ON OR ABOUT 2/4/93, AN AUTHORIZED EPA INSPECTOR CONDUCTED AN INSPECTION TO DETERMINE COMPLIANCE WITH AHERA AND ITS IMPLEMENTING REGULATIONS. RESPONDENT WAS INDICTED ON 3 COUNTS. COUNT 1 RESPONDENT FAILED TO PROPERLY INSPECT 2 SCHOOL BUILDINGS AND TO INSPECT THOSE LOCATIONS FOR ACBM IN VIOLATION. COUNT 2 RESPONDENT FAILED TO PROPERLY COLLECT AND SUBMIT FOR ANALYSIS, BULK SAMPLES OF MATERIAL IN POSSIBLE VIOLATION. COUNT 3 RESPONDENT FAILED TO DEVELOP, ESTABLISH, INCLUDE AND MAIN- TAIN ALL REQUIRED INFORMATION IN THE MANAGEMENT PLAN. UNADJUSTED TOTAL PROPOSED PENALTY $39,000. ADJUSTED TOTAL PROPOSED PENALTY $25,000.