Respondent, an EPA-accredited training program, failed to conduct a Renovation, Repair, and Painting (RRP) Rule Renovator Initial course as specified under the Rule. The training program failed to meet minimum training hour requirements and failed to teach all of the elements required for the hands-on portion of the course. Respondent did not teach proper use of lead test kits, interior cleaning following a renovation, and visual inspection procedures to ensure proper cleaning of renovation work areas. EPA is seeking a penalty, a Supplemental Environmental Project (SEP), and full compliance with regulatory requirements in all future RRP training courses. Under the SEP, the Respondent will offer tuition free RRP training to contractors in Hurricane Sandy impacted areas.