THIS PROPOSES THE FILING OF A CIVIL ACTION FOR VIOLATIONS OF THE NESHAPS REGULATIONS FOR CONTROL OF ASBESTOS EMISSIONS AT DEMOLITION & RENOVATION SITES: PURSUANT TO SECTION 113(B) OF THE CAA, 42 U.S.C. 7413(B), AGAINST GOLDOME FSD ( GOL- DOME ), THE JOHN W. COWPER COMPANY (INC.) ( COWPER ), AND WM. W. KIMMINS AND SONS, INC. ( KIMMINS ) FOR THEIR VIOLA- TIONS OF CAA/112 & CAA/114 & EPA ORDERS ISSUED THEREUNDER. CAA/112(C) PROHIBITS EMISSIONS OF HAZARDOUS AIR POLLUTANTS IN EXCESS OF THE STDS. PROMULGATED PURSUANT TO CAA/112(B). SECTION 114 REQUIRES THE SUBMISSION OF INFORMATION BY ANY PERSON ON REQUEST OF EPA. UNDER SECTIONS 112 & 114 OF CAA, EPA HAS PROMULGATED A SERIES OF NESHAPS INCLUDING STDS. FOR ASBESTOS EMISSIONS FROM AND/OR WORK PRACTICES FOR THOSE WHO ENGAGE IN DEMOLITION & RENOVATION OPERATIONS AS WELL AS PRO- CEDURES FOR NOTIFYING EPA OF SUCH OPERATIONS. UNTIL RECENT- LY, THESE STDS. WERE CODIFIED AT 40 C.F.R. 61.22 AND, SINCE 4/5/84, HAVE BEEN CODIFIED AT 40 C.F.R. 61.140 - 61.156. GOLDOME IS THE OWNER OF THE STRUCTURE IN BUFFALO, NY, UNDERGOING DEMOLITION; COWPER IS THE GENERAL CONTRACTOR FOR REPLACING THE STRUCTURE; KIMMINS IS THE SUBCONTRACTOR FOR DEMOLITION OF THE EXISTING STRUCTURE. INFORMATION FROM A VERY RELIABLE PRIVATE CITIZEN & A NYS DEC ENGINEER ESTAB- LISHED THAT FRIABLE ASBESTOS-CONTAINING DEBRIS WAS BEING COLLECTED & TRANSPORTED FROM THE SITE ON 2/17/84, IN VIOLA- TION OF 40 C.F.R. 61.22(D). ANOTHER D