On August 5, 2002 and September 30, 2002, U.S. EPA filed administrative complaints against the City of Detroit, Department of Public Works (DPW) for violating the asbestos National Emission Standard for Hazardous Air Pollutants (NESHAP). The complaints alleged that DPW violated the asbestos NESHAP at various demolition sites withing the City of Detroit for which DPW was the owner or operator. In response to the administrative compliant, DPW agreed to hire an Asbestos Program Manager (APM) to monitor and manage all demolitions for which DPW is an owner or operator. DPW agreed to develop and implement a Standard Operating Procedure (SOP) for the demolition of structures. The injunctive relief is memorialized in the CCDS for Administrative Compliance Order. DPW also agreed to perform a Supplemental Environmental Project (SEP) involving the removal and proper disposal of illegally dumped debris which contains asbestos containing material at up to six sites within the City of Detroit. Because of DPW's good faith efforts to comply and the environmental improvements that will be achieved through implementation of the SEP, U.S. EPA reduced DPW's penalty to $7,000. The SEP and penalty are memorialized in the CCDS for the CAFO.