This is an Administrative Penalty action pursuant to the Clean Air Act. The violation involves improper asbestos disturbance and failure to notify of the disturbance as required by the asbestos NESHAP promulgated under Sections 112 and 114 of the Clean Air Act. Respondents Lance Gilman and Ralph Lynn d/b/a Lynn House Moving, failed to remove regulated asbestos-containing material from buildings at the Mustang Ranch, site of a former legal brothel, prior to cutting and moving the buildings to Wildhorse Canyon Ranch and Spa in Sparks, Nevada. The Respondents also failed to provide a written notice of demolition to EPA before undertaking such an activity. The Complaint seeks the statuatory maximum fine for an administrative action of $220.000.