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..

R
~~~~~~~~

UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
opp
c
1
C
REGION
111
1650
Arch
Street
~~~~

OCT
3
1
AH
9:
20
Philadelphia,
Pennsylvania
19103­
2029
Mr.
Richard
Brewster,
Program
Manager
Lead
Poisoning
Prevention
Division
. 
OCT
B
1888
Environmental
Health
Administration
51
North
Street
Washington,
DC
20002
Dear
Mr.
Brewster,

In
your
last
correspondence
to
me,
dated
July
6,
1999,
you
stated
that
you
would
provide,
at
the
end
of
July,
a
complete
response
to
my
June
16,
1999
letter
on
the
District s
application
for
TSCA
404
Program
authorization.
No
response
has
been
received
since
your
July
6
letter,
so
I
am
writing
to
remind
you
that
a
response
is
due
and
also
to
highlight
items
that
are
not
complete,
based
on
earlier
correspondence
from
EPA
to
the
District
and
the
materials
that
were
received
with
the
District s
June
and
July
submissions,

Items
Discussed
in
EPA
Mav
3.
1999
Lettec
1.
Enforcement
Resources
A&
B.
At
the
time
of
writing
thisletter,
I
understand
that
a
question
is
outstanding
about
whether
one
Compliance
Monitor
is
to
be
funded
fiom
the
EPA
HUD2
grant
and
another
Compliance
Monitor,
at
exact
same
salary,
is
to
be
funded
out
of
the
EPA
404(
g)
grant.
I
understand
that
deliverables
are
still
being
negotiated
under
the
 
Enforcement 
Program
Element
for
these
two
grants.
Please
confirm
that
the
figures
and
discussion
about
the
roles
and
sources
of
fhnding
that
are
set
forth
in
the
District s
June
1letter
are
still
correct
or
make
changes
as
appropriate.
Development
and
administrationof
audit
formsand
a
third
party
exam
is
typically
not
categorized
in
our
grants
as 
enforcement 
and
these
two
activities
are
not
listed
as 
enforcement 
activities
in
the
Guidancefor
Model
Lead­
Based
Paint
Compliance
and
Enforcement
Programs,
issued
by
EPA
Office
of
Enforcement
and
Compliance
Assurance.
Please
check
that
the
functions
are
listed
consistently
.
in
the
grant
applications
and
in
the
authorization
application.

Also,
please
include
in
Appendix
M
a
description
of
thejob
fimction
of
the
Compliance
Monitor.
Why
is
a
position
for
 
Lead
Inspector/
Industrial
Hygienist 
listed
in
Appendix
M
and
not
in
the
District s
June
1response
to
Item
lA?
c
E.
The
District s
July
response
indicates
that
five
individuals
listed
on
page
12
are
in
Lead
Poisoning
Prevention
Division.
Please
identiq
which
positions
these
are
and
also
identify
the
DivisiodOffice
where
the
othertwo
individuals
are
employed.
Seven
positions
are
listed
on
page
12.

CustomerService
Hotline:
1­
800­
438­
2474
If
the
process
for
determining
specific
enforcement
actions
to
be
taken
in
different
situations
is
documented
in
training
materials
that
are
developed
for
enforcement
officers,
please
provide
that.
Otherwise,
some
other
form
of
documentation
of
the
current
process
should
be
included
in
the
section
on
 
Follow
up
to
Inspection
Reports. 

3.
Trainingof
Inspection
and
Enforcement
Personnel
A.
Please
cross
reference
Appendix
L
on
page
35.

5.
nird
Party
Exam
If
no
one
has
requested
an
exam
as
is
stated
in
your
June
1response,
how
are
individuals
being
certified
in
DC?
Please
provide
a
list
of
individuals
who
have
been
certified
in
DC.
Also,
please
update
page
6,
Examination
Procedures,
with
a
complete
description
of
the
third
party
exam
process,
including
a
description
of
the
name
of
the
vendor
that
developed
the
exam
or
any
alternate
procedures
that
are
relevant,
the
District s
role
in
developing
the
exam
to
ensure
that
the
District s
regulations
are
adequately
addressed,
the
name
of
the
vendor
or
agency
that
administers
the
exam,
where
the
exam
is
offered,
at
what
frequency
the
exam
is
offered,
report
on
the
number
of
individuals
who
have
taken
the
exam
and
describe
processes
to
be
employed
to
keep
the
exam
current.

6.
Certzjkation
of
Individuals
and
Firms
Time
he
and
May
15
response.
Items
listed
in
EPA s
May
20
letter
are
still
outstanding.

11.
Notzj?
cation
­
July
response
(
see
page
28)
continues
to
use
the
phrase
 
lead
activity 
as
if
it
means
abatement
(
asdefined
in
DC s
rules).
However,
 
lead
activity 
also
may
include
inspections,
risk
assessments,
and
project
designing.
Unless
notifications
are
required
for
inspections,
risk
assessments,
and
project
designs,
it
appears
that
the
word
 
lead
activity 
should
be
changed
on
page
28.

Qther
Items
A.
Table
0fContent.
s­
Please
check
Appendix
titles
to
confirm
that
these
are
the
correct
titles.
For
example,
Appendix
N
is
entitled,
 
Civil
Infkaction
Flow
Chart 
on
the
Table
of
Contents,
yet
page
1
of
the
Appendix
itself
is
entitled,
 
Department
of
Health
Notice
of
Proposed
Rulemaking. 
A
title
that
describes
the
information
that
is
conveyed
in
each
appendix
and
that
matches
the
front
page
of
each
appendix
would
be
most
useful.

B.
Page
12,
paragraph
I
­
Is
this
paragaph
still
current
with
the
recent
reorganization?

C.
Page
23,
last
paragraph
­
Is
thisparagraph
still
current
withthe
recent
reorganization?

3
2
B
:,

8
Please
call
me
at
215­
814­
2084
to
establish
a
date
by
when
you
commit
to
providing
a
response
to
the
above
items.
EPA
Region
111is
very
concerned
about
the
length
of
time
that
the
District
has
taken
to
respond
t9
the
items
listed
above,
along
with
the
general
incompleteness
of
the
application
at
this
point
in
time.
All
future
revisions
should
be
marked
withthe
revision
date
in
the
upper
right
comer
of
each
page.

Thank
you.

cc.
S.
Arnold
2245A
M.
Coe
3RC30
A.
Dickens
3WC33
D.
Gallo
3WC33
J.
Sofield
3WC33
Sincerely,

Gerallyn
Valls
Region
111Lead
Program
Coordinator
3WC33
5
