8/9/16 - CONSENT AGREEMENT AND FINAL ORDER ISSUED, ASSESSING A PENALTY OF 273, DUE WITHIN 30 DAYS.
ALLEGATIONS:
RESPONDENT IS A FIRM THAT PERFORMS RENOVATIONS FOR COMPENSATION AS THOSE TERMS ARE DEFINED, BY 40 CFR 745.83.
RESPONDENT PERFORMED RENOVATION ACTIVITIES AT 104 SOUTH HUMES STREET, MEMPHIS, TN.
BASED ON INFO PROVIDED BY RESPONDENT TO EPA DATED MARCH 22, 2016, EPA ALLEGES THAT RESPONDENT VIOLATED TSCA 402 AND 406 AND 40 CFR PART 745, SUBPART E AS FOLLOWS:
A. RESPONDENT FAILED TO RETAIN ALL RECORDS FOR A PERIOD OF 3 YEARS FOLLOWING COMPLETION OF THE RENOVATION ACTIVITIES, NECESSARY TO DEMONSTRATE COMPLIANCE WITH THE REQUIREMENTS OF 40 CFR 745.385 PURSUANT TO 40 CFR 745.86(b)(6); AND
B. RESPONDENT FAILED TO PROVIDE THE OWNER OR ADULT OCCUPANT OF THE UNIT WITH EPA APPROVED LEAD HAZARD INFO PAMPHLET PURSUANT TO 40 CFR 745.84(a)(1).