THIS ACTION WAS FIRST INITIATED IN 1987. IT WAS TRANSFERRED TO DOJ FOR CRIMINAL ACTION. DOJ FINALLY DETERMINED AGAINST CRIMINAL ACTION AND SENT THE MATTER BACK TO EPA FOR CIVIL ACTION IN MAY 1991. THE CIVIL MATTERS WERE THEN RE-INITIATED IN MAY 1991. FACTS: ON 3 SEPARATE OCCASIONS PIRIE WAS OBSERVED VIOLATING OR TO HAVE VIOLATED ASBESTOS NESHAP REGULATIONS. PIRIE WAS WORKING UNDER CONTRACT FOR MCDONALDS ON A FACILITY MCDONALDS WAS LEASING FROM WA STATE DOT. ON ONE OF THOSE OCCASIONS IT WAS REPORTED THAT PIRIE HAD ALSO ENGAGED IN A CLEAN WATER ACT VIOLATION. EVIDENCE OF THE SAME WAS OBSERVED. THE ALLEGED VIOLATIONS OCCURRED IN THE SUMMER AND FALL OF 1987. CD WITH MCDONALDS WAS ENTERED ON AUGUST 26, 1992. CD WITH PIRIE WAS ENTERED ON AUGUST 9, 1993. CD WITH WASHINGTON DOT WAS ENTERED ON SEPTEMBER 29, 1993.