EPA v. ALEPH DAVIS, LLC d/b/a POINTER PAINTING

Case summary

SEPTEMBER 22, 2026 - CONSENT AGREEMENT On August 26, 2025, an EPA inspector conducted an inspection of Respondent?s worksite located at 3424 Woodmont Boulevard, Nashville, Tennessee 37215 (the Woodmont Property) to evaluate Respondent?s compliance. The Woodmont Property was constructed before 1978 and is ?target housing?. During the inspection at the Woodmont Property, the EPA inspector observed that Respondent had failed to cover the ground with plastic sheeting or other disposable impermeable material extending 10 feet beyond the perimeter of the surfaces undergoing renovation or a sufficient distance to collect falling paint debris, whichever is greater (and the property line did not prevent 10 feet of such ground covering), as required. On August 26, 2025, the EPA requested that Respondent provide records to the EPA inspector regarding its compliance. On October 23, 2025, Respondent submitted records to the EPA for review to evaluate its compliance with 40 C.F.R. Part 745, Subpart E for renovations conducted at the Woodmont Property and 8118 Devens Drive, Brentwood, Tennessee 37027 (the Devens Property). The Devens Property was constructed before 1978 and is ?target housing?. At the time of the inspection, and subsequent to the inspection, Respondent was unable to provide records to the inspector documenting that prior to performing renovation work at the Woodmont Property, Respondent had: a. Applied for and obtained ?firm certification? as required by 40 C.F.R. ?? 745.81(a)(2)(ii) and 745.89(a)(1); b. Provided the owner of the target housing with an EPA-approved pamphlet as required by 40 C.F.R. ? 745.84(a)(1); and c. Ensured that all individuals performing renovation activities on behalf of the firm were either certified renovators or had been trained by a certified renovator, as required by 40 C.F.R. ? 745.89(d)(1). Respondent was unable to provide records to the inspector documenting that prior to performing renovation work at the Devens Property, Respondent had provided the owner of the target housing with an EPA-approved pamphlet as required by 40 C.F.R.? 745.84(a)(1). Respondent consents to the payment of a civil penalty, which was calculated in accordance with the Act, in the amount of NINE THOUSAND, SEVEN HUNDRED DOLLARS ($9,700.00), which is to be paid within thirty (30) days of the Effective Date of this CAFO.

Defendants (1)

• ALEPH DAVIS, LLC d/b/a POINTER PAINTINGNamed in complaintNamed in settlement

Facilities (3)

• PRIVATE RESIDENCE

  8118 DEVENS DRIVE, BRENTWOOD, TN, 37027

  Registry ID: 110072293812

• PRIVATE RESIDENCE

  3424 WOODMONT BOULEVARD, NASHVILLE, TN, 37215

  Registry ID: 110072293811

• ALEPH DAVIS, LLC DBA POINTER PAINTING

  1122 STRATFORD AVENUE, NASHVILLE, TN, 37215

  Registry ID: 110072071755

Statutes cited

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

Enforcement conclusions (1)

• ALEPH DAVIS, LLC d/b/a POINTER PAINTINGentered 2026-09-22

  Primary law: TSCA

  Federal penalty: $9,700

Timeline (3 milestones)

• 2026-09-22Final Order Issued
• 2026-09-22Complaint Filed/Proposed Order
• 2026-10-01Enforcement Action Data Entered