Consent Agreement and Final Order to Respondent, initiating and concluding an administrative enforcement proceeding addressing violations of the risk management program (RMP) requirements of Section 112(r)(7) of the Clean Air Act and the regulations at 40 C.F.R. Part 68 at the Respondent's Lockport, New York facility. The facility is a chemical manufacturing plant that uses phosgene in an RMP-covered process for the manufacture of organic chemicals. The Respondent agreed to pay a penalty of $40,262 and perform a Supplemental Environmental Project involving the purchase of equipment for local emergency responders, at a cost of approximately $99,672. In addition to addressing the violations, the Respondent also undertook additional measures to reduce the risks of accidental releases of regulated substances at the facility, including installing an automatically activated scrubber system, implementing inherently safer technology by installing new process equipment allowing for reduction in phosgene usage, and hiring a third party to verify the effectiveness of its mechanical integrity testing program for the facility's phosgene pipelines.