COMPLAINT AND CONSENT AGREEMENT AND FINAL ORDER FOR VIOLATING PARTICULAR ELEMENTS OF40 CFR PART 68, ALSO KNOWN AS THE RISK MANAGEMENT PROGRAM. RESPONDENT AND COMPLAINANT AGREE TO THE TERMS OFTHIS ORDER AND RESPONDENT AGREES TO COMPLY WITH THE TERMS OF THE FINAL ORDER PORTION OF THIS ORDER. REONDENT SHALL PAY A CIVIL PENALTY OF $48,117 WITHIN 30 DAYS OFTHE EFFECTIVE DATE OF THIS FINAL ORDER. RESPONDENT SHALL ALSO COMPLETE A SUPPLEMENTAL ENVIRONMENTAL PROJECT BY 6/30/17.