THE FACILITY IS A FORMER WINERY CURRENTLY OWNED BY DEFENDANT, DIVIDEND DEVELOPMENT CORPORATION AND OWNED BY DIVIDEND AT THE TIME THE VIOLATIONS OCCURRED. DURING THE WEEKEND OF JULY 30, 1988, ELEVEN WINE VATS, FOUR OF WHICH WITH ASBESTOS ATTACHED TO THEIR BOTTOMS AND UNDERLYING PADS, WERE AIR LIFTED BY HELICOPTER FROM THE FACILITY, RESULTING IN DEPOSITION OF ASBESTOS DEBRIS IN THE SURROUNDING NEIGHBORHOOD. THIS ACTIVITY WAS CONDUCTED WITHOUT PRIOR NOTICE TO EPA OR THE STATE AND IN VIOLATION OF THE WORK PRACTICE PROCEDURES SET FORTH IN 40 C.F.R. PART 61.