The Policy for TURA Reporting and Planning for Certain Metalworking Operations provides for an exemption from TURA planning and fees and for reduced reporting for certain metals when certain conditions are met. Under the reduced reporting requirements, firms must submit -- for each metal to which the policy applies - a Form R and a Form S Cover Sheet. With regard to the Form S itself, the firm need only complete the first section. (The first page of the Form S documents be clearly marked "submitted under the provisions of BWP Policy-94-014.")
There is, however, an additional form (Recycling Activity Report Form) that must be completed on a one-time basis to provide the additional information DEP will need to determine if the conditions of the policy are met.
The following checklist is comprised of yes/no questions to help you determine if you have satisfied the conditions of the policy. The policy itself should nevertheless be read carefully.
- Is the metal being claimed under the policy copper, a constituent of a copper alloy, or a constituent of steel?
- Is the metal processed at the facility rather than manufactured or otherwise used?
- Does the metal remain solid (even if the shape of the metal changes)?
- Is scrap metal collected and sent to recycling under a comprehensive and aggressive program? (See page 3 of the policy.)
- Is all the scrap metal sent to a recycler or scrap metal broker without prior treatment (other than mechanical separation)?
- Is the only Form R-reportable release of the transfer sent to a recycler or scrap metal broker?
You should answer YES only if your facility reports NO releases of the metal as fugitive or stack emissions, hazardous waste, wastewater discharges, transfers to on-site or off-site land disposal or other releases reportable on its Form R (except the transfer to the recycler or scrap metal broker.)
If you answer YES to all the questions above, the new policy may be applicable. You should, however, read the policy to confirm whether or not you may proceed under it. If you have any questions, please contact Cynthia Chaves at 617-292-5848.
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