BORDEN CHEMICALS AND PLATICS OPERATES A PLANT IN ILLIOPOLIS, IL PRODUCING A POLYVINLY CHLORIDE RESIN FROM VINLY CHLORIDE MONOMER THAT IS SUBJECT TO THE NESHAP FOR VINYL CHLORIDE. BETWEEN FEBRUARY 1987 AND JULY 1989. BORDEN REPORTED 9 VINYL CHLORIDE RELIEF VALVE DISCHARGES. BORDEN IS BEING ISSUED AN NOV ON THE BASIS THAT 8 OF THE VINYL CHLORIDE DIS- CHARGES WERE PREVENTABLE AND ARE THEREFORE IN VIOLATION OF 40 CFR SECTION 61.65(A).