The Public Involvement Requirements of the MCP raised questions from the regulated community about who was responsible for conducting PIP activities at Tier IA sites. In effort to clarify who should perform these activities(e.g., the Department, the PRP/LSP, or a combination of both), and to facilitate the implementation of public involvement activities at Tier IA sites, the Department has developed the table below. The table lists the public involvement activities that are specified in the MCP or in the Public Involvement Guidance, policy # WSC 800-90 and identifies the party required or recommended to conduct the activity. The Department understands that there may be site specific conditions which would occasionally require a variation from these procedures.
| PUBLIC INVOLVEMENT ACTIVITIES at TIER IA PIP SITES |
WHERE PIP ACTIVITY IS NOTED |
PARTY REQUIRED or RECOMMENDED TO CONDUCT THE ACTIVITY |
| Respond to petition |
MCP (310 CMR 40.1400) |
PRP |
| Interview petitioners and others |
Interim Policy # WSC-800-90 |
PRP and MassDEP |
| Develop and maintain mailing list |
MCP (310 CMR 40.1400) |
PRP |
| Develop DRAFT PIP |
MCP (310 CMR 40.1400) |
PRP |
| Review DRAFT PIP for compliance with MCP and guidance |
MCP (310 CMR 40.0100) |
MassDEP |
| Finalize PIP |
MCP (310 CMR 40.1400) |
PRP |
| Review and approve Final PIP |
MCP (310 CMR 40.0100) |
MassDEP |
| Revise PIP as necessary |
MCP (310 CMR 40.1400) |
PRP and MassDEP |
| Notification of any field work related to response actions involving a) the implementation of involving Phase IV remedial actions b) the use of respirators and other protective clothing, (c) or any sampling involving private drinking water supply wells, indoor air or surficial soils at any residential property adjacent to, or downgradient from any release |
MCP (310 CMR 40.1400) |
PRP |
| Prepare notifications (PIP meeting, IRA+IRA Completion Statement -Imminent Hazard, RAM, RAO statement, Phase reports, DPS |
MCP (310 CMR 40.1400) |
PRP |
| Mail notices of the availability of documents to mailing list |
MCP (310 CMR 40.1400) Interim Policy # WSC-800-90 |
PRP |
| Mail notices of meetings, fact sheets, and etc. to mailing list |
MCP (310 CMR 40.1400) Interim Policy # WSC-800-90 |
PRP |
| Prepare legal notices (Tier I Classification and Permit Application, Site Reclassification, Permit Modification, Transfer, or Extension, Tier II classification, PIP Mtg., AUL or Environmental Restriction) |
MCP (310 CMR 40.1400) |
PRP |
| Prepare MEPA Notices (changing a Tier I classification, availability of a RAP or RIP) |
MCP (310 CMR 40.1400) |
PRP |
| Coordinate and conduct dry runs with participants |
Recommended |
MassDEP |
| Coordinate meeting logistics (room, equipment, etc.) |
MCP (310 CMR 40.1400) |
PRP |
| Run PIP meeting and other meetings specified in the PIP |
Recommended |
MassDEP |
| Prepare meeting summaries |
Interim Policy # WSC-800-90 |
PRP |
| Draft responses to comments |
Recommended |
PRP or MassDEP |
| Respond to comments |
MCP (310 CMR 40.0100) |
DEP |
| Mail responsiveness summaries |
Interim Policy # WSC-800-90 |
DEP |
| Establish and Maintain the information repository |
MCP (310 CMR 40.1400) |
PRP |
| Respond to miscellaneous concerns |
Recommended |
PRP and MassDEP |