Non-editable Data on eDEP Forms

Form Questions

PRP/Client/Multiple Reviewer

Electronic Signature

eDEP System

Miscellaneous

Training

How do you file an AUL in eDEP?

MCP submittals filed via eDEP are no different than submittals filed in paper. eDEP does not change filing requirements, hence the regulatory requirements and applicable policies and guidance documents are the same. The BWSC113A (previously BWSC114) is the required Exhibit D that is recorded and registered at the Registry as part of an AUL filing. (See document - Guidance of Implementing Activity and Use Limitations issued May 1999.)
To file the AUL in eDEP:
* Fill out the BWSC113 and BWSC113A forms in eDEP.
* Print the BWSC113A
* Take the completed original BWSC113A, signed by the LSP, to the Registry to be recorded, registered and appended to the AUL
* When you have the Book and Page Number from the Registry, complete the BWSC113 in eDEP
* Note that the BWSC113A in eDEP is submitted without a LSP signature since the original BWSC113A is filed with the registry. We understand that this is confusing and are working on a solution so that it is clear.
* Scan the certified AUL instrument which includes the signed BWSC113A and attach it to the BWSC113 in eDEP.
* Sign the BWSC113 where appropriate and submit via eDEP.  The eDEP BWSC113 allows for different signatures for the PRP and client.

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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 "Release/Site Location" or "Relationship to the Release of the Person Undertaking the Response Action" the  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 "Release/Site Location",  and "Relationship to the Release of the Person Undertaking the Response Action", 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. To make those changes permanent in the database, please send an email to BWSC.eDEP@state.ma.us listing the RTN and the correct information for MassDEP to update the database.
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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When filing BWSC107 Tier Classification Transmittal Form for a new Tier Classification for a Tier II Site and submitting a Phase I Completion Statement and the Phase II Conceptual Scope of Work (or the Phase II Scope of Work), is it necessary to also submit the BWSC108 Comprehensive Response Action (CRA) Transmittal Form & Phase I Completion Statement?

No, it is not necessary to submit the BWSC108 and submit the same reports, i.e. Phase I Completion Statement and the Phase II Conceptual Scope of Work (or the Phase II Scope of Work) as where submitted with the BWSC107.  BWSC108 CRA Transmittal Form is a stand alone form to be used to submit the Phase I Completion Statement, Phase II Conceptual Scope of Work or the Phase II Scope of Work when you are submitting these reports independent of the BWSC107 Tier Classification Transmittal Form. 

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If  supporting documentation for an eDEP submittal is over the 30 MB limit, what options are available? 

1. Shrink the size of the document using the tips posted in the Managing BWSC eDEP Attachments document.  Click on the link to view the document.
      http://www.mass.gov/dep/cleanup/approvals/attsiz.doc 
     
2. Upload just the text portion of the document (up to 30 MB) in eDEP, and submit  the remainder of the report and/or data reports to the regional office on a CD accompanied by a BWSC125 .  Note in the uploaded report what is being submitted on CD.

3.  Submit all supporting documentation to the regional office on a CD accompanied by a BWSC125 .

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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, for example,  that contains both a Status Report and a Phase Report?

On the Attach Files Page, there will be prompts 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 Status Report and Phase Report submittals, if the report for both submittals is contained in one document (30 MB or less), you can upload the report at the first prompt that calls for an attachment.  At the second prompt 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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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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Where can I find the eDEP RMR or NRS forms since they are not listed in the eDEP 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 Transaction Overview page until the main transmittal form has been filled out and validated. You must indicate in Section B of the main eDEP Transmittal Form that you are submitting an RMR form. When the validation step for the main form 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 Transaction Overview page of the eDEP transmittal form, BWSC107, until you indicate on the transmittal form that an NRS is required. When the validation step for the BWSC107 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 are not available on the Transaction Overview page until you indicate on the BWSC107 form that you want to submit a Compliance History or the Transferor Certification form and you complete and validate the BWSC107 transmittal 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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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.

MassDEP is working on streamlining the notification process, but in the meantime DEP regional offices are committed to entering the 120 day RNFs into the DEP database as soon as possible in order to facilitate eDEP filing.  You will need to wait until the RTN is assigned and data entered by the regional office before making eDEP submittals.

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How does the LSP act as an Agent of PRP and sign the PRP Certification Statement?

The same rules apply for eDEP as for a paper transmittal form, the authority to authorize the LSP to act as the agent of the PRP is found in the MCP at 310 CMR 40.0009(2). For paper transmittal forms the PRP submits a letter to the appropriate regional office authorizing the LSP to act as their agent for response actions at the site (RTN). In eDEP the PRP writes the same letter and the LSP uploads the letter and attaches it to each eDEP submittal for that RTN. The authorization letter can be added to whatever document is being submitted in eDEP.  The LSP then signs their own name in the PRP Certification section "For the Person Undertaking Response Actions"

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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.  Once the eDEP account is created, the user is taken directly to their My eDEP Homepage and can begin using eDEP.

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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".

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.   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 Submittal" 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.

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.   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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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 3 ways that you can confirm that DEP has received the electronic submittal:

1. Open and print the Submittal Summary and Receipt, found on the Transaction Overview 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 Transaction Overview 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.

3.  The online Waste Site / Reportable Release File Viewer is now available. The documents viewable include all site information submitted electronically via eDEP: Web page.

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What types of documents can be submitted in eDEP?

To upload to eDEP, the file must:

• Be less than 30MB 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 30 MB in size can be uploaded in eDEP. Any file greater than 30 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 Transaction Overview page, click on the 'get 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?

30 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 Can I Conduct a Review of Electronic Submittals?

An online Waste Site / Reportable Release File Viewer is now available. The documents viewable include all site information submitted electronically via eDEP: Web page.

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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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