THIS CASE INVOLVES NUMEROUS VIOLATIONS OF THE NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) FOR ABESTOS PURSUANT TO CAA SECTIONS 112 AND 114. THE SPECIFIC REGULATION VIOLATED IN EVERY INSTANCE HAS BEEN 40 C.F.R. SECTION 61.146, STANDARD FOR DEMOLITION AND RENOVATION: NOTIFICATION REQUIREMENTS. THE DEFENDANTS, MARTIN O. SANDIDGE, M.O. SANDIDGE INC., AND UNITY CONS- TRUCTION INC., ARE LEGALLY SEPARATE PERSONS. AS A PRACTICAL MATTER HOWEVER, IT HAS BEEN MARTIN O. SANDIDGE AS AN INDIVIDUAL AND/OR AS PRESIDENT OF THE CORPORATIONS WHO HAS BEEN RESPONSIBLE FOR SUBMITTING THE DEFICIENT NOTI- FICATIONS TO EPA PRIOR TO ASBESTOS DEMOLITION OR RENOVATION WORK. SANDIDGE SUBMITTED INCOMPLETE NOTIFICATIONS FOR DEMO- LITION OR RENOVATION WORK AT VARIOUS TIMES FROM JULY 10, 1985 THROUGH MARCH 23, 1987. SANDIDGE SUBMITED INCOMPLETE NOTIFICATIONS IN 1985 DATED JULY 10, AUGUST 5, AUGUST 13, AUGUST 21, AUGUST 26 AND SEPTEMBER 4. AS A RESULT OF TWO OF THESE NOTICES, EPA HAD ISSUED TWO NOTICES OF DEFICIENCY (NOD) TO M.O. SANDIDGE INC, ON AUGUST 16, 1985. SANDIDGE SUPPLIED INCOMPLETE RESPONSES TO THE TWO NOD'S. EPA ISSUED AN ADMINISTRATIVE ORDER (AO) TO M.O. SANDIDGE ON DECEMBER 13, 1985. THE AO REQUIRED M.O. SANDIDGE INC. TO SUPPLY THE MISSING NOTIFICATION INFORMATION WITH RESPECT TO SIX SPECIDIC PROJECTS AND TO SUBMIT AL