Demonstration of Client Working Relationship

ECI works closely with all of our clients. Since inception in 1998, ECI has maintained a working relationship with every client that has employed ECI (i.e., over 30 major corporations most of which are listed on the NY Stock Exchange, hospitals, and numerous government entities). ECI approaches all working relationships as a “Teaming Effort”. ECI firmly believes that dialog and effort from both ECI and the client make implementation of the scope of work (i.e., established during preparation of proposals and kick-off meetings by establishing our client’s needs and their participation effort) successful.

ECI regards the work performed for a client to be confidential and owned by the client. With that stated, ECI has received a written grading document from the United States Trade Development Agency (i.e., public record) indicating excellence in performing a scope of work related to the People’s Republic of China. In addition, ECI has received numerous platitudes from clients based on confidential scopes of work developed and implemented by ECI and the client.

ECI Domestic Case Studies

ECI provided a food processing company located in Western New York that included three (3) milk-products processing facilities, two (2) truck garages/terminals, and a corporate office building with compliance support for environmental, health, and safety regulations. ECI provided on-going operations environmental, health, and safety evaluations to determine non-compliance issues, estimate the cost of potential agency fines, and estimate the line item costs to bring the facility into compliance. ECI provided turnkey chemical bulk storage tank replacement and upgrade to meet appropriate regulatory requirements; petroleum bulk storage tank evaluations and costs for their truck terminal and garages; OSHA training; due diligence for a new facility; evaluated the corporate building and warehouse for indoor air quality and mold, making several recommendations that eliminated employee complaints; evaluated a company’s process that was proposing to lease a vacant building owned by the food processor; provided design improvements and installation for least-cost compliance with chemical storage areas; reviewed documentation for compliance with regulations pertaining to ammonia refrigeration system including drawings, Emergency Planning and Community Right-to-Know Act (EPCRA) and Contingency Plan and Emergency Procedures documentation (filed Form R and Tier II Forms), Process Safety Analysis and Management (PSA and PSM), Risk Management Program (RMP), and Process Hazard Analysis (PHA). In addition, ECI has worked with and trained site personnel and safety committees to improve compliance with OSHA standards/regulations.

ECI provided a food processing company with ammonia refrigeration system compliance services. The two cheese processing facilities ECI assisted were located in Ohio and New York. ECI developed as-built ammonia refrigeration system drawings, and brought the facilities PSA, PSM, RMP, and PHA documentation into compliance. ECI incorporated the as-built drawings into the aforementioned documentation and provided appropriate on-site training. ECI prepared management personnel (i.e., pre-audit preparation) for both federal and state agency audits of the ammonia refrigeration system and documentation. ECI developed air emissions calculation software for compliance with appropriate regulations and permitted bio-fuel (i.e., methane from an anaerobic wastewater treatment plant) combustion sources at the New York facility.

ECI provided two aerospace metal parts manufacturing facilities located in Western New York all their environmental, health, safety, and ISO14001 compliance requirements. ECI developed a 12-month VOC Emissions Study during 2001 that was used to support the development of a logical/engineering estimating procedure for air emissions at the facility. The study was used in the determination for monthly and 12-month rolling average estimated VOC emissions from the facility. ECI subsequently filed a State Facility Permit Application and negotiated the permit conditions. For the second facility ECI developed the information included in the emission points and emission source engineering drawing for submittal as part of the State Facility Air Permit Application. For both facilities ECI provided the management documentation, filing system, and personnel training for over 500 employees for ISO14001 compliance; and provided coordination of all EPCRA and Contingency Plan and Emergency Procedures documentation. The ISO14001 compliance included developing and arranging a filing index/system at both facilities for environmental, health and safety management and regulatory requirements. ECI provided over 7,000 employee hours of OSHA training to over 700 employees through a grant program. ECI identified the grant program for the client and then authored the application.

ECI provided a merchant producer of foundry coke with review of the NYSDEC draft Title V air permit. ECI developed a report that identified a number of compliance issues regarding written permit conditions. These issues were developed into a letter to the NYSDEC that provided comments from the facility on proposed permit conditions. The final Title V permit reflected the comments and allowed the facility to better comply with the permit conditions and at a lower cost for compliance. ECI also provided comments and compliance strategy on NOx emissions from combusting coke-gas in the facility’s boilers. After the EPA published new wastewater pre-treatment regulations ECI developed and submitted the first Fundamentally Different Factors (FDF) variance application to EPA Region II in over 20 years. Subsequently ECI has prepared additional information requested by the EPA including but not limited to a complete preliminary design of a sophisticated wastewater treatment facility with diversion of storm water, dissolved air floatation, metals removal, and biological system. ECI prepared system sizing and engineering costs as well as schematics of the system. ECI has provided POTW and SPDES permit modification assistance for the facility. Documentation of processes and schematic piping diagrams, analytical data review, permit strategy development, and agency negotiations were all part of the permit modification assistance.

ECI assisted a chemical processing company with over 15 facilities in the United States. ECI provided direct assistance to their facilities located in Upstate New York, Northern Pennsylvania, and North Carolina. For the New York facility ECI lowered their operating costs and improved their operating flexibility by successfully modifying their facility air permit. ECI developed a Performance Test Protocol and Compliance Plan that was negotiated at length with EPA Region II and the EPA Washington DC office. The impact to the facility and the industry in total was to improve operating flexibility and lower operating costs. The facility Performance Test Protocol was developed using state-of-the-art sampling and analytical methods that had been employed for other industries/processing equipment but had not been used for the specific industry. The Compliance Plan was developed to allow for significantly improved operating/chemical processing flexibility and reduced operating costs. For their Pennsylvania facility ECI recommended a number of process/material storage modifications to reduce VOC emissions. For their North Carolina facility ECI provided strategy development for their Title V air permit application and compliance plan.

ECI International Case Studies

ECI provided acquisition/merger and due diligence services in the People’s Republic of China (i.e., China) for two multinational companies that are in the top 100 companies (i.e., revenue generation) worldwide. ECI performed these aforementioned activities in Wuhan, Chengdu, Pudong, and Shanghai for a $1.8 billion acquisition/merger for United States and German based manufacturers. ECI also identified reuse/resale alternatives of solid and semi-solid by-product waste streams from these facilities.

ECI provided support for a United States based chemical processing company for their expansion into China. ECI provided support of joint venture negotiations and construction of a manufacturing facility.

ECI provided marketing, fabrication, and negotiation support for a small multinational United States based company that was evaluating China as a market and potential fabricator of their air pollution control equipment. ECI met with numerous entities in China and assisted in decisions on how to successfully establish a base (i.e., marketing and fabrication) in China.

ECI has provided support for the United States Trade Development Agency (TDA) in China providing technical review of United States manufacturing company processes, marketing guidance and development, process cost estimates for capital costs and operations and maintenance costs, financial analysis of projects, and management guidance. ECI has been given the highest marks by the TDA for the projects completed by ECI and has in writing statements from the TDA that ECI fully understands how business is conducted successfully in China.

Over a four (4) year period ECI provided all the environmental Design, Review, and Advisor (DRA) expertise for the entire $300 million World Bank funded Liaoning Urban Transportation Project (LUTP). The LUTP provided infrastructure roads, busways, bridges, and river crossings for three cities within the Liaoning province. The project started in 1999 and finished in 2004. ECI managed/coordinated all related environmental monitoring and mitigation efforts for all national competitive bid (NCB) and international competitive bid (ICB) construction packages. In addition, ECI lead the effort to assemble the three-company team that prepared the technical bid package to receive this $2.5 million consulting services contract for the LUTP.

ECI provided motor vehicle emissions control strategy planning for three cities in China. ECI was selected from over 40 companies worldwide for this World Bank funded project that started in 2002 and was completed in 2004. ECI personnel established a project office in Shenyang, China where they were based for the duration of the project. ECI project personnel authored an original 350-page document that provided strategy for motor vehicle emission controls including appropriate regulations, emission and fuel standards, maintenance requirements, vehicle emissions testing, and implementation plans. ECI personnel also evaluated motor vehicle emissions that have been identified by the US EPA as a significant cause of urban area ambient air pollutants and result in deposition into water bodies. The World Bank, China government, and other stakeholders were pleased with and approved the document authored by ECI personnel.