IN 1988 RESPONDENT PREPARED A MANAGEMENT PLAN FOR THE LEA. ON OR ABOUT 10/07/91 EPA CONDUCTED AN INSPECTION AT THE BEAVER COUNTY SCHOOL DISTRICT TO DETERMINE IF COMPLIANCE HAD BEEN IMPLEMENTED FOR 40 C.F.R. PART 763 SUBPART E. IT WAS OBSERVED THAT THE RESPONDENT FAILED TO PROPERLY IDENTIFY ONE OF THE 4 TPES OF 12 X 12 INCH GLUED CEILING TILE LOCATED IN THE BELKNAP ELEMENTARY SCHOOL DISTRICT. REPONSDENTS FAILURE TO PROPERLY COMPLETE THE REQUIRED MANAGEMENT PLAN CONSTITUTES A VIOLATION OF SECTION 15 OF TSCA TOTAL PROPOSED PENALTY IS $60,000 ADJUSTED FINAL PENALTY IS $25,000.