COMPLAINT AND CONSENT AGREEMENT AND FINAL ORDER FOR VIOLATING PARTICULAR ELEMENTS OF 40 C.F.R. PART 68, ALSO KNOWN AS THE RISK MANAGEMENT PROGRAM. RESPONDENT AND COMPLAINANT AGREE TO THE TERMS OF THIS CA/FO, AND RESPONDENT AGREES TO COMPLY WITH THE TERMS OF THE FINAL ORDER PORTION OF THIS CA/FO. RESPONDENT SHALL PAY A CIVIL PENALTY OF $14,745 WITHIN THIRTY (30) DAYS OF THE EFFECTIVE DATE OF THIS ORDER.