RESPONDENT FAILED TO PROPERLY DEVELOP, ESTABLISH, INCLUDE AND MAINTAIN ALL REQUIRED INFORMATION IN THE MANAGEMENT PLAN BY OMITTING RECORDS OF SUCH ASSUMPTION/SAMPLING FROM INCLUSION IN THE MANAGEMENT PLAN FOR THE SAMPLING PROCEDURES WHICH REQUIRE THAT BULK MATERIAL SAMPLES ARE TO BE OBTAINED IN A STATISTICALLY RANDOM MANNER AND ALSO FAILED TO INCLUDE THE NAME AND ADDRESS AND OTHER REQUIRED INFORMATION REGARDING THE LABORATORY PERFORMING THE BULK SAMPLE ANALYSIS ADJUSTED PROPOSED PENALTY - $20,000.