THIS IS AN 11 COUNT COMPLAINT BASED ON THE FOLLOWING VIOLATIONS: FAILURE TO PROPERLY INSPECT 5 SCHOOL BUILDINGS BY FAILING TO INSPECT FOR AND TO IDENTIFY ALL LOCATIONS OF SUSPECT FRIABLE ACBM AND NONFRIABLE ACBM; FAILURE TO ASSUME THAT SOME OR ALL OF CERTAIN SUSPECT MATERIALS IN 5 SCHOOL BUILDINGS ARE ACBM AND IN EACH HOMOGENOUS AREA WHERE SUSPECT ACBM IS NOT ASSUMED TO BE ACBM, FAILURE TO COLLECT AND SUBMIT FOR ANALYSIS BULK SAMPLES OR SUCH MATERIAL. THE PROPOSED CIVIL PENALTY IS $25,000.