1. SECTION 207(A) OF THE TOXIC SUBSTANCE CONTROL ACT ( TSCA ), 15 U.S.C. SECTION 2647(A), ENACTED AS A SECTION OF SUBCHAPTER II OF TSCA, KNOWN AS THE ASBESTOS HAZARD EMERGENCY RESPONSE ACT ( AHERA ), 15 U.S.C. SECTION 2641 ET SEQ. 2. FIRST BAPTIST CHILD DEVELOPMENT CENTER 300 SOUTH CENTER ARLINGTON, TARRANT COUNTY, TEXAS 76010 3. RESPONDENT WAS IN VIOLATION OF SECTION 15 OF TSCA BY 1) NOT HAVING THE SCHOOL BUILDING INSPECTED FOR THE IDENTI- FICATION, AND 2) FAILING TO DEVELOP A MANAGEMENT PLAN AND SUBMIT THE MANAGEMENT PLAN TO THE STATE DESIGNATED AGENCY AS REQUIRED. 4. RELIEF SOUGHT PURSUANT TO SECTION 207(A) OF TSCA, EPA PROPOSES A CIVIL PENALTY OF $2,750, A REDUCTION FROM $5,500.