Respondent failed to provide owner of the building with a lead hazard information pamphlet, failed to close windows and doors in the work area and/or cover doors with plastic sheeting or other impermeable material; failed to contain waste from renovation activities; and failed to assign a certified renovator. EPA is seeking a penalty and the company's return to compliance. Initial proposed penalty was calculated at $19,340. However, Respondent demonstrated an inability to pay the proposed penalty and qualified for a substantially reduced penalty under the Agency's Graduated Penalty Approach pilot policy. Respondent has agreed to and submitted a plan for monitoring its compliance with the RRP Rule.