1 2 3 4 THE NORTH BATTLEFORD WATER INQUIRY 5 6 7 8 9 10 11 * * * * * 12 13 14 BEFORE: The Honourable Justice Robert D. Laing 15 16 17 HELD AT: Tropical Inn, 18 North Battleford, Saskatchewan 19 20 21 * * * * * 22 23 24 25 September 17, 2001

1 APPEARANCES: 2 JAMES RUSSELL, Esq. ) 3 CHRISTOPHER BOYCHUK, Esq. ) Commission Counsel 4 BLAIR BLEAKNEY, Esq. ) 5 6 WARREN E. BICKFORD ) Executive Director 7 NORM DOELL ) Registrar 8 9 L. TED PRIEL, Q.C., Esq. ) The City of North 10 ) Battleford 11 GARY D. YOUNG, Q.C., Esq. ) The Battlefords 12 District Health 13 ROBERT McDONALD, Esq. ) Association of 14 Professional Engineers 15 & Geoscientists of 16 Saskatchewan 17 MICHAEL TOCHOR ) Department of Justice 18 L. M. SCHWANN ) Saskatchewan 19 Environment and 20 Resource Management 21 R. G. HISCHEBETT ) Saskatchewan Health 22 R. E. PETRICH ) Saskatchewan Municipal 23 Affairs and Housing 24 T. MICHAEL McDOUGALL ) Saskatchewan Water 25 Corporation

1 SCOTT HOPLEY, Esq. ) Saskatchewan 2 Environment Society and 3 Nature Saskatchewan 4 N.G. GABRIELSON, Q.C., Esq. ) Dr. L. Gerharde Benade 5 Dr. David Butler-Jones 6 and Dr. Eric Young 7 ROBERT W. MITCHELL, Q.C., Esq. ) Canadian Union of 8 SANDRA G. MITCHELL, Ms. ) Public Employees, 9 Local 287 10 G.J. SCHARFSTEIN, Esq. ) On behalf of 427 11 individuals and 12 corporations affected 13 by the contaminated 14 potable water in North 15 Battleford 16 17 18 19 20 21 22 23 24 25

1 TABLE OF CONTENTS 2 Page No. 3 4 ROGER MCDONALD, Sworn 18 5 EXAMINATION-IN-CHIEF BY MR. JAMES RUSSELL 22 6 7 8 Court Reporter's Certificate 221 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

1 LIST OF EXHIBITS 2 NUMBER DESCRIPTION PAGE NO. 3 C-1 Saskatchewan Legislative Framework 4 Binder 16 5 C-2 Written Agreement 17 6 C-3 Roger A. McDonald binder dated September 7 11th, 2001 19 8 C-4 Flashpoint multi-media disk presentation 9 to be made by Mr. McDonald 21 10 C-5 Water Treatment Plant Number 2 Daily 11 Plant Log 22 12 C-6 Water Treatment Plant Water Turbidity 13 Charts 22 14 C-7 Binder of documents entitled, Water Treatment 15 Plant Number 2, Daily Plant Log 22 16 17 18 19 20 21 22 23 24 25

1 --- Upon commencing at 9:58 a.m. 2 3 MR. COMMISSIONER: Well good morning. It 4 appears that everyone is in place and that we can proceed at 5 this time. 6 As most of you are aware, I am Justice Robert 7 Laing of the Court of Queen's Bench, and I've been appointed 8 Commissioner to conduct this Inquiry. 9 Are we having trouble with this mike, or ... 10 Today we begin the Hearings portion of the 11 Inquiry. In a moment I will call on Mr. Jim Russell, our 12 Commission Counsel, who has led the investigation stage of 13 the Inquiry, and who will be responsible for leading evidence 14 throughout this Hearing stage, to outline for you what is 15 contemplated for the week. 16 Mr. Norm Doell, who is seated here in front of 17 me is clerk to the Inquiry, and he will have the usual role 18 of clerk to play in the course of these Hearings. 19 A lot of effort by our Executive Director, Mr. 20 Warren Bickford, has gone into making this Hearing Room as 21 user friendly as possible. But if any of you have any 22 concerns or suggestions, we would suggest you take them up 23 with him. 24 Also you note -- you will note that each 25 counsel table is miked. But it is our request that any

1 counsel wishing to address the Inquiry more -- for more than 2 a few words, if you wish, come forward to the podium 3 microphone. 4 And the reason for this is that, as you may or 5 may not be aware, the local community cable operator in North 6 Battleford is visually recording these proceedings, and there 7 will be two (2) stationary cameras, one (1) directed at the 8 witness table and the other one (1) directed at the podium 9 microphone. 10 And it's for that reason that we would ask you 11 to come forward. 12 Our hours of sitting have been left a little 13 bit up in the air. We certainly agreed to start at 10:00 14 a.m. this morning. But I have to say that given the amount 15 of materials that this Inquiry may yet have to proceed 16 through, my preference would be to start at 9:30 a.m. each 17 morning and proceed until 12:30 p.m. And then from 2:00 p.m. 18 to 5:00 p.m., with a fifteen (15) minute break in each 19 morning and afternoon. 20 However, if any counsel have a major problem 21 with starting at 9:30 a.m., you can advise Mr. Russell, and 22 if we don't hear of any such a concern, we'll start at 9:30 23 a.m. tomorrow morning. 24 Now I would also -- one (1) other housekeeping 25 item, if you wish. I would like to remind counsel that our

1 rules of practice and procedure contemplate that counsel will 2 agree amongst yourselves, the order of cross-examination of 3 any particular witness. And failing that agreement, I will 4 decide. 5 So I guess we would ask that to the extent 6 that you are not able to agree in any one (1) instance or 7 with respect to any one (1) instance, you notify Mr. Russell 8 as soon as you're aware of that fact and I can then consider 9 the matter. 10 Now while the terms of reference of this 11 Inquiry have been reasonably well publicized, at this point I 12 would like to read them into the record. 13 The terms of reference state: 14 "The Commission of Inquiry appointed 15 pursuant to this Order, will have the 16 responsibility to inquire into and report 17 on, and make findings and recommendations 18 with respect to any and all aspects of the 19 following matters. 20 (A) The circumstances that led to the 21 current contamination of the public water 22 supply of the City of North Battleford 23 (B) the adequacy and effectiveness of 24 the actions taken by officials of the 25 Government of Saskatchewan, the Battlefords

1 District Health Board and the City of North 2 Battleford leading up to and in response to 3 the discovery of the contamination of the 4 public water supply in the City of North 5 Battleford. 6 (C) The affect, if any, of the 7 regulations, bylaws, policies, guidelines, 8 procedures and practices of or applicable 9 to the Government of Saskatchewan, the 10 Battlefords District Health Board and the 11 City of North Battleford on the events 12 referred to in (A) and (B). 13 (D) any other relevant matters that the 14 Commission considers necessary to determine 15 that the City of North Battleford's public 16 drinking water is safe in the future. 17 To the citizens of North Battleford I would 18 like to say that I and our Commission staff will be as 19 diligent as we can be in pursuing the items referred to in 20 the terms of reference during the course of this Inquiry and 21 we look forward to working with all parties in this respect. 22 For the citizens who are not able to attend 23 but might be interested, as earlier reported, we do have a 24 website and it is contemplated that transcripts will be 25 posted daily of the previous day's evidence at this Hearing.

1 Well, without further ado, I believe it would 2 be appropriate to ask counsel to stand and identify yourself 3 and the party you represent for the record in these 4 proceedings please. Perhaps starting over here on the left, 5 Mr. Priel. 6 MR. TED PRIEL: Ted Priel, Mr. Commissioner, 7 and Ken Stevenson representing the City of North Battleford. 8 MR. COMMISSIONER: All right, thank you. I 9 believe I will ask you to sit in doing so because the 10 microphone is easier to pick up from a seated position. 11 MR. ROBERT MITCHELL: My name is Robert 12 Mitchell, I'm -- I'm appearing for the CUPE Local who 13 represent the workers at the water treatment plant and the 14 sewage treatment plant. With me is my partner, Sandra 15 Mitchell, and seated beside me is Mr. Frank Hollmann, who is 16 one (1) of the operators. 17 MR. COMMISSIONER: Thank you. All right, 18 next please. 19 MR. GARY YOUNG: Thank you. I'm Gary Young, 20 I am appearing along with Mark Vanstone on my extreme right 21 for The Battlefords Health District and seated with us at the 22 table is Mr. Korluk, the public health inspector for The 23 Battlefords Health District. 24 MR. COMMISSIONER: Thank you. 25 MR. NEIL GABRIELSON: Neil Gabrielson, I

1 represent Dr. Benade, Dr. David Butler-Jones and Dr. Eric 2 Young. 3 MR. COMMISSIONER: Thank you. 4 MR. SCOTT HOPLEY: Scott Hopley, I am here 5 for the -- 6 MR. COMMISSIONER: Could you speak into the 7 microphone, Mr. Hopley? 8 MR. SCOTT HOPLEY: Well, unfortunately -- 9 MR. COMMISSIONER: Oh, you don't have one 10 (1)? 11 MR. SCOTT HOPLEY: -- Mr. Scharfstein and I 12 don't have a microphone. 13 MR. COMMISSIONER: All right, well then I 14 guess -- you are being asked to come to the podium for the 15 purposes of being transcribed; I'm sorry about that. 16 MR. SCOTT HOPLEY: Scott Hopley, I'm 17 appearing on behalf of the Saskatchewan Environmental Society 18 and Nature Saskatchewan. Seated at the table with me is 19 Terry Cherkewich, my assistant. 20 MR. COMMISSIONER: Thank you. 21 MR. GRANT SCHARFSTEIN: My name is Grant 22 Scharfstein, appearing on behalf of the citizen's group and 23 attending with me is Mr. Ed Ryan, one (1) of my associates. 24 MR. COMMISSIONER: Thank you. We'll pass on 25 the first table and the next table...?

1 MR. MICHAEL TOCHER: My name is Michael 2 Tocher, Mr. Commissioner, I'm representing the Province of 3 Saskatchewan and seated with me are Mike McDougall and Lian 4 Schwann. 5 MR. COMMISSIONER: Thank you. Next table. 6 MS. SANDYHA PADMANABH: Sandyha Padmanabh 7 with Environment and Resource Management. 8 MR. COMMISSIONER: All right. 9 MR. PETER THIELE: Peter Thiele with 10 Saskatchewan Environment and Resource Management, as well as 11 Blaine Ganong with Saskatchewan Environment and Art Jones 12 with Saskatchewan Environment. 13 MR. COMMISSIONER: All right. So all of you 14 people would be associated with Mr. Tocher and the Government 15 of Saskatchewan? 16 MR. PETER THIELE: Correct. 17 MR. COMMISSIONER: Thank you. Next table. 18 MR. ROBERT McDONALD: My name -- my name is 19 Bob McDonald, I'm representing the Association of 20 Professional Engineers and Geoscientists of Saskatchewan. 21 MR. COMMISSIONER: Thank you. Does that 22 include everyone who has standing before the Commission at 23 this time? All right, thank you. 24 Mr. Russell, I will now ask you to proceed and 25 perhaps you can introduce the people you have at your table

1 at the same time. Thank you. 2 MR. JAMES RUSSELL: Thank you, Mr. 3 Commissioner. My name's Jim Russell. I'm legal counsel to 4 the Commission. My table, on my immediate left, Mr. Chris 5 Boychuk and on his left, Mr. Blair Bleakney who are legal 6 counsel, assisting me in this matter. 7 Mr. Commissioner, this Commission of Inquiry 8 has been asked to investigate and make recommendations with 9 respect to the matters set forth in the terms of reference, 10 attached to the Order in Council that establishes the 11 Commission pursuant to the Public Inquiry's Act and you 12 already read those terms of reference into the record. 13 In order to conduct our investigations and 14 assemble the relevant evidence for your review and at these 15 public hearings, the -- in the relatively short space of time 16 available to us, Commission staff have been ably and 17 generously assisted by parties with standing and their legal 18 counsel. And the knowledge and advise of many individuals, 19 some of whom will appear before the Commission as witnesses 20 and some of whom will not, has also been of great assistance 21 to us. 22 Our investigations are, at this stage, by no 23 means complete and we will be calling upon others to come 24 forward and assist us as we proceed. But I would be most 25 remiss if I did not, on behalf of myself and Commission

1 staff, thank those parties and legal counsel who we've worked 2 with to date and who have given us considerable support and 3 effort in allowing us to bring the hearings today in North 4 Battleford and begin on today's date. 5 The tale we're about to tell through our 6 various witnesses and documentary evidence is a complex one 7 (1) involving, as it does, some fairly abstruse areas of fact 8 and opinion. And in order to tell this tale clearly and 9 comprehensively we plan, first of all, to introduce this week 10 evidence that will establish the framework within which the 11 relevant events unfolded and within which the characters 12 involved played their respective roles. 13 If time permits, we may get around to calling 14 the plant operators towards the end of the week. But before 15 we come to the actual circumstances of the contamination 16 referred to in the Inquiry's terms of reference and the 17 adequacy and effectiveness of the official action taken in 18 response to that contamination, at all relevant levels, we 19 plan to begin by introducing evidence that will describe the 20 physical plant and infrastructure of the North Battleford 21 drinking water and sewage treatment system, as well as the 22 processes and procedures required to operate that system. 23 In addition, to assist the orientation and 24 familiarization process I would like to place before the 25 Commission a collection of documents that has been prepared

15
  1  by Ms. Lian Schwann and her team at Justice and SERM.  A
  2  collection of documents entitled, Saskatchewan Waterworks and
  3  Sewage Works Regulatory Program.  
  4                 As you will see, Mr. Commissioner, this paper
  5  is divided into three (3) parts.  Part 1 summarizes the
  6  constitutional division of powers between the federal and
  7  provincial levels of government on water issues.  Part 2 is
  8  an overview of the legislative framework for the regulation
  9  of waterworks and sewage works in Saskatchewan, and includes
 10  a brief description of the respective roles of SERM,
 11  Saskatchewan Health, the health districts and Saskatchewan
 12  Water Corporation in this area.  And Part 3 describes the
 13  administrative structure of SERM at the material time.
 14                 In introducing this package of regulatory
 15  instruments at this stage, our intention is that some of our
 16  earlier witnesses may well make reference to it's contents
 17  and it will be helpful, Mr. Commissioner, I think both for
 18  you and legal counsel to have it before you should any such
 19  reference arise.  With your permission, Mr. Commissioner, I
 20  think that I would like to introduce this package as our
 21  first exhibit of the hearings.
 22                 MR. COMMISSIONER:   All right.  Have various
 23  counsel appearing before the Commission received a copy of
 24  this?
 25                 MR. JAMES RUSSELL:   Yes, Mr. Commissioner,

1 they have been circulated to legal counsel. 2 MR. COMMISSIONER: All right. Well, I 3 have -- all right. As I may say to counsel, we are simply 4 going to list all Commission exhibits numerically, starting 5 with C-1 and proceeding numerically thereafter. 6 If and when we get to the point where other 7 parties may end up tendering evidence that is not tendered 8 through the Commission, we'll assign a different letter to it 9 at that time. 10 Likewise, it's expected that because there has 11 been substantial disclosure along the way and hopefully will 12 continue to be, that Mr. Russell will proceed with 13 introducing various documentary evidence, assuming that if 14 someone has an objection to it they will raise it rather than 15 me asking in each instance whether anyone has an objection to 16 any particular piece of evidence and hopefully that's 17 acceptable to all counsel. 18 All right, thank you, Mr. Russell. 19 20 --- EXHIBIT NO. C-1 Saskatchewan Waterworks Legislative 21 Framerwork Binder 22 23 MR. JAMES RUSSELL: Mr. Commissioner, in 24 relation to the -- the last matter which you brought up, I 25 would like to note for the record that legal counsel have

1 agreed that all of the documents disclosed by Commission 2 counsel are admissible as full exhibits and are proven in the 3 absence of proof to the contrary, without the requirement of 4 formal proof for the purposes of this Inquiry and are proven 5 as to authenticity as to execution. 6 In the case of correspondence and/or facsimile 7 transmissions, as to sending by the author and receipt by the 8 address with enclosures within reasonable times after the 9 date of any such document. 10 And in the case of photocopies, that they are 11 accurate reproductions of the original and are admissible in 12 the place of the original documents. 13 But the said documents being admissible as 14 full exhibits and proven, does not make them binding with 15 respect to veracity, weight or effect which shall depend upon 16 the evidence received. 17 We do have a written agreement signed by legal 18 counsel to that affect, Mr. Commissioner, and I would like to 19 place that before the Commission as our second exhibit, with 20 your permission. 21 MR. COMMISSIONER: All right. Written 22 agreement will be C-2. 23 24 --- EXHIBIT NO. C-2 Written Agreement 25

1 (BRIEF PAUSE) 2 3 MR. JAMES RUSSELL: Mr. Commissioner, that's 4 the -- the extent of the preliminary matters as far as 5 Commission staff are concerned and without more ado, with 6 your permission, I would like to call Mr. Roger McDonald as 7 our first witness and ask that he be duly sworn. 8 MR. COMMISSIONER: Yes. 9 THE REGISTRAR: State your full name for this 10 Inquiry. 11 MR. ROGER MCDONALD: My name is Roger A. 12 McDonald. 13 THE REGISTRAR: Spell your last name. 14 MR. ROGER MCDONALD: M-c-D-O-N-A-L-D. 15 16 (MR. ROGER MCDONALD, Sworn:) 17 18 MR. COMMISSIONER: Proceed, Mr. Russell. 19 MR. JAMES RUSSELL: Mr. Commissioner, I would 20 like to note for the benefit of yourself and legal counsel, 21 that Mr. McDonald is being called to testify at this stage of 22 the Hearings for a somewhat narrow purpose, which is to give 23 us a basic understanding of the physical components and basic 24 processes in use at the North Battleford Drinking Water 25 Ins -- in the North Battleford Drinking Water and Sewage

1 Water System. 2 As those processes and physical components 3 existed in early March of 2001, immediately prior to the 4 events that are the subject matter of this Inquiry. 5 And so that we can introduce evidence in an 6 orderly manner, we would ask that legal counsel confine their 7 cross-examination of Mr. McDonald to the role we're asking 8 him to play today. 9 It is our plan to call Mr. McDonald later in 10 these Hearings when we'll be asking him to give evidence on 11 the role he's played in responding to the contamination 12 events in assessing the situation, and his role in assisting 13 the City of North Battleford with the remediation efforts. 14 But that is for another day. 15 Mr. Commissioner, there are several binders of 16 documents associated with this witness which, with your 17 permission, I would like to have marked as exhibits before we 18 begin. 19 There's, first of all, the Roger A. McDonald 20 binder dated September 11th, 2001. This binder has been 21 circulated to legal counsel, and I asked that it be marked as 22 our third exhibit and a copy placed before you. 23 MR. COMMSSIONER: Right. C-3. 24 25 --- EXHIBIT NO. C-3: Roger A. McDonald binder dated

1 September 11th, 2001 2 3 MR. JAMES RUSSELL: The only change in this 4 binder to the material circulated earlier are the loose leaf 5 materials in relation to operator comments, which came too 6 late last week for us to enclose in the original binder. But 7 we've also circulated them to legal counsel and we would ask 8 that they be inserted into the binder. 9 Mr. Commissioner, you'll see that tab 3 of 10 Exhibit 3 contains a disk of a Flash multi-media presentation 11 prepared for use in conjunction with this witness. Tab 3 12 also indicates by way of the letter received from Priel 13 Stevenson Hood and Thornton that the disk circulated to legal 14 counsel is not the final presentation that we'll be seeing 15 today and that some changes will be made to the version they 16 have seen. 17 A subsequent version of the Flash multi-media 18 presentation was delivered to the Commission offices over the 19 weekend. Commission staff were not able to burn copies for 20 circulation to legal counsel prior to these hearings. 21 But I would like -- and I apologize to them 22 for that fact. What I would like to do is to introduce the 23 latest version of this Flashpoint presentation of the North 24 Battleford water distribution system as our fourth exhibit 25 today. I will be confirming the actual changes made with the

1 witness from the previous edition of this disk during the 2 course of examination in-chief. So this will be the disk 3 itself, the disk we're seeing today. 4 MR. COMMISSIONER: Right. All right, C-4 5 will be the most recent disk on the presentation to be made 6 by Mr. McDonald. 7 8 --- EXHIBIT NO. C-4: Flashpoint multi-media disk 9 presentation to be made by Mr. 10 McDonald 11 12 (BRIEF PAUSE) 13 14 MR. JAMES RUSSELL: An additional binder of 15 documents is the Water Treatment Plant Number 2 Daily Plant 16 Log, which I ask be marked as our next exhibit. 17 18 (BRIEF PAUSE) 19 20 And another binder of materials that this 21 witness will be referring to is the Water Treatment Plant 22 Number 2 Turbidity Charts. 23 MR. COMMISSIONER: Water Treatment Plant 24 Number 2 -- 25 MR. JAMES RUSSELL: Turbidity. T-U-R-B-I-D-

1 I-T-Y Charts, which I ask be entered as our next exhibit. 2 MR. COMMISSIONER: Which will be C-6, the 3 previous one being C-5. 4 5 --- EXHIBIT NO. C-5: Water Treatment Plant Number 2 6 Daily Plant Log 7 8 --- EXHIBIT NO. C-6: Water Treatment Plant Water 9 Turbidity Charts 10 11 MR. JAMES RUSSELL: And finally, Mr. 12 Commissioner, for this witness we have a binder of documents 13 entitled, Water Treatment Plant Number 2, Daily Plant Log, 14 which I ask be entered as our next exhibit. 15 MR. COMMISSIONER: All right, C-7. 16 17 --- EXHIBIT NO. C-7: Binder of documents entitled, 18 Water Treatment Plant Number 2, 19 Daily Plant Log 20 21 (BRIEF PAUSE) 22 23 MR. JAMES RUSSELL: These materials, Mr. 24 Commissioner, have been circulated to leading counsel. 25

23
  1  EXAMINATION-IN-CHIEF BY MR. JAMES RUSSELL:
  2                 Q:   Mr. McDonald, I understand that you are
  3  the Manager and Municipal Engineer of MR2, McDonald and
  4  Associates; is that true?
  5                 A:   That's true.
  6                 Q:   Is MR2 McDonald and Associates a
  7  professional partnership?
  8                 A:   It's a -- run by a company called Roger
  9  McDonald Consulting Limited.
 10                 Q:   Of which you are the principal?
 11                 A:   Yes.
 12                 Q:   Okay.  I understand that you refer to
 13  your personal credentials and experience as are set out in
 14  your CV, which is attached as tab 2 to the Roger McDonald
 15  exhibits; is that true?
 16                 A:   Yes.
 17                 Q:   I understand that you are a Municipal
 18  Environment Professional Engineer with broad experience in
 19  both private and public sectors; is that correct?
 20                 A:   Yes.  Do you mean by broad, lengthy?
 21                 Q:   That's one (1) of the things I mean.  And
 22  that in this regard you've participated in various water
 23  quality management programs and studies; is that correct?
 24                 A:   I have.
 25                 Q:   As well as being directly responsible for

1 the design, contract administration and project management of 2 many large and small municipal government and industrial 3 water and waste waterworks; is that correct? 4 A: Yes. 5 Q: I understand that MR2 was hired by the 6 City of North Battleford to assist the city in its response 7 to the contamination that occurred in the spring of 2001; is 8 that correct? 9 A: Yes. 10 Q: Is the scope of the consulting work 11 you've done for the city as set out in the draft scope of 12 work dated May 16th, 2001, and which appears in the exhibit 13 binder, your Roger McDonald exhibit binder, as tab number 5? 14 15 (BRIEF PAUSE) 16 17 A: Yes, I believe this is correct. 18 Q: Is that the scope of work you've been 19 asked to do for the City of North Battleford? 20 A: It's the basic scope of work, we've done 21 other things related to it. 22 Q: Okay. And has MR2 assisted the city with 23 its remediation measures and its response to the 24 contamination events of 2001? 25 A: Well we believe we have.

1 Q: Has MR2 assisted the City of North 2 Battleford to satisfy the conditions necessary for the 3 lifting of the Boil Water Order that was imposed as a result 4 of the contamination events of 2001? 5 A: The protocol requirements for the lifting 6 of the Boil Water Order were apparently satisfied by the -- 7 in the view of the regulatory agency. 8 Q: Did you assist the city in satisfying the 9 regulatory agency to that affect? 10 A: We did help them. 11 Q: Has MR2 also assisted the City of North 12 Battleford in assembling evidence for the defence of the 13 lawsuit that has resulted from the contamination of 2001? 14 A: We've had no direct involvement with any 15 lawsuit action. 16 Q: Are you assisting in preparation for the 17 defence of that lawsuit in any way? 18 A: That hasn't been discussed, as far as I 19 know. 20 Q: Okay, that's no part of your terms of 21 reference? 22 A: Not at this time, no. 23 Q: Have you been presently -- have you been 24 present personally in North Battleford and assisting on the 25 site in the remediation process?

1 A: I have been present a number of times, 2 yes. 3 Q: So are you the person actively involved 4 on behalf of MR2 in assisting the city with these matters? 5 A: I am, yes. 6 Q: So when in fact did you first arrive in 7 North Battleford to attend to these matters? 8 A: I got called from the city on Sunday, 9 April 29 and I arrived in North Battleford Monday afternoon, 10 April 30. 11 Q: And, since that time, have you been 12 regularly on-site and attending to most of the work yourself 13 or have you been assisted by others who work for you? 14 A: We have -- I have done the bulk of the 15 work, I suppose, on-site, we have assistance both -- both 16 from other professionals in our office and from technologists 17 and administrative personnel. 18 Q: But are you the one (1) who has been 19 responsible for ensuring the work gets done, of personally 20 overseeing that it gets done? 21 A: I have direct responsibility, yes. 22 Q: In providing us with the -- the 23 description this morning that I'm about to ask you to provide 24 us with of the North Battleford drinking water and sewage 25 system, are you relying upon your own observations made on or

1 after the time of your arrival in North Battleford to attend 2 to the contamination events? 3 A: I am relying on observations I have made 4 on discussions I've had with city personnel, particularly the 5 operators, on existing plans and developments with respect to 6 the facilities and records and associated information. 7 Q: So you've had the opportunity to review 8 documentation and other materials related to the -- the 9 history of the plants? 10 A: I've had opportunity to review to the 11 extent possible that information, yes. 12 Q: Have you -- have you interviewed people 13 who work in the plants? 14 A: Have I -- well, I've certainly discussed 15 operations with them and issues and -- 16 Q: And have you discussed these matters with 17 people at City Hall too? 18 A: Yes, I have. 19 Q: I understand, Mr. McDonald, that to 20 assist us in following your account of the city's water and 21 sewage system, as they existed immediately prior to the 22 contamination events of 2001, that you have prepared or had 23 prepared a Flash multimedia presentation; is that correct? 24 A: That is. 25 Q: Did you prepare this yourself or did you

1 have assistance? 2 A: This was prepared by agents with the 3 Conestoga-Rovers & Associates out of Waterloo, in association 4 with the city legal counsel and -- and the city, yes. 5 Q: So are these people people you hired or 6 who the city hired? 7 A: I'm not sure an exact commercial 8 arrangement, I suspect they may have been engaged through 9 Priel Stevenson and Company, who are acting on behalf of the 10 city. 11 Q: But have you reviewed this presentation 12 yourself for accuracy? 13 A: I have. 14 Q: Is it accurate? 15 A: It is pretty good. If there is 16 inaccuracies, I'll point it out or if there's changes. 17 Q: Thank you. Have the -- just in relation 18 to the two (2) versions of this presentation that are 19 presently circulating, the changes that have been made to the 20 September 11th, 2001 version that is contained in -- at tab 3 21 of the Roger McDonald exhibit and which was circulated to 22 legal counsel earlier in the week, are the changes that have 23 been made in accordance with the -- the details given in the 24 letter from Priel Stevenson Hood & Thornton, which is also 25 part of tab 3 in that exhibit?

1 A: I believe they are, yes. 2 Q: Perhaps we could begin then, Mr. 3 McDonald, with the -- the overview diagram of the North 4 Battleford water and sewage system. 5 A: Assuming this is working. 6 7 (BRIEF PAUSE) 8 9 Q: Is this map drawn to scale? 10 A: I think it's reasonably to scale, I 11 wouldn't guarantee any accuracy. 12 Q: Okay. So could you begin by identifying 13 the -- the principal component parts of the water treatment 14 system and directing us to one (1) or two (2) landmarks in 15 this map which may help the Commissioner and legal counsel to 16 orientate themselves to the -- the general system? 17 A: Well I guess -- excuse me, in terms of 18 the layout, we have an engineering boo boo here. We have a 19 north arrow going to the right which shouldn't be done. But 20 for convenience, this is the layout. 21 Q: So where, sorry, the north is pointing in 22 the wrong direction? 23 A: No, no, it is pointing in the right 24 direction but it's not good practice to have it going in the 25 right side of the page.

1 Q: I see. 2 A: Anyway, this is the road -- the highway 3 from Saskatoon coming in and of course going across and onto 4 Lloydminster there, the bridge is -- can you see this? Is 5 this okay? Can you see it? 6 THE COMMISSIONER: I can see it, yes. Can 7 everyone else see it? 8 9 CONTINUED BY MR. JAMES RUSSELL: 10 Q: Is that the -- you were just pointing to 11 the highway 16 bridge there? 12 A: The highway 16 bridge, yes. Just so you 13 can get an orientation, the North Saskatchewan River, of 14 course, is flowing this direction. And perhaps, Mr. Russell, 15 if we could, we could just show the -- an air photo of the 16 river? 17 Q: Please proceed. 18 19 (BRIEF PAUSE) 20 21 A: Okay. This is the river here. 22 23 Q: Once again, is that the highway 16 24 bridge? 25 A: This is the highway 16 coming across --

1 Q: Across -- 2 A: -- coming down here, and to Battleford 3 and out. Just a little orientation here, the sewage 4 treatment is located in this area. There is a discharge 5 outfall from the sewage treatment plant and it goes through 6 here and enters the river. 7 Q: What is -- 8 A: Yes? 9 Q: What is -- what's the approximate 10 distance between the sewage treatment plant and the discharge 11 into the river? 12 A: About a thousand (1,000) metres. 13 Q: Thank you. 14 A: Excuse me, just as a matter of 15 clarification, I'm likely to speak in two (2) units, Imperial 16 and Metric. Is that satisfactory? 17 Q: Well as long as we know which one (1) it 18 is at any one (1) time I think we can handle it. 19 A: All right. Anyway, so this is the sewage 20 plant, as I mentioned. The -- the outfall discharge. This 21 is the river. We have in here a -- an island called 22 Finlayson Island. This is the old highway bridge going into 23 Battleford, the old steel truss bridge. 24 Q: Mr. McDonald, do you have a -- I think 25 you have a laser pointer on your desk?

1 A: Would that be better? 2 Q: It may help the people at the back see 3 this a little more clearly. The -- the white hand may get 4 lost in the -- 5 A: Okay. 6 Q: -- in the white. 7 A: Is that better? As I mentioned before, 8 this is a sewage treatment plant, the outfall, the river 9 here. We have Finlayson Island here. The old steel truss 10 bridge here and this is the location of the surface water 11 treatment plant, at this point down here. 12 Q: And can you give us approximately the 13 distance between the steel truss bridge and the surface water 14 treatment plant? 15 A: Well -- 16 Q: It's -- it's downstream, correct? 17 A: It is. I don't have -- well, just a 18 minute. I do have the numbers on another slide but perhaps 19 of interest, the distance between the outfall point and the 20 intake point, here, is approximately thirty-five hundred 21 (3,500) metres. 22 Q: This is the outfall point for the -- the 23 sewage discharge? 24 A: The waste water and -- 25 Q: Waste --

1 A: -- storm water discharge. 2 Q: And the surface water intake? 3 A: And the surface water intake. Are there 4 anymore features here that -- 5 Q: Not unless you feel that -- 6 A: No, I guess not. I -- I guess just as a 7 matter of source, Saskatchewan Hospital Complex is in this 8 area and -- 9 Q: Any pointers perhaps to the hotel, where 10 we are at the moment? 11 A: Well, we should be right there. 12 Q: All right. 13 A: Okay, going back to the city, in terms of 14 their water and waste water facilities, just highlight 15 briefly the key points and perhaps you can see that -- that 16 is water treatment plant number one (1). Water treatment 17 plant number one (1) utilizes groundwater and it supplies 18 water to the city. 19 We have water treatment plant number two (2) 20 located here. And I mentioned, the Saskatchewan Hospital, 21 they have a reservoir for their use, for that complex's use 22 at this site. 23 Q: Is that reservoir exclusively for the use 24 of the Saskatchewan hospital? 25 A: It's primarily used for the Saskatchewan

1 Hospital complex. The city does recover some of the water 2 for back-washing purposes for the operation of the plant. 3 Q: But it doesn't otherwise go into the 4 distribution system? 5 A: No. Within the water distribution itself 6 and we'll get into this a little later, we have some 7 reservoirs, an underground reservoir at 114th Street. We 8 have the water tower, which we'll show later -- 9 Q: Where -- where roughly is the water tower 10 situated? Can you give us a coordinate on that for the 11 purposes of the record? 12 A: I can't give you exact street names 13 because I don't know them off hand, but it's virtually in the 14 center of the community, east a little bit of the downtown 15 area. 16 Q: Right. 17 A: And then we have another underground 18 reservoir up at this site here. And then in terms -- 19 MR. COMMISSIONER: It would be preferable, 20 Mr. McDonald -- 21 THE WITNESS: Yes? 22 MR. COMMISSIONER: -- if you would use the 23 name associated with the reservoir - 24 THE WITNESS: All right. 25 MR. COMMISSIONER: -- and that way people can

1 coordinate it -- 2 THE WITNESS: Okay. 3 MR. COMMISSIONER: -- later on. 4 THE WITNESS: This is called Fairview 5 Underground -- Fairview Underground Reservoir. It's in 6 Fairview Heights. It's a -- a subdivision to the north of 7 the community. 8 And I mentioned the wat -- the underground 9 reservoir at 114th Street. The other major facility within 10 the city is the Sewage Treatment Plant, which is located in 11 here and it's just immediately north of the bypass before you 12 go onto the bridge going on 16 Highway. 13 Those are the so called major features and we 14 get into them a little more detail. Perhaps, Mr. Russell, if 15 you wish we could just have a bit of a view of the -- of the 16 main source. 17 The North Saskatchewan River and this is taken 18 across from the 16 Highway bridge and the sewage treatment 19 plant is in this area up here. And then if we take a look at 20 another photo, looking downstream -- 21 22 CONTINUED BY MR. JAMES RUSSELL: 23 Q: Which island is that? 24 A: That is called Finlayson Island. 25 Q: Hmm hmm.

1 A: It's a very large island. 2 Q: You're looking down here from the -- the 3 bridge. Which bridge? 4 A: This would be the Highway Bridge, the 5 number 16 Highway -- 6 Q: 16 Highway Bridge at Finlayson Island? 7 A: Yes. 8 Q: And the -- my understanding is that 9 the -- the surface water plant is to the left hand side of 10 that island as you're looking down? 11 A: That's right. In terms of the river, 12 because the river's an important aspect to the city's water 13 and waste water systems, this North Saskatchewan River of 14 course headwaters in the Rockies, nor -- upstream of 15 Edmonton. 16 It is a very major river. It is controlled by 17 reservoirs. It's -- 18 Q: Where -- where are these reservoirs 19 situated? 20 A: North of Edmonton, Brazeau Reservoir. 21 I'm sorry, west of Edmonton. 22 Q: So the -- 23 A: On the upper -- 24 Q: -- those reservoirs control the volume 25 flow in the river?

1 A: They're -- they control the rate of flow 2 and they can have some impact on the volume as well, yes. 3 Q: And who is -- who's in control of those 4 reservoirs and establishes the -- the rate of flow in the 5 river? 6 A: The rate of flow in the North 7 Saskatchewan River is essentially controlled by the Alberta 8 Government I believe. There is a -- an arrangement for 9 interprovincial water portioning under the Prairie Provinces 10 Water Board. 11 So there is a minimum flow requirement 12 required at the Alberta/Saskatchewan border. 13 Q: So can you give us in detail, some of the 14 general characteristics of this water source? 15 A: Well, the -- the water source is -- if we 16 look at the flow regime, the water flow -- 17 Q: What is the source of this graph and 18 these figures? 19 A: These figures are based on -- on flow 20 data acquired for the Edmonton station and also on flow data 21 acquired through Water Survey of Canada for the Deer Creek 22 station. 23 The Deer Creek Station Monitoring Station is 24 located very near the Alberta/Saskatchewan border. It is 25 approximately one hundred and forty (140) kilometres upstream

1 of North Battleford. 2 And I guess a major characteristic of this 3 river is that we do get peak flows occurring in the 4 summertime, in the July -- or June/July period, which is 5 normally a result of snow melt in the mountains in -- in 6 Alberta. 7 Q: And can you give us some statistics on 8 the -- the seasonal variations in the flow rates? 9 A: I don't have those at hand but if -- they 10 can vary quite a bit, up to eight hundred (800) and above 11 cubic metres a second. Typical low flows, base flows, are a 12 little over a hundred (100) cubic metres per second, which is 13 a rather substantial water flow. 14 Q: Is the -- is the -- the significant 15 variation you're talking about here, that is in the summer 16 months, correct? 17 A: That's when the flows tend to peak, yes. 18 Q: Do they -- are there any significant 19 variations at any other time of the year? 20 A: The only other variations that would tend 21 to occur would be heavy precipitation events, which would 22 cause runoff, because it's a rather large watershed -- 23 Q: Right? 24 A: -- and if there's extensive precipitation 25 and attendant runoff, this would impact on the water flow.

1 We do have some water quality data but I don't 2 know, do you want to show it at this time, Mr. Russell? 3 Q: Well, perhaps you can give us your 4 knowledge of -- of what you know about the specific qualities 5 of the water coming down the river? 6 A: Well, the water -- do you want me to 7 show numbers or -- 8 Q: If you have them, by all means. 9 A: Well, we did have them somewhere. 10 Where's that next -- okay, is that visible to -- 11 Q: I believe so. 12 A: Okay. There are a number of parameters 13 in which you use assess water quality, and these include both 14 inorganic types of materials and organic types of materials, 15 and biological organisms. 16 These numbers indicate that the -- basically 17 the river water quality as a -- is only moderately salinised. 18 It is relatively low in terms of Saskatchewan context. 19 Q: Can you tell us what we're looking at 20 here, first of all, and the source of this information? 21 A: The source of this information is based 22 on data that the city collected during their monitoring 23 programs on the river from the intake of the Number 2 Water 24 Plant. 25 Q: Over what period of time would that be?

1 A: December '96 to December 2000. Just 2 basically, some of the dissolved salts that we would be 3 interested in are things like sulphate and bicarbonate, 4 sodium, calcium, magnesium, which -- potassium, chloride. 5 Those are what we call dissolved salts. 6 Q: And when you say we would be interested 7 in, who are you referring to there? 8 A: I'm referring to water quality people and 9 treatment people, and users of the water. 10 Q: And why would you be particularly 11 interested in those salts? 12 A: The dissolved salts can have an impact on 13 uses of the water, whether it's for domestic, industrial, or 14 other users. 15 Q: And can it also have an impact on the 16 treatment process that is required to treat the water? 17 A: It can if you're looking to remove or 18 reduce certain of the dissolved salts. 19 Q: Okay. 20 A: Now, we have other constituents that are 21 normally associated with the organic or -- and/or nutrient 22 aspects of the water. We have one (1) called the BOD which 23 is really a measure of the amount of biodegradable organic 24 material. 25 Q: Right?

1 A: BOD stands for Biochemical Oxygen Demand, 2 but is often referred to as BOD. 3 Q: And what is the significance of that? 4 A: The BOD in terms of organic material, 5 biodegradable organic material, can have an impact on the dis 6 -- dissolved oxygen regime of the water. 7 If -- if the number is -- is too high, then 8 organisms that will try and assimilate or degrade this 9 material may use up more oxygen than the river is able to 10 provide. 11 And so that's of importance, particularly to 12 aquatic life. 13 Q: Right. And it would also be important in 14 terms of treatment of the water? 15 A: It would have an impact on water 16 treatment as well, yes. We have other constituents such as 17 dissolved organic carbon, which is simply that. And it 18 normally relates to carbon that can be degraded. 19 And then we get into the -- what we often 20 refer to as the nutrient species, such as nitrogen 21 phosphorous and I -- I'll equate -- equate nutrients to say 22 fertilizing impact. 23 Ammonia is also significant in -- in waters 24 because of its potential toxicity to aquatic organisms, 25 fish -- some fish.

1 We also measure some of the physical 2 attributes of the water and -- and these will include things 3 like total suspended solids and these are really materials 4 that are suspended in the water and they can be of organic or 5 in -- or an inert thing. 6 And then we have some measurements here on 7 indicator bacteria, such as the coliform group, total 8 coliform, fecal coliform and fecal streptococchi. 9 Q: So the parameters we're looking at in 10 this summary of the role of surface water chemistry -- 11 A: Yes. 12 Q: -- these -- these are results of sampling 13 that the city has done -- 14 A: Over -- 15 Q: -- over a period of time? 16 A: -- yes. 17 Q: And these are the constituents that they 18 have found to be in the river? 19 A: These are measurements that were made, 20 yes. 21 Q: Okay. Is this -- is this particularly 22 difficult water to deal with, in terms of treatment? 23 A: This water is -- is -- is quite good 24 quality in terms of a number of factors, for example, the 25 dissolved salt levels are -- are very good for many uses.

1 Nutrient levels are -- and organic levels are 2 also reasonable and -- and shouldn't cause too much 3 difficulty. 4 The big issue, I think in terms of the North 5 Saskatchewan River, is that it does become very turbid. And 6 that is it gets quite muddy at times with high flows. 7 Q: That's right, I suspect we're going to be 8 talking a lot about turbidity during the course of this 9 Hearing -- 10 A: Yes. 11 Q: -- perhaps you can give us a 12 definition -- 13 A: Well -- 14 Q: -- definition that we can use at this 15 stage? 16 A: -- turbidity by -- by definition is 17 really a measurement of the clarity of water. And it's a 18 measurement that's been done over a great number of years and 19 used in water treatment for a great number of years. 20 The instrumentation used to measure turbidity 21 has -- has changed and improved. Right now it really 22 measures the light scatter at a ninety (90) degree angle. 23 But I think the important thing is -- is that 24 turbidity really reflects the clarity of water. And if you 25 have a very clear water, for example, in the beaker or in

1 your glass, you would have a very low -- low turbidity. 2 If it gets very dark and turbid where you have 3 trouble penetrating light, then it will have a very high 4 turbidity. And these numbers can range, I think the river 5 turbidity has increased, for example, up to say sixteen 6 hundred (1600) -- 7 Q: Now you -- when you use these figures, 8 I -- I believe the turbidity measurement is an NTU; is that 9 correct? 10 A: An F -- yeah, it's called an NTU and it's 11 a unit of measurement and it's a relative -- well I should 12 say, it's an absolute measurement, but there's nothing 13 associated with an NTU, you can't go count NTUs in the water. 14 It's just a relative -- a relative 15 measurement. 16 Q: So with -- but the lower the NTU level 17 the clearer the water is? 18 A: That is right. 19 Q: And in terms of -- in terms of turbidity, 20 are there -- in this river here at North Battleford, are 21 there significant seasonal variations? 22 A: You can get seasonal variations. In the 23 wintertime the turbidity levels are -- are normally 24 relatively low and reasonably constant because of the ice 25 cover and the relatively low flow.

1 During open water where you're getting runoff 2 from agricultural or urban or other sources, carrying erosion 3 products into the water, you can get increases in turbidity. 4 You can also get increases in turbidity during extreme flow 5 events because it may -- the flow may be sufficient to re- 6 suspend some of the settle material that's on the bottom of 7 the water -- of the river. 8 Q: And what would be an extreme -- what -- 9 what are extreme flow events? 10 A: Well, I would think that extreme flows 11 would probably be classed in the order of say eight hundred 12 (800) cubic metres per second. 13 Q: And what would be cause of those extreme 14 flow events? 15 A: Well, normally those unregulated flows 16 would be result of extreme precipitation events. 17 Q: And would tend to occur what time of the 18 year? 19 A: Well, I don't -- I'm not a meteorologist 20 but certainly you can get heavy precipitation in the spring, 21 June, July, it's not uncommon. 22 Q: Okay. Is there anything else you think 23 we could usefully say that would be pertinent to the 24 characteristics of this water source? 25 A: A couple of other things that are -- it

1 does carry a very significant sediment load, as I mentioned. 2 And it varies throughout the year. 3 Q: What -- what's the content of that 4 sediment load? 5 A: A lot of it would be very fine silts. 6 But they're also very fine sands that are carried. And we do 7 have, based on information associated with a bridge 8 construction, very deep, luvial beds, very fine sands in the 9 North Battleford area. A lot of the sands seem to get 10 deposited here. 11 Q: Which bridge construction was that? 12 A: The new bridge in the number 16 highway. 13 Q: Okay. And when did that occur? 14 A: Well it's under construction now but -- 15 Q: Oh, I see - 16 A: -- we had access to some test 17 information. 18 Q: I see, okay. Anything else about the 19 source? 20 A: No. I guess historically the river used 21 to have -- or suffer from periodic problems that resulted 22 from the discharge of industrial waste water, particularly in 23 the Alberta, Sherwood Park Complex. Periodic -- were causal 24 agents for taste and odour -- odour problems and it did cause 25 a lot of discomfort with Saskatchewan water users.

1 Q: You say traditionally, is that problem 2 exist -- 3 A: No, I said -- well, I did -- it did cause 4 a problem. That problem does not exist at this time. 5 Measures have been taken in Alberta to alleviate it. 6 Q: I see. 7 A: But that was one (1) of the major quality 8 issues that used to be associated with the North Saskatchewan 9 River. I just -- just on that, in terms of water users, 10 which may be of interest, I guess in urban municipalities the 11 prime users within Saskatchewan would be Lloydminster, North 12 Battleford and the City of Prince Albert. 13 Q: And by in large, they're dealing with the 14 same water source and the same quality of raw water? 15 A: By and large they are, yes. 16 Q: Okay. Do you have figure, before we go 17 any further, do you have figures on the -- on the population 18 of North Battleford and the -- the number of people who are 19 served by this system? 20 A: The number I've been using is fifteen 21 thousand (15,000). 22 Q: Thank you. Could we -- could we now turn 23 to the -- the surface water treatment plant and take a -- a 24 general look at that? Just in terms of identifying this 25 plant, my understanding, Mr. McDonald, is that it's -- it

1 might be called one (1) of several things in the 2 documentation. It can sometimes be the surface water 3 treatment plant, it can sometimes be the Number Two (2) Plant 4 or it can sometimes be the F.E. Holliday treatment plant. 5 Is that correct? 6 A: That is right. 7 Q: And we're talking about the same place 8 whenever -- 9 A: That's right. 10 Q: -- one (1) of those names comes up? 11 A: The name on the building is the F.E. 12 Holliday Water Treatment Plant. 13 Q: Okay. Could you -- could you point out 14 to us the -- the physical components, the building and 15 equipment in use? 16 A: Okay. I -- just before we do that, maybe 17 just -- I don't know, is this going to show? A bit of a 18 setting relative to the river -- 19 Q: Right. 20 A: -- we could show some pictures. This a 21 side of the water treatment plant and this is the intake pump 22 house. The North Saskatchewan River is here and this is a 23 steel truss -- the old bridge -- 24 Q: So we're looking west? 25 A: We are looking upstream --

1 Q: We're looking upstream. 2 A: Yes. 3 Q: And that's the old iron bridge? 4 A: That's the old iron bridge. 5 Q: Okay. Where is the -- where is the water 6 intake in relation to that pump house? 7 A: Okay. Let's try this one (1) then, 8 here's the side of the pump house and this is the intake at 9 this point here. 10 Q: Right. I see it's on the surface. Is it 11 always on the surface? 12 A: This is an ice barrier, a concrete 13 structure, the water actually comes in from this side, 14 underneath. And, depending on the river flow, this could 15 well be flooded as well and you wouldn't see it. 16 Q: Right. But the intake itself is 17 submerged at all times? 18 A: It is. Perhaps just some exterior views 19 of the plant, this is, again, looking towards the river. 20 Q: So we're looking across the river there 21 to the Town of Battleford? 22 A: This is the Town of Battleford here, the 23 steel bridge that I mentioned is at this point here, there is 24 a hill up here from which this site was taken -- this plant 25 was -- shot was taken. Just to give you some context.

1 And then looking at sort of the front end of 2 the building, this is the front end at this side here, the 3 west side, the river in the background. 4 Q: Now, I understand that this particular 5 building has undergone some construction work from time to 6 time. 7 A: Yes. 8 Q: Are you able to point out to us at least 9 externally the -- the original parts and the subsequent 10 additions? 11 A: Well, probably the best photo for the 12 original part is here, this part in here is essentially the 13 original part. 14 Q: So which side of the building is that, is 15 that -- 16 A: This would be on the east side. 17 Q: -- east -- the east side of the building? 18 A: Yes. 19 Q: And that would have contained what, how 20 would we identify that side? 21 A: I can show this in some further -- 22 Q: Okay. 23 A: -- slides. I'm just wondering, Mr. 24 Russell, before we get into -- unless you want to look at the 25 structural, before we get into sort of the components of the

1 plant, whether it might not be useful to discuss sort of the 2 basic water treatment process trains. 3 Q: If that's the -- if that's going to be 4 the most -- the easiest way for you to explain it, that is -- 5 that's certainly fine with me. You -- you want to talk about 6 the -- the basic processes involved in the treatment of 7 water? 8 A: I -- I just thought it might be -- 9 Q: Okay. 10 A: -- might be useful. 11 Q: Please proceed. 12 MR. COMMISSIONER: I wonder, would it be 13 reasonable to the extent we're going to take a fifteen (15) 14 minute morning break, we can do it now, we can do it at 15 11:15; what is convenient? I don't want to interrupt -- 16 MR. JAMES RUSSELL: I think that the -- the 17 treatment processes would probably take quite a while, we 18 need to spend some time in them so I think, if we're going to 19 take a break, Mr. Commissioner, it probably would be wise to 20 do so now. 21 MR. COMMISSIONER: All right. Then we will 22 adjourn for the morning break for fifteen (15) minutes, 23 resuming at 11:15. 24 25 --- Upon recessing at 11:00 a.m.

1 --- Upon resuming at 11:18 a.m. 2 3 MR. COMMISSIONER: Ladies and gentlemen, if 4 you can take your seats please, we will continue. 5 All right, will you proceed, Mr. Russell, 6 please? 7 MR. JAMES RUSSELL: Thank you, Mr. 8 Commissioner. 9 10 CONTINUED BY MR. JAMES RUSSELL: 11 Q: Mr. McDonald, before you get into the 12 treatment processes, I know we're going to come to that 13 shortly. But you may be intending to deal with this later on 14 in your presentation. I think if would be useful for the 15 Commission or legal counsel to have some idea about the -- 16 the history of this plant and the way it has changed over the 17 years, from a view of letting us know what it -- you know, 18 what it can do now that it once couldn't do. 19 If you intend to come to that later, I mean, 20 that's fine. I don't -- I don't really mind where in your 21 presentation that comes, but if you'd like to get that out of 22 the way now, that could also be helpful? 23 A: Well, I can give you an overview of the 24 building history in terms of components. The only issue in 25 terms of looking at the water treatment process, because then

1 people might be able to rate -- relate to what part of the 2 process trained -- 3 Q: I understand? 4 A: -- these pliec -- pieces fall. 5 Q: Understood. Okay. If that's the best 6 way to proceed, if you feel that, then by all means. Can you 7 give us then, generally speaking, what the -- the treatment 8 processes used at the surface water plant are and what's 9 involved in each? 10 A: Okay. We have some schematics and I'll 11 go to -- these are -- are fairly general, but typically in 12 surface water treatment, we have a number of barriers, 13 treatment barriers, that we like to use, and we're showing in 14 a schematic form some of those treatment barriers now. 15 One (1) of the primary treatment components in 16 surface water treatment is called coagulation. And if I 17 could just maybe spend a little bit discussing what 18 coagulation really is. 19 The materials that are suspended in water and 20 may get in to a water intake can be quite varied, but often 21 they will contain very, very fine materials. So many times 22 these are called colloids or very fine materials. These 23 materials have characteristics which tend to make them repel 24 each other or keep separated. 25 So that is very difficult physically to bring

1 them together so that they can settle out. I guess the other 2 aspect is that a lot of these very, very find materials, the 3 plane settling time to get rid of them is so extensive that 4 it's not feasible. 5 So we have to introduce some means of trying 6 to get rid of these fine, fine materials. 7 Q: And is -- is the reason that the 8 materials repel each other because of the way they're 9 charged? 10 A: You could use that analogy that they're 11 somewhat negatively charged, I guess. 12 Q: Is that -- is that an inaccurate analogy 13 from your perspective? 14 A: Well, I think there's things called 15 Vanverwaals forces and various things, but I think it's a 16 reasonable analogy to use. 17 One (1) of the purposes of coagulation is 18 really to destabilize the characteristics of these very fine 19 particles, so that they can agglomerate and join together and 20 become larger particles. 21 And when they're larger particles they tend to 22 settle better and are more easily removed. So this is one 23 (1) of the purposes of coagulation. 24 A common chemical used for coagulation is 25 called alum, which is really aluminum sulphate with some

1 water molecules attached to it. 2 By the nature of the aluminum sulphate 3 chemistry, it is able to neutralize or destabilize these 4 particles so that they can be brought together and in fact 5 form a very small, what we call a micro floc or pinpoint 6 floc. 7 Q: We'll come to floc in a moment, but -- 8 A: That's right. So as I say, alum is a 9 very common coagulant. There are some proprietary coagulants 10 also on the market. These can be such products as a poly 11 aluminum chloride product, or they can be certain polymer 12 products, which are -- 13 Q: So -- 14 A: -- synthetic products. 15 Q: -- is the sole purpose of coagulation 16 then agglomeration or are there other reasons for that? 17 A: The sole purpose of coagulation is to 18 condition the water so it can be more readily settled and 19 filtered out. 20 Q: And primarily that is done through 21 agglomeration. Is anything else done that helps it to settle 22 out through coagulation? 23 A: Well then we -- we get into what we call 24 a coag -- a flocculation process. 25 Q: Right. But I -- just the -- okay.

1 A: But in -- in coagulation we are 2 destabilizing the very fine materials, we are forming a very 3 small floc material, which is a combination of some of these 4 fine particles. 5 Q: Okay. 6 A: Now flocculation -- 7 Q: This is the -- is this sequential? 8 A: -- it is normally sequential, yes. 9 Flocculation is simply the process of taking these very fine 10 particles created by coagulation and making them into larger 11 particles. 12 And to do this it's normally done in a -- a 13 mixing situation, so you have the intimate contact between 14 these particles and then you get a meshing of other 15 particles. 16 So you build up a rather visible -- visible to 17 the eye -- 18 Q: Right. 19 A: -- floc that can be subsequently filtered 20 or settled and -- and filtered. 21 So these are sort of major front end 22 components, pre-treatment components -- 23 Q: So once again -- 24 A: -- to surface water, yes. 25 Q: -- the purpose of the flocculation is to

1 increase the size of the particles so that -- 2 A: It can be better settled and -- and 3 better filtered. 4 Q: Right. 5 A: I should maybe point out in -- in some 6 cases you may have pre-settling before you even add any 7 chemicals. 8 Q: When you say in some cases, do you mean 9 in some treatment facilities? 10 A: In some treatment facilities and some 11 installations they may have either pre-sedimentation or they 12 may utilize what we call off stream storage. 13 Q: And what are the advantages to that? 14 A: Well often the off stream storage is 15 simply a matter of water quantity. Off stream storage is 16 sometimes necessary when the water supply flow is 17 intermittent or not continuous. 18 So the idea with off stream storage is to 19 capture the water and store it for use when the normal supply 20 is not adequate. 21 Q: Right. 22 A: We also can have pre-sedimentation which 23 is a bit of a security issue as well, but also there would be 24 some settling, particularly of the grosser settleable 25 materials in a reservoir, and then it would be delivered to

1 the treatment plant. 2 Q: And if you have that pre-sedimentation 3 does that make the water easier to deal with once it enters 4 the plant? 5 A: It certainly can in terms of high 6 turbidity events. 7 Q: Okay. 8 A: You don't have to deal with it -- 9 Q: Right. 10 A: -- you get a more uniform quality to deal 11 with. 12 Q: Right. But on my understanding at North 13 Battleford, we do not have pre-sediment -- 14 A: We do not have pre-sedimentation, no. 15 The second component after you get this flag -- flocculation, 16 coagulation/flocculation stage, is to normally gravity settle 17 the material out. 18 And this can be done in different types of 19 clarifiers. There's simple gravity clarifiers and there's a 20 number of proprietary clarifiers and a number of variations. 21 But the idea is to just physically allow the settlementation 22 of these materials. 23 Then typically, from the clarification stage, 24 you would go onto a filtration stage which is typically a -- 25 something that is using a granular media. And this can be

1 sands or coal such as anthracite. 2 These are fairly fine media materials and the 3 water has to percolate through the sands and remaining 4 materials that may be left over from the clarification 5 process are retained on and within these filtering units. 6 Q: So these would have been materials that, 7 in the clarification process, were not settled out as a 8 result of gravity? 9 A: That's right. But they would have 10 been -- 11 Q: They remain suspended in the water? 12 A: They remain suspended, yes. 13 Q: And the filter is intended to -- to pick 14 up those -- 15 A: The filter is intended to polish the 16 water and provide an effective barrier for the control of -- 17 of suspended materials. Again, another important barrier, of 18 course, is disinfection of the water. Disinfection can occur 19 at say the head end of a plant. It can also occur after the 20 filtration phase. 21 This process diagram shows that after the 22 filtration phase, and they're a number of means that can be 23 used. Chlorine is a very common chemical that is used as a 24 disinfectant. You can use ultra violet, you can use ozone, I 25 mean you can use ozone upstream as well.

1 We can, if we're interested in certain 2 byproducts that may be formed, go into a process call 3 chloramination. I don't know if you want to describe that 4 or -- 5 Q: Only if it's relevant to the treatment 6 process as you're -- 7 A: I think -- I think in North Battleford 8 it's not necessarily relevant. 9 Q: In North Battleford the chlorination 10 process, the -- 11 A: Yes. 12 Q: -- science of that is not, I take it, 13 where you have it here in your -- 14 A: It presently is not. It is presently, 15 essentially -- prior to the flocculation, if we use that 16 analogy, yes. 17 Q: Right. This is -- when you say presently 18 you mean back in -- 19 A: In March -- 20 Q: -- and previous use? 21 A: Yes. 22 Q: Okay. 23 A: A couple of other things -- okay, I did 24 that -- that may occur in water treatment and I want you to 25 appreciate that particularly in Saskatchewan, we get a great

1 variation of -- of surface waters that act as municipal water 2 supplies. And so quite often we have to have variations in 3 terms of the treatment process or additional steps in the 4 treatment process to address specific problems. 5 One (1) of the issues that we don't show here 6 are -- are taste and odour control, for example. And we can 7 have water supplies that are subject to taste and odour 8 generation problems. Typically these may be surface water 9 bodies or reservoirs that are able to produce and -- and grow 10 quite a bit of algae, for example, which can cause taste and 11 odour generation. 12 Q: Any relation to North Battleford? 13 A: No, there is none in this case. 14 Q: In the surface water? 15 A: In the surface water the taste and odour 16 component is relatively minor. North Battleford does use a 17 preoxident, which we'll get into later but -- 18 Q: Right. 19 A: The other thing that can happen is we can 20 do some pH adjustment or softening. We don't have many 21 softening plants but we can do that. And often we may use 22 lime or soda ash for that -- 23 Q: Right. 24 A: -- purpose. 25 Q: Now I think later we will be talking in

1 some detail -- 2 A: Okay. 3 Q: -- about the chemicals you use. 4 A: All right. Now that is normally a 5 treatment process that is used for relatively turbid waters 6 or waters that may have high turbidity. 7 Q: Would that, do you -- do you class -- do 8 you classify the North Saskatchewan River in that category? 9 A: During the summertime, particularly, yes. 10 Yes. There is a process that is used with relatively low 11 turbidity water and this is called direct filtration. Now, 12 it is somewhat similar except normally the clarification step 13 is missing and often what you might use as a coagulant are 14 products where you don't generate a large amount of floc, 15 these -- probably more like the proprietary chemicals or a 16 polyaluminum chloride. You may or may not go into a 17 flocculation stage and you'll certainly have a mixing stage 18 and then you would go directly onto a filter. 19 Q: So you're making -- in that -- in that 20 process, you -- you're primarily relying upon your filter to 21 remove -- 22 A: You are, yes. 23 Q: -- sediment? 24 A: Yes. And that -- and that can be used 25 and has been used.

1 Q: Can you show us how these processes 2 configure in relation to the North Battleford system? 3 A: Well, in term -- in terms of the North 4 Battleford system, we do have, of course, the raw water 5 source here coming in and we showed you that structure -- 6 Q: Right. 7 A: -- we'll get back to that a little later. 8 Q: You don't -- do you have an actual 9 schematic for North Battleford or are you just -- 10 A: Yeah, I do actually, if we -- like to go 11 down to this here, I wonder if I can get it, yes. 12 Okay. In North Battleford we have the North 13 Saskatchewan River which isn't quite shaped like that, but 14 schematically -- schematically it's like that and the water 15 flows by gravity into a raw water well and we saw that 16 adjacent to the -- to the plant. 17 From there, the water is pumped through raw 18 water pumps, they have sand separator facilities, then the 19 water receives chemical treatment; here they're using 20 potassium permanganate. Potassium permanganate is used as an 21 oxidant and it can be helpful for control of taste -- 22 Q: Right. 23 A: -- and odours -- 24 Q: Oh, I'm going to ask you some detailed 25 questions --

1 A: Okay. 2 Q: -- about those chemicals later so -- 3 A: All right. 4 Q: -- if you could just give us this general 5 flow -- 6 A: So this is sort of the coagulation stage 7 here, okay, we got prechlorination, we have the flocculation 8 and clarification stage is combined in the solids contact 9 unit -- 10 Q: What about sedimentation? 11 A: Yes, the clarification, sedimentation, 12 yes. 13 Q: So you -- you have three (3) processes in 14 effect taking place in the solids contact unit? 15 A: We have initial coagulation somewhat in 16 the pipeline itself, we have some additional coagulation, but 17 a lot of flocculation and then sedimentation in the solids 18 contact unit. From the solids contact unit, then it -- it 19 flows by gravity onto two (2) filter sections and from there 20 it is stored in clear wells and pumped to the distribution 21 system. 22 Q: Right. Could you show us the -- how that 23 process fits into the actual configuration of the plant 24 building and how the -- how the water flow occurs through 25 that building to achieve the respective processes you've

1 outlined for us now? 2 A: Well, if we go to the -- I wonder if this 3 might not be a bad time to just talk about the history a 4 little bit? 5 Q: Go ahead. 6 A: The original plant was constructed, I 7 think, for the Department of Public Works, the Government of 8 Saskatchewan, in about 1950 and this included that eastern 9 section of the plant, we have -- let's see, maybe I can get 10 some labels in here. 11 We had a flocculator sand separator system in 12 here, which is proprietary unit, they had a clarification 13 basin here which was called a hydrotreater and, again, it was 14 a proprietary unit and from that the water flowed on to two 15 (2) granular filters. 16 Underneath this, the filters -- there's a 17 clear well or storage reservoir and there were pumps situated 18 here. Also associated with that construction, there was an 19 office and -- and a lab area in this thing here. 20 Q: Is it my -- it's my understanding that 21 those two (2) filters, 1 and 2, they still exist and are 22 still in use? 23 A: They are, absolutely, yes. 24 Q: And in the old building, I take it there 25 wouldn't have been -- in the original building, sorry, there

1 wouldn't have been a pumphouse? 2 A: There which? 3 Q: Was there a pumphouse in the old 4 building? 5 A: An intake, yes. 6 Q: It was an intake? 7 A: Yes. Yes. 8 Q: Okay. And the old -- the old building, 9 you say the hydrotreater -- 10 A: Yes. 11 Q: -- what purpose did it fulfill? 12 A: It was a -- primarily a clarifier. 13 Q: Okay. So essentially, even in the 14 original building, the same processes were being used? 15 A: They have the same fundamental processes, 16 yes. 17 Q: Okay. 18 A: Yes. 19 20 (BRIEF PAUSE) 21 22 That was the original plan. In about 1981 23 there was an expansion, and it was a major physical expansion 24 to the building itself. At that time they did a number of 25 things that I think the key components was that they

1 abandoned the hydrotreater. There were some problems. 2 They installed this infilco accelatory unit 3 which is a solids contact unit. They installed two (2) 4 additional gravity filters, plus the reservoir down in here. 5 So the process in 1981 essentially included 6 the raw water coming in with -- with chemicals added, coming 7 into the Solids Contact Unit. And from the Solids Contact 8 Unit it was distributed to the new filters here and to the 9 old -- old filters here. 10 Q: What did those -- what did those changes 11 enable the plant to do that it couldn't do before? 12 A: Well, it certainly increased the 13 filtration capacity of the plant in terms of hydraulic 14 capability or capacity or water quantity capacity. 15 Q: But essentially, then, it didn't change 16 the treatment process. It was a capacity issue? 17 A: The process was essen -- fundamentally 18 the same. 19 Q: I mean, for instance, there's the -- the 20 sediment -- the flocculation sedimentation process in the -- 21 in the Solids Contact Unit, is it different in any respect 22 from the way that it occurred within the hydrotreater? 23 A: Yes, a little bit, just because of the 24 nature of the -- of the physical equipment. 25 Q: Okay.

1 A: The accelator, I think -- and we'll get 2 into this a little more, but the Accelator was a -- a unit 3 that was intended to be able to have a higher capacity. That 4 is, by its name it was intended to accelerate the process. 5 Q: Right. 6 A: I think that's where it came from. Just 7 one (1) other aspect in terms of the 1989 work, there were 8 modifications to the intake, to the raw water pumphouse, and 9 also the filters 1 and 2 were changed. The media was changed 10 and new under-drains were put in. 11 So, in effect, these are the newest filters in 12 the old section of the plant. 13 Q: Are they filters 3 and 4, or 1 and 2? 14 A: These are 1 and 2 -- 1, 2, 3 and 4, and 15 we'll get into that. So that's basically the history of the 16 facility. 17 Q: So essentially, when those -- when the 18 media in those filters was replaced -- 19 A: Yes. 20 Q: -- they were in effect new filters of 21 equivalent to the -- the new -- the new filters that were put 22 in as part of the addition? 23 A: Yes, they were equivalent. As I said, 24 they're the most recent filters. 25

1 (BRIEF PAUSE) 2 3 Now, do you want me to go through the process? 4 Q: Well, I think it would be -- if you could 5 now. If you could show us in terms of the -- the way the 6 water flows through this -- this schematic, where the various 7 processes you described in the treatment actually take place? 8 A: Okay, just -- just let me sort of review 9 the major components of the water treatment plant. We have 10 the water intake here, which collects the water, and it goes 11 into this pumphouse here. There are sand separators. The 12 water is delivered into the Solids Contact Unit here, where 13 it is treated. Then it's separated and delivered into these 14 media filters, 3 and 4, 1 and 2 over here and from that it is 15 sent to the clear well storage and distribution. 16 So just -- so you go on that. 17 Q: So what are the -- what are the design 18 rate flows for the plant? What -- what's it's capacity? 19 A: We have set the design flow at a hundred 20 and twenty (120) litres per second. 21 Q: Per second? 22 A: Yes. 23 Q: And how did you -- how did you set it at 24 that level? 25 A: Well based on information and experience

1 at the plant, the solids contact unit is probably originally 2 designed I think for a hundred (100) litres per second, based 3 on -- on inform -- verbal information I received, I didn't 4 have any documentation. 5 The plant can be safely operated at a hundred 6 and twenty (120) in terms of hydraulic capacity of the solids 7 contact unit and the outflow rate is marginally increased of 8 course. 9 Q: And was it being operated at that 10 capacity prior to March of 2001? 11 A: It had been operated at that capacity and 12 I believe it had been operated at slightly higher capacities 13 in the past. 14 Q: Did that -- did that occur, to your 15 knowledge, on a consistent basis, or was it intermittent? 16 A: On a very high -- on the higher 17 capacities? 18 Q: Hmm hmm. 19 A: I believe it was intermittent. 20 Q: And what about at a hundred and twenty 21 (120), was that a regular -- 22 A: A hundred and twenty (120) appears to be 23 a very comfortable operating range. 24 Q: Okay. Where is the -- where is that 25 volume measured in terms of the --

1 A: Of the inflow? 2 Q: Yes. 3 A: It's on -- I'll have to stop this. There 4 is a -- an orifice meter on a raw water supply line -- 5 Q: Okay. 6 A: -- and that's where that flow rate is 7 measured. 8 Q: Is that in a tunnel underneath the ground 9 there? 10 A: It is in a tunnel, yes. 11 Q: Yes. And where are the -- where are the 12 flow rates adjusted? 13 A: Where are the flow rates adjusted? 14 Q: Yes. 15 A: Well they do have a -- a console, and 16 we'll show you the pictures of this. 17 Q: Okay. 18 A: Up here on -- opposite the filters. But 19 essentially the adjustment is by controlling a valve. 20 Q: And that's a manual exercise is it? 21 A: No, it's an automatic exercise, but 22 it's -- but it is by valve control rather than -- rather 23 than -- than specifically controlling the output -- 24 Q: Okay. 25 A: -- of the control by -- by head loss.

1 MR. COMMISSIONER: Control it by what? 2 THE WITNESS: By head loss. What happens 3 in -- with a pump, if you have to pump a greater pressure, 4 normally the output of the pump is decreased. 5 So by controlling or closing a valve part way, 6 you tend to increase the pressure and then the pump does not 7 produce as much. 8 9 CONTINUED BY MR. JAMES RUSSELL: 10 Q: And you're controlling those rates -- 11 well the operator would be controlling those rates in 12 accordance with the operator's assessment of what the city's 13 demand is at any one (1) time? 14 A: Up to a point, certainly I think the 15 rates would be controlled based on how your filters are 16 operating when you've got them both in operat -- both sets in 17 operation, or one (1) in operation. 18 Also I think in terms of how the treatment 19 process is functioning, if it's performing well they would 20 tend to go to a higher rate. And probably the water use 21 demands within the city would have some bearing as well. 22 Q: All right. If you -- I know you're going 23 to take us through the flow, but one (1) of the -- one (1) of 24 the significant aspects of this process is the ability to -- 25 to waste the water. I understand the terminology is to --

1 to -- to pump water to waste; is that correct in your 2 business? 3 A: There can be a couple points where you 4 may want to waste water. 5 Q: And what does -- what does that mean 6 essentially? 7 A: Well, really what it means is that you're 8 passing it through one (1) treatment component, and before 9 you allow it to go on to the next one (1), because of some 10 circumstance, you may want to waste that water or -- or get 11 rid of it. 12 Q: Then it goes -- that means it goes back 13 into the river? 14 A: It would be discharged back into the 15 waste water. 16 Q: So it's -- it's a way of avoiding the 17 plant of -- of unwanted water before it goes through the next 18 process? 19 A: That's true. 20 Q: Can you show us where in the -- in the 21 system here, there was an ability to -- to waste water? 22 A: There was but very difficult, ability to 23 waste water from the solids contact unit but what had to 24 happen is that you had to have filter 3 and 4 out of service. 25 And, in effect, discharge the waste from the solids contact

1 unit into filter 3 and 4 and then discharge it through the 2 normal waste discharge of filters 3 and 4. 3 Q: So in order to do that then you would not 4 be pumping water into the distribution system? Or would you 5 be using the other two (2) filters to do so? 6 A: Well, normally if you're discharging, if 7 you were going to be wasting out of the SCU, you wouldn't be 8 putting that on any filter system. 9 Q: Right. Okay. 10 A: The other point of -- 11 Q: When you say it's -- it was a 12 difficult -- was it not -- was it not part of the design 13 aspects of this plant to be able to do that? 14 A: I couldn't detect ready designed feature 15 to waste that but I can't really comment on the philosophy of 16 that design. I guess just one (1) other comment in terms 17 of -- of wasting, the old section filters did have the 18 ability to waste water after backwashing, before the filters 19 were reinstituted. 20 Q: That is filters 1 and 2? 21 A: Filters 1 and 2, yes. 22 Q: Filters 3 and 4, did they have that 23 ability? 24 A: No. 25 Q: Any other places in the -- in the system

1 where there was the ability to pump the waste? 2 A: In terms of a treatment -- well, I guess 3 in terms of waste, there's always a waste associated with the 4 solids contact unit where there's sediment that has to be 5 discharged. And there's also waste associated with the 6 filters in terms of the cleaning of the filters. 7 But in terms of, sort of inhibiting before a 8 process -- a next process step or next barrier, no, -- 9 Q: So for instance, once the water got into 10 the clear wells it was not then possible to pump that water 11 back out into the river? 12 A: Well it may have been possible, the 13 pumping system wasn't -- 14 Q: Wasn't there? 15 A: -- wasn't set up for that, no. 16 Q: Okay. So can you lead us through the -- 17 the pipeline, as it were, and show us where the processes 18 took place? 19 A: Okay. This schematically shows the water 20 coming in through the intake into that pump well that we 21 described. And from the pump well it then goes into the 22 solids contact unit. 23 Q: And just to repeat again, what -- what 24 occurs in the solids contact unit? 25 A: Solids contact unit is where most of the

1 flocculation and sedimentation occur. 2 Q: All right. 3 A: This slide -- or this picture shows the 4 chemical additions that were made to the raw water supply 5 pipe. 6 Q: Could you tell us again why it is each of 7 these chemicals is used? First of all, can we start with the 8 alum. Can you tell us why that is -- 9 A: Well the alum would be the primary 10 coagulant. 11 Q: Is that added in a liquid form or a solid 12 form? 13 A: That is purchased and added as a liquid 14 alum. 15 Q: Okay. And the potassium permanganate 16 which is -- what -- what's the purpose of that? 17 A: The potassium permanganate can be useful 18 as a preoxident to help oxidize or breakdown some organic 19 materials and thereby reduce taste and odour measures. 20 Q: So that -- that's it's primary function, 21 to make the water more palatable? 22 A: That would be one (1) of it's functions, 23 yes. In this case I think that would be it's function, 24 period. 25 Q: Okay.

1 A: Potassium permanganate does have a slight 2 disinfecting power but probably not in the dosages used here. 3 Q: Okay. What about the aluminex? 4 A: The aluminex is a proprietary material. 5 It is a coagulant. It is a poly aluminium chloride material 6 with some other polymer coagulants, with some other polymer 7 materials attached to it. 8 Q: So does the process then involve adding 9 two (2) coagulants at that stage? 10 A: They have done that on occasion, yes. 11 Q: Do they do that all of the time? 12 A: I'm not -- it would be prior -- 13 Q: Today? 14 A: Now? Or then? 15 Q: Then. 16 A: Then? No, there were times when they 17 didn't do it, as I understand. 18 Q: How did -- how was that decision made? 19 Do you know? As to when it should be used and when it 20 shouldn't be used? 21 A: I would presume it was made by the 22 operating staff. 23 Q: Okay. But you have no -- you have no 24 knowledge of -- of when the aluminex was being used and when 25 it wasn't?

1 A: Well, as I understand it, the information 2 that I learned is that they tended to use aluminex more in 3 the summertime than in the wintertime and relied mostly on 4 alum during the wintertime. 5 Q: Okay. But alum was in continuous use 6 then? 7 A: Alum was a continuous coagulant, yes. 8 Q: Okay. And all three (3) of those 9 chemicals, were they added before that first bend in the 10 pipe? 11 A: Yeah, this is a schematic, there are a 12 number of elbows -- 13 Q: Yeah. 14 A: -- as it comes out of the raw water 15 pumping system, but the pipe that goes into the solids 16 contact unit from the raw water pump house is actually just 17 outside the building and buried -- 18 Q: Right -- right. 19 A: -- so it goes across and out through that 20 way. 21 Q: When the chemicals, when aluminex, alum 22 and potassium permanganate are added at that stage, is there 23 any mixing that goes on? 24 A: There'd only be the normal mixing 25 associated with flow in the pipe and any elbows.

1 Q: Okay. Do those chemical react with each 2 other in any way? 3 A: Not particularly, the permanganate I 4 guess could break down into some manganese dioxide which 5 could affect the alum because it would try to coagulate it. 6 Q: You mean that might make the -- the alum 7 less effective -- 8 A: Not really, no. 9 Q: Okay. 10 A: It may, in fact, make the coagulation 11 process better. 12 Q: Is the -- how is the dosage calculated 13 and controlled at that point? 14 A: Well, in terms of permanganate, the -- 15 one (1) of the ways to control the dosage is, in fact, of 16 colour. Potassium permanganate, and you may be familiar with 17 it, but when it's added to water it's a very deep purple to 18 colour and, if you add it in low dosages, it can form a very 19 pink colour so one (1) of the control mechanisms is to add 20 enough so it loses its -- just loses its pink colour at a 21 point that you want it to lose its pink colour because, when 22 it's lost its pink colour, then its oxidizing properties have 23 diminished. 24 Q: Okay. So does that involve any kind of 25 visual inspection?

1 A: That's right, they can observe that, for 2 example, in the solids contact unit. 3 Q: And then, based upon that visual 4 inspection, they would -- they would adjust the quantity -- 5 A: They could adjust it accordingly, yes. 6 Q: All right, okay. What's the -- what is 7 the reason for adding those chemicals at that stage in the 8 process so early on; is there any significance to that? 9 A: Well, typically, one (1) of the normal 10 components with coagulation is that you like to have a very 11 intimate contact between the chemical, the coagulant that 12 you're adding and the -- and the particles and often this is 13 done by a process called rapid mixing where they have a rapid 14 mix section which really brings these ingredients, the 15 chemicals and the particles, into very close contact. 16 Q: But that doesn't occur here? 17 A: Not very well, no. 18 Q: So is there any reason then for adding 19 the alum right at the beginning for instance? 20 A: Well, normally you would add alum 21 upstream -- 22 Q: Is it a -- 23 A: -- to maximize some reaction. 24 Q: Is it a -- is it a timing issue, is it 25 a --

1 A: Well, I can't really comment why it was 2 added then, but there would be some time benefit in terms of 3 assisting the reaction, yes. 4 Q: How about -- 5 MR. COMMISSIONER: I'm not clear, Mr. 6 McDonald -- 7 THE WITNESS: Yeah. 8 MR. COMMISSIONER: -- on where these things 9 are being added at the moment. I understand the water is 10 coming through that underground pipe -- 11 THE WITNESS: That's right. 12 MR. COMMISSIONER: -- and then you're talking 13 about some stage the addition of chemicals and I'm just 14 not -- 15 THE WITNESS: Okay. 16 MR. COMMISSIONER: -- clear when this is 17 being done, how it's being done and who's measuring it or is 18 it computer controlled or how is it being done? 19 THE WITNESS: All right. The chemicals were 20 being added -- injected directly into that pipe at this point 21 here, up right there. 22 MR. COMMISSIONER: Okay. 23 THE WITNESS: And, in terms of the control, 24 the feeders were -- are -- are remote from where it's being 25 injected, but they were controlled by a feed control system

1 that utilized a timer and so there would be an injection over 2 a certain period of time based on a flow of water that was 3 passing through. 4 The other controls on the -- on -- on the feed 5 rates, of course, are the chemical feed pump settings that 6 can be adjusted as well. 7 MR. COMMISSIONER: And where are they at, the 8 chemical feed pumps? 9 THE WITNESS: The chemical feed pumps or in 10 the chemical room, except for the alum which is down below 11 and we'll show you that, we have a picture of that that we 12 can show you. 13 Q: Okay, thank you. 14 A: Okay. The other, if I can, the other 15 chemical, major chemical that's added prior to the SCU is 16 chlorine, and it's added just before the water enters the CU, 17 and that is generated from a gas chlorination process. 18 Within the SCU itself -- 19 Q: And what's the purpose of adding the 20 chlorine at that stage? 21 A: Well, it's primarily a disinfectant. 22 Q: But is there a reason to add the 23 disinfectant prior to its entry in the Solids Contact Unit? 24 A: There would be some advantage in terms of 25 controlling any biological growths in the Solids Contact unit

1 or in the filters itself. There's potentially another 2 advantage in adding chlorine at that time, is that -- in that 3 you may increase the contact time of the disinfectant and the 4 water before it goes out to distribution. 5 Q: So how is that dosage calculated and 6 controlled? 7 A: That dosage is essentially controlled by 8 the chlorine residual that's measured in the clear wells of 9 the water treatment plant. 10 Q: Okay. 11 A: The residual is an important requirement 12 in terms of disinfectant. 13 Q: No, and we're going to come to that 14 measurement in a moment. But that is what the operator is 15 looking at? He's looking at the chlorine residual -- 16 A: Yes. 17 Q: -- And he's going back and what, manually 18 adjusting the chlorine input, or is there some automatic way 19 to do that? How does that occur? 20 A: They can -- they can adjust the 21 rotameters on the chlorine feeders. 22 Q: They do that manually? 23 A: Yes, they can do that manually. 24 Q: Does the -- does the chlorine react with 25 the -- react with the other chemicals in any way at that

1 stage? 2 A: Not particularly, no. No. The other 3 chemicals that are added to the Solids Contact Unit are lime, 4 and there's also another polymer added. 5 Q: Right? 6 A: One (1) of the -- 7 Q: That's in solid form, both of them? 8 A: The lime is added as a powder. The 9 polymer is added as a liquid. 10 Q: Okay? 11 A: I shouldn't say -- the lime is added as a 12 slurry. It's purchased as a power and it's slaked or -- it's 13 added as a slurry. 14 Q: Okay. The operators do that? 15 A: Well, the operators -- there is a feeder, 16 a dry feeder, that does that for them, yes. 17 Q: Okay. So, what is the purpose of adding 18 those two (2) chemicals? 19 A: The lime is, of course, a base or caustic 20 compound, and -- when you add alum as aluminum sulphate, it 21 tends to also create some acid, which makes a lot of the 22 lower pH, or destroys what we called the alkalinity of the 23 water. 24 So you can add lime to bring back the pH or to 25 restore what you lost with the alum. Lime can also be

1 helpful in terms of coagulation or flocculation. 2 Q: You say it can be. Is it -- is it at 3 this plant, or was it then? 4 A: I think it's marginally helpful. The 5 polymer here that's added is an anionic polymer, it's a high 6 molecular weight polymer, and the purpose of the polymer is 7 to assist in the flocculation process. 8 The polymer will act as a bridging mechanism 9 to help the agglomeration of these coagulated and flocculated 10 particles, so it'll bring them together in a denser, tighter 11 material that can be more readily settled. 12 Q: Okay. And how are those quantities 13 calculated and controlled? 14 A: Well, the lime -- lime dosage would be 15 controlled by pH readings. 16 Q: Right, which are done by the operators 17 where? 18 A: That would be done by the operators 19 either in the SCU itself or else the raw water, and at the 20 finished water. That's where it can be done. 21 Q: And the polymer? 22 A: The polymer would be set based on the 23 observations with respect to the flocculation performance. 24 They would -- they would conduct visual 25 inspections of the solids contact unit?

1 A: Yes, and they can also be set by a 2 technique used we call jar testing, which is used to help 3 select chemical dosages -- 4 Q: Yes, and we'll come -- we'll come to that 5 in a moment. 6 A: Okay. 7 Q: Okay. Now in this -- these two (2) 8 chemicals, once they're added, there -- there's a mixing 9 process involved here in the solids contact unit? 10 A: There is mixing, yes, and we can get to 11 that. 12 Q: Okay, we'll come to that? 13 A: Yes. Presently what we've got to in 14 the -- where we are at in the treatment process description 15 is the water as it goes to the solids contact unit. 16 And if we go to the next stage, then we 17 illustrate here where it comes out of the solids contact unit 18 and goes into these filter sections, filters 1 and 2 appear, 19 and 3 and 4. 20 Q: Does an equal amount of water go to each 21 set of filters, or does that change from time to time? 22 A: I believe most -- a little more than half 23 of the water goes on to filters 3 and 4. 24 Q: Okay. 25 A: Which is really caused by the existing

1 hydraulics of the system. 2 Q: Hmm hmm. 3 A: Presently there is no metering to 4 determine exactly what the flow rate is to either of the 5 filter banks. 6 Q: Okay. 7 8 (BRIEF PAUSE) 9 10 A: From the filters then, the next phase is 11 the water goes into clear wells, and there is a -- these 12 clear wells serve as pumping reservoirs for water to be sent 13 to the distribution system. 14 And there's clear wells underneath in the old 15 section, the old building section under filters 1 and 2, and 16 there's also clear well under the new section, the new 17 building section, where filters 3 and 4 are located. 18 Then the next phase of course in the process, 19 is pumping to distribution. 20 Just as a matter of interest, the water supply 21 to the Sask. Hospital essentially comes out of the old 22 section of the plant, water is supplied to the distribution 23 system of the City of North Battleford, can come out of the 24 new section plus the old section, if necessary. 25 And the other point I should make is that

1 these reservoirs are interconnected via pipe. So there is 2 interconnection between them. 3 4 (BRIEF PAUSE) 5 6 A: Anything further on that? 7 Q: I don't think so. Can you take us now 8 down into the solids contact unit? 9 10 (BRIEF PAUSE) 11 12 A: This is a schematic of a solids contact 13 unit. 14 Q: And does it approximate to the one (1) in 15 use in North Battleford at the moment? 16 A: I think it's fairly close, yes. 17 Q: Are there any -- any significant 18 differences that we should note? 19 A: No, we did -- well, I guess there is one 20 (1) issue that this launder here which collects clarified 21 water. 22 Q: In the schematic or at North Battleford? 23 A: Both. 24 Q: Okay. 25 A: There is one (1) around the end. But I

1 just want to point out there are radial arms that go out here 2 and collect it at various points. 3 Q: Yes, that's in the -- in the one (1) as 4 it exists in North Battleford -- 5 A: That's right. 6 Q: -- with the radial arms? 7 A: Yes. 8 Q: And I'm assuming you're going to show us 9 a view from the top of that unit and we'd be able to see -- 10 A: We have some photos I think -- 11 Q: Yes. 12 A: -- that may pick that up. 13 Q: Okay. So could you take us through the 14 principal components of the solids contact unit, and how it 15 works? 16 A: Okay. Let's put those on. Well 17 fundamentally the raw water comes in from the side towards 18 the centre of the solids contact unit. 19 And from there it flows down and mixes with -- 20 in a primary reaction zone with the existing slurry pool. 21 Q: What causes it to flow down at that 22 point? 23 A: Just the way the water can come in. 24 There is shroud or a baffle. 25 Q: Which forces the water down?

1 A: Which forces the water down as it comes 2 in. It mixes with this slurry material. There is a -- an 3 impeller turbine mixer at this point here that rotates. 4 Q: Is that the mixer referred to in some of 5 the documents as the vari drive? 6 A: It could -- yes, it's variable speed 7 drive. Okay, from there we go into this primary mixing zone. 8 It then goes upwards through a secondary mixing and reaction 9 zone which is really another part of the flocculation 10 process. 11 The water then -- it goes down through here 12 and we get sedimentation of this floc into the slurry pool. 13 Q: And does the slurry pool exist only in 14 one (1) side of that solids contact unit? 15 A: No, it -- it involves around the 16 periphery of the -- 17 Q: The periphery of the whole unit? 18 A: Yes. Yes. We get sedimentation of this 19 floc and essentially then we get clarified water where it 20 separates, comes up and goes through orifices in the side of 21 the launder. And from the launder it is then delivered to 22 the filters. 23 Q: Okay. 24 25 (BRIEF PAUSE)

1 CONTINUED BY MR. JAMES RUSSELL: 2 Q: Now where does that sedimentation process 3 take place? Where does the -- where does the sediment 4 collect? 5 A: The sediment collects on the ex -- in 6 external side of the -- of the skirts here. 7 Q: Okay. And that's right around the 8 periphery? 9 A: Yes. 10 Q: And how is that sediment dealt with? I 11 mean, presumably it accumulates over time? 12 A: That's right. And when you are producing 13 or treating water, you're forming this flocculated or -- 14 materials. And what you have to do is try and balance it 15 because you're -- you are forming this material so you 16 have -- also have to get rid of as much as you form to 17 maintain a balance. 18 Q: Okay. 19 A: And this is done through a -- blow off 20 systems that they have where they can blow down concentrated 21 sludge and send it to waste. 22 Q: Do you have any diagram to show us of how 23 that blow off system works? 24 A: Not a detailed one. It's schematically 25 shown -- shown here. There is a gate that they manually

1 open. There is a valve they have to manually open and then 2 there is a timer which they have to activate so it blows down 3 for a specified period of time. 4 There are essentially four (4) ports on this 5 solids contact unit. They designate them south and west. 6 Q: Do they exist at each corner of the unit 7 or just -- ? 8 A: Well, they're almost at a hundred and 9 eighty (180) degrees across from each other. 10 Q: Can you show us on your -- on the 11 overview of the -- the solids contact unit where -- where 12 they would be? 13 A: Yeah, I believe I can. There's some in 14 this area here. 15 Q: Yes? 16 A: And there's some in this area here. 17 Q: Okay. 18 A: I think that's close. Is that close? 19 Q: And when that blow off occurs it blows 20 off the sludge? 21 A: It'll blow off sludge, yes. 22 Q: And where does the sludge go? 23 A: Sludge is put in their -- into a sump 24 which is subsequently released back to the river. 25 Q: The river. Now that sludge, as it's

1 forming, does the sludge itself play any -- play any role in 2 the filtration process or the sedimentation process? 3 A: Well the sludge becomes intimately mixed 4 with the raw water to enhance the coagulation, flocculation 5 process of the raw water. And it also potentially provides 6 some more efficient use of chemicals because you get a bit of 7 a recycling effect. 8 Q: I see. The -- the chemicals contained in 9 the sludge can be recycled? 10 A: Well they're recycled in -- in the sense 11 that the raw water coming in passes through a lot of that 12 sludge you get so we try and -- it's use is maximized I 13 guess -- 14 Q: Okay. 15 A: -- or optimized perhaps. 16 Q: And what does floc look like, can you 17 tell us? 18 A: Floc looks like -- 19 Q: I don't suppose you have a picture? 20 A: -- I can, but I've just got to be careful 21 how I just phrase it here. I was going to say very tight 22 snowflakes sometimes. 23 Q: Hmm hmm. 24 A: I guess in some cases it looks like very 25 dense fluff --

1 Q: Hmm hmm. 2 A: -- and you may occasionally get from 3 certain trees. 4 Q: All right. And you mentioned earlier I 5 think the term pin floc? 6 A: Yes, pin floc is a very small floc -- 7 Q: Hmm hmm. 8 A: -- it's really a reflection of the size. 9 Q: If you get pin floc, what does that tell 10 you about the -- the flocculation process? 11 A: It tells you that you should probably be 12 looking at trying to either add more coagulant aid or you're 13 going to have to adjust your -- your process chemicals. 14 Q: So is the idea then that you -- you -- 15 you try to get the -- the larger floc? 16 A: To improve -- what you want is a 17 relatively dense, relatively large floc that has good 18 settling characteristics. 19 Q: And the reason for that is? 20 A: Well so it can be readily settled out. 21 You know, one (1) of the purposes of the clarifying process 22 is to essentially promote the longevity or the length of use. 23 You can use filters before they have to be 24 cleaned. So you try to maximize the material that in -- in 25 removal in the clarifiers before it goes on to filtration.

1 Q: Right, so you don't want large sediment 2 going into your filters? 3 A: That would be preferable not to, yes. 4 Q: Can you show us then how the filters 5 work? 6 A: Filters, okay. 7 8 (BRIEF PAUSE) 9 10 This is a -- a schematic obviously, of what we 11 call a dual media filter. And dual media means there is two 12 (2) types of granular media that serve as a filtering 13 material or filter medium. 14 In this case we're describing them as 15 anthracite in sand, and if you want to extend this a little 16 bit to -- to the North Battleford situation, the -- the sand 17 is approximately a zero point five (0.5) millimetre effective 18 size. 19 And the anthra -- 20 Q: What -- what -- what does that mean? 21 Does that mean that's the size of the sand or that's the size 22 of the particles it can handle? 23 A: No, that is the size of the sand and then 24 overlaying that is a layer of anthracite or coal, which is a 25 little larger sized, I believe their sizes are typically in

1 the range of about maybe point six (.6) to point eight (.8) 2 millimetres -- 3 Q: Right. 4 A: -- effective size. 5 Anthrocite is -- of course has a -- a lower 6 density, a lower specific weight than -- than sand, so it 7 tends to settle on the bottom and we can get the 8 stratification, and we get the segregation fairly well. 9 So fundamentally when this is -- 10 Q: And both sets of filters in North 11 Battleford are the same? 12 A: -- both sets of filters cont -- contain 13 anthracite and sand, they're not exactly the same, no. 14 Q: But you will -- will you show us the 15 difference between them, can you show us the difference 16 between them, once you've demonstrated this? 17 A: Not today. 18 Q: Okay. 19 A: I can verbally address it -- 20 Q: Well perhaps -- 21 A: -- but I can't show you. 22 Q: -- sure, verbally is fine. 23 A: Basically the water comes in from the 24 clarifier and solids contact unit, it flows in by gravity, it 25 goes on to the filter. Some of the materials are trapped at

1 the surface, some of the materials are trapped at depth. 2 The idea is to avoid any significant loss of 3 materials through the bottom of the filters, so you try and 4 maximize the performance and then from there the water flows 5 by gravity to clear well. 6 Okay, that is the normal filtration process, 7 it's fairly clean cut. In terms of backwashing, when we 8 refer to backwashing we're trying to clean the filters of the 9 material that it has trapped. 10 Q: You're pushing water back through the 11 filters in the opposite direction? 12 A: We're essentially pushing water back. 13 Now in North Battleford, this -- this thing doesn't show it, 14 but they also have an air wash, which helps clean the 15 filters. 16 And typically air under pressure is injected 17 through the under drain system, and it agitates -- agitates 18 the filter as well, which helps clean it. 19 Q: Does it do that by loosening up the 20 particles that have been trapped in the filter? 21 A: It does, and it creates a scrubbing 22 motion between the media. 23 Q: So it loosens the particles so that when 24 the water passes back in the opposite direction they can 25 be -- they can be --

1 A: When they go back into what we called a 2 hydraulic backwash, they can be more easily passed out and 3 cleaned out, yes. 4 Q: Okay. 5 A: What happens is that after the air wash, 6 then they go into the -- a water wash in which they bring 7 water at a fairly high rate back in a reverse direction 8 through the filter and the sand and the under side bed expand 9 because of the flow rate through that. 10 And you get further separation of the media 11 and better ability to clean particles off of the media. 12 Q: Better ability when you're backwashing, 13 or when they -- they're put back on line? 14 A: Well, when you're backwashing in terms of 15 cleaning it. 16 Q: Okay. 17 A: After -- after the backwash -- backwash 18 cycle, then typically they go into the filtering cycle. 19 Q: And what's the filtering cycle? 20 A: The filtering cycle is, again, when 21 you're taking water from the clarifier, running it through 22 the filters and into the clear water -- the reservoir. 23 Q: Into the clear well? 24 A: Yes. 25 Q: Now your backwash water goes -- when you

1 say waste bed, that goes into the river? 2 A: Yes. 3 Q: Okay. And following that, the cycle you 4 talked about, when the filter's put back on line, I think you 5 mentioned earlier that it was possible with one (1) set of 6 these filters to filter to waste, once the filter -- 7 A: Yes. 8 Q: Which set of filters are those again? 9 A: 1 and 2. 10 Q: 1 and 2. So can you -- can you show 11 us -- do you have diagrams showing us how you filter to waste 12 with 1 and 2 once the water goes back on line? 13 A: I don't think I have a diagram. Let me 14 make sure. I've got photos. 15 16 (BRIEF PAUSE) 17 18 No, we don't have good photos but, I guess, 19 very simply, water comes out, is piped from the bottom of the 20 filter, and there is a branch off that line coming out of the 21 bottom of the filter and it can be valved and opened and 22 discharged to waste, so it's -- it's a manual valve now, I 23 believe. 24 Q: Okay. And back then it was a manual 25 valve too?

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1 A: Still is. 2 Q: And so that is subject to what, visual 3 inspection by the operator? Is the valve controlled from -- 4 A: Well, if they were using it, there would 5 be, I guess, some experience used to assess how long it 6 should be wasted. 7 Q: Right. 8 A: I guess, if you want to get into what we 9 call a filter ripening, one (1) of the reasons you may want 10 to backwash or filter to waste is that in some instances, it 11 takes a little time for the filter to ripen and perform. 12 By ripening, it means that if we get the 13 filter a little dirty, then it works better. 14 Q: So that once it's been cleaned and it's 15 put back on line, it's too clean to function as efficiently 16 as it should? 17 A: In some cases that can happen, yes. 18 Q: And is there typically a period of time 19 during which the ripening process takes place? 20 A: It seems to -- seems to vary at North 21 Battleford. And largely it's somewhat contingent on how -- 22 how they go through their backwash operation, whether they 23 tend to super clean it or whether they may leave some 24 residual or not clean it fully. 25 Q: Okay. Good. So are there any other --

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1 any other components to -- to be examined? You've now 2 reached the clear well, I think? 3 A: We have, yes. There are two (2) clear 4 wells. Perhaps there are some items here just for 5 clarification, and I don't say this as a pun. But back in 6 the raw water supply, just so you know how this operates a 7 little bit, the water flows in and they have what they call 8 vertical turbine pumps, the impellers are down at the bottom, 9 and they pump the water up through the sand separators and 10 out ultimately to the solids contact unit. Not shown here, 11 there are air lift pumps also in this vessel because the city 12 does get a lot of suspended material settling out in here so 13 they have to blow that off periodically as well. 14 Q: Do you have any photographs of the air 15 lift pumps? Before you do that, this -- the procedure we're 16 seeing here, this is prior to the addition of the first three 17 (3) chemicals? 18 A: That's right. 19 Q: The alum, the aluminex and the potassium 20 permanganate? 21 A: Yes. 22 Q: This is prior to that; right? 23 A: Yeah. No, I don't have any pictures, 24 it's in a pump well -- 25 Q: Okay.

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1 A: -- it's pretty dark. 2 Q: Now, the -- the various processes you've 3 shown us, as the -- the water goes through the plant -- 4 A: Hmm hmm. 5 Q: -- with the diagram; do you have any 6 pictures to -- to back that up with so we can see what it 7 actually looks like? 8 A: Yes, we have pictures. Let's start, 9 again, on the intake side. These are -- actually, this is a 10 motor, but the pump shaft for one (1) of the raw water 11 pumps -- 12 Q: This is in the bottom of the pump house? 13 A: Well, this is at grade level -- 14 Q: Right. 15 A: -- the pump column actually sticks 16 below -- 17 Q: Okay. 18 A: -- down in this pump well. The pump well 19 I guess is below this floor here, this is simply a motor, 20 there's a drive and the pump column comes up there and 21 discharges through here and heads into the sand separator 22 units. 23 Q: Right. 24 A: There are three (3) raw water supply 25 pumps, there's this one (1) here, there's one (1) behind here

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1 and then there's actually one (1) a little to the left. 2 This is similar to the picture we had before, 3 again, showing the -- the pumping station. Actually, when I 4 said at grade, that might have been a little misnomer because 5 the pump levels probably sit down about at this level here. 6 Q: Hmm hmm. Do you -- 7 A: By the river bank. 8 Q: -- do you have any photographs inside the 9 tunnel underneath where the three (3) chemicals are added? 10 A: Let's see. 11 12 (BRIEF PAUSE) 13 14 I do, but they're not on this program. 15 Q: Okay. 16 A: This is the intake again. Let's go to 17 the solids contact unit. 18 Q: Is that window a reflection? 19 A: It is, but this is a picture -- these are 20 the launders that I described to you, I mentioned the radial 21 launders which weren't shown on the schematic, but this is a 22 picture of the floc -- 23 Q: Yes. 24 A: -- coming out, being discharged. 25 Q: So we're looking down into the unit?

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1 A: We're -- we are looking down into the 2 unit. 3 4 (BRIEF PAUSE) 5 6 And the reason that we can see this floc at 7 the bottom is the water is relatively clear at top. 8 Q: Okay. Can you take us anywhere else? 9 A: Yes, I can -- let's see. Here's another 10 picture of the solids contact unit taken from the side and, 11 again, here are the radial collectors, there's a circular 12 collector, a launder collector. The draft tube where the 13 chemicals are added is in this area here and this is a drive 14 for the mixer. 15 Actually, this solids contact unit extends 16 under a floor -- 17 Q: Oh, that's what -- 18 A: -- the floor on top of part of -- right 19 here. 20 Q: Oh, I see. 21 A: Okay. So you can't see it; this is a 22 walkway out to it. 23 Q: And how many of those launder tubes are 24 there, roughly? 25 A: One (1), two (2), three (3), twelve

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1 (12) -- 2 Q: Okay. 3 A: -- maybe. 4 Q: Approximately? 5 A: Yeah. But the idea of these radial tubes 6 is to provide an even distribution of the up flow water and 7 to capture it. 8 Q: But the up flow water there, is it -- it 9 comes from the centre of the unit first? 10 A: The outflow -- 11 Q: The up flow. 12 A: -- the up flow comes out here, enters 13 these launders with holes in them and then flows in this 14 radial one (1) here, and then actually there is a centre 15 discharge that goes out to the filters. 16 Q: To the filters, okay. 17 A: This is a picture of the filter console 18 at filters 3 and 4, in front of filters 3 and 4. 19 Q: So what are we seeing there? 20 A: We're seeing some gauges here that assist 21 the operators in terms of knowing what valve settings they 22 are and what rates are being used. 23 Q: Are you able to read from that gauge 24 the -- the effectiveness of the -- of the filter and how it's 25 functioning?

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1 A: What the gauges will tell us are what we 2 call a loss of head. 3 Q: Yes. 4 A: And a loss of head will help describe how 5 dirty the filter might be getting. And once you get up to a 6 certain loss of head or after a certain time, then it's 7 backwash time. 8 Q: Is there any maximum length of time for 9 which these filters can be run or is it always a loss of head 10 decision? 11 A: Well as a rule of thumb they try to, as I 12 understand it, backwash them at least at an eighty (80) hour 13 filter run. 14 Q: Okay. 15 A: You talked about the flow measurement on 16 the entire plant, the inflow. This is the gauge here which 17 tells you what the raw water inflow is, as it happens to be 18 sitting here. 19 Q: The -- the volume of water coming in? 20 A: The rate of water coming in. 21 Q: Okay, the rate of water coming in, okay. 22 A: These are head loss gauges and I can't 23 read what's on them, but they're gauges for operations. 24 They'll tell you of valve openings, rate of backwash and 25 things of that nature, so ...

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1 Q: And do both sets of filters have a -- 2 A: Both sets of filters have a filter 3 console. 4 Q: Okay. 5 A: Maybe if we can go over here. This is a 6 picture of one (1) of the filters, actually I think it's 7 filter number 2. 8 During operation these are troughs here, 9 they're called overflow troughs. 10 Q: Sorry, they're called what? 11 A: Overflow troughs. 12 Q: Yes. 13 A: And their purpose -- primary purpose is 14 to collect backwash water when the waters are being cleaned, 15 so the water rises, flows into these troughs and out to 16 waste. 17 Q: Do you have a shot of num -- the 3 and 4 18 filters, and could you show us the pumping to waste mechanism 19 that can be used there on the 3 and 4 filters? 20 A: I don't have any of those pictures. 21 Q: Thank you. 22 MR. JAMES RUSSELL: Oh, so sorry. 23 MR. COMMISSIONER: I just wonder, I notice 24 it's 12:30, Mr. Russell, is it a good time to take a break? 25 MR. JAMES RUSSELL: I think it is, Mr.

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1 Commissioner. 2 MR. COMMISSIONER: All right, we'll stand 3 adjourned until 2:00 p.m. 4 5 --- Upon recessing at 12:30 p.m. 6 --- Upon resuming at 2:00 p.m. 7 8 MR. COMMISSIONER: Ladies and gentlemen, if 9 you would take your seats please. 10 11 (BRIEF PAUSE) 12 13 All right. Are you ready to proceed, Mr. 14 McDonald? 15 THE WITNESS: I am. 16 MR. COMMISSIONER: All right then perhaps we 17 will resume the hearings. Mr. Russell? Oh yes, and we're 18 continuing at this time with the evidence of Mr. Roger 19 McDonald who is testifying on the waterworks here in North 20 Battleford. 21 22 CONTINUED BY MR. JAMES RUSSELL: 23 Q: Mr. McDonald, I'd like to for the moment 24 move into the area of -- of monitoring and testing. But 25 before we do, just one (1) point of clarification on what you

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1 said this morning. I believe you identified several points 2 in the -- in the system, i.e., the -- the -- the surface 3 water treatment plant number 2, where it was possible to pump 4 the water to waste, i.e., pump it back into the river without 5 sending it through to the next process. 6 Could you identify for me, again, where those 7 points were? 8 A: The primary points were the filters 1 and 9 2. 10 Q: Yes? 11 A: The water could be wasted during a 12 filtering operation. The other item that I mentioned or 13 alluded to was the potential for discharge of water from the 14 solids contact unit through the system in filters 3 and 4. 15 Q: All right. And when the -- when the 16 water is -- is pumped out into the river from either of those 17 two (2) sites, where is the outlet into the river? 18 A: The outlet is downstream of the intake. 19 Q: Thank you. If you would, I'd like you to 20 take us through some of the various monitoring devices and 21 testing procedures that were used in the plant at the time. 22 And perhaps, because we've heard of turbidity already and we 23 know what it is, could we maybe start with turbidity? 24 And could you tell us how the operators were 25 testing for turbidity levels and where they were testing for

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1 them? 2 A: In terms of turbidity, the -- I think we 3 got a -- if I can and we have a photo here. There are two 4 (2) ways in which they can test for turbidity. 5 Q: Can you give us the sites, first of all, 6 the testing sites? 7 A: Okay. Prior to -- well, during the 8 period of -- of interest right now, the sampling sites were 9 primarily related to the treated water in the clear wells, 10 and as well as they would also sample and test the raw water. 11 And occasionally they would test the water out of the Solids 12 Contact Launder. 13 Q: Right? 14 A: The methods of testing were using bench 15 scale equipment and here we have two (2) examples, here. 16 Q: Before we get to the instrumentation -- 17 A: Okay. 18 Q: -- just to clarify this. Can you tell 19 us, I mean, why -- this sounds elementary, I'm sure, to you, 20 but why does the operator need to know, for instance, what 21 the raw water turbidity is? 22 A: The raw water turbidity would give him -- 23 the operator an indication whether if the raw water quality 24 was changing. And if he might have to make chemical dosage 25 alterations or modifications.

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1 Q: Okay. And why would an operator need to 2 know, for instance, the turbidity in the Solids Contact Unit 3 effluent? 4 A: Again, it would be an operational issue 5 to see whether he was getting a lot of carry over or excess 6 turbidity coming off the solids contact unit. 7 Q: And in the case of the turbidity in the 8 clear well? 9 A: The turbidity in the clear well is very 10 important because that is the water that is delivered to 11 consumers and there are drinking water quality objectives 12 attached to water that is delivered to consumers, for 13 turbidity. 14 Q: Okay. In the case of when the tests have 15 been done for final turbidity in the clear well, because of 16 the way the filters -- the two (2) pairs of filters, 17 discharge water into the clear wells, when you're testing for 18 turbidity in those clear wells, is that a combined turbidity 19 test for the water that's come through both of the filters 20 into the clear well, or is there a way or was there a way for 21 testing the turbidity level of the water coming through 22 separate filters? 23 A: The general procedure -- general 24 operating procedure, to my knowledge, was that they had a -- 25 a recording turbidimeter and this recording turbidimeter was

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1 supplied with water from both reservoirs -- both clear wells, 2 and they mixed before it went through the instrument. 3 In terms of some of the manual -- on the 4 treated water, they do have a tap in their laboratory at the 5 sink. And this was also plumbed in such a way as to be a 6 representative of both clear wells. 7 Q: So, in both cases, in both types of 8 tests, the turbidity is the mixed water from both of the 9 clear wells? 10 A: That is correct. 11 Q: So at that time there was no -- no 12 turbidity testing in relation to any of the one (1) filters, 13 any separate filters, is that the case? 14 A: That's right. Unless this is done 15 periodically and manually, yes. 16 Q: Okay. Can you lead us through, then, in 17 each case the procedure for actually doing the turbidity 18 test? Let's -- can we start with the raw -- the raw water at 19 the -- at the other end and can you -- can you let us know 20 how the operators were testing for turbidity in the raw 21 water? 22 A: Well, that procedure would have involved 23 collecting a sample of the raw water off the discharge of the 24 pumps, taking it to the plant lab and using one (1) of these 25 bench instruments to measure.

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1 Q: Okay. And can you tell us how that 2 works? 3 A: Well, in -- it's rather simple, you take 4 a sample, pour it into a vial and pop it into the machine, 5 push a button and read the number. 6 Q: Okay. And was the same procedure 7 followed in -- if they measured the effluent from the Solids 8 Contact Unit? 9 A: Yes. 10 Q: And what about in relation to the final 11 turbidity? 12 A: Well, the final turbidity from the lab 13 tap could be done the same way as I just described. 14 Alternatively, they did have a continuous turbidimeter. 15 Q: Reading both of the clear wells -- 16 A: Yes. 17 Q: -- combined from both of the clear wells? 18 Now how old was that, is it called a turbidimeter or -- okay. 19 How old was that particular instrument? 20 A: I can't give you the exact time, probably 21 three (3) or four (4) years -- 22 Q: Okay. 23 A: -- I would suspect, at least. 24 Q: Was it functioning correctly, as far as 25 you can determine?

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1 A: As far as we could determine. Actually, 2 I think on one (1) of the first day or two (2) that I was out 3 there, I checked their instruments against our portable 4 instrument to see if they were right; it seemed to be close. 5 Q: Okay. And it was -- it was working 6 correctly? 7 A: Hmm hmm. 8 Q: Sorry. Does that metre give a continuous 9 read on the turbidity? 10 A: Pardon? 11 Q: Does that metre give a continuous read on 12 the turbidity levels? 13 A: The recording turbidimeter does, yes. 14 Q: Yes? 15 A: Yes. 16 Q: And where is that reading recorded? 17 A: That reading, at the time, was recorded 18 on a circle chart. 19 Q: They are the pie charts, so-called pie 20 charts that form, I believe, Exhibit C-6? 21 A: Yeah, could be, I call them circle 22 charts. 23 Q: Circle charts. Can we -- 24 A: I can show you a picture on here, if you 25 want.

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1 Q: Okay, go ahead? 2 3 (BRIEF PAUSE) 4 5 A: This is the output of the continuous 6 turbidimeter. 7 Q: Okay? 8 A: That reading was transferred to this 9 circle chart here which recorded turbidity. 10 Q: Right. Could you look at Exhibit C-6, 11 the turbidity charts, and let us know if that's what you're 12 referring to when you're referring to the circle chart that 13 is taking the contiguous -- continuous read of the -- from 14 the metre? 15 A: Yes. 16 Q: Now, there are charts in the -- in -- 17 you'll notice in Exhibit C-6 there are circle charts in that 18 binder from December 31st, 2000 to April 1st, 2001. Could 19 you check that to make sure you agree with me on that? 20 21 (BRIEF PAUSE) 22 23 A: Will you just repeat those dates again? 24 Q: I believe they run from December 31st, 25 2000 to April 1st, 2001?

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1 A: Okay. This also includes information up 2 through in July 1st. 3 Q: These are -- this is the Turbidity Chart 4 Binder? 5 A: Yes. 6 7 (BRIEF PAUSE) 8 9 Q: Could you tell us where you see that and 10 which tab? 11 A: It's under tab 7, it's June 30th, July 12 1st, 2001, the very first page? 13 A: Okay, I think -- they were slightly out 14 of order so I didn't see how far it went. 15 Q: Does other circle charts which exist 16 though before this period? 17 A: Yes. 18 Q: And do they go back to the beginning of 19 the history of the -- of the metre? 20 A: I would presume so, but I can't verify 21 that for sure. 22 Q: But are -- are you aware that such charts 23 do exist though? 24 A: There are a number of historical charts 25 available.

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1 Q: Do you know where they're -- do you know 2 where they're kept? 3 A: A lot of them were being kept at the -- 4 at the Holliday Water Plant. 5 Q: That's the number 2 plant, the surface 6 water plant, and to your mind, they're still there? 7 A: To my knowledge they're still there, 8 unless they've been removed for photocopying or whatever. 9 Q: Okay. But do you know how far back those 10 circle charts go? 11 A: I cannot tell you that, no. 12 Q: If we look at these circle charts in 13 Exhibit C-6, am I correct that they measure the turbidity up 14 to one (1) NTU? 15 A: The scale ranges from zero (0) to -- 16 Q: To one (1)? 17 A: -- and it's -- and it's set at zero to 18 one (1), yes. 19 Q: Okay, so what would happen if the 20 turbidity rose above one (1)? How would that be recorded on 21 these charts? 22 A: I would assume it would stop at one (1) 23 and just rotate. 24 Q: So these charts don't necessarily show, 25 or they don't show at all, those occasions in which the

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1 turbidity rose above one (1) NTU? 2 A: If that happened they wouldn't show it, 3 yes. 4 Q: It wouldn't show on this chart, thanks. 5 MR. COMMISSIONER: What is the purpose of 6 setting a turbidimeter at one (1) if it's capable of going to 7 a hundred (100), for the sake of discussion? Is there an 8 alarm or something that comes on when it hits one (1), or -- 9 THE WITNESS: I'm unaware of any alarms. Why 10 this particular chart was rated at zero (0) to one (1) I'm 11 not sure, except I -- I just want to make an observation. 12 It's -- based on their normal operating performance. I 13 think, in history, their turbidities are frequently under one 14 (1). 15 To get an expansion of scale it would be 16 logical to use the zero (0) to one (1), and that's just an 17 observation. 18 MR. COMMISSIONER: All right, thank you. 19 20 CONTINUED BY MR. JAMES RUSSELL: 21 Q: But in addition to this reading on the 22 circle chart, was the final turbidity in the clear wells also 23 being tested by the operators at the bench in the plant? 24 A: I'm not sure if it was tested all the 25 time or -- or periodically.

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1 Q: Okay. 2 A: They did -- they did rely on the 3 recording turbidometer to get much of their data. 4 Q: Well, if it were -- if it was being 5 recorded at the bench in the lab, how would it be recorded? 6 Where would it appear? 7 A: It would be recorded on their daily 8 worksheets. 9 Q: Okay. So could you turn to your exhibit 10 which refers to the -- the daily -- sorry, the Daily Plant 11 Record? 12 13 (BRIEF PAUSE) 14 15 If you look at the sheets used by the 16 operators to make the various recordings they do on a daily 17 basis in this exhibit, there are, I think, three (3) 18 references to turbidity measurements. Is that the case? Do 19 you agree with me? 20 A: Okay, excuse me, but which record are 21 you -- 22 Q: Okay? 23 A: -- referring to? 24 Q: Do these rec -- do these charts change? 25 Do these, over time?

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1 A: The record forms were altered in July. 2 Q: Okay, so can we go back to the time that 3 they were -- we're talking about here, prior to March 2001, 4 and look at that record chart? 5 A: All right. 6 7 (BRIEF PAUSE) 8 9 Q: The standard chart I'm looking at refers 10 to a roll water turbidity and then following pH it refers to 11 turbidity again? 12 A: Yes. That turbidity would be treated 13 water turbidity. 14 Q: And then there's a laundered turbidity? 15 A: Right. 16 Q: What is -- what is that? 17 A: That is the turbidity of a sample 18 collected from a launder at the solids contact unit. 19 Q: Okay. And the final turbidity is the 20 measurement which appears beneath the pH, the pH column? 21 A: Yes. 22 Q: Thank you. 23 24 (BRIEF PAUSE) 25

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1 Now Exhibit 5, the Daily Plant Record you're 2 looking at seems to run, as far as I can see, from the period 3 January of 1999 to August 8th, 2001. Is that your 4 understanding of the materials that appear in this binder? 5 A: Mine start from January 4th -- 6 Q: Is that '99? 7 A: -- '99, and if they're in order then 8 extends to August 8th, 2001. 9 Q: Okay. Now how extensive are these 10 records? Do they go back before that time? 11 A: The handwritten records? 12 Q: Yes? 13 A: I believe -- I believe go back quite a 14 ways, but I cannot give you a precise date as to -- 15 Q: And is -- of these records though, are 16 they -- they still in existence and they're still available? 17 A: As far as I know. 18 Q: The handwritten charts? 19 A: The handwritten notes, yes. 20 Q: Do you know where they exist? 21 A: It's my belief they might exist in Water 22 Treatment Plant number 2. 23 Q: Are you aware of any significant gaps 24 that appear in that record of the -- the daily record we're 25 looking at here?

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1 Did you -- did you examine these -- did you 2 examine these -- these daily charts as part of your -- as 3 part of your work for the City? 4 A: We did a brief review of a certain time 5 period in response to some questions the Saskatchewan 6 Environment and Resource Management raised. 7 Q: And the record -- the -- the time period 8 you're talking about is basically the charts as they appear 9 in this exhibit? 10 A: They were during the period of starting 11 in January 2001 -- 12 Q: Okay? 13 A: -- forward. 14 Q: So as part of that exercise you didn't 15 examine anything earlier of -- in the daily charts, the daily 16 record? 17 A: Not in any great detail. 18 Q: Okay, so you wouldn't be aware if there 19 were any significant gaps? 20 A: I've never been advised of any apparent 21 gaps, nor would I be aware. 22 Q: Now once these -- once the operators make 23 this manual record then, what -- what happens to it? 24 Anything? Does it just stay in this daily record book? 25 A: A lot of the material would be entered

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1 into their computer data logging system at the water 2 treatment plant. 3 Q: Okay, and how -- how does that occur? 4 What's the process? 5 A: The operator would take the information, 6 go to the keyboard, enter it. Enter the data he wished to 7 under the appropriate columns. 8 Q: So he merely manually enters the data? 9 A: He does. 10 Q: Okay. And is that computer record 11 available? 12 A: As far as I know, yes. 13 Q: Do you know -- have you examined that? 14 A: I examined in a little more detail, the 15 particular period I mentioned earlier. Apart from that I 16 flipped through them or looked at them, but not in any great 17 detail. 18 Q: Do you know how far that record goes 19 back? 20 A: I cannot give you a precise date, no. 21 Q: Okay. Are there any problems associated 22 with that computer that you were able to ascertain, or not 23 ascertain I suppose, as part of your -- your examination? 24 A: One (1) of the issues that concerned me 25 is -- is the default mechanism in the computer. And what

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1 happens if every time an oper -- as I understand the system, 2 every time an operator makes an entry, then if there's no 3 change entered in cert -- on any of the columns, the computer 4 output repeats what was contained in the previous entry. 5 So what happens, it defaults. So for example 6 if you -- if an operator entered a reading, let's say at 9:30 7 in the morning, and it may be in a certain component, it 8 may -- it would then repeat the data that was probably 9 generated at nine o'clock in the morning. So it may not 10 necessarily represent that at the exact time. And this is -- 11 was of little concern, particularly with -- with measurements 12 because measurements may be repeated -- 13 Q: You mean chem -- the measurements of the 14 chemicals? 15 A: Chemical test measurements or whatever, 16 may be -- may be repeated, and yet the measurements weren't 17 necessarily made at that time. 18 Q: I see. And could that be a problem, for 19 instance, with the recording of the turbidity levels at any 20 particular time? 21 A: Well, I think it brings some confusion to 22 this when one is assessing the data. And it certainly 23 brought probably some confusion when trying to prepare the 24 computer outputs versus the circle charts -- 25 Q: Right.

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1 A: -- versus the handwritten data. The 2 other issue, of course, is that when the handwritten data is 3 entered into the computer, the computer records the time of 4 entry, not necessarily the time of the test. 5 Q: Right. And could there be any kind of 6 significant gap between the time of entry and the time of the 7 test? 8 A: I would say normally not. I think the 9 operators -- you know, the operators are pretty diligent. 10 They try and get it fifteen (15), twenty (20) minutes, or -- 11 but it could, you know, there could be a delay. 12 Q: And how often was the -- were the tests 13 being done, the turbidity tests and the entries being made? 14 A: Well, typically, raw water would be 15 tested at the time of each plant start up. Every time they 16 started the plant, they'd do the raw water. Normally the 17 frequency of testing was on an hourly basis during the period 18 of operation of the plant. 19 Q: Right. And what's done with turbidity 20 results? I mean, who looks at them? 21 A: Who was looking at them or who looks at 22 them now? 23 Q: Well, who was looking at them? 24 A: Presumably the operators and probably the 25 manager.

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  1                 Q:   Were there any reporting requirements as
  2  regards to turbidity?  
  3                 A:   With regards to turbidity?  
  4                 Q:   Yes?
  5                 A:   The information had to be maintained and
  6  if you could let me check on their permit requirements I
  7  might be able to retrieve that for you.  
  8                 Q:   If you can do that quickly, sure, go
  9  ahead.  What you're going to look now at the -- can you tell
 10  us what you're going to look at?
 11                 A:   I want to take a look at the -- no, I've
 12  got to do this backwards here.  Under the -- let's see if I
 13  can do this.  Okay, can you give me the distribution system? 
 14  Okay.  This is under the permit requirements issued by
 15  Saskatchewan Environment and Resource Management.  
 16                 They had to do a continuous turbidity testing
 17  on the treated water.  I don't see the reporting
 18  requirements, I don't believe there was a defined reporting
 19  requirement under this permit.
 20                 Q:   Right.  I think the permit appears in
 21  your exhibit binder at tab 7.  Could you let us know if that
 22  is the permit you were talking about?  The Minister's Order
 23  for waterworks dated the 26th day of March, 1998?
 24                 A:   You say under tab 7?  
 25                 Q:   Sorry, 6?

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1 A: Okay. 2 3 (BRIEF PAUSE) 4 5 Q: There is a schedule of waterworks -- 6 there's a waterworks monitoring schedule attached -- 7 A: Yes. 8 Q: -- to that permit? 9 A: Yes. 10 Q: Is that what you're referring to here on 11 the screen? 12 A: That is part of it, yes. 13 Q: Well, is the -- is the full requirement 14 the one (1) contained in the -- in the schedule -- the 15 written schedule here at tab 6? 16 A: Okay. That's a schedule associated with 17 section 6 on the waterworks monitoring schedule. 18 Q: Right. 19 A: It's simply that it identifies where 20 samples are to be collected and what analyses are to be 21 performed -- 22 Q: Right? 23 A: -- and at what frequency. 24 Q: Right? 25 A: In terms of reporting, I think that was

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1 the issue you raised first -- 2 Q: Right? 3 A: -- as I interpret this, what it says is 4 that the City shall maintain records -- 5 Q: Right. 6 A: -- and information, including annual 7 operating records. In terms of submission, it says the City 8 shall make records and information required to the Parkland 9 eco-region upon request. 10 Q: Right? 11 A: So there wasn't, according to this 12 permit, a defined submission requirement. 13 Q: Right. And, to your knowledge, the -- 14 the City was not reporting -- other than maintaining the 15 record and making it available, the City was not passing that 16 information on to anyone else? 17 A: As far as I know, they -- that 18 requirement was not set. 19 Q: Could we move on to the -- the chlorine 20 testing that was done at the number 2 plant, the surface 21 water plant? Can you tell us how chlorine levels were tested 22 and what the test sites were? 23 A: Again, the primary interest would be on 24 the SCU, effluent and -- the launder effluent, and on the 25 treated water.

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1 Q: So three (3) sites were tested? 2 A: No, the SCU effluent and on the treated 3 water. 4 Q: Two (2) sites were tested? 5 A: Two (2) sites, yeah. 6 Q: Okay. Could you tell us what the 7 procedure was for dealing with those two (2) sites? 8 A: Well, they had a residual recorder that 9 would monitor the water out of the treated water reservoir, 10 and out of the launder they have to -- if they're doing 11 chlorine testing out of the launder, it has to be a grab 12 sample and then tested on a bench scale instrument. 13 Q: Do you have any pictures of the apparatus 14 that was used to do these tests? 15 A: The residual recorder? 16 Q: Yes. 17 A: No, I do not. 18 Q: Okay. Two (2) chlorine tests were being 19 done at each site? 20 A: Chlorine was being recorded on the final 21 effluent from the reservoirs -- 22 Q: Right. 23 A: -- based on a combination sample. 24 Q: Right. 25 A: And the chlorine on the launder was being

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1 performed, but I can't at this point say, unless I looked at 2 this data, say what kind of frequency. 3 Q: Okay. And you mentioned that a chlorine 4 residual was being tested. What about the total chlorine 5 levels? 6 A: When I use the term chlorine residual -- 7 Q: Yes? 8 A: -- I refer to total and/or free chlorine. 9 Q: Can you explain, for the benefit of the 10 Commissioner and legal counsel, the difference between total 11 and free chlorine and why that is significant? 12 A: Okay. The chemistry of chlorine is such 13 that you can have free chlorine, which is really a 14 hypochlorite ion, and it's a very strong disinfectant and 15 this is called free chlorine. 16 Chlorine can also react with ammonia-based 17 compounds in water and these form chloramines -- what are 18 called chloramines and there are some -- couple of, two (2) 19 or three (3) types of chloramines. These chloramines are 20 also disinfectants so when you measure chlorine, you can 21 measure a total chlorine and there's a certain protocol for 22 doing that, certain procedure. 23 You can also measure the free chlorine. The 24 difference between the two (2) represents what we call 25 combined chlorine or chloramines.

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1 Q: And the significance of that for water 2 treatment is? 3 A: Well, the significance is that both of 4 them are -- are disinfectants, both of the combined chlorine 5 and the free chlorine. Free chlorine is a more rapid 6 disinfectant and free chlorine is a current regulatory 7 requirement under the environmental regulations, that is, of 8 water leaving the treatment plant. 9 In the distribution system, the requirement 10 under regulation is to achieve a certain level of free 11 chlorine or a larger level of total chlorine. 12 Q: So the -- the free chlorine is the 13 chlorine that remains free to -- to -- to react with other 14 substances? 15 A: Chlorine -- free chlorine is a very 16 efficient and very rapid disinfectant. On the other hand, if 17 you'd like me to just carry on for a minute, free chlorine is 18 dissipated rather rapidly and it is not as persistent as some 19 of the combined chlorines. 20 And for this reason, in some areas, a practice 21 called chloramination is used, which deliberately adds 22 ammonia to form the chloramines, because they persist a lot 23 longer in a distribution system, for example, than free 24 chlorine. 25 Q: Was that the practice here in North

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1 Battleford? 2 A: No. 3 Q: And the -- both the total and the free 4 chlorine, how is that information recorded? 5 A: That was recorded on the handwritten 6 notes or record forms. 7 Q: So that would appear in the -- the daily 8 plant record? 9 A: Right. 10 Q: Would that information also be punched 11 onto the computer? 12 A: Yes. 13 Q: Okay. Now what are done with those 14 chlorine measurements from the surface water plant? Who 15 looks at them? Who has an interest in them? 16 A: Well, the operators and -- 17 Q: For purposes of insuring that they're -- 18 A: -- the manager -- 19 Q: -- they comply? 20 A: -- would look at them as well. 21 Q: Yes. Any reporting requirement there? 22 Are the -- are the results sent out somewhere else to review 23 from the surface water plant? 24 A: There's no regulatory requirement unless 25 it was requested.

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1 Now we're talk -- excuse me, just so we're 2 clear on this. We're talking about the water treatment plant 3 number 2. 4 Q: Right, we're not talking about the 5 distribution system? 6 A: I just -- just as a point, I just want to 7 make sure. Everybody's aware, the waterworks comment that is 8 issued to the City represents all of their waterworks and all 9 of the components. 10 Q: Right? 11 A: Okay. 12 Q: I understand that there was also a 13 settling test in use there; am I correct? 14 A: They used a settling test in conjunction 15 with the operation and the solids contact unit, yes. 16 Q: Can you tell us what a settling test is 17 and what its purpose is? 18 A: A settling test was the -- involved the 19 collection of a sample from the centre tube of the Solids 20 Contact Unit. This is the centre of the secondary reaction 21 component of that Solids Contact Unit which contained the 22 slurry -- the floc slurry. 23 A sample was taken of that, it was poured into 24 a one thousand (1,000) millilitre graduate cylinder, and the 25 amount of settlement that occurs near the bottom after a five

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1 (5) minute period is measured. 2 Q: You don't have a picture of that cylinder 3 anywhere do you, on your system? 4 A: No. 5 Q: I thought you might have had a picture of 6 the laboratory there with a cylinder in the background? 7 A: Well, we do have a picture of the 8 laboratory, but I'm not sure if the cylinders in it. I can 9 maybe check. 10 Q: Yes, could we check. 11 A: I've got to go -- 12 13 (BRIEF PAUSE) 14 15 -- that looks like that -- that point 16 there -- 17 Q: Right? 18 A: -- is a graduate cylinder. The one (1) 19 they use -- the one (1) they usually use, oops, sorry, is 20 normally what's sighted over here though. 21 Q: But the one (1) normally in use looks 22 like something like that one (1) -- 23 A: That's right -- 24 Q: -- over on the -- 25 A: -- that's right, yeah.

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1 Q: -- and it's -- it's calibrated and it's a 2 thousand (1,000) millilitres? 3 A: It's calibrated in millilitres, yes. 4 Q: When the sample was taken from the Solids 5 Contact Unit, where -- where in the unit was the sample taken 6 from? 7 A: The sample would be -- be dipped just off 8 the -- off the lockway, maybe a half way between the entry 9 and the paddle shaft. 10 Q: Well, is there some record of where the 11 operators were taking it from? 12 A: No, but there is a cushion there -- 13 Q: I see? 14 A: -- that they kneel on to do -- 15 Q: I see. Okay. And how often was that 16 done? 17 A: I think generally it was done on an 18 hourly basis. 19 Q: Okay. And the operators were there 20 measuring the amount of settlement that was occurring in the 21 Solids Contact Unit over a fixed period of time? 22 A: This was -- this settling test was an 23 instantaneous test. It represented the conditions at the 24 time of sampling. 25 Q: Right?

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1 A: Okay, can I -- can you clarify your 2 question? 3 Q: Well, I'm wondering what the sch -- the 4 test actually -- actually shows us in terms of what's going 5 on in the Solids Contact Unit? 6 A: Well, the test really shows how much 7 settleable material is being generated in the process, 8 whether it settles very rapidly, whether there might be some 9 stragglers or some things that aren't settling readily. This 10 is fundamentally what it shows. 11 Q: If the -- if a sam -- I'm assuming the 12 sample is taken from close to the surface of the water? 13 A: It is. 14 Q: So is that an accurate read as to what's 15 happening within the Solids Contact Unit, generally, or lower 16 down in the water? 17 A: It is for the purpose of the test in the 18 sense that they would typically take the test at the same 19 site. So you have a number of relative gauges. And it would 20 reasonably represent what may be happening within the SCU. 21 Q: So you're feeling is that would give you 22 an accurate read as to what was happening in the SCU 23 generally? 24 A: Well, I think for the purposes of the 25 settling test, it was fine, yes.

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1 Q: Okay? 2 A: And that simply tends to follow what the 3 manufacturer was suggesting, at the same time. 4 Q: So there are manufacturer's 5 recommendations in relation to this test? 6 A: Yes, on how to take it and what the 7 expectations might be. 8 Q: Do you recall what they say? 9 A: Well, in terms of testing it is 10 collecting a sample, measuring over five (5) minutes in a 11 graduate cylinder -- 12 Q: Okay? 13 A: -- recording the visible interface of the 14 settled material, and expressing it as a percent. The 15 manufacturer's information written in 1975 suggested that 5 16 to 10 percent may be typical. But frankly that really 17 depends on the characteristics of the plant and the raw water 18 and a number of factors so -- 19 Q: In your review of the records here at the 20 number 2 plant, has that been the -- the typical measurement 21 that has been recorded for settling in the solids contact 22 unit? 23 A: Often the numbers will get up fifteen 24 (15), twenty (20), twenty-three (23). 25 Q: And where are those results recorded?

138

1 A: Those results are recorded on the 2 manually completed record forms. 3 Q: Right? 4 A: And I believe they're also transferred 5 into the computer printout. 6 Q: And do you know at all, in your 7 examination, how far back those records go for settling in 8 terms of the manually completed daily forms on the computer? 9 A: I don't know the precise date, I would 10 expect that they would go back a considerable period of time. 11 Q: And what is done with those measurements? 12 Why is the -- why does an operator collect settling 13 measurements? 14 A: Well, the operator collects these for a 15 number of reasons. They're -- it's a useful tool to look at 16 the performance of the coagulants. It's also a useful tool 17 to determine whether they're getting too much in the slurry 18 pool and they might have to release some of the sludge or 19 the -- some of the slurry pool to waste. 20 Q: Okay. So this is an operation tool for 21 the -- 22 A: Primarily, yes. 23 Q: I think you mentioned earlier that some 24 jar testing was also done at this plant? 25 A: Yes, bench jar testing.

139

1 Q: So what -- what's a jar test, can you 2 tell us? 3 A: Jar test is an attempt to somewhat 4 simulate the processes of coagulation, flocculation and 5 sedimentation in a beaker. 6 Q: For what purpose? 7 A: To assess the performance of certain 8 chemical additions, the dosages, and perhaps the way in 9 which -- the sequence in which they're added. What happens 10 is there is an apparatus with paddles on it where -- we 11 don't -- we don't have a picture there -- but anyway, a 12 paddle -- they're called a paddle mixer, and -- 13 Q: And whereabouts in the plant is that 14 contained? 15 A: Well, that piece of equipment is in their 16 laboratory. 17 Q: Okay? 18 A: It's an old piece of equipment. They've 19 had it for some time. 20 Q: Okay? 21 A: But, actually, what happens is that it's 22 a useful measure in -- to try and get an estimate of the 23 performance of coagulants and of their -- their 24 effectiveness. 25 The paddle mixer allows you to simulate rapid

140

1 mix and also by a speed control mechanism allows you to slow 2 it down and go into the slow mix flocculation stage, so 3 that's basically what a jar tester does. 4 They normally have a number of beakers and you 5 may have a six (6) piece apparatus in which you could set up 6 a control and then set up five (5) other beakers and test the 7 effects incrementally. 8 Q: So is -- was jar testing done for all of 9 the chemicals used in the plant? 10 A: I don't believe it was. Jar testing is 11 of particular interest in terms of the coagulation 12 flocculation process. 13 Q: I see. And you say you're -- you're 14 looking at the -- you're looking at the mixing speed? 15 A: No, only that, when we set up mixings, 16 see, you do certain protocols are established and you may 17 want to have a rapid mix on say a hundred (100) rpm for a 18 short period of time, ten (10), twenty (20), thirty (30) 19 seconds, followed by a slow mix. 20 The slow mix may try to emulate the type of 21 flocculation system you have or they may use an arbitrary 22 one, but it's a relatively slow, gentle mix just trying to 23 build up the floc. 24 Q: So, once again, is jar testing primarily 25 directed at what's going on in the solids contact unit?

141

1 A: Jar testing is primarily directed to see 2 what chemicals and agents are good at achieving reasonable 3 coagulation and flocculation. It's not necessarily trying to 4 simulate exactly what's going on in a solids contact unit, 5 but it does give you an idea of the effectiveness in 6 approximate dosages. 7 Only under real plant conditions, real 8 operating conditions, would you fine tune the dosages. I 9 mean, because to scale up from a beaker -- 10 Q: Right? 11 A: -- to a larger unit, you can't do it 12 directly. 13 Q: But following the jar test, depending 14 upon what the result was, what would the operator then do, go 15 back and adjust the chemical dosages? 16 A: He may, if -- if there's been some 17 concern about the plant process and he wants to make some 18 adjustments. 19 Q: Is there anything else he might do as a 20 result of reading a jar test result? 21 A: Only -- one (1) of the other ways in 22 which a jar test is useful is if they're trying out new 23 chemicals, new coagulants and coagulant aids, new polymers; 24 that's an appropriate place to -- 25 Q: But there's no -- there's no indication

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1 that that kind of activity was going on at the number 2 plant 2 at the material time, is there? 3 A: Well, there has been some testing. 4 Sometimes suppliers will come in -- chemical suppliers -- 5 Q: I see? 6 A: -- and do some testing. 7 Q: Okay. And how were those -- how were 8 those results recorded from the jar testing? 9 A: There's no place on the record form as 10 such for that kind of documentation. The options are you 11 either do it on the back of the sheet or you use another pad 12 of paper. 13 Q: So is there no permanent record of any 14 jar test that's done? 15 A: I haven't been made aware of any. 16 Q: Okay. I also understand that the pH was 17 tested? 18 A: Yes. 19 Q: Surface water plant. Can you tell us 20 again what pH is? 21 A: How technical? 22 Q: As -- as comprehensible as -- make it as 23 technical as you think we can possibly understand without 24 blinding us with science. 25 A: Okay, no, I'm not that type -- kind of

143

1 guy, but I just want to say that, first of all, pH is a 2 logarithmic kind of measurement, but simply, pH tells you 3 whether water is -- tends to be more acidic or tends to be 4 basic -- 5 Q: And why -- 6 A: -- and seven (7) being neutral. 7 Q: And why is the test necessary in water 8 treatment though? What's its purpose in -- 9 A: Well, pH is very important. pH is 10 related to alkalinity in water and these parameters are 11 important in determining whether a water is stable, whether 12 it might be scale forming, whether it might be corrosive. 13 And you normally like to have water that is within a certain 14 pH range for a number of uses. 15 pH is also -- can be a very important in the 16 coagulation process and what's the most effective 17 coagulant -- coagulant dosage. 18 Q: What were the sites for the pH testing? 19 A: The sites, I think, were the raw water, 20 the Solids Contact Launder and treated water, reservoir 21 water -- clear well water. 22 Q: Why, for instance, would an operator need 23 to know the pH of the -- of the clear well water? 24 A: That's the water that's going out to the 25 consumer, that's of interest.

144

1 Q: Can you tell us why? 2 A: Well, again, to deter -- just to make 3 sure it's within the proper appropriate range that they 4 desire. 5 Q: What could be the effect on a consumer of 6 having it in the wrong range? 7 A: In a system? Well, for example, if -- if 8 the water becomes aggressive or somewhat corrosive, it could 9 have an impact on plumbing and fixtures and piping and things 10 of that nature. On the other hand, if the water is severely 11 scale forming, that creates opposite sets of problems, again 12 in terms of plumbing, hot water heaters scaling, and a lot of 13 the plumbers like it because they sell a lot of faucets, they 14 have to replace them. 15 Q: So an operator is looking at the pH in 16 the clear Well because he -- he wants to insure that it's at 17 the appropriate level to protect the distribution system? 18 A: Well, that would be one (1) thing. He 19 would also be looking at the pH in terms of the raw water pH 20 and the lime addition as well, because the lime -- both the 21 alum and the lime used in the treatment process have the 22 ability to affect water's pH. 23 Q: Okay. The end result he's interested in 24 is what the pH is in the -- in the clear well? 25 A: He's interested in that, yes.

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1 Q: Okay. And how are those results 2 recorded? 3 A: Similar to previous comments. 4 Q: Okay. On the -- on the handwritten 5 sheets? Goes in the daily record? And then it -- does it 6 appear on the plant log as well? Is it punched into the 7 machine? 8 A: I believe it is. 9 Q: Okay. The records also seem to show, 10 would you agree, that the temperature of the water is tested? 11 A: Hmm hmm. 12 Q: Do you agree with that? 13 A: Pardon? 14 Q: Do you agree with that? 15 A: The raw water temperature? Yeah. 16 Q: So what's the purpose of test -- do they 17 only test the -- the raw water temperature? 18 A: Can I cheat and look? 19 Q: Sure. 20 21 (BRIEF PAUSE) 22 23 A: There's only a column for a raw water in 24 their previous testing. 25 Q: And why does an operator need to know the

146

1 temperature of the -- of the raw water? 2 A: Water temperature has a -- it can have a 3 profound effect on coagulation process. 4 Q: So once again, he needs to know that for 5 purposes of adjusting chemicals? 6 A: It's very helpful for the operator to 7 know what the temperature is. 8 Q: And how often was that test done? 9 A: I think typically it was done at the time 10 of plant start up. 11 Q: Okay. Were the results recorded in the 12 same way as the -- ? 13 A: In the same way. 14 Q: On the handwritten sheet? 15 A: On the handwritten sheet. 16 Q: Into the computer, into the log; is that 17 correct? 18 A: Yes. 19 Q: And once again, who -- who looks at those 20 records? Just the operator? 21 A: I would presume mainly the operator, yes. 22 Q: Are there any other tests or sampling 23 that was going on at the surface water plant that we haven't 24 mentioned so far? 25 A: I suspect there were periodic tests for

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1 alkalinity. 2 Q: Do you -- do you know that? 3 A: No, I susp -- well, only in anecdotal 4 evidence discussions. 5 Q: Who have you discussed that with? 6 A: One (1) of the operators or one (1) of 7 the previous operators. 8 Q: Okay. And can you give us the operators 9 name? 10 A: Lenn Holliday. 11 Q: Okay. And is he -- is he presently an 12 operator at the plant? 13 A: I understand he's -- he's retired, but I 14 understand he's doing some work. 15 Q: Was he working at the plant at the -- at 16 the material time, immediately prior to the 2001 17 contamination? 18 A: No, no, not as far as I know. 19 Q: Have you checked with the other operators 20 who were working there as to what they did in terms of -- of 21 that kind of testing? 22 A: I don't think there was much of it being 23 done. 24 Q: Okay? 25 A: The reason I say that is that we altered

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1 the record forms and started putting in a suggestion for more 2 alkalinity testing. 3 Q: Okay? 4 A: Again, that's particularly related to 5 coagulation and addition of lime, for example. 6 Q: Right. Now I understand that this -- the 7 surface water plant does have a -- a daily log which we've 8 entered as an exhibit. I'm wondering if you could -- if you 9 could pick up your Daily Plant Log Exhibit? 10 11 (BRIEF PAUSE) 12 13 Q: The first page I have in my log is for 14 June the 5th, 2001? 15 A: Yes. 16 Q: Do you have that page? 17 A: Yes. 18 Q: Has the format of this Daily Plant Log 19 changed since you became involved during 2001, or is this the 20 same format that was used prior to March of 2001? 21 A: I'm not aware of it being changed. 22 Q: Okay. And, by and large, if I understand 23 what you've told me, and correct me if I'm wrong, this log is 24 compiled as a result of, first of all, the operators making 25 handwritten entries on the daily worksheets which are then

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1 punched into the computer which then creates this log; is 2 that the way it works? 3 A: For some of the constituents, yes. 4 Q: For which of the -- what happens to the 5 others and which are they? 6 A: Well, I think, unless the speed's 7 changed -- let me go into mid-treatment, for example. Unless 8 the speed is changed, it would just default and remain the 9 same. 10 Q: Oh, you're talking about the -- the 11 problem with the computer actually recording the appropriate 12 result here? 13 A: Well, I'm just telling you that's what 14 probably happened. 15 Q: Yes? 16 A: And the alum dosages and -- and some of 17 the other dosages would be repeated unless there was a 18 deliberate change into either the time of the feeder 19 operation or feeder adjustment. The operator would then 20 enter -- would recalculate a dosage calculation. 21 Q: Okay. But the only way a figure gets 22 onto this plant log is through that computer; is that 23 correct? 24 A: Yes. 25 Q: Okay. Now just so that we -- some of the

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1 reproductions are not very clear. Can you tell us what each 2 of these columns records, at least give us its title? 3 A: Is there a particular one (1) that you 4 want to use as -- 5 Q: Should we start on the left hand side and 6 we've got time, we've got operator. 7 A: Operator is the name of the operator, 8 yes. 9 Q: Then we've got LS. 10 A: Okay. That is the plant inflow in litres 11 per second. 12 Q: So that's showing us how much is -- the 13 rate? 14 A: That's the rate of flow. 15 Q: Yes. And then the column after that, I 16 can't quite read in my version. Is it -- 17 A: It's gallons. It's a conversion of the 18 metric to the imperial -- 19 Q: So that says gal? 20 A: It does. 21 Q: Okay. And then we have turb; I'm 22 assuming that's turbidity? 23 A: That's turbidity, raw water turbidity. 24 Q: Temperature? 25 A: pH.

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1 Q: pH. What's the 't' there? 2 A: Total alkalinity. 3 Q: That isn't measured? 4 A: Pardon? 5 Q: Is that measured? 6 A: No, as I said, periodically the -- 7 Q: Okay. 8 A: -- alkalinity is not frequently measured. 9 Q: And on the raw water side, the final 10 column, I can't read the heading? 11 A: It refers to hydroxide. It says O-H. 12 Q: O-H? 13 A: And it's a type of alkalinity. 14 Q: Okay. And the -- there's no -- there's 15 no measurement taken of that? 16 A: No. 17 Q: In the mid-treatment stage -- 18 A: Yes. 19 Q: -- speed -- what is that the speed of? 20 A: That would be the speed of the Rotor 21 Impeller Assembly in the Solids Contact Unit. 22 Q: The vari-drive system? 23 A: Okay. 24 Q: The turbidity there is the Solids Contact 25 Unit effluent?

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1 A: That's right. 2 Q: The settling is the settling test result 3 we've just spoken about from the calibrated jar? 4 A: That's right, expressed in percent. 5 Q: And then we have, I think it says, is it 6 blow off? 7 A: Yes. 8 Q: And I can't read the columns that follow 9 that; can you help us there? 10 A: Well, one (1) is loss of head. 11 Q: Okay? 12 A: And that loss of head refers to the 13 pressure loss through a filter or what we really call a head 14 loss through the filter. 15 Q: So are we measuring the efficiency of the 16 filter there? 17 A: It's measuring the resistence of passage 18 of water in the filter at that time. 19 Q: Okay? 20 A: The -- 21 Q: And -- and which filter do we know is 22 being measured there? 23 A: Well, on the far right of that mid- 24 treatment section -- 25 Q: Right?

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1 A: -- you see filter 1. 2 Q: Yes? 3 A: Then you see filter 2 -- 4 Q: Yes? 5 A: -- and then you go down to filter 3 and 3 6 would represent filters 3 and 4. 7 Q: Okay. That's a combined result? 8 A: Right, just the way the filters operate 9 is different. 10 Q: Okay? 11 A: So the second column then would be after 12 the loss of head, which I think is expressed in litres. The 13 hours would be the hours of operation since they were last 14 backwashed. 15 Q: Okay. And in the -- in the blow off 16 column -- 17 A: Yes. 18 Q: -- what are the figures telling us there? 19 A: Well, as I mentioned, there were sort of 20 four (4) blow -- blow off ports -- 21 Q: Yes? 22 A: -- two (2) of them in the west and two 23 (2) of them in the south. 24 Q: Right? 25 A: So you might have south 1, so it would be

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1 one (1) that would be open, west there would be none open, 2 two (2) on the second column going down, south may have two 3 (2) open, the west would have none open. 4 Q: Okay. And are the times recorded for the 5 openings of those blow off gates? 6 A: Only the time of entry when that 7 information was entered. 8 Q: I see, so -- so we wouldn't know when 9 the -- the gate had actually been opened or the length of 10 time? 11 A: Not precisely, not by this. 12 Q: Okay. If we move to the finished water 13 section, now the first column is turbidity? 14 A: Right. 15 Q: And the second column is free chlorine? 16 A: Right. 17 Q: Then total chlorines? 18 A: Good. 19 Q: And I can't read the next column? 20 A: It looks like -- 21 Q: Is it an O-H? 22 A: O-H is hydroxide alkalinity. 23 Q: So, once again, that measurement just is 24 not -- is not made? 25 A: No.

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1 Q: Okay. 2 A: It only -- just so you know, hydroxide 3 alkalinity only occurs with very high pH values. 4 Q: Okay. So you're saying that here it is 5 not necessary to make that measurement? The next column is 6 the pH in the clear well? 7 A: Right. 8 Q: Is that a -- that's the combined pH? 9 A: Well, it would be -- represent the 10 combined pH. 11 Q: Of both wells -- both clear wells? 12 A: Of both clear wells. 13 Q: And then T-Alk? 14 A: Total alkalinity. 15 Q: Once again, that is not measured? 16 A: Right, not in the date I was looking at 17 it. 18 Q: And then, after that, we just have our 19 chemical feeder columns? 20 A: That's right. 21 Q: Okay. Now, besides the materials we've 22 looked at, were there any other logs or records kept at the 23 surface water plant that you became aware of? 24 A: Yes, there are, there was certainly 25 maintenance logs for various pieces of equipment.

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1 Q: Could you tell us which pieces of 2 equipment have logs for maintenance? 3 A: I can speak to it in a general sense and 4 these -- these we'd refer to. Pumps, mechanical equipment, 5 chemical feeders, anything that's probably a motion -- that 6 has motion to it -- 7 Q: Okay? 8 A: -- that may be subject to wear or require 9 lubrication or have external drive mechanisms such as belts 10 or -- 11 Q: Okay? 12 A: -- things of that nature. 13 Q: Would that include, for instance, the 14 mixer in the Solids Contact Unit? 15 A: Probably, but I couldn't specifically 16 identify -- 17 Q: So you're -- you're not aware of any 18 record that exists in relation to that -- to that mixer? 19 A: In terms of maintenance? 20 Q: Yes? 21 A: Whether it was greased or not? 22 Q: Well, any repair that had been done on 23 it? 24 A: Okay. I'm talking about a -- you know, a 25 routine maintenance --

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1 Q: Okay? 2 A: -- logging. 3 Q: Yeah, okay, all right. So you're just 4 talking about greasing, cleaning, making sure it's 5 functioning? 6 A: And there are certain -- you know, they 7 have -- they did have certain requirements for things that 8 are supposed to be done at a certain periods of time. 9 Q: Okay. Okay. What about in relation to 10 the replacement of equipment, any information along those 11 lines available? 12 A: Well, their information was maintained in 13 files. Some of these files are kept at the sewage treatment 14 plant because that's where the manager is normally sited. 15 Q: Hmm hmm. 16 A: And some of their -- there's also 17 information on a number of items at the Surface Water 18 Treatment Plant. 19 Q: Can you tell us what those items are? 20 A: Specifically? 21 Q: Yes? 22 A: No. 23 Q: Okay. 24 25 (BRIEF PAUSE)

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1 A: If you -- in here -- if I can get to it, 2 just a minute, let me go here first. In here we give some 3 examples -- 4 Q: So what is this we're looking at? 5 A: Well, you asked about other records. 6 Q: Yes? 7 A: Now we went through the routine 8 operational monitoring in terms of -- of what quality was 9 measured. 10 And here's some of the other records that were 11 maintained in terms of the filters, the pumps and the 12 reservoirs, volumes, pump operations, and also some of the 13 items on maintenance, maintenance checks and lubrication, 14 things of that nature. 15 Q: Okay, so -- 16 A: So this is a sort of a general list of 17 some of the records that were and are being maintained at the 18 Water Treatment Plant number 2. 19 Q: Okay? 20 21 (BRIEF PAUSE) 22 23 Besides those maintenance records, anything 24 else that was being maintained? 25 A: Prior to March?

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1 Q: Yes? 2 A: Not that I can specifically recall. 3 Q: We attached to your binder this morning, 4 this new few pieces of paper which look like comments by the 5 operators. Can you help us to identify what that document 6 is? 7 8 (BRIEF PAUSE) 9 10 A: Now you're asking me, do I know what this 11 document is? 12 Q: Yes, do you know what it is? 13 A: It just looks like notes that were 14 probably entered -- 15 Q: Have you -- 16 A: -- by operators. 17 Q: -- have you never seen this before? 18 A: Have I never seen this before? Not this 19 particular format, but have I seen incidental comments on -- 20 on record forms, yes, I have. 21 Q: Okay, so you don't know how this list is 22 compiled and who does it? 23 A: No, I do not. I don't know if it -- I 24 didn't know it was -- I wasn't aware a list of this nature -- 25 Q: Existed?

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1 A: -- was compiled. 2 Q: Okay, okay. But you -- what were you 3 aware of in terms of operator comments? 4 A: Well, what I've seen would be entered on 5 the daily record forms. 6 Q: Okay? 7 A: Just to -- 8 Q: And would it -- would it appear in the -- 9 the exhibit of the -- the daily record? 10 A: I would think so, if they're on the back 11 or -- 12 Q: If they're there, that's where they'll 13 be, is that what you're saying? 14 A: That's where I've noticed some records. 15 Q: Okay? 16 A: And I've noticed some comments. 17 18 (BRIEF PAUSE) 19 20 Q: And in your exhibit binder, the Roger A. 21 McDonald Exhibit Binder at -- at tab 4, a CD Rom has been 22 produced which seems to contain certain records. Can you 23 enlighten us as to what those records are and what their 24 significance is? 25

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1 (BRIEF PAUSE) 2 3 Mr. Stevenson says that it might help you to 4 know that this is something to do with the Excel format in 5 Retrieve? 6 A: Okay. Well then I presume it refers to a 7 summary of -- of water production or water treatment data. 8 I'd have to look at it. 9 Q: Okay. So you're not aware of what's on 10 that CD Rom? 11 A: Well not -- not intimately. I may have 12 seen it in another form. 13 14 (BRIEF PAUSE) 15 16 Q: Is there any way we can -- we can look at 17 that to see what it is? 18 A: Well, certainly. I -- I -- can we put it 19 on? 20 21 (BRIEF PAUSE) 22 23 MR. COMMISSIONER: We might as well keep that 24 one (1) in there, I guess. Mr. Russell has one (1), do you? 25

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1 (BRIEF PAUSE) 2 3 Or can Mr. Bleakney play that on his? Is this 4 a good time, I don't know, it's a little early for a break 5 but should we be taking a break? 6 MR. JAMES RUSSELL: Well it might help us to 7 solve a technical problem. 8 MR. COMMISSIONER: Sure. Well all right 9 then, we'll take a fifteen (15) minute break. 10 11 --- Upon recessing at 3:08 p.m. 12 --- Upon resuming at 3:26 p.m. 13 14 MR. COMMISSIONER: All right, ready to 15 proceed, Mr. McDonald? 16 MR. JAMES RUSSELL: Thank you, Mr. 17 Commissioner. 18 MR. COMMISSIONER: All right, Mr. Russell. 19 20 CONTINUED BY MR. JAMES RUSSELL: 21 Q: Mr. McDonald, I think we were at the 22 point of looking at the -- the CD contained in your exhibit 23 binder just to see what information is contained there and 24 what its significance is for the -- the monitoring and 25 testing procedures at the number 2 plant. Can you enlighten

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1 us in that regard? 2 A: This particular record merely shows the 3 water production from the number 2 plant, where the water 4 went to, whether it went to the Saskatchewan Hospital and how 5 much went to the city; the sum of those, of course, is the 6 total produced. 7 The next column refers to the production of 8 water under the number 1 water treatment plant and then the 9 sum of the water plant number 1 and 2 was the total water 10 sent to the city for consumption. 11 Q: Okay? 12 A: And that's called total water or total to 13 the city. The total water produced would include the total 14 to the city, plus that delivered to the Saskatchewan 15 Hospital, and then there's the calculation of the relative 16 contribution from the groundwater treatment plant in terms of 17 the total production to the city. 18 Q: Right. Now -- okay, go ahead? 19 A: Further columns -- I think I can do this 20 this way. This shows what would happen if water treatment 21 plant number 1, the groundwater supply, was increased by five 22 hundred (500) gallons a minute and I think there's other 23 rates so it gives you a variation on what would happen if the 24 groundwater supply was increased and what the relative impact 25 on water treatment plant number 2 requirements would be.

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1 Q: Now, when was this record compiled? 2 A: I think it was fairly recently. 3 Q: So is -- is this record compiled as a 4 result of the work that you have been doing? 5 A: No. 6 Q: Was it something compiled by the city? 7 A: I think it was compiled by an ex- 8 operator. 9 Q: On behalf of the city? 10 A: On behalf of the city or the city's 11 solicitors. 12 Q: Okay. But what period of time, can you 13 help us here, are we -- are we looking at? Is this relevant 14 to the period of time that we're interested in prior to the 15 2001 contamination? 16 A: Well, this -- yeah, this particular table 17 relates the experiences during the year 2000. 18 Q: I see. So we could work out from these 19 figures, for instance, the -- the percentage of water going 20 up to the city from the number 2 plant and compare that with 21 the percentage going from the number 1 plant up to the city 22 over this period of time? 23 A: For the year 2000? 24 Q: The year 2000, yes? 25 A: We also have in our presentation a graph

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1 showing the relative percentages over a period of years. 2 Q: Okay. Is this the only material 3 contained upon the -- your CD? 4 A: No, I believe there's some other files 5 which I may be able to get into; then again, I may not. 6 7 (BRIEF PAUSE) 8 9 A: Okay, these are further production tables 10 for the historical. It goes back a few years. 11 Q: So this is the same information, the same 12 type -- 13 A: A similar type of information, yes. 14 Q: Is this compiled by the same person for 15 the city? 16 A: I believe it was. 17 Q: So this is not information you can speak 18 to, because it's been compiled by someone else? 19 A: I can't directly speak to it other than 20 it's probably off their records. 21 Q: Okay. Is there anything else on there 22 that would be relevant to the period we're looking at? 23 A: Well, here's historical water 24 productions. 25 Q: Now who compiled this information?

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1 A: This information was compiled on behalf 2 of the city through its agents and it just summarizes the 3 trends and water use by month -- 4 Q: Is this something -- 5 A: -- over a number of years. 6 Q: -- have you been involved in compiling 7 this information? 8 A: No, only I had a look at it. 9 Q: Okay? 10 A: It is of interest. 11 Q: It is? Can you tell us why? 12 A: In terms of looking at the groundwater 13 treatment plant and the surface water treatment plant and 14 capacities, production and things of that nature. 15 Q: So when -- after we've taken a look at 16 the groundwater plant, you would be able to use this 17 information to make some comparisons for us? 18 A: We can, as I mentioned -- 19 Q: Yes -- 20 A: -- there is another -- 21 Q: -- you've already -- 22 A: -- chart which is easier to read. 23 Q: Okay, okay? 24 25 (BRIEF PAUSE)

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1 A: Is there anything else you're 2 particularly -- 3 Q: Not unless there's something else on 4 there that -- 5 A: Is there anything else on there that we 6 know of? 7 8 (BRIEF PAUSE) 9 10 A: All right. 11 12 (BRIEF PAUSE) 13 14 This is a three (3) dimensional bar chart, 15 showing monthly use over a period of years, in terms of 16 trends. 17 So what it really indicates is the seasonal 18 water use within the city in the sense that these hot summer 19 months, because of irrigation use and things of that 20 nature -- 21 Q: Okay? 22 A: -- provides the high demand periods. 23 Q: So this is a historical water production 24 chart showing combined -- total water use by the city from 25 all sources?

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1 A: This would be water production I think, 2 in terms of water produced from both plants. 3 Q: Both plants, okay. 4 5 (BRIEF PAUSE) 6 7 Is there anything else on this CD? 8 9 (BRIEF PAUSE) 10 11 Q: Well, perhaps what we can do with it in 12 terms of, Mr. McDonald, if you -- the likelihood of our 13 finishing examination in-chief today with you is totally -- 14 it's probably remote. 15 So maybe we can give you a chance to look at 16 the information on that CD and then revisit it at some other 17 time? 18 A: Oh, certainly, yeah. 19 Q: Thank you. In terms of the information 20 we do have, could you turn to your -- the Holliday Water 21 Treatment Plant Daily Plant Log for June the 5th of 2001. 22 We were looking earlier at the various columns 23 of information recorded there, and I want to ask you 24 something concerning the -- the turbidity column for finished 25 water, which on the June 5th, 2001 table, says zero point one

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1 six (0.16); do you agree? 2 A: That's what the number says, yes. 3 Q: Now, is that measurement taken from the 4 metre or is that taken from the lab test done by the 5 individual operator and entered onto this computer? 6 A: That's an interesting question. The 7 reason I say that at this time, we had other turbidimeters at 8 the plant -- 9 Q: Okay? 10 A: -- and I suspect this is the one (1) 11 taken out of the reservoir for 3 and 4, the clear well for 12 filters 3 and 4. 13 Q: So, when you're talking about this period 14 of time in June 5th, 2001, I only looked at the charts 15 because it was the first page, not because it had any 16 relevance to the period we're looking at; are you saying 17 practice changed in this regard? If we go back to the 18 relevant period, prior to March of 2001, when that 19 measurement was being recorded, can you let us know -- do you 20 know whether that was done from the metre or from the -- the 21 reading taken by the individual operator? 22 A: It's my information -- I believe it was 23 taken from the metre -- 24 Q: From the metre? 25 A: -- the treated water.

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1 Q: So that ought to correspond with whatever 2 appears on the -- on the circle chart? 3 A: That's right, if the time is appropriate. 4 Q: Okay. So we would not, for instance, see 5 here then on this daily plant log the -- necessarily the 6 individual measurement taken by an operator and written on 7 the -- handwritten on the daily sheets? 8 A: Only in the -- on the mid-treatment side 9 and on the raw water side. 10 Q: Can you show us where the turbidity there 11 would be the -- would be the handwritten record as well that 12 would correspond to the handwritten record? 13 A: Yes. 14 Q: Okay. And why is it we can't tell that 15 for the finished water? 16 A: Well, I -- I suspect it was written in. 17 What -- the question here was on June 5th, exactly what that 18 finished water turbidity represents. 19 Q: Yes -- no, but if we -- if -- I'm sorry I 20 misled you by directing you to June the 5th, 2001. If we go 21 to this chart -- if we go to a chart -- the version of this 22 chart prior to -- 23 A: All right. 24 Q: -- March of 2001 -- 25 A: Hmm hmm.

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1 Q: For instance, if we take -- 2 A: I have March 6th. 3 Q: -- March 6th? 4 MR. COMMISSIONER: Under tab 4. 5 MR. JAMES RUSSELL: Right. 6 MR. COMMISSIONER: At the back. 7 8 CONTINUED BY MR. JAMES RUSSELL: 9 Q: In the mid-treatment -- sorry, in the 10 finished water section there we have a turbidity recording of 11 zero point one five (0.15) -- 12 A: Yes. 13 Q: -- for the first one (1); is that what 14 you see there? 15 A: Yes. 16 Q: Now, are you able to tell us where that 17 reading is taken from? Is it from the metre via the circle 18 chart or is it from the individual reading taken by the 19 operator? 20 A: I would -- I believe that would be taken 21 off the metre -- 22 Q: Okay. 23 A: -- the reading off the metre output. 24 Q: Okay. So the only place we would likely 25 find the reading for the finished water, as regards turbidity

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1 during that period, would be on the handwritten chart? 2 A: Well, this would represent from the 3 reservoirs. 4 Q: Right? 5 A: Okay. Which would be the treated water. 6 Q: Right. This is the final -- the final 7 turbidity and that was being recorded on the handwritten 8 chart manually by the operators, was it not? 9 A: I suspect -- yes, it was. 10 Q: Okay. And that would not appear, that 11 handwritten measurement would not appear in this daily plant 12 log at this time? 13 A: No, I think it would. 14 Q: It would? 15 A: They would write it off the metre, write 16 in the handwritten -- in the handwritten chart -- handwritten 17 table and then transfer it onto here. 18 Q: So what would be the purpose of putting 19 it onto the handwritten table before they put it here? I 20 thought, in addition to the metre, were they not also testing 21 for turbidity themselves? Were they not doing the test in 22 the lab, as well as using the metre? 23 A: They would do -- they could do that 24 periodically, but their main tests would probably be the 25 recording turbidimeter; that's the one (1) they would read.

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1 I mean, they did the raw water, they did the launder 2 effluent, had to use the bench testing equipment for that. 3 Q: So, when we look at the daily record for 4 turbidity for the finished water, in terms of the handwritten 5 record, that reading could be taken from the metre, could it? 6 A: Yes. 7 Q: I see. So there is no independent 8 handwritten record of the finished turbidity independent of 9 the metre? They're not testing final turbidity in any other 10 way? 11 A: Well they may have on some occasions but 12 I think the standard practice was probably to utilize the 13 metre. The metre was situated in the laboratory where they 14 could easily read it and record it. 15 Q: Okay. 16 17 (BRIEF PAUSE) 18 19 How many operators were working at this plant 20 at the material time? Are you aware of that? What the work 21 force was in terms of operators? 22 A: I believe there was eight (8). 23 Q: Now were those eight (8) operators just 24 allocated to the surface water plant? 25 A: No.

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1 Q: How did the system work? 2 A: We do have that on our presentation, if I 3 can get into it? 4 Q: Go ahead. 5 A: How do I close out here? 6 7 (BRIEF PAUSE) 8 9 What's the best way to get into that other 10 program? 11 12 (BRIEF PAUSE) 13 14 This summarizes the operator assignment and 15 shifts. The system was that the compliment of the operators 16 were rotated on various shifts and at various locations 17 within the water and waste water works. 18 Q: They are the three (3) plants, right? 19 A: That's right. 20 Q: These people only worked in those three 21 (3) plants, though; is that true? 22 A: Fundamentally, unless there was some 23 maintenance -- 24 Q: Okay? 25 A: -- sewage lift stations or perhaps

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1 looking at some of the reservoirs. 2 Q: Okay? 3 A: So these are the primary shifts and where 4 they went. There's a shift from eight (8) to sixteen hundred 5 (1600) at water plant 2. Water plant number 1 was from eight 6 (8) to seventeen hundred (1700). Sewage treatment plant went 7 from seven (7) to fifteen hundred (1500). And then there 8 were further shifts that covered off water treatment plants 9 number 1 and 2 from 4 o'clock to midnight and then the sewage 10 treatment plant as needed from fifteen hundred (1500) to 11 twenty-three hundred (2300). 12 Q: And then what happened at midnight at 13 the -- 14 A: If necessary people would be brought back 15 on for a good night shift. 16 Q: Okay. So this plant could be kept going 17 twenty-four (24) hours a day, if necessary? 18 A: Yes. 19 Q: Okay. Is that it for -- 20 A: Yeah. 21 Q: Those shift schedules would be allocated 22 by whom? 23 A: By the manager or -- it's generally by 24 the manager. There seemed to be a sequence that they 25 followed. You started at a and went b, c, d, whatever.

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1 Q: Right. And when you arrived at the plant 2 into 2001, who was the manager? 3 A: There was no manager on site. 4 Q: So do you know at that time who was 5 allocating the shift schedules? 6 A: I think the shift schedules were 7 allocated among discussions with the Public Works and 8 Engineering personnel and -- and the operators. 9 Q: To assist the operators in running this 10 plant, was it, at that time, was there any operations manual 11 available to them? 12 A: At water plant number 2? 13 Q: Yes? 14 A: Not a specific operations manual that I 15 could find. 16 Q: Did you find any kind of a manual? 17 A: There was information -- general 18 information respecting the operation of the solids contact 19 unit. This is information put out by the manufacturer. 20 There was some information in terms of -- of binders 21 associated with construction of various components which 22 would have included shop drawings and maintenance instruction 23 for various pieces. 24 And there were files as well there which 25 indicated various components and what they're doing. But I

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1 didn't see an operations manual, per se. 2 Q: I see. Related to the general -- 3 A: Related to general procedures. 4 Q: -- procedures? Okay? 5 A: Right. 6 Q: In terms of -- referring to the group of 7 operators you've mentioned, the -- the group of eight (8), in 8 terms of longevity, can you give us some idea as to who were 9 the people who had been there for some time? And who were 10 the people who perhaps were somewhat newer? 11 A: By name? 12 Q: Was it -- was it a -- no, just by number. 13 Was it a -- was it an experienced work force here? 14 A: Generally it was. A couple of the 15 operators, I think, had in excess of twenty-five (25) years 16 experience at the plant. Others were in the order of ten 17 (10) years or better. 18 Q: Were there any new people? 19 A: Yes, there were. There was one (1) 20 operator, I believe, had just started early or late in 2000. 21 Q: Was that the only recent arrival? 22 A: It was the most recent arrival. 23 Q: Before that, can you remember when the -- 24 the next most recent had -- had started work? 25 A: I believe it was three (3) years or

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1 something in that order? 2 Q: Okay? 3 A: These new people -- the newer more recent 4 operators, as I understand it, had some technological 5 training from recognized institutes. 6 Q: These are the people who had just 7 started, the -- 8 A: Yes. 9 Q: -- the recent arrival? 10 A: Hmm hmm. 11 Q: Okay. So, Mr. McDonald, looking back 12 over what you've told us about the surface water treatment 13 plant, is there, to your understanding, anything in the 14 design features of that plant in terms of the processes 15 you've described for us, could -- could you help identify 16 which parts of those processes might, perhaps, be relevant 17 to -- as part of a barrier to those parasites? 18 A: Well, speaking of cryptosporidium, I 19 think that filtration is a very important barrier. 20 Coagulation and flocculation would also be a good barrier. 21 Q: Prior to the installation of that Solids 22 Contact Unit and the older processes that used to exist in 23 the plant, the -- the older piece of equipment you referred 24 to earlier, I forget the name of it now? 25 A: Oh, they called it -- the trade name was

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1 a hydrotreater. 2 Q: The hydrotreater. Before the advent of 3 the Solids Contact Unit at this plant, was there any kind of 4 barrier at that time for cryptosporidium, giardia or any 5 other parasite? 6 A: The hydrotreater system in the works just 7 upstream of it were also a flocculation -- coagulation/ 8 flocculation/sedimentation system so you'd have a similar 9 type of barrier. 10 Q: Okay. And in the tests that we've been 11 talking about today, the various -- the various tests 12 undertaken, we're just talking, of course, about the surface 13 water plant at the moment, is there anything in that testing, 14 for instance, which involves a test for the presence of 15 giardia, cryptosporidium or any other parasite? 16 A: This is prior to March? 17 Q: Yes? 18 A: No. 19 Q: No. At any of the testing that was done 20 prior to March, are there any surrogate indicators that might 21 be used to identify the presence of cryptosporidium, giardia 22 or any other parasite? 23 A: I think that would be very difficult. 24 The closest one might be able to use would be to look at 25 turbidity in -- in the sense of water clarity, but I'm not

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1 sure would be a real definitive indicator of a potential for 2 parasites. 3 Q: Are you saying that, if the -- if the 4 turbidity levels were high, they're an indicator of some 5 danger? 6 A: Well, there are drinking water quality 7 objectives, the maximum acceptable concentration listed in 8 Saskatchewan was one -- one (1) NTU. 9 Q: Okay? 10 A: So, presumably, one might think that, if 11 you didn't exceed that, the water might be reasonably 12 satisfactory. 13 Q: But nobody is specifically testing for 14 those parasites when they take a turbidity reading? 15 A: No. 16 Q: No. Having taken us through the surface 17 water plant number 2, could we now turn to the groundwater 18 plant? 19 A: We can. 20 Q: Does this plant have a name, such as 21 the -- 22 A: No. 23 Q: It's just called the groundwater plant or 24 the number 1 plant? 25 A: Water treatment plant number 1, as far as

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1 I know. And I'm not sure -- Mr. Holliday was a former 2 superintendent of plants at North Battleford -- 3 Q: Right. 4 A: -- and that may have had some influence 5 in plant number 2. I don't know who didn't get saddled with 6 number 1. 7 The groundwater treatment plant is probably 8 the oldest treatment plant in the city, it was constructed in 9 the '40s for sure or started to be constructed. It has a 10 variable flow rate. Now, this variable flow rate, what you 11 see there ranging from five hundred (500) to twelve hundred 12 (1,200) gallons per minute is largely a function of two (2) 13 factors, (a) the water demand situation, but, secondly, the 14 output from the groundwater supply sources. 15 Q: Which are? 16 A: The wells. 17 Q: Right? 18 A: And it normally would operate fairly 19 continuously. Let's just -- just for some perspective of 20 where it is, this is the road into the groundwater treatment 21 plant and in the background you can see the water tower. 22 This is located on the west side of the road 23 going across number 8 -- number 16 highway going across the 24 North Saskatchewan River. 25 Q: And it's north of the sewage treatment

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1 plant; is that correct? 2 A: It's upstream of the sewage plant, that's 3 correct. 4 Q: Sorry, not north, upstream? 5 A: That's right. This is just another 6 picture of the road, you can see the sewage treatment 7 plant -- maybe you can't see it, but anyway, it's there. 8 It's in that background. 9 The wells -- here's an example of one (1) well 10 house here, they're a number of wells -- 11 Q: Do you know the number of this well? 12 A: The number of this one? 13 Q: Yes? 14 A: I think it might be number 9 but I'm not 15 sure. But anyway, a lot of the wells are -- are along the 16 river, upstream. Upstream and along the river and they 17 normally discharge into a common header pipe which supplies 18 the water treatment plant. 19 Q: Are they -- are all of the wells or were 20 all of the wells at that time on the river side of that pipe? 21 A: Of this line? That's a roadway. 22 Q: Of the -- no, the header pipe that takes 23 the water to the plant. Were all the wells on the -- 24 A: No, they weren't. Some of the wells at 25 the far end, I think, were tied in on the other side or

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1 almost directly into the head end. 2 Q: Okay? 3 A: I guess one (1) other photo I should show 4 you. This is the structure for the groundwater treatment 5 plant. 6 Q: And does it have a history, as the 7 surface water plant does, in terms of additions? 8 A: Yeah, right here was an old plant. 9 Q: Which is no longer there? 10 A: Which is no longer there. There is some 11 auxiliary buildings further this way which are now used for 12 storage. This is the older part of the plant in here. And 13 there is an addition put on, on this side over here. 14 Q: And what was the -- what was the effect 15 of that addition? What did it achieve that the plant -- 16 A: The addition? 17 Q: Yes? 18 A: Well, it permitted the addition of 19 additional -- of two (2) water treatment plant -- or water 20 filters, pressure filters. And thereby increasing the 21 capacity. It also provided more clear well and improved 22 distribution pumping capability, a laboratory and things of 23 that nature. 24 Q: Right. So was this -- this driven by a 25 greater demand in the -- in the city as the population of the

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1 city increased, the capacity needed to increase? 2 A: I can't really comment on that. 3 Q: Okay? 4 A: The genesis of that. 5 Q: Now at the time we're talking about here, 6 prior to March of 2001, how many of the wells were actually 7 in production? 8 A: I think eight (8) were able to be used -- 9 or, sorry, nine (9) were able to be used. 10 Q: Yes? And did production vary between the 11 wells? 12 A: Yes. 13 Q: To a considerable extent? 14 A: Yes. 15 Q: Was there any particular reason for that? 16 A: Yes. Because they -- wells are 17 susceptible to fouling due to the migration of finds that 18 tend to plug the screen. There's also a potential for some 19 bio fouling in some of the wells. The bio fouling is 20 occasioned by iron bacteria and organisms of that nature. 21 Q: Can that not be prevented by a -- a 22 maintenance program? 23 A: The capacity can be maintained by 24 appropriate maintenance. 25 Q: Had that occurred here?

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1 A: The city has maintained their wells. I 2 understand that over the last little while there had been 3 some slippage on maintenance practices. 4 Q: When you say little while do you mean 5 prior to the events of 2001, prior to March of 2001? 6 A: Yes. 7 Q: Yes? 8 A: But for now long, I don't know. But the 9 city used to go out and acidize the main -- or the wells. 10 I'm not sure when they were last cleaned by a well driller. 11 The last set of wells that were put in in 1995 did show some 12 capacity reductions. 13 Q: Hmm hmm. Because of the fouling? 14 A: Because of the fouling of the well 15 screen, yes. 16 Q: And were they the most recent wells at 17 that time? They'd been drilled in '95? 18 A: Yes. 19 Q: Okay? 20 A: Just further on this, this is 21 fundamentally what happens in terms of the treatment at Well 22 Number -- Water Treatment Plant Number 1. 23 Q: Is this once again a schematic, or is 24 an -- a schematic of North Battleford? 25 A: This is a schematic applicable to North

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1 Battleford. 2 Q: Okay? 3 A: Basically, we get raw water coming in 4 from the Well field. It is pumped in and then can be 5 distributed to four (4) pressure filters. These pressure 6 filters are fairly large diameter; eight (8) and ten (10) 7 foot diameters, very high. 8 They contain an upper section which has lava 9 rock in it. And the lava rock is a porous medium. They 10 inject air up through the lava rock. The water falls against 11 it and the purpose of this is to add air to oxidize the iron, 12 the soluble iron in the water. 13 The water then passes from there through a 14 filter media and then out to the clear Well. 15 Q: What's -- what's in the filter media? 16 A: The filter media is primarily sand. I -- 17 there might be some anthracite. I'm not fairly sure, but I 18 think it's primarily sand. 19 I should point out that in terms of the 20 groundwater supply quality, it is -- would be considered to 21 be quite good. The major issues related to iron and 22 manganese that are in the water in concentrations that are 23 unacceptable. 24 So we have four (4) pressure filters. The 25 effluent from the pressure filters is then collected. There

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1 is a sequestering agent, which is really a sodium 2 tripolyphosphate. 3 It is added to the filtered water and the 4 purpose of this is to sequester, or to hold in solution, the 5 manganese because manganese is not removed during the 6 treatment process. 7 The water then is -- is disinfected with 8 chlorine, stored in a clear Well underneath the plant floor 9 and then sent on to the city. 10 Q: So this is a very different process from 11 the one we've been looking at in relation to Number 2 plant? 12 A: That is true. And the purposes and the 13 needs between the two (2) water sources dictate what is 14 required for treatment. 15 Q: Right. So, you outlined for us the 16 principal processes in use in treatment at the Number 2 17 plant. Can you list for us the principle treatment processes 18 and use at the Number 1 plant? 19 A: The principal processes, again, 20 considering that what we're after is control of iron and 21 manganese, the principal processes are oxidation and this is 22 to convert the soluble iron into an insoluble form that can 23 be filtered. 24 Sequestering in an attempt to keep the 25 manganese from precipitating out and causing problems in the

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1 distribution system, or for users -- 2 Q: Right? 3 A: -- and then disinfection. Those are the 4 main processes. 5 Q: So, what kind of problems would the 6 manganese cause in the distribution system, or for users? 7 A: Well manganese is primarily an excet -- 8 aesthetic issue -- 9 Q: Yes? 10 A: -- and can cause staining of laundry and 11 plumbing, things of that nature, tends to discolor the water, 12 these would be of primary concern. 13 Q: Taste issues? 14 A: Maybe not. 15 Q: So basically what's been taken out here 16 is -- 17 A: Iron. 18 Q: -- iron? 19 A: Yes. 20 Q: And that in affect, is the -- is the 21 principal process? 22 A: Iron removal. 23 Q: Iron removal. Can we just summarize 24 the -- in this process, the -- you've told us some of the 25 chemicals being used but can you give us a complete list of

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1 the chemicals that are actually used in this process? 2 A: That's it. 3 Q: That's it? It's the -- 4 A: Sequestering agent. 5 Q: Sequestering agent. 6 A: And -- 7 Q: And the chlorine. 8 A: -- the chlorine. And it's used -- fed in 9 a gas form. Within the plant itself -- oops I better. One 10 (1) of these has got it. Oh, I've got to close it, sorry. 11 This shows the layout of the plant in North 12 Battleford and if I can quickly run you through it. The raw 13 water comes in from the central header, then distributed to 14 the filters. These are the older filters. 15 Q: Do they have numbers? 16 A: Yes. We can call that one (1), two (2), 17 three (3) and four (4). Okay, so, they're smaller diameter 18 but those are the older filters. Then this is constructed, I 19 believe, and then this one (1), separately. 20 So the water runs through the filters as 21 described, is collected in a common header and discharges 22 into the clear Well which underlays this area. The water is 23 then pumped out here into the distribution system and out to 24 the city. 25 If you want to see some pictures of what some

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1 of these things look like. You can see these vessels here? 2 This vessel here is -- be filter number 1. And this would be 3 filter number 2. 4 Q: So these are pressure filters as opposed 5 to gravity filters? 6 A: These are called pressure filters as 7 opposed to gravity filters, yes. The water is actually 8 pumped to them under some pressure. 9 Q: Okay. Pumped to them or pumped through 10 them? 11 A: Well, pumped to them and it goes through. 12 I mean there is residual pressure coming out. 13 Q: Okay. 14 A: Just some other pictures. These filters 15 also have to be cleaned periodically, and backwashed. And 16 that is done normally on a two (2) day rotation. There's an 17 example of -- this I believe is number 3 filter. 18 Q: And are they the same ripening problems 19 with these filters as there would be with the filters at the 20 surface water plant? 21 A: There can be but it's normally not as 22 problematic or not of concern. 23 Q: Because the water to begin with is just 24 -- 25 A: That's right.

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1 Q: -- cleaner water? 2 A: That's right. We're worrying about iron 3 removal. The magic number might be point three (.3) whether 4 we have point two five (.25) or point two eight (.28) is not 5 particularly significant. 6 We'd like to be down lower than that but -- 7 Q: So why is it possible at this plant to 8 ask a simple question to avoid that whole coagulation 9 flocculation, sedimentation process? 10 A: Simply because of the water supply. The 11 groundwater supply is not subject to the turbidity and the -- 12 the other problems associated with surface water. 13 Q: But the -- the treatment that's brought 14 that's brought the water by those processes, how is that 15 effected in relation to this water? Is it because it's -- 16 it's Well water and -- 17 A: Well, groundwater passes through 18 considerable distance of very fine, porous media. So it has 19 a natural filtering system within it. 20 Q: So we're relying upon nature to do those 21 things? 22 A: We do. I don't know, is there other -- 23 we -- this plant is equipped with a generator set which gives 24 auxiliary power if they -- if they need it. We also have an 25 engine driven distribution pump in case of power failures.

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1 These are distribution pumps here as well. 2 Q: Now are there turbidity issues then 3 associated with this water? 4 A: Frankly there is. I mean, this water 5 does have turbidity values that sometimes get a little high. 6 The issue here is, in terms of turbidity, is, and I'm not 7 going to say good or bad turbidity, but the turbidity concern 8 typically from a groundwater plant, would normally be of 9 aesthetic interest versus a health related interest. Just 10 because of the vulnerability of the water source. 11 And you're -- people may be aware that there 12 are two (2) turbidity values in the drinking water quality 13 objectives. One (1) is called a maximum acceptable 14 concentration which is more of a health interest number of 15 one (1) NTU. There is also an aesthetic objective which is 16 five (5) NTU. 17 Now the application of this is typically on a 18 surface water plant, you would apply a one (1) NTU on the 19 water leaving the plant as a maximum, for example. But 20 within the distribution system, it may be acceptable to use 21 up to five (5). 22 Q: I see. So is turbidity testing done at 23 this plant? At the number 1 plant? 24 A: Yes. 25 Q: Is the -- what range is -- different

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1 sites? 2 A: Pardon? 3 Q: Different sites, do we test for raw, do 4 we test for -- 5 A: Well, no. Normally the -- the routine 6 turbidity measurements at water plant number 1 are on the 7 total treated water. 8 Q: Okay. That's the only measurement taken? 9 A: Yes, and that's done manually using bench 10 top equipment. 11 Q: Okay. 12 A: These are simply showing some of the 13 chart recorders, operations, pumpage and this kind of stuff. 14 Q: I see. 15 A: There is also, you know, the plant does 16 have a lab area where they are able to carry out testing, 17 some of the equipment. 18 Q: Now chlorine testing is also done as 19 well? 20 A: Yes. 21 Q: Okay. 22 A: Chlorine test -- iron and manganese. 23 Q: And that -- all of that testing is done 24 in the clear Well? 25 A: Off the treated water, yes.

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1 Q: Treated water? 2 A: There is some raw water testing done but 3 not as frequently. 4 Q: Okay. 5 A: Anything else? 6 Q: Well in this con -- I'm just thinking in 7 terms of testing and to make comparisons with the number 2 8 plant, do we -- are there the same concerns with -- with 9 temperature, with alkalinity, with the other matters that are 10 tested there? Is that -- is that a problem at this plant? 11 Is that something that is monitored and tested for? 12 A: Well, the temperature of the groundwater 13 tends to be relatively constant. It will vary but it tends 14 to be relatively constant. The alkalinity again is 15 relatively constant in the groundwater. 16 So it's -- we don't have the dynamic changes 17 in water quality from groundwater that we might have in 18 surface water. 19 Q: Right. And is there a daily plant log 20 kept at this plant, too? 21 A: There is. 22 Q: Does it follow the same kind of 23 sequencing and recording that we have at the number 2 plant? 24 A: That log is more tailored to number 1 25 plant, operations, in terms of the testing program that's

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1 carried out and other operational features. 2 Q: And I think from what you've told us 3 earlier that the same personnel who operate the number 1 4 plant -- or number 2 plant also operate this plant? 5 A: Yes. 6 Q: Can you tell us something about the -- 7 the relative capacities of these -- of these two (2) plants 8 in terms of their ability to produce water for the city's 9 needs? 10 A: As of when? 11 Q: Well, as of prior to March of 2001, going 12 back over a, you know, a reasonable period of time, a few 13 years, so that we can get the picture and establish what the 14 general trend was? 15 A: Let me comment, sort of vis a vis March 16 of 2001. I believe the capacity of the groundwater plant or 17 the flows -- the groundwater supply was in the order of five 18 hundred (500) gallons per minute. And this would compare 19 with the surface water plant maybe being able to produce 20 fifteen hundred (1,500) gallons a minute. 21 Now, on a daily basis, because the groundwater 22 plant would be operating virtually twenty-four (24) hours a 23 day versus a shorter duration, then they would come pretty 24 close. 25 And probably, the groundwater plant would out

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  1  produce the surface water plant.
  2                 Q:   Purely because it's --it's operating on a
  3  full time basis?
  4                 A:   Right.  That would be a major factor.  In
  5  fact, I mentioned earlier some of the changes, or the
  6  relative contributions from the two (2) sites and I have up
  7  on the screen now, some values between the years 1988 to the
  8  year 2000.
  9                 And typically, you would note that the
 10  groundwater plant would produce in the range of 70 to 90, or
 11  say 80 plus percent on the water production for the city and
 12  the balance of course come from the other -- other plant.
 13                 You would also notice that there is not a
 14  constant line and I attribute some of this due to the change
 15  in the ability to secure groundwater, that is the groundwater
 16  availability may have been decreased.
 17                 Q:   And is that -- that decrease would have
 18  been the -- the result of the -- the Wells not producing as
 19  much, or --
 20                 A:   It could have been a function of the
 21  Wells not producing as much, or alternatively, it could be a
 22  function of demands increasing within the area and there
 23  would be a need for additional Wells to supply the
 24  groundwater.
 25                 Q:   Right.  Are there any times of the year,

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1 seasonal times of the year when one (1) plant is not used at 2 all, or are both plants available for -- for use for the full 3 season, or the full year? 4 A: It's my understanding both plants are 5 able to produce water year around. The operation durations 6 will change seasonally, depending on demands. 7 Q: Right. Now, is it possible to tell, or 8 have you been able to ascertain whether each plant supplies 9 water to a different area of the city distribution system? 10 A: The -- well, if we go back to this system 11 here, let me go back somewhere else here. This is a bit of a 12 pictorial on the water distribution system. Water treatment 13 plant number 2, or surface water plant actively supplies the 14 east side, so it's coming out here. 15 It's probable main sphere of interest is on 16 the east side and on the north part here. 17 Q: Okay. 18 A: And the water treatment plant number 1 19 really serves this area in here. 20 Q: Okay. But both water supplies are mixed 21 within the system; is that true? 22 A: In some parts of the system they may not 23 be mixed. 24 Q: How -- 25 A: Particularly on the -- nearest the

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1 plants. 2 Q: Oh, yes. Okay. 3 A: And there may be areas here it gets where 4 there may not be too much mixing. Essentially -- do you want 5 to talk about the reservoirs now, or do you want to leave 6 that until later? 7 Q: I was just coming to that after you've 8 done this, but go ahead. Go ahead. 9 A: Okay. We have a series of reservoirs in 10 the community which we alluded to earlier this morning. This 11 114th underground reservoir largely gets its water from water 12 plant number 2. 13 And it has a capacity of three-quarters of a 14 million gallons, when at the time of -- of interest here, it 15 was on a manual operation, that is they had to physically go 16 and either fill it or pump it. 17 Q: Okay? 18 A: It was being retained largely for fire 19 protection purposes so there would be a reserve of water 20 available in case in the event of fire and the need was in 21 the city. 22 Q: So how long could the -- the water remain 23 in that reservoir? 24 A: A number of days. 25 Q: Is it days or weeks or, if it's for --

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1 A: I would think probably more a number of 2 days. 3 Q: Okay? 4 A: The major, of course, and I say major 5 only because it has such a high profile, is the water tower. 6 Its capacity is seven hundred and fifty thousand (750,000) 7 galls as well. It normally operates between ten (10) and 8 twenty-five (25) feet and that ten (10) and twenty-five (25) 9 feet is what's measured in the expanded portion -- 10 Q: Right? 11 A: -- of the actual storage point. The 12 water level in -- in this reservoir is very instrumental in 13 the operations of the facilities of the city. 14 For example, number 2 water plant's filling or 15 operational duration may be contingent on the water level in 16 the tower, sort of a key indicator on the storage capability 17 within the city. 18 Q: It's contingent in what ways and for what 19 reasons? 20 A: Well, for example, if the water tower was 21 full or virtually full -- 22 Q: Yes? 23 A: -- they may not choose to operate water 24 plant number 2. 25 Q: So it's -- is it necessary then to keep

200
  1  that tower full?
  2                 A:   Well, it's always nice if you can, but
  3  that doesn't happen because we do have consumers that --
  4                 Q:   Right?
  5                 A:   -- use the water.  This --
  6                 Q:   But at least you have to keep it -- do
  7  you have to keep it up to a certain level?
  8                 A:   Oh, absolutely, I mean you have to keep
  9  it -- you have to have enough pressure in your system to keep
 10  the water above the bottom of the base for sure --
 11                 Q:   Right?
 12                 A:   -- at least you want to.  I should point
 13  out that -- and these reservoirs, I didn't mention that in
 14  114th and this reservoir and the other one (1) are all served
 15  by a single pipe, that is the water is either filling or
 16  emptying, but it always goes through the same pipe --
 17                 Q:   I see?
 18                 A:   -- you can't have simultaneous filling or
 19  withdrawal from these reservoirs.
 20                 Q:   So is the function of the tower to keep
 21  the pressure in the system?
 22                 A:   Well, the function of the tower is two
 23  (2) fold, one (1) is to provide storage --
 24                 Q:   Yes?
 25                 A:   -- and it also acts as a pressure --

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1 pressure device and a bit of a surge tank, but I -- 2 Q: But if you didn't need the -- the 3 pressure, would you not be able to provide that storage 4 easier in a reservoir? 5 A: I don't -- not sure what easier is. One 6 (1) of the advantages of -- of a water tower is you don't 7 repump. If you have underground storage, you -- delivering 8 water into that storage, you're pumping it, to get the water 9 out of that underground storage, you have to pump it again. 10 Q: Okay. So what would -- what would happen 11 if the -- the water in the tower fell below the required 12 level? What would be the consequences? 13 A: Well, we -- the city would be very 14 worried about fire protection depending on the capacities of 15 the other reservoirs. I think, if it was getting very low 16 and the plant production was unable to keep up, then 17 certainly they probably get some water into the system from 18 the underground reservoirs. 19 Q: Okay. But the idea is to keep that tower 20 up? 21 A: Well, to keep it up to a satisfactory 22 level, yes. 23 MR. COMMISSIONER: Just on the point you 24 raise, Mr. McDonald, the 114th Street reservoir -- 25 THE WITNESS: Yes.

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1 MR. COMMISSIONER: -- and indicated the time 2 it was basically being maintained for firefighting 3 purposes -- 4 THE WITNESS: Yeah. 5 MR. COMMISSIONER: -- and that the value of 6 the water for drinking purposes was probably measured in a 7 matter of days. 8 THE WITNESS: The which? 9 MR. COMMISSIONER: The suitability of it as 10 drinking water would be determined or could be affected if 11 the water remained there a number of days, as I understood 12 you? 13 THE WITNESS: Well, the only deterioration, I 14 think that's what we're talking about, whether the water 15 quality would deteriorate, I think the major issue in terms 16 of long residence time in that reservoir is whether an 17 adequate disinfectant level would be maintained. 18 MR. COMMISSIONER: Hmm hmm. 19 THE WITNESS: And that's probably the only 20 issue. 21 MR. COMMISSIONER: Right, okay. So the only 22 issued I'm asking about is, was this -- I'm not clear what 23 this 114th Street reservoir role was in the overall drinking 24 water available in the city. 25 THE WITNESS: It's not specifically, at least

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1 I don't it's specifically related, other than we're trying to 2 give you an overview of the system and how it functions. 3 MR. COMMISSIONER: Well, I understand that, 4 but I'm interested in the drinking water for the moment, not 5 the water that fights fires. 6 THE WITNESS: Well, no, but this water would 7 also be used for drinking. 8 MR. COMMISSIONER: All right. Then I 9 misunderstood you on the reservoir, on the 114th Street. I 10 got the impression that water was just sitting there for days 11 at a time, waiting for some use if it should develop? 12 THE WITNESS: No, I think the question was 13 how long would it sit there, could it sit there? And I think 14 you're wondering whether it may be longer than weeks, or into 15 weeks. 16 MR. COMMISSIONER: Yes. 17 THE WITNESS: And I suggested it probably 18 wouldn't be that long. It would probably be in a matter of 19 days. It did have to be operated manually though, in terms 20 of integration with the distribution system. 21 MR. COMMISSIONER: Right. 22 THE WITNESS: And certainly one (1) of the 23 functions of that reservoir was to keep a base volume in 24 there for fire protection. Not necessarily the entire volume 25 in the reservoir, but at least a portion of that volume --

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1 MR. COMMISSIONER: Okay. 2 THE WITNESS: -- within the reservoir. 3 MR. COMMISSIONER: All right. Thank you. 4 5 CONTINUED BY MR. JAMES RUSSELL: 6 Q: So that if the -- if the demand for 7 drinking water required, someone could go to that reservoir 8 and manually -- 9 A: Absolutely. 10 Q: -- add more water into the drinking 11 system? 12 A: Yes. 13 Q: And in order to maintain the quality of 14 that water, did it -- did it have a chlorination process 15 attached to it? 16 A: It did not, at the time. The other, one 17 (1) of the other features is the -- there is a booster 18 station as well. And that's mainly to increase pressure 19 because we have a variation in topography in North 20 Battleford. 21 The north end is a lot higher, so we have to 22 get the water up there. The tower pressure's really not high 23 enough to get water up here. 24 The other reservoir that we have is the one 25 (1) in Fairview Heights, called the Fairview Reservoir, and

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1 it supplies water during peak demand. It is normally 2 operated by a timer. It'll be set so it may pump out for a 3 number of hours a day and in certain time periods, normally 4 to coincide with the high demand periods. 5 Q: Once again, is the same pipe used? 6 A: The same pipe is used, yes. 7 Q: Okay? 8 A: And it has a larger capacity of a million 9 (1,000,000) gallons. That -- as of March 2001, there was a 10 chlorination capability at that station. 11 Q: Okay. Can you tell us a little bit about 12 the distribution system in general? I mean, what are the 13 physical components of that whole distribution system? 14 What's -- what's it made from? 15 A: Well, the distribution system includes 16 the pipes that deliver water and these, I think, can vary 17 from say sixteen (16) inch diameter, the primary main, down 18 to probably the smallest pipe would be a six (6) inch 19 diameter pipe of probably varying materials, depending on 20 when it was constructed. 21 Cast iron could have been used, asbestos 22 cement could have been used. Polyvinyl chloride or PVC could 23 have been used. On the larger sections, there could be some 24 steel. 25 So, it -- the distribution system includes the

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1 water mains; these are the water mains of varying sizes. 2 There would be a system of valves on these mains for 3 isolation purposes and fire hydrants. And attached to all of 4 this would be the connections to provide water to the various 5 consumers. 6 Q: Okay. Now, in terms of monitoring and 7 testing within that distribution system, what's your 8 understanding of how the monitoring test -- and testing 9 requirements are established for the City of North Battleford 10 for the distribution system? 11 A: In terms of the bacteriological testing? 12 Q: Well, any testing -- any of the testing 13 that needs to be done in the distribution system? 14 A: Can we go back and just review the permit 15 requirements? 16 Q: Well, I was going to say, in the course 17 of your work, have you -- have you reviewed the current 18 Minister's Order for waterworks -- 19 A: I have reviewed it. 20 Q: -- issued pursuant to the Environmental 21 Protection Act? I believe it's at tab 6 -- 22 A: Yes. 23 Q: -- in your exhibit binder? 24 A: Yes. 25 Q: In the Roger McDonald exhibit binder?

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1 A: Yes. 2 Q: Tab 6, is that the -- is that the current 3 Minister's Order? 4 A: As I understand it, it is the present 5 one(1), yes. 6 Q: Paragraph two (2) of that order says, if 7 I read it correctly: 8 "That the city shall monitor water quality 9 pursuant to the attached waterworks 10 monitoring schedule." 11 Do you agree that that's what it says? 12 A: I agree. 13 Q: And is the -- is the waterworks 14 monitoring schedule that the city follows the one which 15 accompanies that Order under tab 6? 16 A: This is the one I understand they 17 endeavour to follow -- 18 Q: Okay? 19 A: -- in terms of regulatory compliance 20 monitoring. 21 Q: Now do you agree with me that -- that 22 this schedule requires the city to test and sample water at 23 various sites and locations as identified in that schedule? 24 A: True. 25 Q: Now do you agree that from what we've

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1 discussed so far today that some of those sites and locations 2 and the tests that need to be done under this waterworks 3 monitoring schedule in relation to both the surface water 4 treatment plant and the groundwater treatment plant, that 5 we've already discussed, some of the testing contained in 6 this Order as it pertains to those two (2) plants? 7 A: Yes. 8 Q: Okay. Is it your understanding that in 9 conducting tests in the distribution system that this 10 monitoring -- waterworks monitoring schedule was the one (1) 11 in use by the city prior to the 2001 contamination? 12 A: It would have been, yes. 13 Q: Now one (1) of the tests I see required 14 here in the schedule is bacteriological testing; do you 15 agree? 16 A: Hmm hmm. 17 Q: And I believe the schedule says it has to 18 be done three (3) times per week from a representative 19 locations in the distribution system? 20 A: Three (3) sites per week, yes. 21 Q: And it also says that the samples are to 22 be submitted to the H.E. Robertson Provincial Laboratory in 23 Regina? 24 A: Yes. 25 Q: Is that the case? Can you show us where

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1 those sites, those testing sites were? 2 3 (BRIEF PAUSE) 4 5 A: Not specifically. I don't have a plan on 6 the screen that I can specifically identify. 7 Q: And how many sites were there, prior to 8 2001? 9 A: Five (5) major sites. 10 Q: Five (5) major sites. Any minor sites? 11 A: No. 12 Q: Okay. 13 A: Except for some backups. 14 Q: Now what's your understanding of the 15 procedure involved in doing that test in a distribution 16 system and how the city went about doing it prior to 2001? 17 A: In terms of bacteriological testing? 18 Q: Yes? 19 A: Well, first of all one would have the 20 proper sterile container for collection of the sample. And 21 these would -- are acquired through the provincial 22 laboratory, the H.E. Robertson Laboratory. These particular 23 bottles are treated with a sodium thiosulphate or they have a 24 sodium thiosulphate tablet to extinguish any chlorine 25 residuals.

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1 They're -- and they're sterile of course. The 2 procedure would be to select the -- at the sampling site, 3 ensure that there's no problems with the faucet or wherever 4 it's being sampled in terms of aeration or that a proper 5 sample -- representative sample can be taken. 6 The water would be run for a period of time to 7 ensure that the water is reasonably fresh and not stagnant 8 within their internal plumbing system. And a sample 9 collected, careful -- being careful that there's no contact 10 with hands or other things that may contaminate the sample. 11 During this process -- during the 12 bacteriological sampling collection, there will also be 13 sample collected and at that time there would be a 14 determination of chlorine and turbidity or a sample would be 15 collected and taken back to a plant and chlorine and 16 turbidity would be determined. 17 Q: Right. From the same sites? 18 A: From the same sites in -- at 19 approximately the same time. 20 Q: And who was doing that testing prior to 21 March of 2000? 22 A: One (1) of the staff members of the 23 engineering public works I think was doing it primarily. 24 Q: It -- it wasn't in -- 25 A: In -- in recent year -- in the recent

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1 year. 2 Q: In the recent year. So it wasn't anyone 3 involved at the -- any of the water plants, it wasn't any of 4 the operators who would do that testing? 5 A: I believe at one time the manager may 6 have undertaken some of that work. 7 Q: But individual plant operators? 8 A: As far as I know, they didn't routinely 9 do it unless they were called in to the breach in case of the 10 need. 11 Q: Okay. Now, how and where was that 12 information recorded, you've said that three (3) tests were 13 done at these sites, chlorine testing was done, the 14 bacteriological testing was done and turbidity testing was 15 done -- 16 A: Yes. 17 Q: -- how was that information recorded? 18 A: Normally it was entered on the submittal 19 forms to the laboratory. 20 Q: And which of those tests were submitted 21 to the laboratory? 22 A: The bacteriological tests -- 23 Q: Right? 24 A: -- but, on the bacteriological test 25 submission form, there is spaces for entry of turbidity and

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1 chlorine residual information. 2 Q: Okay. And have you -- have you 3 reviewed -- what happens to the -- what happens to the test 4 results after it goes to the laboratory? 5 A: The test results on a routine basis are 6 then returned to the city, a copy of the form with the result 7 is returned to the city. If there is a particular problem, 8 then the Health District or Saskatchewan Environment and 9 Resource Management may be notified. 10 Q: Okay. And when the -- when it comes back 11 to the city, is there -- is there a log made of this testing 12 in the distribution system? 13 A: I have seen summary data on -- on Excel 14 spreadsheets, for example, maintained. 15 Q: So this information is merely contained 16 on a spreadsheet on a computer somewhere, there's no -- 17 there's no log as there is in relation to the surface water 18 plant? 19 A: I'm not -- I'm not sure what you mean by 20 a log. If you're referring to that computer printout, it 21 would be an internal database system within the city. 22 Q: Oh. Referring to the -- the daily plant 23 log that is kept for the surface water plant. 24 A: The computer generated daily plant log? 25 Q: Yes. Is a similar log generated for the

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1 distribution system? 2 A: No, but there are summaries for each of 3 the sampling sites and the values and the time of sampling. 4 Q: But they exist on a computer? 5 A: Well, and printed out. 6 Q: And then printed out from time to time? 7 A: Yeah. 8 Q: And -- and how long has that recording 9 system been in place, are -- are -- do you know that? 10 A: I do not. 11 Q: Okay. So do you know how far those 12 records go back? 13 14 (BRIEF PAUSE) 15 16 A: Well, certainly two (2) years and it may 17 be longer, but -- 18 Q: Okay. You've seen -- you've seen two (2) 19 years? 20 A: I think I've seen two (2) years, yes. 21 Q: The chlorine testing, it's -- it's for 22 both free and total chlorines? 23 A: Yes. 24 Q: Okay. If you look at the waterworks 25 schedule at -- we just identified as attached to the -- the

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1 Minister's order -- 2 A: Hmm hmm. 3 Q: -- it requires other testing to be done 4 on a less frequent basis in the distribution system; is that 5 the case? 6 A: Yes. 7 Q: And I think these are tests for general 8 chemicals, health and toxicity and trihalomethanes? 9 A: Right. 10 Q: Perhaps you can tell us what 11 trihalomethanes are? 12 A: Trihalomethanes are products -- are 13 disinfection byproducts, but essentially products formed when 14 chlorine reacts to certain organic substances. 15 Q: Okay? 16 A: And some of the common ones might be 17 known as chloroform as a trihalomethane. 18 Q: But what's the concern there? 19 A: There has been some concern related to 20 trihalomethanes and the potential implications in cancer. 21 Q: Okay? 22 A: And there are guideline limits set for 23 trihalomethanes. 24 Q: Okay. These additional tests are 25 necessary under the monitoring schedule. Who does that

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1 testing for the city? 2 A: Trihalomethanes? 3 Q: No, for the whole -- the whole gambit of 4 tests I just mentioned. The general chemicals, the health 5 and toxicity and the trihalomethanes; who does that testing? 6 A: Oh, a laboratory. A service laboratory. 7 Some of it could be done at the provincial laboratories. 8 Some of it could be done at Saskatchewan Research Council, 9 for example. 10 Q: Okay. But who does the sampling? 11 A: The sampling would be done by the city. 12 Q: By the city. And would it be forwarded 13 to those laboratories? 14 A: Yes. 15 Q: Okay. Now, besides the testing that is 16 mentioned in the Waterworks Monitoring Schedule, was the city 17 conducting any other tests, or sampling in the distribution 18 system at that time? 19 A: Within March of 2001? 20 Q: Yes, or immediately prior to? 21 A: I'm unaware of any. 22 Q: Okay. Is there any maintenance required 23 of that distribution system? Is there a routine maintenance 24 procedure? 25 A: Yes, there is. The -- there is flushing

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1 carried out. 2 Q: What's flushing? 3 A: Flushing is running large volumes of 4 water through the system. This is often carried out in 5 conjunction with testing of hydrants, which is of 6 considerable interest to the fire department. 7 The city does have a stage program of swabbing 8 the lines. Swabbing the lines involves insertion of a -- a 9 foam, what we call a pig or a swab, into the system and using 10 water pressure forcing it through. 11 It's under compression and it tends to clean 12 the interior -- interiors of the pipes. Of course, there are 13 frequent -- there are periodic requirements for the 14 maintenance of valves, or replacement of valves and -- and 15 other pertinences. 16 Q: Now, this swabbing and the flushing, are 17 they -- are they routine maintenance procedures? 18 A: As I understand it, they are. 19 Q: Okay? 20 A: Now, in some -- again, I -- I say that at 21 some point there is some sharing with the fire department, in 22 terms of the flushing program because the fire department 23 obviously has considerable interest in the fire hydrants and 24 the ability to use them. 25 Q: Okay. Now, all of these procedures in

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1 relation to the distribution system; the testing, the 2 monitoring, the maintenance, I think you mentioned -- you 3 mentioned earlier that the -- the plants' operators may have 4 been involved in some of the -- the test sampling for 5 chlorine for instance in the past, but on a -- only on an 6 occasional basis. 7 Apart from that, are the plants' operators 8 involved in any way in the -- in the -- in the maintenance 9 and operation of that distribution system? 10 A: They seem to have considerable 11 familiarity and activity with respect to some of the 12 reservoirs. 13 Q: Hmm hmm? 14 A: Particularly the underground reservoirs 15 and the booster station. 16 Q: Would they have occasion to go there for 17 any reason? 18 A: To which? 19 Q: Would they have occasion to go to those 20 sites for any reasons -- 21 A: Yes. 22 Q: -- as part of their job? 23 A: Yes. One (1) thing I should point out, 24 like the water levels in these reservoirs is maintained 25 centrally at the sewage treatment plant. So the operators

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1 have access to the water levels, what's happening in these 2 reservoirs. 3 Q: The record for them is maintained at the 4 sewage treatment plant? 5 A: They have information respecting what the 6 current status of the reservoir, what the water level is in 7 these reservoirs. 8 Q: Okay? 9 A: It's transmitted to the city's treatment 10 plant. 11 Q: So this is essential -- 12 A: It's a real-time observation. 13 Q: Okay. So, when they come to work at the 14 sewage treatment plant they can, for instance, see 15 immediately -- 16 A: They can see what the elevations or the 17 levels are in the various -- in the reservoir. 18 Q: In the tower? 19 A: Yes. 20 Q: Okay? 21 Mr. Commissioner, in relation to the -- the 22 system, we have one (1) major area left, which is the -- the 23 sewage treatment aspect of this. 24 MR. COMMISSIONER: Hmm hmm. 25 MR. JAMES RUSSELL: That will certainly take,

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1 I think, longer than the time we have left available for us 2 today. I could, if you wish, make a start with that, or we 3 might begin fresh with that on some other occasion. 4 MR. COMMISSIONER: Well, I think we've 5 probably, and the witness has probably had about as much as 6 he would like to have for one (1) day. 7 And so certainly, we're close enough to five 8 o'clock that we're not bending too many rules. It's fair to 9 say we would terminate now and start again tomorrow 10 morning. 11 MR. JAMES RUSSELL: I believe -- 12 MR. COMMISSIONER: And I -- did you receive 13 any concerns about starting at 9:30 a.m. tomorrow morning? 14 MR. JAMES RUSSELL: I have not received any 15 personally, Mr. Commissioner. To -- tomorrow morning we have 16 had some indication from one (1) of our other witnesses, Dr. 17 Belosevic that his availability is confined to tomorrow. 18 He is the -- going to give us the biological 19 aspects of -- of the picture. And our hope would be that, of 20 course, we can -- we can finish with him tomorrow and if 21 it's -- if it's okay with you, we would like to start with 22 Dr. Belosevic so that we can get that side of the picture out 23 of the way, and then resume with Mr. McDonald as soon as 24 we've finished that process. 25 MR. COMMISSIONER: Yes. Well, I take it no

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1 one has any exceptions. In effect, we will stand Mr. 2 MacDonald down here from this other witness and then resume 3 with Mr. MacDonald then. 4 MR. JAMES RUSSELL: Thank you, Mr. 5 Commissioner. 6 MR. COMMISSIONER: All right. And that will 7 be at 9:30 a.m. 8 MR. JAMES RUSSELL: I think so. 9 MR. COMMISSIONER: All right. We'll adjourn 10 until 9:30. Thank you. 11 You're free to step down. 12 13 (THE WITNESS RETIRES) 14 15 --- Upon adjourning at 4:47 p.m. 16 17 18 19 20 21 22 23 24 25