1. SECTION 207(A) OF THE TOXIC SUBSTANCES CONTROL ACT ( TSCA ), 15 U.S.C. SECTION 2647(A). 2. BRADFORD CHRISTIAN SCHOOL, A LOCAL EDUCATION AGENCY 231 EAST GRAHAM PRYOR, MAYES COUNTY, OKLAHOMA 74361 3. RESPONDENT WAS IN VIOLATION OF SECTION 15 OF TSCA BY FAILING TO DEVELOP A MANAGEMENT PLAN FOR THE HIGH SCHOOL BUILDING AS REQUIRED. 4. RELIEF SOUGHT PURSUANT TO SECTION 207(A) OF TSCA, EPA PROPOSES A CIVIL PENALTY OF $2,640.