THIS IS A PROPOSED ACTION FOR CIVIL PENALTIES AND INJUNCTIVE RELIEF AGAINST CONSOLIDATED MINERALS, INC., CHARLESTON SHIPBUILDERS, INC. (CSI), AND ATLANTIC INSULATION AND REFRACTORY COMPANY, INC (AIRC) FOR VIOLATIONS OF THE NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) FOR ASBESTOS, 40 C.F.R. PART 61, SUBPART M. THE DEFENDANTS ARE OPERATORS OF AN ASBESTOS RENOVATION PROJECT CONDUCTED ABOARD THE USS ROBINSON IN CHARLESTON, SC. EPA IS ALLEGING THAT THE DEFENDANTS VIOLATED THE ASBESTOS NESHAP REGULATIONS BY: (1) FAILING TO THOROUGHLY INSPECT THE FACILITY WHERE THE RENOVATION OPERATION WOULD OCCUR; (2) FAILING TO ADEQUATELY WET THE ASBESTOS INSULATION DURING THE RENOVATION WORK TO PREVENT THE RELEASE OF ASBESTOS FIBERS INTO THE AIR; (3) FAILING TO ADEQUATELY WET THE ASBESTOS INSULATION DEBRIS THAT HAD BEEN REMOVED FROM THE PIPES UNTIL IT COULD BE PROPERLY DISPOSED OF; AND (4) FAILING TO ENSURE THAT NO DISCHARGE OF VISIBLE EMISSIONS TO THE OUTSIDE AIR WOULD OCCUR BY SEALING THE ASBESTOS-CONTAINING WASTE MATERIALS IN LEAK TIGHT CONTAINERS WHILE AWAITING DISPOSAL. THIS CASE IS NATIONALLY SIGNIFICANT FOR THE FOLLOWING REASONS. THE PENALTY PROPOSED IN THE REFERRAL IS $1,040,200. THE CASE INVOLVES THE REMOVAL OF ASBESTOS CONTAINING MATERIAL FROM A NAVAL VESSEL, THE USS ROBINSON, DOCKED AT THE CHARLESTON NAVAL SHIPYARD, A FACILITY AUTHORIZED FOR CLOSURE PURSUANT TO T