Document 37GGQprj3N7v7XwO2Y6KOMb16

ft E A ~ United States .._..,~ Environmental Protectior ,,. Agency Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 12/11/2024 Toxic Substance Control Act Renovation Repair and Paint (RRP) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Arkansas Restoration Inc. Arkansas Restoration Inc. 5000 Northshore Lane North Little Rock, Arkansas 72118 Pulaski County (501) 753-3600 James Edwards james@arkrestoration.com I I General Manager FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A N/A N/A 236115 1521 Personnel participating in inspection: Angela Hays EPA Region 6 Stan Lancaster EPA Region 6 James Edwards Arkansas Restoration, Inc. Adam Wiechern Arkansas Restoration, Inc. Inspector Inspector General Manager Project Manager EPA Lead Inspector Signature/Date ANGELA HAYS Digitally signedbyANGELAHAYS Date: 2025.01.2915:14:05 -06'00' Angela Hays Date Supervisor Signature/Date Stuckey, Troy~:~a;~;!~;,~r;;~~~: Troy Stuckey Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION Arkansas Restoration, Inc. Inspection Date 12/11/2024 PURPOSE OF THE INSPECTION The focus of the inspection was to evaluate compliance to the Toxic Substances Control Act (TSCA) Lead Base Paint, Renovation Repair and Paint (RRP) rule, codified at 40 C.F.R. 745, Subpart E. The company was identified during a larger effort to inspect companies that perform RRP work in Arkansas. FACILITY DESCRIPTION Arkansas Restoration, Inc., is based in North Little Rock and Hot Springs, Arkansas. The facility offers services in emergency restoration, damage repair, and remodeling for commercial and residential properties. Section II - OBSERVATIONS On 12/11/2024 EPA inspectors Angela Hays and Stan Lancaster visited the offices of Arkansas Restoration Inc (ARI). The inspectors presented their credentials and explained the purpose of the TSCA RRP inspection. Mr. Edwards received and signed the Notice of Inspection (NOI) (Appendix 1). The inspectors began the interview with ARI and completed the RRP Checklist (Appendix 2). During the interview the facility stated that ARI works as the general contractor and sub-contracts out all leadbased paint work. The inspectors requested a list of the sub-contractors and their credentials. ARI was able to provide a copy of the ARI's Lead Safe Firm Certification (Appendix 3) at the time of the inspection. Following the inspection, on 01/06/2025 Mr. Edwards provided the Lead Abatement Contractor certificates for ARI's lead-based paint sub-contractors; Snyder Environmental issued on March 22, 2024 and Environmental Protection Associates issued on November 10, 2024. ARI also provided copies of the mentioned sub-contractors Asbestos Abatement Contractor Certificates. Section III - AREAS OF CONCERN No areas of concern were found at the time of inspection. Section IV - FOLLOW UP No Follow Up Appendix: 1 Notice of Inspection 2 Inspection Checklist 3 Lead Safe Firm Certificate 4 Receipt for Documents and Samples 2 Arkansas Restoration, Inc. Inspection Date 12/11/2024 Appendix: 1 Notice of Inspection 3 ,-EPA thi tcd Si,1tcs f-.'.Jironmenta! Protection li-.gf:rcy ENVIRONMENTAL PROTECTION ------------ ---- Washington, DC 20460 . - -- -- ----- ---- - Notice of inspection AGE NCY Office of Enforcemen t and Compliance Ass urance ; li 2 Inspector's Add ress 4. Facility Address --1! ~o~,ll::;:;~;,:Ln72I/ ----1 I = = ====== = ===== ---- --'-=-=========== ===:::::::'::~--- ------D ,fo r internal EPA Use. Copies may be provided to t he recipient JS acknow ledgment of th is notice. 1 ---- --- ------- -------------------------- -----~ Reason for Inspection l :u nder the authority of Section 11 of the Toxic Substances Control Act ' For the purpose of inspecting (including taking samples, photographs, statements and other inspection activities) an establishment, fa ci lity or other premises in which chemical substances or mixtures, articles containing same are manufactured, processed, stored or held before or after their distribution in commerce (including records, files, papers, :_r::{processes, control a-nd facilities) and any conveyances being used to transport chemical substance, "!-iixtures or artic:es i containing same in connection with their distribution in commerce (includ ing records, files, papers, processes, controls and facilities) bearing on whether the requirements of the Act are applicable to the chemical substances, mixtures or articles., within , or associated with, such premise or conveyance have been complied with. [ : In addition, this inspection extends to (check appropriate blocks): D A. Financial Data D D. Personnel Data O B. Sales Data D E. Research Data O C. Pricing Data The n3ture and extent of inspection of such data specified in A through E above is as follows: 1-l nspe<1.. :or Co py J-1 Jcility Copy Arkansas Restoration, Inc. Inspection Date 12/11/2024 Appendix 2 Inspection Checklist 4 - ft -e - U.S. EPA - - - - Lead Renovation/Repair/Painting Compliance Checklist - Property Management US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION - Firm Information Com an Name Address - Contact Name Contact Tele bone Contact Email Mana Mana Mana --- EPA Firm Certification Number Y - N - NIA Comments -- I Facility/operator provided copy of entry document - Copy of Lead Base Paint Pamphlet .... rovided 1/ - The items identified in this inspection have the potential to incur civil penalties in the amount identified. Your firm has - 90 days in which to submit proof that the items identified have been corrected. These deficiencies are of a serious nature - and if left uncorrected could result in formal enforcement action. Your response should be submitted to: Copy of inspection checklist and on-site report sent to: Print Name:- ----~----- Date - - - - Email: - -- - - - - - - - - - - - Page 1 of 6 --- Facility/Company Name: _____ft_-12__ 1__________________ - ft --- 0U.S. EPA Lead Renovation/Repair/Painting Compliance Checklist - Property Management US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION -# Ree Ref I 40 CFR &745.87(c) Question Did the company permit entry for inspection? Y-N-N/A v Comments - 2 40 CFR 745 .87(c) Did the company provide requested information and/or records during or after the inspection? Fotlol<) up - Comments I - lo<25 3 40 CFR 745.87(c) Is this company a licensed real estate brokerage firm ? If so, provide state u licensing number in comments. Comments - 4 40 CFR &745.87(c) Does this company manage target housing? tJ Comments - 5 40 CFR &745.87(c) How many target housing properties does this company manage? - Comments 6 40 CFR &745.87(c) Are children under the age of 6 years living in any of these properties? - Comments Al A/IA 7 40 CFR &745.87(c) Are pregnant women living in these properties? X//14 - Comments 8 40 CFR &745.87(c) Has renovation/repair/painting work been performed on these properties? - Comments I (,-~S 9 40 CFR &745.87(c) Which properties had RRP work performed and when? See List - Comments )- le - 2c; Follow vft Tot/ow II JI? I - 10 40 C.F.R. Did the renovator or property manager provide the owner of the unit with 745.84(a)(l) the EPA-approved lead hazard information pamphlet? fol!fJ'w /J J'J Comments 11 40 C.F.R. Did the renovator or property manager provide the adult occupant of the - 745.84(a)(2) unit (if not the owner) with the EPA-approved lead hazard information pamphlet? - Comments 12 40 C.F.R. In Common Areas, did the renovator or property manager provide the - 745.84(b)(1) owner of the multi-family housing with the EPA-approved lead hazard information/pamphlet or to post informational signs? - Comments 13 40 C.F.R. In Common Areas, did the renovator or property manager notify in - 745 .84(b)(2) writing, or ensure written notification of, each unit of the multi-family - housing and make the pamphlet available upon request prior to the start of the renovation, or to post informational signs? - Comments 14 40 C.F.R. In renovation in Child-Occupied Facilities, did the renovator or property foll~w /,<--() ;J)(I JJ/4 745 .84(C)(1 )(i) manager provide the owner of the building in which the child-occupied facili ty is located with the EPA-approved lead hazard information pamphl et? }I/A Comments Page 2 of 6 Facility/Company Name: _ _ _ __.Lf4.'--'Q'---"-I== = - - - - - - - - - - - - - - - - - - ft --- 0U.S. EPA Lead Renovation/Repair/Painting Compliance Checklist - Property Management US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION - 15 40C.F.R. In renovation in Child-Occupied Facility, did the renovator or property - 745 .84(C)( 1)(ii) manager provide an adult representative of the child-occupied facility N /R with the pamphlet, if the owner is not the operator of the child-occupied - facility? Comments - 16 40 C.F.R. In renovation in a Child-Occupied Facility did the renovator or property 745.84(c)(2) manager provide the parents and/or guardians of children using the child- occupied facility with the pamphlet and information describing the general nature and locations of the renovation and the anticipated - completion date, by mailing or hand-delivering the pamphlet and renovation information, or by posting informational signs describing the - general nature and locations of the renovation and the anticipated completion date, posted in areas where they can be seen by parents or - guardians of the children frequenting the child-occupied facility, and accompanied by a posted copy of the pamphlet or information on how - interested parents or guardians can review a copy of the pamphlet or - obtain a copy from the renovation firm at no cost to the parents or guardians? tJ/ft Comments 17 40 C.F.R. 745.85 For all renovations, did the renovator or property management firm post - (1). signs clearly defining the work area and warning occupants and other fol (~t,<J persons not involved in renovation activities to remain outside of the work area; to prepare, to the extent practicable, signs in the primary uf language of the occupants; and/or to post signs before beginning the - renovation and make sure they remain in place and readable until the renovation and the post-renovation cleaning verification have been - completed? Comments - 18 40 CFR - 745.84(a)(l )(i) Did the firm establish and maintain records and make those records available during the inspection? Fol /oW uP Comments - 19 40 CFR 745.84(a)(l )(i) Did the firm receive written acknowledgement from the owner for receipt Fu//ot,..) of a lead education pamphlet? up - Comments 20 40 CFR 745 .84(a)(2)(i) Did the firm receive written acknowledgement from an adult occupant, of/for a lead education pamphlet? Fol/ow up Comments - 21 40 C.F.R. 745.84(a)(2) Did the firm provide the adult occupant of the unit (if not the owner) with Fo//u-t,,J the EPA-approved lead hazard information pamphlet? VP Comments 22 40 C.F.R. 745.84(b )(1) Did the renovator provide the owner of the multi-family housing with the EPA-approved lead hazard information/pamphlet or to post infonnational i/tt - signs? Comments Page 3 of 6 Facility/Company Name: _____.B...._I_T__________________ - - ft --- eU.S. EPA Lead Renovation/Repair/Painting Compliance Checklist - Property Management US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION - 23 40 C.F.R. Did the renovator notify in writing, or ensure written notification of, each - 745.84(b)(2) unit of the multi-family housing and make the pamphlet available upon request prior to the start of the renovation, or to post informational signs? - Comments 24 40 C.F.R. Did the renovator provide the owner of the building in which the child- - 745 .84(C)(1 )(i) occupied facility is located with the EPA-approved lead hazard information pamphlet? - Comments 25 40 C.F.R. Did the renovator or owner provide an adult representative of the child- - 745 .84(C)( 1)(ii) occupied facility with the pamphlet, if the owner is not the operator of the /ft child-occupied facility? - Comments - 26 40C.F.R. Did the renovator or owner provide the parents and/or guardians of 745.84(c)(2) children using the child-occupied facility with the pamphlet and - information describing the general nature and locations of the renovation and the anticipated completion date, by mailing or hand-delivering the - pamphlet and renovation information, or by posting informational signs J/1+ describing the general nature and locations of the renovation and the - anticipated completion date, posted in areas where they can be seen by parents or guardians of the childrer1 frequenting the child-occupied - facility, and accompanied by a posted copy of the pamphlet or information on how interested parents or guardians can review a copy of t!lr+ Al/It the pamphlet or obtain a copy from the renovation firm at no cost to the parents or guardians? - Comments 27 40 C.F.R. 745.85 (1) Did the renovator or property management finns post signs clearly - defining the work area and warning occupants and other persons not involved in renovation activities to remain outside of the work area; to fo(/oiu f prepare, to the extent practicable, signs in the primary language of the - occupants; and/or to post signs before beginning the renovation and make sure they remain in place and readable until the renovation and the post- - renovation cleaning verification have been completed? Comments - 28 40 C.F.R. - 745.84(a)(l) During the renovation did the renovator obtain, from the owner, a written acknowledgment that the owner has received the pamphlet, pursuant to 40 C.F.R. 745.84(a)(l)(i) or failure to obtain a certificate of mailing at ft!(/ow uf least 7 days prior to the renovation? Comments 29 40 C.F.R. 745 .84(a)(2) During the renovation did the renovator obtain, from the adult occupant, a written acknowledgment that the adult occupant has received the pamphlet, pursuant to 40 C.F.R. 745 .84(a)(2)(i) or failure to obtain a certificate of mailing at least 7 days prior to the renovation? follow if Comments Page 4 of 6 -- Facility/Company Name: ______.....,/,l_-~/-tc---=---------------- - ft --- 0U.S. EPA Lead Renovation/Repair/Painting Compliance Checklist - Property Management US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION - 30 40 C.F.R. During the renovation in Common Areas, did the renovator obtain, from 745.84(b)(l)(i) the owner, a written acknowledgment that the owner had received the pamphlet, or that information signs had been posted, or they had obtained - 40 C.F.R. a certificate of mailing at least 7 days prior to the renovation? 745.84(b)(l) - Comments 31 40 C.F.R. During the renovation in Common Areas, did the renovator prepare, sign, - 745.84(b)(3) and date a statement describing the steps performed to notify all occupants of the intended renovation activities and offer to provide the - pamphlet? Comments - 32 40 C.F.R. During the renovation in Common Areas, did the renovator notify, in 745 .84(b)(4) writing, the owners and occupants of the scope, locations or expected - I starting and ending dates of the planned renovation activities, before the - renovator initiated work beyond that which was described in the original notice? ,JIrt ?J/11rJ tt- Comments 33 40 C.F.R. During renovation in a Child-Occupied Facility, did the renovator obtain, - 745.84(C)(1 )(i) from the owner of the building, a written acknowledgment that the owner I had received the pamphlet, or obtained a certificate of mailing at least 7 - days prior to beginning the renovation? Comments - 34 40 C.F.R. During renovation in Child-Occupied Facility, did the renovator obtain 745 .84(C)( 1)(ii) from an adult representative of the child-occupied facility, if the operator of the child-occupied facility is not the owner of the building, a written acknowledgment that the operator had received the pamphlet, or obtained - a certificate of mailing at least 7 days prior to beginning the renovation? - Comments 35 40 C.F.R. During renovation in Child-Occupied Facility, did the renovator prepare, 745 .84(c)(3) sign and date a statement describing the steps performed to notify all parents and guardians of the intended renovation activities and to provide - the pamphlet? Comments - 36 40 C.F.R. During all renovations, did the renovator include a statement recording 745.84(d)(l) the owner or occupant's name and acknowledgement of receipt of the - pamphlet prior to the start of the renovation, the address of the unit undergoing renovation, the signature of the owner or occupant as rJ ff fJ/tt tJl1r ;:o//gw f applicable, and the date of signature? Comments 37 40 C.F.R. During all renovations, did the renovator provide written - f 745 .84(d)(2) and (3) acknowledgment ofreceipt of the pamphlet on either a separate sheet or as part of any written contract or service agreement for the renovation, and written in the same language as the text of the contract or agreement or lease or pamphlet? p{ftli,J Page 5 of 6 Facility/Company Name: _ _ _ _ _.{,_+_R-J=\:_:;;.._ _ _ _ _ _ _ _ _ _ _ _ _ _ __ - ft 0 - U.S. EPA Lead Renovation/Repair/Painting Compliance Checklist - Property Management US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTRO~ ACT TITLE IV-LEAD HAZARD REDUCTION Comments 38 40 C.F.R. 745.86 During all Renovations, did the renovator or property manager retain all records necessary to demonstrate compliance with the residential property {o(}pw renovation for a period of 3 years following completion of the renovation U-f activities? Comments 39 40 C.F.R. 745.225 (i) During all Renovations, did the renovator, or property manager implement a program to maintain and make available to EPA upon request, records for a period of 3 years and 6 months? /;t/oiu up Comments 40 40 C.F.R 745.225, In Target Housing and Child-occupied Facilities, did the owner, 745.226, 745.227, renovator, or property manager establish, maintain, provide, copy, or permit access to records or reports? ti/ft 40 C.F.R. 745.235 (b) - Comments Target Housing Major= one or more occupants under age 6 and/or pregnant woman Significant= no information about age of the youngest occupant, or one or more occupants between ages of 6 and 17 Minor= no occupants under age 18 Child Occupied Facility Major= one or more occupants under age 6 (by definition, a child-occupied facility is regularly visited by one or more children under 6) Minor= renovation activities were completed during a period when children did not access the facility (e.g., as summer vacation) and there is no continuity of enrollment (i.e., the same children are not returning after the break). Page 6 of 6 Facility/Company Name: _ _ _ _ __.f~1-:=RaT,...._-_ _ _ _ _ _ _ _ _ _ _ _ _ __ Arkansas Restoration, Inc. Inspection Date 12/11/2024 Appendix 3 Lead Safe Firm Certificate 5 !!nit.eh ~tat.es ifnt1iro11n1.e11tal Jrnt.ectiott Ag.ettcy IDJ1is is tu .c.ertify tqat ARI-Arkansas Restoration Inc. has fulfilled the requirements of the Toxic Substances Control Act (TSOA) Section 402, and has received certification to conduct lead-based paint renovation, repair, and painting activities pursuant to 40 CFR Part 745.89 ~ 3/urinhi-:titr~ of: All EPA Administered States, Tribes, and Territories This certification is valid from the date of issuance and expires September 15, 2025 NAT-7367 5-3 Certification # September 09, 2020 Issued On Michelle Price, Chief Lead , Heavy Metals, and lnorganics Branch Arkansas Restoration, Inc. Inspection Date 12/11/2024 Appendix 4 Receipt for Documents and Samples 6 l oEPA United Sta te!; i Env1ronrnf'nta l Protec1inn Agency United States ENVIRONMENTAL PROTECTION AGENCY Washington, DC 20460 Receipt for Samples and Documents I Office of Enforcement and Compliance Assurance I ---- - - r -1 1. Investigation Identification 2. Company Name I II Date Inspection No. Daily Seq. No. ~/11/t1J 11 /}L 11 ()j_ ,4(1 k ~ t S /<.re5-kyq,ftc ,,_, :L,c_ I - ; 3. Inspector Address 4. Company Address II ut!I Clm 1: Utt/as IX 1ZS27{) 1$0 ilO '!Jo ,#uho...,_ Ln _ 6rl1i ldH1R.ceil .J-R..TR-ilt iFor internal EPA use. Copies of this form may be provided to recipient as acknowledgment of t he documents and samples of chemical I I -7 !substances and/or mixtures described below collected in connection with the adm inistration and enforcement of the Toxic Substances Contml f IA I ~- I ~0- I ! Ii) ~ - - - - -- - -- - - -- - - -- - - - - - - - - -- --- Receipt of Document(s) and/or Sample(s) Described is Hereby Acknowledged: m-t::r rn 1'11~//-,/ (/uflcYI Description Y/1 JYV1 l,,~f -1 -~- - - ____,! Ii ('/fl hrt~rl-<._ l 1 -- - -71 11 j I I I I VJ) h/rY7 I I I Jh htl_S-f-r)<:, - Ahr,-_,1'_71-7-/?uNTl.1/Jr'J../- C!(}_{]_-ft(lL:l-c/ -- I ,i n ---- --1 I' ii .. Jl - --- I ,. -- - --.. - J II I I I I I I -- I I I I - ,,,, I" ! " .. --~ I I n Optional: Duplicate or Split Samples: Requested and Provided 1 1 - - - - -- -- - - - - -- - - -- , Inspector's Not Requested Ii - 1_j I i I : !Title j H11sp0ctor Copy 7-Facility ( "IJV