The EPA identified about 138,000 square feet of asbestos containing materials in these structures with asbestos concentrations inside exceeding 1%. Much of the asbestos materials on or in the buildings had migrated outside, caused in part by continued trespass, attempts by owners to reclaim scrap metal inside the buildings, and by animal infestation. The EPA issued an Action Memorandum for cleanup of asbestos contamination at the Property on April28, 2011, and requests for ceiling increases on March 16, 2012 and August 31, 2012. The EPA began removal work at the Property on April 28, 2011 and completed this work in April of 2013