COMPLAINT FILED 8/25/98 PROPOSING A PENALTY OF $39,627.50 COMPLAINT ALLEGES: COUNT I RESPONDENT VIOLATED 40 C.F.R SECTION 82.34(A) (2) BY USING AN UNCERTIFIED TECHNICIAN TO PERFORM SERVICE OR REPAIR ON MVACS INVOLVING REFRIGERANT FOR CONSIDERATION. COUNT II RESPONDENT VIOLATED 40 C.F.R. SECTION 82.42 (A) BY REPAIRING OR SERVICING MOTOR VEHICLE AIR CONDITIONERS FOR CONSIDERATION WITHOUT SUBMITTING THE REQUIRED WRITTEN CERTIFICATION TO EPA. COUNT III RESPONDENT VIOLATION SECTION 612 OF THE ACT, 42 U.S.C. SECTION 7671K, AS IMPLEMENTED THROUGH 40 C.F.R. SECTION 82.17(D), BY INSTALLING HC-12A OR DURACOOL 12A INTO A MAVAC AS A SUBSTITUTE FOR CFC-12 WHILE REPAIRING OR SERVICING THE VEHICLES AT ITS FACILITY. CACO ISSUED 3/11/99, ASSESSING A PENALTY OF $2,000. RESPONDENT SHALL MAKE TWO PAYMENTS OF $1,000 PLUS 5% INTEREST AND A $15 HANDLING FEE ON THE SECOND PAYMENT.