On October 12, 2010, Region 1 received a complaint regarding two workers using power equipment to remove paint from an exterior wall of a residential building without using any containment. As a result of an inspection and additional information provided by Respondent and other sources, Region 1 has determined that Respondent has violated Sections 15 and 409 of TSCA, the Residential Lead-Based Paint Hazard Reduction Act of 1992, and the RRP Rule, as set forth at 40 C.F.R. Part 745, Subpart E. Specifically, Region 1 has determined that Respondent failed to: (1) obtain initial certification as a renovation firm from EPA; (2) post warning signs in the work area; (3) cover the ground in the work area with plastic sheeting to collect falling paint debris; (4) contain waste from the renovation activities to prevent releases of dust and debris before the waste is removed from the work area for storage or disposal; (5) prohibit use of machines that remove lead-based paint through high speed operation without HEPA exhaust controls; and (6) establish and maintain records necessary to demonstrate compliance with the RRP Rule.