EPA CONDUCTED A RE-INSPECTION AT THE REQUEST OF BRENT KUMMER TO DETERMINE COMPLIANCE WITH AHERA AND ITS IMPLEMEN- TING REGULATIONS. 15 COUNTS WERE ALLEGED VIOLATIONS COUNTS 1-7: RESPONDENT FAILED TO IDENTIFY ALL HOMOGENOUS AREAS OF SUSPECT ACBM IN THE LEA. COUNTS 8-14: RESPONDENT FAILED TO PROPERLY ASSUME/SAMPLE CERTAIN SUSPECT ACBM. COUNT 15: RESPONDENT FAILED TO DEVELOP, ESTABLISH, INCLUDE AND MAIN- TAIN ALL REQUIRED INFORMATION IN THE MANAGEMENT PLAN. PROPOSED CIVIL PENALTY $129,000 ADJUSTED TOTAL PROPOSED PENALTY $50,000.