1. SECTION 207(A) OF THE TOXIC SUBSTANCES CONTROL ACT ( TSCA ), 15 U.S.C. SECTION 2647(A), ENACTED AS A SEC- TION OF SUBCHAPTER I OF TSCA, KNOWN AS THE ASBESTOS HAZ- ARD EMERGENCY RESPONSE ACT (AHERA). 2. GULF COAST COUNCIL OF LA RAZA (LA RAZA SCHOOL) 2203 BALDWIN BOULEVARD CORPUS CHRISTI, LIVE OAK COUNTY, TEXAS 78405-2011 3. RESPONDENT WAS IN VIOLATION OF SECTION 15 OF TSCA BY FAILING TO INSPECT THE SCHOOL BUILDINGS AND BY FAILING TO DEVELOP AND SUBMIT A MANAGEMENT PLAN TO THE AGENCY DESIGNATED BY THE GOVERNOR. 4. RELIEF SOUGHT PURSUANT TO SECTION 207(A) OF TSCA, EPA PROPOSED A CIVIL PENALTY OF $4,400 BUT PROPOSED A RE- DUCTION IN THE PENALTY TO $1,320.