1. SECTION 207(A) OF THE TOXIC SUBSTANCES CONTROL ACT ( TSCA ), 15 U.S.C. SECTION 2647(A). 2. ST. JOHN CHRISTIAN ACADEMY, A LOCAL EDUCATION AGENCY 5700 NORTH KELLY AVENUE OKLAHOMA CITY, OKLAHOMA COUNTY, OKLAHOMA 73111 3. RESPONDENT WAS IN VIOLATION OF SECTION 15 OF TSCA BY FAILURE TO INSPECT AND DEVELOP A MANAGEMENT PLAN. 4. RELIEF SOUGHT PURSUANT TO SECTION 207(A) OF TSCA, EPA PROPOSED A CIVIL PENALTY OF $4,400 FOR THE VIOLATIONS CITED.