DURING A COMPLIANCE INSPECTION CONDUCTED MAY 9-10, 1991, JOAN THALMANN AND AUTHORIZED EPA INSPECTOR OBSERVED THAT RESPONDENT, AN AUTHORIZED ASBESTOS CONTRACTOR, 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. THIS IS A THREE COUNT COMPLAINT WITH A PROPOSED CIVIL PENALTY IN THE AMOUNT OF $39,000. AS DIRECTED BY GUIDELINES IN THE ENFORCEMENT RESPONSE POLICY, THE PROPOSED TOTAL CIVIL PENALTY IS REDUCED TO $25,000 PER DAY. THE PENALTY PROPOSED IS BASED ON ONE DAY OF VIOLATION FOR THE SCHOOL.