By: Scott Manser
If your Ontario business is emitting compounds into the air, or has sources of noise associated with its operations, you will most likely need to register through the provincial Environmental Sector Activity Sector (EASR) system. The EASR system is the default path, with exclusions for specified industry codes and process operations. Facilities covered either in whole or in part by these exclusions are required to obtain an Environmental Compliance Approval (“ECA”).
Although numerous exemptions from the requirement to register or obtain an ECA exist, the Ministry of Environment, Conservation and Parks (MECP) has made it clear that exempt sources still require an assessment against the provincial air quality criteria. Often, we find that permitting and assessment requirements are not well understood, and the value that is driven from it may not be clear. At ORTECH we make every effort to help the process move along rapidly, and strive to help you understand our methods.
Regardless of the regulatory system in place it is important that all contaminants (including noise) emitted into the environment by your facility are assessed. It is also imperative for facilities to understand that planned modifications trigger a re-assessment of emissions and an amendment to either the EASR or ECA. These planned modifications may include (but are not limited to) the addition of equipment, changes in process rates, or a reformulation of existing materials.
For facilities subject to the EASR system, modifications can be assessed and registered within a relatively short time frame (a few weeks). For facilities requiring an amendment to an ECA approval, MECP is currently providing a one-year service standard. For this reason subject facilities may also apply for an ECA with Limited Operational Flexibility which permits most modifications from occurring without having to receive an amendment to the ECA. In a fast-paced market condition, this allows facilities to adapt quickly, meet new customer requirements, or expand product lines.
How ORTECH can help
Practicing an "Educate-Plan-Comply" progression to ensure our clients comprehend the ECA process, our aim is for you to fully know the implications for your company. We have worked on countless applications and have fine-tuned our approach, concentrating on a client-centric focus.
ORTECH can assist you in determining the regulatory requirements of your air and noise emissions: EASR, ECA or exempt. As part of our service offerings ORTECH can:
Discuss the pros and cons of an ECA with Limited Operational Flexibility;
Work with the client to assemble documentation and information required to support the assessment results;
Complete a site visit;
Review your current Emission Summary and Dispersion Modelling (ESDM) Report, if available, and update to include any changes;
Complete dispersion modelling and compare results to MECP air quality limits;
Complete primary or secondary noise screening and coordinate an Acoustic Assessment Report (AAR), if required;
For EASR documents, provide the required Professional Engineer seal and signatures;
Assemble the ECA application, including all supporting documents and forms;
Regularly follow up with the MECP to check the status of the application;
Assist in answering technical questions the MECP review engineer may have; and
Review the draft ECA to ensure the Terms and Conditions are appropriate and accurate.
ORTECH can assist you with maintaining compliance with the new permit by providing the following services, if applicable:
Assist in preparing an operating manual;
Complete source testing and/or odour testing;
Prepare and maintain a modification log;
Review facility operations and assess modifications which may require an update to the ESDM Report; and
Prepare the Annual Written Summary Forms and supporting documentation for ECAs with Limited Operational Flexibility.
