THE DEFENDANT IS THE LITTLE ROCK SCHOOL DISTRICT (LRSD), WHICH OWNS AND OPERATES SOME FIFTY PUBLIC SCHOOL LOCATED IN PULASKI COUNTY, ARKANSAS. FOR THE 1989-1990 SCHOOL YEAR, THE DISTRICT HAD AN ENROLLMENT OF 26,500 STUDENTS, AND EMPLOYED 1,382 TEACHERS. ON MARCH 29, 1991, EPA TRANSMITTED A CIVIL LITIGATION REPORT TO THE DEPARTMENT OF JUSTICE AND THE OFFICE OF ENFORCEMENT CONCERNING ASBESTOS VIOLATIONS AT THE PANKY EXCEPTIONAL SCHOOL BETWEEN JULY, 1990 AND JANUARY, 1991 UNDER THE CLEAN AIR ACT AND THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION AND LIABILITY ACT. EPA HAS NO RECORD OF OTHER ENVIRONMENTAL ENFORCEMENT ACTIONS AGAINST LRSD. WATSON ELEMENTARY SCHOOL IS LOCATED AT 7000 VALLEY DRIVE IN LITTLE ROCK, ARKANSAS. WATSON ELEMENTARY SCHOOL WAS INSPECTED FOR ASBESTOS IN ACCORDANCE WITH THE REQUIREMENTS OF THE ASBESTOS HAZARD EMERGENCY RESPONSE ACT (AHERA), BY MORRIS AND ASSOCIATES, CONTRACTORS FOR THE LITTLE ROCK SCHOOL DISTRICT. ACCORDING TO THE SEPTEMBER 5, 1988 AHERA COMPLIANCE INSPECTION REPORT, THE FLOOR AREA OF THE BUILDING IS 53,846 SQUARE FEET. THERE WAS 2' X 4' LAY-IN CEILING TILE THROUGHOUT THE BUILDING, EXCEPT FOR THE KITCHEN, MECHANICAL ROOM, AND TOILETS. VINYL ASBESTOS FLOOR TILE WAS PRESENT THROUGHOUT THE BUILDING. TWO SAMPLES OF THE CEILING TILE COLLECTED ON SEPTEMBER 5,