APPROXIMATELY 40 COUNTS OF FAILURE TO PROPERLY NOTIFY OF INTENT TO RENOVATE ASBESTOS CONTAINING STRUCTURES. I. SYNOPSIS OF THE CASE THE DEFENDANTS ENGAGE IN DEMOLITION AND RENOVATION OPERA- TIONS. MANY OF THESE INVOLVE THE REMOVAL OF FRIABLE ASBES- TOS MATERIALS AND, THEREFORE, NOTICE TO THE USEPA IN ADVANCE OF THE COMMENCEMENT OF THE OPERATIONS UNDER ASBESTOS NATL EMISSION STANDARD FOR HAZARDOUS AIR POLLUTANTS, 40 CFR S61. 140 ET SEQ. BETWEEN SEPTEMBER 1984 AND MAY 1986, THE DEFENDANTS SUBMIT TED 36 NOTICES OF ASBESTOS REMOVAL. EACH NOTICE CONTAINED SOME DEFICIENCIES. A FINDING OF VIOLATION ( FOV ) WAS ISSU- ED, ADDRESSING EACH NOTICE. SEE ATTACHMENT. BASED UPON IN- FORMATION SUBMITTED PURSUANT TO THE SECT 113 CONFERENCE, FOV COUNT 28 WAS DELETED. OF THE 35 REMAINING COUNTS, 19 WERE CONSIDERED SERIOUS ENOUGH TO MERIT INCLUSION IN THIS REFER- RAL. THE BREAKDOWN OF TYPE OF VIOLATION, IN ORDER OF SEVERI TY, IS LISTED BELOW. THE FOV COUNT IS CHARACTERIZED BY THE MOST MAJOR DEFICIENCY IN THE NOTICE. MOST NOTICES ALSO CON- TAINED MINOR OMISSIONS OR DEFICIENCIES. FOV COUNT TYPE OF VIOLATION 1, 5 NOTICE SUBMITTED AFTER ASBESTOS REMOVAL COMPLETED 8, 9 NOTICE LACKS JOB LOATION AND ASBESTOS REMOVAL STARTING