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          Texas Natural Resource Conservation Commission
                      Interoffice Memorandum

To:  Distribution
From: Jeanne Philquist, Manager, Compliance Section, Air Quality Enforcement Division
     Bill Zeis, Senior Staff Attorney, Legal Services Division
Date: September 20, 1994
Subject: Enforcement Policy on Standard Exemptions

This memo is to document agreements reached during our August 23, 1994 meeting among the
Directors of New Source Review, Permitting, Air Quality Enforcement, members of their staffs
and representatives of Legal Services, Field Operations and the Small Business Advocate's
Office.  The issue being considered was the agency's policy on treatment of facilities that:

1) were constructed under standard exemptions that required registration at the time of
construction; and

2) met all the conditions of the original standard exemption, except the owner/operator failed to
register the facility at the time of construction and 

3) the standard exemption since has been revised to become more stringent.

It was agreed that the owners/operators of such facilities may achieve compliance by submitting
the registration form that was originally required. The agency will not require that such facilities
meet the more stringent requirements now in effect, provided the facility was constructed in
compliance with all of the substantive provisions of the original exemption except for the
registration requirement.  

Please let me or any of the meeting participants know if you have any questions or need
additional information.  

cc: Air Program Managers
      Debra Barber, Air Program Director, Field Operations Division
      Kerry Drake, Manager, Small Business Assistance Program
      August 23, 1994 Meeting Participants
      Compliance Staff