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Air Quality

Emissions Solutions for a Bagel Bakery

The Challenge

A bagel bakery on the East Coast was facing challenges with their air permit, as they were exceeding production limits. Their volatile organic compounds (VOCs) emissions came under scrutiny, primarily due to ethanol production during yeast fermentation.

To accurately reflect production levels and adhere to the state’s VOC Reasonable Available Control Technology (RACT) hourly limits, the bakery needed a revised air permit and emissions solution. They also sought a review of other environmental programs to achieve facility-wide compliance.


  • Air audit - Site inspection, emissions inventory (with review of product yeast usage) and regulatory review
  • Audit Disclosure - Voluntary air self-disclosure and compliance plan
  • Control System Selection - Identify and assist with required control system selection
  • Air Permit - Air permit modification application, including hazardous air pollutant (HAP) and air toxics risk screening

The Solution

Aeterra conducted a comprehensive baseline air audit evaluating production processes, including yeast fermentation, flavors, and combustion sources to identify emissions.

Together with the client and its legal team, Aeterra prepared a voluntary, state-level self-disclosure. The disclosure included a compliance plan tailored to address VOC RACT regulations, with the selection of thermal oxidizer control system. Aeterra then met with the agency’s permit team to discuss the technical approach for the application and negotiate a compliance timeline. Given the estimated nine-month timeline for the thermal oxidizer installation, the facility was particularly concerned about potential production impacts. An air permit modification was prepared and submitted, incorporating the required assessment of HAPs and air toxics screening level. Aeterra developed the required material use and emissions tracking sheet.

An environmental compliance review verified compliance with other chemical reporting, process wastewater, and waste management. Aeterra assisted with Tier II reporting.

The Results

The Client successfully obtained a modification of the bakery’s air permit. With the installation of a thermal oxidizer, the client achieved compliance with the state’s VOC RACT hourly limits. This not only mitigated VOC emissions, but also demonstrated the client’s commitment to environmental compliance. This commitment allowed the facility to maintain production until controls were fully installed. In addition, the facility understands other environmental compliance programs and requirements. The voluntary disclosure serves as a proactive step to mitigate potential penalties for non-compliance.

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