Q: Does the RRP Rule apply where no paint at all is present, such as in a 100 year old unfinished basement?

No.  The RRP Rule applies to activities that result in the disturbance of painted surfaces.  Where there is no paint to disturb, the RRP Rule does not apply. 

No.  The RRP Rule applies to activities that result in the disturbance of painted surfaces.  Where there is no paint to disturb, the RRP Rule does not apply.