THIS IS A THREE COUNT COMPLAINT AND NOTICE OF OPPORTUNITY FOR HEARING BASED ON THE FOLLOWING: FAILURE TO PROPERLY INSPECT TWO SCHOOL BUILDINGS BY FAILING TO INSPECT FOR AND TO IDENTIFY ALL LOCATIONS OF SUSPECT FRIABLE ACBM AND NONFRIABLE ACBM. FAILURE TO ASSUME THAT SOME OR ALL OF CERTAIN SUSPECT MATERIALS IN THE SCHOOL BUILDINGS ARE ACBM A AND IN EACH HOMOGENEOUS AREA WHERE SUSPECT ACBM IS NOT ASSUMED TO BE ACBM, FAILURE TO COLLECT AND SUBMIT FOR ANALYSIS BULK SAMPLES OF SUCH MATERIAL. FAILURE TO PROPERLY DEVELOP, ESTABLISH, INCLUDE AND MAINTAIN ALL REQUIRED INFORMATION FOR THE LEA IN THE MANAGEMENT PLAN. THE PROPOSED CIVIL PENALTY IS $39,000. AS DIRECTED BY GUIDELINES IN THE ENFORCEMENT RESPONSE POLICY, THE PROPOSED TOTAL CIVIL PENALTY IS REDUCED TO $25,000 PER DAY FOR EACH SCHOOL WHERE THE VIOLATIONS WERE FOUND.