1. SECTION 207(A) OF THE TOXIC SUBSTANCES CONTROL ACT, 15 U.S.C. SECTION 2647(A), ( TSCA ), ENACTED AS A SECTION OF SUBCHAPTER II OF TSCA, KNOWN AS THE ASBESTOS HAZARD E- MERGENCY RESPONSE ACT (AHERA), 15 U.S.C. SECTION 2641 ET SEQ. 2. ASHERTON INDEPENDENT SCHOOL DISTRICT, A LOCAL EDUCATION AGENCY HIGHWAY 83 NORTH, P.O. BOX 398 ASHERTON, DIMMIT COUNTY, TEXAS 78827-0398 3. RESPONDENT WAS IN VIOLATION OF SECTION 15 OF TSCA BY 1) FAILURE TO NOTIFY REGARDING THE AVAILABILITY OF MANAGE- MENT PLANS, 2) FAILURE TO MAINTAIN A MANAGEMENT PLAN AT RESPONDENT'S SCHOOLS, 3) FAILURE TO INSPECT/DEVELOP MAN- AGEMENT PLANS FOR ASHERTON ELEMENTARY/JUNIOR HIGH SCHOOL AND ASHERTON HIGH SCHOOL, AND 4) FAILURE TO REINSPECT. 4. RELIEF SOUGHT PURSUANT TO SECTION 207(A) OF TSCA, EPA PROPOSED A CIVIL PENALTY OF $15,180 FOR THE VIOLATIONS CITED. AFTER CONSIDERATION OF FACTORS LISTED IN TSCA, THE PROPOSED PENALTY WAS REDUCED TO $7,590.