1. Violation of TSCA Section 409 and RRP Rule requirement of 40 C.F.R. 745.81 (a)(2 (ii) - performance of a target housing renovation after April 22, 2010 without first obtaining the required initial lead-safe firm certification from EPA pursuant to 40 C.F.R. 745.89 requirements;
2. Violation of TSCA Section 409 and RRP Rule requirement of 40 C.F.R. 745.84(a)(i) failure to obtain from Target Housing Property owner a written acknowledgment of receipt of the required EPA-approved lead hazard information pamphlet entitled Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Schools ;
3. Violation of TSCA Section 409 and RRP Rule requirement of 40 C.F.R. 745.85(a)(1) - failure to post required lead work warning signs to warn occupants and other persons not involved in renovation activity to remain outside of the work area during the entire course of the renovation and post-renovation cleaning verification activities conducted by Respondent at the Target Housing Property; and
4. Violation ofTSCA Section 409 and RRP Rule requirement of 40 C.F.R. 745.86(b)(6 - failure to retain and provide to EPA, upon request, records that Respondent is required to maintain in order to document its compliance with the work practice standards of 40 C.F.R. 745.85, including documentation that a certified renovator perfomed or directed workers to perform tasks described by 40 C.F.R. 745.85(a) and followed the post-renovation cleaning verification standards descr