In the past few months, a slew of EPA Section 114 letters have been issued to bakeries. An emissions test performed recently at a bakery located in the Midwest showed higher emission rates than the published levels for ethanol, the most common byproduct of bread making. Section 114, under the Clean Air Act, is a request for information by the EPA to determine emission levels previously unknown or is questionable.

Section 114 letters have and continue to be used by EPA as a means to collect information “as the Administrator may reasonably require.” This could range from collecting internal records to emission testing of sources to determine upcoming emission limits. In years past, different industries were targeted. Two years ago, the EPA called upon the mini steel mill industry to generate emission numbers for PM2.5 and mercury. The same was true for chip dryers among secondary aluminum smelters where specific organic hazardous air pollutants were investigated. Today, it is ethanol and other organics from bakeries.