In Section B6 of the Progress Report, does a TURA EMS need to have been audited at least once between 2006 and 2008?
No, the regulations require that an EMS must have been audited at least once to qualify as a TURA EMS. If you are planning to use the EMS option for the 2008 planning year (i.e., you have or will modify your EMS to meet the TURA requirements by July 1, 2008), but your EMS was last independently audited prior to July 1, 2006, you would answer “no” to Question 6 (“Our EMS has been audited by a qualified independent auditor at least once during the past two year TURA planning cycle.”), and then in #8 you would explain that your audit schedule has been revised to the two-year cycle required by 310 CMR 50.82(13) and that your EMS will be independently audited prior to July 1, 2010. 33. Is Section B7 of the Progress Report redundant, since soliciting information from vendors, consultants, government agencies, etc. is part of identifying and evaluating alternatives as asked in Question 1? Question 7 complements and elaborates on Question 1 to make it more explicit that a facility should look
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- In Section B6 of the Progress Report, does a TURA EMS need to have been audited at least once between 2006 and 2008?