THE NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUT- ANTS ( NESHAP ) FOR ASBESTOS WERE VIOLATED BY FAILURE TO COMPLY WITH NOTICE REQUIREMENTS, REMOVAL PROCEDURES, AND DISPOSAL REQUIREMENTS. SPECIFICALLY, IN JULY 1988 THE DE- FENDANTS CAUSED THE DEMOLITION OF BUILDINGS WITHOUT HAVING NOTIFIED EPA, IN VIOLATION OF 40 CFR SECT 61.146 AND WITHOUT HAVING ALL FRIABLE ASBESTOS MATERIALS REMOVED FROM THE FA- CILITY, IN VIOLATION OF 40 CFR SECT 61.147(A). IN ADDITION, THE DEFENDANTS DID NOT ENSURE THAT THE REMOVED FRIABLE AS- BESTOS REMAINED WET UNTIL THEY WERE COLLECTED FOR DISPOSAL, IN VIOLATION OF 40 CFR SECT 147(E). THE DEFENDANTS ALSO FAILED TO DEPOSIT ALL ASBESTOS-CONTAINING MATERIAL AT A WASTE DISPOSAL SITE OPERATED IN ACCORDANCE W/THE PROVISIONS OF SECT 61.156, IN VIOLATION OF 40 CFR SECT 61.152(A) AND DISCHARGED VISIBLE EMISSIONS TO THE OUTSIDE AIR DURING THE COLLECTION OF ASBESTOS CONTAINING MATERIAL, IN VIOLATION OF 40 CFR SECT 61.152(B). ON AUGUST 30, 1988 EPA ISSUED A COMPLIANCE ORDER TO HARDY, NEL TRADING, AND PYRAMID COMPANIES. ON SEPT 19, 1988 EPA ISSUED A COMPLIANCE ORDER TO ABE COOPER OF SYRACUSE, INC., AND ON JANUARY 25, 1989, EPA ISSUED A COMPLIANCE ORDER TO CONKLIN, LTD. THE ABOVE-MENTIONED ORDERS REQUIRED DEFENDANTS TO PERFORM SPECIFIC TASKS, INCLUDING CLEAN-UP OF THE SITE IN ACCORDANCE WITH A PLAN SUBMITTED BY THE DEFENDANT