ECAs and AE-EASRs
If a facility discharges or emits any contaminants to the environment, the facility is required, according to the Environmental Protection Act, to operate under either an Environmental Approval or Registration. We have helped clients obtain approvals for many years. Currently, ECAs, Environmental Compliance Approvals (previously Certificates of Approval or CofAs), are approvals that cover activities that affect air, waste and noise and are required for facilities with specific NAICS codes. ECAs can either be site-wide or have limited operational flexibility within a prescribed operational envelope. If a facility does not have a NAICS code that requires an ECA, a facility will have to register their air and noise emissions with an Air Emissions Environmental Activity and Sector Registry, or EASR.
Note that generators, cooling towers and comfort heating systems may be exempt from any approval if they meet certain specifications.
Once we determine that a client needs an ECA or EASR, we generally follow the steps listed below.
- Step 1 – We have an initial consultation with the client. At this time we set up a site visit to familiarize ourselves with processes and activities at the facility.
- Step 2 – Gather chemical data from SDSs, info from equipment specifications, and quantities of product used.
- Step 3 – Preform calculations to estimate emissions from info gathered during step 2.
- Step 4 – Run a dispersion model using site specific data.
- Step 5 – If the facility shows compliance, than an ESDM report will be prepared. If not, proceed to step 6.
- Step 6 – Try either one of the following or a combination:
- 1. Obtain more accurate data, i.e., precise quantities used.
- 2. Stack testing.
- 3. Use a different model.
- 4. Look at implementing emission control equipment.
- Step 7 – Put an application package together and submit to the MECP for the ECA stream. Assemble documents for registration on the MECP website for the EASR stream.