NATURE OF CASE BF GOODRICH, OPERATES A BULK OR MASS TYPE POLYVINYL CHLORIDE PLANT IN PLAQUEMINE, LOUISIANA. THE PLANT WAS ORIGINALLY BUILT BY DOW CHEMICAL, BUT WAS OWNED BY GOODYEAR WHEN THE VINYL CHLORIDE REGULATIONS WERE PROMULGATED. EMISSIONS FROM THE FACILITY ARE SUBJECT TO THE NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) PROGRAM, 40 CFR PART 61. REGION 6 REQUESTS CIVIL PENALTIES PURSUANT TO SECTION 113(B) OF THE CLEAN AIR ACT, 42 USC 7413(B). 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 DISCHARGE FROM MANUAL VENT VALVES ON PVC REACTORS EXCEPT FOR EMERGENCIES (40 CFR 61.64(A)(3)); PROHIBIT DISCHARGE FROM RELIEF VALVES (AND RUPTURE DISCS), EXCEPT FOR EMERGENCIES (40 CFR 61.65 (A)); REQUIRE REPORTING OF SUCH DISCHARGES WITHIN TEN DAYS; AND PROHIBIT DISCHARGE OF EXHAUST GASES FROM VARIOUS EQUIP- MENT AND PROCESSES IN CONCENTRATIONS GREATER THAN 10 PPM. REGION 6 HAS DETERMINED THAT THIRTY-FIVE DISCHARGES, TOTAL- LING 55,400 POUNDS VINYL CHLORIDE, WERE VIOLATIONS OF 40 CFR 61.65(A), AND FOUR DISCHARGES WERE VIOLATIONS OF THE 10 PPM STANDARD. IN ADDITION, EACH DEFENDANT FAILED TO RE- PORT A MANUAL VENT DISCHARGE WITHIN TE