ON OR ABOUT 9/21/92, AN AUTHORIZED EPA INSPECTOR CONDUCTED AN INSPECTION TO DETERMINE COMPLIANCE WITH AHERA AND ITS IMPLEMENTING REGULATIONS. INSPECTOR OBSERVED THAT RESPONDENT FAILED TO PROPERLY INSPECT EACH SCHOOL BUILDING WHICH LEA OWNS.RESPONDENT WAS INDICTED ON 6 COUNTS COUNTS 1 & 2 RESPONDENT FAILED TO PROPERLY IDENTIFY AND INSPECT THE FOLLOWING HOMOGENOUS AREAS: HIGH SCHOOL & ELEMENTARY SCHOOL BUILDINGS. COUNTS 3 & 4 RESPONDENT FAILED TO COLLECT AND SUBMIT FOR ANALYSIS, BULK SAMPLESOF MATERIAL. COUNTS 5 & 6 RESPONDENT FAILED TO PROPERLY DEVELOP, ESTABLISH, INCLUDE AND MAINTAIN ALL REQUIRED INFORMATION IN THE 2 MANAGEMENT PLANS. UNADJUSTED TOTAL PROPOSED PENALTY $78,000. ADJUSTED TOTAL PROPOSED PENALTY $50,000.