BETWEEN MAY 1, 1989 AND APRIL 11, 1991, THE ROCKY FORD SUGAR FACTORY WAS DEMOLISHED BY TWO DIFFERENT DEMOLITION OPERATORS. DURING THIS PERIOD, THE PROPERTY CHANGED OWNERSHIP THREE TIMES. THE DEMOLITION WAS SUBSTANTIAL, INVOLVING THE PARTIAL DEMOLITION OF ONE 4 STORY BUILDING AND THE SALVAGE AND REMOVAL OF LARGE PIECES OF SUGAR PROCESSING EQUIPMENT FROM SEVERAL BUILDINGS. THE SALVAGED EQUIPMENT INCLUDED STAINLESS STEEL AND COPPER BOILERS, PIPES, TANKS, AND HOPPERS. MOST, IF NOT ALL, OF THIS EQUIPMENT WAS ORIGINALLY INSULATED WITH ASBESTOS INSULATION COVERED BY A FOIL OR CARDBOARD WRAP. DURING THE DEMOLITION, ASBESTOS INSULATION WAS REMOVED, RESULTING IN VERY LARGE QUANTITIES OF ASBESTOS WASTE. THE AMOUNT OF ASBESTOS INSULATION IN THE RFSF BEFORE DEMOLITION BEGAN WAS ESTIMATED TO BE 105,000 SQUARE FEET; AN ESTIMATED 90 CUBIC YARDS WERE DISPOSED OF BY DECEMBER 1990. THE ROCKY FORD STORAGE, INC. RESPONDENTS VIOLATED NUMEROUS NESHAPS AND CAA REGULATIONS. THE PROPOSED CIVIL PENALTY IS $8,466,000.