THE DEFENDANTS ENGAGE IN DEMOLITION OPERATIONS. MANY OF THESE INVOLVE THE REMOVAL OF FRIABLE ASBESTOS MATERIALS AND, THEREFORE, NOTICE TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ( U.S. EPA ) IN ADVANCE OF THE COMMENCE- MENT OF THE OPERATIONS UNDER THE ASBESTOS NATIONAL EMISSION STANDARD FOR HAZARDOUS AIR POLLUTANTS ( NESHAPS ), 40 C.F.R. SECTION 61.140, ET SEQ. BETWEEN AUGUST 1984 AND NOVEMBER 1985, THE DEFENDANTS SUBMITTED 26 NOTICES OF ASBESTOS REMOVAL, FOR 28 DEMOLITION OPERATIONS. EACH NOTICE CONTAINED SOME DEFICIENCIES. FOR ONE OPERATION, DEFENDANT DEMOLISHED A BUILDING WITHOUT GIV- ING ANY NOTIFICATION TO U.S. EPA. A FINDING OF VIOLATION ( FOV ) WAS ISSUED, ADDRESSING EACH NOTICE. SEE ATTACHMENT 2. BASED UPON INFORMATION SUBMITTED PURSUANT TO THE SECTION 113 CONFERENCE, FOV COUNTS 3, 13, 15, 18, 20, 24 AND 26 WERE DELETED FROM THIS REFERRAL. THE 20 REMAINING COUNTS ARE SERIOUS ENOUGH TO MERIT INCLUSION IN THIS REFERRAL. THE BREAKDOWN OF TYPE OF VIOLATION, IN ORDER OF SEVERITY, IS LISTED BELOW. THE FOV COUNT IS CHARACTERIZED BY THE MOST MAJOR DEFICIENCY IN THE NOTICE. MOST NOTICES ALSO CONTAINED MINOR OMISSIONS OR DEFICIENCIES. PROPOSED RELIEF: PERMANENT INJUNCTION. CIVIL PENALTY OF AT LEAST $25,000.