Texas Air Control Board Austin Texas Memorandum To: Permit Division Directors, Permit Engineers and Regional Directors From: Lawrence E. Pewitt, P.E., Director, Permits Program Date: November 1, 1990 Subject: Permitting Requirements for 4-D Operations The Standard Exemption List was developed for inclusion of facilities that have emissions considered insignificant both in emission rate and type of emissions. This consideration includes facilities that emit, or may emit, odorous compounds. Facilities proposing to process dead, dying, diseased or disabled (4-D) animals, or parts of animals, are not the type of facilities that are included, or intended to be included, in the list of exempt facilities. The nuisance potential of these facilities, regardless of any cooking or heat processing, warrants careful site selection and a thorough review of all operating procedures. Please do not allow construction of these facility types under Standard Exemptions. Permit procedures will be used to ensure that proper consideration will be made to the development of enforceable provisions in a permit that will prevent a nuisance condition from occurring. cc: Mr. James C. Myers, Deputy Director Regulatory Operations Ms. Debra Barber, Director Enforcement and Field Operations Ms. Jeanne Philquist, Director, Compliance Division