ALLEGED VIOLATIONS OCCURRED WHEN CHUGACH ELEC ENTERED INTO A SUBLEASE WITH HOBBS INDUSTRIES. AS REQUIRED BY THE SUBLEASE, HOBBS WAS RENOVATING THE KNIK ARM POWER PLANT IN ANCHORAGE, AK. HOBBS HIRED MARTECH USA TO REMOVE ASBESTOS FROM: 1) THE COAL UNLOADING AREA (CAR SHOP); 2) ALL OTHER AREAS. AFTER MARTECH FINISHED ITS WORK UNDER TWO CONTRACTS, IT RETURNED TO THE POWER PLANT, ON A TIME-AND-MATERIALS BASIS, TO REMOVE ADDITIONAL ASBESTOS CONTAINING MATERIAL EXPOSED DURING REMOVAL OF FOUR BOILERS BY INDUSTRIAL POWER CONTRACTORS. THE ASBESTOS REMOVAL OF THE COAL AREA INVOLVED STRIPPING AND REMOVAL OF AT LEAST 21,625 SQUARE FEET AND 320 LINEAR FEET OF FRIABLE ASBESTOS. THE REMOVAL IN THE REST OF THE POWER PLANT INVOLVED AT LEAST 40,000 SQUARE FEET AND 100,000 LINEAR FEET OF FRIABLE ASBESTOS. ON 9/14/89 AN EPA INVESTIGATOR INSPECTED THE CAR SHOP FOR COMPLIANCE WITH NESHAPS. BECAUSE THE INSPECTOR SAW WORKERS USING WET METHODS OF ASBESTOS REMOVAL, THE CAR SHOP WORK IS NOT THE BASIS OF ANY ALLEGATIONS OF IMPROPER WORK PRACTICES. 0N 2/6/90 AN EPA EMPLOYEE INSPECTED THE SECOND PHASE OF ASBESTOS REMOVAL. THE INSPECTOR SAW LARGE QUANTITIES OF DRY, FRIABLE ASBESTOS ON THE FLOOR, EQUIPMENT, AND ON NEARLY ALL HORIZONTAL SURFACES; AIRBORNE DUST. INSTEAD OF USING THE AVAILABLE PLYWOOD CHUTE, A MARTECH WORKER DROPPED DRY, FRIABLE ASBESTOS THROUGH A FLOOR GRA