EPA v. GREP SOUTHEAST, LLC (GREYSTAR PROPERTIES)

Case summary

9/23/2025 - CONSENT AGREEMENT AND FINAL ORDER ISSUED ASSESSING A PENALTY OF $140,200.00 TO BE PAID IN 30 DAYS AFTER THE EFFECTIVE DATE OF THIS CAFO. ALLEGED VIOLATIONS: ON JULY 26, 2022, AN INSPECTOR WITH THE EPA CONDUCTED AN INSPECTION AT RESPONDENT?S PLACE OF BUSINESS LOCATED AT 521 EAST MOREHEAD STREET, SUITE 400, CHARLOTTE, NORTH CAROLINA, AS AUTHORIZED UNDER SECTION 11 OF TSCA, 15 U.S.C. ? 2610. DURING THE INSPECTION, THE INSPECTOR REQUESTED THAT A REPRESENTATIVE OF RESPONDENT PROVIDE RECORDS FOR THE INSPECTOR?S REVIEW. THE REPRESENTATIVE ADVISED THAT HE WOULD CONFER WITH RESPONDENT?S MANAGEMENT AND THAT THE RECORDS WOULD BE PROVIDED AFTER THE INSPECTION. ON AUGUST 29, 2022, SEPTEMBER 16, 2022, OCTOBER 28, 2022, MARCH 6, 2023, AND MARCH 7, 2023, RESPONDENT SUBMITTED VARIOUS ELECTRONIC RECORDS TO THE EPA VIA EMAIL WHICH WERE REVIEWED TO EVALUATE RESPONDENT?S COMPLIANCE WITH 40 C.F.R. PART 745, SUBPARTS E AND F. BASED ON THE EPA?S REVIEW OF THE RECORDS SUBMITTED BY RESPONDENT, THE EPA ALLEGES THAT RESPONDENT, IN ITS CAPACITY AS AN AGENT CONCERNING THE LEASING OF TARGET HOUSING DESCRIBED IN PARAGRAPH 30 OF THIS CAFO, FAILED TO: A. INCLUDE IN THE CONTRACTS FOR LEASE, A STATEMENT BY THE LESSEE AFFIRMING RECEIPT OF THE INFORMATION REQUIRED UNDER 40 C.F.R. ?? 745.113(B)(2) AND 745.113(B)(3), AND THE LEAD HAZARD INFORMATION PAMPHLET REQUIRED BY 15 U.S.C. ? 2686, IN VIOLATION OF 40 C.F.R. ? 745.113(B)(4); AND B. INCLUDE AS AN ATTACHMENT OR WITHIN THE CONTRACT TO LEASE TARGET HOUSING A STATEMENT BY THE AGENT INVOLVED IN THE TRANSACTION TO LEASE TARGET HOUSING THAT THE AGENT HAD INFORMED THE LESSOR OF THE LESSOR?S OBLIGATIONS, AND THAT THE AGENT WAS AWARE OF ITS DUTY TO ENSURE COMPLIANCE, IN VIOLATION OF 40 C.F.R. ? 745.113(B)(5). BASED ON THE EPA?S REVIEW OF RESPONDENT?S RECORDS, THE EPA ALLEGES THAT PRIOR TO THE TIME RESPONDENT PERFORMED RENOVATIONS AT THE PROPERTIES, RESPONDENT FAILED TO: A. APPLY TO THE EPA AND OBTAIN FIRM CERTIFICATION TO PERFORM, OFFER, OR CLAIM TO PERFORM RENOVATIONS FOR COMPENSATION, IN VIOLATION OF 40 C.F.R. ?? 745.81(A)(2)(II) AND 745.89(A)(1); B. PROVIDE THE OWNER OR ADULT OCCUPANT OF THE UNIT WITH THE EPA-APPROVED PAMPHLET, IN VIOLATION OF 40 C.F.R. ? 745.84(A)(1); AND C. ENSURE THAT ALL INDIVIDUALS PERFORMING RENOVATION ACTIVITIES ON BEHALF OF THE FIRM WERE EITHER CERTIFIED RENOVATORS OR WERE TRAINED BY A CERTIFIED RENOVATOR, IN ACCORDANCE WITH 40 C.F.R. ? 745.90 WITH RESPECT TO RENOVATIONS AT THE PROPERTIES LISTED IN PARAGRAPH 32.A ? K, IN VIOLATION OF 40 C.F.R. ? 745.89(D)(1).

Defendants (1)

• GREP SOUTHEAST, LLCNamed in complaintNamed in settlement

Facilities (10)

• GREYSTAR PROPERTIES/GREP SOUTHEAST, LLC (BAY COVE CLEARWATER-TARGET HOUSING)

  19135 US. HIGHWAY 19 NORTH, UNITS #A12 & F09, CLEARWATER, FL, 33764

  Registry ID: 110072071763

• GREYSTAR PROPERTIES/GREP SOUTHEAST, LLC (MARIETTA CROSSING-TARGET HOUSING)

  4414 HIGHLAND PARC PLACE SE, MARIETTA, GA, 30067

  Registry ID: 110072071760

• GREYSTAR PROPERTIES/GREP SOUTHEAST, LLC (AVANA CUMBERLAND-TARGET HOUSING)

  2383 AKERS MILL ROAD, UNITS #D04 & #T09, ATLANTA, GA, 30339

  Registry ID: 110072071626

• GREYSTAR PROPERTIES/GREP SOUTHEAST, LLC (CARLYLE OF SANDY SPRING-TARGET HOUSING)

  1912 SANDALWOOD DRIVE, ATLANTA, GA, 30350

  Registry ID: 110072071628

• GREYSTAR PROPERTIES/GREP SOUTHEAST, LLC (THE LAURELS-TARGET HOUSING)

  2346 WINKLER AVENUE, UNITS #J107 & F202, FORT MYERS, FL, 33901

  Registry ID: 110072071762

• GREYSTAR PROPERTIES/GREP SOUTHEAST, LLC (CAMERON COURT-TARGET HOUSING)

  804 WEST MORGAN STREET, UNITS R3B & E3B, RALEIGH, NC, 27603

  Registry ID: 110072071624

• GREYSTAR PROPERTIES/GREP SOUTHEAST, LLC

  521 EAST MOREHEAD STREET, SUITE 400, CHARLOTTE, NC, 28202

  Registry ID: 110071316504

• GREYSTAR PROPERTIES/GREP SOUTHEAST, LLC (LOFTS@WOODSIDE MILL APT-TARGET HOUSING)

  1 EAST MAIN STREET, UNIT #1453 & #1448, GREENVILLE, SC, 29611

  Registry ID: 110072071627

• GREYSTAR PROPERTIES/GREP SOUTHEAST, LLC (TARGET HOUSING)

  255 MONTGOMERY STREET, UNIT #0509, SAVANNAH, GA, 31401

  Registry ID: 110072071629

• GREYSTAR PROPERTIES/GREP SOUTHEAST, LLC (100 MIDTOWN-TARGET HOUSING)

  100 10TH STREET NW, APARTMENT 902-B, ATLANTA, GA, 30309

  Registry ID: 110072071761

Statutes cited

• TSCA 1018 — Lead: Disclosure
• TSCA 406B — Lead: Pre-Renovation Education Rule
• TSCA 402C — Lead: RRP

Enforcement conclusions (1)

• GREP SOUTHEAST, LLC (GREYSTAR PROPERTIES)entered 2025-09-23

  Primary law: TSCA

  Federal penalty: $140,200

Timeline (4 milestones)

• 2025-09-23Complaint Filed/Proposed Order
• 2025-09-23Final Order Issued
• 2025-09-24Enforcement Action Data Entered
• 2025-10-23Enforcement Action Closed