On February 22, 2017, Region 1 filed a Consent Agreement and Final Order resolving an administrative complaint pursuant to TSCA filed against Brady Sullivan Millworks II, LLC (Millworks) and Brady Sullivan Millworks IV, LLC (Millworks IV), for violations of the Lead Disclosure Rule and the Renovation, Repair and Painting (RRP) Rule. The RRP Rule violations resulted from the renovation of a portion of a Manchester, New Hampshire former mill building owned by Brady Sullivan conducted by a subcontractor for the purpose of converting the space to apartments. Because the sandblasting activities were not properly contained, dust containing high levels of lead spread to common areas and residential units located on the upper floors of the building. In June 2015, Region 1 issued an Order to Brady Sullivan under Section 7003 of RCRA to clean up the lead dust in the building. Millworks II owns the third and fourth floors of the building where the residential apartments are located. Millworks IV owns the area where the renovation was being conducted on the first floor. Children and at least one pregnant woman resided in the building at the time of renovation. The specific violations alleged in the complaint were as follows: Millworks II - failure to provide lessees with records or reports pertaining to lead-based paint or lead based-paint hazards. Millworks IV (as general contractor) - failure to obtain initial firm certification; failure to assign a certified renovator; and fa