NATURE OF THE CASE OCCIDENTAL OWNS AND OPERATES A POLYVINYL CHLORIDE PLANT IN ADDIS, LOUISIANA. THE PLANT BEGAN OPERATION IN LATE 1979 UNDER THE OWNERSHIP OF FIRESTONE, WHICH SOLD IT TO HOOKER CHEMICALS AND PLASTICS CORP ON 10/30/80. HOOKER SUBSEQUENT- LY CHANGED ITS NAME TO OCCIDENTAL. CAUSE OF ACTION 40 CFR SECTION 61.65(A) PROHIBITS THE DISCHARGE OF VINYL CHLORIDE TO THE ATMOSPHERE THROUGH A RELIEF VALVE, EXCEPT IN EMERGENCIES. DURING THE PERIOD FIRESTONE OWNED THE PLANT, THERE WERE 23 DISCHARGES, 21 OF WHICH REGION VI HAS DETER- MINED TO BE PREVENTABLE AND THEREFORE VIOLATIONS OF SECTION 61.65(A). ADDITIONALLY, FIRESTONE FAILED TO REPORT THESE DISCHARGES WITHIN THE REQUIRED TEN DAY PERIOD, BUT INSTEAD REPORTED ALL OF THEM ON 9/22/81, AFTER THE COMPANY HAD SOLD THE PLANT. SINCE OCCIDENTAL PURCHASED THE PLANT, THERE HAVE BEEN TEN DISCHARGES, NINE OF WHICH ARE CONSIDERED TO BE VIOLATIONS OF THE RELIEF VALVE DISHCARGE STANDARD. OCCIDENTAL REPORTED TWO OF THESE DISCHARGES LATE. PROPOSED REMEDY REGION VI IS SEEKING INJUNCTIVE RELIEF AGAINST OCCIDENTAL FOR IMPROVED OPERATOR TRAINING AND PREVENTATIVE MAINTENANCE PROCEDURES. THE REGION HAS ALSO PROPOSED A CIVIL PENALTY SETTLEMENT FIGURE OF $196,740 FOR FIRESTO