FAILURE TO IDENTIFY A HOMOGENEOUS AREA OF SUSPECTED ACBM; FAILURE TO ASSUME A HOMOGENEOUS AREA IS ACM AND FAILURE TO ADEQUATELY SAMPLE AND FAILURE TO INCLUDE A DESCRIPTION OF SUSPECTED ACBM IN THE MANAGEMENT PLAN FOR CONDRAY CHRISTIAN SCHOOL. THE PROPOSED PENALTY IS $13,000. TSCA DOCKET NO. VI-530C(A).