Day 009 - 08 Jul 94 - Page 44


     
     1        A.  Correct.  It is not a flat surface.  A pulp tray is a
              tray with the recessed pockets for drinks.
     2
         Q.   Right, OK.  The food trays are plastic; is that right?
     3        A.  The plastic trays, if you were to go to our restaurant
              and order a meal and bring it back to your seat in the
     4        restaurant, would be a plastic tray roughly the size of,
              what, two feet wide and a foot and a half deep covered
     5        with the tray liner.
 
     6   Q.   Right.  The tray liners have usually some promotion or
              something like that on them, have they not?
     7        A.  Yes.
 
     8   Q.   So that is one of the purposes of the tray liner?
              A.  Yes.
     9
         Q.   I think in 1990 you said that was when the polystyrene
    10        recycling scheme was underway in a large number of stores,
              is that right, or was it 1989?
    11        A.  We had started our polystyrene recycling test in 1989,
              and it went all the way through towards the end of 1990,
    12        yes.
 
    13   Q.   Was that financed in any way by the national polystyrene
              recycling coalition?
    14        A.  No.
 
    15   Q.   It was not?
              A.  No.  The way that was financed is through, well, we
    16        had to pay for McDonald's.  The cost to McDonald's in
              simplistic terms was the extra transportation to cart the
    17        materials to the recycling centre, and we had to make
              arrangements with hauliers to pick it up and then pay for
    18        their services.  We also had to pay for the educational
              materials in separate bins.  Again all that money was paid
    19        for by McDonald's.
 
    20        We received -- just to complete the cycle -- we would have
              our polystyrene delivered to the recycling centre, and at
    21        points in time it had some value by the national poly
              recycling company.  I recall at one point in time they
    22        agreed to pay us three cents per pound, but that was not
              financing, that was a matter of what material was worth to
    23        them as a raw material for the recycling process.
 
    24   Q.   OK.  We heard from Mr. Kouchoukos that McDonald's has used
              incineration as a method of waste disposal of polystyrene?
    25        A.  That is not what you heard from Mr. Kouchoukos.  What
              you heard was the fact that in the United States today as 
    26        we speak, roughly 10 to 13 per cent of the municipal solid 
              waste stream is incinerated.  Obviously, whatever portion 
    27        of McDonald's waste that is in the waste stream, that
              would follow the path, the same path.
    28
         Q.   Were there not some stores that set up, I think they were
    29        called Archie McPuffs for incineration on store?
              A.  Yes, we conducted some tests in the late 1980s.  We
    30        had a two store test.  We had an on site incinerator on
              two of our restaurants.  What we were testing at that time

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