THIS REFERRAL SEEKS CIVIL PENALTIES FOR VIOLATIONS OF THE NATIONAL EMISSION STANDARD FOR ASBESTOS (NESHAPS), 40 CFR, PART 61 PROMULGATED PURSUANT TO SECTION 112 OF CAA. FRIABLE ASBESTOS MATERIALS WERE DEMOLISHED AND REMOVED FROM WILLARD HALL, WITHOUT PRIOR SUBMISSION TO EPA OF WRITTEN NOTICE OF INTENTION TO DEMOLISH, AS REQUIRED BY 40 CFR, 61.146. IN ADDITION, THE FRIABLE ASBESTOS MATERIALS WERE NOT ADEQUATELY WETTED, AS REQUIRED BY 40 CFR, 61.147. FINALLY, VIABLE EMISSIONS WERE DISCHARGED TO THE OUTSIDE AIR DURING COLLECTION, AND PROPER DISPOSAL METHODS WERE NOT USED, IN VIOLATION OF 40 CFR, 61.152. THESE VIOLATIONS OF SECTION 112 OF CAA SUBJECT THE VIOLATORS TO CIVIL PENALTIES UNDER 113(B) OF CAA. ON 2/11/86, AN ONGOING DELMOLITION AND REMOVAL PROJECT WAS REPORTED TO THE IDAHO OPS OFFICE OF EPA. THE PROJECT INVOLVED A BUILDING CALLED 'WILLARD HALL' LOCATED IN NAMPA, ID. EPA INSPECTORS VISITED THE PROJECT 2/11/86 AND 2/13/86, AND BASED ON SAMPLING, PHOTOGRAPHS, OBSERVATIONS AND MEASUREMENTS TAKEN AT THAT TIME, IT HAS BEEN DETERMINED THAT OVER 300 LINEAR FEET OF PIPE INSULATION CONTAINING ASBESTOS HAD BEEN REMOVED FROM WILLARD HALL WITHOUT BEING PROPERLY WETTED, BAGGED, OR PACKAGED. IN ADDITION, NO NOTIFICATION HAD BEEN RECEIVED BY EPA PRIOR TO THE START-UP OF THE PROJECT. AFTER EPA INSPECTORS INFORMED THE PROJECT OPERATOR OF THE HAZARDOUS CONDITIONS,