THIS PROPOSES THE FILING OF AN AMENDED COMPLAINT IN U.S. V. BENJAMIN KURZBAN & SONS, INC. , 85 CIV 2267(SDNY), BASED ON ADDITIONAL VIOLATIONS OF THE ASBESTOS NESHAPS BY THE DEFENDANT AT A DIFFERENT SITE. THE VIOLATIONS IN THE ORIGINAL COMPLAINT FILED ON 3/22/85 OCCURRED AT ELLIS ISLAND & REGION II PROPOSES TO ADD VIOLATIONS WHICH OCCURRED SUB- SEQUENTLY AT 120 CHURCH ST., NEW YORK CITY. THE NEW VIOLATIONS ARE BASED ON THE NESHAPS ASBESTOS RENO- VATION AND DEMOLITION REGULATIONS AS IS THE ORIGINAL COM- PLAINT. KURZBAN IS A LOCAL CONTRACTOR ENGAGED IN ASBESTOS REMOVAL AT RENOVATIONS IN THE N.Y.C. AREA. IN THIS CASE, KURZBAN WAS A SUBCONTRACTOR FOR ASBESTOS REMOVAL ON A GSA CONTRACT FOR THE RENOVATION OF THE 9TH & 10TH FLOORS OF THE I.R.S. OFFICES AT 120 CHURCH ST., N.Y.C. AS PART OF AN OVERALL RENOVATION OF ABOUT 35,000 SQUARE FEET ON BOTH FLOORS, THE GSA CONTRACTING OFFICER'S REPRESENTATIVE ESTIMATES THAT A TOTAL OF 3,600 SQ. FT. OF ASBESTOS FIRE-PROOFING WAS REMOVED FROM STRUCTURAL MEMBERS, TO BE REPLACED BY NON-ASBESTOS FIRE PROOFING. EPA RECEIVED NOTIFICATION OF THE RENOVATION PROJECT BY THE GENERAL CONTRACTOR, GRAMERCY CONTRACTORS, INC., ON 11/5/84. AS A RESULT OF NOTIFICATION BY GSA OF PROBLEMS AT THE JOB SITE, AN EPA ENGINEER INSPECTED THE SITE ON 11/26/84 WHILE KURZBAN EMPLOYEES WERE REMOVING ASBEST