ON JUN. 27, 1992, EPA REGION 6 COMMENCED AN INSPECTION OF DOW CHEMICAL COMPANY'S MANUFACTURING COMPLEX LOCATED IN FREE, TX. (DOW-FREEPORT COMPLEX). THE THREE WEEK INSPECTION REVIEWED THE COMPANY'S COMPLIANCE WITH THE CLEAN AIR ACT, CLEAN WATER ACT, AND THE TOXIC SUBSTANCES CONTROL ACT. THE ONLY VIOLATIONS IDENTIFIED BY EPA REGION 6 THAT REQUIRE A FORMAL ENFORCEMENT RESPONSE RELATE TO THE CLEAN AIR ACT. THE EPA INSPECTORS IDENTIFIED SEVERAL APPARENT VIOLATIONS OF SECTIONS 111 AND 112 OF THE ACT RELATING TO DOW'S BENZENE PRODUCTION OPERATIONS AND DOW'S ASBESTOS HANDLING PRACTICES; HOWEVER, THE NON-ASBESTOS RELATED VIOLATIONS HAVE BEEN RE- FERRED TO THE TEXAS NATURAL RESOURCE CONSERVATION COMMISSION FOR FURTHER ENFORCEMENTACTION. THE ASBESTOS VIOLATIONS WHICH ARE BEING ADDRESSED HEREIN RE- LATE TO DOW'S PRODUCTION OF CHLORINE UTILIZING ASBESTOS DIA- PHRAGM TECHNOLOGY, VARIOUS DEMOLITION ACTIVITIES AT THE DOW- FREEPORT COMPLEX SINCE NOV. 1990, AND DOW'S ASBESTOS WASTE HANDLING PRACTICES. ALL OF THE VIOLATIONS WHICH ARE BEING REFERRED TO DOJ CONCERN VIOLATIONS OF SECTIONS 112 AND 114 OF THE ACT, AND THE NATIONAL EMISSION STANDARDS FOR HAZARD- OUS AIR POLLUTANTS FOR ASBESTOS (ASBESTOS NESHAP) REGULA- TIONS FOUND AT 40 C.F.R. PART 61, SUBPART M. ONE OF THE VIOLATIONS OBSERVED DURING THE EPA INSPECTION INVOLVES A FAILURE TO FOLLOW THE REQUIRED ASBESTOS NESHAP WORK PRAC- TICE REQUIREMENTS WHILE DEMOLISHING