ON OR ABOUT 9/22/93, AN AUTHORIZED EPA INSPECTOR CONDUCTED AN INSPECTION TO DETERMINE COMPLIANCE WITH AHERA AND ITS IMPLEMENTING REGULATIONS. THE RESPONDENT WAS INDICTED ON 3 COUNTS COUNT 1 RESPONDENT FAILED TO PROPERLY INSPECT ALL AREAS OF ACBM COUNT 2 RESPONDENT FAILED TO COLLECT AND SUBMIT FOR ANALYSIS BULK SAMPLES FOR EACH HOMOGENEOUS AREA WHERE THE SUSPECT MATERIAL WAS NOT ASSUMED TO BE ACBM. COUNT 3 RESPONDENT FAILED TO PROPERLY DEVELOP, ESTABLISH, INCLUDE AND MAINTAIN ALL REQUIRED INFORMATION IN THE MANAGEMENT PLAN TOTAL UNADJUSTED PROPOSED PENALTY $60,000 ADJUSTED PROPOSED TOTAL PENALTY $25,000