COMPLAINT AND CONSENT AGREEMENT AND FINAL ORDER FOR VIOLATING PARTICULAR ELEMENTS OF 40 CFR PART 68, ALSO KNOWN AS THE RISK MANAGEMENT PROGRAM. RESPONDENT AND COMPLAINANT AGREE TO THE TERMS OF THIS CONSENT AGREEMENT AND FINAL ORDER, AND RESPONDENT AGREES TO COMPLY WITH THE TERMS OF THE FINAL ORDER PORTION OF THIS ORDER. RESPONDENT SHALL PAY A CIVIL PENALTY OF $101,808 WITHIN 30 DAYS OF THE EFFECTIVE DATE OF THIS FINAL ORDER.