THIS IS A THREE COUNT COMPLAINT ISSUED FOR FAILURE TO PROPERLY INSPECT THE SCHOOL BUILDING BY FAILING TO INSPECT FOR AND IDENTIFY ALL LOCATIONS OF SUSPECT FRIABLE AND NONFRIABLE ACBM; FAILURE TO COLLECT AND SUBMIT FOR ANALYSIS BULK SAMPLES OF SUSPECT ACBM; FAILURE TO PROPERLY DEVELOP, ESTABLISH, INCLUDE AND MAINTAIN ALL REQUIRED INFORMATION IN THE MANAGEMENT PLAN. THE PROPOSED CIVIL PENALTY IS $25,000.