Document 4q9JOr4L0K1ae0zb8mZOKEOQ
EAIA 0ft
Unrted States
1"\~~~i~~mental Protection
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
3/18/2024 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:
Blackwell Construction and Remodeling LLC
222 N Rosemont Ave , Dallas
Dallas TX 75218
(469) 951-9500
Jeff Blackwell
I I Owner
jeffblackwellconstruction@gmail.com
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC:
N/A N/A N/A
236118 1521
Personnel participating in inspection:
Angela Hays
EPA Region 6
Stan Lancaster
EPA Region 6
Jeff Blackwell
Blackwell Construction and Remodelin
Inspector Inspector Owner
EPA Lead Inspector Signature/Date
ANGELA HAYS
Angela Hays / Date
Digitally signed by ANGELA HAYS Date: 2024.05.01 13:38:41 -05'00'
Supervisor Signature/Date
H STUCKEY
Troy Stuckey / Date
Digitally signed by H STUCKEY Date: 2024.05.01 13:45:39 -05'00'
6ENFORM-019-R8.2 (02/12/2020)
1
Blackwell Construction and Remodeling LLC Inspection Date 03/18/2024
Section I INTRODUCTION
PURPOSE OF THE INSPECTION
The focus of the inspection was to evaluate compliance to the Toxic Substances Control Act (TSCA) Lead Base Paint (LBP) Renovation Repair and Paint (RRP) Rule. The company was identified during a larger effort to inspect companies that perform Renovation, Repair, or Paint (RRP) work in West Dallas in the general vicinity of RSR Corporation's smelter facility. The RSR Corporation operated a lead smelter that after shut-down became an EPA Superfund Site. Lead contaminants were removed between 1991 and 1994 and is currently undergoing redevelopment. EPA Region 6 prioritized this area to conduct TSCA RRP inspections to reduce potential of harm from lead-based paint in pre-1978 homes and verify compliance with TSCA regulations.
Blackwell Construction and Remodeling was identified as a company that has performed or intends to perform renovations on target housing in the RSR area. The inspectors are not aware of any citizen complaints at this facility.
FACILITY DESCRIPTION
Blackwell Construction is a general contractor that performs renovation and repairs in homes in the DFW metroplex area. Mr. Blackwell is the owner of Blackwell Construction Remodeling and offers a variety of construction related and home improvement type of services including remodels that have the potential to be regulated under the RRP Rule of TSCA. The inspection took place at an active job
site located at 130 N Montclair Dallas TX 75208.
Section II OBSERVATIONS
On 03/18/2024 at 1:00 PM EPA inspectors Angela Hays and Stan Lancaster visited with Mr. Jeff Blackwell, at 130 N Montclair Dallas TX 75208. The inspection was an announced inspection to ensure that Mr. Blackwell would be available at this time. Upon arrival, the inspectors presented their credentials to Mr. Blackwell and the purpose of the inspection was discussed and a Notice of Inspection was signed (Appendix 1).
The inspectors conducted an interview with Mr. Blackwell and discussed the jobs performed over the past five years. Mr. Blackwell stated that no jobs completed in the past five years disturbed lead based paint. The location was an active jobs site where the facility was remodeling a detached garage. The garage was constructed in 2012.
2
Blackwell Construction and Remodeling LLC Inspection Date 03/18/2024
Section III AREAS OF CONCERN
No areas on concern noted
Section IV FOLLOW UP
1) Documentation of the build date on the detached garage at 130 N Montclair Ave 2) Written statement of type of work performed at 707 N Edgefield Ave
. Section V Appendix 1 Appendix 2
LIST OF APPENDICES NOI Inspection Checklist
3
Blackwell Construction and Remodeling LLC Inspection Date 03/18/2024
Appendix 1
Notice of Inspection
4
&EPA : ll .1OL1t-.:, ; t,.11on~1,.111.-1! Prvt"rinn
\]1'1'1G)'
United States
ENVIRONfVlENTAL PROTECTION AGENCY
~Was hington, DC 20460
Notice of Inspection
Office of Enforcement and Compliance Assurance
G~ I 1. Investigation Identification
3.Facility Name
Date
II Inspection Number
Id-)-tt./llil I
Daily Seq . Number
11 1 I
1$/4_Yt/U,df
2. Inspector's Address
4. Facility Address
I
I
J')..01
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>-tTI:-c 4 , 54; 1-r.- soi:> ,
I
/30 JV //tc;,11.;c/at';,_
tJ. ,11-~ c ~x--c..s. 7S.J. 70
-
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For Internal EPA Use. Copies may be provided to the recipient as acknowledgment of this nqtke.
i-
Reason for Inspection
Undei 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, facility or other premises in which chemical substances or mixtures, articles containing same are
i _manufactured, processed, stored or held before or after their distribution in commerce (including records, files, papers,
IID processes, control and facilities) and any conveyances being used to transport chemical substance, mixtures or articles containing same in connection with their distribution i n commerce (including 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
D B. Sales Data
O E. Research Data
!
D C. Pricing Data
j The nature and extent of inspection of such data specified in A through E above is as follows:
Inspector's Signature
Recipient's Signature
1-1mpecto1 Copy ~-f-,,,:iiity : :,py
Blackwell Construction and Remodeling LLC Inspection Date 03/18/2024
Appendix 2
Inspection Checklist
5
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
EPA Inspector Name EPA Inspector Telephone EPA Inspector Email Inspection Date Inspection Type: Inspection Location
Company Name Address Contact Name Contact Telephone Contact Email Mana2.er Name Manager Telephone Manager Email
Jnsoection Checklist
Angela Havs
214-665-2285
Havs.an1Iela@eoa.1Iov
.3I I 8' I;t..,J
ta.itJ l?o II '/?1McJ4.,r
Firm Information
I{ l/,.11//,,,,,dl
I~ .IV /: ... / {.,,/'" J~.f.P- 11I ~ ,v, ,,, l l
EPA Firm Certification Number
Introduction & Purpose Pennission to enter granted Permission to enter document signed Facility/operator provided copy ofentry document Copy of Lead Base Paint Pamphlet provided
Y-N-N/A
v
,v
c/
y
r
Comments
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 ofa setious nature
and if left uncorrected could result in formal enforcement action. Your response should be submitted to:
Angela Hays
/JtJ lllvddk~ a./Lu/117'7 .-j-tJ /tf)f'XL I~ 26/Z
ECD-SR US Environmental Protection Agency Region 6 1201 Elm Street
'Jfll.t11or 'tJfhrU)ffl 4'5yb<-,S ~ .
/ti~;, ~llfradcr d-:df- J~+ Fusr
Dallas, TX 75270
;:-;uiJ'f '(J--bv.r;Jiz ,
..JJ, - J_ ./'< ,-1,_rlf 'fhn:YvAi Cu,fa-d.R.
Copy of inspection checklist and on-site report sent to: /OAuftny J {//I
t1
hoYlt/!. _ Ji
,
)f1f/~
.
lo3$' i.tJtJ.5t:w'-1~ - 2nd -(!/tJor a.co ,-hov,
Pagelof9 -(c;t).L of-+ f?...ook- l,t_./J, p/c25t-e,r ~'1 f f ~
Facility/Company Name: JtJJ ff;;,_knc4 1uh4
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
Print Name: _ _ _ _ _ _ _ _ __
Date _ _ __
Email
# Re2: Ref ] 40 CFR
745 .87(c) Comments 2 40 CFR 745.87(c)
Comments 3 40 CFR
745.87(c)
Comments 4 40 CFR
745.87(c) Comments 5 40 CFR 745.87(c) Comments 6 40 CFR 745.87(c) Comments 7 40 CFR 745.87(c) Comments 8 40 CFR 745 .87(c) Comments 9 40 CFR 745.87(c) Comments 10 40 C.F.R. 745.84(a)( I )
Comments 11 40 C.F.R.
745.84(a)(2 )
/tic) 4vl,~ <:-s tu~r--c.. ,rtW>l-i>,~APi"- -fh.R. ~ ~ , A
Question
,YA"N-N/A Mai~ie-Min H-M-L Potential,Penaltv
inspection? Did the company permit entry for cJ.i ~ c ~'f5,J?tz l-uJ1<.I - ~
Did the company provide requested
IJ,c,. --?/.,,.I-~~/\
:;p
information and/or records during or
after the inspection?
Js this company a licensed real estate brokerage firm? Ifso, provide state licensing number in comments.
Does this company manage target housing?
How many target housing properties does this company manage?
Are children under the age of 6 years living in any of these properties?
Are pregnant women living in these properties?
Has renovation/repair/painting work been performed on these properties?
Which properties had RRP work performed and when? Sec List
\ \ \ \ \
\
\ \ \ \ \ \
Did the renovator or property manager provide the owner ofthe unit with the EPA-approved lead hazard infonnation pamphlet?
Did the renovator or property manager provide the adult occupant of the unit (if not the owner) with the
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Page 2 of 9 Facility/Company Name:._ _ _ __ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Property Management
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 7S202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
EPA-approved lead hazard
information pamphlet?
Comments
12 40C.F.R. In Common Areas, did the renovator
745.84(b)( or property manager provide the
1)
owner of the multi-family housing
with the EPA-approved lead hazard
information/pamphlet or to post
informational si!Nls?
Comments
\
13 40 C.F.R. In Common Areas, d the renovator
745.84(b)( or property manager tify in writing,
2)
or ensure written notifi tion of, each
unit of the multi-family Ii using and
make the pamphlet availab upon
request prior to the start of ti
renovation, or to post infonna onal
signs?
Comments
\
14 40 C.F.R. In renovation in Child-Occupied \
745.84(c)(l Facilities, did the renovator or
\ )(i)
property manager provide the owner
of the building in which the child-
occupied facility is located with the
EPA-approved lead hazard
information pamphlet?
Comments
\
15 40 C.F.R. In renovation in Child-Occupied \
745.84(c)(l Facility, did the renovator or property
)(ii)
manager provide an adult
representative ofthe child-occupied
facility 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
745.84(c)(2 Facility did the renovator or property
)
manager provide the parents and/or
guardians of children using the child-
occupied facility witn the pamphlet
and information describing the
general nature and locations of the
renovation and the anticipated
completion date, by mailing or hand-
Page 3 of9
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Facility/Company Name:' - - - - - - - - - - - - - - - - - - - - - - - - -
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 REDU.CTION
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 see\1 by parents or
guardians of the chi ldrei frequenting
the child-occupied facility, and
accompanied by a posted c y of the
-
pamphlet or information on h w
interested parents or guardians 11
review a copy ofthe pamphlet or
obtain a copy from the renovation
;
firm at no cost to the parents or
""'"'~ guardians?
Comments 17 40 C.F.R. For all renovations, did the renovator
745 .85 (I). or property management firm 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 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
c lean ing verification have been
completed?
Comments
18 40 CFR Did the firm establish and maintain
745.84(a)( I records and make those records
)(i)
available during the inspection?
Comments
19 40 CFR Did the firm receive written
745.84(a)(I acknowledgement from the owner for
)( i)
receipt of a lead education pamphlet?
Comments
20 40 CFR Did the firm receive written
745.84(a)(2 acknowledgement from an adult )(i)
Page 4 of 9
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Facility/Company Name:_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
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0
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
occupant, of/for a lead education
pamphlet?
Comments
21 40 C.F.R. Did the firm provide the adult
745.84(a)(2 occupant of the unit (if not the owner)
)
with the EPA-approved lead hazard
information pamphlet?
Comments
22 40 C.F.R. Did the renovator provide the owner
745.84(b)( of the51.taim-itfy:housing with the
I)
EPA-app ed lead hazard
information/p phlet or to post
"' informational si ?
Comments
23 40 C.F.R. Did the renovator notify~writ,ionrg 745.84(b)( ensure written notification o , ach
2)
unit of the multi-family housing d
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
745.84(c)(I of the building in which the child-
)(i)
occupied facility is located with the
~ EPA-approved lead hazard
infonnation pamphlet?
~
-
Comments
25 40 C.F.R. Did the renovator or owner provide
745.84(c)(J an adult representative ofthe child-
)(ii)
occupied facility with the pamphlet, if
the owner is not the operator of the
child-occupied facility?
Comments
26 40 C.F.R. Did the renovator or owner provide
745.84(c)(2 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 si!!lls
Page 5 of 9
Facility/Company Name:_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
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
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 infonnation
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?
Comments
27 40 C.F.R. Did the renovator or property
745.85 (1) management firms post s igns clearly
defi ning the work area and warning
occupants and other persons not
involved in renovation activities to
remain outside of the work area; to
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
J
28 40 C.F.R. During the renovation did the
745.84(a)( 1 renovator obtain, from the owner, a
)
written acknowledgment that the
owner has received the pamphle ,
pursuant to 40 C.F.R.
745.84(a)( l)(i) or failure to obtain a
certificate of mailing at least 7 days
prior to the renovation?
Comments
29 40 C.F.R. During the renovation did the
745.84(a)(2 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
Page6of9
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Facility/Company Name:_ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
.ft
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
certificate of mailing at least 7 days
prior to the renovation?
Comments
30 40C.F.R. During the renovation in Common
745.84(b)( Areas, did the renovator obtain, from
l)(i)
the owner, a written acknowledgment
that the owner had received the
40 C.F.R. pamphlet, or t $ info1 rmation signs 745.84(b)( had been posted, o they had obtained
1)
a ce1tificate of mailin at least 7 days
prior to the renovation?
Comments
31 40 C.F.R. During the renovation in C ""' o ~ n
745.84(b)( Areas, did the ren.ovator prepar sign,
3)
and date a statement describing th
steps performed to notify a ll
~ occupants ofthe intended renovation
activities and offer to provide the pamphlet? Comments 32 40 C.F.R. During the renovation in Common 745.84(b)( Areas, did the renovator notify, i11
'\.
~
4)
writing, the owners and occupants of
the scope, locations or expected
starting and ending dates of the
planned renovation activities, before
the renovator initiated work beyond
that which was described in the
original notice?
Comments
33 40 C.F.R. During renovation in a Child-
745.84(c)( l Occupied Facility, did the renovator
)(1)
obtain, from the owner of the
building, a written acknowledgment
that the owner 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
745.84(c)( I Facility, did the renovator obtain from
)(ii)
an adult representative of the child-
occupied facility, if the operator of
the child-occupied fac ility is not the
Page 7 of9
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Facility/Company Name:_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
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
owner of the building, a written
acknowledgment that the operator had
received the pamphlet, or obtained a
ce11ificate of mailing at\least 7 days
prior to beginning the renovation?
Comments
35 40 C.F.R. During renovation in Child-Occupied
745.84(c)(3 Facility. did the renovator prepare,
)
sign and date a statement describing
the steps performed to notify a)l.
parents and guardians of the inte~ded
renovation activities and to provide
the pamphlet?
\
Comments
\
36 40 C.F.R. During all renovations, did the
\
745.84(d)( renovator include a statement
I)
recording 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
applicable, and the date of signature?
Comments
\
37 40 C.F.R. During a ll renovations, did the
745 .84(d)( renovator provide written
2) and (3) acknowledgment of receipt of the
pamphlet on either a separate sheet or
as pait 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?
Comments
38 40 C.F.R. During all Renovations, did the
745.86
renovator or property manager retain
a ll records necessary to demonstrate
compliance with the residential
property renovation for a period of3
years following completion of the
renovation activities?
Comments
39 40 C.F.R. During a ll Renovations, did the
745.225 (i) renovator, or property mana!!er
Page 8 of9
Facility/Company Name:_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
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
implement a program to maintain and make available to EPA upon request, records fora period of3 years and 6 months? Comments 40 40 C.F.R In Target Housing and Child745.225, occupied Facilities, did the owner, 745.226, renovator, or property manager 745.227, establish, maintain, provide, copy, or permit access to rec rds or reports? 40 C.F.R. 745.235 b Comments
Penalty Amount:
Target Housing Major= one or more occupants under age 6 and/or pre nant woman Significant= no information about age of the youngest oc pant, or one or more occupants between ages Qf 6 and 17 Minor= no occupants under age 18
Child Occupied Facility Major= one or more occupants under age 6 (by definition, a child- cupied facility is regularly visited by one or more children under 6) Minor= renovation activities were completed during a period when chi ren did not access the facility (e.g., as summer vacation) and there is no continuity of enrollment (i.e., the same children e not returning after the break).
Page9of9 Facility/Company Name:_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __