CONOCO CHEM CO ('THE CO') OWNS AND OPERATES AN ETHYLENE DICHLORIDE (EDC)/VINYL CHLORIDE MONOMER (VCM) FACILITY IN WESTLAKE, LA (AROUND LAKE CHARLES). THE PLANT BEGAN OPERA- TION IN 1/68. EMISSIONS FROM THE PLANT ARE SUBJECT TO NESHAP. CIVIL SUIT FOR PENALTIES AND INJUNCTIVE RELEIF IS REQUESTED PURSUANT TO SECTION 113(B)(3-4) OF THE CAA. CAUSE OF ACTION THE NAT'L EMISSION STANDARD FOR VC PROHIBITS, AMONG OTHER THINGS, ANY VC DISCHARGES FROM ANY RELIEF VALVE IN VC SER- VICE EXCPET FOR EMERGENCIES; REQUIRES REPORTING OF RELIEF VA VALVE DISCHARGES W/IN 10 DAYS; LIMITS VC EMISSIONS FROM E QUIPMENT USED IN EDC PURIFICATION AND IN VC FORMATION AND PURIFICATION TO 10 PPM; AND LIMITS, TO 10 PPM, VC EMISSIONS REMOVED FROM IN-PROCESS WASTEWATER AND DUCTED THROUGH A CONTROL SYSTEM. SINCE THE VC STANDARD BECAME EFFECTIVE, ON 10/21/76, CONOCO HAS REPORTED 20 DISCHARGES TOTALLING 13,326.8 LBS OF VC. REGION 6 DETERMINED THAT 16 RELIEF VALVE DISCHARGES WERE IN VIOLATION OF 40CFR 61.65(A), ONE DISCHARGE WAS IN VIOLATION OF 40CFR 61.63(A), ONCE DISCHARGE WAS A VIOLATION OF 40CFR 61.62(A), 61.63(A), AND 61.65(B)(9)(II), AND ONE DISCHARGE WAS SUBJECT ONLY TO 40CFR 61.63(A) AND WAS FOUND IN COMPLIANCE WITH THAT STANDARD, AND ONE DISCHARGE WAS NOT SUBJECT TO NESHAP REGULATIONS. OUR CONCERN IS THE FAILURE OF THE CO.