Areas of Practice & Representative Projects
We understand the nuances of state permitting programs and the complexities of federal programs, such as PSD, NANSR, and Title V.
Natural Gas Processing Plant and Underground Storage. Air construction permitting for an expansion to increase processing capacity from 60 to 306 MMSCFD, including a new NRU, dew-point control, NGL storage and load-out facilities, and H2S scavenging, as well as amine treatment and TEG dehydration system modifications. Our professionals successfully negotiated with the regulatory agency to obtain permit waivers in advance of permit issuance to meet critical construction milestones.
Multi-Media Permitting for a New Compressor Station. Tora personnel led the multi-media permitting effort for a new compressor station comprising three compressors relocated from an existing facility. The project scope included: consultations with the SHPO, THPO, ACOE, USFWS, and SCDNR; preparation of permit applications for air quality, stormwater discharges, hydrostatic testwater discharges, road encroachment, and wetland/waterbody impacts; preparation of the Environmental Report to support the FERC filing; and, stormwater inspections and FERC reporting during construction and restoration.
Air Construction Permitting for a State-of-the-Art Asphalt Roofing Manufacturing Facility. Our professionals participated in significant negotiations with the state permitting agency to overcome project uncertainties related to emission rates, capture efficiency, paved roadway silt loading, and other factors. To address these issues, Tora personnel presented an analysis of a large stack test data set to support stated emission rates, performed roadway silt testing to support silt loading values, and assisted the client with designing their point capture ventilation systems.
FERC and Air Quality Permitting, 60 Mile Pipeline and Compressor Station Project. Tora professionals served as the air quality technical lead for preparation of air permitting applications, FERC Resource Report 9, and the Air Quality Cumulative Impact Analysis for a project involving the construction of a new compressor station, modification of an existing compressor station, and construction of approximately 60 miles of pipeline. The project was authorized under Section 7(c) of the Natural Gas Act through the FERC pre-filing process.
Mid-Stream Natural Gas Facility Permitting. We are mid-stream natural gas industry experts. We know the processes, applicable regulations, and air pollution control best practices. Our staff’s extensive portfolio of industry projects includes compressor stations, dew point control plants, underground storage facilities, and natural gas processing plants.
Title V Permitting. Tora personnel have significant experience permitting facilities under the Title V Operating Permit Program. Tora’s staff has permitted facilities across the United States in a variety of industries, including but certainly not limited to: Power Generation, Natural Gas Transmission, Natural Gas Processing, Automative, Furniture, MSW Landfills, Building Materials, Asphalt Roofing, Fiberglass Boats, Flexographic Printing, ISO Foam, and TPO Extrusion.
Our modeling experts address normal dispersion modeling issues, like NAAQS, PSD increment, and state toxics requirements. We've also addressed some more unique challenges via dispersion modeling.
PSD Modeling for a New Combined-Cycle Power Plant. Tora personnel performed interactive source air dispersion modeling associated with a PSD permit application for a proposed 475 MW natural gas-fired, combined-cycle power plant. In the midst of their lawsuit with EPA, NCDEQ required that the PM2.5 increment demonstration consider a 1975 major source baseline date. With a lack of historic PM2.5 emissions data, Tora professionals developed a unique approach utilizing potential emissions data from the PM2.5 NAAQS inventory, with iterative refinements made as needed. With this step-wise approach, Tora professionals were able to satisfy PSD increment requirements by demonstrating that the plant would not significantly contribute to modeled off-site violations of the PM2.5 increment.
Modeling Analysis Development for Informed Site Selection. Recognizing the extreme risks associated with NAAQS/PSD Increment compliance demonstration requirements of the new source review program, the client requested a high-level analysis of multiple sites to determine those with the highest modeling-related risks. Tora's air quality experts developed a one-of-a-kind GIS-based, semi-quantitative analysis of factors that contribute to modeling risks: meteorology, off-site facility emissions, and terrain. The client chose the site recommended by the analysis. The analysis can be integrated with other data sets (such as wetlands, soils, historic resources, etc.) to provide a comprehensive environmental site selection tool.
Modeling-Driven Facility Design. Due to the nature of facility emission sources and site size constraints, Tora personnel had to use air dispersion modeling results to drive the design of a new facility in the midwest. The analyses set stack heights, stack locations, and building configurations, which is not all that uncommon. But, because of PM10/PM2.5 issues in the airshed, the dispersion modeling analysis also drove the design of site entries/exits, roadways, and forklift travel paths.
Leak Detection and Repair
Our air quality professionals have designed LDAR programs to address some of the most complex regulatory requirements in the United States. Our sister company, Target Emission Services, Inc., provides LDAR services focused on the use of Optical Gas Imaging (OGI) technology.
LAER-LEVEL LDAR Program for LNG Import/Export Facility. Tora personnel designed a custom LDAR program to meet the lowest achievable emission rate (LAER) requirements of the client's non-attainment new source review permit. Monitoring under the program is performed using optical gas imaging technology pursuant to the alternative work practice in 40 CFR 60.18. Our AWP program will provide a greater emissions reduction and save the client millions of dollars as compared to an equivalent program utilizing traditional Method 21 monitoring.
Compressor Station LDAR Programs. For one client, our staff designed and implemented LDAR programs at over 40 compressor stations. To minimize the compliance burden for the client, our programs combined the requirements of all state and federal requirements related to fugitive emissions (e.g., PA GP LDAR, NSPS OOOOa, and 40 CFR Part 98, Subpart W). We continue to provide the client with assistance interpreting key regulatory provisions, updating LDAR monitoring plans, and reporting.
Natural Gas Processing and Liquefaction. If you get us involved early enough in your design and permitting process, we can provide guidance to your design team on the information needed to efficiently establish your LDAR program, saving you hundreds of thousands of dollars. But, we understand if LDAR isn't your priority when you are in the early design phase. We are
experts in the review of process data (P&IDs, PFDs, ISOs, etc.) for the purposes of determining the composition of fluids in contact with fugitive emission components at various stages of the process, estimating potential emissions, and establishing component databases.