Document L5JL0862XboQB6d6oj4KX9jg
Document No: R8FQPForm-2010 R0 Effective Date: 07/27/2017
EPA Region 8 TSCA 1018 Lead-Based Paint Disclosure Rule Recordkeeping Inspection Checklist
Page 1 of 8
BASIC INSPECTION INFORMATION
Inspection 1. Date / Time: 03/02/2023 12:56
2. ICIS #: 3601510460
3. Inspector Name: Kristin Jendrek
4. Name & Address of Facility / Company:
Keystone Property Management 601 N Main Street, Ste 205
5.
Type of Facility:
6.
Mailing Address of
7.
Facility:
residence
office
other ________________________
Description/Name: Property Management Office
Street Address:
City/State/Zip:
Point of Contact:
Telephone Number:
Company Name:
Street Address:
City/State/Zip:
8.
Owner:
Name: Susan D. Sanders
Address:
City/State/Zip: Person(s) interviewed during inspection:
Name & Title:
Employer:
Contact Information:
Susan D. Sanders, Owner
Keystone Property Mgmt 719-543-4575
9. Ann Sanders
Keystone Property Mgmt
Document No: R8FQPForm-2010 R0 Effective Date: 07/27/2017
EPA Region 8 TSCA 1018 Lead-Based Paint Disclosure Rule Recordkeeping Inspection Checklist
Page 2 of 8
Facility Name: Keystone Property Management
Inspection Date: 03/02/2023
On _0_3_/_0_2_/2_0_2_3________________ at approximately _1_2_:_3_0_______
a.m. p.m.
I, _K_r_is_t_in__J_e_n_d_r_e_k______________ arrived at _K_e_y_s_t_o_n_e_P__ro_p__e_rt_y_M__a_n_a_g_e_m__e_n_t______.
Upon arrival, I was greeted by _S_u_s_a_n__S_a_n_d_e_r_s__a_n_d_A__n_n_S__a_n_d_e_r_s_____________.
I introduced myself, presented my credentials, and provided my business card.
I explained that the purpose of my visit was to conduct an audit of files to determine the level of compliance with the Lead-Based Paint Disclosure Rule. I explained that after asking for some general business information, I would review a number of target housing rental agreements and associated disclosure forms according to the following table:
number of units
1 - 60
61-100
Over 100
10.
files to audit
6
10%
10 or more
(Sampling could increase for very large or complex properties.)
I asked Mr. /Ms. ________________ if he/she was the person who handled the transactions with the tenants and if all the leases were filed at this location of if the disclosure forms could be elsewhere.
I explained that at the conclusion of the inspection, I would conduct a closing conference with him/her at which I would review any potential violations observed, explain how to avoid them in the future, and provide compliance assistance materials.
I examined the lead-based paint disclosure form, or the lease containing lead-based paint disclosure
information that the facility uses: Yes No
Sample attached at _____.
I examined a sample of the lead hazard information pamphlet that the facility provides to lessees. The
sample provided...is is not EPA-approved.
Sample attached at _____.
GENERAL BUSINESS INFORMATION
Number of different properties: 11.
Number of property owners represented:
Number of target housing units:
Number of HUD/Section 8/assisted units:
Number of studio apartments:
owns
manages 250 residential rental dwelling units.
at the inspection location
total
250 87 200 5 vouchers
Document No: R8FQPForm-2010 R0 Effective Date: 07/27/2017
EPA Region 8 TSCA 1018 Lead-Based Paint Disclosure Rule Recordkeeping Inspection Checklist
Page 3 of 8
Facility Name: Keystone Property Management Inspection Date: 03/02/2023
Target Housing Rental Transactions Reviewed information is recorded based on the date of the inspection
Address of unit: 109 E evans ave.
Name(s) of Lessee(s): Dennis Porter
# tenants age 0-5 yrs:
# tenants 6-18 yrs: 1 (6yo)
# pregnant tenants:
Type of lease: initial renewal
Building type: Single Family Multi Family
# of bedrooms: 2
12.1
Lease Term/Occupancy Dates: From: 10/21/2022 to: 10/30/2023
Date Lease signed by Lessee: 10/21/2022
by Lessor/Agent:
Date Disclosure Form signed by Lessee: 10/21/2022 by Lessor/Agent:
Agent Name
Ann Sanders
Lessee acknowledged receipt of Lead Information pamphlet:
Yes
No
No line/box available
Copies of documents collected: (included at Attachment E-1)
lease/rental agreement lead information pamphlet
disclosure form other
Comments: Unit of Cree Terrace Apartments
Address of unit: 109 1/2 E Evans Ave.
Name(s) of Lessee(s): Aurora Aldrich & Gelene Montoya
# tenants age 0-5 yrs: 0
# tenants 6-18 yrs: 0
# pregnant tenants: 0
Type of lease: initial renewal
Building type: Single Family Multi Family
# of bedrooms: 2
12.2
Lease Term/Occupancy Dates: From: 08/31/2021 to: 05/31/2022
Date Lease signed by Lessee: 08/31/2022
by Lessor/Agent:
Date Disclosure Form signed by Lessee: 05/20/2022 by Lessor/Agent: 05/20/2022
Agent Name
Ann Sanders
Lessee acknowledged receipt of Lead Information pamphlet:
Yes
No
No line/box available
Copies of documents collected: (included at Attachment E-1)
lease/rental agreement lead information pamphlet
disclosure form other
Comments: Unit of Cree Terrace Apartments
Address of unit: 111 E Evans Ave.
Name(s) of Lessee(s): Katrina Folds & Joseph DeJoy
# tenants age 0-5 yrs:
# tenants 6-18 yrs: 2
# pregnant tenants:
Type of lease: initial renewal
Building type: Single Family Multi Family
# of bedrooms: 2
12.3
Lease Term/Occupancy Dates: From: 04/07/2022 to: 03/31/2023
Date Lease signed by Lessee: 04/07/2022
by Lessor/Agent: 04/07/2022
Date Disclosure Form signed by Lessee: 04/07/2022 by Lessor/Agent: 04/07/2022
Agent Name
Ann Sanders
Lessee acknowledged receipt of Lead Information pamphlet:
Yes
No
No line/box available
Copies of documents collected: (included at Attachment E-1)
lease/rental agreement lead information pamphlet
disclosure form other
Comments: Unit of Cree Terrace Apartments
Document No: R8FQPForm-2010 R0 Effective Date: 07/27/2017
EPA Region 8 TSCA 1018 Lead-Based Paint Disclosure Rule Recordkeeping Inspection Checklist
Page 4 of 8
Facility Name: Keystone Property Management Inspection Date: 03/02/2023
Target Housing Rental Transactions Reviewed
12.4
Address of unit: 2024 Pine Street 81004
Name(s) of Lessee(s): Shirleen Sabatino
# tenants age 0-5 yrs: 0
# tenants 6-18 yrs: 0
# pregnant tenants: 0
Type of lease: initial renewal
Building type: Single Family Multi Family
# of bedrooms: 2
Lease Term/Occupancy Dates: From: 01/19/2023 to: 01/31/2024
Date Lease signed by Lessee: 01/19/2023
by Lessor/Agent: 01/19/2023
Date Disclosure Form signed by Lessee: 01/19/2023 by Lessor/Agent: 01/19/2023
Agent Name
Ann Sanders
Lessee acknowledged receipt of Lead Information pamphlet:
Yes
No
No line/box available
Copies of documents collected: (included at Attachment E-1)
lease/rental agreement lead information pamphlet
disclosure form other
Comments: Built in 1905. asbestos disclosure form included
12.5
Address of unit: 2623 Routt Avenue, Pueblo, CO 81004
Name(s) of Lessee(s): Jennifer Montez, Enrique Montelongo, Rio Montez
# tenants age 0-5 yrs: 0
# tenants 6-18 yrs: 0
# pregnant tenants: 0
Type of lease: initial renewal
Building type: Single Family Multi Family
# of bedrooms: 3
Lease Term/Occupancy Dates: From: 05/23/2022 to: 05/31/2023
Date Lease signed by Lessee: 05/23/2022
by Lessor/Agent: 05/23/2022
Date Disclosure Form signed by Lessee: 05/23/2022 by Lessor/Agent: 05/23/2022
Agent Name
Ann Sanders
Lessee acknowledged receipt of Lead Information pamphlet:
Yes
No
No line/box available
Copies of documents collected: (included at Attachment E-1)
lease/rental agreement lead information pamphlet
disclosure form other
Comments: Built in 1903.
Address of unit: 126 E Grant Avenue #2
Name(s) of Lessee(s): Chelsea Walters
# tenants age 0-5 yrs:
# tenants 6-18 yrs: 2
# pregnant tenants:
Type of lease: initial renewal
Building type: Single Family Multi Family
# of bedrooms: 2
Lease Term/Occupancy Dates: From: 05/01/2020 to: 04/30/2021
Date Lease signed by Lessee: 05/01/2020
by Lessor/Agent: 05/01/2020
Date Disclosure Form signed by Lessee: 05/01/2020 by Lessor/Agent: 05/01/2020
Agent Name
Ann Sanders
Lessee acknowledged receipt of Lead Information pamphlet:
Yes
No
No line/box available
Copies of documents collected: (included at Attachment E-1)
lease/rental agreement lead information pamphlet
disclosure form other
Comments: one unit within an 8-plex
12.6
Document No: R8FQPForm-2010 R0 Effective Date: 07/27/2017
EPA Region 8 TSCA 1018 Lead-Based Paint Disclosure Rule Recordkeeping Inspection Checklist
Page 5 of 8
Facility Name: Keystone Property Management Inspection Date: 03/02/2023
Target Housing Rental Transactions Reviewed Address of unit:
12.7
Name(s) of Lessee(s):
# tenants age 0-5 yrs:
# tenants 6-18 yrs:
# pregnant tenants:
Type of lease: initial renewal
Building type: Single Family Multi Family
# of bedrooms:
Lease Term/Occupancy Dates: From: Date Lease signed by Lessee:
to: by Lessor/Agent:
Agent Name
Date Disclosure Form signed by Lessee:
by Lessor/Agent:
Lessee acknowledged receipt of Lead Information pamphlet:
Yes
No
Copies of documents collected: (included at Attachment E-1)
lease/rental agreement lead information pamphlet
No line/box available disclosure form other
Comments:
Address of unit:
12.8
Name(s) of Lessee(s):
# tenants age 0-5 yrs: Type of lease: initial renewal Lease Term/Occupancy Dates: From: Date Lease signed by Lessee:
# tenants 6-18 yrs: Building type: Single Family
to: by Lessor/Agent:
# pregnant tenants:
Multi Family
# of bedrooms:
Agent Name
Date Disclosure Form signed by Lessee:
by Lessor/Agent:
Lessee acknowledged receipt of Lead Information pamphlet:
Yes
No
Copies of documents collected: (included at Attachment E-1)
lease/rental agreement lead information pamphlet
No line/box available disclosure form other
Comments:
Address of unit:
12.9
Name(s) of Lessee(s):
# tenants age 0-5 yrs:
# tenants 6-18 yrs:
# pregnant tenants:
Type of lease: initial renewal
Building type: Single Family Multi Family
# of bedrooms:
Lease Term/Occupancy Dates: From: Date Lease signed by Lessee:
to: by Lessor/Agent:
Agent Name
Date Disclosure Form signed by Lessee:
by Lessor/Agent:
Lessee acknowledged receipt of Lead Information pamphlet:
Yes
No
No line/box available
Copies of documents collected: (included at Attachment E-1)
lease/rental agreement lead information pamphlet
disclosure form other
Comments:
Document No: R8FQPForm-2010 R0 Effective Date: 07/27/2017
EPA Region 8 TSCA 1018 Lead-Based Paint Disclosure Rule Recordkeeping Inspection Checklist
Page 6 of 8
Facility Name: Keystone Property Management Inspection Date: 03/02/2023
Target Housing Rental Transactions Reviewed Address of unit:
12.10
Name(s) of Lessee(s):
# tenants age 0-5 yrs:
# tenants 6-18 yrs:
# pregnant tenants:
Type of lease: initial renewal
Building type: Single Family Multi Family
# of bedrooms:
Lease Term/Occupancy Dates: From: Date Lease signed by Lessee:
to: by Lessor/Agent:
Agent Name
Date Disclosure Form signed by Lessee:
by Lessor/Agent:
Lessee acknowledged receipt of Lead Information pamphlet:
Yes
No
Copies of documents collected: (included at Attachment E-1)
lease/rental agreement lead information pamphlet
No line/box available disclosure form other
Comments:
Address of unit:
12.11
Name(s) of Lessee(s):
# tenants age 0-5 yrs: Type of lease: initial renewal Lease Term/Occupancy Dates: From: Date Lease signed by Lessee:
# tenants 6-18 yrs: Building type: Single Family
to: by Lessor/Agent:
# pregnant tenants:
Multi Family
# of bedrooms:
Agent Name
Date Disclosure Form signed by Lessee:
by Lessor/Agent:
Lessee acknowledged receipt of Lead Information pamphlet:
Yes
No
Copies of documents collected: (included at Attachment E-1)
lease/rental agreement lead information pamphlet
No line/box available disclosure form other
Comments:
Address of unit:
12.12
Name(s) of Lessee(s):
# tenants age 0-5 yrs:
# tenants 6-18 yrs:
# pregnant tenants:
Type of lease: initial renewal
Building type: Single Family Multi Family
# of bedrooms:
Lease Term/Occupancy Dates: From: Date Lease signed by Lessee:
to: by Lessor/Agent:
Agent Name
Date Disclosure Form signed by Lessee:
by Lessor/Agent:
Lessee acknowledged receipt of Lead Information pamphlet:
Yes
No
No line/box available
Copies of documents collected: (included at Attachment E-1)
lease/rental agreement lead information pamphlet
disclosure form other
Comments:
Document No: R8FQPForm-2010 R0 Effective Date: 07/27/2017
EPA Region 8 TSCA 1018 Lead-Based Paint Disclosure Rule Recordkeeping Inspection Checklist
Page 7 of 8
Facility Name: Keystone Property Management
Inspection Date: 03/02/2023
COMPLIANCE ASSISTANCE
I provided the appropriate compliance assistance information pertaining to the Lead-Based Paint Disclosure 13. Rule 1018 and the Pre-Renovation Education (PRE) Rule 406(b). I explained the materials and made sure it
was understood.
14. I provided the appropriate compliance assistance information pertaining to the Renovation, Repair, and Painting (RRP) Rule 402(c). I explained the materials and made sure it was understood.
CLOSING CONFERENCE
At the closing conference, I reviewed the potential violations observed, and explained how to correct them. I also explained that there could be changes, pending further review by EPA Regional Office staff. I explained that as the inspector, I collected information and evidence, but would not be making a final determination with 15. regard to compliance and/or enforcement
This completed the inspection and I left the premises at 03/02/2023 1:45 pm
SUMMARY / COMMENTS (explanations, corrections and clarifications - refer to preceding sections)
Inspector visited Cree Terrace Apartments at 109 E Evans Ave, an apartment complex built in 1939, and realized there is not a leasing office on site. One of the tenants directed the inspector to Keystone Property Management, whom she called and subsequently visited to conduct the inspection. Inspector met with the owner, Susan D. Sanders, and employee Ann Sanders, who were both very familiar with the Lead Disclosure Rule. She reviewed several leases for the Cree Terrace property and several random additional leases from pre-1978 properties the company manages. Keystone has been including the lead disclosure form, which includes the Lead Warning Statement, providing a copy of the Protect Your Family pamphlet to prospective tenants, and in all cases has had no knowledge of specific lead-based paint or lead-based paint hazard information to share from property owners. Disclosure forms were all signed the same day the leases were signed.
After discussing lead disclosure, inspector asked if they were aware of the RRP Rule. Both Susan and Ann indicated they were not familiar with it. They indicated that all work to be done on their rental units is contracted out and not performed by employees of Keystone Property Management. Inspector provided an explanation of property managers' obligations with regard to RRP, gave them copies of the Renovate Right pamphlet and the Small Entity Compliance Guide, and answered questions about how to find certified contractors, what to expect for different kinds of work, etc. Inspector mentioned an upcoming EPA presentation to a local landlord association on these regulations, and Susan expressed interest in attending.
Document No: R8FQPForm-2010 R0 Effective Date: 07/27/2017
EPA Region 8 TSCA 1018 Lead-Based Paint Disclosure Rule Recordkeeping Inspection Checklist
Facility Name: Keystone Property Management Inspection Date: 03/02/2023
SUMMARY / COMMENTS (cont'd)
Page 8 of 8
REPORT SUBMITTED BY Inspector signature:
Print or type inspector's name:
Kristin Jendrek
Digitally signed by KRISTIN JENDREK Date: 2023.04.12 09:03:47 -06'00'
Date:
04/12/2023
REPORT REVIEWED BY Reviewer signature:
Digitally signed by BRITTA COPT Date: 2023.04.13 08:21:09 -06'00'
Print Name & Title of Reviewer:
Britta Copt, Enforcement Officer
Date:
04/13/2023