NATURE OF THE CASE CABOT CORPORATION OWNS AND OPERATES A FURNACE PROCESS CARBON BLACK FACILITY IN ST. MARY PARISH NEAR CENTERVILLE, LA. CABOT & ITS CONTRACTOR, HOTCO INSULATION OF FRANKLIN LA., CONDUCTED A RENOVATION PROJECT TO REMOVE INSULATION FROM AN OVERHEAD PIPE RACK. THE PROJECT WAS SUBJECT TO THE REQURIEMENTS OF THE NAT'L EMISSION STANDARDS FOR THE HAZAR- DOUS AIR POLLUTANT ASBESTOS. REGION VI REQUESTS CIVIL SUIT FOR PENALTIES AND INJUNCTIVE RELIEF PURSUANT TO SECTION 113B OF THE CAA FOR FAILURE TO COMPLY WITH THOSE REQUIREMENTS. CAUSE OF ACTION DURING AN INSPECTION BY THE STATE OF LA AND EPA ON 3/8/83, INSPECTORS OBSERVED A RENOVATION PROJECT INVOLVING REMOVAL OF APPARENT ASBESTOS-CONTAINING MATERIAL FROM AN OVERHEAD PIPE RACK. CABOT HAD FAILED TO SUBMIT THE REQUIRED NOTICE OF ITS INTENTION TO RENOVATE PRIOR TO COMMENCEMENT OF THE PROJECT. CABOT AND ITS CONTRACTOR ALSO FAILED TO WET THE FRIABLE ASBESTOS DURING THE STRIPPING OPERATION. IN A 1978 CASE, THE SUPREME COURT HELD THAT PARTS OF THE ASBESTOS NESHAP IN THE FORM OF WORK-PRACTICE STANDARDS WERE NOT EMISSION STANDARDS WITHIN THE MEANING OF SECTION 112. ?ADAMO WRECKING CO. V. US, 434 U.S. 275 (1978)! CABOT AND HOTCO ARE BEING CITED ONLY FOR PROVISIONS OF THE REGULATION WHICH WERE NOT AFFECTED BY THE ADAMO CASE, OR WHICH WERE REPROMULGATED AFTER THE 1977 AMENDMENTS T