1/18/08 - NOTICE OF DETERMINATION ISSUED. BY LETTER DATED JULY 20, 2006, RESPONDENT NOTIFIED EPA THAT RESOPNDENT HAD DISCOVERED VIOLATIONS OF CAA SEC 609, NAMELY (1) FAILURE TO CERTIFY TO EPA THAT RESPONDENT HAD AND WAS USING APPROPRIATE REFRIGERANT RECYCLING OR RECOVERY EQUIPMENT; AND (2) THAT RESPONDENT HAD NOT OBTAINED OR RECORDED CAA SEC 609 TECHNICIAN TRAINING CERTIFICATION INFO. RESPONDENT ALSO PROVIDED EVIDENCE THAT IT HAS CORRECTED THE VIOLATIONS: (1) A COMPLETED US EPA REFRIGERANT RECOVERY OR RECYCLING DEVICE ACQUISITION FORM; AND (2) A LIST OF ITS CERTIFIED TECHNICIANS WITH CERTIFICATION NUMBERS. UNDER EPA'S ENFORCEMENT POLICY FOR CAA VIOLATIONS, A GRAVITY-BASED PENALTY OF $25,000 COULD HAVE BEEN ASSESSED FOR THESE NON-REPORTING VIOLATIONS.