EPA DETERMINED THAT HALL TIRE AND AUTO LUBE SERVICE HAS FAILED TO COMPLY WITH 40 CFR SECTION 82.174(D). IN A LETTER TO EPA DATED 4/15/98, HALL TIRE STATED THAT HC-12(A) WAS INSTALLED INTO APPROX. 6 MVACS AS A SUBSTITUTE FOR CFC-12 WHICH SERVICING VEHICLES AT THE FACILITY. (HC-12(A) IS UNACCEPTABLE FOR USE AS A SUBSTITUTE FOR CFC-12 IN MVACS).