1. SECTION 207(A) OF THE TOXIC SUBSTANCES CONTROL ACT ( TSCA ), 15 U.S.C. SECTION 2647(A). 2. SECOND BAPTIST CHRISTIAN SCHOOL, AN LEA 600 GARLAND AVENUE HOT SPRINGS, GARLAND COUNTY, ARKANSAS 71913 3. RESPONDENT WAS IN VIOLATION OF SECTION 15 OF TSCA BY 1) FAILING TO DEVELOP A MANAGEMENT PLAN FOR THE SCHOOL. 4. RELIEF SOUGHT PURSUANT TO SECTION 207(A) OF TSCA, EPA PROPOSED A CIVIL PENALTY OF $4,400 FOR THE VIOLATION CITED.