THE VIOLATIONS UPON WHICH THE ACTION IS BASED: 1. DIS- CHARGES OF VINYL CHLORIDE FROM ETHYLENE DICHLORIDE PURIFICATION IN EXCESS OF THE 10 PPM STANDARD OF 40 C.F.R. SEC. 61.62(A), 2. DISCHARGES OF VINYL CHLORIDE FROM VINYL CHLORIDE FORMATION AND PURIFICATION IN EXCESS OF THE 10 PPM STANDARD OF 40 C.F.R. SEC. 61.63(A), 3. DISCHARGES OF VINYL CHLORIDE FROM RELIEF VALVES IN VIOLATION OF THE NO DISCHARGE STANDARD OF 40 CFR SEC. 61.65(A). THE STATUTES AND REGULATIONS WHICH ARE THE BASIS FOR THE PROPOSED ACTION CLEAN AIR ACT SECTION 112(C)(1), 42 U.S.C. SEC. 7412(C)(1) NATIONAL EMISSION STANDARDS FOR HAZARDOUS POLLUTANTS AND 40 C.F.R. SUBPART F. NATIONAL EMISSION STANDARD FOR VINYL CHLORIDE. THE PROPOSED RELIEF TO BE SOUGHT IS A MINIMUM PENALTY OF $59,000 AND INJUNCTIVE RELIEF REQUIRING OPERATOR TRAINING AND EQUIPMENT INSTALLATION. DOW OWNS AND OPERATES THIS CHEMICAL COMPLEX WHICH INCLUDES THREE SOURCES SUBJECT TO VINYL CHLORIDE STANDARDS: 1. AN ETHYLENE DICHLORIDE (EDC) PLANT USING PURE OXYGEN OXYHYDROCHLORINATION PROCESS. 2. AN VINYL CHLORIDE MONOMER (VCM) PLANT (VINYL I). 3. A VCM PLANT (VINYL II). JAN 1977-10/14/83: DOW REPORTED 31 DISCHARGES TOTALLING 61,776 LBS. OF VC. AFTER ELIMINATING THE DISCHARGES WHICH FALL OUTSIDE THE FIVE-YEAR STATUE OF