This is a Complaint, Consent Agreement, and Final Order ( CAFO ) pursuant to CAA Section 112(r)(7) (40 CFR Part 68) and EPCRA Sections 311 and 312 (40 CFR Part 370) issued to Semco Couth Cooling, LLC. The Respondent operates a Program 3 refrigerated produce warehouse in Yuma, Arizona that failed to submit a Risk Management Plan, did not submit a list of subject chemicals to the required points of compliance, and did not annually submit hazardous chemical inventories to the appropriate state and local authorities. In the CAFO, Respondent agrees to pay the full $55,375 penalty sought by EPA.