THE OUTRIGGER REEF HOTEL ( THE FACILITY ) HAS 19 FLOORS AND 885 UNITS, AND IS LOCATED IN HONOLULU, HAWAII. THE FACILITY IS OWNED BY DEFENDANT OUTRIGGER HOTELS HAWAII, A LIMITED PARTNERSHIP. IN AUGUST 1990, DEFENDANT OUTRIGGER SERVICES, INC., A CLEANING AND MAINTENANCE FIRM THAT WORKS FOR OUTRIGGER HOTELS HAWAII, STRIPPED APPROXIMATELY 1,440 SQUARE FEET OF FRIABLE ASBESTOS-CONTAINING MATERIAL FROM THE FLOOR OF A STORAGE ROOM AND LAUNDRY ROOM AT THE FACILITY DEFENDANTS FAILED TO NOTIFY EPA OR THE STATE OF HAWAII ABOUT THIS RENOVATION IN VIOLATION OF 40 C.F.R. 61.146. IN ADDITION, AN INSPECTION BY THE STATE OF HAWAII REVEALED THAT DEFENDANTS STRIPPED THE ASBESTOS-CONTAINING MATERIAL WITHOUT ADEQUATELY WETTING IT, AND FAILED TO KEEP THE MATERIAL WET UNTIL COLLECTED FOR DISPOSAL IN VIOLATION OF 40 C.F.R. 61.147 (C) AND (E).