Day 011 - 12 Jul 94 - Page 04

     
     1        A.  Well, the point is that no landfill is filled to
              capacity because of, by weight, it is filled to capacity
     2        by volume.  Landfills are not filled because -- let us put
              it differently.  A landfill is not closed because it
     3        weighs too much.
 
     4   Q.   For a given volume, the greater the density of material,
              the greater the weight of material within that given
     5        volume, correct?
              A.  Sorry, would you ask that question again?
     6
         Q.   The more you squash things, the more things you can get
     7        into the hole?
              A.  Is that the same question?
     8
         Q.   Yes.
     9        A.  The more you squash things, the more you can get them
              into the hole, yes, that is right.
    10
         Q.   McDonald's polystyrene foam waste does not lie around the
         United States of America in uncontrolled mountains, does
              it?
    12        A.  Well, it depends at what point you are talking about
              in the disposal process.  If you are talking about styrene
    13        foam lying around in mountains in a landfill, no, the
              landfill is a compilation of a large body of waste from a
    14        number of sources.  If you are talking about McDonald's
              foam in its dumpsters, then you are talking about
    15        uncompacted foam.  If are you talking about McDonald's
              foam in recycling facilities you are talking about very
    16        large piles of foam.
 
    17   Q.   Those are transitory stages.  The landfill is supposed to
              be the terminus, is it not?
    18        A.  Yes.
 
    19   Q.   So, whatever the volume in cubic feet of the polystyrene
              foam in its transitory state, what one must look at to
    20        judge fairly McDonald's contribution to the municipal
              waste stream is how it ends up?
         A.  Yes.
 
    22   Q.   That is either by incineration, where its volume is
              reduced to practically nothing, or else in a landfill
    23        site?
              A.  Its volume is not reduced to practically nothing.  Its
    24        volume is transferred into the air.
 
    25   Q.   In terms of billions of cubic feet, incineration reduces
              those billions of cubic feet, whatever other substances 
    26        may be liberated, in terms of volume of polystyrene foam 
              incineration reduces the polystyrene foam to practically 
    27        nothing in terms of volume?
              A.  No, according to the laws of physics the incineration
    28        of polystyrene foam cannot destroy the matter in the foam
              such that the volume of the package is made to no longer
    29        exist.  It is merely transformed into another phase.
 
    30   MR. JUSTICE BELL:  Yes, but hold on a minute, quite a
              proportion of the volume is just air, I mean, what we call