RENOVATIONS INVOLVING AT LEAST 260 LINEAR FEET OR 160 SQUARE FEET OF ASBESTOS CONTAINING MATERIAL OCCURRED AT 50 DIFFERENT SITES OWNED BY THE BOARD OF EDUCATION. THE SUBJECT CONTRACTORS EACH PERFORMED ONE OR MORE OF THESE ASBESTOS REMOVAL JOBS. EPA REGION II WAS NOT NOTIFIED AS REQUIRED BY C.F.R. 61.146 PRIOR TO THE COMMENCEMENT OF WORK. BOTH THE OWNER AND OPERATOR HAVE A STATUATORY DUTY TO DO SO. AN INJUNCTION MANDATING THAT ALL DEPARTMENTS OR AGENCIES OF THE CITY OF NEW YORK AND THE SUBJECT CONTRACTORS PERFORM ALL THE REQUIREMENTS OF THE ASBESTOS NESHAP AND APPROPRIATE CIVIL PENALTIES. THIS CASE, BROUGHT AGAINST MULTIPLE DEFENDANTS, ALSO INVOLVES VIOLATIONS ARISING FROM WORK PERFORMED AT MULTIPLE FACILITIES. BECAUSE OF THE NUMBER OF PARTIES AND NUMBER OF FACILITIES, THIS CASE WILL REQUIRE SIGNIFICANTLY MORE RESOURCES THAN A USUAL ASBESTOS CASE IN THIS REGION.