'Complaint filed 9/23/2002, proposing a penalty of $222,200. Respondent failed to provided written notice of intention to the Administrator at least ten days prior to the commencement of the renovation. Count II - Respondent failed to remove the asbestos before engaging in activities that caused the RACM to be disturbed. Count III - adequately wet the RACM during cutting and disjoining operation. Count IV - Respondent failed to ensure that the RACM remain wet until collected and contained or treated in preparation for disposal. Count V - Respondent failed to ensure that there wer no visible emissions to the outside during the collection, processing or transporting of the asbestos containing material, through the use of emissions control waste treatment specified in 40 C.F.R. ? 61.140(a)(1) through (4). Count VI - Respondent failed to have at least one person adequately trained in compliance with the asbestos NESHAP regulations present at the facility during the disturbance of the RAC