Day 007 - 06 Jul 94 - Page 21


     
     1        for -- are these million pounds?
              A.  Yes, they are.
     2
         Q.   In millions of pounds at the bottom.  Are these figures
     3        for the United States?
              A.  They are.  Yes, they are.
     4
         Q.   You say at the top they are the 1987 figures?
     5        A.  Yes.
 
     6   Q.   Have you extrapolated the 1987 figures or are these the
              actual 1987 figures?
     7        A.  These are figures reported to me by the industry.
 
     8   Q.   We see that HCFC 22 has in use 181 million pounds for that
              year?
     9        A.  Yes.
 
    10   Q.   Of which  180 million pounds was used as refrigerant?
              A.  Correct.
    11
         Q.   Do you see that, the last item?
    12        A.  Correct.
 
    13   Q.   But one million pounds, single million pounds as a blowing
              agent?
    14        A.  Yes.
 
    15   Q.   When it says it is used as a refrigerant, that would be
              what?  Obviously refrigerators in houses?
    16        A.  Refrigerators in houses.
 
    17   Q.   Air conditioning units ---
              A.  Yes, also.
    18
         Q.   -- in cars as well as houses?
    19        A.  Yes, both.
 
    20   Q.   Then do we find on the next page after that, page 3 of the
              internal numbering, "McDonald's quantify" -- do you see
    21        that subheading?
              A.  Yes.
    22
         Q.   "Based on materials purchased by Perseco in 1988,
    23        McDonald's consumed about 600,000 pounds  of Formacel S".
              That is HCFC 22?
    24        A.  Correct.
 
    25   Q.   In 1988?
              A.  Correct. 
    26 
         Q.   Then you go on:  "600,000 pounds is 2 per cent of all 
    27        blowing agents used for foam packaging; 600,000 pounds is
              about a quarter of one per cent of all blowing agents
    28        consumed in 1987.  600,000 pounds is less than one 12th of
              a per cent of all CFCs consumed in 1987 in the US; 600,000
    29        pounds is less than one 30th of one per cent of world
              consumption of CFCs."
    30
              Mr. Kouchoukos, what was the purpose of, as it were,

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