~~~~~~~~

UNITED
STATES
ENVIRONMENTAL
PROTECTIONAqPPT
p4::
JC
REGION
111
1650
Arch
Street
~~~~

Philadelphia,
Pennsylvania
19103­
2029
057
3
i
hip!
 
13:
263
Mr.
Richard
Brewster,
Program
Manager
Lead
Program
Prevention
Division
DC
Environmental
Health
Administration
825
North
Capitol
St.,
NE
5th
Floor
Washington,
DC
20062
Dear
Mr.
Brewster,

I
received
a
letter
from
the
District,
dated
June
1,
1999,
that
pertains
to
the
District s
application
for
State
Lead
Program
Authorization
but
appears
to
be
missing
most
of
its
attachments.
The
Table
of
Contents
were
included,
as
were
Appendices
B
and
M,
but
that
is
all
that
was
attached
to
the
letter.
Also,
the
last
page
of
the
letter
appears
to
be
missing.
Our
version
ends
with
a
response
to
Item
11
but
includes
no
signature.
Wouldyou
please
have
these
sent
immediately?

Based
upon
reviewing
the
material
that
we
did
receive,
listed
below
are
some
questions
and
comments.

1E.
Enforcement
Rmources
­
Please
indicate,
on
page
12,
the
Division
in
which
each
individual
works.
DC
responded
that
five
individuals
are
located
in
the
Lead
Poisoning
Prevention
Division
but
did
not
show
where
the
other
two
individuals
are
located,
nor
which
ones
work
in
LPPD.

Is
the
only
document
now
to
be
included
in
Appendix
E
to
be
the
organizationalchart?
The
Organization
Order
dated
11/
6/
98is
not
included
in
the
District s
response.

5.
Third
Paw
Exam
­
Please
describe
the
alternate
procedures
that
we
underway
for
certification
based
on
prior
training.

Part
of
running
an
authorized
State
Lead
Program
includes
administering
a
third
party
exam.
When
the
District
self­
certified
last
August,
thisimplied
that
the
District
was
running
a
full
program,
which
includes
administering
a
third
party
exam
for
inspectors,
supervisors,
and
risk
assessors.
Whether
issuance
of
the
exam
is
included
as
a
specific
grant
deliverable
is
not
pertinent.

Why
have
no
requests
been
received
for
taking
the
exam?
Please
provide
a
list
of
individuals
that
are
certified
in
the
District
for
conduct
of
lead­
based
paint
activities.

CustomerService
Hotline:
1­
800­
438­
2474
1
If
no
individuals
have
taken
the
third
party
exam
in
the
District,
who
is
supervising
abatements
and
performing
inspections
and
risk
assessments
in
the
District?
What
compliance
monitoring
activities
are
underway
in
the
District
to
ensure
that
these
LBP
activities
are
not
underway
without
adequate
certification?

6.
CertiJicatiunofIndividuals
­
The
March
15
letter
fbm
the
District
was
not
fully
responsive.
Please
see
EPA s
letter
to
the
District,
dated
May
20,
1999.
(
A
copy
is
enclosed
with
this
letter.)

Please
call
me
when
you
receive
this
letter
to
discuss
how
the
District
intends
to
respond.
We
also
should
begin
to
discuss
prospects
and
procedures
for
Interim
Authorization
to
the
District
as
a
means
of
addressing
EPA s
enforcement­
related
concerns.

Thank
you.

cc.
G.
Amisial
S.
Arnold
P.
Cestone
M.
Coe
A.
Dickens
D.
Gal10
J.
Sofield
enclosure
(
1)
Sincerely,

/.
9
Gerallyn
Valls
U
Region
111Lead
Program
Coordinator
