B&S IS THE OWNER OF THE FACILITY AND HIRED TORYPETE AS GENERAL CONTRACTOR RESPONSIBLE FOR SITE DEVELOPMENT WITH RESPECT TO THE DEMOLITION OF THE FORMER DOWNINGTOWN FARMER'S MARKET AND ADJACENT FORMER RESIDENTIAL STRUCTURES, THE CONSTRUCTION OF THE NEW ASHBRIDGE SQUARE AT EAST CALN SHOPPING CENTER AND THE MANAGEMENT OF THE SUBCONTRACTORS IT ENGAGED TO PERFORM DEMOLITION, ASBESTOS REMOVAL, REDEVELOPMENT AND OTHER SITE-RELATED ACTIVITIES. FULL MOON CONSTRUCTION CO., INC. WAS THE PRIME SUBCONTRACTOR HIRED BY TORYPETE MANAGEMENT, INC. TO DEMOLISH ALL STRUCTURES AT THE FACILITY, PERFORM ANY NECESSARY ASBESTOS ABATEMENT AND OTHERWISE PREPARE THE SITE FOR REDEVELOPMENT. TERRA ENVIRONMENTAL CONTRACTORS, INC. WAS A SUBCONTRACTOR OF FULL MOON CONSTRUCTION CO., INC. AND WAS HIRED TO ASSIST FULL MOON IN PERFORMING DEMOLITION ACTIVITIES, INCLUDING CERTAIN ASBESTOS ABATEMENT ACTIVITIES, AT THE FACILITY. THROUGH A FACILITY INSPECTION AND INFORMATION REQUEST LETTER EPA ALLEGES THAT ALL OF THE RESPONDENTS VIOLATED THE CAA AND APPLICABLE ASBESTOS NESHAP REQUIREMENTS BY FAILING TO: THOROUGHLY INSPECT THE FACILITY FOR THE PRESENCE OF ASBESTOS PRIOR TO THE COMMENCEMENT OF DEMOLITION OPERATIONS IN ORDER TO DETERMINE THE APPLICABLE ASBESTOS NESHAP REQUIREMENTS; PROVIDE WRITTEN NOTICE TO EPA REGARDING DEMOLITION ACTIVITIES AT THE FACILITY AT LEAST TEN (10) DAYS PRIOR TO INITIATING ASBESTOS STRIPPING, REMOV