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                Texas Air Control Board
          Austin                       Texas

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

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
     Ms. Jeanne Philquist, Director, Compliance Division