This is a civil administrative penalty action brought against Respondent pursuant to Section 16(a) of the Toxic Substances Control Act (TSCA), 15 U.S.C. Section 2615(a), for violation of Section 409 of TSCA, 15 U.S.C. Section 2689, for failing to comply with Sections 402 and 406 of TSCA, 15 U.S.C. Sections 2682 and 2686, and their implementing rules issued at 40 C.F.R. Part 745, Subpart E - Residential Property Renovation.