1. SECTION 207(A) OF THE TOXIC SUBSTANCES CONTROL ACT ( TSCA ), 15 U.S.C. SECTION 2647(A), ENACTED AS A SECTION OF SUBCHAPTER II OF TSCA, ASBESTOS HAZARD EMERGENCY RE- SPONSE ACT ( AHERA ), 15 U.S.C. SECTION 2641 ET SEQ. 2. EPISCOPAL SCHOOL OF DALLAS 4100 MERREL ROAD DALLAS, DALLAS COUNTY, TEXAS 75229 3. RESPONDENT WAS IN VIOLATION OF SECTION 15 OF TSCA BY FAILING TO INSPECT THE GYMNASIUM, ACADEMIC, FINE ARTS BUILDING AND THE BUILDING CONSTRUCTED IN 1994 AS REQUIRED AND BY FAILING TO DEVELP A MANAGEMENT PLAN FOR THE GYM- NASIUM, ACADEMIC, AND FINE ARTS BUILDINGS AND THE BUILD- ING CONSTRUCTED IN 1994 AS REQUIRED. 4. RELIEF SOUGHT PURSUANT TO SECTION 207(A) OF TSCA, EPA PROPOSES A REDUCED PENALTY OF $5,500.