This enforcement action was filed in response to multiple violations to CAA 112(r)(7) which were discovered during a Risk Management Plan (RMP) inspection conducted on 8/6 and 8/7/2007. Violations covered the following areas: failure to provide a 5-year update and revision to the facility's Risk Management Plan, failure to develop written procedures for emergency shutdown and subsequent startup, failure to conduct compliance audits and failure to update and revalidate process hazard analysis for the ethylene oxide and sulfur dioxide process.