RESPONDENT DISPOSED OF APPLIANCES WITHOUT FIRST RECOVERING THE REFRIGERANT; RELEASING REFRIGERANT INTO THE ENVIRONMENT. AO REQUIRES COHEN INDUSTRIAL SCRAP PROCESSORS TO COMPLY WITH SECTION 608(A) OF THE ACT AND THE REQUIREMENTS OF 40 C.F.R. PART 82, SUBPART F AT ANY AND ALL SCRAP DISPOSAL FACILITIES THAT IT OWNS OR OPERATES. THERE ARE ALSO SEVERAL ADDITIONAL REQUIREMENTS OUTLINE IN THE AO THAT COHEN MUST COMPLY WITH PRIOR TO DISPOSING OF APPLIANCE CONTAINING REFRIGERANT (SEE ORDER EPA-5-99-113(A)-06 FOR DETAILS).