Day 011 - 12 Jul 94 - Page 07

     
     1        type of material that has a memory as to its shape to some
              degree; that it can -- to put it differently, if you take
     2        a foam package and you squeeze it in your fingers and then
              you let it go, the foam package goes back to its shape.
     3
         Q.   So far as the interests of society at large are concerned,
     4        Mr. Lipsett, the figure that matters is the amount of
              space which, when it has done its journey, McDonald's
     5        waste will occupy?
              A.  That is right.
     6
         Q.   Correct.  This figure is misleading, is it not?
     7        A.  As I have said, it could be an under estimation.
 
     8   Q.   Are you really saying that in a landfill site polystyrene
              foam has a density of --  I will just get the figure --
     9        0.0054 pounds per cubic foot, as little as that?
              A.  You are referring to a study by Mr. Rathjay, are you
    10        not?  You are referring to a figure derived from a study
              by Mr. Rathjay.
    11
         Q.   No, I am not. I am using your figures.
    12        A.  That figure is -- please?
 
    13   Q.   I will explain it again.
              A.  Yes.
    14
         Q.   I have taken your cubic footage, the one suggested in your
    15        statement, 1.3 billion cubic feet?
              A.  Yes.
    16
         Q.   I have divided that into the number of pounds used by
    17        McDonald's in 1987, which is roughly 70 million.  That is
              the way to arrive at the density, is it not?
    18        A.  No, as I said, we multiplied the volume.
 
    19   Q.   Bear with me.  If you want to find out what the density of
              a substance is, you divide the cubic footage into the
    20        pounds, do you not?
              A.  OK.
    21
         Q.   You want to know the number of pounds per cubic foot?
    22        A.  That is fine.
 
    23   Q.   This comes out at .0054 pounds per cubic foot, according
              to your calculations?
    24        A.  OK, as I say, I do not have a calculator ------
 
    25   Q.   Do you say that that is a realistic density for
              polystyrene foam in a landfill site? 
    26        A.  I say it is a realistic density for McDonald's foam in 
              the waste stream. 
    27
         Q.   I do not want to go over old ground.  You agreed with me,
    28        I think, that the point in the waste stream which matters
              is where the waste ends up?
    29        A.  Yes.
 
    30                       Re-Examined by the defendants.