THE VIOLATIONS UPON WHICH THE ACTION IS BASED. NATIONAL EMISSION STANDARDS FOR ASBESTOS WERE VIOLATED BY FAILURE TO COMPLY WITH REMOVAL PROCEDURES AT 40 CFR SECTION 61.147. SPECIFICALLY: 1) ON 08/11/87, FAILURE TO ENSURE THE FRIABLE ASBESTOS MATERIALS ARE ADEQUATELY WET WHEN THEY ARE BEING STRIPPED FROM FACILITY COMPONENTS BEFORE THE MEMBERS ARE REMOVED FROM THE FACILITY. THE PROPOSED RELIEF TO BE SOUGHT IS INJUNCTIVE RELIEF DIRECTING THE DEFENDANT TO SUBMIT TO EPA PLANS, SCHEDULES AND SITE CONTACTS FOR EACH ASBESTOS RENOVATION OR DEMOLITION; TO PROVIDE EPA INSPECTORS WITH IMMEDIATE ACCESS; SAMPLE AND ANALYZE FRIABLE MATERIAL BEFORE STRIPPING; PROVIDE ADJUSTED STARTING AND COMPLETION DATES; TO COMPLY WITH THE NESHAP REGULATIONS GOVERNING ASBESTOS RENOVATIONS AND DEMOLITIONS; AND TO COLLECT CIVIL PENALTIES IN THE AMOUNT OF $53,500 BASED ON EPA'S ASBESTOS DEMOLITION AND RENOVATION CIVIL PENALTY POLICY DATED 02/08/85. RECENT CONTACTS WITH THE DEFENDANT, INCLUDING ANY PREVIOUS ADMINIS- TRATION ENFORCEMENT ACTIONS TAKEN ARE AS FOLLOWS: 1) 114 LETTER SENT TO DEFENDANTS ON 01/21/88; 2) EPA MET WITH WILLIAM BARCZAK, COUNSEL FOR SUNY ON 09/15/87.