PRE-REFERRAL TO JUSTICE ON JUNE 28, 1996 REQUESTING THEIR CONCURRENCE FOR THE REGION TO COMMENCE SETTLING NEGOTIATIONS WITH THE PROPOSED DEFENDANTS PRIOR TO FORMALLY REFERRING THE CASE TO JUSTICE. THE HPD CONTRACTED WITH EACH NAMED CONTRACTOR TO RENOVATE OR DEMOLISH AT LEAST ONE COMMERCIAL OR APPLICABLE RESIDENTIAL BLDG, AND FAILED TO NOTIFY EPA REGION II EITHER BEFORE OR AFTER COMPLETION OF DEMOLITATIONS IN VIOLATION OF SECTION 112 AND 114 OF THE CAA AND AS REQUIRED BY 40 C.F.R. SECTION 61.145(B). THE REGION PROPOSES AN INJUNCTION MANDATING THAT ANY AND ALL SUBSEQUENT ACTIVITIES BY THE DEFENDANTS BE ACCOMPLISHED IN ACCORDANCE WITH THE APPLICABLE SECTION OF THE ASBESTOS NESHAP, 40 CFR PART 61 SUBPART M AND APPROPRIATE CIVIL PENALTIES FOR PAST VIOLATIONS THEREOF. * THERE ARE 16 DEFENDANTS 15 ARE CONTRACTORS TO NYC HPD. * 06/28/96 - PRE-REFERRAL PACKAGE SENT. 05/27/99 - REQUEST FOR CONCURRENCE IN SETTLEMENT RE NYCHPD TO RA AND TO DISMISS THE CONTRACTORS. -EPA DETERMINED THAT THE CONTRACTORS WERE LESS CUPABLE. THE THE ACTION AGAINST THE CONTRACTORS WAS DISMISSED. EACH CONTRACTOR WAS ISSUED AN ADMINISTRATIVE ORDER REQUIRING FUTURE COMPLIANCE WITH NESHAP.