On April 18, 2018, EPA Region III filed a Consent Agreement and Final Order simultaneously commencing and concluding an administrative enforcement action against HBW Properties, Inc. (Respondent) for alleged violations of TSCA and EPA's RRP Rule in connection with a renovation at University Towers, two 15-story brick high rise condominium buildings in Silver Springs, Maryland. Respondent, a Maryland corporation that performs commercial and institutional building construction activities, was not a certified lead-safe firm. Respondent acted as general contractor, subcontracting with firms that also were not certified lead-safe firms, to perform renovation activities at University Towers. Alleged violations included failing to obtain a lead-safe firm certification and to use lead-certified renovators to perform the renovation activities, failing to provide the owner and occupants with an EPA-approved lead hazard pamphlet, failing to post warning signs, failing to comply with various lead dust containment work practice standards, employing restricted work practices and failing to retain records demonstrating compliance with lead safe work practices. Per the terms of the CAFO, Respondent will pay a civil penalty in the amount of $40,000. The Maryland Department of the Environment's Lead Poisoning Prevention Program was notified and did not object to this action.