1. SECTION 207(A) OF THE TOXIC SUBSTANCES CONTROL ACT ( TSCA ), 15 U.S.C. SECTION 2647(A). 2. FORT WORTH ACADEMY, A LOCAL EDUCATION AGENCY 7301 DUTCH BRANCH ROAD FORT WORTH, TARRANT COUNTY, TEXAS 76132 3. RESPONDENT WAS IN VIOLATION OF SECTION 15(A)(D) OF TSCA BY FAILING TO DEVELOP A MANAGEMENT PLAN AS REQUIRED. 4. RELIEF SOUGHT PURSUANT TO SECTION 207(A) OF TSCA, EPA PROPOSES A CIVIL PENALTY OF $2,640.