BANK IV, THE OWNER OF A THREE STORY MULTI-FAMILY DWELLING LOCATED AT 101 NORTH 10TH STREET, INDEPENDENCE, KS, HIRED TAYLOR CRANE AND RIGGING, INC. TO UNDERTAKE DEMOLITION OF THE STRUCTURE. ON OR ABOUT MAY 6, 1991, THE DEMOLITION OPERATION WAS COMMENCED. DEFENDANTS VIOLATED THE NESHAP FOR ASBESTOR AS FOLLOWS: (1) DEFENDANTS FAILED TO NOTIFY EPA OF THEIR INTENTION TO DEMOLISH THE FACILITY PRIOR TO DEMOLITION; (2) DEFENDANTS FAILED TO INSPECT THE FACILITY FOR THE PERESENCE OF ASBESTOS PRIOR TO DEMOLITION; (3) DEFENDANTS FAILED TO REMOVE THE REGULATED ASBESTOS -- CONTAINING MATERIAL (RACM) FROM THE FACILITY BEING DEMOLISHED PRIOR TO DEMOLITION; AND (4) DEFENDANTS FAILED TO WET ALL RACM AND ENSURE THAT THE MATERIAL REMAINED WET UNTIL COLLECTED FOR DISPOSAL. REFERRAL SEEKS INJUNTIVE RELIEF REQUIRING DEFENDANT TO COMPLY WITH THE REGULATIONS IN FUTURE DEMOLITION/RENOVATION OPERATIONS AND PAYMENT OF A CIVIL PENALTY. WITHIN 30 DAYS AFTER ENTRY OF THE CONSENT DECREE, TAYLOR CRA NE SHALL PAY A CIVIL PENALTY IN THE AMOUNT OF $27,500. WITHIN 30 DAYS AFTER ENTRY OF THE CONSENT DECREE, BANK IV SHALL PAY A CIVIL PENALTY IN THE AMOUNT OF $127,500 IN FULL SATISFACTION AND SETTLEMENT OF THE CIVIL CLAIMS ALLEGED IN T HE COMPLAINT