NATURE OF THE CASE: CONOCO IS A LARGE MANUFACTURER OF PETROCHEMICAL & RELATED PRODUCTS. THE ABERDEEN FACILITY IS A POLYVINYL CHLORIDE PLANT. CAUSE OF ACTION: THIS PLANT IS SUBJECT TO THE NATIONAL EMISSION STANDARD FOR VINYL CHLORIDE, 40 CFR SEC 61.60 ET SEQ. ON NUMEROUS OCCASIONS, THE CO HAS DISCHARGED VINYL CHLORIDE INTO THE ATMOSPHERE THROUGH RELIEF VALVES, IN VIOL OF THE PROHIBITION SET FORTH IN SEC 61.65(A) OF THE STANDARD. PROPOSED REMEDY: THIS CIVIL ACTION SHOULD SEEK INJUNCTIVE RELIEF REQUIRING CONOCO TO INSTITUTE OPERATION & MAINTENANCE PROCEDURES, OPERATOR TRAINING, & POSSIBLY INSTALLATION OF EQUIPMENT DESIGNED TO PREVENT FUTURE RELIEF VALVE DISCHARGES. IN ADDITION, CONOCO SHOULD BE REQUIRED TO PAY A CIVIL PENALTY FOR PAST VIOL'S. NATIONALLY SIGNIFICANT ISSUES: RESOLUTION OF THIS CASE, WHICH INVOLVES NATIONALLY APPLICATION STANDARDS, WILL SET PRECEDENT FOR ALL VINYL CHLORIDE ACTIONS BROUGHT BY THE GOV'T.