EPA v. PARTNERS MANAGEMENT LLC

Case summary

On May 7, 2003, EPA issued a Notice of Determination ( NOD ) pursuant to the Final Policy Statement on Incentives for Self-Policing: Discovery, Disclousre, Correction, and Prevention of Violations . The NOD resolves self-disclosures provided by Partners Management LLC ( Partners Management), for violations of Section 1018 of Title X of the Residential Lead-Based Paint Hazard Reduction Act of 1992 ( RLBPHRA ), 42 U.S.C. Section 4852d, Sections 16(a) and 409 of the Toxic Substances Control Act ( TSCA ), 15 U.S.C. Section 2615(a) and 2689, and 40 C.F.R. Part 745, Subpart F (also known as the Disclosure Rule ) at target housing, Seton Park apartments located at 3601 Parkview Avenue, Baltimore, Maryland and Henderson House apartments located at 101 E. Royal Avenue, Baltimore, Maryland 21202. Partners Mangement is a corporation with offices located at 105 W. Chesapeake Avenue, Towson, Maryland and has been the agent , as defined in 40 C.F.R. Section 745.103, for Seton Apartments Limited Partnership located at 105 West Chespeake Avenue, Towson, Maryland and Mount Royal Apartments Limited Partnershp located at 2850 N. Charles Street, Baltimore, Maryland, owners of Seton Park and Henderson House, respectively. Partners Management failed to make disclosures concerning lead-based paint to lessees of units qualifying as target housing, with regard to each of 320 lease transactions. Specifically, as an agent, Partners Management failed to ensure that a lessor had performed all activities required under 40 C.F.R. Section 745.107, .110 and .113. Partners Management found recordkeeping errors involving missing signatures, missing initials and missing dates and use of unapproved form. The total gravity-based civil penalty for these violations would be $35,200. Partners Management satisfied all of the conditions of EPA's Self-Disclosure Policy and the amount of economic benefit gained is insignificant. EPA waived the entire gravity-based civil penalty for the disclosed violations

Defendants (1)

• PARTNERS MANAGEMENT LLCNamed in complaintNamed in settlement

Facilities (2)

• SETON PARK

  3601 PARKVIEW AVE, BALTIMORE, MD, 21207

  Registry ID: 110015777435

• HENDERSON HOUSE

  101 E MT. ROYAL AVE, BALTIMORE, MD, 21202

  Registry ID: 110001831812

Statutes cited

• TSCA 406B — Lead: Pre-Renovation Education Rule

Enforcement conclusions (1)

• Partners Management LLCentered 2003-05-07

  Primary law: TSCA

Timeline (4 milestones)

• 2000-08-07Enforcement Action Data Entered
• 2003-05-07Final Order Issued
• 2003-05-07Enforcement Action Closed
• 2003-05-07Complaint Filed/Proposed Order