THE NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POL- LUTANTS ( NESHAP ) FOR ASBESTOS WERE VIOLATED BY FAILURE TO COMPLY WITH REMOVAL PROCEDURES. SPECIFICALLY, IN JULY, AUGUST AND SEPTEMBER, 1991, DEFENDANTS CAUSED THE DEMOLITION OF A BUILDING. DURING THE DEMOLITION, DEFENDANTS FAILED TO WET REGULATED ASBESTOS CONTAINING MATERIAL ( RACM ) DURING STRIPPING OPERATIONS, IN VIOLATION OF 40 CFR SECTION 61.145(C)(3), FAILED TO MAINTAIN RACM WET UNTIL COLLECTED FOR DISPOSAL, IN VIOLATION OF 40 CFR SECTION 61.145(C) (6) (I), AND FAILED TO LABEL CONTAINERS OR WRAPPED MATERIALS WITH THE NAME OF THE WASTE GENERATOR AND THE LOCATION AT WHICH THE WASTE WAS GENERATED. ON 10/16/91, EPA ISSUED COMPLIANCE ORDERS TO CERTIFIED ABATEMENT TECHNOLOGIES, INC AND COOPER INDUSTRIES, INC. THE ORDERS REQUIRED DEFENDANTS TO CEASE VIOLATION OF AND TO COMPLY WITH ALL APPLICABLE PROVISIONS OF 40 CFR PART 61, SUBPART M AT THIS FACILITY AND ANY FACILITY WHERE FRIABLE ASBESTOS IS PRESENT. THE PROPOSED RELIEF TO BE SOUGHT IS AN INJUNCTION DIRECTING DEFENDANTS TO COMPLY WITH REGULATIONS GOVERNING ASBESTOS DEMOLITIONS AND RENOVATIONS AND TO COLLECT PENALTIES IN THE AMOUNT OF $50,000, BASED UPON EPA'S ASBESTOS DEMOLITION AND RENOVATION CIVIL PENALTY POLICY DATED 8/22/89. RECENT CONTACTS WITH THE DEFENDANTS