Michiana, a window replacement company, conducted renovation activities at target housing in 2008 and 2009. Based on the review of available information, EPA determined Michiana failed to obtain, from the owner of target housing, a written acknowledgement that the owner has received the EPA pamphlet titled Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Schools, or any pamphlet developed by EPA under section 406(a) of TSCA before beginning renovation activities, as required by 40 C.F.R.
§ 745.84(a)(1)(i). The CAFO provides for payment of a civil penalty of $684 and implementation of a Supplemental Environmental Project (SEP) by Michiana to resolve EPAÂs enforcement of seven violations of the lead hazard information pamphlet provisions under the RRP Rule. Michiana must perform a SEP in the form of a lead hazard abatement project involving window replacement at a residence in Mishawaka, Indiana, that has a state-lead paint indicator of 75. Respondent must spend at least $6,158 to complete the SEP. Contractors that Respondent hires to conduct the SEP must be certified to conduct lead abatement work and Respondent must have lead clearance testing done post-project.