VIOLATION OF NESHAP FOR ASBESTOS--FAILURE TO ADEQUATELY WET FRIABLE ASBESTOS MATERIALS BEFORE BEING STRIPPED FROM FACIL- ITY COMPONENTS, AND FAILURE TO ENSURE THAT SUCH MATERIALS REMAINED WET UNTIL COLLECTED FOR DISPOSAL. IN VIOLATION OF 40 C.F.R. SECTION 61.147(C) AND (E) AND 42 U.S.C. SECTION 7412(C). VIOLATIONS OCCURRED DURING RENOVATION PROJECT AT PITTSBURGH STATE UNIVERSITY, PITTSBURGH, KS. VIOLATIONS ALSO CONSTITUTE VIOLATION OF ADMINISTRATIVE ORDER ISSUED TO DEFENDANT BY REGION ON 11/16/87, ORDERING DEFENDANT TO COM- PLY WITH ALL ASBESTOS NESHAP REQUIREMENTS AND SPECIFICALLY ORDERING DEFENDANT TO USE PROPER REMOVAL AND HANDLING PRO- CEDURES IN ALL RENOVATION OR DEMOLITION OPERATIONS. VIOLA- TION OF SUCH ADMINISTRATIVE ORDER IS A VIOLATION OF 42 U.S.C SECTION 7413. THE REGION PROPOSES TO ATTEMPT SETTLEMENT OF THIS MATTER THROUGH PRE-REFERRAL NEGOTIATION PROCESS, WITH A BOTTOM-LINE CIVIL PENALTY OF $10,000.