THE REGION PROPOSES FILING A CIVIL ACTION PURSUANT TO CAA/113(B), 42 USC 7413(B), AGAINST OCCIDENTAL CHEMICAL CORP. ( OCCIDENTAL ) FOR VIOLATIONS OF CAA SECT. 112 & 114. SECT. 112(C) PROHIBITS EMISSIONS OF HAZARDOUS AIR POLLUTANTS IN EXCESS OF THE STDS PROMULGATED PURSUANT TO 112(B). SECT. 114 REQUIRES THE SUBMISSION OF INFORMATION BY ANY PERSON UPON REQUEST BY EPA. UNDER 112 & 114, EPA HAS PROMULGATED A SERIES OF NESHAPS INCLUDING STDS FOR VINYL CHLORIDE EMIS- SIONS AND RESINS & REPORTING RQRMTS. THESE STDS ARE CODI- FIED AT 40 CFR 61.60 ET. SEQ. OCCIDENTAL IS THE OWNER OF A POLYVINYL CHLORIDE MANUFAC- TURING PLANT IN BURLINGTON, NJ. IAW 40 CFR 61.70, THE CO. IS REQUIRED TO SUBMIT SEMI-ANNUAL REPORTS WHICH IDENTIFY: A) REACTOR OPENING LOSSES & THE EMISSION OF VINYL CHLORIDE FROM EACH PRODUCTION VESSEL; & B) THE VINYL CHLORIDE CONTENT OF THE POLYVINYL CHLORIDE ( PVC ) RESIN FOR EACH DAY. THE REACTOR OPENING LOSS FROM EACH REACTOR SHALL NOT EXCEED 0.02 GRAMS OF VINYL CHLORIDE PER KG OF PVC PRODUCT PURSUANT TO 40 CFR 61.64(E)(1). REGION II HAS REVIEWED THE SEMI-ANNUAL REPORTS SUBMITTED BY OCCIDENTAL FOR THE PERIOD 3/1/80 TO 8/31/84. OCCIDENTAL FAILED TO REPORT REACTOR OPENING LOSSES IN 188 OUT OF 2314 OPENINGS (8.1% NONCOMPLIANCE). THE REACTOR OPENING LOSSES EXCEEDED 0.02 GRAMS OF VINYL CHLORIDE PER KG OF PVC PRODUCT IN 44 OPENINGS OUT OF 2126 MEASURED OP