THE DEFENDANTS VIOLATED THE STANDARD FOR DEMOLITION AND RENOVATION: NOTIFICATION REQUIREMENTS, 40 CFR S61.146, OF NESHAP, S112 OF THE ACT, 42 USC S7412. SECT 113B OF THE ACT 42 USC S7413B, AUTHORIZES THE USEPA TO INITIATE A CIVIL AC- TION. THE ENCLOSED LITIGATION REPORT DOCUMENTS THE DEFENDANTS' VIOLATION OF 40 CFR S61.146, AND S112 OF THE ACT, 42 USC S74 12. SPECIFICALLY, THE DEFENDANTS ARE THE OWNER AND OPERATOR OF A STATIONARY SOURCE, AND DURING A RENOVATION OPERATION STRIPPED OR REMOVED AT LEAST 80 LINEAR METERS (260 LINEAR FT) OF ASBESTOS CONTAINING MATERIAL (ACM) FROM PIPES AND AT LEAST 15 SQUARE METERS (160 SQUARE FT) OF ACM FROM OTHER FACILITY COMPONENTS, AND FAILED TO PROVIDE TO THE OHIO ENVI- RONMENTAL PROTECTION AGENCY, NORTHWEST DIST OFFICE (NEDO), AS EARLY AS POSSIBLE BEFORE THE RENOVATION OPERATION BEGAN, WRITTEN NOTICE OF THEIR INTENT TO CONDUCT A RENOVATION OPERA TION. THE STATE OF OHIO REFERRED THIS MATTER TO REGION V, AND REQUESTED THE REGION'S ASSISTANCE IN TAKING EFFECTIVE EN FORCEMENT ACTION.