INSPECTION ON 6/30/93 & 7/1/93 BY AN AUTHORIZED INSPECTOR TO DETERMINE COMPLIANCE WITH AHERA AND ITS IMPLEMENTING REGULATIONS. 10 COUNTS WERE ALLEGED TO BE VIOLATED. COUNTS 1-3 RESPONDENT FAILED TO PROPERLY IDENTIFY THE LOCATIONS OF ALL THE AREAS OF SUSPECTED ACBM IN PIUTE COUNTY'S PIUTE HIGH SCHOOL, CIRCLEVILLE ELEMENTARY SCHOOL AND MARYSVILLE/ OSCARSON ELEMENTARY SCHOOL. COUNTS 4-6 RESPONDENT FAILED TO COLLECT AND SUBMIT FOR ANALYSIS BULK SAMPLES FROM THE ABOVE MENTIONED AREAS. COUNTS 7-9 RESPONDENT FAILED TO CLASSIFY THE ACBM AND SUSPECTED ACBM WITHIN THE CATEGORIES OUTLINED INAND REASONING FOR THE CLASSIFICATION BE INCLUDED IN A WRITTEN ASSESSMENT. COUNT 10 RESPONDENT FAILED TO PROPERLY DEVELOP, ESTABLISH, INCLUDE AND MAINTAIN ALL REQUIRED INFORMATION IN THE MANAGEMENT PLAN PROPOSED CIVIL PENALTY IS $178,000. ADJUSTED TOTAL PROPOSED PENALTY $75,000.