORED IN THE SOIL OF THE ENRICHED ZONE
MORE EASILY MINERALIZED THAN THOSE FAR FROM THE
DR. QUALLS VOLUME II PAGE 300
HILLSBORO CANAL UNDER (a) AEROBIC CONDITIONS, AND
THEN (b), UNDER ANAEROBIC CONDITIONS?" BRIEFLY,
WHAT WOULD YOUR ANSWER TO THOSE BE?
A. TO THOSE -- THOSE PARTICULAR OBJECTIVES, I
HAVEN'T ANALYZED THE DATA ENOUGH TO FIGURE THAT
OUT YET---
Q. UH-HUH (YES).
A. ---THERE'S A WHOLE SECTION OF THAT EXPERIMENT,
WHERE WE FRACTIONATED THE VARIOUS FORMS OF ORGANIC
MATTER, BEFORE AND AFTER THAT SIX MONTHS
INCUBATION, AND WE'VE DONE THE ANALYSES, BUT I
HAVEN'T HAD TIME TO COMPLETELY ANALYZE AND COMPILE
ALL THAT DATA.
Q. OKAY. COULD YOU GIVE ME PRELIM -- PRELIMINARY
ANSWERS---
A. WELL---
Q. ---IF THEY WERE QUALIFIED IN THAT WAY?
A. ---I'M NOT EVEN REALLY SURE I COULD EVEN GIVE YOU
PRELIMINARY ANSWERS, EXCEPT THAT JUST FROM LOOKING
ROUGHLY AT THE NUMBERS, I THINK THAT A LARGE PART
OF THE PHOSPHORUS THAT WAS MINERALIZED IN THE
ANAEROBIC INCUBATION HAD TO HAVE COME FROM
MICROBIAL BIOMASS, THE DEATH OF MICROBIAL BIOMASS
THERE.
DR. QUALLS VOLUME II PAGE 301
Q. THAT'S AS FAR AS YOU WANT TO GO?
A. YEAH. AND THAT -- THAT'S JUST A BALLPARK IDEA,
FROM LOOKING AT THE VERY ROUGH NUMBERS.
Q. OKAY. THE SECOND OBJECTIVE WAS, "IS THE
DECOMPOSITION OF SUBSURFACE PEAT SIGNIFICANT UNDER
ANAEROBIC CONDITIONS?" CAN YOU ANSWER THAT?
A. OKAY. THERE'S TWO QUESTIONS HERE. WAS THERE A
SIGNIFICANT DECOMPOSITION OF CARBON---
Q. UH-HUH (YES).
A. ---OF THE SOIL ORGANIC MATTER ITSELF. AND THAT
ACTUALLY TURNED OUT TO BE VERY SMALL. AND THERE
DID SEEM TO BE A SIGNIFICANT RELEASE, THOUGH OF
PHOSPHATE FROM THOSE ANAEROBIC INCUBATIONS. BUT,
LIKE I SAY, I THINK THAT THAT WAS LARGELY DUE TO
THE INTENSELY REDUCING CONDITIONS THAT DEVELOPED
OVER THAT SIX MONTH INCUBATION, AT THIRTY-FIVE
DEGREES INSIDE AN INCUBATOR.
Q. SO WE PRETTY MUCH NARROWED THAT ONE TO THOSE
FAIRLY UNIQUE CIRCUMSTANCES, I GUESS---
A. YES, UH-HUH (YES).
Q. ---IN YOUR OPINION?
A. RIGHT, YEAH. AND THE INTENTION OF THAT EXPERIMENT
WAS NOT TO SIMULATE THE ANAEROBIC CONDITIONS THAT
ARE ACTUALLY FOUND IN THE FIELD, BUT RATHER TO TRY
DR. QUALLS VOLUME II PAGE 302
TO GET AS MUCH DECOMPOSITION AS POSSIBLE, SO THAT
WE COULD MEASURE SOME SORTS OF CHANGES DURING THAT
SIX MONTH PERIOD. AND IT'S REALLY KIND OF AN
ASSAY, RATHER THAN ANYTHING MEANT TO REPRESENT THE
FIELD CIRCUMSTANCES.
Q. I BELIEVE THAT ONE OF YOUR CO-WORKERS -- I BELIEVE
IT WAS DR. RADER -- SAID THAT THERE IS GOING TO BE
AN EXPERIMENT SET UP TO SEE IF DECOMPOSITION IS
ENHANCED BY NUTRIENT ENRICHMENT. ARE YOU AWARE OF
THAT?
A. THAT'S RIGHT, YEAH.
Q. OKAY. WILL THAT ANSWER SOME OF THESE QUESTIONS?
A. YEAH. WELL, LET ME SAY THAT THE DECOMPOSITION OF
RECENT LEAF LITTER, AND THE DECOMPOSITION OF THE
OLDER PEAT ARE PROBABLY TWO SEPARATE QUESTIONS. I
THINK THEY PROBABLY BEHAVE A LITTLE BIT
DIFFERENTLY.
Q. UH-HUH (YES).
A. STEVE DAVIS HAS ALREADY SHOWN THAT IN THE ENRICHED
AREA, THE CATTAIL AND SAWGRASS LEAVES DECOMPOSED
FASTER IN THE ENRICHED AREA THAN IN THE UNENRICHED
AREA.
Q. OKAY. I DIDN'T REALIZE THE DECOMPOSITION
EXPERIMENT WAS -- IT'S -- IT'S RESTRICTED TO
DR. QUALLS VOLUME II PAGE 303
ABOVEGROUND?
A. RIGHT, YEAH. THESE ARE JUST RECENTLY---
Q. ABOVE -- YEAH, SURFACE.
A. ---YOU KNOW, LEAVES, BASICALLY KIND OF---
Q. OKAY.
A. ---LIKE AUTUMN LEAVES, EXCEPT THAT THERE'S NO
AUTUMN THERE.
Q. WE HAVE OUR SEASONS. NUMBER THREE, "HOW DOES THE
PERIODIC LOWERING OF WATER LEVEL (AEROBIC
CONDITIONS) AFFECT THE MINERALIZATION OF
PHOSPHORUS?" CAN YOU ANSWER THAT, BRIEFLY?
A. WELL, OKAY, IN TERMS OF ORGANIC MATTER---
Q. OKAY.
A. ---OBVIOUSLY, THE -- UNDER AEROBIC CONDITIONS, IT
DECOMPOSED MUCH, MUCH FASTER. UNDER ANAEROBIC
CONDITIONS, IT ACTUALLY LOOKED LIKE THERE WAS MORE
PHOSPHORUS RELEASED UNDER ANAEROBIC CONDITIONS
THAN THERE WAS. BUT I THINK FROM PRELIMINARY
LOOKS AT THE DATA, THAT THAT'S NOT NECESSARILY DUE
TO ACTUALLY DECOMPOSITION OF THAT DEAD ORGANIC
MATTER. BUT IT WAS INSTEAD PROBABLY MAINLY DUE TO
THE BACTERIA AND FUNGI THAT WAS IN THERE DYING
UNDER THOSE INTENSE ANAEROBIC CONDITIONS AND
RELEASING THEIR TISSUE PHOSPHORUS. AND THEN THERE
DR. QUALLS VOLUME II PAGE 304
WAS NO NEW MICROBES GROWING THAT WOULD BE ABLE TO
TAKE THAT BACK UP.
Q. OKAY. THAT'S WHAT YOU DISCUSSED WITH ME THIS
MORNING?
A. RIGHT, YES, UH-HUH (YES).
Q. OKAY.
A. AND SO, RIGHT NOW, I CAN'T FULLY ANSWER THAT
QUESTION, UNTIL I'VE HAD A CHANCE TO REALLY
THOROUGHLY LOOK AT ALL THE RESULTS FROM THE
FRACTIONATION.
Q. AND YOU SAID THAT'S GOING TO TAKE SIX MONTHS? WAS
THAT THE ONE THAT WAS TAKING SIX MONTHS, OR YOU
HAVEN'T TOLD ME HOW LONG---
A. NO, I THINK THAT WAS---
Q. ---HOW LONG THIS WAS GOING TO TAKE?
A. ---THAT WAS ANOTHER ONE.
Q. OKAY.
A. AND, YEAH, I WOULD SAY, IT'S GOING TO TAKE ANOTHER
TWO OR THREE MONTHS, BECAUSE---
Q. OKAY. AND THEN YOU THINK YOU WOULD HAVE ANSWERS
AT THE CONCLUSION OF THOSE TWO TO THREE MONTHS?
A. I HOPE SO. YOU KNOW, IT'S ALWAYS POSSIBLE THAT --
THAT MANY OF THE THINGS VARIED STATISTICALLY SO
MUCH THAT WE WON'T BE ABLE TO SAY WITH A
DR. QUALLS VOLUME II PAGE 305
NINETY-FIVE PERCENT CONFIDENCE INTERVAL THAT SUCH
AND SUCH CHANGES OCCURRED, BUT HOPEFULLY.
Q. NUMBER FOUR: IS THE DECOMPOSITION AND
MINERALIZATION OF PEAT NITROGEN AND PHOSPHORUS
ACCELERATED BY ADDITION OF INORGANIC NITROGEN OF
PHOSPHORUS IN, FIRST, THE ENRICHED ZONE, AND THEN
THE NON-ENRICHED ZONE?
A. AT THE VERY HIGH LEVELS OF ADDITION OF INORGANIC
NITROGEN, AND THE VERY HIGH LEVELS OF ADDITION OF
ORGANIC PHOSPHORUS, IT DID SEEM LIKE THAT THE --
THAT THE ORGANIC MATTER, OR THE PEAT DID DECOMPOSE
FASTER IN -- UNDER THE INFLUENCE OF ADDITIONS OF
LARGE AMOUNTS OF PHOSPHORUS. WE DON'T KNOW THAT
UNDER THE AMOUNTS OF PHOSPHORUS WHICH MIGHT BE,
YOU KNOW, ACTUALLY BE OCCURRING RIGHT NOW IN THE
UNENRICHED AREA -- I MEAN -- SORRY -- IN THE
ENRICHED AREA---
Q. OKAY. NUMBER FIVE---
A. ---IN OTHER WORDS, WE DIDN'T USE ENTIRELY NATURAL
CONCENTRATIONS. WE USED VERY, VERY HIGH
CONCENTRATIONS TO TRY TO, YOU KNOW, GET A HANDLE
ON THAT FIRST, YOU KNOW.
Q. AND THIS IS THE SAME AS YOU'VE BEEN DISCUSSING
WITH ME ALONG?
DR. QUALLS VOLUME II PAGE 306
A. RIGHT, YEAH.
Q. OKAY. NUMBER FIVE: HOW LABILE OR REFRACTORY IS
EACH OF THE FRACTIONS SEPARATED BY THE PHOSPHOROUS
FRACTIONIZATION PROCEDURE UNDER AEROBIC AND
ANAEROBIC CONDITIONS?
A. AND THAT AGAIN IS ONE QUESTION WHICH WE---
Q. OKAY.
A. ---WE HAD HOPED TO ANSWER, BUT HAVEN'T COMPLETELY
ANALYZED THAT DATA YET.
Q. OKAY. AND FINALLY, "WHAT PERCENTAGE OF NITROGEN
LOST OR IN DECOMPOSITION IS ACTUALLY IN THE
REFRACTORY DISSOLVED ORGANIC NITROGEN FORM, WHICH
IS FOUND IN SUCH HIGH CONCENTRATIONS?"
A. YEAH. ACTUALLY, WE DID ANSWER THAT QUESTION, AND
THAT IS -- THAT IS THE SUBJECT OF PART OF CHAPTER
NINE THERE. AND IT'S IN FIGURE -- FIGURE 9-3 ON
PAGE 374. AND IF YOU'LL NOTICE, I HAVE THE THREE
FORMS OF NITROGEN THAT WERE MINERALIZED DURING
THAT EXPERIMENT, AND DISSOLVED ORGANIC NITROGEN IS
THE TOP BAR. AND, AS YOU'LL NOTICE, THERE IS
PRETTY LARGE QUANTITIES OF DISSOLVED ORGANIC
NITROGEN GENERATED.
Q. TURNING TO THE APPLICATION, DR. QUALLS, OF WHAT
YOU'VE DONE WITH THE MINERALIZATION POTENTIAL OF
DR. QUALLS VOLUME II PAGE 307
NITROGEN AND PHOSPHORUS---
A. OKAY.
Q. ---YOU GIVE US THE CONCLUSION -- OR I'M CALLING A
CONCLUSION -- THAT ON BALANCE, CATTAIL COMMUNITIES
IN THE ENRICHED AREAS SO EFFECTIVELY REMOVE AND
STORE PHOSPHORUS---
A. UH-HUH (YES).
Q. ---AND WE DISCUSSED THAT---
A. RIGHT.
Q. ---THAT PREVIOUSLY. BEYOND THAT, TELL ME WHAT THE
APPLICATION OF ALL OF THESE FINDINGS THAT YOU'VE
MADE, HOW WE WOULD APPLY THOSE TO, LIKE SAY STA'S
OR FLOWWAYS?
A. OH, YEAH, FOR THE MINERALIZATION CHAPTER -- I
THINK THAT AS FAR AS BEING ABLE TO ACTUALLY
MANIPULATE THE STA'S, I'M NOT SURE IT'S GOING TO
BE ABLE TO EASILY MANIPULATE THE STA'S TO TAKE
ADVANTAGE OF THE VARIOUS DIFFERENCES AND
MINERALIZATION POTENTIAL. AND -- AND ONE OF THE
QUALIFICATIONS HERE IS BECAUSE OF THE -- UNDER
THE ANAEROBIC CONDITIONS, THEY DID TURN OUT TO
BE UNNATURALLY LOW -- UNNATURALLY LOW REDOX
POTENTIALS. AND I THINK THAT THAT WOULD NOT BE
REPRESENTATIVE OF THE ANAEROBIC CONDITIONS THAT
DR. QUALLS VOLUME II PAGE 308
WOULD ACTUALLY PROBABLY OCCUR IN THE STA'S. AND
THAT'S OF COURSE, JUST A GUESS, BECAUSE I, I
DON'T---
Q. SURE.
A. ---YOU KNOW, I'VE NEVER BEEN TO THE STA'S, BUT,
YOU KNOW, JUST JUDGING FROM WATER CONSERVATION
AREA 2A. SO, RIGHT AT THE MOMENT, I WOULD SAY
THEY HAVE FAIRLY LIMITED APPLICABILITY FOR
ANYTHING THAT WOULD ACTUALLY BE MANIPULABLE IN THE
STA'S.
Q. THE GOAL HAD BEEN THAT YOU HAD HOPED THAT YOU
WOULD BE ABLE TO PRODUCE SOME INFORMATION THAT
WOULD BE USEFUL?
A. YES.
Q. IS THAT FAIR TO SAY?
A. UH-HUH (YES). RIGHT. UH-HUH (YES).
Q. OKAY. BUT, RIGHT NOW, BEYOND THE FACT THAT --
THAT YOUR WORK SUPPORTS THAT MAYBE CATTAILS WOULD
BE USEFUL TO BE GROWN, AND THEN THERE'S -- THERE'S
LIMITED APPLICATION OF ANYTHING ELSE?
A. RIGHT.
Q. OKAY.
A. I GUESS IN A SENSE THAT IS AN APPLICATION THOUGH,
IN THE SENSE THAT WE DID -- THE SURFACE SOIL THAT
DR. QUALLS VOLUME II PAGE 309
WAS TAKEN FROM THE ENRICHED ZONE, WAS IN A CATTAIL
AREA, AND THERE WAS SLIGHTLY MORE MINERALIZATION
FROM THE -- THIS SURFACE SOIL FROM THE ENRICHED
AREA, MAINLY BECAUSE IT HAD HIGHER CONCENTRATION
OF PHOSPHORUS TO BEGIN WITH.
Q. I HAVE ONLY ONE QUESTION ON DEPOSITION EXHIBIT 67,
AND IT'S ON THE COVER. I GAVE YOU THE WHOLE
EXHIBIT, AND I DON'T REALLY KNOW WHY.
A. OH, OKAY.
Q. I MUST HAVE BEEN TIRED WHEN I HAD THINGS
REPRODUCED. DO YOU SEE THIS ONE?
A. YEAH.
Q. THERE'S A REFERENCE TO JOHN DUNKLEMAN. WHO IS HE?
A. OH, YOU KNOW, I DON'T EVEN KNOW. THAT'S -- THAT'S
NOT EVEN MY HANDWRITING.
Q. OH, OKAY. DO YOU KNOW WHOSE HANDWRITING IT IS?
A. NO, I'M NOT EVEN SURE. WAS THIS IN THAT FILE?
Q. IT'S MARKED DEPOSITION EXHIBIT NUMBER 67, QUALLS,
ANNUAL REPORT. DO YOU KNOW WHO HE IS?
A. OH, THIS IS ACTUALLY THE FRONT OF A MANILA
FOLDER---
Q. SURE, PROBABLY.
A. ---SO, NO, I DON'T EVEN KNOW WHO HE IS.
Q. OKAY.
DR. QUALLS VOLUME II PAGE 310
A. MY GUESS IS THAT SOMEBODY WAS USING THAT MANILA
FOLDER FOR A SCRATCH PAD OR SOMETHING LIKE THAT.
Q. OKAY. HOW ABOUT KOCH, SOUTH FLORIDA WATER
MANAGEMENT DISTRICT REPORT?
A. YEAH. I KNOW THAT JUST BE MARGUERITE COOK, I
THINK.
Q. OKAY. COOK, YOU'RE RIGHT. YOU'RE RIGHT. OKAY.
ALL RIGHT, THAT'S ALL I HAD. I HAVE SEVERAL MORE,
BUT NOT MANY. I THINK I HAVE A FEW QUESTIONS ON
ONE OF THE CHAPTERS, CHAPTER SIX. I'M GOING TO
ASK YOU A LITTLE BIT REGARDING YOUR CV, AND THOSE
OTHER DOCUMENTS, AND WE'LL BE DONE.
A. OKAY.
Q. YOUR CV IS PULLED OFF OF DISK NUMBER 22. IS THIS
THE MOST RECENT, DO YOU KNOW? I HAVE ANOTHER ONE,
BUT I -- AND I GUESS I DIDN'T CHECK THE DATES.
THERE WERE TWO, AND I JUST TOOK THIS ONE. THEY
LOOKED TO ME TO BE PRETTY MUCH THE SAME.
A. YEAH, PROBABLY, YEAH.
Q. IS IT GOOD ENOUGH?
A. YEAH---
Q. OKAY.
A. ---I DON'T THINK ANYBODY -- ANYTHING HAS CHANGED
SINCE AUGUST, THERE.
DR. QUALLS VOLUME II PAGE 311
Q. OKAY. WILL YOU DESCRIBE BRIEFLY FOR ME, YOUR
EDUCATION?
A. WELL, THE FIRST PART OF IT WAS POOR, BECAUSE I
GREW UP IN NORTH CAROLINA, BUT -- WHICH I FOUND
OUT WHEN I GOT INTO MY FIRST CALCULUS CLASS, WHERE
EVERYBODY ELSE WAS OUT OF STATE. I WAS THE ONLY
NORTH CAROLINA NATIVE, AND THEY HAD ALREADY HAD IT
IN HIGH SCHOOL.
Q. IT'S LOOKS LIKE YOU CAUGHT UP, LOOKING AT YOUR
GPA, AND---
A. SO, ANYWAY, I GOT A B.S. IN BIOLOGY AT THE
UNIVERSITY OF NORTH CAROLINA, AN M.S. IN PUBLIC
HEALTH, SPECIALIZING IN ENVIRONMENTAL CHEMISTRY
AND BIOLOGY, FROM THE UNIVERSITY OF NORTH
CAROLINA, AND THEN A Ph.D. IN ECOLOGY FROM THE
UNIVERSITY OF GEORGIA.
Q. OKAY. JUST BRIEFLY, WHAT TYPES OF COURSES DID YOU
TAKE IN YOUR BACHELOR'S WORK? AND I WOULD JUST
LIKE YOU TO TELL ME BRIEFLY THE COURSES OF YOUR
MAJOR AREA OF STUDY.
A. OH, YEAH, IN THE BACHELOR'S WORK, I MAJORED IN
BIOLOGY AND TOOK COURSES LIKE CELL BIOLOGY,
GENETICS, INVERTEBRATE ZOOLOGY, AND VARIOUS MATH
COURSES, AND A LOT OF CHEMISTRY, ORGANIC
DR. QUALLS VOLUME II PAGE 312
CHEMISTRY, ANALYTICAL CHEMISTRY, GENERAL
CHEMISTRY.
Q. OKAY. YOUR MASTER'S?
A. FOR A MASTER'S, I GUESS PROBABLY THE MOST
PERTINENT COURSES THAT I TOOK THERE WAS WATER
CHEMISTRY, I THINK ADVANCED METHODS OF
INSTRUMENTAL ANALYSIS, AND, LET'S SEE, SOME
MICROBIOLOGY COURSES. I THINK THERE'S A MICROBIAL
ECOLOGY COURSE THERE. AND THOSE ARE PROBABLY THE
MOST PERTINENT ONES.
Q. WHAT WAS YOUR -- YOUR THESIS ON?
A. FOR MY MASTER'S, THE THESIS WAS ON CONTROL OF
NITROGEN CYCLING AND LEAF LITTER DECOMPOSITION IN
A SWAMP STREAM.
Q. HOW ABOUT NITROGEN CYCLING? IT'S NOT THAT USEFUL,
IS IT, FOR YOUR WORK HERE?
A. WELL, IT COMES IN HANDY EVERY ONCE IN A WHILE---
Q. RIGHT.
A. ---WE'RE WORKING ON PHOSPHORUS AND NITROGEN
SIMULTANEOUSLY, SO.
Q. RIGHT. OKAY. ALL RIGHT, AND YOUR Ph.D.?
A. THAT WAS DONE AT THE UNIVERSITY OF GEORGIA. AND
YOU WANT THE COURSES?
Q. JUST GENERALLY.
DR. QUALLS VOLUME II PAGE 313
A. YEAH, THEY'RE LISTED IN THE---
Q. OH, THESE ARE THE ONES LISTED?
A. YEAH, THEY'RE ACTUALLY LISTED HERE.
Q. OH.
A. SYSTEMS ECOLOGY, SOIL CHEMISTRY.
Q. YOU DON'T HAVE TO READ THEM IF THESE ARE THE
LISTED COURSES, THAT'S FINE. AND YOUR
DISSERTATION?
A. THAT WAS "THE BIOGEOCHEMICAL PROPERTIES OF
DISSOLVED ORGANIC MATTER IN A DECIDUOUS FOREST
ECOSYSTEM: THEIR INFLUENCE ON THE RETENTION OF
NITROGEN, PHOSPHORUS AND CARBON."
Q. OKAY. YOU'RE LISTED AS A CONSULTANT IN HERE FOR
J.M. MONTGOMERY CONSULTING ENGINEERS. WHAT
TYPE---
A. THAT'S RIGHT.
Q. ---OF WORK DO YOU DO FOR THEM?
A. THAT'S HELPING THEM DESIGN EXPERIMENTS AND SYSTEMS
FOR USING ULTRAVIOLET LIGHT TO DISINFECT WATER AND
WASTEWATER.
Q. TREATMENT SYSTEMS?
A. RIGHT, UH-HUH (YES).
Q. OKAY. DO YOU HAVE SOME EXPERIENCE IN DESIGNING
WASTEWATER TREATMENT SYSTEMS?
DR. QUALLS VOLUME II PAGE 314
A. YEAH, I WORKED FOR A COUPLE OF YEARS DOING
RESEARCH ON ULTRAVIOLET DISINFECTION OF WATER AND
WASTEWATER, MAINLY WASTEWATER, AND BUILT SOME
PILOT PLANTS, AND DESIGNED SOME MEANS FOR
EVALUATING THE EFFICIENCY OF THESE WATER --
WASTEWATER TREATMENT SYSTEMS, MAINLY.
Q. DO YOU DO ANY OTHER CONSULTING WORK?
A. NO.
Q. OKAY. I -- AND I GUESS I'M GOING TO ASSUME THAT
YOU'RE IN THE SAME POSTURE AS DR. CRAFT, THAT
YOU'RE NOT A CONSULTANT OR BEING PAID FOR ANYTHING
RELATED TO THE EVERGLADES, SWIM CHALLENGES, OR ANY
OF THE EVERGLADES LITIGATION?
A. RIGHT, YEAH, UH-HUH (YES).
Q. OKAY. ALL RIGHT. YOU'RE NOT BEING PAID TO BE
HERE TODAY?
A. NO.
Q. OKAY. I'M SORRY. ALL RIGHT. THAT'S ALL I HAVE
ON THAT. I WOULD LIKE TO ASK YOU A FEW QUESTIONS
ON NUMBER 123, SLOUGH -- SOMETHING OR ANOTHER --
EXP.
A. RIGHT, SLOUGH EXPERIMENT, PROBABLY.
Q. RIGHT.
A. YEAH. OKAY, THIS IS -- LOOKS LIKE A MANILA
DR. QUALLS VOLUME II PAGE 315
FOLDER, PROBABLY.
Q. IS IT A MISCELLANEOUS FILE?
A. YES.
Q. OKAY. I'D LIKE TO ASK YOU FIRST, IF -- ARE YOU
THE ONE WHO TESTED PERRIER WATER AND TOLD US WHAT
THE PHOSPHORUS CONTENT OF IT WAS?
A. NO, NO. ACTUALLY, NOW I REALIZE THAT THIS IS ONE
WHICH ACTUALLY CAME FROM THE GENERAL LAB RECORDS.
THIS WAS NOT SPECIFICALLY FROM A FILE OF MINE IN
PARTICULAR.
Q. BUT DOES THIS REFLECT THAT TESTING OF DIFFERENT
KINDS OF WATER FOR PHOSPHORUS?
A. ABOUT HOW MANY PAGES DOWN IS THAT?
Q. I THINK IT'S RIGHT IN THE BEGINNING, DEEP PARK,
DEER PARK SPRING, ZEPHYR HILL.
A. OH, OKAY, YEAH, SORRY.
Q. I'VE BOUGHT SOME OF THESE.
A. OH, YEAH. YEAH, I DIDN'T TEST THOSE. THAT WAS A
TECHNICIAN. IT'S FROM THE FILES OF A TECHNICIAN,
WHO NOW WORKS AT SAS INSTITUTE, YOU KNOW, SO HE'S
LONG GONE. THAT WAS A LONG TIME AGO, I THINK.
Q. WHOSE IDEA WAS THIS---
A. '91---
Q. ---TO CHECK THE BOTTLED WATER FOR PHOSPHORUS?
DR. QUALLS VOLUME II PAGE 316
A. I'M NOT EXACTLY SURE.
Q. IT WASN'T YOUR IDEA?
A. NO, I DIDN'T HAVE ANYTHING TO DO WITH IT.
Q. OKAY. AND YOU DON'T KNOW WHOSE IDEA IT WAS?
A. NO.
Q. OKAY. WHERE IT SAYS FLORIDA WATER, WHAT IS THAT,
ORTHOPHOSPHATE ANALYSIS FOR RUSS RADER, SITES,
BLAH, BLAH, BLAH? THOSE ARE -- THOSE ARE JUST
SAMPLES THAT ARE TAKEN?
A. HOW MANY PAGES DOWN WAS THAT?
Q. OH, JUST BEHIND.
A. OH, OKAY, YEAH. THAT'S A FEW PAGES DOWN. YEAH,
THAT IS FROM ANALYSES WHEN WE WERE LOOKING FOR A
GOOD PLACE TO PUT THE DOSING STUDY SITE, AND WE
WENT AND TOOK SOME SAMPLES FROM 2A, 2B, AND THEN
FLEW INTO A PART OF 3B TO TAKE SOME WATER SAMPLES
THERE.
Q. ALL RIGHT. IF YOU GO A LITTLE FURTHER BACK, YOU
SEE TO RUSS RADER FROM ERIC WALDBAUER?
A. YEAH, UH-HUH (YES).
Q. "PHOSPHORUS LEVELS AT DIFFERENT SITES."
A. YEAH.
Q. AND I GUESS I'M A LITTLE CURIOUS WHAT THESE
ARE, AND WHERE THE ENP -- I ASSUME THAT'S
DR. QUALLS VOLUME II PAGE 317
EVERGLADES NATIONAL PARK -- WHERE THOSE NUMBERS
CAME FROM?
A. YEAH, I'M NOT EXACTLY SURE, BECAUSE AT THAT TIME,
RUSS WAS PRETTY MUCH HEADING UP THAT, YOU KNOW,
SEARCH FOR THE SITE.
Q. OKAY. YOU DON'T WHAT THESE NUMBERS REFLECT OR
WHERE THE EVERGLADE'S NUMBERS ORIGINATED?
A. NOT REALLY---
Q. OKAY. THAT'S ALL I HAVE ON THAT ONE.
A. ---I WAS ONLY ALONG ON ONE OF THOSE THINGS WHERE
WE GOT SOME FROM 3A.
Q. WERE YOU ON THE SAMPLING TRIP WHEN THE WATER WAS
COLLECTED?
A. I WAS ON THE ONE TO 3A, BECAUSE WHAT WE DID WAS
WENT -- WE WERE DOING THE REGULAR GRADIENT
STUDY---
Q. UH-HUH (YES).
A. ---I THINK THAT WAS EITHER FEBRUARY -- I GUESS IT
MUST HAVE BEEN FEBRUARY IN 1991, AND THEN AT THE
END OF THE DAY, WE JUST FLEW DOWN TO AN AREA IN
3A AND LOOKED FOR A SITE.
Q. DID YOU GO TO 2B THAT DAY, ALSO?
A. I DON'T THINK WE WENT TO 2B THAT DAY. I THINK WE
MAY HAVE GONE TO THE SITE IN 2A, PROBABLY CLOSE TO
DR. QUALLS VOLUME II PAGE 318
WHERE OUR DOSING STUDY ACTUALLY ENDED UP BEING
LOCATED---
Q. WERE YOU ON---
A. ---AND THEN WENT DOWN TO 3A THAT SAME DAY.
Q. WERE YOU ON THE SHIP, THE MARCH 28, 1991, IS THAT
THE DATE, TO THE BEST OF YOUR RECOLLECTION, THAT
THE TRIP MIGHT HAVE BEEN TAKEN?
A. NO, I THINK THE TRIP WAS PROBABLY TO HAVE BEEN
TAKEN IN FEBRUARY---
Q. OKAY.
A. ---OH, THAT'S WHEN I WENT, YOU KNOW.
Q. OKAY.
A. THESE COULD ACTUALLY BE, YOU KNOW, ANOTHER TRIP
TO 3A. I JUST REMEMBER IT WAS ON ONE OF OUR
REGULAR SAMPLING TRIPS, THAT WE JUST TOOK A LITTLE
JAUNT DOWN TO 3A.
Q. SO, YOU ARE UNAWARE OF DR. RADER ACTUALLY ENTERING
THE PARK TO TAKE SAMPLES?
A. NO.
Q. NO. YOU'RE NOT AWARE OF ANY OF THAT?
A. RIGHT. YEAH, NO, I'M NOT AWARE OF ANY OF IT.
Q. OKAY. OKAY. I'D LIKE TO ASK YOU ABOUT A DOCUMENT
FROM YESTERDAY, CRAFT NUMBER 35. IT'S A -- IT WAS
HIS FILE, AND I DON'T KNOW IF YOU'VE EVER SEEN IT
DR. QUALLS VOLUME II PAGE 319
OR NOT, BUT I'M JUST GOING TO SHOW IT TO IT.
IT'S "MERCURY CONTAMINATIONS IN THE EVERGLADES'
ECOSYSTEM," HAVE YOU EVER SEEN THAT DOCUMENT?
A. NO.
Q. OKAY. THAT'S THE LAST QUESTION I WOULD HAVE ON
THAT DOCUMENT.
A. OKAY.
Q. YOU REFER TO MERCURY IN THE EVERGLADES IN ONE OF
YOUR CHAPTERS, AND AT THE MOMENT, I CAN'T RECALL
WHERE IT IS, BUT I PROBABLY CAN FIND IT. DO YOU
RECALL WHERE IT IS? IS IT IN CHAPTER SIX?
A. OH, FOR -- OH, YEAH. I THINK -- YEAH, I REMEMBER
REFERRING TO IT SOMEWHERE, BUT I'M NOT EXACTLY
SURE WHERE. I THINK IT WAS IN CONNECTION WITH
REDOX POTENTIALS AND---
Q. CAN YOU HELP ME GET THERE?
A. ---THAT'S PROBABLY IN CHAPTER SIX.
Q. I THINK ON PAGE 222. AND THEN THERE MAY BE -- MAY
HAVE BEEN A REFERENCE SOMEWHERE ELSE. I CAN'T
RECALL.
(THEREUPON, MS. PONZOLI REVIEWS DOCUMENTS.)
Q. ON PAGE 247---
A. OH, OKAY.
Q. ---THERE'S TWO -- THERE'S TWO REFERENCES TO
DR. QUALLS VOLUME II PAGE 320
MERCURY THERE. I'D LIKE TO JUST TAKE A SECOND AN
LOOK AT THOSE TWO.
(THEREUPON, WITNESS REVIEWS DOCUMENTS.)
MR. McCAUGHAN: BOTH ON 247?
MS. PONZOLI: ONE'S ON 222, AND ONE
IS ON 247.
Q. (BY MS. PONZOLI) ON 222, YOU SAY THAT "...THERE
HAS BEEN CONCERN THAT THE NUTRIENT-ENRICHED
CATTAIL ZONE DID TEND TO HAVE LOW REDOX
POTENTIALS..."
A. RIGHT.
Q. WHICH YOU DID FIND?
A. WELL, THAT'S BASED ON THE -- THE CONCERN FOR THAT
WAS BASED ON THE SWIM PLAN, WHERE IT ACTUALLY SAYS
SOMEWHERE IN THE SWIM PLAN. I THINK THAT WAS
BASED ON BELANGER'S WORK---
Q. UH-HUH (YES).
A. ---SHOWING THERE WAS POSSIBLY SOME DIFFERENCES IN
DISSOLVED ORGANIC AND -- NO -- IN DISSOLVED
OXYGEN. AND ALSO THERE WAS ANOTHER STUDY DONE BY
THE SOUTH FLORIDA WATER MANAGEMENT DISTRICT, AND I
READ THIS VERY LONG AGO, THAT I'M KIND OF STILL
VAGUE ON THAT, BUT IT HAD -- IT WAS SOMETHING
ABOUT ANAEROBIC METABOLISM, OR ANAEROBIC
DR. QUALLS VOLUME II PAGE 321
MICROORGANISMS BEING MORE COMMON IN THE CATTAIL
ZONE, THE ENRICHED ZONE. AND I BELIEVE THAT WAS
ACTUALLY SPECULATION, BUT I REMEMBER SEEING IT
CITED AS FACT ONE TIME IN THE SWIM PLAN---
Q. SURE.
A. ---WHERE IT WAS ACTUALLY SPECULATION, JUST TO
POSSIBLY EXPLAIN SOME ODD RESULTS IN THE ORIGINAL
PAPER.
Q. HOW DO YOU KNOW IT WAS SPECULATION?
A. OH, BECAUSE I READ BOTH VERSIONS, AND THE SWIM
PLAN HAD IT WRONG.
Q. OKAY. AND THE OTHER ONE WAS -- TELL ME AGAIN, YOU
SAID WAS---
A. THE OTHER ONE WAS A DOCUMENT PUT OUT BY THE SOUTH
FLORIDA WATER MANAGEMENT DISTRICT BY -- I THINK,
BUT I COULDN'T SWEAR TO THIS, THAT IT WAS PAM
REEDER AND STEVE DAVIS, I BELIEVE---
Q. OKAY.
A. ---AND, YOU KNOW---
Q. ---YOU SAY---
A. ---I WOULD HAVE TO LOOK AT THIS AGAIN.
Q. ---YOU SAY THEY EXTRAPOLATED TOO MUCH IN THE SWIM
PLAN FROM THAT FIRST DOCUMENT?
A. RIGHT, SOMEHOW -- YEAH, SOMEHOW IT MADE IT FROM
DR. QUALLS VOLUME II PAGE 322
SPECULATION TO SAYING THAT THEY ACTUALLY FOUND
THAT---
Q. OKAY.
A. ---I BELIEVE AT THE TIME THEY WERE JUST TRYING TO
EXPLAIN WHY THEY FOUND RELATIVE -- THEY FOUND A --
I MAY BE WRONG ABOUT THIS, SO THIS IS JUST WHAT I
REMEMBER -- THEY FOUND THAT THERE WERE LOWER
NUMBERS OF MICROORGANISMS IN THE ENRICHED -- SOME
OF THE ENRICHED AREAS. AND THEY THOUGHT, WELL,
THIS MIGHT BE EXPLAINED BY MAYBE THERE ARE JUST
HIGHER NUMBERS OF ANAEROBIC MICROORGANISMS,
BECAUSE THEY DIDN'T ASSAY FOR THAT. AND THEY
WERE JUST SPECULATING AS TO WHY THERE MIGHT BE
LOWER NUMBERS OF AEROBIC MICROORGANISMS. AND I
BELIEVE THAT IN THE SWIM PLAN THAT WAS QUOTED AS
AN ACTUAL FINDING. AND I THOUGHT THAT, YOU KNOW,
THAT WAS A SIGNIFICANT PROBLEM, THAT, YOU KNOW,
SOMETHING THAT NEEDED TO BE ADDRESSED. AND THAT
WAS ONE OF THE PURPOSES FOR LOOKING AT THE REDOX
POTENTIAL.
Q. OKAY. BUT YOU DID FIND LOWER REDOX IN YOUR
ENRICHED CATTAIL ZONE, DID YOU NOT?
A. NO, NOT -- ONLY SLIGHTLY LOWER. AND, IN MOST
CASES, IT WAS NOT STATISTICALLY SIGNIFICANT.
DR. QUALLS VOLUME II PAGE 323
Q. THAN THE -- THAN THE DENSE SAWGRASS STAND?
A. RIGHT, YEAH, YEAH, SO---
Q. BUT DEFINITELY LOWER THAN THE OPEN WATER
UNENRICHED SITE?
A. WELL, NO, WE DIDN'T TAKE ANY REDOX POTENTIALS IN
THE OPEN WATER ENRICHED SITES.
Q. BUT YOU WOULD EXPECT THAT THEY WOULD DEFINITELY BE
LOWER, WOULD YOU NOT?
A. IN THE OPEN WATER ENRICHED SITES?
Q. NO, NO, IN YOUR -- IN YOUR SAWGRASS ENRICHED
SITES, THAN IN AN OPEN WATER UNENRICHED SITE.
A. OH, NO, IN FACT, I WOULD -- THAT JUST CALLS FOR
SPECULATION, BUT I DON'T REALLY THINK THAT.
Q. DO YOU THINK IT WOULD BE THE OTHER WAY AROUND?
A. QUITE POSSIBLY, BUT, YOU KNOW---
Q. YOU DON'T KNOW?
A. ---UNTIL WE WOULD ACTUALLY DO SOME REDOX PROFILES,
I WON'T KNOW.
Q. HAVE YOU DONE THEM?
A. NO.
Q. NONE AT ALL?
A. WE HAVE -- NO, WE HAVEN'T DONE ANYTHING---
Q. OKAY.
A. ---IN THE OPEN WATER SLOUGH AREAS. AT LEAST, I
DR. QUALLS VOLUME II PAGE 324
HAVEN'T. WE WERE STICKING STRICTLY IN THOSE TWO
COMMUNITIES THAT WERE DEALT WITH PREVIOUSLY IN
THOSE OTHER EXPERIMENTS BY BELANGER.
Q. I MUST -- I MUST HAVE -- I MUST BE TIRED, AND THE
DAY IS GETTING LONG, AND I'VE BEEN DOING THIS TOO
MANY DAYS, BUT I THOUGHT WE WENT ALL THROUGH THIS,
THIS MORNING, AND YOU SAID THAT IN THE OPEN WATER
AREAS THAT ARE UNENRICHED, WHERE YOU'VE GOT
SUNLIGHT AND AIR, YOU'RE---
A. RIGHT, YEAH.
Q. ---GOING TO HAVE---
A. YEAH.
Q. ---HIGHER DISSOLVED OXYGEN?
A. YEAH, IN THE SURFACE WATER---
Q. RIGHT.
A. ---BUT THAT'S ONLY IN THE SURFACE WATER---
Q. OKAY.
A. ---ABOVE AN ALGAL MAT.
Q. UH-HUH (YES).
A. ANYWHERE BELOW THAT ALGAL MAT---
Q. RIGHT.
A. ---I DON'T REALLY KNOW. BUT I WOULD SUSPECT
THAT THAT WOULD NOT BE THE CASE BELOW THE ALGAL
MAT.
DR. QUALLS VOLUME II PAGE 325
Q. DO YOU THINK IT'S GOING TO BE THE SAME AS YOUR --
AS YOUR ENRICHED CATTAIL, DENSE MACROPHYTE AREAS?
A. I DON'T REALLY KNOW.
Q. OKAY. ALL RIGHT. WELL, LET'S GO ON THE SECOND
PART OF THE SENTENCE. YOU SAID "THERE HAS BEEN
CONCERN THAT IF THE NUTRIENT ENRICHED CATTAIL ZONE
DID TEND TO HAVE LOW REDOX POTENTIALS" -- I
UNDERSTAND WHAT YOU SAID---
A. UH-HUH (YES).
Q. ---"MERCURY IN THE SOIL AND THE WATER MIGHT
UNDERGO UNDESIRABLE TRANSFORMATIONS AND ADD TO THE
HIGH MERCURY CONCENTRATIONS FOUND IN SOME AREAS OF
THE EVERGLADES."
A. UH-HUH (YES). RIGHT.
Q. WHAT DO YOU KNOW ABOUT MERCURY METHYLATION, IN
THESE TYPE OF CONDITIONS?
A. OH, VERY LITTLE. THAT'S JUST BASICALLY A VERY
GENERAL STATEMENT, AND -- AND WE'RE TRYING TO SAY,
YOU KNOW, THIS IS A SIGNIFICANT PROBLEM, YOU KNOW,
WE NEED TO LOOK AT.
Q. THE MERCURY PROBLEM?
A. RIGHT, AS A RATIONALE FOR ACTUALLY DOING THE
EXPERIMENTS ON REDOX POTENTIAL.
Q. OKAY. OKAY.
DR. QUALLS VOLUME II PAGE 326
A. AND, YOU KNOW, WE DIDN'T DO ANYTHING WITH MERCURY
AT ALL.
Q. DO YOU PLAN TO?
A. IN CONNECTION WITH THOSE EXPERIMENTS, NO.
Q. DO YOU PLAN TO?
A. NO.
Q. YOU HAVE NO PLANS?
A. NOT---
Q. OKAY.
A. ---NOT MYSELF.
Q. DO YOU KNOW OF ANYONE WHO DOES?
A. I DON'T KNOW.
Q. HAVE YOU HEARD OF ANYONE WHO'S DOING THIS TYPE OF
WORK?
A. I DON'T REALLY KNOW.
Q. ALL RIGHT. PAGE 247, YOU SAY AGAIN, "BECAUSE
NATURAL DISSOLVED ORGANIC MATTER IS A POWERFUL
AGENT FOR COMPLEXATION OF METALS"---
A. UH-HUH (YES).
Q. ---"IT PLAYS AN IMPORTANT ROLE IN METAL TOXICITY
(e.g., MERCURY)"---
A. UH-HUH (YES).
Q. ---"METAL EXPORT (e.g., MERCURY AGAIN) AND
WEATHERING OF ROCK."
DR. QUALLS VOLUME II PAGE 327
A. UH-HUH (YES).
Q. OKAY. IS THIS CONCERN JUST THE SAME, THAT MERCURY
IS A BIG PROBLEM IN THE EVERGLADES, AND THIS IS A
RATIONALE FOR LOOKING AT REDOX?
A. THAT'S RIGHT, YEAH. WE DIDN'T DO ANYTHING
SPECIFIC THERE, BUT THAT IS JUST THE REASON, YOU
KNOW, WHY IS, IN THIS CASE, DISSOLVED ORGANIC
NITROGEN -- WHY WOULD THAT -- WHAT ROLES MIGHT
THAT PLAY IN THE ECOLOGY OF THE EVERGLADES. AND
THAT CERTAINLY IS A ROLE FOR HUMIC SUBSTANCES.
THEY ARE POWERFUL AGENTS FOR COMPLEXING METALS.
AND I HAVE READ A COUPLE OF REFERENCES THAT
MERCURY, WHEN IT'S BOUND BY HUMIC SUBSTANCES CAN
UNDERGO SOME TRANSFORMATIONS, PARTICULARLY IN
CONJUNCTION WITH SUNLIGHT. BUT BEYOND THAT, THAT
WAS STRICTLY JUST HAVING READ A REFERENCE, YOU
KNOW.
Q. OKAY. DO YOU KNOW DR. PATRICK AT LSU?
A. YES, UH-HUH (YES).
Q. ARE YOU AWARE OF DR. PATRICK DOING ANY MERCURY
TESTING?
A. NO. I HAD HEARD SOME -- SOMETHING ABOUT THAT HE
WAS INTERESTED IN IT.
Q. UH-HUH (YES).
DR. QUALLS VOLUME II PAGE 328
A. BUT I DON'T REALLY KNOW ANY DETAILS.
Q. IS THIS RECENTLY?
A. I THINK IT IS FAIRLY RECENTLY.
Q. BUT YOU HAVE NO IDEA WHAT HE PLANS TO DO, OR
WHERE?
A. NOT REALLY.
Q. I WOULD -- I'D LIKE TO ASK YOU JUST A FEW
QUESTIONS ABOUT SIX, THAT SOMEHOW I HAVEN'T
COVERED IN THE COURSE OF MY OTHER QUESTIONS, AND
I'M -- I'M DONE. YOU TALK ABOUT ON 196 AN
INTERESTING CONCEPT THAT WE WENT BACK AND FORTH
ON YESTERDAY, A SYSTEM BEGINNING TO COME TO
EQUILIBRIUM, WITH TWENTY-FIVE TO THIRTY YEARS OF
NUTRIENT INPUTS FROM THE HILLSBORO CANALS -- IN
THE MIDDLE OF THE PAGE?
A. YEAH.
Q. OKAY. WHAT DO YOU MEAN, A SYSTEM BEGINNING TO
COME TO EQUILIBRIUM?
A. WHAT I MEANT IN THAT -- AT THAT POINT WAS, THAT
WHEN WE BEGAN OUR SAMPLING ALONG THE GRADIENT IN
WATER CONSERVATION AREA 2A, IT WAS DURING THAT
YEAR, I THINK THAT, AT LEAST OFFICIALLY, THE CANAL
GATES TO THE HILLSBORO CANAL WERE NOT OPENED
DURING THAT YEAR.
DR. QUALLS VOLUME II PAGE 329
Q. UH-HUH (YES). UH-HUH (YES).
A. SO, IT PROVIDED US A GOOD OPPORTUNITY TO SEE, YOU
KNOW, WHAT WOULD HAPPEN, IF, YOU KNOW, FOR AN
ENTIRE YEAR YOU SHUT OFF ALL THE INPUTS. AND I
DIDN'T MEAN TO SAY THAT IT WAS COMING TO ANY SORT
OF EQUILIBRIUM WITH, YOU KNOW, BEING SATURATED
WITH PHOSPHORUS, OR ANYTHING LIKE THAT. WHAT I
REALLY MEANT THERE WAS THAT IT WAS BEGINNING TO,
YOU KNOW, YOU'VE CUT OFF THE INPUTS, AND IT'S
BEGINNING TO KIND OF RE-EQUILIBRATE.
Q. OKAY. BUT ONCE YOU OPEN THE GATES AGAIN, THAT
WOULD BE DISTURBED, IS THAT -- IS THAT IMPLICIT IN
YOUR ANSWER?
A. WELL, YOU KNOW, NOT NECESSARILY DISTURBED, BUT IN
THE SENSE THAT ONCE YOU OPEN THE GATES AGAIN, IT
COULD BE SUBJECT TO FURTHER CHANGES, YOU KNOW,
OBVIOUSLY FURTHER PHOSPHORUS INPUTS.
Q. OKAY.
A. BUT WE THOUGHT IT WAS A GOOD OPPORTUNITY TO SEE,
YOU KNOW, WHAT WOULD HAPPEN FOR AN ENTIRE YEAR,
WHEN THERE WAS NO FURTHER INPUTS.
Q. OKAY. YOU USED THE WORD, THE MAGIC WORD,
SATURATED. I'D LIKE TO KNOW WHAT YOU MEAN BY
SATURATED.
DR. QUALLS VOLUME II PAGE 330
A. RIGHT.
Q. IF THAT SYSTEM WERE SATURATED, WHAT WOULD THAT
MEAN?
A. I WOULD LIKE TO -- THAT'S OBVIOUSLY, AGAIN, A
SEMANTIC TERM---
Q. UH-HUH (YES).
A. ---AND I WOULD DEFINE SATURATION OF A NUTRIENT IN
A CERTAIN ECOSYSTEM AS WHEN THE OUTPUT OF THE
NUTRIENT EQUALS THE INPUT OF THE NUTRIENT, AND
THERE'S NO CHANGE IN THE STORAGE OF THAT NUTRIENT
OR ELEMENT WITHIN THE SYSTEM. AND, I THINK THAT
IN A SYSTEM WHICH IS ALWAYS BUILDING PEAT, YOU
WOULD NEVER BE ABLE TO SAY THAT IT'S SATURATED,
BECAUSE AS LONG AS YOU ARE LAYING DOWN PEAT, YOUR
INPUTS -- YOUR OUTPUTS WILL ALWAYS BE LOWER THAN
YOUR INPUTS---
Q. NOW---
A. ---EXCEPT FOR SOME TEMPORAL OSCILLATIONS,
POSSIBLY---
Q. OKAY. PUTTING---
A. ---BUT THIS IS MORE OR LESS A THEORETICAL---
Q. I UNDERSTAND.
A. ---CONCEPT, YOU KNOW, OF SATURATION. BUT I THINK
YOU KNOW, THE ONE MOST PERTINENT TO WHAT WE'RE
DR. QUALLS VOLUME II PAGE 331
INTERESTED IN, IN TRYING TO DECIDE, YOU KNOW,
WHAT'S GOING ON IN THE STA'S, WHAT'S GOING ON IN
THE NATURAL SYSTEM THAT'S RECEIVING PHOSPHORUS, IS
I WOULD USE THAT DEFINITION AS TO WHEN THE OUTPUTS
WILL EQUAL THE INPUTS, AND THERE WILL NO LONGER BE
ANY NET ACCUMULATION AND DEPOSITION IN THE SOIL.
AND I DON'T THINK THAT THAT WILL HAPPEN. I THINK
THAT THERE WILL ALWAYS BE DEPOSITION OF PEAT, AND
ALWAYS BE DEPOSITION OF PHOSPHORUS.
Q. SO, IF I UNDERSTAND YOU CORRECTLY, YOUR DEFINITION
OF SATURATION WOULD BE THE SAME AS IF IT WERE IN
EQUILIBRIUM? I DON'T MEAN TO COMPLICATE THINGS.
IT JUST SOUNDED TO ME AS THOUGH IT'S IN
EQUILIBRIUM, IF THE INPUTS ARE EQUALLY THE
OUTPUTS. I DON'T MEAN TO COMPLICATE THIS. IF
IT'S NOT THE SAME, I'LL LET IT GO.
A. RIGHT, YEAH. I THINK WE WOULD HAVE TO, YOU KNOW,
TALK ABOUT EQUILIBRIUM. I WOULD SAY POSSIBLY YOU
MIGHT APPLY THE WORD EQUILIBRIUM TO THE ENTIRE
SYSTEM, BUT I DON'T THINK WE COULD APPLY THAT WORD
EQUILIBRIUM IN THAT CASE, SO---
Q. OKAY---
A. ---YOU KNOW, NO, I WOULD -- I WOULD DISAGREE.
Q. ---WHAT WOULD EQUIL -- WHAT WOULD EQUIL -- WE'LL
DR. QUALLS VOLUME II PAGE 332
PUT A DIFFERENT DEFINITION ON EQUILIBRIUM. WHAT
WOULD EQUILIBRIUM MEAN FOR WATER CONSERVATION
AREA 2A?
A. I THINK -- I THINK WE WOULD HAVE TO BE MUCH MORE
SPECIFIC THAN THAT, BECAUSE YOU COULD HAVE CHANGES
IN SPECIES, POPULATIONS, YOU COULD HAVE CHANGES IN
THE VARIOUS FORMS OF THE NUTRIENTS, ALL THINGS
THAT I WOULD CALL DYNAMIC PROCESSES GOING ON, AND
STILL POSSIBLY SEE A CASE WHERE, SAY, INPUTS AND
OUTPUTS STAYED AT A ROUGHLY EQUAL LEVEL OVER THE
YEARS. SO, I DON'T REALLY THINK WE CAN EVEN, YOU
KNOW, GENERALIZE THAT MUCH TO SAY WHAT EQUILIBRIUM
FOR THAT ENTIRE SYSTEM WILL BE.
Q. DR. QUALLS, WOULD YOU -- WOULD YOU JUST BRIEFLY
EXPLAIN TO ME HOW YOU DID YOUR WEIGHTED DISTANCES
THAT ARE ON PAGE 202? WELL, THEY'RE THROUGHOUT
HERE, BUT---
A. RIGHT, UH-HUH (YES).
Q. ---AND I KNOW YOU'VE EXPLAINED THEM IN THE TEXT,
BUT IF YOU'D JUST DO IT VERBALLY, I'D APPRECIATE
IT.
A. YES. BASICALLY WHAT IT IS, IS I MEASURED THE
DISTANCES. I TOOK AT ANY ONE PARTICULAR POINT,
LET'S SAY POINT NUMBER D1---
DR. QUALLS VOLUME II PAGE 333
Q. UH-HUH (YES).
A. ---MEASURED THE DISTANCE TO THE "D" GATE, ADDED TO
IT THE DISTANCE TO THE "C" GATE, AND THEN ADDED TO
THAT THE DISTANCE TO THE "A" GATE, ALTHOUGH
THERE'S A LITTLE EXCEPTION THERE. BUT JUST FOR
PURPOSES OF ILLUSTRATION, ADDED UP THE DISTANCES
TO EACH OF THE THREE GATES, AND -- AND, THEN,
LET'S SEE, THEN DIVIDED BY THREE. IN OTHER WORDS,
KIND OF LIKE AVERAGING THE DISTANCES FROM THOSE
THREE GATES. BUT, THEN I PUT A WEIGHT ON EACH OF
THOSE DISTANCES, AND I COUNTED THE DISTANCE TO THE
"D" GATE MUCH MORE THAN THE DISTANCE TO THE "C"
GATE, BECAUSE IT HAD A HIGHER LOAD OF PHOSPHORUS
OVER THE YEARS. AND THE LOADS OF PHOSPHORUS THAT
I HAD USED TO CALCULATE THAT WEIGHTED AVERAGE WERE
THE ONES THAT WERE QUOTED IN THE SWIM PLAN AS THE
TOTAL NUMBER OF TONS OF -- METRIC TONS OF
PHOSPHORUS COMING IN EACH GATE DURING THE PERIOD
OF -- I THINK IT WAS 1978 TO '89, OR SOMETHING
LIKE THAT.
Q. ALL RIGHT. WAS THIS YOUR IDEA?
A. I THINK SO. YOU KNOW, SOMETIMES IT'S HARD TO
REMEMBER, YOU KNOW, WHEN YOU'RE CONSTANTLY
DISCUSSING THIS AMONG SEVERAL PEOPLE IN THE LAB,
DR. QUALLS VOLUME II PAGE 334
BUT, YOU KNOW, I THINK SO.
Q. YOU DON'T THINK IT WAS ANYONE ELSE'S IDEA? YOU
THINK YOU -- YOU -- YOU'RE THE ONE WHO DECIDED TO
DO WEIGHTED DISTANCES?
A. I BELIEVE SO.
Q. YOU SEEM A LITTLE UNSURE.
A. WELL, NO, I'M JUST TRYING TO, YOU KNOW, NOT TO,
YOU KNOW -- NOT TO EXCLUDE IF IT WAS ANYBODY
ELSE'S IDEA---
Q. IF THEY WANT TO TAKE CREDIT---
A. ---AND I JUST DON'T REMEMBER.
Q. ---YOU'LL LET THEM?
A. RIGHT, YEAH, UH-HUH (YES). I MEAN, YOU KNOW, ALL
THESE THINGS, WE, WE TALK ABOUT THESE THINGS, AND
THRASH THEM OUT, AND WE HAVE WEEKLY MEETINGS IN
THE LAB, YOU KNOW, AS TO WHAT THE BEST APPROACH TO
ALL THESE THINGS ARE.
Q. HOW DID YOU DECIDE WHAT WEIGHT TO PLACE ON THE
VARIOUS -- YOU SAID THAT YOU -- YOU ASCRIBED A
WEIGHT. HOW DO YOU -- HOW DID YOU MAKE THAT
DETERMINATION?
A. THE WEIGHT IS BASED ON THE RELATIVE LOADS OF THE
PHOSPHORUS THAT CAME THROUGH THE---
Q. OKAY. ALL RIGHT. OKAY. ALL RIGHT. YOU TOLD ME
DR. QUALLS VOLUME II PAGE 335
THAT, I'M SORRY. I APOLOGIZE.
A. YEAH.
Q. DID YOU WORK THIS OUT WITH ANYONE ELSE, OR DID YOU
DO THIS ALL BY YOURSELF?
A. I THINK, YOU KNOW, WHEN I WAS ACTUALLY DOING THE
CALCULATIONS, I THINK I JUST LOOKED UP THE LOADS
IN THE SWIM PLAN---
Q. UH-HUH (YES).
A. ---AND TOOK A MAP THAT HAD LATITUDE AND LONGITUDE
ON IT, AND PLOTTED THE POINTS, ACCORDING TO THEIR
LATITUDE AND LONGITUDE, ACCORDING TO LORAN-C.
Q. UH-HUH (YES).
A. AND THEN ACTUALLY PHYSICALLY MEASURED THE
DISTANCES WITH A RULE, AND TYPED THEM INTO A LOTUS
PROGRAM, AND ADDED THE WEIGHTS AND EVERYTHING.
NOW, ONE EXCEPTION TO THAT WAS, SINCE WE NEVER SAW
WATER FLOWING FROM THE S10 GATE TOWARDS THE "D" OR
"C" TRANSECTS, WE THOUGHT THAT IT SHOULDN'T BE
WEIGHTED SO MUCH -- YOU SHOUL