COMPLAINT FILED 9/1/98 PROPOSING A PENALTY OF $15,015 COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO USE A CERTIFIED TECHNICIAN TO PERFORM SERVICE, MAINTENANCE, REPAIR AND/OR DISPOSAL OF APPLIANCES. IN VIOLATION OF 40 C.F.R. SECTION 82.161(A). COUNT II RESPONDENT FAILED TO SUBMIT TO THE ADMINISTRATOR OF EPA THAT IS ACQUIRED CERTIFIED RECOVERY OR RECYCLING EQUIPMENT AND IS COMPLYING WITH THE APPLICABLE REQUIREMENTS OF 40 C.F.R. PART 82, SUBPART F, WITHIN 30 DAYS OF A CHANGE IN OWNERSHIP OF AN ENTITY THAT MAINTAINS, SERVICES, OR REPAIRS APPLIANCES.