NATURE OF CASE THIS IS A CIVIL ACTION AGAINST AN ASBESTOS REMOVAL CON- TRACTOR AND SIX SCHOOL DISTRICTS IN THE STATE OF WYOMING. THE ACTION IS PURSUANT TO SECTION 113(B) OF THE CLEAN AIR ACT, 42, U.S.C. 7413(B) AND SEEKS PENALTIES AND INJUNCTIVE RELIEF FOR FAILURE TO COMPLY WITH THE NOTIFICATION PROVISION OF THE NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAPS) FOR ASBESTOS, 40 C.F.R. SUBPART M, SECTION 61.140 ET SEQ., ARISING OUT OF THE RENOVATION OF 35 SCHOOL BUILDINGS IN WYOMING. CAUSE OF ACTION THIS ACTION ALLEGES THAT THE DEFENDANT ENERGY INSULATION, INC. (EII) REMOVED ASBESTOS FROM 35 SCHOOL BUILDINGS. BY REMOVING ASBESTOS THE RESPONDENT RENOVATED THE BUILDING AS DEFINED IN 40 C.F.R. SUBPART M, SECTION 61.141. THE BUILD- INGS CONTAINED MORE THAN 260 LINEAR FEET OR 160 SQUARE FEET OF FRIABLE ASBESTOS MATERIAL. THE ACTION ALLEGES THAT THE NOTIFICATION REQUIREMENTS OF NESHAPS ARE THEREFORE APPLICABLE TO THE RENOVATIONS, AND THAT DEFENDANT EII AND THE SIX SCHOOL DISTRICTS AS OWNERS OF THE BUILDING FAILED TO GIVE THE AGENCY ADVANCE NOTICE IN ALL 35 INSTANCES. ALL THE RENOVATION PROJECT OCCURRED OR WERE COMPLETED IN 1984. ALTHOUGH DEFENDANT EII HAS STATED THAT IT COMPLIED WITH THE REGULATIONS GOVERNING THE MANNER OF ASBESTOS REMOVAL, THE REGION HAS NO INDEPENDENT EVIDENCE TO