EACH OF THE 6 NAMED RENOVATIONS, RESPONDENT: (1)FAILED TO RETAIN RECORDS DOCUMENTING THAT THE CERTIFIED RENOVATOR PERFORMED OR DIRECTED WORKERS TO PERFORM THE WORK PRACTICE STANDARDS DESCRIBED IN 40 C.F.R. 745.85(a) AND (2) FAILED TO RETAIN RECORDS DOCUMENTING THAT THE CERTIFIED RENOVATOR PERFORMED THE POST-CLEANING CHECKLIST DESCRIBED IN 40 C.F.R. 745.85(b).