RESPONDENT REMOVED FRIABLE ASBESTOS WITHOUT PROPER ACCREDITATION. TSCA 206A REQUIRES THAT ASBESTOS WORKERS MUST BE ACCREDITED TO CONDUCT RESPONSE ACTIONS INVOLVING FRIABLE ASBESTOS-CONTAINING MATERIALS. THE COMPLAINT ALLEGED THAT MR. KUBIK HAD RECEIVED CERTIFICATION OF ANNUAL WORKER REFRESHER TRAINING IN COMPLIANCE WITH TSCA, BUT HAD NOT IN FACT ATTENDED SUCH TRAINING. THE COM- PLAINT FURTHER ALLEGED THAT MR. KUBIK HAD PARTICIPATED IN A RESPONSE ACTION INVOLVING FRIABLE ASBESTOS DURING THE TIME PERIOD COVERED BY THIS CERTIFICATE. MR. KUBIK SHOWED EVIDENCE OF EXTREMELY LIMITED ABILITY TO PAY, WHICH WAS A SIGNIFICANT FACTOR IN REDUCING THE ASSESSED PENALTY.