EPA determined that the Respondent had: (1) performed a renovation subject to the RRP Rule without obtaining initial firm certification from EPA, (2) failed to establish and maintain records of compliance for the renovation conducted; and (3) failed to contain waste from renovation activities to prevent the release of dust and debris. The Respondent will pay a penalty of $20,000 and has agreed to amend business practices to prevent against the chance of future violations of the RRP Rule.