ON OR ABOUT 8/5/91 AN AUTHORIZED EPA INSPECTOR CONDUCTED AN INSPECTION TO DETERMINE COMPLIANCE WITH AHERA AND ITS IMPLEMENTING REGULATIONS. THE RESPONDENT WAS INDICTED ON 9 COUNTS COUNTS 1-4 RESPONDENT FAILED TO IDENTIFY ALL AREAS OF SUSPECTED ACBM-THERMAL SYSTEM INSULATION, VINYL FLOOR TILES, CEILING TILES AND DRYWALL IN MAIN BUILDING. COUNT 5-8 RESPONDENT FAILED TO COLLECT AND SUBMIT FOR ANALYSIS, BULK SAMPLES IN THE PREVIOUS 4 AREAS NOTED IN COUNTS 1-4. COUNT 9 RESPONDENT FAILED TO DEVELOP, ESTABLISH, INCLUDE AND MAIN- TAIN ALL REQUIRED INFORMATION IN THE MANAGEMENT PLAN. UNADJUSTED PROPOSED TOTAL PENALTY $126,000 ADJUSTED PROPOSED TOTAL PENALTY $25,000 PAYMENT TO BE MADE WITHIN 30 DAYS OF RECEIPT OF THIS COM- PLAINT.