Agency adjudication did not have jurisdiction, since the two notices of violation were consolidated into a single civil claim in excess of the statutory maximum. The Federal courts have exclusive jurisdiction over claims with an amount in conttroversy in excess of the statutory maximum during the actual pendency of the civil proceeding.
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.