ON OR ABOUT 10/04/92 AN AUTHORIZED INSPECTOR FOR THE EPA CONDUCTED AN INSPECTION TO DETERMINE COMPLIANCE WITH AHERA AND ITS IMPLEMENTING REGULATIONS. THE INSPECTOR OBSERVED THAT THE RESPONDENT FAILED TO PROPERLY INSPECT EACH SCHOOL BUILDING, FAILED TO COLLECT AND SUBMIT FOR ANALYSIS BULK SAMPLES OF SUCH MATERIAL. INSPECTOR FURTHER NOTED THAT RESPONDENT FAILED TO PROPERLY DEVELOP, ESTABLISH INCLUDE AND MAINTAIN ALL REQUIRED INFORMATION IN THE MANAGE- MENT PLAN BY FAILING TO IDENTIFY ALL AREAS OF ACBM. THERE WERE 3 SEPARATE BUILDINGS TO BE INSPECTED AND EACH FAILURE TO COMPLY WITH EACH SCHOOL BUILDING CONSTITUTES A SEPARATE VIOLATION OF TSCA. COUNTS 1-3 RESPONDENT FAILED TO INSPECT FOR ALL LOCATIONS OF SUSPECT FRIABLE AND NONFRIABLE ACBM IN THE 3 SEPARATE BUILDINGS. COUNTS 4-6 RESPONDENTFAILED TO COLLECT AND SUBMIT FOR ANALYSIS BULK SAMPLES OF SUCH MATERIAL. COUNTS 7-9 RESPONDENT FAILED TO PROPERLY DEVELOP, ESTABLISH INCLUDE AND MAINTAIN ALL REQUIRED INFORMATION IN THE 3 MANAGEMENT PLANS. UNADJUSTED PROPOSED PENALTYTOTAL $159,000 ADJUSTED PROPOSED PENALTY $75,000