JUDICIAL REFERRAL SEEKING INJUNCTIVE RELIEF AND CIVIL PENALTIES FOR VIOLATIONS OF THE ASBESTOS NESHAP, 40 CFR, PART 61, SUBPART M. SUCH RELIEF IS AUTHORIZED BY SEC 112 & 113(B) OF CAA, 42 USC, PARTS 7412 & 7413(B). DEFENDANTS REMOVED FRIABLE ASBESTOS MATERIAL FROM THE COLEMAN FERRY TERMINAL (PIER 52 IN SEATTLE, WA OWNED BY WA DOT, HEAVILY USED BY THE PUBLIC) WITHOUT SUBMITTING PRIOR WRITTEN NOTIFICATION TO EPA, OR TO THE DELEGATED LOCAL AGENCY, PSAPCA. THIS FAILURE TO NOTIFY VIOLATED 40 CFR, PART 61.146. DEFENDANTS ALSO FAILED TO USE PROPER WORK PRACTICES IN REMOVING THE ASBESTOS MATERIAL FROM THE FERRY TERMINAL, 40 CFR, PART 61.147, AND IN COLLECTING THE MATERIAL FOR DISPOSAL, 40 CFR, PART 61.152(B). THE VIOLATIONS OCCURRED IN THE WINTER AND SPRING OF 1985.