THE VIOLATIONS UPON WHICH THIS ACTION IS BASED ARE AS FOLLOWS. THE NATIONAL STANDARDS FOR HAZARDOUS AIR POLLUTANTS ('NESHAP') FOR ASBESTOS WERE VIOLATED BY FAILURE TO COMPLY WITH REMOVAL PROCEDURES AT 40 CFR 61.147, 61.152 AND BY FAILURE TO COMPLY WITH THE NOTIFICATION REQUIREMENT AT 61.146. SPECIFICALLY: 1) ON OR ABOUT 6/3/87, FAILURE TO NOTIFY EPA BEFORE THE RENOVATION BEGAN IN VIOLATION OF THE 40 CFR 61.146(B)(4); 2) ON OR ABOUT 5/27/87, FAILURE TO ENSURE THAT THE FRIABLE ASBESTOS MATERIAL REMAINED WET UNTIL COLLECTED FOR DISPOSAL; AND 3) ON OR ABOUT 5/27/87, CAUSING VISIBLE EMISSIONS OF ASBESTOS-CONTAINING MATERIAL TO THE OUTSIDE AIR IN VIOLATION OF 40 CFR 61.152(B). THE PROPOSED RELIEF SOUGHT IS INJUNCTIVE RELIEF DIRECTING THE DEFENDANT TO COMPLY WITH THE NESHAP REGULATIONS GOVERNING ASBESTOS RENOVATIONS AND DEMOLITIONS; AND TO COLLECT CIVIL PENALTIES IN THE AMOUNT OF $41,200 BASED ON EPA'S ASBESTOS DEMOLITION AND RENOVATION CIVIL PENALTY POLICY DATED 2/8/85. CONTACTS WITH DEFENDANT INCLUDE 1/21/88, EPA REGION II SENT LETTERS PURSUANT TO 114 OF THE ACT TO ALL DEFENDANTS. EPA HAS NOT TAKEN ANY PRIOR ADMINISTRATIVE ACTION AGAINST THE DEFENDANT FOR VIOLATION OF THE ASBESTOS NESHAPS.