NATURE OF THE CASE: GOODRICH IS A LARGE MANUFACTURER OF PETROCHEMICALS & RELATED PRODUCTS. THE LOUISVILLE FACILITY IS A POLYVINYL CHLORIDE 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 VIOL'D THE RELIEF VALVE DISCHARGE STANDARD, SEC 61.65(A), WHICH PROHIBITS THE RELEASE OF VINYL CHLORIDE INTO THE ATMOSPHERE FROM RELIEF VALVES EXCEPT IN EMERGENCIES. PROPOSED REMEDY: THIS CIVIL ACTION SHOULD SEEK INJUNCTIVE RELIEF RE- QUIRING GOODRICH TO INSTITUTE OPERATION & MAINTENANCE PROCEDURES, OPERATOR TRAINING, & IF NECESSARY, INSTALL EQUIPMENT DESIGNED TO PREVENT FUTURE RELIEF VALVE DIS- CHARGES. IN ADDITION, GOODRICH SHOULD 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.