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 ASBESTOS HAZARD EMERG- ENCY RESPONSE ACT ( AHERA ). 2. HOUSTON INDEPENDENT SCHOOL DISTRICT FACILITIES: 1. AUSTIN SENIOR HIGH SCHOOL 1700 DUMBLE STREET HOUSTON, HARRIS COUNTY, TEXAS 77023 2. THE ADMINISTRATIVE BUILDING 3701 WEST ALABAMA, SUITE 205 HOUSTON, HARRIS COUNTY, TEXAS 77027 3. RESPONDENT WAS IN VIOLATION OF SECTION 15 OF TSCA BY 1) FAILING TO INSPECT THE ADMINISTRATION BUILDING FOR THE I- DENTIFICATION OF ASBESTOS MATERIALS, 2) FAILING TO DE- VELOP A MANAGEMENT PLAN FOR THE ADMINISTRATION BUILDING, AND SUBMITTING THENPLAN TO THE STATE DESIGNATED BUILDING, AND 3) FAILING TO COLLECT THE REQUIRED NUMBER OF BULK SAMPLES AS REQUIRED. 4. RELIEF SOUGHT PURSUANT TO SECTION 207(A) OF TSCA, EPA PROPOSES A CIVIL PENALTY OF $7,000, A REDUCTION FROM THE PROPOSED $11,000.