Tora frequently manages engineering stack testing programs to generate data for multivariate testing (MVT) analyses, which identify the key process parameters that influence emissions. These analyses prepare facilities for compliance testing, raw material variation, process changes, and air pollution control device design or commissioning. To date, Tora has coordinated more than 25 testing events, providing…
Tora developed a data collection protocol and managed field testing for an engineering evaluation of methane emissions from centrifugal compressors used at midstream natural gas transmission stations. The study focused on comparing emissions from two compressor types: Using a statistically valid dataset from multiple sites, Tora’s analysis challenged a key EPA assumption: in some cases,…
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: Tora also developed fugitive emissions monitoring (FEM) and compliance programs aligned with EPA Subpart OOOOa for multiple compressor stations in the eastern…
Tora led the multi-media environmental permitting for the addition of butane injection systems at existing gasoline distribution terminals. The effort involved: These projects were successfully permitted at both Title V facilities (major sources under the Clean Air Act) and Synthetic Minor facilities (sources that limit their emissions to avoid Title V requirements), showcasing Tora’s ability…
Tora prepared and submitted an air quality construction permit application for a major capacity expansion at an existing natural gas processing facility, increasing throughput from 60 million to 306 million standard cubic feet per day (MMscfd). The project scope included: To maintain the project timeline, Tora also helped the client obtain permit waivers that allowed…
Tora assisted a client in re-permitting two facilities to allow for the temporary flaring of sour gas after they lost their contractual agreement to send it off-site for processing. Sour gas refers to natural gas containing hydrogen sulfide or other sulfur compounds that require treatment before use. We prepared Title V air permit applications for…
Tora assisted a client by conducting in-person audits of more than 250 recently acquired upstream oil and gas assets located in three formations across Texas. The audit scope covered the full range of the client’s air quality compliance program, including: Tora identified and flagged all permitting or compliance gaps, inconsistencies between site conditions and permits,…
Tora served as the program manager for air permitting and compliance across all Dominion Carolina Gas Transmission facilities in South Carolina. Our responsibilities included: A key component of the project was a top-down Best Available Control Technology (BACT) analysis to evaluate emissions control options for nitrogen oxides (NOₓ). Tora successfully demonstrated that the available control…
Tora Consulting recently completed a detailed emissions evaluation at an asphalt roofing materials manufacturing facility, focused on comparing agitated and non-agitated blowstill operations used in asphalt coating production. Blowstill operations involve heating and blowing air through asphalt to modify its physical properties—a key step in roofing product manufacturing. The project included on-site source testing, real-time…
Tora designs site-specific multivariate testing programs to identify optimal process and equipment settings that support both operational performance and environmental compliance. In one case, the analysis revealed reduced efficiency in Zones 8 and 9 of a Regenerative Thermal Oxidizer (RTO)—confirmed by thermal and visual imaging. In another, we used the model to identify specific process…