NATURE OF THE CASE PPG OWNS AND OPERATES AN ETHYLENE DICHLORIDE (EDC)/VINYL CHLORIDE MONOMER (VCM) FACILITY. EMISSIONS FROM THE EDC/VCM FACILITY ARE SUBJECT TO THE NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP), 40 CFR PART 61. CIVIL SUIT FOR PENALTIES AND INJUNCTIVE RELIEF IS REQUESTED PURSUANT TO SECTION 113(B)(3) AND (B)(4) OF THE CLEAN AIR ACT. CAUSE OF ACTION THE NATIONAL EMISSION STANDARD FOR VINYL CHLORIDE, 40 CFR 61.60 ET SEQ. WAS PROMULGATED OCTOBER 21, 1976. AMONG OTHER THINGS, THE REGULATIONS PROHIBIT VINYL CHLORIDE (VC) DISCHARGES FROM ANY RELIEF VALVE IN VC SERVICE EXCEPT FOR EMERGENCIES; LIMIT VC EMISSIONS FROM EQUIPMENT USED IN EDC PURIFICATION AND IN VC FORMATION AND PURIFICATION TO 10 PPM; AND LIMIT, TO 10 PPM, VC EMISSIONS REMOVED FROM INPROCESS WASTEWATER AND DUCTED THROUGH A CONTROL SYSTEM. SINCE THE VC STANDARD BECAME EFFECTIVE, 36 VC DIS- CHARGES, TOTALING 39,078 LBS. OF VC, HAVE BEEN REPORTED AND REVIEWED. I HAVE DETERMINED THAT 34 OF THESE DISCHARGES, TOTALING 34,984 LBS. OF VC, ARE VIOLATIONS OF 61.65(A), AND THAT THE REMAINING 2 DISCHARGES TOTALING 4,094 LBS. OF VC, ARE VIOLATIONS OF 61.63(A).