Document omJwgkLaaoqQDr8oBJQ3Y97jo

0ft EAIA Unrted States 1"\~~~i~~ mental Protection Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 3/27/2024 Toxic Substance Control Act Renovation Repair and Paint (RRP) Company Name: Facility Name: Facility Physical Location: (city, state, ip code) Mailing address: (city, state, ip code) County/Parish : Facility Phone Number Facility Contact: EcoStar Remodeling & Construction 13140 Coit Rd Suite #340 Dallas, TX 75240 Dallas (214) 612-5331 Ariel Tchernechovsky ArielT2892P'mail.com I I 818-306-8021 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 Ariel Tchernechovsky EcoStar Inspector Inspector Manager EPA Lead Inspector Signature/Date ANGELA HAYS Angela Hays/ Date Digitally signed by ANGELA HAYS Date: 2024.05.02 13:29:18-05'00' Supervisor Signature/Date H STUCKEY Troy Stuckey/ Date Digitally signed by H STUCKEY Date: 2024.05.02 14:36:35 -05'00' 6ENFORM-019-R8.2 (02/12/2020) 1 Section I INTRODUCTION PURPOSE OF THE INSPECTION FACILITY DESCRIPTION Section II OBSERVATIONS EcoStar Remodeling & Construction Inspection 03/27/2024 The inspectors and Mr. Tchernechovsky agreeed to hold a phone interview on April 2, 2024 at 2:00PM to complete the interview. During the meeting EPA inspectors requested 1) one year of addresses where RRP work was completed on pre-1978 residences 2) EcoStar's Lead Safe Firm Certification Number 3) List of subcontractors, contact information, and lead training certificates by April 12, 2024. After the meeting counsel for EcoStar has been in contact with EPA and an extension for the requested documents was granted. Section Ill - AREAS OF CONCERN No areas of concern were identified at the time of inspection. Additional information requested to demonstrate RRP compliance . Section IV - FOLLOW UP 1) one year of addresses where RRP work was completed on pre-1978 residences 2) EcoStar's Lead Safe Firm Certification Number 3) List of subcontractors, contact information, and lead training certificates Section V- LIST OF APPENDICES Appendix 1- NOi Appendix 2 - Inspection Checklist 3 EcoStar Remodeling & Construction Inspection 03/27/2024 Appendix 1 Notice of Inspection 4 ~SEPA I 1 t btJl1\: United Stotes ENVIRONrvH:NTAL PROTECTION AGENCY .,con~,..,.~.. ~ Fu,,. 1 r:, - ------- Washington, DC 20460 Notice of Inspection Office of Enforcement and Compliance Assurance -, ] . Investigation Identification J . Facility Name il Inspection Number Daily Seq.NUmbe, L "_,w-- 4 - ~ ~ rcr~ I !:I i 11 1 I 2.lnspector's Address 4. Facility Address ~ il f)..01 tf'U1,r I f/f/CJ c.~ / T}Z;( I ~ ;~ '1'//7, ) fK 75':u:r::1 vtl A-, J9'c:7 Jz.{c-,//4 J ~ 752.Y-iJ -- !"c<lote,;;;jEPAUse. Copies may be provided to the recipient a$ acknowledgment of this nqtice. -l ,-- -- 1 Reason for Inspection unde1 the authority of Section 11 of the Toxic Substances Cont1ol Act 1 I 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 ! n;.d'f)ufilctured, processed, stored or held before or after their distribution in com merce (including records, files, papers, lr7Processes, control and facilities) and any conveyances being used to transport chemical substance, mixtures 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 t o the chemical substances, mixtures or articles, within, or associated with, such premise or conveyance have been complied with. C In addition, this inspection extends to (check appropriate blocks): D A. Financial Data n B. Sales Data O C. Pricing Data O D. Personnel Data rJ E. Research Datil 1-Sa-ve F-or-m -,I [ PrintFornr 1 I IIISJil'Ctor ( opy ; f.:dlity ( ,;1 EcoStar Remodeling & Construction Inspection 03/27/2024 Appendix 2 Inspection Checklist 5 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 EPA Inspector Name EPA Inspector Telephone EPA Inspector Email Inspection Date Inspection Type: Inspection Location Company Name Address Contact Name Contact Teleohone Contact Email Manae:er Name Manae:er Telephone Manae:er Email EPA Firm Certification Number Inspection Checklist ~ Crh. ~ /-#1 rJ".. $'k., I A-n-t,J/ l4.. I I ~ , 3 I ..21 / ef1. Y I r 't?l/2? c/i/2 I e.- e_ r,'f J'C&P 57A-/L,. Firm !"formation V ~co ST!t~ JsJLJo C.OT, R D -ii 3c/c, 'Della,:; 7 5Z'-I 0 211---/ ~12 533/ e:.-C.o-5 ~ ., ~- 1 r ;,,,. da//479 r' o ,,..,,., -,, A I I I "-'<- J tr.lf&'fl__r!J5f1Jfc>V5i! V tl 8/'?f -30& - 'ifO 2- / J, ~., J.v1P I -r 2'%C/2 t:J, t:lm/1.; I J ~l,'J / /1/2/11 Introduction & Puroose Permission to enter granted Permission to enter document signed Facility/operator provided copy of entry document Copy o f Lead Base Paint Pamphlet provided Y - N-N/A Comments The items identified in this inspection have the potential to incur c ivil penalties in the amount identified. Yo ur firm has 90 days in which to submit proof that the items identified have been corrected. These deficiencies are of a serious nature and if left uncorrected could result in formal enforcement action. Your response should be submitted to: Copy of inspection checklist and on-site report sent to: Print Name: _ _ _ _ _ _ _ _ __ Date Email: - - -- - - - - -- - - Page 1 of6 Facility/Company Name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ ft 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 # Re2Ref Question l 40 CFR 745.87(c) Did the company permit entry for inspection? Comments 2 40 CFR 745.87(c) Did the company provide requested information and/or records during or after the inspection? Comments 3 40 CFR 745.87(c) rs this company a licensed real estate brokerage firm? If so, provide state licensing number in comments. Comments 4 40 CFR 745.87(c) Does this company manage target housing? Comments 5 40 CFR 745.87(c) How many target housing properties does this company manage? Comments 6 40 CFR &745.87(c) Are children under the age of 6 years living in any of these prooerties? Comments 7 40 CFR 745.87(c) Are pre!!Ilant women living in these properties? Comments 8 40 CFR 745.87(c) Has renovation/repair/painting work been performed on these properties? Comments 9 40 CFR 745.87(c) Which properties had RRP work performed and when? See List Comments 10 40 C.F.R. Did the renovator or property manager provide the owner of the unit with 745.84(a)(l) the EPA-approved lead hazard information pamphlet? Comments 11 40 C.F.R. Did the renovator or property manager provide the adult occupant of the 745.84(a)(2) unit (if not the owner) with the EPA-approved lead hazard information pamphlet? Comments 12 40 C.F.R. In Common Areas, did the renovator or property manager provide the 745.84(b)(l) owner of the multi-family housing with the EPA-approved lead hazard information/pamphlet orto post informational si!ms? Comments 13 40 C.F.R. In Common Areas, did the renovator or property manager notify in 745.84(b)(2) writing, or ensure written notification of, each unit ofthe multi-family housing and make the pamphlet available upon request prior to the start of the renovation, or to post informational si!ms? Comments 14 40C.F.R. In renovation in Child-Occupied Facilities, did the renovator or property 745.84(c)(1 )(r) manager provide the owner of the building in which the child-occupied facility is located with the EPA-approved lead hazard information pamphlet? Comments Y-N-N/A Page 2 of 6 Facility/Company Name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ ft 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 15 40 C.F.R. 745.84(c)( I)(i1) In renovation in Child-Occupied Facility, did the renovator or property 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 40C.f.R. In renovation in a Child-Occupied Facility did the renovator or property 745.84(c)(2) manager provide the parents and/or guardians of children using the child- occupied facility with the pamphlet and information describing the general nature and locations ofthe renovation and the anticipated completion date, by mailing or hand-delivering the pamphlet and renovation information, or by posting informational signs describing the general nature and locations ofthe renovation and the anticipated completion date, posted in areas where they can be seen by parents or guardians ofthe children frequenting the child-occupied facility, and accompanied by a posted copy ofthe pamphlet or information on how interested parents or guardians can review a copy of the pamphlet or obtain a copy from the renovation firm at no cost to the parents or guardians? Comments 17 40 C.F.R. 745.85 For all renovations, did the renovator or property management firm post (1). signs clearly defining the work area and warning occupants and other 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 18 40 CFR 745.84(a)( 1) ( i ) Did the firm establish and maintain records and make those records available during the inspection? Comments 19 40 CFR 745.84(a)( l )(i) Did the firm receive written acknowledgement from the owner for receipt of a lead education pamphlet? Comments 20 40 CFR 745.84(a)(2)(i) Did the firm receive written acknowledgement from an adult occupant, of/for a lead education pamohlet? Comments 21 40 C.F.R. 745.84(a)(2) Did the firm provide the adult occupant of the unit (if not the owner) with the EPA-aooroved lead hazard information pamphlet? Comments 22 40 C.F.R. 745.84(b)( l) Did the renovator provide the owner ofthe multi-family housing with the EPA-approved lead hazard infonnation/pamphlet or to post informational signs? Comments Page 3 of 6 Facility/Company Name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ ft 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 23 40 C.F.R. Did the renovator notify in writing, or ensure written notification of, each 745.84(b)(2) unit ofthe multi-family housing and make the pamphlet available upon request prior to the start of the renovation, or to post informational signs? Comments 24 40 C.F.R. Did the renovator provide the owner of the building in which the child- 745.84(c)( I)(z) occupied facility is located with the EPA-approved lead hazard information pamphlet? Comments 25 40 C.F.R. Did the renovator or owner provide an adult representative ofthe child- 745.84(c)(I )(ii) occupied facility with the pamphlet, if the owner is not the operator ofthe child-occupied facility? Comments 26 40 C.F.R. Did the renovator or owner provide the parents and/or guardians of 745.84(c)(2) children using the child-occupied facility with the pamphlet and information describing the general nature and locations ofthe renovation and the anticipated completion date, by mailing or hand-delivering the pamphlet and renovation information, or by posting informational signs describing the general nature and locations of the renovation and the anticipated completion date, posted in areas where they can be seen by parents or guardians of the children frequenting the child-occupied facility, and accompanied by a posted copy ofthe pamphlet or information on how interested parents or guardians can review a copy of the pamphlet or obtain a copy from the renovation firm at no cost to the parents or guardians? Comments 27 40 C.F.R. 745.85 (1) Did the renovator or property management firms 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 cleaning verification have been completed? Comments 28 40C.F.R. During the renovation did the renovator obtain, from the owner, a written 745.84(a)( I) acknowledgment that the owner has received the pamphlet, pursuant to 40 C.F.R. 745.84(a)(])(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 renovator obtain, from the adult occupant, a 745.84(a)(2) written acknowledgment that the adult occupant has received the pamphlet, pursuant to 40 C.F.R. 745.84(a)(2)(i) or failure to obtain a certificate of mailing at least 7 days prior to the renovation? Comments Page 4 of 6 Facility/Company Name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ .. ft 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 30 40 C.F.R. 745.84(b)(l)(i) During the renovation in Common Areas, did the renovator obtain, from the owner, a written acknowledgment that the owner had received the 40C.F.R. 745.84(b)(1) pamphlet, or that infonnation signs had been posted, or they had obtained a certificate of mailing,at least 7 days prior to the renovation? Comments 31 40 C.F.R. During the renovation in Common Areas, did the renovator prepare, sign, 745.84(b)(3) and date a statement describing the steps performed to notify all occupants of the intended renovation activities and offer to provide the oamohlet? Comments 32 40 C.F.R. During the renovation in Common Areas, did the renovator notify, in 74S.84(b)(4) writing, the owners and occupants ofthe scope, locations or expected starting and ending dates ofthe 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-Occupied Facility, did the renovator obtain, 745.84(c)(1 )(i) 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 Facility, did the renovator obtain 745.84(c)( 1)(ii) from an adult representative of the child-occupied facility, ifthe operator ofthe child-occupied facility is not the owner of the building, a written acknowledgment that the operator had received the pamphlet, or obtained a certificate of mailing at least 7 days prior to beginning the renovation? Comments 35 40 C.F.R. 74S.84(c)(3) During renovation in Child-Occupied Facility, did the renovator prepare, sign and date a statement describing the steps performed to notify all parents and guardians ofthe intended renovation activities and to provide the pamphlet? Comments 36 40 C.F.R. 74S.84(d)(I) During all renovations, did the renovator include a statement recording the owner or occupant's name and acknowledgement of receipt ofthe pamphlet prior to the start ofthe renovation, the address of the unit undergoing renovation, the signature of the owner or occupant as applicable, and the date ofsignature? Comments 37 40 C.F.R. During all renovations, did the renovator provide written 74S.84(d)(2) and (3) acknowledgment of receipt of the pamphlet on either a separate sheet or as part ofany 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? Page 5 of 6 Facility/Company Name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ .. ft 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 Comments 38 40 C.F.R. 745.86 During all Renovations, did the renovator or property manager retain all records necessary to demonstrate compliance with the residential property renovation for a period of 3 years following completion of the renovation activities? Comments 39 40 C.F.R. 745.225 During all Renovations, did the renovator, or property manager (i) implement a program to maintain and make available to EPA upon request, records for a period of3 years and 6 months? Comments 40 40 C.F.R 745.225, In Target Housing and Child-occupied Facilities, did the owner, 745.226, 745.227, renovator, or property manager establish, maintain, provide, copy, or pennit access to records or reports? 40 C.F.R. 745.235 (b) Comments Target Housing Major= one or more occupants under age 6 and/or pregnant woman Significant= no information about age of the youngest occupant, or one or more occupants between ages of 6 and 17 Minor= no occupants under age 18 Child Occupied Facility Major= one or more occupants under age 6 (by definition, a child-occupied facility is regularly visited by one or more children under 6) Minor= renovation activities were completed during a period when children did not access the facility (e.g., as summer vacation) and there is no continuity of enrollment (i.e., the same children are not returning after the break). Page 6 of 6 Facility/Company Name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __