ON APRIL 11-12, 1987, DAVID BOWEN, A CARPENTER WITHOUT ASBESTOS TRAINING, REMOVED A TEXTURED CEILING CONTAINING ASBESTOS ON THE FIRST FLOOR OF A COMMERCIAL BUILDING AT 570 PRICE AVENUE IN REDWOOD CITY. THIS REMOVAL VIOLATED THE ASBESTOS NATIONA EMISSION STANDARD FOR HAZARDOUS AIR POLLUTANTS (NESHAP) UNDER SECTION 112 OF THE CLEAN AIR ACT. BOWEN WAS HIRED BY GLENN WILLIAMS, AN INSURANCE AGENT, WHO WAS IN THE PROCESS OF BUYING THE BUILDING FROM MONTEREY INVESTMENTS (MONTEREY). THE GENERAL PARTNER OF MONTEREY, WILLIAM RELLER, HAD APPROVED THE RENOVATION. AT THE TIME OF THE RENOVATION THE BUILDING WAS IN ESCROW. ALL OF THE PARTIES INVOLVED CLAIM THEY DID NOT KNOW THE CEILING CONTAINED ASBESTOS, AND NONE OF THE ASBESTOS NOTIFICATION, WORK PRACTICE OR DISPOSAL REQUIREMENTS WERE FOLLOWED. A TENANT AT 570 PRICE, WILLIAM YOUNG, CALLED THE SAN MATEO COUNTY ENVIORNMENTAL HEALTH DEPARTMENT ABOUT THE RENOVATION ON APRIL 13. THAT AGENCY BEGAN THE INVESTIGATION BUT HAS NOT YET FILED ANY CHARGES. THE BAY AREA AIR QUALITY MANAGEMENT DISTRICT (BAAQMD), THE LOCAL AGENCY RESPONSIBLE FOR ADMINISTERING THE ASBESTOS NESHAP PROGRAM, DID NOT INVESTIGATE. WILLIAMS ARRANGED FOR AN ASBESTOS CONTRACTOR, ABMS, TO CLEAN UP THE SITE ONCE HE WAS INFORMED THAT THE AREA CON- TAINED ASBESTOS. APPARENTLY, RELLER PAID FOR THE CLEAN UP. SINCE NO ASBESTOS REMAINS ON SITE, THI