CLEAN AIR ACT ASBESTOS NESHAP VIOLATIONS. THE PENALTY OF $44,000 WAS ASSESSED TO TWO SEPARATE RE- SPONDENT VIA TWO SEPARATE COMPLAINTS. THE LITIGATION TEAM APPORTIONED THE TOTAL PENALTY OF $44,000 ON A 50-50 BASIS, WITH EACH RESPONDENT BEARING A $22,000 LIABILITY. THE PENALTY WAS REDUCED TO $8,000 FOR SETTLEMENT, DUE TO DEGREE OF COOPERATION AND ABILITY TO PAY.