Project Type
- Refining, Petrochemical
and Industrial - Power Plants
- Offshore Oil and Gas
- Buildings
- Heavy Civil, Highway, Rail, Underground, and Water/Wastewater
- U.S. Projects by Region
- International Projects
The projects listed were performed by our consultants in a lead/key expert role for Long International or for other consulting firms.
Refining, Petrochemical and Industrial
Long International personnel have been involved in numerous claims and project consulting assignments associated with oil refineries; chemical and petrochemical plants; gas, gas-to-liquids, and LNG facilities; oil production and terminal facilities; oil shale, coal and coke gasification, tar sands, ethanol, and mineral processing plants; pipelines; and other manufacturing facilities. Many of these projects have been located outside the United States.
Chemical Plants-
Colorado Prepared an owner's claim against an engineering & construction management firm which was terminated by default for defective design work, delays, and cost overruns on a guaranteed maximum price contract to build a commercial-scale chemical plant scaled up from a pilot plant test facility. East Germany Provided overall guidance on contract dispute resolution to owner project teams involved with a $4 billion (approximate) restructuring of a chemical complex. The intent of this oversight was to have a uniform approach to dispute resolution across multiple projects. Jordan Performed an analysis of the technical entitlement of over 400 change orders associated with an engineering and construction contractor’s $60 million claim on a magnesium oxide production plant. Determined the cause-effect relationship between the changed work and the resulting schedule impact and additional costs. Work was in preparation for expert testimony at an ICC arbitration hearing. Louisiana Performed an analysis of entitlement, schedule delay and damages for a contractor's $12 million claim against a major international chemical company related to the construction of two process units in an existing chemical plant. Louisiana Performed an analysis of an EPC contractor's change order and delay claims on a chemical plant project. Spain, Argentina, and The Netherlands Supplied dispute resolution services in support of a chemical company who was defending against $150 million in impact claims made by a European EPC contractor on Polyethylene Terephthalate (PET) plants in Spain, The Netherlands and Argentina. Participated in the document discovery, research, organization and coding of over 500,000 project records into an internet-based document repository. Assisted in answering interrogatories and prepared questions for fact witness depositions. Scrutinized the entitlement of alleged critical path schedule delays due to late and continuous changes, technology changes, late turnover package approvals, weather impacts, and slow agency reviews potentially affecting 15,000 schedule activities. Developed a comprehensive delay allocation model used to quantify and document critical path and concurrent delays affecting the schedules. Correlated issues to schedule activities. Employed a retrospective CPM schedule delay analysis methodology to correctly calculate entitlement for compensable delay costs and evaluate concurrent delays due to approved change orders, fact-based project issues, and weather impacts as supported by project records. Based on the findings, the contractor’s claims were grossly overstated and unsupported in which the Owner enjoyed a favorable settlement at a small fraction of the total dispute. Tennessee Analyzed an owner’s claim for delays and cost overruns against the engineering, procurement, and construction contractor of a polyol chemical plant project. Texas Performed an analysis of a contractor's $19 million claim for change orders, delay, and disruption on an EPC project involving a MDI chemical plant. The issues also included interpretation of whether the contract was reimbursable or unit rate/lump sum price. The Netherlands Performed an analysis of the delays associated with the punchlist work, mechanical completion, and startup/commissioning of a chemical plant in The Netherlands. West Virginia Retained by the owner of a surfactants expansion project to defend a claim by the electrical contractor for increased costs and loss of productivity. Evaluated standard of care, schedule, causation, labor productivity (including loss productivity due to changes), and damages.
Gas, GTL, and LNG Plants-
Electrical Building Installation for LNG Facility Singapore and Spain On behalf of the Owner, performed an analysis of a $15 million cost overrun and cumulative effect claim by an electrical contractor on a $15 million electrical and instrumentation building to be installed offshore on an LNG facility. Gas Plants Australia Evaluated defective design and project management performance problems associated with a gas plant and pipeline project. California Provided claims analysis, entitlement analysis, schedule analysis and assessment of $20 million in cost overruns on a lump sum, fast-track gas processing plant project. Issues included defective specifications, changes, and delays. Saudi Arabia Performed an analysis and expert report regarding schedule delays and increased costs associated with an EPC contractor's $138 million claim on a gas plant project. The work involved correction of the contractor's baseline and schedule updates, assessment of impacts allegedly due to change orders, welding defects, late drawing deliveries by the owner, and contractor performance problems. Prepared a time impact and an as-built but-for schedule analysis to address time extension entitlement, compensable delay, and loss of productivity. Developed a chronological database and assisted the law firm with witness statements and document disclosure requests. LNG Plants Canada On behalf of an insurance company, performed an analysis of delays to the construction of an LNG terminal in New Brunswick, including equipment to unload tanker, transfer to LNG storage tanks, vaporize the LNG, and meter the gas as it is introduced into the natural gas pipeline. The claim was filed by the owner as a result of materials being lost overboard at sea in severe weather while being shipped to the site. Nigeria Developed the implementation of a contracting strategy for 10 MM TPY grass roots LNG liquefaction plant. Assignment included preparation of bid packages and bid evaluations for 8 LSTK contracts that covered every portion of the project. Facilitated senior shareholder meetings to arrive at the strategy and to approve its implementation. Trinidad Performed an analysis of the adequacy of a cost estimate and construction risks associated with the upgrade of an LNG facility. LNG Terminal Project Spain and Italy Performed an analysis of delays and project management performance deficiencies in defense of a $40 million claim of an EPC contractor for additional overhead and fee on a cost reimbursable contract that was delayed over 18 months. Analyzed deficiencies in the EPC contractor's schedules, and performed an analysis of concurrent delays. Prepared the basis of a counterclaim by the owner against the EPC contractor. Natural Gas Plant Canada Provided claims analysis services for the insurance company regarding the reconstruction of a natural gas plant in British Columbia following an explosion. Performed a schedule analysis to determine when the reconstruction of the plant could have been completed absent the improvements to the facility made by the owner. NGL Extraction and Fractionation Plant Illinois Retained by the owner of a natural gas liquids extraction and fractionation plant involved in arbitration with the electrical and instrumentation contractor. Analysis and opinions provided included contract review, determination of breach of contract, delay analysis, and calculation of cost reimbursements owed to the contractor and damages incurred by the owner. NGL Processing Plants Illinois Analyzed damages for an owner regarding the cost reimbursable construction of a large NGL separation, processing and storage facility. Damages analysis focused on the reasonableness and causation of significant construction and startup cost overruns related to work performed by the prime contractor’s electrical sub-contractor. Nigeria Performed an analysis of EPC schedules for a $1.7 billion Gas to Liquids facility. Verified the schedule work scope against contract requirements. Evaluated schedule metrics, reviewed schedule logic, assessed the reasonableness of the critical path and provided recommendations for optimizing the schedule. Also evaluated a cumulative impact claim. Nigeria Evaluation of a piping module subcontractor's delay claim associated with a Gas to Liquids facility. Evaluated the integrity of the subcontractor's schedules and verified the impact of changes to the subcontractor's schedule. Participated with the EPC contractor and Owner to achieve a settlement of the time extension and cost components of the subcontractor's claim. Nigeria and Germany Evaluation of a civil subcontractor's delay claim regarding foundation and civil works associated with a Gas to Liquids facility. Evaluated the integrity of the subcontractor's schedules and verified the impact of changes to the subcontractor's schedule. Participated with the EPC contractor and Owner to achieve a settlement of the time extension and cost components of the subcontractor's claim. Wyoming Provided analysis regarding schedule delay and cost overrun issues on a NGL processing project involving construction of central process and satellite facilities. The analysis work was performed on behalf of the owner to identify the magnitude and compensability of potential affirmative claims against the prime contractor. NGL Project Venezuela Prepared CPM fragnets depicting schedule delays and analysis of productivity losses on a natural gas liquefaction project.
Manufacturing Facilities-
Aluminum Smelter Caribbean Created an EPC contract and contract exhibits for the Owner’s use in negotiating the EPC of a $ 1 billion aluminum smelter. Blast Furnace/Coke Oven Indiana Provided litigation support of a $400 million blast furnace and coke oven battery project involving analysis of construction cost and schedule overruns and the adequacy of the engineering design. Calciner Facility Canada Performed an audit of the EPCM and general contractor's cost records to identify potential billing discrepancies and problems on cost reimbursable contracts for a Calciner expansion project. Cement Plants Florida Assisted the owner in the defense of a $12 million claim on a project involving the design, delivery and construction of a new cement production line from ore receiving to finish mill and product loadout. The EPC contractor claimed for increased costs due to alleged owner-caused delays and disruption arising from late delivery of proprietary design information, and late delivery of materials and equipment, and impacts to labor productivity due to numerous changes to the work and contractor's alleged acceleration to overcome delays. Illinois Analyzed a $7 million claim by a contractor against an equipment manufacturer regarding extra work involving the structural steel installations on a new cement manufacturing plant. The analysis also involved the contractor's claim that it constructively accelerated its work to overcome delays. Texas Prepared a detailed evaluation of project costs and schedule, and prepared requests for equitable adjustment against the owner and an equipment supplier relative to the design, procurement, construction and start-up of a cement manufacturing facility. Also provided expert testimony (in arbitration) related to defective design, late and out-of-sequence deliveries, extra work, disruptions to the work, and delayed completion of construction. Texas Assisted the supplier of proprietary equipment in defending against $20 million claim on a project involving the design, delivery and construction of a new cement production line from ore receiving to clinker storage and loadout. The general contractor claimed for increased costs allegedly due to delays, disruption and labor impact arising from late delivery of design data and proprietary equipment, and a defective design. The case was arbitrated in Texas with client liable for only a portion of disputed extra work. Fertilizer Plant Iraq Prepared a claim, developed a document database, and performed an analysis of costs and schedules for a $450 million fertilizer plant. Prepared a $100 million claim against the owner, which was abandoned as a result of the Gulf War. Successfully negotiated one Turkish and two Korean subcontractor's claims against the Japanese prime contractor. Fiberglass Insulation Plant Canada Evaluated delays and cost overruns on an insulation manufacturing facility in Alberta. Analysis of schedule and cost data in support of the Owner’s $28 million counterclaim against the EPC contractor’s $20 million claim. Testified as a CPM schedule and cost expert witnesses for the arbitration. Glass Bottle Plant Colorado Performed an analysis of a contractor’s delay and loss of productivity claim against a Finnish equipment supplier providing a design build materials handling facility for a glass bottle manufacturing plant. Gold Ore Processing Plant Nevada Assisted equipment supplier in defending against a $10 million claim by the owner of a gold mine. The project involved the design and construction of a prototype gold ore processing plant. The Owner sought recovery of costs associated with alleged breaches by client resulting from late and deficient proprietary engineering information, late delivery of proprietary equipment, and failure of equipment to perform as specified. Case was settled during arbitration with client paying no damages. Nuclear Fuel Storage Containers Massachusetts Assisted original principals in defending a $6 million claim by the acquiring firm regarding a project that manufactured long term storage containers for spent nuclear fuel. The purchasing firm alleged that the principals of the original firm for misrepresented relevant financial information related to the project’s progress and forecast costs at the time of the change in ownership. Assisted original principals in substantiating that actual performance of the work in progress was in fact consistent with projections and the only exceptions were due to a substantial change in the definition and allocation of overhead burdens, and other business decisions made by the acquiring firm subsequent to the transfer of ownership. Claim was settled prior to hearings and on terms very favorable to defendant client. Paper Plant Texas Performed an analysis of a contractor’s cost claim for unforeseen conditions for the owner of a paper manufacturing facility. Polyester Chip Facility South Carolina Assisted EPC contractor with $10 million claim against owner for increased costs associated with increased scope of work, project delays and disruption and loss of labor productivity arising from subsequent acceleration on the design, delivery and construction of an additional line for the production of polyester chips for use in manufacture of plastic soda bottles. Pulp & Paper Mill Washington Performed an analysis of a Swedish contractor’s delay and disruption claim involving the design and construction of a pulp and paper mill. Waste Shipping Facility Colorado Provided an independent analysis and evaluated subcontractor change orders for the construction of the Building 440 Addition, TRU Waste Shipping Facility. In addition, prepared budget estimates for the construction of a Gas Generator Testing System and for the installation of the TRU waste container lid stands.
Miscellaneous Process Plants-
CO2 Recovery Process Plant Texas Prepared damages and schedule analyses in support of the owner's defense against a contractor's $5 million delay and disruption claim on a fast-track CO2 recovery process plant facility. Condensate Plant Colorado Performed an analysis of an owner's errors and omissions claim against the design contractor on a condensate plant project. Food Processing Plants Colorado Represented a general contractor in defending against a $1 million delay, acceleration and loss of productivity claim on a poultry processing plant. Case was settled during trial with defendant client paying $150K. Georgia Performed a $20 million estimate to support a claim for the as-built building cost and replacement cost value resulting from a total loss fire at a poultry processing facility. Food Processing Projects South Dakota Prepared a contractor's delay and loss of productivity claim against an owner cooperative on the construction of a $32 million soybean processing plant. Developed a document database, prepared a detailed schedule analysis, and calculated the contractor's entitlement to delay and loss of productivity damages as a result of the defective design by the process equipment licensor and late delivery of equipment. Washington Developed a 1,200-activity master schedule for a new $98 million sugar beet refinery project. Established the work breakdown structure for the project. With the corporate accounting department, developed the cost code of accounts. Integrated the master schedule activity coding and breakdown with the coding and breakdown created for the job cost system. Prepared graphics and summary schedules for presentation at public and Board of Directors’ meetings. Nitrogen Plant Mexico Performed an analysis and prepared an expert report in support of the owner’s entitlement to claims against the EPC contractor involving the standard of care in its management of the design and construction of a nitrogen plant project.
Oil Production and Terminal Facilities-
Oil Production Facility Alaska Evaluated the merits of a tax petition relative to the dismantlement of oil production and related facilities on the North Slope of Alaska. The evaluation included a review and critique of the overall dismantlement, removal and restoration plan, estimated quantities of work, labor and equipment costs, logistics and transportation, disposal of scrap and salvaged materials, and the dismantlement schedule. Oil Terminal Projects Asia Performed an analysis of a Korean contractor's $75 million delay and disruption claim and the owner's counterclaims due to late and defective work on a major oil terminal project. Canada On behalf of the owner, performed an analysis of causes of cost overruns incurred by the contractor on an oil terminal project in Alberta. Review and compared bid package drawings with Issued for Construction drawings, welding data; and other information to determine if the owner has a basis for disputing the contractor's costs. Louisiana Prepared an expert report and provided testimony regarding the analysis of an owner's property damage claim following a fire at an oil terminal.
Petrochemical Plants-
Algeria Performed an analysis of the quantum aspects of a contractor's $130 million delay and changed conditions claim involving the relocation of a petrochemical plant project site after construction had commenced because of the discovery of unfavorable soil conditions. Prepared expert report, rebuttal expert report, and testified in ICC arbitration. Angola Performed an analysis of a contractor's $11 million claim involving disputed change order work, loss of productivity, late materials deliveries, and other delay events on a new petrochemical plant project. Argentina Performed an analysis of delays, acceleration, change orders, unit rate, and loss of productivity claims totaling $20 million by a major U.S. engineering contractor and counterclaims by a major U.S. chemical company on an ethylene plant project. Argentina Performed an analysis of a contractor's delay and loss of productivity claim on the design and construction of a polypropylene project. Canada Performed an analysis and prepared an expert report/testimony regarding an owner's alleged business interruption loss due to an unplanned shutdown of an MTBE plant in Alberta. Canada Performed an analysis of an EPC contractor’s change order, delay, and loss of productivity claims on a Linear Alpha Olefin (LAO) Project. Nigeria Performed an analysis of the integrity of a Korean contractor's EPC schedule regarding logic problems, constraints, and reasonableness of the critical path for a major petrochemical plant project. Texas Performed an analysis of delays and time extension entitlement on a $75 million claim involving the engineering, procurement, and construction of a major petrochemical plant. Texas Performed an analysis of a $500 million property damage and business interruption claim resulting from fire damage to a petrochemical plant. Costs estimates for the property damage claim and schedule analyses were prepared considering acceleration, betterments, upgrades, and non-rebuilt facilities. The Netherlands Performed an analysis of delay and disruption claims on the engineering, procurement, and construction of a ethylene cracker project. Trinidad Performed an analysis of delay and acceleration claims on the engineering, procurement, and construction of an ethylene project.
Pipelines-
Pipelines California Evaluated a contractor’s claim for environmental and permitting delays, disruption to work activities, changes in scope, and changes in alignment associated with the construction of 70 miles of 20-inch diameter pipeline. The assignment also included the identification and systematic evaluation of major engineering and construction problems and their cause/effect relationship on cost overruns and schedule impacts. Illinois Provided litigation support and expert witness testimony (at deposition) related to the review and evaluation of a contractor’s $11.5 million claim for disruption, delay and increased costs associated with the construction of a 28 mile, 36-inch diameter pipeline. Oklahoma Evaluated pipe welding problems and the documentation of increased costs associated with rework, extra work, labor inefficiency and extended site overhead costs. Texas and California Prepared a cost estimate and schedule for the engineering, procurement, and construction of an artificial island, marine off-loading facilities, sub-sea pipeline, 1,500 miles of 30-inch land pipeline, pumping stations, a communications system, a terminal, and storage facilities for a proposed pipeline project. Trinidad Performed an analysis of a French contractor's $14 million claim on a gas pipeline and valve station project. Pipeline Compressor Station Projects Colorado Analysis of an electrical and instrumentation subcontractor's claim on behalf of the EPC contractor regarding a compressor station project. Assessed allegations of schedule impact and acceleration, and prepared an expert report that challenged the claims made by the subcontractor's expert. Nigeria Performed an analysis of an EPC contractor's $43 million claim on behalf of the owner involving hundreds of alleged P&ID changes to the FEED design of a compressor station and pipeline project, and resulting delay to the completion of lump sum EPC compressor station project. Analyzed the technical entitlement to the P&ID changes based on standard industry practice for design development, the owner’s specifications, and the timing of the changes. Pipeline Facilities Kuwait Performed an analysis of delay and disruption impacts incurred by a construction company on the revamp of an oil and gas gathering center. The project involved extension of and tie-ins to large diameter, high pressure crude oil headers and collection pipelines. Pipeline/Gas Compressor Project India Performed an analysis of delay and performance problems on a gas compressor/pipeline project resulting in liquidated damages in excess of $50 million. This project involved ICC arbitration in Geneva, Switzerland.
Refinery-
Alaska Performed an analysis of a large engineering and construction firm's claims for cost overruns and delays associated with the lump sum construction of hydrocarbon production and process modules for the Kuparuk project. Belgium Performed an analysis of a European/Japanese EPC firm’s $75 million claims on a refinery upgrade project. Assessed the technical entitlement of over 100 change orders forming the basis of the claims as well as the schedule analysis to demonstrate entitlement to an extension of time and delay damages. Evaluated the loss of productivity analysis for proof of damages for labor cost overruns. California Performed claims analysis, damages assessment, and delay evaluations on a $250 million refinery expansion project involving $20 million in damages. The primary issues included bid error, loss of labor productivity, delay and acceleration. Canada Performed an analysis of the expediting costs associated with the $320 million rebuild of a refinery in Alberta following a fire. This work was performed in support of the insurance company’s interest on a property damage claim filed by the owner of the refinery. Analyzed the trade offs of increased time-related costs that would have been incurred had the work not been expedited compared to the increased costs as a result of a fast track schedule. The results of the various scenarios were evaluated using Monte-Carlo calculations to derive a probabilistic determination of the range of costs as a function of the variables involved in the analyses. Analyses contributed to a successful settlement between the insurance carrier and the owner. Canada Analyzed damages for the owner defending numerous change order claims on an international oil refinery upgrade project. Provided critical assessments of the contractor's pricing of its change order estimates. Colorado Prepared an expert report defending against a contractor's claim associated with disputed change orders, delay and loss of productivity on a new refinery debutanizer unit. Illinois Performed an analysis of an owner's $19 million claim against a major engineering and construction firm relative to home office and field cost budget overruns under a reimbursable contract for a $200 million refinery project. Mexico Reviewed and critiqued contractor-prepared change requests, prepared a preliminary evaluation of the contractor’s costs to date, and performed a detailed “but-for” analysis of the project schedule to establish a reasonable completion (absent supplier-caused delays) for the $1.6 billion expansion of a refinery. Texas Performed an analysis and an expert report regarding design defects that allegedly caused a failure of welds attaching the diplegs to the cyclone body in an FCC regenerator. Texas Performed an analysis of change order, delay and disruption claims involving a ultra low-sulfur diesel Unicracker project at a refinery. Trinidad Performed an analysis of a major international contractor's $22 million delay and disruption claim on a $100 million refinery upgrade project involving new hydrotreater and sulfur recovery units. Prepared a detailed schedule delay analysis, damage analysis, and provided mediation testimony. Trinidad Performed an analysis of a Canadian contractor's $25 million delay and disruption claim against the owner of a Caribbean refinery involving the construction of a new Visbreaker Unit, revamped Fluid Catalytic Cracking unit, and Instrument Modernization facilities. Trinidad Performed schedule delay and change order analysis in support of an owner's defense of a $10.5 million claim on upgrades to piping, boiler and flare facilities in a major international oil refinery. Trinidad Performed an analysis of various contractor's delay and change order claims on behalf of the owner on a major Gasoline Optimisation Project. Claim evaluations included an assessment of the integrity of the contractor's baseline and schedule updates, preparing alternative impact analysis of delays allegedly caused by scope changes, reviewing cost support for the change order amounts, and participation during negotiations to achieve settlement of the change order claims. UAE Evaluated a contractor’s delay and disruption claim against a major equipment supplier including a review and analysis of the as-planned and as-built schedules, preparation of a retrospective “but-for” analysis of the project schedule, and an assessment of damages relative to the expansion of a refinery. UAE Acted as the Project Management Advisor for FEED execution of a refinery hazardous waste facility and preparation of EPC contract documents. US Virgin Islands Performed an analysis of a contractor's pipe fabrication loss of productivity claim on a project involving the upgrade to an existing refinery. Venezuela Prepared a mechanical contractor’s $20 million claim for delay, additional work, labor disputes, and loss of productivity regarding a $790 million delayed coker project at the Cerro Negro oil upgrading project. Assisted counsel in the preparation of its briefs and document discovery requests, and prepared an expert report which was intended for witness testimony at ICC arbitration hearings in Geneva, Switzerland; however, the case settled before the hearing was conducted. Wyoming Evaluated the causes of cost overruns incurred by the EPC contractor during a project to upgrade the coker in a refinery. Although the work was performed under a reimbursable contract, the owner decided to not pay part of the EPC contractor's costs due to an alleged agreement to cap the Project Management costs and Fee.
Synfuels, Tar Sands, Ethanol & Mineral Processing Plants-
Coal Gasification Plant Alabama Provided litigation support, database management system development, and assessment of the technical design, cost and schedule overruns, and start-up problems of a coal gasification project. Coke Gasification Plant Kansas Performed an analysis of alleged deficiencies in the design of a petroleum coke gasification and syngas plant, resulting in change orders, delay, and loss of productivity claims totaling $25 million against the owner of a refinery. Ethanol Plant New York Analyzed change order claims alleged by the EPC contractor on an Ethanol from corn project at an old brewery site. Oil Shale Project Colorado Developed cash flow economic evaluation computer models and prepared capital and operating cost estimates and economic analyses used in the negotiation of the $1.1 billion project loan guarantee for the Colony Shale Oil Project. Refractory Ore Treatment Plant Nevada In an International Chamber of Commerce, International Court of Arbitration, provided deposition testimony on schedule delay, loss of productivity, cost reporting, extra work, and damages claims of $50 million on the construction of a $150 million Refractory Ore Treatment Plant. The case was settled in arbitration with the defendant client paying no damages. Tar Sands Mine and Upgrader Canada Performed an analysis of a $200 million insurance claim for non-traditional coverages resulting from delays and cost overruns in the construction of a tar sands mine facility and upgrader unit in Alberta. Prepared expert witness reports in support of the ICC Arbitration. Canada Performed an analysis of a $500 million claim for business interruption losses due to delays to the start-up and commissioning of an Upgrader Refinery that was built to process synthetic crude oil from a tar sands production facility. The delays were allegedly caused by a fire at the tar sands production mine site, which delayed the transport of bitumen to the refinery through a 200-plus mile pipeline. Prepared detailed CPM schedule analyses and an expert witness report. Designated as a CPM expert witness in support of the ICC Arbitration in Alberta. Tar Sands Upgrader Canada Provided contract/entitlement analyses, schedule review and risk assessment, for the owner, relative to the design, procurement and construction of a synthetic crude oil upgrader. Canada Performed an analysis of a major fire at an upgrader in Alberta that processed synthetic crude oil from a tar sands facility. Our client, a major construction company and its insurer, was defending against liability for property damage and business interruption damages amounting to $1 billion.



