THE PEWAUKEE SCHOOL DISTRICT UNDERTOOK A RENOVATION ACTIVITY (REMOVAL OF FLOOR TILES AND MASTIC) AT THE PEWAUKEE HIGH SCHOOL BETWEEN AUGUST 11-20, 1997. THE WISCONSIN DEPARTMENT OF NATURAL RESOURCES (WDNR) INSPECTED THE HIGH SCHOOL AND SUBSEQUENTLY CITED THE SCHOOL DISTRICT FOR VIOLATIONS OF THE ASBESTOS NESHAP. HOWEVER, WDNR WAS UNABLE TO CITE THE BUILD ING AND GROUNDS SUPERVISOR, PATRICT J. ACKER, WHO WAS RESPONSIBLE FOR THE RENOVATION ACTIVITY, DUE TO STATUTORY LIMITATIONS UNDER WISCONSIN LAW. AN ADMINISTRATIVE CONSENT ORDER (ACO) WITH NO MONETARY PENALTY WAS ISSUED TO MR. ACKER TO ENSURE FUTURE COMPLIANCE WITH THE ASBESTOS NESHAP. MR. ACKER DID NOT SIGN THE ACO SO A UNILATERAL ADMINISTRA- TIVE ORDER (UAO) WAS ISSUED TO HIM. SEE UAO NO. EPA-5-01- 113(A)-WI-3 FOR TERMS AND CONDITIONS.