Day 007 - 06 Jul 94 - Page 88


     
     1   MR. MORRIS:  I think the good news is that is all I have to
              say.
     2
                             Re-examined by Mr. Rampton
     3
         MR. RAMPTON:  I have some questions in re-examination strictly
     4        by way of clarification.  Can I ask you this, when you are
              using CFCs or HCFCs, or indeed a hydrocarbon, as a blowing
     5        agent, Mr. Kouchoukos, which stage in the process does it
              present any risk to the environment?
     6        A.  The majority of the environmental impact would be
              immediately subsequent to its formation, so it would be at
     7        the converter.  It is not -- the most of the release is at
              the conversion facility.
     8
         Q.   Is there any residual environmental risk in the actual
     9        product itself?
              A.  There is residual blowing agent that will probably
    10        just remain in the foam.
 
    11   Q.   So in that regard does it differ from a refrigerating
              agent in a car or a house?
    12        A.  Sorry?
 
    13   Q.   When you fill a refrigerator with a CFC, if that is what
              you do or used to do, is one point of danger to the
    14        environment the filling point or is it more likely the
              release point?
    15        A.  It is difficult to say but it would probably be both.
 
    16   Q.   Can you just have a quick look at your chart on page 34 of
              the yellow bundle 3?
    17
         MR. JUSTICE BELL:  Which page is that?
    18
         MR. RAMPTON:  Page 34, my Lord.
    19        A.  OK.
 
    20   Q.   I have a few page numbers, so I can help.  That table
              makes statements, as I understood it, of simply the amount
    21        of CFCs and HCFCs production used for different purposes
              in the United States in that year, is that right?
    22        A.  Correct.
 
    23   Q.   Does it make any distinction about the, as it were,
              eventual environmental hazard which that use may create?
    24        A.  No, it does not.
 
    25   Q.   So when we see at the bottom, or near the bottom of the
              page, HCFC 22 refrigerant 180 million pounds, are we 
    26        seeing simply a statement of the amount used for 
              refrigerating purposes? 
    27        A.  Yes.
 
    28   Q.   Now another question, Mr. Morris asked you some questions
              about landfill and incineration of polystyrene foam,
    29        I think, do you remember being asked those questions?
              A.  Yes.
    30
         Q.   Can I ask you this?  Do you know, roughly speaking, what

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