THE VIOLATIONS UPON WHICH THE ACTION IS BASED. FAILURE TO NOTIFY STATE AND EPA OF RENOVATION PROJECT, FAILURE TO FOLLOW PROPER WORK PRACTICES, AND FAILURE TO PROPERLY DISPOSE OF ASBESTOS-CONTAINING MATERIALS. * THE PROPOSED RELIEF TO BE SOUGHT, INCLUDING INJUNCTION, AND PROPOSED AMOUNT OF PENALTY TO BE SOUGHT AT SETTLE- MENT, IF APPLICABLE. WE ARE REQUESTING A CIVIL PENALTY SETTLEMENT AMOUNT OF $340,004, ALONG WITH INJUNTIVE RELIEF ORDERING THAT THE REMAINING FRIABLE ASBESTOS CONTAINING MATERIAL BE REMOVED AND DISPOSED OF IN ACCORDANCE WITH THE REGULATIONS AT 40 CFR 61.140 ET SEQ. * SIGNIFICANT NATIONAL OR PRECEDENTIAL LEGAL OR FACTUAL ISSUES. SOUTHGLENN MALL IS THE FIRST SHOPPING MALL IN THE COUNTRY TO BE SHUT DOWN FOR ASBESTOS CONTAMINATION. THE CLOSURE OCCURRED PURSUANT TO STATE ORDER. * ANY OTHER ASPECT OF THE CASE WHICH IS SIGNIFICANT OR SHOULD BE HIGHLIGHTED, INCLUDING ANY EXTRAORDINARY RESOURCE DEMANDS WHICH THE CASE MAY REQUIRE. THE NESHAP VIOLATIONS OCCURRED IN A LARGE PUBLIC SHOPPING MALL WITH ATTENDANT EARLY PUBLIC EXPOSUR