RESPONDENT IS AN ABATEMENT CONTRACTORS. ON JANUARY 17, 1992, RESPONDENT BEGAN AN ASBESTOS REMOVAL AT THE FIRST NATIONAL BANK. ON JANAUARY 22, A U.S. EPA INSPECTOR OBSERVED VIOLATIONS OF THE ASBESTOS NESHAP AND EPA ISSUED A CEASE AND DESIST ORDER. ON MAY 20, 1992, U.S. EPA ISSUED AN ADMINISTRATIVE PENALTY ORDER FOR VIOLATIONS OF THE ASBESTOS NESHAP. AS WELL AS VIOLATIONS OF THE ADMINISTRATIVE ORDER.