Day 007 - 06 Jul 94 - Page 16

     
     1        technology to use as an alternative and to put that in
              place and consume our inventory.
     2
         Q.   Was one of the substances with which CFCs were replaced --
     3        in fact it was CFC 12 I think that was mostly used?
              A.  Correct.
     4
         Q.   Was that substance replaced, to some extent at least, by a
     5        substance called HCFC 22?
              A.  That is correct.
     6
         Q.   Is one difference between a CFC and an HCFC that the HCFC
     7        is only partly halogenated?
              A.  Partially halogenated.  It has a hydrogen added with
     8        it also.
 
     9   Q.   At the time when the change was made by you on behalf of
              McDonald's, were there any perceived hazards, difficulties
    10        or dangers to the atmosphere in the use of HCFC 22?
              A.  They were researching it at the time to try to
         understand what the environmental impact of HCFC 22 might
              be.  They knew the environmental impact of CFC 12 had an
    12        ozone depletion potential, and it was also felt that HCFC
              22 would be much less of an impact and was recommended as
    13        an interim solution.
 
    14   Q.   You will find, I hope, in the stack behind you on a little
              chair a volume pink spine with a Roman V on it.
    15
         MR. JUSTICE BELL:  Can I understand what you just said?  HCFC
    16        22 had not been given a clean bill of health; it was known
              to be significantly less than a CFC?
    17        A.  Correct.
 
    18   Q.   It was treated as something to use until something better
              was found?
    19        A.  Correct.  The hydrogen atom makes it more reactive in
              the lower atmosphere.  There was scientific thought it
    20        would not get up into the upper atmosphere where it could
              do the damage.  It did not have as much chlorine, so it
         was something that was viewed as a temporary solution.
 
    22   MR. RAMPTON:  To expand on that answer, it may help,
              Mr. Kouchoukos, to look at this document which is
    23        behind divider 22 in pink volume V?
              A.  Yes.
    24
         Q.   Have you seen this document before?
    25        A.  Certainly.
  
    26   Q.   Did you see it at the time it was produced, April 12th 
              1988? 
    27        A.  I did.
 
    28   Q.   May I ask you this:  First of all, who are the Natural
              Resources Defense Council, or what is it?
    29        A.  The Natural Resources Defense Council is a "not for
              profit" environmental organisation in our country -- in
    30        the US.  I am sorry.