THE BANK OF CANTON HIRED VALLEY CONSTRUCTION COMPANY TO DEMOLISH AN OLD HOTEL. VCC HIRED ASBESTOS CONTROL GROUP TO REMOVE ASBESTOS FROM THE BOILER ROOM OF THE HOTEL. VCC BEGAN DEMOLISHING THE HOTEL WITHOUT REMOVING MOST OF THE ASBESTOS CONTAINING MATERIAL. DEFENDANTS VIOLATED THE ASBESTOS NESHAP BY FAILING TO NOTIFY EPA OF THE DEMOLITION, AND FAILING TO REMOVE ASBESTOS PRIOR TO DEMOLITION, AND ALLOWING ASBESTOS CONTAINING DEBRIS TO DRY.