THIS ACTION SEEKS INJUNCTIVE RELIEF & CIVIL PENALTIES AGAINST AN ASBESTOS MANUFACTURING FACILITY, RAYMARK INDUSTRI AL DIVISION, FOR VIOLATIONS OF THE NAT'L EMISSION STD FOR ASBESTOS, FOUND AT 40 CFR PART 61 SUBPART M, WHICH OCCURRED DURING THE MANUFACTURING & TRANSPORTING OF ASBESTOS-CONTAIN- ING MATERIALS. RAYMARK INDUSTRIAL DIVISION IN STRATFORD, CT EMPLOYS 600 PEOPLE IN THE PROD'N OF BRAKE SHOES & SPECIALTY PRODUCTS SUCH AS GASKETS & CLUTCH PADS, SOME OF WHICH CON- TAIN ASBESTOS. BETWEEN 1971 & JAN 1, 1984, RAYMARK CORP HAS BEEN A DEFENDANT OR CODEFENDANT IN 14,963 LAWSUITS ALLEGING INJURY &/OR DEATH FROM EXPOSURE TO ASBESTOS FIBERS IN THE AIR. ON OCT 22, 1984, EPA ISSUED AN ADMINISTRATIVE ORDER A- GAINST RAYMARK FOR RCRA VIOLATIONS. RAYMARK SIGNED A CON- SENT AGREEMENT W/EPA IN JUNE 1985, IN WHICH THEY AGREED TO CORRECT THE RCRA VIOL'S & PAY A CIVIL PENALTY. THE CONN DEP HAS FOUND RAYMARK IN VIOL OF STATE REGS 20 TIMES DURING THE LAST 2 YRS. NUMEROUS CITIZEN COMPLAINTS HAVE ALSO BEEN MADE TO EPA CONCERNING ODORS & PARTICULATE EMISSIONS COMING FROM THE STRATFORD FACILITY. VIOLATIONS: ON 3/7/84, 2 CT DEP INSPECTORS OBSERVED VISIBLE EMIS- SIONS OF WHITE PARTICULATE MATERIALS INTO THE OUTSIDE AIR AT THE STRATFORD FACILITY. THEY OBSERVED THAT THIS DUST ORIGI- NATED FROM A BAGHOUSE OR FABRIC FILTER WH