THIS ADMINISTRATIVE PENALTY ORDER IS ISSUED TO CIRCUIT CITY FOR USING A TECHNICIAN WHO WAS NOT CERTIFIED BY AN APPROVED TECHNICIAN PROGRAM; FOR FAILURE TO KEEP COPIES OF CERTIFICATIONS AT THEIR PLACE OF BUSINESS; FOR FAILURE TO CERTIFY TO THE ADMINISTRATOR THAT IT HAD ACQUIRED CERTIFIED RECOVERY OR RECYCLING EQUIPMENT; AND FOR VENTING OR OTHERWISE RELEASING INTO THE ENVIRONMENT A CLASS I OR CLASS II SUBSTANCE USED AS A REFRIGERANT. THE PROPOSED PENALTY FOR THESE VIOLATIONS IS $177,600.