THIS ADMINISTRATIVE PENALTY ORDER IS ISSUED TO MBT, LLC, THE OWNER AND OPERATOR OF THE AIRPORT INN AND SUITES. LIGHTFOOT'S, INC. IS THE FORMER OWNER AND OPERATOR OF THE HOTEL FACILITY. ON OR ABOUT 8/9/2000, HAZ-MAT UNIT WAS NOTIFIED THAT THERE WAS A POSSIBLE ILLEGAL RELEASE OF REFRIGERANT FROM AIR CONDITIONING UNITS AND REFRIGERATORS. AN EMPLOYEE OF RESPONDENTS ADMITTED THAT HE HAD CUT THE AIR CONDITIONER AND REFRIGERATOR LINES TO RELEASE THE REFRIGERANT INTO THE ENVIRONMENT. EPA PROPOSES THAT RESPONDENTS BE ASSESSED A CIVIL PENALTY IN THE AMOUNT OF $216,000 FOR THE VIOLATIONS ALLEGED IN THIS COMPLAINT.