Day 011 - 12 Jul 94 - Page 02

     1                                                12th July 1994
     2                        Mr. Lipsett, recalled.
                   Cross-Examined by Mr. Rampton, continued.
         MR. RAMPTON:  My Lord, I am left with landfills so far as
     4        Mr. Lipsett is concerned.
     5   MR. JUSTICE BELL:  Yes.
     6   MR. RAMPTON:  You recall, Mr. Lipsett, in your written report
               -- do you still have it there?
     7        A.  Yes, I do.
     8   Q.   On the penultimate page of text under the heading:  Issues
              Surrounding Polystyrene Foam Food Packaging Disposal, yes?
     9        A.  Yes.
    10   Q.   The second paragraph under that heading at the bottom of
              the page reads as follows:  "Landfill disposal of foam
    11        products results in an over filling of landfills with
              bulky non-degrading plastics.  In the environment these
    12        foam substances do not decay and can be found on beaches
              and littering roadsides when they are not disposed of in
    13        landfills.  CCHW research determined that McDonald's
              contributed 1.3 billion cubic feet of foam packaging waste
    14        to the nation's waste stream annually".
              A.  Yes.
         Q.   Upon what density was that figure of 1.3 billion cubic
    16        feet based?
              A.  Upon what?  Sorry, I did not hear the third word.
         Q.   Upon what density per cubic feet?
    18        A.  Density?
    19   Q.   Yes, pounds per cubic foot?
              A.  The calculation was based on the figure in the Modern
    20        Plastics article where it was stated that McDonald's was
              using 70 million pounds of polystyrene or styrene in
    21        1987.  The calculation was based on deriving the volume
              that that particular material would encompass and, based
    22        on interviews with polymer scientists in the University of
              Maryland, a general figure which would allow us to
    23        calculate what would happen to that volume when it was
              expanded by the blowing agents.  So that the figure was
    24        arrived at by multiplying 70 million pounds by the
              specific gravity of styrene, then multiplying that again
    25        by a factor of 20 which was the figure we were informed
              was the correct figure for the expansiveness, the degree 
    26        to which that volume would expand when foam was blown with 
              gas.  That is how the figure is arrived at. 
         Q.   Yes.  In a landfill site?
    28        A.  Yes.
    29   Q.   Polystyrene is compacted polystyrene foam, is it not,
    30        A.  No, I would say that polystyrene is crushed.  When it
              is crushed it is crushed unevenly.  The actual foam does

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