FOV WAS ISSUED FOR NOTICE AND WORK PRACTICE VIOLATIONS WHICH EPA ALLEGES. THESE ALLEGATIONS ARE BASED ON INSPECTION RE- PORTS. FOVS WERE SENT TO SUPERIOR DEMOLITION AND EXCAVATING INC. (THE DEMOLITION CONTRACTOR) AND CHELM MANAGEMENT COM- PANY (THE MANAGER OF THE PROPERTY) ON 8/12/91. AN FOV WAS ISSUED TO NORTHEAS INDUSTRIAL PROPERTIES (THE OWNER) ON 9/12 /91. - INFORMAL CONFERENCES WERE HELD WITH CHELM MGT AND SUPERIOR DEMOLITION ON 9/12/91, AND 9/20/91, RESPECTIVELY. - WHEN THE FOVS WERE ISSUED IN AUGUST, EPA KNEW THAT THIS FACI LITY HAD SUFFERED A FIRE. CDAPC INSPECTORS TOLD US THAT PART OF THE BUILDING WAS UNDER A DEMOLTIION ORDER AND PART WAS NOT AND THAT THEY DETECTED NOTICE AND WORK PRACTICE VIOLATIONS. - THE INFORMAL CONFERENCE REVEALED THAT THE ENTIRE BUILDING WAS SUBJECT TO A CITY CONDEMNATION ORDER DUE TO A FIRE WHICH CAUSED THE MIDDLE OF THE BUILDING TO COLLAPSE. - CHELM HIRED SUPERIOR TO DEMOLISH AND TOOK NO OTHER MEASURES. - SUPERIOR WENT TO DEMOLISH IN AUGUST, BUT ARSON INVESTIGATION CREWS PREVENTED ANY WORK. THE ASRSO