THE NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLU- TANTS ( NESHAP ) FOR ASBESTOS WERE VIOLATED BY FAILURE TO COMPLY WITH NOTICE REQUIREMENTS, REMOVAL PROCEDURES, AND DISPOSAL REQUIREMENTS. SPECIFICALLY, ON JUNE 17, 1988, THE DEFENDANTS WERE DEMOLISHING A BUILDING WITHOUT HAVING NOTIFIED EPA, IN VIOLATION OF 40 CFR 61.146 AND WITHOUT HAVING ALL FRIABLE ASBESTOS MATERIALS REMOVED FROM THE FACILITY, IN VIOLATION OF 40 CFR 61.147(A). IN ADDITION, THE DEFENDANTS FAILED TO ADEQUATELY WET THE FRIABLE ASBESTOS MATERIALS WHEN THEY WERE BEING STRIPPED FROM FACILITY COM- PONENTS BEFORE THE MEMBERS WERE REMOVED FROM THE FACILITY, IN VIOLATION OF 40 CFR 61.147(C), AND DID NOT ENSURE THAT THE REMOVED FRIABLE ASBESTOS MATERIALS REMAINED WET UNTIL THEY WERE COLLECTED FOR DISPOSAL, IN VIOLATION OF 40 CFR 61.147(E)(1). THE DEFENDANTS ALSO DISCHARGED VISIBLE EMISSIONS TO THE OUTSIDE AIR DURING THE COLLECTION OF ASBES- TOS CONTAINING MATERIAL, IN VIOLATION OF 40 CFR 61.152(B). EPA ISSUED A COMPLIANCE ORDER TO EACH OF THE DEFENDANTS ON JUNE 29, 1988. EPA SUBSEQUENTLY DOCUMENTED VIOLATIONS OF THE ORDERS AND SOUGHT RELIEF BY APPLYING FOR A TEMPORARY RESTRAINING ORDER (TRO) AND A PRELIMINARY INJUNCTION IN THE DISTRICT COURT OF NEW JERSEY. A PRELIMINARY INJUNCTION WAS GRANTED ON JULY 22, 1988. INJUNCTIVE RELIEF DIRECTING THE DEFENDANT TO SUBMIT TO EPA PLANS, SCHEDULES AND SITE CONTRACTS FO