THIS CASE ALLEGES VIOLATIONS OF THE ASBESTOS NESHAP BY INDUSTRIAL IRON WORKS CORP. (IIW), HAMAKUA SUGAR CO., INC., FIJI SUGAR CORPORATION LTD., AND R&D HAWAII, WHEN IIW REMOVED A BOILER AND ASSOCIATED PIPE. THE PIPE INSULATION CONTAINED ASBESTOS. THE FACILITY, A SUGAR REFINERY OWNED BY THE HAMAKUA SUGAR CO., INC., IS LOCATED IN O'OKALA, HAWAII. THE LITIGATION REPORT DOCUMENTS VIOLATIONS OF BOTH THE NOTIFICATION AND THE WORK PRACTICE REQUIREMENTS OF THE ASBESTOS NESHAP, REQUESTS AUTHORIZATION TO CONDUCT PRE-REFERRAL NEGOTIATIONS WITH THE DEFENDANT, AND RECOMMENDS CIVIL PENALTIES OF $36,500.