who we are
Tora's professionals leverage unmatched regulatory expertise, industry knowledge, and innovative technical solutions to help our clients navigate their most complex business decisions. From project planning and site selection, to permitting for construction, to operational permitting and compliance, we add strategic value in all phases of our client's projects. Tora’s mission is to be integrated into our client's team, such that we are an extension of the intellectual machine that drives projects and key initiatives forward. We provide environmental consulting services such as permitting, compliance reporting, and recordkeeping. As advisors we help our clients develop internal policies and procedures; negotiate with regulatory agencies; assess the impacts of new regulations; conduct training; plan projects; and provide other services which are focused on helping our clients make long-term business decisions. We are constantly thinking of creative ways to solve our client’s most complex problems, as if they are our own.
our portfolio
We have helped clients solve complex environmental challenges across the entire roofing manufacturing supply chain. Our project portfolio encompasses the following types of manufacturing plants:
Glass Fiber
Roofing Aggregate Mining and Processing
Wet-Formed Fiberglass Mat
Filler Milling
Asphalt Processing (Oxidized and Polymer Modified)
Asphalt Roofing (2-, 3-, and 4-Wide shingle, Rolled Roofing, and Mod-Bit)
Recycled Asphalt Shingle (RAS) Processing
Polyisocyanurate (ISO) Foam Board
Thermoplastic Polyolefin (TPO) and Polyvinyl Chloride (PVC) Membrane
Miscellaneous Products (Ridge Vent, Ridge Cap, Metal Parts, and Tiles)
Roofing and Other Architectural Coatings
Tora’s experts are exceedingly familiar with the equipment, processes, challenges, and applicable environmental regulations at these plants. There is no other consulting firm with more comprehensive and concentrated environmental expertise specific to the roofing industry.
our services
AIR QUALITY PERMITTING & COMPLIANCE
Construction (Minor, Conditional Major, Major NSR/PSD, Non-Attainment NSR)
Operating (Minor, FESOP, Title V)
Control Evaluations (BACT, RACT, LAER, MACT)
GHG Reporting and Accounting
Emissions Inventories
Compliance and Regulatory Reporting
Stack Test Management, Support, and Process Optimization
MODELING & MONITORING
Air Dispersion Modeling Analyses (PSD, Air Toxics, etc.)
Modeling-Driven Facility Design
Ambient Air Monitoring Data Analysis
Low-Cost Sensor Networks
ENVIRONMENTAL COMPLIANCE PROGRAM MANAGEMENT
Multi-media Permitting and Auditing
National Pollutant Discharge Elimination System (NPDES)
Spill Prevention, Control, and Countermeasure (SPCC) Plans
Stormwater Pollution Prevention Plan (SWPPP)
Wastewater
Underground and Aboveground Tank Compliance
Compliance Program Development and Tracking
SITING & EXPANSION
Environmental and Non-Environmental Permit Tracking
Desktop Endangered Species, Cultural Resources, and Wetlands Reviews
Long-Term Regulatory Flexibility Assessments
Modeling-Driven Siting (Class I Areas, Terrain, Off-Site Emission Sources)
Emissions-Optimized Greenfield and Expansion Project Design
EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW-ACT
Hazardous Chemical Inventory Reporting (Tier II)
Toxic Release Inventory (TRI) Reporting
STRATEGIC ADVISORY SERVICES
C-Suite Reporting
Corporate Environmental Strategy Development
EMS Design, Development, and Management
Environmental Justice and Community Engagement
Environmental SOP and Policy Development
Environmental Training
Regulatory Negotiations
Rulemaking
ROOFING PROJECT EXAMPLES
Tora is here to help resolve challenges, minimize future obstacles, and be an advocate for your operating needs. Our extensive knowledge and experience in environmental and engineering projects make us a great partner to help address any complex environmental issue.
Greenfield Asphalt Processing & 4-Wide Asphalt Shingle Plant
Tora was engaged to lead all primary environmental activities associated with the construction of a Greenfield, state-of-the-art, roofing manufacturing facility consisting of a stillyard, a 4-wide shingle line, recycled asphalt shingle (RAS) liquefaction equipment, and associated appurtenances. We evaluated sites in four (4) states, helping the client select its Kansas site based on anticipated permitting timeframes and operational flexibility requirements. We also assisted with facility design, including air pollution control technology selection. Tora developed a system to track and manage all environmental and non-environmental permits necessary to authorize construction and operation of the plant. We lead all environmental permitting efforts and are in the process of developing the infrastructure necessary for plant startup (e.g., stormwater permit, SPCC plan, etc.).
ISO Plant Control Device Selection
Tora performed engineering measurements to assess airflow and VOC loading from various on-line and off-line sources at an ISO foam manufacturing plant. The results identified the minimum number of sources that would need to be controlled to meet production goals while maintaining synthetic minor status. The client was able to install a much smaller Regenerative Thermal Oxidizer (RTO), resulting in ~$1MM cost savings compared to their original selection.
CAPACITY EXPANSIONS
Staff have executed air permitting analyses and permit modifications (where necessary) to facilitate capacity expansions at over a dozen roofing plants in various jurisdictions across the United States. The profit created by these expansions is worth over $250MM per year.
AIR PERMIT OPTIMIZATION
Tora professionals are experts at optimizing permits to reduce risk and maximize operational flexibility. At one 4-wide shingle plant, we consolidated several equipment-specific limits into a facility-wide limit to allow balancing of emissions/production across various processes. We have successfully negotiated outlet-only concentration limits in lieu of destruction efficiency requirements at shingle and mat plants in multiple jurisdictions, providing significant reductions in thermal oxidizer operational costs. We have conducted permit reviews to identify risks, developed mitigation options, and executed permit modifications at over 20 residential and commercial roofing plants.
Engineering Testing and Process Optimization
Tora designs site-specific multi-variate testing programs to identify optimized process and equipment settings. Our test programs involve the use of sophisticated methods to obtain real-time emissions and other environmental data, which we pair with real-time processes and equipment data obtained from facility PLC systems (Historian, Trend, BrainCube, etc.). The results of our analyses are used to pinpoint potential equipment issues and identify process conditions that improve performance and minimize environmental risks. The example provided in Figure 1 illustrates how our testing programs have been used to identify RTO performance issues; specifically, a significant loss in efficiency in Zones 8 and 9, which was consistent with visible and thermal imaging observations. Figure 2 illustrates how we are able to identify changes to process variables necessary to achieve specific emissions results.
BLOW LOSS STUDY: AGITATED V. NON-AGITATED BLOWSTILLS
Tora Consulting recently completed a detailed emissions evaluation at an asphalt roofing materials manufacturing facility, comparing agitated and non-agitated blowstill operations used in asphalt coating production. The project included on-site source testing, real-time and laboratory analysis of gaseous, condensable, and particulate emissions, as well as hydrocarbon speciation. The evaluation provided insights into how agitation impacts blow loss, combustion efficiency, processing rates, and overall emissions performance. Results supported the facility in making informed decisions regarding process optimization and air permit compliance. Tora’s industry-specific expertise helped deliver actionable recommendations tailored to the unique operational needs of an asphalt roofing manufacturing plant.
PROGRAMMATIC ENVIRONMENTAL MANAGEMENT SYSTEM SERVICES
Tora has worked with numerous clients in roofing and related industries to develop and implement environmental management systems (EMS) from the ground up. As a part of each EMS, we build media-specific Environmental Compliance Plans (ECPs), which detail applicable environmental requirements, and the methods used to demonstrate compliance with such requirements. We help clients select and implement electronic compliance tracking systems (Gensuite, Velocity EHS, etc.), develop custom learning management system (LMS) trainings, develop company-specific plans and procedures, and provide overall EMS management support.