1. SECTION 207(A) OF THE TOXIC SUBSTANCES CONTROL ACT ( TSCA ), 15 U.S.C. SECTION 2647(A). 2. SAINT MARY HALL 9401 STARCREST DRIVE SAN ANTONIO, BEXAR COUNTY, TEXAS 78217 3. RESPONDENT WAS IN VIOLATION OF SECTION 15 OF TSCA BY FAILING TO DEVELOP AN ASBESTOS MANAGEMENT PLAN AND SUB- MITTING THE PLAN TO THE STATE DESIGNATED AGENCY. 4. RELIEF SOUGHT PURSUANT TO SECTION 207(A) OF TSCA, EPA PROPOSES A CIVIL PENALTY OF $4,400 FOR THE VIOLATION CITED.