Day 007 - 06 Jul 94 - Page 59


     
     1        possibility is that it shifted from 11 and 12 into
              alternatives, but I do not know.
     2
         Q.   You do not know?
     3        A.  No.
 
     4   Q.   You see, the figures given for McDonald's are 1988, are
              they not, so really it is not all that comparable?
     5        A.  It was difficult to compare because we did not track
              certain things in 1987 and there is that conflict of
     6        year.  It assumes that things were constant through the
              following year.  One scenario:  If a billion people in
     7        China suddenly got refrigerators then CFC 11 and the need
              for refrigerants could have gone up tremendously; I do not
     8        know that though.
 
     9   Q.   I think it is right, is it not, that McDonald's ceased
              using CFCs in late 1988?
    10        A.  That is correct.
 
    11   Q.   Right.  You see, you have given us the figures here
              600,000 pounds Formacel-S and Formacel-S is HCFC, is it
    12        not?
              A.  It is.
    13
         Q.   So that does not include the figures for McDonald's use of
    14        CFCs?
              A.  Can you refer me to a document so I can see when that
    15        might have been?
 
    16   Q.   It is page 36, it is under "McDonald's Quantified".
               "Based on materials purchased by Perseco in 1988,
    17        McDonald's consumed 600,000 pounds of Formacel-S".  Your
              argument was that those 600,000 pounds was only two per
    18        cent of all blowing agents used for foam packaging?
              A.  And your question again was, I am sorry?
    19
         Q.   There is no mention of CFCs?
    20        A.  I would have to go back to my records to see if indeed
              we did not consume any CFCs in 1988, I do not recall.
    21
         Q.   You have just told me that CFCs, McDonald's finished
    22        phasing them out in late 1988, so it stands to reason they
              must have been using CFCs in 1988?
    23        A.  That could follow, but it could be that, I am not sure
              with the information I have in front of me when in the
    24        year we phased out.  I could follow that up though, if we
              needed to.
    25
         MR. JUSTICE BELL:  If it were right that McDonald's used some 
    26        CFCs or CFC in 1988, that would have to be added to the 
              600,000? 
    27        A.  Actually, the method I chose to calculate HCFC
              consumption was to look at how many pounds of polystyrene
    28        foam we consumed.  I know that to make the polystyrene
              foam it takes five per cent HCFC or CFC.  So what my
    29        feeling would be that I would have to confirm, if you
              would like, of the 600,000 pounds, the 600,000 pounds
    30        would appear to me with looking at what I have to be an
              inclusive number of either both or just the HCFC and I am

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