COMPLAINT FILED 3/8/99 PROPOSING A PENALTY OF $19,250 COMPLAINT ALLEGES: RESPONDENT USED AN UNACCEPTABLE SUBSTITUTE REFRIGERANT IN TH E SERVICING OF AN MVAC. IN VIOLATION OF THE CAA SECTION 82.174(D). COUNT II RESPONDENT FAILED TO CERTIFY TO THE ADMINISTRATOR THAT RESPONDENT HAS ACQUIRED, AND IS PROPERLY USING, APPROVED EQUIPMENT AND THAT EACH INDIVIDUAL AUTHORIZED TO USE THE EQUIPMENT IS PROPERLY TRAINED AND CERTIFIED IN ACCORDANCE WITH 40 C.F.R. SECTION 82.40. IN VIOLATION OF SECTION 609(C).