DEFENDANT OWNS AND OPERATES A PLANT IN CALVERT CITY, KENTUCKY WHICH PRODUCES VINYL CHLORIDE. REGION IV HAS TAKEN PREVIOUS ENFORCEMENT ACTION AGAINST THE PLANT FOR RELIEF VALVE DISCHARGES, A VIOLATION OF SECTION 112 OF THE CAA - NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP), AND 40 C.F.R. PART 61, SUBPART F. THE AGENCY AND GOODRICH ENTERED INTO A CONSENT DECREE ON 02/13/87 FOR $123,500 AND REMEDIAL CONTROLS. SINCE THEN GOODRICH HAS HAD INTERMITTENT VIOLATIONS OF THE NESHAP VINYL CHLORIDE REGULATIONS, INCLUDING ADDITIONAL RELIEF VALVE DISCHARGES AND EXCEEDANCES OF VINYL CHLORIDE EMISSION LIMITS UNDER SUBPART F. REGION IV NOW PROPOSES TO NEGOTIATE A CIVIL SETTLEMENT INCORPORATING A PENALY OF $103,000 TO COVER THE ADDITIONAL NESHAP VIOLATIONS, AND REQUIRING AN ENVIRONMENTAL AUDIT BY AN OUTSIDE CONSULTANT TO DETERMINE THE REASONS FOR THE VIOLATIONS AND TO DETERMINE CORRECTIVE MEASURES. IN ADDITION, THE REGION WILL TRY TO GET GOODRICH TO AGREE TO CONDUCT INTERNAL ENVIRONMENTAL AUDITING OF ITS LOUISVILLE POLYVINYL CHLORIDE PLANT (WHICH HAS BEEN CITED IN AN EARLIER ACTION) AND OF ITS DEER PARK, TEXAS VINYL MONOMER PLANT (GOODRICH INTENDS TO SELL ITS CALVERT CITY VINYL CHLORIDE FACILITY, AND PRODUCE ALL ITS VINYL CHLORIDE MONOMER OF THE DEER PARK PLANT).