FAILURE TO IDENTIFY ALL HOMOGENEOUS AREAS OF SUSPECTED ACBM, AND FAILURE TO ASSURE HOMOGENEOUS AREAS ARE ACM AND FAILURE TO COLLECT AN ADEQUATE NUMBER OF BULK SAMPLES FOR 3 SEPARATE SCHOOL BUILDINGS ON THE CAMPUS OF THE BARBARA GORDON MONTESSORI SCHOOL. EPA FILED AN ADMINISTRATIVE COMPLAINT SEEKING A $75,000 CIVIL PENALTY.