Non-editable Data on eDEP Forms

Form Questions

PRP/Client/Multiple Reviewer

Electronic Signature

eDEP System

Miscellaneous

Training

How do you correct inaccurate data on the preloaded forms in eDEP?

For the first time, by using eDEP, PRPs and LSPs are able to view data exactly as it is stored in the MassDEP database. The user now has the opportunity to verify the accuracy of the data and to assist MassDEP in updating the data.

1. In order to maintain data integrity, certain sections such as the "Relationship to the Release of the Person Undertaking the Response Action" or the "Release/Site Location" information cannot be updated directly on BWSC forms. For quality control purposes, eDEP pulls data directly from the MassDEP BWSC database, and only certain staff has the authority to update these fields. Therefore, to update information in the form sections, "Relationship to the Release of the Person Undertaking the Response Action" and "Release/Site Location", please send an email to BWSC.eDEP@state.ma.us listing the RTN and the correct information for MassDEP to update the database.
2. For other sections, such as the information contained in the "Person Undertaking Response Actions" section, including the contact name, address information, and phone numbers, users can update the information in certain fields directly on the eDEP BWSC Transmittal Forms. The plan is to have these changes to automatically update the database. However, eDEP does not yet have the capability to perform this function. In the interim, MassDEP requests that you please send an email to BWSC.eDEP@state.ma.us listing the RTN and the correct information for MassDEP to update the database, as in A.
3. For LSP Section, if the telephone number that appears on the eDEP form is incorrect, please send an email to BWSC.eDEP@state.ma.us listing the correct telephone number and MassDEP will update the database.

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In the "Required Attachment and Submittals Section" of a BWSC transmittal form, what does the statement below mean?  The statement is found on all BWSC transmittal forms.

Check here if the Response Action(s) on which this opinion is based, if any, are (were) subject to any order(s), permit(s) and/or approval(s) issued by DEP or EPA.  If the box is checked, you MUST attach a statement identifying the applicable provisions thereof.

The "opinion" noted above is the LSP Opinion that is a combination of the transmittal form attestation section (where the LSP signature and stamp/electronic seal is placed), and any site specific information that is attached as supporting documentation.   eDEP will require that you attached a summary of the site specific requirements, such as order(s), permit(s) and/or approval(s) issued by DEP or EPA if you check the box found in the Required Attachment and Submittals section of all BWSC transmittal forms.

The attachment is a one-page statement identifying the specific order or approval of the response action that you will upload to the submittal.  For example, an Interim Deadline specifies that an Imminent Hazard Evaluation is required.  The statement should reference that the submittal is being made as part of an Interim Deadline requirement. 

The due dates for MCP submittals are specified in the provisions related to a given submittal.  For example, the due date for a Tier Classification Submittal is specified in 310 CMR 40.0501(3).  The MCP at 310 CMR 40.0008 details when a grace period is applicable.

In Summary:  A 7-day grace period from the actual due date is allowed for most submittals.  In other words, the submittal is considered received on time if the document is delivered within 7 calendar days of the actual submittal due date.  If given by electronic transmission the document is considered received by the due date, if the date the transmission is delivered to the Department is within 7 days of the due date.   If the actual submittal due date falls on a weekend, holiday or any other day MassDEP offices are closed, the due date runs to the end of the next business day and the 7-day grace period is calculated from that day.  If the 7th day of the grace period falls on a weekend, holiday or any other day MassDEP offices are closed, the last day of the 7-day grace period is the next business day. 

The following are NOT subject to the 7-day grace period:

• Notifications required by 310 CMR 40.0300, including Notification of Releases, Threats of Release and Imminent Hazards
• The date of MassDEP's receipt of a written request for approval of an IRA
• The computation of time periods for timely action for Tier I Permits.  (Note: Tier I Permit Applications are subject to the 7-day grace period only if a copy of the permit application fee remittance is attached to the application and the applicant certifies that the application fee has been mailed or hand-delivered to MassDEP concurrent with submittal of the application or the permit application fee has been paid by electronic transmittal).
• Submittals required by Interim Deadlines
• Submittals required by Notices of Noncompliance
• Any deadline in any MassDEP enforcement order, penalty assessment or other enforcement document.

These exceptions to the 7-day grace period are set forth in more detail in 310 CMR 40.0008(5).

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By signing the eDEP Transmittal Form, the Person Undertaking the Response Action is certifying the completeness of the transmittal form and the work performed/status at the site detailed in the supporting documentation.  To ensure that the steps in the electronic mode of submittal do not circumvent the ability of the Person Undertaking the Response Action to review that supporting documentation, the requirement to upload the documentation takes place before the Certification (Signature) step in eDEP.

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 What if I have one report that contains both the Status Report and RMR information?

On the Current Submittal Page, there will be steps in eDEP to up upload an attachment for each submittal checked off in Section B on the BWSC Transmittal Form.  In the example of the BWSC105 Status Report and RMR submittals, if the report for both submittals is contained in one document (20 MB or less), you can upload the report at the first step that calls for an attachment.  At the second step in eDEP that calls for an attachment, upload a memo indicating that the required information is contained in the previous document uploaded to the submittal form.

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BWSC transmittal forms are multi-purpose, meaning that more than one MCP "submittal" can be transmitted to MassDEP on a form.  For example, BWSC105 can be used to submit a Status Report and a RMR to MassDEP.  An attachment (up to 20MB) can be uploaded to each of these "submittals", which correspond to each box checked off in Section B of the Transmittal Form. 

If you are making multiple submittals on a BWSC transmittal form and the report containing the required documentation is larger than 20MB, there are several options available to upload the document.

1. Split the Report into 2 portions and upload a portion of the report at each eDEP documentation prompt.  Use a cover memo as the first page of each document explaining that the report is split in two and is attached to this transmittal form.

2. Submit the transmittal form and report through eDEP and submit data tables or large appendices on a CD.  Include a copy of the Transaction Summary Report with the CD.

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It seems that UTM Coordinates are now required on most BWSC transmittal forms. Is this a new MCP requirement?

UTM Coordinates are required for the submittal of the BWSC103 Release Notification and Retraction Form and BWSC107A Numerical Ranking System (NRS) Scoresheet Form.

UTM Coordinate fields are optional on all other BWSC forms. These forms will validate in eDEP with the UTM fields left blank.

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What do you do in eDEP when submitting BWSC105 for an IRA Completion Statement, when it is within 60 days of notification and no IRA Plan has been submitted? The BWSC105 form will not validate in eDEP. The error message brings you back to the form at B.1., List Submittal Date of Initial IRA Written Plan. Since there is no written IRA Plan to submit, there is no date to put on the form.

In the IRA Plan date field, please use the same date as the Oral Approval date for the IRA. The form will not validate without a date in that field. We are working to make the validation more flexible.

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What is an eDEP Sub-form? Where can I find the eDEP RMR or NRS forms as they are not listed in the eDEP dropdown list of forms?

The Remedial Monitoring Report (RMR) is a sub-form to the following forms: BWSC105, Immediate Response Action Transmittal (IRA) Form; BWSC106, Release Abatement Measure (RAM) Transmittal Form; BWSC108, Comprehensive Response Action Transmittal Form; and BWSC119, Utility-Related Abatement Measure (URAM) Transmittal Form. Sub-forms are secondary forms that do not appear on the Current Submittal page of the main transmittal form (BWSC105, 106, 108 or 119 for the RMR), until the main transmittal form has been filled out and validated. You must indicate on the main eDEP Transmittal Form, that you are submitting an RMR form. When the validation step for the main forms is completed, the RMR is then available to fill out.

Another example of a transmittal form with sub-forms is the BWSC107 Tier Classification Transmittal Form. The BWSC107A Numerical Ranking System (NRS) Scoresheet not a stand -alone form, and does not appear on the Current Submittal page of the eDEP main transmittal form, BWSC107, until you indicate on the main transmittal form that an NRS is required. When the validation step for the main form is completed, the NRS is then available to fill out. The BWSC107B Tier II Compliance History and BWSC107C Tier II Transferor Certification are also sub-forms of the BWSC107 Tier Classification Transmittal Form and will not appear on the BWSC107 Current Submittal page until you indicate on the main transmittal form that you want to submit a Compliance History or the Transferor Certification form and you fill out and validate the main BWSC107 transmittal form.

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Can you make minor changes to the paper copy of a BWSC form that has been previously submitted via eDEP, i.e., changing the paper copy only?

No. When a BWSC form or documentation has been submitted in eDEP, it is not permissible to make changes on the paper copy of the form or the submittal documentation that is filed with the MassDEP regional office since you will be altering the statement of record. To make a change to a previously submitted BWSC form in eDEP, the PRP and LSP, if required, must submit a revised transmittal form or permit noting the change on the form.

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Do I have to fill out the sub-form part B of the RMR, if I do not have any system effluent/discharge? The validation does not allow me to leave the form blank.

The current validation of the RMR requires that if you have an active remedial system (A1a), you must indicate the kind of effluent/discharge (A3). If you do not have any discharge, then select the "Other" option to satisfy the validation, and describe accordingly. The effluent/discharge validation also creates part B of the form, and the first line must be completed to bypass this sub-form.

If there is no monitoring criteria for the system that is applicable to the part B sub-form, then you may fill out the required fields with: "NA" as the Point of Measurement, the date you are making the submittal as the date, "None" as the Contaminant, Measurement and/or Indicator Parameter, check Discharge, check ND/BDL, "0.0" as the Permissible Concentration, "None" as the units, and "Y" for within the Permissible Limits. We recognize that these entries do not represent actual data, but you may caveat that in your supporting documentation.

We initially establish validation rules based on what applies in the majority of situations, and in most cases, a treatment system or monitoring program has at least one point of measure, whether it be influent/effluent to the system, or sampling of a related monitoring well. We have since realized that this restriction may not necessarily accommodate all situations, and we will correct this oversight in a future version of the form.

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After selecting the Transmittal Form in eDEP and entering the Release Tracking Number (RTN) on the Pre-Form page, eDEP is telling me that the RTN I entered is not valid. Why is that happening? This is an RTN that has been around for a long time, for example, RTN 3-00XXX.

When entering an RTN on the BWSC Pre-Form -page, first use the dropdown arrow to select the Region Number of the RTN. Then enter the Tracking Number, but do not enter the leading zeros. In the example, RTN 3-00XXX, just enter the XXX Tracking Number without the two zeros in front. eDEP will then retrieve the applicable disposal site information from the MassDEP database.

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Are the Transmittal Forms updated?

The following BWSC Transmittal forms have been revised to reflect submittal requirements in the April 3, 2006 MCP Revisions: BWSC103 Release Notification and Notification Retraction Form; BWSC104 Response Action Outcome (RAO) Statement; BWSC105 Immediate Response Action Transmittal (IRA) Form; BWSC106 Release Abatement Measure (RAM) Transmittal Form; BWSC108 Comprehensive Response Action Transmittal Form; and BWSC119 Utility-Related Abatement Measure (URAM) Transmittal Form.

BWSC103 is in fillable format when downloaded from the web and in eDEP. UTM coordinates will not be required on the BWSC103 until July 3, 2006.

Starting April 4^th, 2006, a 90-day Transition Period began, where MassDEP will accept both the old and new versions of BWSC103 RNF, BWSC104 RAO, BWSC105 IRA, BWSC106 RAM, BWSC108 CRA and BWSC119 URAM. As of Monday, July 3, 2006 the old versions of the forms will no longer be accepted.

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How can I use eDEP for 120-day notifications?

Currently it is not possible to use eDEP for the initial filing of a BWSC103, Release Notification and Release Retraction Form, for a 120-Day notification condition.

The Regional Office cannot assign the RTN until the BWSC103 form is received. The original BWSC103 must be submitted in paper, manually, to the appropriate MassDEP regional office where MassDEP will assign the RTN to the release and enter the RTN information into the database. Once the RTN is entered into the database, eDEP can be used for all future MCP submittals. This procedure does not impact the eDEP submittal of BWSC103 for a 2-hour or 72-hour reporting condition that has been assigned an RTN by MassDEP. MassDEP is looking at ways to streamline assigning RTNs to 120-Day notifications.

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Is a Client (Person Making the Submittal) required to submit a Proof of Identity?

No, the registration process is very simple for most clients needing to certify BWSC Transmittal Forms.  The client would click on the new user link on the eDEP Homepage, https://edep.dep.mass.gov/DEPHome.aspx and set up their eDEP account, creating a user name and password.  A nickname is also created at the time of registration that is used to share forms in eDEP.  The client does not need to submit a Proof of Identity form to allow certification of BWSC Transmittal Forms through eDEP.   In "Step 2 of 2: How will you use eDEP?" of the registration process, the client is usually not one of these users, and should skip this page by clicking on the button next to  "No, none of the items describe me or how I will use eDEP".  The client should then click on the "NEXT " button (blue), to be brought to his/her personal eDEP Homepage. 

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Why does eDEP keep rejecting my client's signature at the Signature Step for the Person Undertaking Response Actions?

Please note that in eDEP the name of the person entered in the first field of the Certification of Person Undertaking Response Actions section on the transmittal form, must match EXACTLY the name entered in the Signature step of eDEP.

"EXACTLY" means that initials, punctuation, such as periods, and spaces used in this field of the Certification of Person Undertaking Response Actions section must be duplicated precisely the same in the Signature Step in eDEP for that person. For example: On BWSC105 IRA the name entered in Section I. 1., or on BWSC108 CRA the name entered in Section G. 1., must match exactly with the name entered in the Signature step of eDEP.

Please be aware that differences in capitalization do not matter in the eDEP. The name of the Person Undertaking Response Actions can be entered all in capital letters and the Signature entered all in lower case, and as long as the name is entered exactly the same, the signature entered in the Signature Step will validate in eDEP with no problem.

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What does the word "Owner" mean in eDEP? When I try to share my transmittal form with my client for signature, do I make my client the "owner" since he/she owns the property where the release is located?

Any eDEP user can begin a form, the LSP, the person performing the response action, or the Administrator. In eDEP, the person who begins the form is the eDEP form "owner".

Remember the words "eDEP Form Owner" when you want to share a BWSC transmittal form. When sharing a form in eDEP, the word "Owner" only applies to the BWSC transmittal form, it has no relationship to the site, the RTN or the owner of the property.

In eDEP, after completing the BWSC transmittal form and related sub-forms (if any) and the supporting documentation is uploaded, is the time when the LSP would most likely want to share the form with the client for review and signature.

Only the form "Owner", the person who started the form, has the ability to share the form with other eDEP users.

On the page "Share a Submitttal" note the box labeled "Role". Usually if you are sharing the transmittal form with the client, you will select the role of Editor and Signer or maybe just Signer.

If you select the role of Owner, then your are in fact transferring ownership of this submittal to the other person and giving that eDEP user the ability to share the transmittal form or to delete the form prior to submittal to DEP.

Make sure that you want to transfer ownership of this transmittal form to another eDEP user if you select "Owner" here.

For example, in your company, an assistant begins the BWSC form, the assistant sends the form to the LSP for review and signature and the LSP needs to send the form to the client for review and signature. The assistant, who began the form, is the form owner. When the assistant shares the form with the LSP, the assistance must choose to give the LSP the role of "Owner" of the transmittal form if the LSP wants to share the form with another eDEP user. Ownership of the form will allow the LSP to share the form with the client.

In eDEP the role of "Owner" of a BWSC form has no relationship to the RTN, the site or ownership of a property. In most cases the LSP will want to retain "ownership" of the BWSC transmittal form and give the client the role of "Reviewer and Signer" of that particular BWSC transmittal form.

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I am reviewing a shared transmittal form with my client, and I cannot see their edits or certification?

It is not possible for both of you to be updating the form at the same time, and see any changes made until the form has been saved to the system. You and your client need to exit the form, so the form and data can refresh.

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What happens if the client is not computer literate, or does not have access to or own a computer?

MassDEP recognizes that some clients are reluctant to authorize the use of eDEP for their submittals for a number of reasons. However, electronic business processes are becoming the normal way of doing business rather than the exception. MassDEP is committed to working with the regulated community over the next 18 months to ease the transition and address the clients' concerns.

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How does the client sign an eDEP submittal?

Both the LSP and the Person Making the Submittal (PRP) must register in eDEP. Go to the MassDEP homepage and click on online filing. https://edep.dep.mass.gov/DEPHome.aspx. For the client, the registration process is similar to creating any online account with a user name and password. The PRP does not need to submit to the Proof of Identity form that the LSP is required to stamp and send to MassDEP. There is a sharing function in eDEP that allows BWSC documents to be shared, edited and electronically signed by each party. Signatures on paper copies are not required if the submittal is made through eDEP. The electronic signature is the legal signature of the document.

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How are forms made available to more then one user, i.e. for signing purposes?

Forms can be shared in eDEP by using a registered user's Nickname.

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After I have submitted a transmittal form through eDEP, do I need to stamp and sign the hard copy of the transmittal form that I attach to the supporting documentation mailed to MassDEP?

No. You do not need to sign the hard copy of a transmittal form that has been submitted through eDEP. Note that you should not print out the final copy of the transmittal form until you have submitted it through eDEP. The submitted copy will have the electronic signatures of both you and your client, and the electronic LSP stamp, as well as, an eDEP date stamp confirming the date and time of submittal through eDEP.

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Does an electronic signature have the same legal protections as a written signature?

There is detailed case law establishing the legality of electronic signatures. Electronic signatures carry the same legal authority as a hand written signature. MassDEP is confident that the use of the electronic signature is appropriate and legal for eDEP submittals and will continue to conduct outreach to the regulated community to address their concerns.

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Are the electronic submittals and signatures secure?

Once MassDEP receives a submittal electronically, it is in Read-Only format and cannot be changed. The eDEP signature is only available to the eDEP account holder with that user name and password.

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Once I press the eDEP submit button, what proof do I have that DEP has received the electronic submittal?

There are 2 ways that you can confirm that DEP has received the electronic submittal:

1. Open and print the Submittal Summary and Receipt, found on the Current Submittal page for the eDEP transaction.  The Receipt shows the date and time DEP received the transmittal, also shown are the RTN, site location, name of person making submittal, LSP name, person making the certification and any ancillary (uploaded) document(s). 

2. Open the transmittal form from the Current Submittal page and print the form, the DEP Date and Time of Receipt will be imprinted in the Receipt Box on the last page of the transmittal form.

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What types of documents can be submitted in eDEP?

To upload to eDEP, the file must:

• Be less than 20MB in file size
• Be in one of the following formats:
  doc, gif, html, jpeg, jpg, pdf, rtf, tiff, txt, xls, xml, xsl, or zip.

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What sizes of documents can be submitted in eDEP?

Files up to and including 20 MB in size can be uploaded in eDEP. Any file greater than 20 MB should be submitted on CD to the appropriate regional office. Along with the CD, please submit a paper copy of the eDEP Transaction Summary Report to indicate the RTN and transmittal form associated with the documents on the CD.

For a RMR submittal that includes a large amount of data, the RMR Report can be uploaded in eDEP together with the RMR transmittal form. The RMR data reports can be submitted on CD together with the eDEP Transaction Summary Report.

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Can you save an eDEP Transmittal Form or Permit to the hard drive of your computer?

Yes. There are two ways to save the eDEP Transmittal Form or Permit to your hard drive. From your My Homepage, or the Current Submittal page, click on the 't copy' link for the submittal you want to save. The 'get copy' link activates the eDEP batch processing function that compiles the form(s) for the specific transmittal into a file that can be downloaded to your hard drive. Note that when the 'get copy' link is clicked, it will compile the form for that specific moment. More specifically, if you run the batch processing when the form is still a work in progress, it will not display the completed and submitted form, even if you submit the form before the batch processing is completed.

If your computer is running a full suite of Adobe, such as Acrobat Professional, the second way to save the form to your hard drive is to use the browser's 'Save As' function to save a copy of the completed form. However, if you only have Adobe Reader, this option is not applicable.

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What are the compatibility issues between operating systems and software, and what are the systems/software requirements to use eDEP?

The minimum requirements for using the eDEP online system are detailed below:

Windows PC:

Microsoft Windows NT 4.0, 2000, or XP
Microsoft Internet Explorer Version 5.0 and higher or Netscape Navigator Version 7.0 and higher
For best performance use the latest version of the FREE Adobe Reader (Version 7.0.7 or higher). Other Adobe Reader Versions above 5.0.1 will also work EXCEPT for Versions 6.0.0 and 7.0.0, which will NOT work in eDEP because of known bugs in Adobe's software.

Macintosh:

Mac OS 10.2.8 or greater
Apple Safari Browser
For best performance use the latest version of the FREE Adobe Reader for Mac (Version 7.0.7 or higher). Older versions of Adobe Reader for Mac do NOT work with eDEP. To ensure compatibility, please download the latest version.

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What is wrong when the Transmittal Forms will not load in Adobe in eDEP?

eDEP computer requirements noted above call for users to have Adobe Reader 5.0 or above installed on the computer. eDEP will not work (PDF forms will not load properly) if earlier versions of Adobe Reader or Acrobat are also installed.

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Will the file size limitation in eDEP be increased?

20 MB is the current size limit for each eDEP attachments, and can be increased in the future if needed.

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Why is the response time slow when working with eDEP slow, and why does the system go down completely at times?

The response time in eDEP is usually very good. There is scheduled maintenance of eDEP that is noted on the web site, and occasionally there are unforeseen problems or crashes. Please contact the eDEP Help Desk at DEP.Help@state.ma.us, if you have questions regarding eDEP system response time or availability concerns. MassDEP is working on making the response time even faster.

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How do you save a form in eDEP?

Any form created in eDEP can be saved the hard drive of your computer by using the "Save As" function.

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How Can I Conduct a Review of Electronic Submittals?

Electronic file review is the goal of eDEP.   In the interim the following steps should be followed when conducting a site file review.

1.      There is a list available in the regional service centers, updated frequently, which details all eDEP submittals.   Please review the list to see if the RTN under review has any eDEP submittals.

2.      If there is no paper copy of the forms and/or supporting documentation in the site file under review, and you need to review the documents, please send an email to the eDEP mail box, BWSC.eDEP@state.ma.us , and include the following information:

• RTN
• eDEP Transaction number of eDEP submittal requested
• Supporting documentation requested
• Name of person requesting file
• Telephone number
• eMail address

3.   MassDEP will send the file(s) to you via email.  Please be sure to include your telephone number with your request.  If the file(s) cannot be sent via email due to size constraints, MassDEP will contact you to make additional arrangements.

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Can a Company Title be added or updated in the MassDEP Database?

Currently it is not possible to update or add a title in the MassDEP database. It is anticipated this field in the database will be fixed in the near future.

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Why is tax I.D. number needed on the Standard Proof of Identity form?

The tax I.D. number is only needed to grant an Administrator access to eDEP Submittals. If Administrator level is not required then the Tax ID is not required.

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Is there a fee associated with eDEP?

No additional fee is required.

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Is there a mechanism to allow a practice session or practice projects?

Registered users can practice creating, sharing and signing submittals at any time in eDEP. Submittals can be deleted at any point prior to clicking on the eDEP submit button.

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Are there instructions on current web page regarding eDEP and electronic submittals?

There are 2 power point training presentations on the BWSC Online Filing homepage, http://www.mass.gov/dep/service/compliance/edepbwsc.htm Scroll down to bottom of the page to locate the presentations.

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