Day 007 - 06 Jul 94 - Page 55


     
     1   Q.   Have you taken it down directly, you know, word for word,
              what is written in their document?
     2        A.  For the consumptions assumably I would have, but my
              recall on how I translated the numbers is vague.
     3
         Q.   So they say that, is it Dupont say that you would use
     4        three pounds of CFCs per refrigerator?
              A.  Right.
     5
         Q.   Is that right?
     6        A.  And other than their source, I would have no clue.
 
     7   Q.   Right.  You see, when packaging is used it is thrown away
              directly afterwards, is it not?
     8        A.  It is.
 
     9   Q.   But when you buy a refrigerator, generally speaking, you
              keep it for more than a day or two days?
    10        A.  Yes, that is a valid point, but these were annual
              sales so this is an annual consumption based on -- versus
    11        an annual consumption so year after year new refrigerators
              are made that consume these quantities.
    12
         Q.   Except that your argument says there are 85 million
    13        households in the USA and that each one of them uses a
              refrigerator consuming three pounds of CFCs, and that the
    14        total of that would be 265; the implication from that is
              that you are just counting every refrigerator in the USA?
    15        A.  Where are you reading that from?
 
    16   Q.   Page 37.
              A.  OK.
    17
         Q.   OK, per year, sorry.
    18        A.  There is -- was there a question?  I am sorry.  I lost
              track.
    19
         Q.   Yes.  I am a bit confused about what you are saying about
    20        what these figures are.  As I understand them, your
              argument is here that there are 88 million households in
    21        the USA and that you say it is safe to assume each
              household has a refrigerator each consuming three pounds
    22        of CFCs, which gives you a total of 265 million pounds?
              A.  OK.  I think that was just for a frame of reference.
    23        I do not think I used it in subsequent calculations, or
              did I?  No, I do not think so.
    24
         MR. JUSTICE BELL:  When you use refrigerant, how much of that
    25        is actually sealed in the equipment?
              A.  Hopefully all of it and then as the charge may 
    26        dissipate and leak out over time, which I think is the 
              case most of the time, and you then have to put a new 
    27        charge, a new loading, into -- I think that is more common
              with cars.
    28
         Q.   What, if anything, is the equivalent of that in home
    29        packaging?
              A.  How much is sealed in a foam package?
    30
         Q.   Yes.

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