Tora managed the complete setup of Leak Detection and Repair (LDAR) programs for a large liquefied natural gas (LNG) export facility and several midstream gas processing plants across the U.S.

Key responsibilities included:

• Developing a custom calculation algorithm for emissions estimation software
• Coordinating among internal stakeholders, contractors, and regulatory agencies
• Drafting annual fugitive emissions inventories
• Supplying detailed contingency workflow charts and employee training modules
• Supporting unit shutdown emissions calculations
• Providing ongoing technical support to field contractors

Tora also developed fugitive emissions monitoring (FEM) and compliance programs aligned with EPA Subpart OOOOa for multiple compressor stations in the eastern U.S. OOOOa is a federal rule regulating methane and VOC emissions from new oil and gas sources.

We successfully negotiated with state agencies to:

• Allow the use of Alternate Work Practices (AWPs)
• Secure an extended initial startup period
• Remove NSPS Subpart KKK applicability (VOC leak rules for gas processing equipment) from one facility
• Remove Subpart OOOO applicability from another

Following these changes, Tora conducted a retroactive compliance gap analysis to identify any historical vulnerabilities under the updated regulatory landscape.