THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY (U.S. EPA) IS TRANSMITTING TO THE DEPARTMENT OF JUSTICE A LITIGATION REPORT THAT DOCUMENTS VIOLATIONS OF THE NATIONAL EMISSION STANDARD FOR HAZARDOUS AIR POLLUTANTS FOR ASBESTOS ( ASBESTOS NESHAP ) AND THE CLEAN AIR ACT, 42 U.S.C. SECTION 7041 ET. SEQ. ( THE ACT ), BY PERFORMANCE ABATEMENT SERVICES , INC. ( PAC ), RUDOLPH / LIBBE ), INC. ( RUDOLPH/LIBBE ), AND PARKE DAVIS PHARMACEUTICAL RESEARCH DIVISION OF WARNER- LAMBERT COMPANY ( PARKE DAVIS ). SECTION 113(B) OF THE ACT AUTHORITY THE UNITED STATES TO INITIATE A CIVIL ACTION TO ABATE VIOLATIONS AND TO SEEK CIVIL PENALTIES. THE ENCLOSED LITIGATION REPORT DOCUMENTS VIOLATIONS OF THE ASBESTOS NESHAP, 40 C.F.R., PART 61, SUBPART M, WHICH OCCURRED DURING A RENOVATION OPERATION AT BUILDING 20 OWNED BY PARKE DAVIS. PAS WAS THE ASBESTOS REMOVAL CONTRACTOR, AND RUDOLPH /LIBBE WAS THE OVERSIGHT CONTRACTOR. ON MARCH 31, 1993, THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY , REGION 5, EASTERN DISTRICT OFFICE, NCSC ENVIRONMENTAL ENGINEER, INSPECTED BUILDING 20 IN ORDER TO DETERMINE COMPLIANCE WITH THE ASBESTOS NESHAP. THE INSPECTOR OBSERVED VIOLATIONS OF THE WORK PRACTICE REQUIREMENTS OF 40 C.F.R. SECTION 61.145. THE ASBESTOS NESHAP WAS PROMULGATED UNDER THE AUTHORITY OF SECTION 112 OF THE ACT, 42 U.S.C. SEC