ONE OF THE COMPANY'S OWNERS, DAVID HANNEGAN, PROVIDED A WRITTEN STATEMENT TO EPA STATING THAT HE TESTS ALL PRE-1978 HOUSING UNITS FOR HIS COMPANY WORKS ON FOR LEAD. HE STATED THAT, AS OF THE DATE OF THE INSPECTION, HE HAD NOT HAD ANY OF THE RESIDENCES TEST POSITIVE FOR LEAD. ACCORDING TO HANNEGAN, IF THESE RESIDENCES HAD TESTED POSITIVE FOR LEAD, THE COMPANY WOULD HAVE FOLLOWED THE PROPER PROCEDURES. THE COMPANY DID NOT RETAIN THE RECORDS AND REPORTS OF THE TEN TEST RESULTS EXAMINED BY EPA IN THE INSPECTION, AS REQUIRED BY 40 CFR SECTION 745.86(B)(1). MANY OF THESE RESIDENCES WERE BUILT BEFORE 1960, ONE AS OLD AS 1900.