EPA seeks to resolve claims against Two State's Exterior for violations of its Renovation, Repair, and Painting (RRP) Rule, TSCA 402C - Lead: RRP. The following violations of the RRP Rule were observed or documented:
All Renovations: Failure or refusal to establish and maintain records, or to make available such records, pursuant to 40 C.F.R. ?745.87(b), which states that such failure or refusal is a violation of TSCA?409
40 C.F.R. ?745.89(a)(1) & 745.81(a)(2)(ii) - Failure to obtain initial firm certification from EPA
40 C.F.R. ?745.85(a)(4)(ii) - Waste from renovations: Failure at the conclusion of each workday and/or at the conclusion of the renovation, to ensure that waste that has been collected from renovation activities was stored under containment, in an enclosure, or behind a barrier that prevents release of dust and debris out of the work area and prevents access to dust and debris.