DOW CHEMICAL, U.S.A. OWNS AND OPERATES A LARGE CHEMICAL COMPLEX IN PLAQUEMINE, LOUISIANA, WHICH INCLUDES THREE SOURCES THAT ARE SUBJECT TO 40 CFR PART 61, SUBPART F OF THE NATIONAL EMISSION STANDARD FOR HAZARDOUS AIR POLLUTANTS (NESHAP) FOR VINYL CHLORIDE: (1) AN ETHYLENE DICHLORIDE (EDC) PLANT USING PURE OXYGEN OXYHYDROCHLORINATION PROCESS; (2) A VINYL CHLORIDE MONOMER (VCM) PLANT (VINYL II). COW HAS A SECOND EDC FACILITY THAT SUPPLIES EDC TO VINYL I, BUT THE EDC IS MADE BY DIRECT CHLORINATION OF ETHYLENE WITH CHLORINE AND IS NOT COVERED BY THE EMISSION STANDARD FOR VINYL CHLORIDE. CAUSE OF ACTION FROM JANUARY, 1977 TO OCTOBER 14, 1983 (THE DATE OF THE FINAL NESHAP DELEGATION TO THE LOUISIANA DEPARTMENT OF ENVIRONMENTAL QUALITY, LDEQ), DOW CHEMICAL U.S.A. REPORTED 31 DISCHARGES TOTALING 61,776 LBS. OF VINYL CHLORIDE (VC). FOR THE PERIOD OF OCTOBER 14, 1983 TO PRESENT, DOW HAS REPORTED FOUR DISCHARGES TOTALING 1125 LBS. TO LDEQ UNDER 77 .6(A) AND 76.18 OF THE LESHAP REGUALTIONS. UNDER THE TERMS OF THE FINAL NESHAP DELEGATION, AS PUBLISHED IN THE FEDERAL REGISTER, ALL INFORMATION PURSUANT TO 40 CFR PART 61 WAS SUBMITTED DIRECTLY TO THE STATE AGENCY. TWO OF THE REPORTED DISCHARGES WERE RELIEF VALVE DISCHARGES, ONE WAS SUBJECT TO THE 10 PPM STANDARD, AND ONE WAS FOUND NOT TO BE SUBJECT TO THE LESHAP STANDARD. IN ALL INSTANC