ON OR ABOUT JUNE 19, 1989, WINIFRED BROMLEY, AN AUTHORIZED INSPECTOR FOR THE EPA, CONDUCTED AN INSPECTION OF THE LEA. THE COMPLIANCE INSPECTION WAS CONDUCTED TO DETERMINE COMPLIANCE WITH AHERA AND ITS IMPLEMENTING REGULATIONS. DURING THE COMPLIANCE INSPECTION, IT WAS OBSERVED THAT RESPONDENT, FAILED TO PROPERLY INSPECT EACH SCHOOL BUILDING WHICH LEA OWNS, LEASES OR OTHERWISE USES AS A SCHOOL BUILDING, BY FAILING TO INSPECT FOR AND TO IDENTIFY ALL LOCATIONS OF SUSPECT FRIABLE AND NONFRIABLE ACBM. IT WAS FURTHER NOTED THAT RESPONDENT FAILED TO ASSUME THAT SOME OR ALL OF CERTAIN HOMOGENOUS AREAS OF SUSPECT ACBM IN EACH OF THE TWO SCHOOL BUILDINGS ARE ACBM AND FOR EACH HOMOGENOUS AREA OF SUSPECT ACBM THAT WAS NOT ASSUMED TO BE ACBM, THE RESPONDENT FAILED TO COLLECT AND SUBMIT FOR ANALYSIS BULK SAMPLES OF THE MATERIAL. THE PROPOSED CIVIL PENALTY FOR THE SIX COUNTS OF THIS COMPLAINT IS $25,000.