THIS REFERRAL INVOLVES THE FILING OF A CIVIL ACTION TO SEEK PENALTIES AND INJUNCTIVE RELIEF FOR VIOLATIONS OF THE WORK PRACTICE STANDARDS SET FORTH IN NESHAPS, 40 CFR, PART 61, SUBPART M. THE VIOLATIONS ALLEGED ARE BASED ON A RENOVATION PROJECT CONDUCTED AT THE TRIDENT SEAFOODS' FACILITY IN ANACORTES, WA THAT INVOLVED THE STRIPPING AND REMOVAL OF AT LEAST 3240 SQ FEET AND 104 LINEAR FEET OF FRIABLE ASBESTOS. THE ASBESTOS ABATEMENT PROJECT IN QUESTION WAS STARTED ON OR ABOUT 8/27/88 AND WAS COMPLETED ON OR ABOUT 9/2/88. DURING THIS TIME FRIABLE ASBESTOS-CONTAINING MATERIALS WERE STRIPPED AND REMOVED FROM 9 RETORTS AND VARIOUS PIPES IN 2 BUILDINGS ON THE FACILITY GROUNDS. CERTAIN PIPES AND THE 9 RETORTS WERE DISMANTLED, AND THE RETORTS WERE MOVED OUTSIDE. NO WRITTEN NOTIFICATION WAS GIVEN TO EITHER THE EPA OR THE NORTHWEST AIR POLLUTION CONTROL AGENCY PRIOR TO COMMENCING THE RENOVATION. WHILE WATER WAS APPARENTLY USED DURING THE REMOVAL OF THE ASBESTOS, A MONTH AFTER THE ABATEMENT WAS SUPPOSEDLY COMPLETED LARGE QUANTITIES OF DRY, FRIABLE ASBESTOS- CONTAINING MATERIAL WAS ALSO FOUND AT THAT TIME ON AND BENEATH RETORTS THAT HAD BEEN REMOVED FROM THE WAREHOUSE TO LOCATIONS OUTSIDE OF THE BUILDINGS. THE BUILDING HOLDING THE RETORTS IS SUPPORTED BY A PIER OVER THE GUEMES CHANNEL WATERWAY. DUR