This enforcement action was filed in response to violations to CAA 112(r)(7) which were discovered during a Risk Management Plan (RMP) inspection conducted on 9/24-25/2009. It was found that the facility failed to comply with RMP regulations for Program 3 requirements in the following manner: 1.) Respondent failed to submit a Risk Management Plan that reflects all covered processes at the facility; 2.) Respondent had not conducted a process hazard analysis (PHA) on the process involved in the storage of sulfur trioxide, ethylene oxide and propylene oxide in railcars; and 3.) Repondent failed to conduct a compliance audit on this same railcar storage process for the three chemicals listed in Item 2.