Respondent performed window replacement in Wynantskill, New York. After review of records and Respondent's answer to an EPA issued Information Request Letter, it was determined that Respondent had not retained necessary records and did not ensure that the aforementioned window replacement was performed in accordance with the lead-safe work practices as outlined in the federal regulations for residential renovation. In settlement of this matter, Respondent will implement additional business practices to avoid future non-compliance including implementation of a corporate compliance plan and pay a $24,300 penalty.