RESPONDENT WAS A SUB-CONTRACTOR DURING AN AUGUST 1989 ASBESTOS ABATEMENT PROJET AT THE CARDINGTON ELEMENTARY SCHOOL IN CARDINGTON, OH. THE COMPLAINT ISSUED 8/3/90, ALLEGED THAT RESPONDENT FAILED TO COMPLY WITH THE REQUIREMENTS OF 15 USC SECTIONS 2614 AND 2643, AND 40 CFR SECTION 763.90(I), BY SPLITTING THE ASBESTOS PROJECT AREA INTO SMALL CONTIGUOUS AREA. THE COMPLAINT PROPOSED A PENALTY IF $25,000. RESPONDENT CERTIFIED THAT ITS CURRENT ABATEMENT WORK IS CONDUCTED IN COMPLIANCE WITH AHERA, THAT NO CONTAMINATION OF THE ABATEMENT SITE WAS SHOWN BY AIR TESTING, AN THAT IT RECEIVED NO ECONOMIC BENEFIT DUE TO THE FACT THAT IT HAD TO PERFORM ADDDITIONAL TESTING DUE TO THE SEPARATION. USEPA RECOGNIZED THAT RESPONSIBILITY FOR THE VIOLATION WAS SHARED BY THE CONTRACTOR, ASBESTOS REAL ESTATE CONSULTANTS, INC, WHICH WAS SUBJECT TO, AND SETTLED, A SEPARATE ADMINISTRATIVE ACTION RELATING TO THE SAME IMPROPER SEPARATION.