A contractor begins work on a 1968 Oregon home renovation without RRP certification. The homeowner files a complaint. What is the maximum EPA penalty for the first violation?
Correct Answer
A) $37,500
EPA can assess penalties up to $37,500 per day for RRP violations. First-time violations typically result in significant fines even without ongoing daily penalties.
Why This Is the Correct Answer
The EPA's Renovation, Repair, and Painting (RRP) Rule allows civil penalties of up to $37,500 per day per violation for non-compliance. For a first violation, $37,500 is the published maximum penalty per day. Homes built before 1978 require RRP-certified firms and renovators due to the risk of lead-based paint disturbance.
Why the Other Options Are Wrong
Option B: $16,000
$16,000 does not correspond to the current EPA RRP penalty maximum. This figure may reflect an outdated penalty schedule or be confused with another environmental regulation. The EPA updated its civil penalty authority, and the current maximum is $37,500 per day.
Option C: $50,000
$50,000 exceeds the RRP-specific daily maximum. While some EPA enforcement actions under other statutes (such as TSCA Section 16) can reach $50,000+, the RRP rule's per-day maximum civil penalty is $37,500.
Option D: $21,000
$21,000 does not match any standard EPA penalty tier for RRP violations. It may appear plausible as a 'middle ground' number but has no statutory basis in the RRP penalty schedule.
Memory Technique
Associate $37,500 with RRP: '37.5 thousand reasons to get certified before touching old paint.' The year 1978 is the RRP cutoff — any home older than 1978 triggers the rule, so a 1968 home is clearly covered.
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A subcontractor completes electrical work on February 15th. The general contractor stops all work on March 1st due to weather, then resumes April 10th and finishes the project May 20th. Under ORS 87, the subcontractor's lien filing deadline is: