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, KNOWN AS THE ASBESTOS HAZARD E- MERGENCY RESPONSE ACT ( AHERA ), 15 U.S.C. SECTION 2641 ET SEQ. 2. SPRINGER PUBLIC SCHOOL DISTRICT SPRINGER ELEMENTARY SCHOOL AND SPRINGER JR.-SR. HIGH SCHOOL HIGHWAY 77 SPRINGER, CARTER COUNTY, OKLAHOMA 73459 3. RESPONDENT WAS IN VIOLATION OF SECTION 15 OF TSCA BY 1) FAILING TO INSPECT THE SCHOOL BUILDINGS FOR THE IDENTIFI- CATION OF ASBESTOS MATERIALS AS REQUIRED, AND 2) FAILING TO DEVELOP MANAGEMENT PLANS FOR THE 1ST AND 2ND GRADE AND BUS GARAGE AND SUBMITTED TO THE DESIGNATED STATE AGENCY. 4. RELIEF SOUGHT PURSUANT TO SECTION 207(A) OF TSCA, EPA PROPOSED A CIVIL PENALTY OF $7,800, BUT HAS BEEN ADJUSTED TO $3,900 FOR VIOLATIONS FOR A SINGLE BUILDING.