THE VIOLATIONS UPON WHICH THE ACTION IS BASED: 1. TWENTY SIX INCIDENTS OF EMISSIONS TO THE ATMOSPHERE FROM A VINYL CHLORIDE MONOMER RECOVERY UNIT WHERE THE EXHAUST GAS CONCENTRATIONS OF VINYL CHLORIDE WERE GREATER THAN THE PRESCRIBED STANDARD OF 10 PPM. 2. THE PROPOSED RELIEF SOUGHT IS A MINIMUM PENALTY OF $114,000. NO INJUCTIVE RELIEF IS SOUGHT. DEFENDANT HAS INCORPORATED CERTAIN CONTROL TECHNOLOGY TO PROHIBIT FUTURE INCIDENTS OF VIOLENCE OF STANDARD. 3. RECENT CONTACTS WITH THE DEFENDANT: 11/27/85: EPA ISSUED SECTION 114 REQUEST. 12/19/85: DEFENDANT RESPONDS TO SECTION 114 REQUEST. 4. DATE OF INSPECTIONS, INFORMATION RESPONSES, OR RECEIPT OF EVIDENCE NEEDED TO INITIATE ENFORCEMENT ACTION. 12/19/85: DEFENDANT'S RESPONSE TO SECTION 114 REQUEST. 02/11/86: TECHNICAL SUPPORT DOCUMENTS REACHED REGIONAL COUNCIL OFFICE. 03/31/86: REFERRAL SIGNED BY REGIONAL ADMINISTRATOR. B.F. GOODRICH OWNS AND OPERATES A POLYVINYL CHLORIDE (PVC) PLANT AT PLAQUEMINE, LOUISIANA. THE PLANT WAS BUILT BY DOW CHEMICAL. ON SEPTEMBER 30, 1983, REGION VI TRANSMITTED TO EPA HEADQUARTERS A LITIGATION REPORT ADDRESSING MANUAL VENT VALVE AND RELIEF VALVE DISCHARGE VIOLATIONS OF THE VINYL CHLORIDE STANDARDS BY THE B.F. GOODRICH C