ON OR ABOUT 2/4/93, AN AUTHORIZED EPA INSPECTOR CONDUCTED AN INSPECTION TO DETERMINE COMPLIANCE WITH AHERA AND ITS IMPLEMENTING REGULATIONS. RESPONDENT WAS INDICTED ON 3 COUNTS COUNT 1 RESPONDENT FAILED TO PROPERLY INSPECT ALL BUILDINGS IN THE LEA. COUNT 2 RESPONDENT FAILED TO COLLECT AND SAMPLE FOR ANALYSIS, BULK SAMPLES OF SUCH MATERIALS. COUNT 3 RESPONDENT FAILED TO DEVELOP, ESTABLISH, INCLUDE AND MAIN- TAIN ALL REQUIRED INFORMATION IN THE MANAGEMENT PLAN. UNADJUSTED TOTAL PROPOSED PENALTY $39,000 ADJUSTED PROPOSED PENALTY$25,000