FMC CORPORATION RETAINED MARSHALL PRICKETT GENERAL CONTRAC- TOR, INC. (MARSHALL PRICKETT) TO REMOVE ASBESTOS-CONTAINING FLOOR TILE FROM A BUILDING LOCATED AT FMC'S STEEL PRODUCT DIVISION FACILITY IN ANNISTON, CALHOUN COUNTY, ALABAMA. FROM JANUARY 2-4, 1991, MARSHALL PRICKETT REMOVED APPROXIMATELY TEN THOUSAND SQUARE FEET OF ASBESTOS-CONTAINING MATERIAL (AMC) FROM FMC'S TWO STORY STRUCTURE COMMONLY REFERRED TO AS THE MECHANICSVILLE SCHOOL. PRIOR TO THE RENOVATION PROJECT AS REQUIRED BY REGULATION, MARSHALL PRICKETT NOTIFIED THE ALABAMA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT (ADEM) OF THE PLANNED ASBESTOS ABATEMENT PROJECT. HOWEVER, THIS NOTIFICA- TION DID NOT CONTAIN ALL OF THE INFORMATION REQUIRED UNDER APPLICABLE REGULATIONS. ON JANUARY 4, 1991, WHICH WAS THE THIRD AND FINAL DAY OF THE DEFENDANTS, FLOOR TILE REMOVAL PROJECT, ADEM COMPLIANCE IN- SPECTOR, PARTHA P. GHOSH, CONDUCTED AN UNANNOUNCED INSPEC- TION OF THE FMC FACILITY. DURING HIS INSPECTION, HE NOTED SEVERAL VIOLATIONS OF ASBESTOS REMOVAL WORK STANDARDS WHICH ARE CONTAINED IN APPLICABLE FEDERAL REGULATIONS. ADEM THERE- AFTER NOTIFIED REGION IV OF THE CASE AND INDICATED THE STATES RELUCTANCE AND/OR INABILITY TO PURSUE FURTHER ENFORCE MENT ACTIONS. REGION IV HAS DETERMINED THAT FMC AND MARSHALL PRICKETT VIO- LATED THE NESHAP FOR ASBESTOS, WHICH ARE CODIFIED AT 40 CFR PART 61, SUBPART M. IN PARTICULAR, R