Document ZBed5xVp1nBywkb7QxLY2nB70

OFT > .<, TENNECO CHEMICALS, INC. ) T W. P. Andersoi Teuneeo Inc. . P. Su'.ldstedt P: scat-away EPA Conducted Compliance Review 8/15, no Dr. K. T. Gottesman With regard to your memo ot July 2b, TCI has not received, to date, any letters from EPA concerning general compliance inspections. However, as part of the Agency's program to review the vinyl chlor ide standard, the Pasadena plant was asked to provide specific, VCM-f related information, and prepare for an on-site inspection by EPA representatives and their contractor TRW. Attempts to negotiate an, appropriate confidentiality agreement, are in progress. This might bo pare speculation on my part but, at the Government Institutes Master's Seminar held last year, .in SPA attorney was describing a,, agency proposal to institute an Audit Program. As he described it, the Audit would be conducted by an outside con sultant-- 1. Licenced by EPA Paid for by the company The results of tins Audit would bt the basis of citation by the agency for non-comp]lance with any permit, environmental law or regulation, etc. The assumption of t.he agency is that, in general, because there are so few excursions/violations being reported by industry (primarily, under NPDES requirements), industry must be "cheating". The amount of data requested m EPA's letter suggests to me that tins might be a trial run for tnis type of Audit/Inspec tion Program. JPS:eg J. I?. Sandstedt COLORITE 017117