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ft E A ~ United States .,,..._., Environmental Protectior , Agency Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 10/22/2024 Toxics Substances Control Act (TSCA) Renovation, Repair and Painting (RRP) and 1018 Disclosure Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: Hunt Military Community (HMC) Randolph Family Housing 205 New B Street East Universal City, Texas, 78148 205 New B Street East Universal City, Texas, 78148 Bexar 803-483-9900 I Sam Ezernach I NA NA NA 53131 6531 Personnel participating in inspection: Stan Lancaster EPA Region 6 Angela Hays EPA Region 6 Kiera Hancock EPA Region 6 Andrea Price EPA OECA HQ Sam Ezernach Randolph Family Housing Patricia Zauala Beltran Randolph Family Housing Justin Tran Hunt Military Communities Brandon Taylor Hunt Military Communities Inspection Officer Inspection Officer Inspection Officer Inspection Officer Manager Assistant Manager Community Director Maintenance Director EPA Lead Inspector Signature/Date Supervisor Signature/Date ANGELA HAYS Angela Hays Digitally signed by ANGELA HAYS Date: 2024.12.11 13:47:45 -06'00' Date Stuckey, Troy Date: 2024.12.11 14:53:29 -06'00' Digitally signed by Stuckey, Troy Troy Stuckey, Chief Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION Hunt Military Community at Randolph Inspection Date: 10/22/2024 PURPOSE OF THE INSPECTION To investigate facility for compliance with the Lead Based Paint Renovation, Repair or Painting (RRP) Rule and 1018 Disclosure Rule of Toxic Substances Control Act (TSCA). The inspection was initiated as part of a national initiative to inspect military bases identified to have reported elevated blood lead levels. FACILITY DESCRIPTION Randolph Family Housing, located within Joint Base San Antonio, is managed by Hunt Military Communities (Hunt) with 317 historic residences, consisting of 173 single-family homes and 144 duplexes. Hunt offers housing to Active Duty, Retirees, Veterans, Department of Defense Employees, National Guard, Reservists, and other service members. Most leases are a 12-month term. Hunt has been managing the properties at Randolph since 2007. Section II - OBSERVATIONS On October 22, 2024, at 10:30 AM, EPA inspectors Angela Hays, Stan Lancaster, Kiera Hancock, and Andrea Price arrived at Hunt Military Communities located at Randolph Air Force Base inside of Joint Base San Antonio. Upon entry, inspectors Hays, Lancaster, Hancock, and Price presented their credentials to Randolph Family Housing Manager, Sam Ezernach, and Assistant Manager, Patricia Zauala Beltran as well as Hunt Military Communities Community Director, Justin Chan and Maintenance Director Brandon Taylor. The inspection team explained the purpose of the inspection. The Notice of Inspection (Form 7740-3) was filled out and a copy provided to Mr. Tran (Appendix 1). The interview began with discussions of the property types and build dates. The properties are all singlefamily homes and duplexes with a potential for children under six and pregnant women to occupy. Build dates are all pre-1978. The inspection team requested to review of compliance with the TSCA 1018 disclosure. A total of 30 leases were reviewed to verify lead addendum and receipt of EPA LBP Pamphlet. Randolph Family Housing also gives a copy of the EPA Lead Pamphlet to each tenant in the "Welcome to JBSA Randolph" packet. Leases are typically a 12-month term. The inspection team then went on to discuss compliance with the TSCA Renovation, Repair and Painting Rule (RRP). The RRP checklist was completed (Appendix 2). Hunt's management was unaware of Hunt's Lead Safe Firm Certification Number. Follow up of the number was requested. During the discussion Hunt management stated that typical painting work does not remove existing paint layers. Painting is performed by painting over the existing layer. If work is needed that will disturb lead-based paint, Hunt hires RRP vendors. Most work performed by Hunt consists of plumbing and HVAC. The Hunt workers at Randolph consist of seven technicians, one community director, one maintenance manager and one 2 Hunt Military Community at Randolph Inspection Date: 10/22/2024 maintenance director. EPA inspectors requested a copy of the standard operating procedures of how LBP is managed and the Contractor names, contact information, certifications, and assigned renovators used for LBP RRP work for the past five years. The inspection team then drove the residential areas within Randolph to look for active RRP work. EPA was provided maps of Randolph Family Housing (Appendix 3). No active work was being performed at the time of site visit. The inspectors conducted a closing conference and discussed the areas of concern found. The inspection team went over a list of requested documents and supplied lead-based paint education materials to the facility. The inspection concluded at approximately 12:00 PM. Section III - AREAS OF CONCERN Hunt Military Communities at Randolph does not appear to have a Lead Safe Firm Certification. Section IV - FOLLOW UP Documentation of the following information was requested by 10/29/2024. Currently some of the documentation has been submitted to EPA and is under review. The remainder of the requested information submission has been extended to 12/13/2024. 1) Hunt Military Communities Randolph Lead Safe Firm Certification number. 2) List of lead contractors used for RRP in the past 5 years (Or since Hunt has managed property) including; a. Firm Certification Numbers b. Training Certifications c. Contact information. 3) Ownership of Housing between Hunt and Randolph 2) 2008 Lead based paint inspection 3) 2011 (or most recent) maintenance SOP 4) 2025 Environmental Baseline Survey 5) Past 90 Days of RRP Work Orders Section V - APPENDIX Appendix 1 - Notice of Inspection (Form 7740-3) Appendix 2 - Lead RRP Compliance Checklist Appendix 3 - Maps of Randolph Community Appendix 4 - Receipt for Samples and Documents (Form 7740-1) 3 Hunt Military Community at Randolph Inspection Date: 10/22/2024 Appendix 1 Notice of Inspection (Form 7740-3) 4 Hunt Military Community at Randolph Inspection Date: 10/22/2024 ENVIR t11ENTA P OT CTION AGENCY Washlngl on, DC 0460 Not ice of lnspe1. tion Ofike of Enfoicement an Compllance Ass urance 1 lrwes11gat1on Id,~ ,f1.a11011 J "t I ~ lvame Ddte fiot~Jm./ IInspection Number I Daily Seq Number liJ-14 ~ 1 a11 rk - 7 1 .fttt'Y')At'J/tJ'ts - fwi.U 11''- f,:.tr1i")' 1- l - ji l - ] .,,,.. ,.. ,.-, , ~t'\1 ~ - , - =_ ____,J-=- - l_ - - - - -- - - -=---- 2 nspecto, s Add1 ess For Internal EPA U, e Copies rrny be provided to the rec, 01ent as acknov.1edgrnerot of this not ,cP I- -- - - -- ----- --cc--~-:- - -- ----- Reason for Inspection Ju nder the authunty of Section 11 of the Toxic SubstancesControl Act For the purpose of inspecting (including taking samples, photographs, statements and other inspection act1v1 t1es) an I establishment, facility or other premises in which chemi cal substances or mixtures, articles containing same are _ _;)>ilnufactured, processed, stored or held before or after their distribution In commerce (Including record s, flies, pap~rs, Vprocesses, control and facil1t1es) and any conveyances being used to transport chemical substance, m ixtures or articles containing same In connection with their distribution In 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 ar ticles, w ithin, or associated w1t/1, such premise or conveyance have been complied with I- In addition, thisinspection extends to (check appropriate blocks) f1 A. F1nanc1al Data D 8 Sales Data D C. Pricing Data 17 D Personnel Data [1 E. Research Data Tne na ure and extent of Inspection of such data specified in A through Eabove is as follows: ta r l T1tle~:'.-::!g_:1::d~ ~ .,_== =-c-,..l 1,,I t cl/ 2-1.- z. rr ~ Fo1rn 7740 3(RPV J/16) S9ve Form 1 I -I ~==~T=ri =a="~' ====~=----1! Title l c t o,11,111(11 , iy Dt red-or r ,D t ~ / ae~ t 0 ::1/ :;) '1 J Print Form 5 Hunt Military Community at Randolph Inspection Date: 10/22/2024 Appendix 2 Lead RRP Compliance Checklist 6 Hunt Military Community at Randolph Inspection Date: 10/22/2024 ft e, U.S. EPA '/JI:v~ ll'>rfvr <.iVlf<., Cf :lf()' (N,r,,f- Lead \1/,,;. l - , ' '{ Renovation/Repair/ Painting Compliance Checklist - Renovato rs US ENVIRONMENTAL PROTECTION AGENCY //. 10 REGION 6, DALLAS, TX 7S202 (,d'( U1 ""-'/4 ~ OfA!l''tl'\ as,n1 ; ~~t). c,f ~~1j C< A l ~ TOXIC SUBSTANCES CONTROL ACT J/ ' 5 :1 : ui,t t:z,,- TITLE IV-LEAD HAZARD REDUCTION Renovation Firms & Renovators l11s11eetio11 C hecklist EPA lnsncctor Name EPA lnsneetor Tclcnhone EPA lnsncctor Email ln s1Jection Da te Inspection Tyne: lns ncetion Location Name Address Contact Name Contact Teleohone Contact E ma il Mana2er Name Mana!!er Telenhonc Mana2er Email /w,.uJ1.,, ~ , , S h =11 Lc.u , . .~ , f/., lvR: f f ' /'I' "'(,._ .,L,, In, , V II? / 72,, / 2-u 'l.N L?,, I - A- - 1 4-Jc-,(\-}- - n..JIJ) cf- ( 0 I ff' /'Z..4'd n/ul,-- Affo Firm Information JI, , . '- /{11~ - LLKYW...v1 ,.h'}< - ilt.n,,J..v l,; k h<m,L /-lu..,,h ~ :l.D s lie ..., D .5-r F IA1,,V1 A, I {,.~ .. I V 7 o 15c, EPA Firm Certification Number Na ture/Description of Work: ~N\. ~ v~k E1...e r f1,ec,l,_ ;; J/kM>,~ Ul""-1" : - 6<;1'1\.1,\-e f. e1.l!.ro'\&td,,.. , _j_ @i,.S . ,:,+, m , I 'J'i.<~-t.11 Trc.11 .. W'Y1ri,,w,> o;,l'le:tv1 -:: 7 ~t 1v1 . +rt.n@ /ttun.J-l<-vY\/701io. t. uo/\ {.c 1.t ,,c. ;1' B(,:r,d-<)A \ ~ I Q/ - (W,,~~fvy 6 ri:,,(..l<M_, ft.7' i <J @ VJLlnf-w fl,,.rt;<iJ. <'.'.:, n-- c.S,~1 ~o..\x\e.\c. 1.o.1.X>-\0.. ?-fil\;~o,n ~Oc\'<.\C.\O .1cvG-\o--fB\\\o.n OPENING CONFERENCE Y-N- Comments NIA Introduction & Purpose y Permission to enter granted y y Permission to enter document signed a; .ei t .it<\\ entrv document Facility/operator prov ided copy of 'f y Copy o f Lead Base Paint Pamphl et orovided Page 1 of 21 COMPANY NAME: - - -~1:t~u_,"_\_.t..,_---1'=a'=r:v:u...ucl..>..1.-.1o'--'-.h..,___ _ __ _______ I 7 Hunt Military Community at Randolph Inspection Date: 10/22/2024 ft 0 U .S. EPA Lead Renova tion/ Repair/ Paint ing Compliance Checkl ist - Renovators US ENVIRONMENTAL PROTE CTION AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION Comments/ In formati on gathered: Did the company cooperate and provide requested documents? Is the company a licensed real estate brokerage firm ? ff Yes, w hat is their license number? Doe the company manage/sale/renovate target housing? I f yes, how many?_ __ _ __ _ _ _ _ _ __ Are there children under the age of 6 living in these properties? Under the age of 18? Pregnant women? \t'.-(5 I f managing properties, has any renovations been performed on these properties in the past 5 years? Was list provided? 17 ;, J' f '-f Hvc..c J, ? 1 - / 1J1k<fubv~ J , ? tu oo ,\f'-".', , J.2 ). h<c-:'' oc, .....11...,.--1 ..,, f,::g I tWl,6 Cw tvl v1 , trc , z_ , .,,.,,\tw,""::k-- ~ ....:.,,.., Tut fufC11".) h<.,)""~' , #-LA>')+- L~/..,c,-f-!fl.1, r'.}d,<.Av1<Z: ,l::C('-i .:r4< ,J j'4\)(. vY:>Q<:t- tr'-cz,c./ I ,I V,(, ?V d: f "-""&I:: (ji tbvlv l.. ...\ . flw, Jv f- 1.,-ri11',d f{?nJ<. Inspector: 6ECDST US Environmental Protection Agency Region 6 120 I Elm Street Dallas. T X 75207 Copy of inspection check list and on-site report sent to: Prim ame: _ _ _ _ _ _ _ _ _ __ Emai l: _ _ _ _ __ _ _ _ _ _ __ Page 2 of 21 _ fLl- f -U. t,,.) 2,.0 L~<-o7, - L~I' f"r-tJt-c. l- ~! l ~ en_ - Li->\- cJ- C e,V1 +-,e,. tf,:/\ l.J c-e, -1.'(.(,.,-u~ l.>r '"'"'"'- L.> l v1Tt:-., ,;- , r.,.f-,, Date _ _ __ COMPANY NAME: _ _ __,._,i/i-"'Uu.O.L.t---1,..e_(l...n,4iC-LL~LJobr.=J-_ _ _ __ _ _ _ __ 8 Hunt Military Community at Randolph Inspection Date: 10/22/2024 ft 0 U.S. EPA Lead Rcnova lion/Rcpair/ Painling ompliance hcck li I - Renovator US ENVIRONMENTAL PROTECTION AG ENCY REGION 6, OALIAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION INFO RMATION DISTRIBUTION REQUIR EMENTS # Reg Ref Question Y-N-N/A I 40 C.F.R. 745.84(a)( I) Renovation in Dwelling nit: Did the reno awr/property owner/property manager provide the owner of th e unit with the EPA-approved lead hazard information pamphlet? [JI -> v1 Comments 2 40 C.F.R. 745 .84(a)(2) Renovation in Dwelling Unit: Did the renovator/property owner/property manager provide the adult occupant of th e unit (if occupant is not the owner) with the EPA-approved lead \-c,llot,) uf hazard information pamphlet? Comments 3 40 C.F.R. 745.84(b)(I) Renovation in Common Arca: Did the renovator provide the property manager/owner of the multi-fami ly housing with the EPA-approved lead hazard information/pamphlet and/or to post mu ltifamily N/'t\ informational signs? Comments 4 40 C. F.R. 745.84(b)(2) Renovation in Common Area: Did the renovator/property manager/property owner notify in 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 and/or post informational signs? multi family tJ / ri- Comments 5 40 C.F.R. 745.84(c)( I)(i) Renovation in Child-Occupied Facility: Did the renovator/property manager provide the owner of the building in which the child-occupied faci lity is located with the EPA- aooroved lead hazard in formation oamphlet? Child facility tJ I r. Comments 6 40 C.F.R. 745.84(c)( I)(ii) Renovation in Child-Occupied Facility: Did the renovator/property manager/property owner provide an adult representative of the child occupied facil ity with the pamphlet, if the owner is not the operator of the cl1ild-occuoied facility? Child facility rJ /ft Comments 7 40 C.F.R. Renovation in Child-Occupied Facility: Did the Child facility 745.84(c)(2) renovator/property manager/property owner provide the parents and/or guardians ofchildren using the child-occupied faci lity NIA 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 in formational igns describing the general nature and locations of the renovation Page 3 of 21 COMPANY NAME: _ ___H~-u~a~+_ _.g.~a~c...d....c.,~lt"p,....h_ _ _ _ _ _ _ _ __ 9 Hunt Military Community at Randolph Inspection Date: 10/22/2024 r ft 0 U.S. EPA Lea d R cnova tion/ R cpair/ Paintin a C omp lian ce C heck list - Renovator US ENVIRONMENTAL PROTECTION AG ENCY REGION 6, DALLAS, TX 7S202 TOXICSUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION and the anticipated completion date, posted in areas where they can be een by parents or guardians of the children frequenting the child-occupied faci lity. and accompanied by a posted copy of the pamphlet or in formation on how interested parent or guardians can review a copy of the pamphlet or obtain a copy from th e renovation firm at no cost to th e oaren'lS or guard ians? Comments 8 40 C.F.R . All Renovations: Did the renovator post igns c learly defin ing 745.85 ( 1) the work area and warning occupants and other persons not involved in renovation activities to rem ain 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 unti l the renovation and the post-reno vation cleaning verification have been comoleted? Co mments \(>\ v v~ # Reg Ref Question TEST KITS Y-N-N/A l 40 C.F.R. 745 .88 All Renovations: D id the renovator/firm use an EPA approved dust test k it w hen determining the presence of lead, where the test kit provided an accurate result for the presence of lead? -\di J) v ~ Comments FAILURE TO ALLOW ACCESS TO RECORDS OR REFUSAL OF AN INSPECTION # Reg Ref Question Y-N-N/A l 40 C.F.R. All Renovations: Did the renovator/ property owner/property 745 .87(c) manager refuse to permit entry or inspection? Failure or refusal to permit entry or inspection is also a violation ofTSCA 15 ~) ft and TSCA &409. Comments FAILURE TO ESTABLISH AND MAINTAIN RECORDS, FAfLURE OR REFUSAL TO MAKE RECORDS AVA[LABLE # Reg Ref I 40C.F.R. 745.237 Question All Renovations: Did the renovator/firm/ property owner/property manager fa il or refusal to establish and maintain records, or to make available such records? Such fai lure or refl1sal is a violation ofTSCA &409. Y-N-N/A ~J )ot of> Comments Page 4 of 21 coMPANY NAM E: _ _ _ _ ...._l+-'-1'""Ja"-'-f--'-'Rt.a...,.,_f_l..,c"lo'",,_~lF!..hc.,__ _ _ _ __ _ __ 10 Hunt Military Community at Randolph Inspection Date: 10/22/2024 ft 0 U.S. EPA Lead Renovation/Repair/Pai nting ornplia nce Chcck li t - Renovato r US ENVIRONMENTAL PROTECTION AGENCY REGION 6, CALI.AS, TX 7S202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION ACKNOWLEDGEMENT AND CERTI FICATION ST TEMENT REQ lREMENTS (RENOVATION PAMPlILEn # Reg Ref I 40 C.F.R. 745.84(a)( I)(i) 40 C.F.R. 745.84(a)( I) Qu estion Renovation in Dwelling Unit: Did the renovator/finn/propeny manager obtain, from the owner, a written acknowledgment that the owner had received the pamphlet. or obtain a ccnificate of mailing at least 7 days prior to the renovation? Y-N-N/A Owner occupied ~{. Co mment s 2 40 C.F.R. Renovation in Dwelling Unit: Did the renovator/finn/propeny rental 74 5.84(a)(2) 40 C. F.R. manager obtain, from the adult occupant. a written acknowledgment that the ad ult occupant has received the pamphlet, or obtain a certificate of mailing at least 7 days prior ~o.v ~ 745.84(a)(2)(i) to the renovation? Comments 3 4.0 C.F.R. 745.84(b)( l) Renovation in Common Arca: Did the renovator/firm/property manager obtain, from the owner, a written acknowledgment that the owner has received the Mulu-family ~~,i) ~ ,J 40 C.F.R. 745.84(b)(I )(i) pamphlet, or that information signs have been posted, or obtain a certificate of mailing at least 7 days prior to the renovation? Comments 4 40 C.F.R. 745.84(b)(3) Renovation in Common Arca: Did the renovator/firm/ property manager prepare, sign, and date a statement describing the steps performed to notify all Mu hi-family ),!,~o\.iJ .fi. occupants of the intended renovation activities and to provide the pamphlet? Comments 5 40 C.F.R. Renovation in Common Arca: Did the Mu hi-family 745.84(b)(4) renovator/firm/propeny manager notify, in writing, the owners ~b..j} and occupants of the scope, locations or expected staning and \ \) ~ ending dates of the planned renovation activities change after the initial notification, before the renovator initiated work beyond that which was described in the original notice? Comments 6 40 C.F. R. Renovation in Child-Occupied Facility: Did the Child Facil it) 745 .84(c)( l)(i) renovator/firm/property manager obtain, from the owner of the building, a written ack nowledgment that the owner had NI\\- received the pamphlet, or obtained a cen ificate of mai ling at least 7 days prior to the renovation? Comments Page s of 21 COMPANY NAME - - - - '~'--'--"'-t:'"""ot,___~(<,=a,.=NI~c.1....t'-pL.fh- -- - - - - - -- - 11 Hunt Military Community at Randolph Inspection Date: 10/22/2024 ft 0 U.S. EPA Lead Renovation/Repair/ Painting Compliance hcckfi t - Renovator US ENVIRONMENTAL PROTECTION AGE NCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION 40 C.F.R. Renovation in C hild-Occupied Facility: Did the Child Facility 745.84{c){l){ii) renovator/fi rrn/property owner/property manager obtain from an adult representative of the child occupied facility, if the operator of the child-occupied faci lity i not the owner of the building, a wrinen acknowledgment that the operator has ~\- received the pamphlet. or obtained a certificate ofrnailing at least 7 days prior to the renovation? C o mm ents 8 40 C.F.R. 745 .84(c)(3) Renovation in Child-Occupied Facility: Did the renovator/fi rm/property owner/property manager prepare, sign and date a statement de cribing the steps performed to notify all parents and guardians ofthe intended renovation activitie and Child Facohty ~l to provide the pamphlet? Comments 9 40 C.F.R. 745.84(d){ I) All Renovation s: Did the renovator/firm /property owner/property manager include a statement recording the owner/occupant 's name and acknowledgment of the pamphlet receipt prior to the start of the renovation, the address of the ' \}~ unit undergoing renovation, the signature of the owner o r occupant as annlicable. and the date of signature? Comments RECORD RETENTION REQUrREMENTS # Reg Ref I 40 C.F.R. 745 .86 Question All Renovations: Did the renovator/firrn/property manager/property owner retain all records necessary to demonstrate compliance with the residential property renovation for a period of 3 years fo llowing completion of the renovation activities? Y-N-N/A \J.J Comments 2 40 C.F. R. 745.225 (i) All Renovations: Did the training program mainta in and make available to EPA upon request, n:cor<ls for a period of 3 years and 6 months? ,j.'~' \ ~~ C o mments 3 40 C.F.R. Target Housing and Child-occupied Facilities: did the 745.225, 7-15.226. or 7-15.227 & 40 renovator/firm/ property manager/property owner/training activity fai l or refuse to establish, maintai n. provide. copy. or permit access to records or report ? \ tJ~v C.F.R. 745.235 !b) Page 6 of 21 coMPANv NAME: - - - - - ~f~lu~o~+-~ol.....,a,~r~Vi~l=d_..,t,.2."'6" 1--- - - - - - - 12 Hunt Military Community at Randolph Inspection Date: 10/22/2024 ft 0 U.S. EPA Lead Ren ovat ion/ Repa ir/P aintin g Complia nce C heckl ist - Ren ova to rs US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CON TROL ACT TITLE IV-LEAD HAZARD REDUCTION I C o mm e nts CERTI FICATION AND RELAT ED REQUIREMENTS # Ree Ref I 40 C.F.R. 74 5 .89(a) pursuant to 40 FR Q uestio n All Renovations: Did the renovator/ fi rm that performs, offers or claims to perform renovations or dust sampling fo r compensation obtai n initial certification from EPA? If the firm did not obtain initial certification, then proceed next section. 745.81 (a)(2)(i i) C o mm e nts 2 40 CFR All Renovations: If in itial certification has expired, did the 745.89(a& 40 EPA-certi fied cease renovations or d ust sampling upon C.F.R. expiration of certification? 745.89(b)( I)(iii) Comments 3 40 C.F.R. All Renovations: Did firm amend certification within 90 days 745.89(b). & 40 of pertinent information change? Did the firm halt renovations C . F. R . or dust sampling until its certification was amended? 745.89(c) Y- N- N/A \Jo' ~ 0v Vv( '?ovJ ll~ C o mm e nts 4 40 C.F.R. All Renovations: Are all individuals performing renovations 745 .89(d)( l ) & certified renovators or trained by certified renovators? 40 C.F.R. 745.8 l(a)(2) C omm e nts 5 40 C.F.R. All Renovations: Is a certified renovator assigned to and 745.89(d)(2) & avai lable at each renovation? 40 C.F.R. 745.8 1(a)(2) Comments 6 40 C. F.R. 745 .90(b) or (c) All Renovations: Did the certified renovator o r dust sampling technician ensure compliance with 745.85 at a ll renovations to 40 CFR which they were assigned? 745.90(a) \O~; ~~\)t ~\)~ 40 C.F.R. 745.8 1(a)(3) Comm ents Page 7 of 21 ' coMPANv NAME: _______,f..-.l,=Lll~~~f:-+R=es.=rv~.l.c..'f./n~b ~ - - - -- - - - 13 Hunt Military Community at Randolph Inspection Date: 10/22/2024 ft 0 U.S. EPA Lead Renova t io n/ Re pai r/ Pa in t in g o mplia nce C hec klist - Renovators US ENVIRONM ENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 7S202 TOXI C SUBSTAN CES CONTROL ACT TITLE IV-LEA D HAZARD REDU CTI ON 40 CFR All Re nova tions : Did the renovator or dusl ampling 745 .90(b)(7) technician. performi ng rcnovalor or d u I sampling re pon ibilitics under 40 C.F. R. 745 .90(b) or (c) to mainla in and make avai!able copie of 1heir course complelion certificale(s) (proof o f certification) al 1hc work sile? C o mm e nt s 8 40 C.F.R. All Renovations: Did lhe dust sampling technician to pe rform 745 .90(c) op1ional du t clearance sa mpling under 745.85(c)? Comm ents 9 40 C.F.R. Target Housing and Child-occupied Facilities: Did the 745.8l(a)(3) previously EPA-certi fied individual stop di recting renovalions if he/she d id not obtain recerti fication under 40 CFR 745 .90(a)(4)? Comments '. JJ N~ \r,t ve ~:~ WORK PRACTICE STANDARDS FOR COND UCTING RENOVATIONS IF RENOVATIONS DID NOT OCCUR T HIS SECTION IS N/A Ree: Ref Ques tion Y-N-N/A l 40 C.F.R. Interior Renovations: D id the renovation fi rm remove all 745 .85(a)(2)(i)( objects from the work area, includ ing furniture, rugs, a nd \t A) w indow coverings, or cover them with plastic sheeting or othe r impermeable material w ith all seams and edges taped or otherwise sealed? Comments 2 40 C.F.R. Interio r Renovations: Did the renovation fi rm, before 745 .85(a)(2)(i)(B beginning the renovation, close and cover all ducts opening in ) the work area with taped-down plastic sheeting or other ~\~ imoermeable material? C om ments 3 40 C.F.R. Interior Renovations: Did the renovation firm close w indows 745 .85(a)(2)(i)(C a nd doors in the work area, cover doors w ith plastic sheeting or ) other impermeable material, and/or cover doors used as an entra nce to the work area with plaslic sheeti ng or other ~ \t impermeable material in a manner that allows workers to pass through while confining dust and debris to the work a rea? Comm ents 4 40 C.F.R. 745 .85(a)(2)(i)( D) Interior Renovations: Did the renoval ion firm, before beginning the renovat ion, cover the noor surface, including installed carpet, with taoed-down olastic sheeting or other ~t~ Page 8 of 21 coMPANv NAME: - - - - -~J-li-v~O~f-,1<i~C~lfld-~11....,l~A~-- -- -- - \ 14 Hunt Military Community at Randolph Inspection Date: 10/22/2024 ft 0 U.S. EPA Lead Renova tion/Repair/Painting Co mpli ance Checklist - Reno va tors US ENVIRONMENTALPROTE CTIO N AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION impermeable material in the work area 6 feet beyond the perimeter of surfaees undergoing ren ovation or a sumcient distance to contain the dust, whichever is greater? Comments 745 .85(a)(2)(i)(E to ensure that all personnel, tools, and other items includi ng the 5 40 C.F. R. Interior Renova tions: Did the renovation firm use precauti ons ~o~ ) exteriors of containers of waste, are free of dust and debris before leav ing the work area? Comments 6 40 C.F.R. Exterior Renovations: Did the renovati on firm , before 745 .85(a)(2)(ii)( beginning the renovation, close all doors and windows within A) 20 feet of the renovation, close all doors and windows within 20 feet of the renovation on the same floor as the renovation on multi-story buildings, and/or close all doors and windows on all floors below that are the same horizontal distance from the renovation? ":-,/ ~A Comments 7 40 C.F. R. Exterior Renovations: Did the renovation firm, before 745 .85(a)(2)(ii)( beginning the renovation, ensure that doors within the work B) area that will be used while the job is being performed are covered with plastic sheeting or other impermeable material in a manner that allows workers to pass through while confining dust and debris to the work area? y\o; Comments 8 40 C.F.R. Exterior Renovations: Did the renovation firm , before 745 .85(a)(2)(ii)( C) sheeting or other disposable impermeable material extending I0 beginning the renovation, cover the ground with plastic ~~) feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to collect falling paint debris, whichever is greater, unless the property line prevents IO feet of such ground covering? Comments \o~o~ 9 40 C.F.R. Exterior Renovat ions: Did the renovati on firm , before 745 .85(a)(2)(i i)( beginning the renovations in certain situations, take extra D) precautions in containing the work area to ensure that dust and debris from the renovation does not contaminate other buildings or other areas of the orooertv or migrate to adjacent orooerties? Comments Page 9 of 21 COMPANY NAME: ____ , _""'H""',;f)'-"--'--t-""~"c'"t....,n...u..d..o. ""'l'-ftJ""'h'-'---- - - - - - - 15 Hunt Military Community at Randolph Inspection Date: 10/22/2024 ft 0 U.S. EPA Lead Renovation/Repair/Painting Compliance Checklist - Renovators US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 7S202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION 10 40 C.F.R. 74 5.85(a)(3)(i) Prohibited and restricted practices: Did th e ren ovator/firm prohibit the use of open-n ame burning or torchin g of lea d- based paint during renovations? Comments 11 40 C.F. R. Prohibited and rest ricted practices: Did the ren ovator/firm 745 .85(a)(3)( ii) prohibit the use of machines that remove lead-based paint through hi gh speed operation such as sanding, grinding, power planning, needle gun, abrasive blasting, or sandblasting, unless such machines are used with HEPA exhaust control? Comments 12 40 C.F.R. Prohibited and restricted practices: Did the renovator/firm 745 .85(a)(3)(ii i) restrict the oRerating/use of a heat gun on lead-based paint to temperatures below 1100 degrees Fahrenheit? Comments 13 to 40 C.F.R. 745 .85(a)(4)(i) Waste from renovations: Did the renovator/firm contain waste from renovation activities to prevent releases of dust and debris before the waste is removed from the work area for storage or disposal and/or failure to cover a chute if it is used to remove ' waste from the work area? Comments 14 40 C.F.R. 745 .85(a)(4)(ii) Waste from renovations: Did the renovator/firm , at the conclusion of each. work day and/or at the conclusion of the renovation , ensure that waste that had been collected from renovation acti vities 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? Comments IS to 40 C.F.R. 745 .85(a)(4)(i ii) Waste from renovations: Did the renovation firm contain the waste to prevent release of dust and debris during the transport of waste from renovation activities? Comments 16 40 C.F.R. 745 .85(a)(5) Clea ning the work area: Did the renovation firm clean the work area until no dust, debris or residue remained after the renovation had been completed? Com ments 17 40 C.F.R. 745 .85(a)(5)(i)( Cleaning the work area : did the renovati on firm collect all paint chips and debris and sea l the materi al in a heavy-duty bag A) without dispersing any of it? Comments Page 10 of 21 iJ 1~ r11~ ~l ~\ ~\~ ~\t- ~\ ~\~ COMPANY NAME: _ _ _ _ _...,l_f..z.><)c.oL+,_,__1e"4"'1.i_,__(]d==/JC'Lt-J=ch.+-- - - - - - - 16 Hunt Military Community at Randolph Inspection Date: 10/22/2024 ft 0 U.S. EPA Lead Renovation/Repa ir/ Painting Complia nce heckli t - Ren ova tors US ENVIRONMENTAL PROTECTION AGENCY REGION 6, OALIAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION 18 40 C.F. R. Cleaning the work area: Did 1hc renovalion finn remove 1he 745.8.(a)(5)(i)(B pro1ec1ive shee1ing by misting 1he heeling before foldi ng it, ) fo lding the dirty side inward, and/or either taping shut to seal or sca ling it in heavv-dutv bags? iY \~,J Comments ~ 19 40 C.F.R. Cleaning the work area: Did the renovalion fi rm keep in place 'jJ 745.85(a)(5)(i)(B the plastic sheeting u ed to isolate contaminated rooms from t non-contaminated rooms until after the cleaning and removal of ~ u other sheeting? Comments 20 40 C.F. R. Cleaning the work area: Did the renovation firm dispose of 745.85(a)(5)(i)(B the plastic sheeting, used as occupant protection at the ) renovation site, as waste? "\ ~~~ Comments 21 40 C. F.R. 745 .85(a)(5)(ii) Cleaning the work area: Did the renovation firm clean all objects and surfaces in the work area and within 2 feet of the work area, cleaning from higher to lower? ,? ~\\\~ Comments 745.85(a)(5)(ii)( in the work area, starting at the ceiling and working down to th 2 e 2 40 C.F.R. Cleaning the work area: Did the renovation firm clean walls )<!J isP A) floor, by either vacuuming with a HEPA vacuum or wiping ~ with a damo cloth? Comments 23 40 C.F. R. Cleaning the work area: Did the renovation firm thoroughly 745.85(a)(5)(i i)( vacuum all remaining surfaces and objects in the work area, B) including furniture and fixtures, with a HEPA vacuum and/or ~~ ~ fa ilure to use a HEPA vacuum equipped with a beater bar when vacuuming carpets and rugs? _ Comments 24 40 C. F.R. Cleaning the work area: Did the renovation fi rm to wipe all 745.85(a)(5)(ii)( C) remaining surfaces and objects in the work area, except for carpeted or upholstered surfaces, with a damp cloth and/or fa ilure to mop uncarpetcd floors thoroughly, using a mopping V'"~ method that keeps the wash water separate from the rinse water, such as the 2-bucket mopping method, or using a wet mopping system? Comments 25 40 C.F.R. 745.85(b)( I)(i) I\Jo~ renovator perform a visual inspection of the interior work area Standards for post-renovation cleaning verification: Did the ~ to de1er111ine whe1her dust, debris or residue is still present. to Page 11 of 21 COMPANYNAME:- ---+-li~u~n~+~f<~c.=la~"c-l.""o71(JF-'-'--'h__________ 17 Hunt Military Community at Randolph Inspection Date: 10/22/2024 ( ft 0 U.S. EPA Lead Renovation/Repair/Pa intin g Compli ance Checklist - Renova tors US ENVIR ONM EITTAL PROTECT ION AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEA D HAZARD REDUCTION remove du st, de bris or residue by re-c leaning if necessa ry, and/or perfo rm anoth er v isual inspection? Comm ents 26 40 C. F.R. Standard s for pos t-renovation cleanin g verificati on: Did the 745 .85(b)( I)(ii)( renovator veri fy th at each interi or windows ill in th e work area A) has been adequately clea ned usin g a di sposa ble clea ning cloth(s) compared to the clean in g verificatio n card fo llowi ng the prescribed procedures, pursuant to 40 C.F.R. 745 .85 (b)( l )( ii) (A) or fa ilure by a cert ified renovator to arrange fo r the co llection du st cl eara nce samples as part of opti onal dust clearance testing? Comments 27 40 C.F. R. Standards for post-renovation cleaning verification : Did the 745.85(b)( I)( ii)( renovator fail to veri fy that each interi or fl oor in th e wo rk area B) has been adequately cleaned usin g a di sposable cleaning cloth(s) compared to the cleanin g verificati on card fo ll ow in g the prescribed procedures pursuant to 40 C. F.R. 745 .85 (b)( l )( ii ) (B) or fa ilure by a certified renovator to arrange fo r tlie co llecti on dust clea rance sampl es as part o f optional du st clearance testing? Comments 28 40 C. F.R. Standards for post-renovation cleaning verification: Did the 745 .85(b)( I)(iii) renovator wa it until interior work area passes post-renovation cleanin g verificati on be fo re removin g signs? Comments 29 40 C.F. R. Stand ards for post-renovation cleaning verification: Did the 745 .85(b)(2) renovator perform a visual in spection of the exteri or work area to determine whether dust, debris or residue is still present, to remove dust, debris or res idue by re-cl eaning if necessary, and/or perfo rm another visual inspection? Comments 30 40 C.F. R. Standards for post-renovation cleanin g verification: Did the 745 .85(b)(2) renovator wait unti l exterior work area passes visual in spection before remov ing signs? Comments 31 40 C.F.R. Standards for post-renovation clea nin g verification : Did the 745.85(c) renovati on firm arrange fo r perfo rm ance of optional dust clearance testing at the co nclu sion of the renovatio n if req uired 10 do so by the person co ntractin g fo r the renovati on, a Federa l, State, Territori al. Tribal, or loca l law or regulation? tc>\~ " ~~,,,.) V f ~~,? '1-...o 0 1.1Q io"' 0 \) ~o-Y Page 12 of 21 co MPANYNAME: - - - - - ~Y~u~a~+~ l{~JJ,o~d~.1-14-oF_h~ - - - - -- - - 18 Hunt Military Community at Randolph Inspection Date: 10/22/2024 ft 0 U.S. EPA Lead Re novation/Repair/Pa inting Complia nce Checklist - Renovators US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DAUAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION Comments 32 40 C.F.R. Standards for post-renovation cleanin g verification: Did the 745 .85(c)(2) renovator have the optional du t clearance testing performed by a certified inspector, risk assessor or dust sam pling technic ian at the conc lusion o f the renovation? C o m m e nts 33 40 C.F.R. Standards for post-renovation cleaning verification: Did the 745.85(c)(3) renovation firm re-clean the work area until dust clearance results are below clearance standards? Comments ~ ~\~ INSPECTION/RISK ASSESMENT/ABATEMENT WORK PRACTICE STANDARDS APPLICABLE ONLY IF CERTIFIED INSPECTIONS AND ASSESSMENTS OCCURED # Rel? Ref Q uestion Y-N-N/A 1 40 C.F. R. Target Housing and Child-occupied Facilities: Did the 745 .227(a)(I) renovator/firm perform all lead-based paint activities pursuant to the work practice standards, appropriate requirements, \J\ i methodolo!!ies and clearance levels soecified and referenced? Comments 2 40 C.F.R. 745.227(a)(2) Target Housing and Child-occupied Facilities: Did the renovator/firm ensure lead-based paint activity described by the ~ \ \C>c certified individual as an inspection, lead-hazard screen, risk assessment or abatement, was performed by a certi lied individual? Comments 3 40 C.F.R. Target Housing and Child-occupied Facilities: Did the 745.227(b)(l) renovator/firm ensure an inspection was conducted only by a person certified by EPA as an ins pector or risk assessor and, if 0\ t- conducted, must be conducted accord ing to the prescribed procedures? Comments 4 40 C.F.R. 745.227(b)(2) Target Housing and Child-occupied Facilities: Did the renovator/firm conduct an inspection at select locations ~\t accord ing to documented methodo logies to be tested fo r the oresence of lead-based oaint? Comments 745 .227(b)(2)(i) renovator/firm test for lead-based 1>aint each interior and/or 5 40 C.F.R. Target Housing and Child-occupied Facilities: Did the t-l \ Page 13 of 21 COMPANY NAME: - - - - - - "Y""v..:..,()+...,__ .uf""",'y-.l-.U/o<'I /J~h.___ _ _ _ _ _ _ __ I 19 Hunt Military Community at Randolph Inspection Date: 10/22/2024 ft 0 U.S. EPA Lead Renovation/Repair/ Painting Co mpliance Check list - Renovators US ENVIRONM ENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 7S202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION exterior compone nt w ith a distinct paint ing history in a resident ia l dwelling and/o r ch ild occupied fa cilitv? Co mm e nt s 6 -40 C.F.R. Target Housing and Child-occ upied Facilities: Did the 74 - .227(b)(2)(ii) renovator/firm test for lead-ba ed paint each in terior and/or exterior component, ith a distinct painting history in a multi- family dwell ing? Comments 7 40 C.F. R. Target Housing and C hild-occupied Facilities : Did the 745.227(b)(3)(i) renovator/firm ensure that paint sampled for analysis to determine the presence o f lead was conducted us ing documented methodologies which incorporate adeq uate quality control orocedures? Comments 8 40 C.F.R. Target Housing and Child-occupied Facilities: Did the 745 .227(b)(3)(ii) renovator/firm ensure that all collected pa int chip samples were analyzed according to 40 C.F.R. 745 .227(f) to determine if they conta in detectable levels of lead that can be quantified num e r ical Iv ? Comments 9 40 C.F. R. Ta rget Housing and Child-occupied Facilities: Did the 745.227(b)(4) inspector or risk assessor prepare an inspection report that inc ludes the required information? C o mm c t s 10 40 C.F.R. Target Housing and C hild-occupied Facilities: Did the 745 .227(c)(I) renovator/firm ensure that a lead hazard screen was conducted only by a person certified by EPA as a risk assessor? C omm e nts 11 40 C.F.R. 745 .227(c)(2)(i) Ta rget Housing a nd Child-occupied Facilities: Did the renovator/firm ensure that a lead hazard screen included the collection of background information regarding the phys ical characteristics of the residential dwelling or child-occupied faci lity and occupant use patterns that may cause lead-based paint exposure to one or more children age 6 years and under? Comments 12 40 C.F.R. Target Housing and Child-occnpied Facilities: Did the 745 .227(c)(2)(ii) renovator/firm ensure a lead hazard screen includes a visua l (A) insoect ion to determine the DTCsence of deteriorated paint? Comments \lo,) \){> yj\b.J Jf v~ ~\o~ y~ \/~ r;,\o.,J J~ -.? ~ ),~() Page 14 of 21 20 Hunt Military Community at Randolph Inspection Date: 10/22/2024 U.S. EPA Lead Ren ova tion/Repair/Painting ompliancc hcckli t - Renova tors US ENVIRONMENTAL PROTECTION AGENCY REGION 6, OAUAS, Tl< 7S202 TOXIC SUBSTANCES CONTROLACT TITLE IV-LEAD HAZARD REDUCTION 13 40 .F.R. Targcl Ho using and C hild -occupied Facililics: Did 1hc 745.227(c)(2)(ii) renovalor/firm en urc a lead haza rd screen incl udes a visual (8) i11spec1ion to locale at least two dust samples performed ~\,?~ according 10 the prescribed methodologies? Comments 14 40 C.F.R. 745 .227(c)(3) Target Housing and C hild-occupied Facililics : Did the renova1o r/firm en u rea lead hazard screen includes the collection and analysis of dust ample acco rding to the 'x~6~~ prescribed methodologies? C o mm e nt s 15 40 C.F.R. Target Hous ing and Child-occupied Facilities: Did the ) 745.227(c)(4) renovato r/fi rm ensure a lead hazard screen includes the collection and analysis o f paint samples accord ing 10 1he ti~Q prescribed methodologies? Comments 16 40 C.F.R. 745.227(c)(5) Target Housing and Child-occupied Facilities: Did the renovator/firm ensure a risk assessor prepared a lead hazard screen report that includes the required information fo und in 1he regu lation? ~t~ Comments 17 40 C.F.R. 745.227(d)( l) Target Housing and Child-occupied Facilities: Did the renovator/firm ensure a risk assessment was conducted only by a person certified by EPA as a risk assessor? -~a..i ~\"~ Comments 18 40 C.F.R. 745.227(d)(2) Target Housing and C hild-occupied Facilities: Did the renovator/firm ensure that a risk assessment includes a visual inspection of lhe residential dwe ll ing or child-occupied faci lity to locale lhe existence of deteriorated painl, assess the extent .) ~o 't ,J~ and causes ofthe deterioration, and other potential lead-based paint hazards? C o m me nts 19 40 C.F. R. Target Housing and C hild-occupied Facilities: Did the 7 4 5 . 2 2 7 (d )(3) renovator/firm ensure that a lead hazard screen includes the Ml collection of background info rm ation regarding the phys ical characteri stics of the residentia l dwelling or c hild-occupied ~ \)~ facil ity and occupa nt use patterns that may cause lead-based paint exposure to o ne or more children a,e 6 years and under? Comments Page 15 of 21 COMPANY NAME: - - - -----'-'H-"'u-'--'')1_.r_ _,_{<_.,_,a,...,,.....,~c~lo~l.pfwch.,___ _ _ __ _ _ _ __ 21 Hunt Military Community at Randolph Inspection Date: 10/22/2024 U.. PA Lead Reno alion/Repair/Painling omplia nce hccklist - Renovator US ENVIRONM ENTAL PROTECTION AGENCY REGION 6, CALLAS, 1'X 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION 20 40 C.F.R. 74 .227(d)(4) Target Housing and Child-occupied Facilities: Did the reno ator/ finn tc t fi r the pre cncc o r lead on each urface determined to have a distincl oainting history? >P"~ Comm ent s 21 40 .F.R. 745.227(d)(5) Residential Dwellings: Did the renovator/ firm collect and analyze for lead concentration du t am pies (either composite or ingle-surface samples) from the interior window sill(s) and 0oor( ) in all living areas where one or more children, age 6 and under are most likely to come into contact with dust? .j) ~\~ Comments 22 40 C.F. R. 745.227(d)(6) Multi-family Dwellings and Child-occupied Facilities: Did the renovator/firm collect and analyze interior window sill and noor dust samples (either composite or single-surface samples) v; ~ J~ for lead concentration from the prescribed locations? Comments 23 40 C.F.R. 745.227(d)(7) Child-occupied Facilities: Did the renovator/firm collect and analyze interior window sill and floor dust samples (either composite or single-surface samples) for lead concentration in each room, hallway or stairwell utilized by one or more children, age 6 and under, and in other common areas in the child occupied facility? ..;; ~~ Comments 24 40 C.F.R. Target Housing and Child-occupied Facilities: Did the 745.227(d)(8) renovator/firm collect and analyze soil samples for lead concentrations in the orescribed locations? ~,~ Comments 25 40 C.F.R. Target Housing and Child-occupied Facilities: Did the 745.227(d)(9) renovator/firm conduct all paint, dust, or soil sampling or testing using documented methodologies that incorporate adequate quality control orocedures? ,,// - Comments 26 40 C.F.R. 745.227(d)(I 0) Target Housing and Child-occupied Facilities: Did the renovator/firm analyze any collected paint chip, dust, or soil ti samples according to 40 C.F.R. 745.227(f) to determine if they 0 \)~ contain detectable levels of lead that can be quanti tied numerically? Comments 27 40 C.F.R. Target Housing and Child-occupied Facilities: Did the 745.227(d)( l I) renovator/firm/risk assessor prepare a risk assessment report that includes the required information? \.)I-J Page 16 of 21 COMPANY NAME: _ _ _ _ __1,_-h....,J.J,_'.l._,_ __,_R.u.a&.L.LaU.d-'-<n_,__l1,_,.o....,h'----- -- - -- - - 22 r Hunt Military Community at Randolph Inspection Date: 10/22/2024 ft 0 U.S. EPA Lead Renovation/Repa ir/Paintin g Compliance Checklist - Renova tors US ENVIRONMENTALPROTECTION AGENCY REGION 6, DALLAS, TX 7S202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION Comm ents \~ 28 40 C.F.R. 74".227(e)( l) Target Housin g and Child-occupied Facilities: Diel the renovator/fi rm ensure that an abatement i conducted only by a person certi fied by EPA, and, if conducted, is conducted accordin11. to the orescri bed tJrocedures? Comments 29 40 C.F.R. 74 5. 22 7(e)(2) Target Housin g and Child-occupied Facilities: Did the fi rm ensure a certified renovator was available to be onsite for each abatement project during all work site preparation, during the post-abatement cleanu p of work areas, and to be onsite at other J\ ~ times during the abatement or available by telephone, pager or answering service and able to be present at the work site in no more than 2 hours? Comments 30 40 C.F.R. Target Housing and Child-occupied Facilities: Did the fi rm 745 .227(e)(3 ) ~\ t ensure a certified renovator was available to direct acti vities and ensure that all abatement activities are conducted according to the requirements of 40 C.F.R. 745.227(e) and all other Federa l, State and local requirements? Comments 31 40 C.F. R. Target Housin g and Child-occupied Facilities: Did the 745 .227(e)(4)(i- renovation firm noti fy EPA of lead-based paint abatement v) activities or to update notification as prescribed and by the designated deadline? 0\~ Comments 32 40 C. F.R. Target Housing and Child-occupied Facilities: Did the 745 .22 7(e)(4)(vi) renovation firm include the designated info rmation in each notifi cati on? ; tp~DJQ Comm ents 33 40 C.F.R. Target Housing and Child-occupied Facilities: Did the 745.227(e)(4)(vii certified firm accomplish written or electronic notification via ) one of the prescribed methods? ~o~Q Comments 745.227(e)(4)(vii renovation fi rm begin lead-based paint abatement act 3 iv 4 ities on 40 C.F.R. Target Housing and Child-occupied Facilities: Did the ~~ i) the date and at the location speci fied in either the origina l or updated Notification? C o mm e nt s 35 40 C.F.R. Target Ho using and Child-occupied Facilities: Did the ~~ 74 5.227(e)(4)(ix) cert ified renovation fi rm or individual noti fy EPA before Page 17 of 21 COMPANY NAME: _ _ _ _ _/,-_'1-U.-<inJU...,../._ ..,_,?,.a."'-'r--:'vw:leos.."-,l,""o.,__b,____________ 23 Hunt Military Community at Randolph Inspection Date: 10/22/2024 ft 0 U.S. EPA Lead Re novatio n/Repa ir/ Pa int ing Comp lia nce Check list - Re novators US ENVIRONMENTAL PROTECTI ON AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTROLACT TITLE IV-LEAD HAZARD REDUCTION e ngaging in lead-based paint abatement activities defined in 40 C .F.R. ~ 745.223? Comments 36 40 C.F.R. 745.227(e)(5) Target Housing and Child-occupied Facilities: Did the certified renovation firm o r indiv idua l de velop a written occupant protection plan fo r al l abatement projects and in accordance with the orcscribed orocedures? Com ments 37 40 C.F.R. 74 5 .2 2 7 (e)(6)( i) Target Housing and Child-occupied Facilities: Did the certified firm/renovator prohi bit the use of open-flame burning or torching of lead-based paint durim! abatement activities? Comments 38 40 C.F.R. Target Housing and Child-occupied Facilities: Did the 745.227(e)(6)(ii) certified firm/renovator prohibit the use of machines that remove lead-based paint through sanding, grinding, abrasive blasting, or sandblasting, un less such mac hines a re used with HEPA exhaust control which removes particles o f0 .3 m icrons or la rger from the air at 99.97 percent or greater effi ciencv? Comments 39 40 C.F.R. Target Housing and Child-occupied Facilities: Did the 745.227(e)(6)(iii certified firm/renovator prohibit the dry scraping o f lead-based ) paint un less it is used in conjunction w ith heat guns or around electrical outlets or when treating defecti ve paint spots totaling no more than 6 square feet in any one room, hallway, or stairwell or totaling no more than 20 square feet on exterior surfaces? Comments 40 40 C .F.R. Target Housing and Child-occupied Facilities: Did the 745.227(e)(6)(iv) certified firm/renovator restrict the operating of a heat gun on lead-based paint at temperatures below 1100 degrees Fahren he it? Comments 41 40 C.F.R. Target Housing and Child-occupied Facilities: Did the 745.227(e)(7) certified firm/renovator conduct soil abatement, when necessarv, according to the orescribed methods? Comments 42 to 40 C.F.R. Target Housing and C hild-occupied Facilities: Diel the 7 4 5 . 2 2 7(e)(8) certified firm /renovator have a ce rtified inspector or risk assessor oerform the oost-abatement clearance nrocedures? Comments Page 18 of 21 ~ v'.) ,J ~ ~ ~\~ i\~ ~\ ~ ~'-~, ~\ COMPANY NAME: _ _ __ ___h,_Ji:lcXeJ.L~L._. _,.,g.uOCLOCu.u/,c,,._Jf"p..:...M.,___ _ _ _ _ _ __ _ I 24 Hunt Military Community at Randolph Inspection Date: 10/22/2024 ft 0 Lead Renovation/Repair/ Painting omplian ce hccklist - Renovators US ENVIRONMENTAL PROTECTION AGENCY REGION 6, OALIAS, TX 75202 U.S. EPA TOXIC SUBSTANCES CONTROL ACT I TITLE IV-LEAD HAZARD REDUCTION I 43 40 C.F.R. I 745 .227(c)(S)(i) Target Housing and Child-occupied Facilities : Did the certified firm have an in pector or risk assessor to perform a i ual in pect ion aficr abatement to detcnninc if deteriorated painted surfaces and/or vi iblc amounts of dust. debris or residue arc still present and to remove any hazard that still ~ y}-~.,'.) I remain? Com ments 44 40 C.F.R. Target Housing and Child-occupied Facilities: Did the ,.,~ I 74 -.227(e)(8)(ii) certified firm/renovator wait until the requ ired visual inspection ~ ~l and any necessary post-abatement cleanups were completed I before oerforming clearance samoling for lead in dust? I Comments 45 40 C.F.R. Target Hous ing and Child-occupied Facilities: Did the 745.227(e)(8)(iii certified firm/renovator take dust samples for clearance ) purposes using documented methodologies that incorporate adequate Quality control orocedures? ~ ~\\6,/ Comments 46 40 C.F.R. Target Housing and Child-occupied Facilities: Did the 745.227(e)(8)(iv) certified firm/renovator wait a minimum of I-hour after completion of final post-abatement cleanup activities to collect dust samoles for clearance ourooses? ,i) ~\I ~ J\ Comments 745.227(e)(8)(v) certified firm/renovator collect the required dust samples from 47 40 C.F.R. Target Housing and Child-occupied Facilities: Did the ~l (A) the prescribed surfaces in the designated rooms after conducting \0 J~ an abatement with containment between abated and unabated areas? Comments 745.227(e)(8)(v) certified firm/renovator collect the required 4 d 8 ust samp 4 le 0 s C fr . o F m .R. Target Housing and Child-occupied Facilities: Did the i l (8) the prescribed surfaces in the designated rooms after conducting ~I)~ an abatement with no containment? Comments 49 40 C.F.R. Target Housing and Child-occupied Facilities: Did the 745.227(e)(8)(v) certified firm/renovator conduct a visual inspection and clean ) (C) horizontal, outdoor surfaces of visible dust and debris, perform ~ IJ~ visual inspection for paint chips on the dripline and remove and properly dispose of any paint chip fo und following an exterior oaint abatement? C o m men ts Page 19 of 21 COMPANY NAME: - - - -~H=o~a~f_: ..f..l~.o.._y'.]~d_,_o"liff-.L-h,___ __ _ __ _ _ _ 25 Hunt Military Community at Randolph Inspection Date: 10/22/2024 ft 0 U.S. EPA Lead Reno va tion/Repa ir/ Painting hcckli t - Ren ova tor US ENVIRONMENTAL PROTECTION AGENCY REGION 6, OALLAS, TX 7S202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION 50 40 .F.R. Target Housin g and C hild-occupied Facilities: Did the 74 - .227(e)(8)(vi) certified firm/renovator elect the rooms, ha ll ways or sta irwell for sampling according 10 documcn1ed methodolog ies? Co mments 51 40 .F.R. Target Housing and Ch ild-occupied Faci lities: Did the 7.\5.227(c)(S)(vi i cert ifi ed inspector or ri k as essor compare the residual lead ) level from dust amplcs with clearance levels lo determine if level exceeds the annl icable clearance level? Comments 52 40 C.F. R. Target Housing and Child-occupied Faci lities: Did a 745.227(e)(8)(vii certified inspector or ri sk assessor re-clean and retest the ) surface o f components that were determined 10 have fai led clearance testing after a batement? Comments 53 40 C.F.R. Target Housing and Child-occupied Facilities: Did the 745 .227(c)(8)(vii certified firm/renovator use the standard clearance levels for i) lead in dust of 40 g/ ft.2 for floors, 250 g/ft.2 for interio r window sills, and 400 g/ft.2 for window troughs to determine if a level in a sample exceeds the annlicable clearance level? Comments 54 40 C.F.R. 745.227(e)(9) Target Housing and Child-occupied Facilities: Did a certified firm/renovator perform random sampling in a multifamily dwelling with similarly constructed and mainta ined residential dwellings according to the prescribed methods? Comments 55 40 C.F. R. Target Housing and Child-occupied Facilities: Did a 745.227(e)( I0) certified renovator/supervisor or projec t designer prepare an abatement report that includes the requ ired in formation? Comments 56 40 C.F.R. Target Housing and Child-occupied Facilities: Did a 745.227(t) certified renovator ensure that a ll paint chip, dust, or soil samples obtained are collected by a certified risk assessor or oaint inspector and analyzed bv an EPA recognized laboralorv? Comments 57 40 C.F.R. Target Housing and Child-occupied Facilities: Did the 745.227(g) certifi ed renovator limit composite dust sampling 10 only those situations specified? Comments /vJ l~ ) I ~\o ~ { 0 \o,p '\ \'"\)~ ~u\\o;~ / ~\i~ '( v / btovJ~ \" v ,, ~o.,) v o \)~ / r~\/v~ Page 20 of 21 c oMPANv NAME: _ _ __,_H....,u"'"n.,_+,__-'-\_(,_,"a",,n--"c~lo=l,.,..p,_h,__ _ _ _ _ _ _ _ __ 26 Hunt Military Community at Randolph Inspection Date: 10/22/2024 ft t'> U.S. EPA Lead Renovation/ Repair/ Pa inting omplia ncc Chcckli I - Renova tor US ENVIRONMENTALPROTECTION AGENCY REGION 6, DALLAS, TX 7S202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION 58 40 C.F.R. Target Housin g and Child-occupied Facilities: Did the 74".227(h) certified renovator make a determination on the presence of lead-based paint? Comment s 59 40 CFR 745.233 Target Housing and Child-occupied Facilities: Is the fi rm certified performs, offers or claims to perform renovations or dust sampling for compensation to obtain in itial certification from EPA. under 40 C.F.R. &745.226? Comments I' ~.,J r~\ ~ ~ r ? v\)~~ # Re2 Ref LEAD-BASED PAINT RJSK ASSESSMENTS Qu estion Y-N-N/A I 40 C.F. R. 745.227(d)( I) Is the person performing a risk asses ment certified by EPA as a risk assessor? 0 ,~ Comments 2 40 C.F.R. 745.22 7(d)(2) Did a certified renovator conduct a visual inspection fo r risk assessment ofa child-occupied facility to locate the existence of deteriorated paint. assess extent and causes of deterioration, and ~\~ other potential lead based paint hazards? 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 M inor = no occupants under age 18 Child Occupied Facility M ajor = one or more occupants under age 6 (by definition, a child-occupied facility 1s 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 contin uity of enrollment (i.e., the same children are not returning after the break). Page 21 of 21 COMPANY NAME: _ _ __ .._llix)--''-""t---'Ru-=-._,,nr'--l'-c..J.. f'-p"""h'-------- - - ---- - - -- - - - - - - - - - -------.-------- - -- - -- - -- - - - -- - --ft:'~ 27 Hunt Military Community at Randolph Inspection Date: 10/22/2024 Appendix 3 Maps of Community 28 Hunt Military Community at Randolph Inspection Date: 10/22/2024 13 16 ~ ... l ' l ' ., ,_.,...,,., 1 - 11 ! . I ~-:;... , ~ .. i I ~'\.~' ~.. I =I" 905 ~ 41 ..__ _., -:., I!" ~ , ......... ~/ ....~ I.' .' l i ,; I .. ~ ~~- _, I -- 4"1 ! 1111. J; A i. I i I' I C )- --"" :e ~ q I ~ go ~ - 8 L I ' " i_ ~ 71 70 '< . .... eio._, ._ ,...,_ ., . . , _ .. ..__. > ,- ~ - - c - . . . .,..,. .- .... - . n it.u-- ,. .... _,,,., . , _ , - . .c- -"""" --- ,._....,J_,.a ,, _ _c_ ..----- w: v '" - - - -.. - - - , . _ JBSA - Randolph Q I J 600 Tinch = 530 feel 29 Hunt Military Community at Randolph Inspection Date: 10/22/2024 Appendix 4 Receipt for Samples and Documents (Form 7740-1) 30 Hunt Military Community at Randolph Inspection Date: 10/22/2024 ~ - ,~EPA l'"fed ,.. [ ~ t a,.,,,,t.ctlO" Agency United St t es ENVIRONMENTAL PROTECTION AGENCY Wa shington, DC 20460 Receipt for Samples and Documents Office of Enforcement and Compliance Assurance ,I II 1 lnvestogat1on Identifica tion Dat e Inspect ion No. l10/u../t-01.l1II 1-1 Daily Seq No. 11 I 2 Company Name I 114ht- 1,1111 ,h:--] lM'1r11uvi1h't:s 1 ,14,J "'r." f;...y-,0 H-iM.,1~ 3. Inspector Address I11..ol E"lm. .s;-.u..+ 1 : ~.qfr... , f"c~t. \ )~~.70 I 4. Company Address 1Jo 5 f/ t:l..,,J r., s-t U r, IJ-cb c...l f': , l ,""-f, ~ l ]J/So For internal EPA use Copies of th,s form may be provided to rec,pIent as acknowledgmen t of the documents and samples of chemical su bstancesand/or mixtures described below collected ,n connection w,th the admin,stra t1on and enforcement of the Tox,c Substances Control Act Recei pt of Document(s) and/or Sample(s) Descri bed is Hereby Acknowledged: No. Descri ption I I ll ~ f of- "J l,SA- - /2.c.f't,,l vltfll.A {_ [).. l uf ; t.l.) I I I 11 I I I I I Optional: Duplica te or Spht Sam ples: Requested and Provided Not Requested D Inspector's Sig nature ~ /,/jf,D :.A- / '11 Name l ~ /4 JJ~. ( - Clai m ant'~ Signa t ure ~ Namff Jusl-- T.,,.,,. ntle I Iris/ah,;, JIDatel /J/zr_/~1IT/Itie IC,i,/flm toi , -f..y D, r <c+c-,,. ll Date ~ EPA 101m 77-40-1 (Rev ]/16) 31