Day 011 - 12 Jul 94 - Page 03

     1        not reduce in volume but, in fact, is crushed upon itself
              so there are airspaces within that, what is left of that
     2        package.
     3   Q.   Are you aware of research done at the University of
              Arizona which shows polystyrene foam is more compactable
     4        in a landfill site than paperboard?
              A.  I am aware of research at that university regarding
     5        the topic "garbology" by Mr. William Rathjay(?).  I am not
              aware of that particular statement.  We did identify
     6        Mr. Rathjay's research and we did not find it to be, in
              general, particularly convincing.
         Q.   You would not agree then that in a landfill site an
     8        estimate of the density of polystyrene foam, once crushed,
              is three pounds per cubic feet?
     9        A.  No, I would not agree.
    10   Q.   Your figures give a density or specific gravity, if you
              like -- I prefer the word "density" -- a density of 0.0058
    11        pounds per cubic foot, do they not?
              A.  Sorry?
         Q.   If you divide 70 million pounds by 1.3 billion cubic feet,
    13        you get a density of .0058 pounds per cubic foot, do you
    14        A.  I do not have a calculator here to check your figures.
    15   Q.   That suggests you did not take the element of compaction
              or compactability into account at all when you gave that
    16        figure?
              A.  Again, as I said, I do not agree with the notion that
    17        compaction in a landfill will necessarily result in a
              reduction of any significance in the volume of foam.
         Q.   Your calculation, or your figure, suggests simply that the
    19        polystyrene foam used by McDonald's just sits around in
              large mountains or hills, does it not?
    20        A.  Yes, I suppose that is an assumption.
    21   Q.   Yes.  That is not what happens in a landfill site, is it?
              A.  Well, what happens in a landfill site is that the
    22        trash is dumped.  Then it is run over by heavy equipment.
              But that does not assume that the foam does not revert
    23        back to a previous shape when it has been run over, or any
              other material does not revert to a previous shape when it
    24        has been run over.
    25   Q.   When it has been put on top of the landfill it is run over
              by heavy vehicles.  The reason for that might be, might it 
    26        not, Mr. Lipsett, so that you can put other material, 
              whether of the same kind or a different kind, on top of 
    27        it, yes?
              A.  True.  Actually the reason it is run over and crushed
    28        is because by the end of the day it is required by law to
              be covered by dirt.
         Q.   So, to make the maximum use or optimum use of the landfill
    30        site, you need to crush the contents as far as you
              possibly can, do you not?

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