THE VIOLATIONS UPON WHICH THE ACTION IS BASED NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS ( NESHAP ) FOR ASBESTOS WERE VIOLATED BY FAILURE TO COMPLY WITH ONE NOTIFICATION AND THREE WORK PRACTICE STANDARDS AT A HOTEL RENOVATION AT 16 PARK PLACE, NEWARK, NEW JERSEY. THE FOUR NESHAP VIOLATIONS INCLUDED: 1) FAILURE TO PROVIDE EPA WITH WRITTEN NOTIFICATION OF INTENTION TO RENOVATE THE BUILDING, IN VIOLATION OF SECTION 61.146; 2) ON 10/9/87, A VIOLATION OF SECTION 61.147 FOR FAILURE TO REMOVE FRIABLE ASBESTOS MATERIALS FROM THE FACILITY BEFORE DISMANTLING OR WRECKING, IN VIOLATION OF SECTION 61.147(A); ON 10/9/87, 7/11/88, 7/29/88 AND 8/5/88 AND POSSIBLY ON THE DATES IN BETWEEN FAILURE TO WET ADEQUATELY MATERIALS STRIPPED OR REVOVED FROM FACILITY/STRUCTURAL COMPONENTS AND TO ENSURE THAT THEY REMAINED WET UNTIL COLLECTED FOR DISPOSAL, IN VIOLATION OF SECTION 61.147(C) AND (E)(1); ON 10/9/87 FAILURE TO CAREFULLY LOWER THE ASBESTOS MATERIAL TO THE GROUND WITHOUT DROPPING OR THROWING IT, IN VIOLATION OF SECTION 61.147(E); 2) ON 10/9/87 FAILURE TO TRANSPORT THE MATERIALS TO THE GROUND VIAL DUST-TIGHT CHUTES OR CONTAINERS IN VIOLATION OF 6.147(E)(3); 3) ON 10/9/87 AND POSSIBLY ON THE DAYS LEADING UP TO 7/11/88 FOR DISCHARGING VISIBLE EMISSIONS TO THE OUTSIDE AIR DURING OLLECTION AND TRANS- PORTATION OF ASBESTOS-CONTAINING MATERIAL FROM THE RENOVA- TION SITE, IN VIOLATION OF 61.152(B);