NATURE OF THE CASE: GOODRICH IS A LARGE MANUFACTURER OF PETROCHEMICALS & RELATED PRODUCTS. THE CALVERT CITY FACILITY IS AN ETHYL- ENE DICHORIDE PLANT. CAUSE OF ACTION: THIS PLANT IS SUBJECT TO THE NATIONAL EMISSIONS 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 RE- QUIRING GOODRICH TO INSTITUTE OPERATION & MAINTENANCE PROCEDURES, OPERATOR TRAINING, & POSSIBLY INSTALLATION OF EQUIPMENT DESIGNED TO PREVENT FUTURE RELIEF VALVE DIS- CHARGES. IN ADDITION, GOODRICH WILL BE REQUIRED TO PAY A CIVIL PLTY FOR PAST VIOL'S. NATIONALLY SIGNIFICANT ISSUES: RESOLUTION OF THIS CASE, WHICH INVOLVES NATIONALLY APPLICABLE STANDARDS, WILL SET PRECEDENT FOR ALL VINYL CHLORIDE ACTIONS BROUGHT BY THE GOV'T.