1. SECTION 207(A) OF THE TOXIC SUBSTANCES CONTROL ACT ( TSCA ), 15 U.S.C. SECTION 2647(A). 2. GENESIS SCHOOLS D.B.A. PEGASUS CHARTER SCHOOLS 2121 MAIN STREET DALLAS, DALLAS COUNTY, TEXAS 75201 3. RESPONDENT WAS IN VIOLATION OF SECTION 15 OF TSCA BY 1) FAILING TO DEVELOP A COMPLETE MANAGEMENT PLAN FOR THE SCHOOL. 4. RELIEF SOUGHT PURSUANT TO SECTION 207(A) OF TSCA, EPA PROPOSED A CIVIL PENALTY OF $3,300 FOR THE VIOLATION CITED.