Day 007 - 06 Jul 94 - Page 56


     
     1        A.  I have not done those calculations, and I would just
              be speculating at this point.  I know that in a foam
     2        package -- if a package is made under pressure -----
 
     3   Q.   Start from the basics.  What is the mechanism?  I do not
              want to get into the ozone layer itself, but what is it
     4        which has a potential for damage?  Is it the escape of CFC
              gas?
     5        A.  Yes.
 
     6   Q.   Then I can see that whatever escapes in making foam
              packaging is the equivalent of the 2.5 pounds of CFCs used
     7        for foam insulation, or might be painting with a very
              broad brush, but what about the half pound for CFCs for
     8        cooling purposes.  At some stage that may go into -----
              A.  I think up to that point, up until 1989, in disposing
     9        of refrigerators or disposing of automobiles, the
              refrigerants were not recaptured and recycled.
    10
         Q.   When the automobile is crushed, that is your point of
    11        escape, is it, unless there is some kind of accident
              before?
    12        A.  Right, but an automobile will lose -- it is not a
              sealed system in an automobile.  We have to recharge them
    13        every five years or so.
 
    14   MISS STEEL:  Every five years, so we should at least divide
              that by five, the figures you have there?
    15        A.  You can.  I do not know that was relative to the point
              that was being brought there as a consumption figure and
    16        what resulted in that specific application.  I am not
              claiming that those are the same figures as in the annual
    17        consumptions in the front table.  That was just meant to
              point some perspective on where things did go to.
    18
         Q.   It would be about right though, would it not, for your
    19        figures -- I think on page 2 you have 469 million pounds
              used in refrigerants.  Then on page 37 you have -- I do
    20        not know, I mean, can you explain what your figures show?
              I am getting lost, to be honest.
    21
         MR. JUSTICE BELL:  We may be able to do the arithmetic or, if
    22        it is thought to be worthwhile, it can be done later.
              I think the point Miss Steel is making or the point she is
    23        seeking to make, if you look on page 34, subject to
              anything you tell me about blowing agents being sealed
    24        within the foam itself, it looks as if they are released
              into the atmosphere -- using atmosphere in a very general
    25        sense -- aerosol propellants, cleaning solvents and so
              on.  If you buy a cleaning solvent this year in a sealed 
    26        container, it may not be released this year but the one 
              you bought two years will be.  But when we come to 
    27        refrigerants a rather different situation may prevail?
              A.  It certainly could.
    28
         Q.   Putting it at its very lowest, you cannot say just when,
    29        if at all, it is going to be released into the atmosphere?
              A.  No.
    30
         MR. JUSTICE BELL:  That is what you are getting at.

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