1.Violation ofTSCA Section 409, 40 C.F.R. 745.87(a) and RRP Rule firm certification requirements of 40 C.F.R. 745.89 -failure to have and maintain a lead-safe firm certification from EPA, in accordance with the firm certification requirements of 40 C.F.R. 745.89, at times when Respondent continued to perform target housing renovations for compensation in target housing or child occupied facilities that did not qualify for any of the exceptions identified in 40 C.F.R. 745.82(a) or (c).
2.16 violations of TSCA Section 409, 40 C.F.R. 745.87(a) and RRP Rule requirement of 40 C.F.R. 745.84(a)(l) - failure to comply with an applicable 40 C.F.R. ? 745.Sl(a)(l)(i) or (ii) requirement, by and through Respondent's failure to obtain from each of 16 target housing residential dwelling property owners a written acknowledgment that they had each timely received the required EPA-approved lead hazard information pamphlet.
3.17 violations of TSCA Section 409, 40 C.F.R. 745.87(a) and RRP Rule requirement of 40 C.F.R. 745.86(b)(6) - failure to retain and provide to EPA, upon request, those records required to document compliance with the work practice standards of 40 C.F.R. 745.85 during the course of 17 target housing residential dwelling property renovations