NATURE OF CASE ONE OF CIRCLE B'S LINES OF BUSINESS IS ASBESTOS ABATE- MENT. FOR EACH DEMOLITION OR RENOVATION PROJECT, THE NESHAP'S REGULATIONS REQUIRE TIMELY AND COMPLETE NOTICES PRIOR TO THE COMMENCEMENT OF SUCH PROJECTS. CAUSE OF ACTION ALL NOTICES SUBMITTED BY CIRCLE B HAVE BEEN INCOMPLETE. THREE OF THESE WERE LATE. IN THREE OTHER INSTANCES, NO NOTICE WAS CORRECTLY FILED. THESE ACTS AND OMISSIONS CON- STITUTE VIOLATIONS OF 40 CFR 61.146 (FORMERLY 40 CFR 61.22 (D)) AND SECTION 112(C) OF THE CLEAN AIR ACT, 42 U.S.C. SECTION 7412. U.S. EPA MAY BRING SUIT TO TERMINATE ALL SUCH VIOLATIONS AND RECOVER CIVIL PENALTIES, UNDER SECTION 113 OF THE ACT, 42 U.S.C. SECTION 7413. PROPOSED REMEDY U.S. EPA AND CIRCLE B HAVE DISCUSSED DETAILED PROCE- DURES AND FORMS WHICH SHALL ENSURE THAT CIRCLE B WILL PRO- VIDE ADEQUATE AND COMPLETE NOTICE IN THE FUTURE. IN ADDI- TION, REGION V RECOMMENDS A PENALTY FOR SETTLEMENT PURPOSES OF NOT LESS THAN $20,000. ISSUES OF NATIONAL SIGNIFICANCE THIS CASE MAY BE OF NATIONAL SIGNIFICANCE IN THAT IT IS ONE OF THE FIRST TO ENFORCE THE NOTIFICATION REQUIREMENTS OF THE ASBESTOS STANDARD WITHOUT A WORK PRACTICE OR EMISSION VIOLATION. IF ENFORCEABILITY IS CHALL