NATURE OF THE CASE: BORDEN IS A LARGE MANUFACTURER OF PETROCHEMICALS & RE- LATED PRODUCTS. THE LEOMINSTER FACILITY IS A POLYVINYL CHL- ORIDE PLANT. CAUSE OF ACTION: THIS PLANT IS SUBJECT TO THE NATIONAL EMISSIONS STAND- ARD FOR VINYL CHLORIDE, 40 CFR SEC 61.60 ET SEQ. ON NUMEROUS OCCASSIONS, THE CO HAS VIOL'D THE RELIEF VALVE DISCHARGE STANDARD, SEC 61.65(A), WHICH PROHIBITS THE RELEASE OF VINYL CHLORIDE INTO THE ATMOSPHERE FROM RELIEF VALVES EXCEPT IN EMERGENCIES. PROPOSED REMEDY: THIS CIVIL ACTION SHOULD SEEK INJUNCTIVE RELIEF REQUIR- ING BORDEN TO INSTITUTE OPERATION & MAINTAINANCE PROCEDURES, OPERATOR TRAINING, &, IF NECESSARY, INSTALL EQUIPMENT DESIG- NED TO PREVENT FUTURE RELIEF VALVE DISCHARGES. IN ADDITION, GOODRICH SHOULD BE REQUIRED TO PAY A CIVIL PLTY FOR PAST VIOL'S. NATIONALLY SIGNIFICANT ISSUES: RESOLUTION OF THIS CASE, WHICH INVOLVES NATIONALLY APP- LICABLE STANDARDS, WILL SET PRECEDENT FOR ALL VINYL CHLORIDE ACTIONS BROUGHT BY THE GOVT. * FACILITY NAME: BORDEN CHEMICAL CO