THE REFERRAL IS BASED ON DORE AND ASSOC., MIDLAND PUBLIC AND FLINT COMMUNITY SCHOOLS FAILURE TO PROVIDE TO USEPA AC- CURATE AND COMPLETE NOTICES OF INTENT TO RENOVATE AND DEMO- LISH AND TO KEEP ADEQUATELY WET STRIPPED OR REMOVED FRIABLE ASBESTOS MATERIAL UNTIL THEY WERE COLLECTED FOR DISPOSAL, AND DORE'S AND FLINT'S FAILURE TO REMOVE ASBESTOS FROM A FACILITY BEFORE WRECKING OR DISMANTLING THAT WOULD PRECLUDE ACCESS TO THE MATERIALS FOR SUBSEQUENT REMOVAL, AS REQUIRED BY THE ASBESTOS NESHAP. SECT 113B OF THE CAA, 42 USC S7413B, AUTHORIZES THE USEPA TO INITIATE A CIVIL ACTION TO ABATE THE VIOLATIONS AND TO SEEK CIVIL PENALTIES.