RESPONDENT FAILED TO COMPLY WITH THE REQUIREMENTS OF RENOVATION, REPAIR AND PAINTING (RRP) RULE BY FAILING TO OBTAIN INITIAL FIRM CERTIFICATION FROM EPA, POST SIGNS CLEARLY DEFINING THE WORK AREA, CLOSE AND COVER ALL DUCT OPENINGS IN THE WORK AREA WITH TAPED-DOWN PLASTIC SHEETING OR OTHER IMPERMEABLE MATERIAL, COVER THE GROUND WITH PLASTIC SHEETING OR OTHER IMPERMEABLE MATERIAL EXTENDING TEN FEET BEYOLND THE PERIMETER OF SURFACES UNDERGOING RENOVATION, AND CONTAIN WASTE FROM RENOVATION ACTIVITIES.