NC0001970_Report_20200402

Draper Aden Associates D [ C 2 p d
NZ, Engineering • Su-vexing • Environmental Services
114 Edinburgh South Drive APR - 2 2020
Suite 200
Cary,North Carolina 2751 I
919.827.0864 DIVISION OF WATER RESOURCES
www.daa.com DIRECTOR'S OFFICE
March 31, 2020
Mr. Danny Smith, Director
Division of Water Quality Via email:[e-mail]
North Carolina Department of Environmental Quality
1617 Mail Service Center
Raleigh, North Carolina 27669-1617
Re: 2019 Annual Chloride Reduction Report
Bay Valley Foods, LLC—Faison, North Carolina
354 N. Faison Avenue, Faison, North Carolina
NPDES Permit No. NC0001970
Draper Aden Associates Project No.: 20080165-010103
Dear Mr. Smith,
On behalf of Bay Valley Foods, LLC(Bay Valley), Draper Aden Associates (DAA) is pleased to present 2019 Annual
Chloride Reduction Report.
In accordance with Special Condition A. (5) b.: NPDES Permit No. NC0001970, Bay Valley Foods, LLC-Faison, NC,
continues efforts to study and evaluate chloride removal technologies and chloride reduction strategies. Enclosed
please find a copy of the facility's 2019 Annual Chloride Reduction Report. As stated in previous reports,through
the 1980's, 1990's and 2000's significant investments were made on process improvements, new equipment
purchases, and process change strategies aimed at reducing salt use and subsequent chloride discharges.
Notable investments and process changes include the replacement of wooden fermentation tanks, reduction of
salt concentration in brines, process automation, and brine recycling technology. The early efforts resulted in
substantial reduction in salt use with subsequent focus on pollution prevention efforts further reducing chloride
discharges to surface water. As noted in our Chloride Variance Request and previous Annual Chloride Reduction
Evaluation Reports,there have been no economically feasible scientific breakthroughs in chloride removal
technologies applicable to the production processes employed at Bay Valley Foods, LLC— Faison, NC. Efforts
continue to improve process control/automation focused on reducing brine loss and salt waste.
If you have any questions or comments, please contact us at 919-582-7271.
Sincerely,
Draper Aden Associates
c.77,9/cr"
James Y.Joyner, II, RSM Candy E. Elliott, P.G.
Senior Consultant Project Geologist
Enclosure
cc: Mr. Donovan Brock (1 HC)
Blacksburg•Charlottesville•Manassas •Newport News•Richmond• Virginia Beach
Fayetteville•Raleigh

ANNUAL CHLORIDE REDUCTION EVALUATION REPORT
YEAR 2019
Bay Valley Foods, LLC
(former Dean Pickle and Specialty Products)
NPDES Permit No. NC0001970
DAA Project No.: 20080165-010103
March 30, 2020
Prepared for
Bay Valley Foods, LLC
354 N. Faison Avenue
Faison, North Carolina 28341
Prepared by
Draper Aden Associates
114 Edinburgh South Drive
Cary, North Carolina 27511
Draper Aden Associates
I:nXineerArk Sirverin,Y l.nru•uunrnral Sen•icrs

3RD PARTY REVIEW
This Report has been subjected to technical and quality reviews by:
Billy Newcomb, PG March 26, 2020
Name: Printed Signature Date
Senior Program Manager
Candy Elliott March 30, 2020
Name: Printed Signature Date
Project Geologist
q74'-7.#vot
James Joyner, II, RSM March 30, 2020
Name: Printed Signature Date
Quality Reviewer/
Environmental Team Leader

TABLE OF CONTENTS
3`d Party Review i
Executive Summary ii
1.0 Basic Information 1
2.0 Production 5
3.0 Evaluated and/or Implemented Technologies and Approaches 6
4.0 Technologies &Approaches Considered For 2020 and Beyond 8
4.1 Bypass Salting/No Fermentation Process 8
4.2 Desalt Process Improvements 8
4.3 Brine Reclaim Process Improvement - 5-gallon Pail Line 8
4.4 Wastewater Treatment Process Improvements 8
4.5 Pickle Packers International (PPI) 9
4.6 Treatment Technologies 9
5.0 Waste Reduction 10
TABLES
Table 1.0 2019 Chloride Discharge Data 1
Table 2.0 Annual Production Units and Chloride to Production Ratio (1996-2019) ' 2
Table 3.0 Annual Average Stream Chloride Levels 1997-2019 3
Table 4.0 Comparison of All Data 4
CHARTS
Chart#1 Average Cl- Discharge per Day (lbs/day)
Chart#2 Annual Production (Millions of Equivalent Units Produced)
Chart#3 Average Instream Chloride Concentrations (lbs per day)
Chart#4 Cl- Discharge per Equivalent Unit (Ibs)
Chart#5 Annual Chloride Discharge (lbs/year)
Chart#6 2019 Chloride Limits

EXECUTIVE SUMMARY
This report is being submitted in accordance with Special Condition A. (5) b, which states; "The
permittee shall continue to study and evaluate new and emerging chloride removal technologies and
reduction methods and shall report its findings directly to the Division of Water Quality annually on or
before March 31st of each year." The annual report shall include a summary of findings from a qualified
waste reduction specialist employed to specifically evaluate source reduction of chloride."
This report will be limited to chloride, chloride discharges and approaches/technologies researched,
evaluated, and/or implemented for the reduction of chloride discharges during the calendar year 2019.
Comparisons are made to previous years including 1996, the benchmark year.
Table 1.0 and Chart#1 summarize annual average chloride discharges in pounds per year. There were
no exceedances of either the "Monthly Average Discharge Limit" or the "Daily Maximum Chloride
Discharge Limit" in 2019. (Refer to Chart#6)
Table 2.0 and Chart# 2 provide annual production information for 2019 and for previous years,
measured in equivalent production units (eq. units), as well as the pounds of chloride discharged per
equivalent production unit. Production volume in 2019 decreased 11.9% compared to 2018. The 2019
chloride lbs. discharged per production unit ratio decreased 44% from 0.34 in 2018 to 0.19 in 2019.
Over the past five years (2015 through 2019), the average chloride lbs. per equivalent unit of production
is 0.24 lbs./eq. units.
Table 3.0 and Chart#3 summarize the in-stream chloride concentrations at the established monitoring
points located both upstream and downstream of the facility's treated process wastewater discharge
outfall. Data are provided from 1997, when in-stream chloride concentration monitoring became an
NPDES permit requirement. In-stream chloride concentrations at all monitoring locations, including
upstream from the facilities wastewater discharge outfall, peaked in 2007 due to an extended drought
in the Faison area resulting in low flow in the receiving stream. Increased precipitation in subsequent
years has resulted in in-stream sampling data that show a long-term decline in chloride concentrations
at all monitoring locations. Chloride concentrations at downstream monitoring location Downstream
#1 decreased between 2018 and 2019 and Downstream #2 and Downstream #3 increased.

Table 4.0 summarizes data pertinent to chloride discharges from 2005 through 2018.
• Bay Valley Foods, LLC - Faison, NC did not exceed the "Daily Maximum Chloride Discharge Limit"
or the "Monthly Average Discharge Limit" in 2019. (Refer to Chart#1)
• The 2019 annual production total of 4.83 million equivalent production units represents an
11.9% decrease from 2018 production. (Refer to Chart#2)
• Chlorides discharged per equivalent production unit in 2019 decreased 44% compared to 2018
and decreased 66% compared to the benchmark year of 1996. In 2019 the ratio was calculated
at 0.19 pounds of chlorides discharged per equivalent production unit. (Refer to Chart#4)
• The calculated annual pounds of chlorides discharged (903,820 lbs.) in 2019 is 74.8% less than
the largest amount discharged in 2007. (Refer to Chart#5)
iii

1.0 BASIC INFORMATION
Bay Valley Food, LLC— Faison, NC (BVF), remains committed to continue efforts to maintain the
downward trend in chloride discharges from its production facility. Through emphasis on its
comprehensive pollution prevention; advanced process control and automation aimed at reducing
brine loss; replacement of inefficient equipment; and ongoing efforts in the identification and
implementation of new and innovative reduction opportunities, BVF maintains its focus on the
reduction of chlorides from its waste stream (Refer to Chart#1). BVF will continue to investigate and
monitor technological advances that may have potential application to the pickle processing industry
and supports research efforts in this area through its membership in professional trade organizations
such as Pickle Packers International. BVF is willing to implement cost-effective chloride removal
technologies and pollution reduction measures that can be proven effective and not compromise or
impair finished product quality and/or characteristics.
Table 1.0. 2019 Chloride Discharge Data
Monthly Average = 13,476 lb/day
Current Chloride Discharge Limits:
Daily Maximum = 19,120 lb/day
Chloride Discharge (lb/day)
Month Max Min Avg.
January 3129 12 1140
February 1057 180 794
March 1250 975 1114
April 3211 723 1523
May 6267 829 3635
June 6194 2184 4290
July 8195 2399 4515
August 9992 2176 5094
September 6588 850 2464
October 3004 732 1860
November 1995 163 940
December 3229 863 2135
1

Table 2.0 Annual Production Units and Chloride to Production Ratio (1996-2019)
Production
Production Year Equivalent Units Chloride to Units
(millions)
Produced Ratio
1996 5.74 0.51
1997 NA NA
1998 NA NA
1999 7.09 0.42
2000 7.28 0.38
2001 7.59 0.33
2002 7.84 0.37
2003 8.52 0.37
2004 8.75 0.3
2005 7.86 0.35
2006 9.04 0.35
2007 8.98 0.4
2008 8.57 0.38
2009 8.82 0.35
2010 8.23 0.39
2011 7.85 0.25
2012 7.26 0.2
2013 6.82 0.19
2014 6.6 0.21
2015 7.01 0.17
2016 6.84 0.22
2017 5.89 0.26
2018 5.49 0.34
2019 4.83 0.19
NA:data are not available
2

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Table 4.0. Comparison of All Data (2005-2019)
Data Description 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019
Annual Chloride Discharge 2,731,749 3,133,189 3,588,806 3,250,525 3,090,730 3,193,908 1,962,923 1,464,092 1,273,754 1,418,341 1,218,420 1,497,130 1,542,683 1,869,489 903,820
(Ibs)
Annual Production 8,234,700 9,039,500 8,981,990 8,572,000 8,821,135 8,226,346 7,846,314 7,258,154 6,816,632 6,602,658 7,012,627 6,837,706 5,896,035 5,486,941 4,834,657
(Equivalent Units)
Chloride Per Equivalent Unit 0.33 0.35 0.40 0.38 0.35 0.39 0.25 0.2 0.19 0.21 0.17 0.22 0.26 0.34 0.19
Annual Water Use 119.2 98.03 109.11 94.3 101.78 107.7 115.32 97.6 91.61 114.47 133.6 133.77 114.29 118.23 92.34
(MG)
Annual NaCI &CaCI Purchases 4,409,000 4,929,000 6,652,000 6,104,000 4,913,000 4,020,000 1,998,000 3,702,000 3,805,000 3,228,325 2,603,393 4,259,319 6,471,116 6,578,677 3,027,909
(Ibs)
Salt Use Per Equivalent Unit 0.54 0.55 0.74 0.71 0.56 0.49 0.25 0.51 0.56 0.49 0.37 0.62 1.1 1.2 0.63
4

2.0 PRODUCTION
Bay Valley Foods, LLC - Faison, NC uses an established formula whereby all production types, in all
facilities, are normalized. The unit of measure is referred to as an "Equivalent Production Unit" and
allows for a fair and equal comparison of differing sized containers from 10-ounce jars to 5-gallon
bucket. The equivalent production unit brings all production to a case equivalent volume and enables a
fair comparison of production between facilities and production years and provides a balanced method
to evaluate performance.
The Faison, NC facility production requirements increased annually between the benchmark year of
1996 and 2006, at which time production peaked at 9.04 million eq. units. Since 2006, the trend
indicates a reduction in production throughput (Refer to Chart#2). The 2019 production volume was
4.834 million eq. units, a 6.9% decrease from the 2018 volume (5.487 million eq. units). The 2019
average ratio of chloride discharged in pounds per equivalent production units (0.19) is below the 1996
— 2019 average ratio (0.32) and below the 2015 - 2019 five-year average ratio (0.24). Due to the
ongoing commitment from facility leadership, the pounds of chloride discharged per equivalent
production unit continue to show a long-term downward trend (Refer to Chart#3).
5

3.0 EVALUATED AND/OR IMPLEMENTED TECHNOLOGIES AND
APPROACHES
Summary of Chloride Reduction Strategies Implemented and/or Evaluated at Faison, NC
• 1982 through 1990— Replace all wood fermentation tanks with fiberglass or plastic;
• 1982 through 1994—Salt Use Reduction in Brining - %salt reduced from 15.8%to 6.3% salt;
(Substitute calcium chloride and acetic acid in brine prep)
• 1987 to 1989— Recycle Brine—Currently recycle 100%of brine;
• 1988 — Desalting Operation Moved to Brine Yard;
• 1991 — Enhanced Automation of 5-Gallon Production Line;
• 1991 — Enhanced Automation of Major Customer Brine System;
• 1992 — Replace Open-Top Blancher with Rotary Blancher;
• 1992 — Enhanced Bulk Product Handling Processes;
• 1993 — Upgrade Brine-making Station;
• 1993 — Replace Brine Yard Pickle Pump;
• 1994— Install Titanium Heat Exchanger— Brine Recycling/Pasteurization Process;
• 2002- Increase Brine Reclaim;
• 2003, 2004, 2005, 2006 —Evaluate Use of De-Salt Water for Brining and/or Product Fluming;
• 2003, 2004, 2005, 2006—Evaluate Use of De-Salt Water for Subsequent De-Salting
Operations;
• 2003, 2004— Evaluate Recovery of Bottom 2-inches of Concentrated Brine Left in
Fermentation Tanks After Cleaning;
• 2004— Install De-Salt Flume Conveyor;
• 2004— Evaluate De-Salt Brine Filtering for Possible Reuse;
• 2004, 2005 — Evaluate De-Salting through the Lyco Blancher (Continuous Process vs. Batch
Process);
• 2004, 2005 — Evaluate Rapid De-Salt Process;
• 2005, 2006— Evaluate Improvement in Cover Brine Recovery/Blow Lines;
• 2005 — Evaluate New De-Salting Operation Located in Tank Yard;
• 2005 — Install WW Sludge Filter Press and Clean Sludge from WW Treatment Ponds;
• 2005, 2006, 2007, 2008 — Evaluate In-Line De-Salting;
• 2005 — Implemented By-Pass Salting / No Fermentation Process;
• 2005 (2006, 2007, 2008 2009)— Begin 4-Phase Storm Water Management Project;
• 2007, 2008 — Improvements to Cover Brine Efficiency& Recovery Line 1 and 2;
• 2008— Implemented Enhanced Relish Desalting Control;
• 2009—Implemented Replace Pickle Conveyor Pump;
• 2009— Implemented Upgrade Desalting Operation by Installing Four Additional De-Salt
Tanks;
• 2011 —Implemented a project to remove excess biomass from Pond 1 of its wastewater
treatment system. 1500 tons of biomass was dewatered and removed at a cost of$143,000.
• 2012 —Continued the removal process of excess biomass from Pond 1 with an additional
removal and dewatering of 3000 ton at a cost of$249,000.
• 2014 - Continued the removal process of excess biomass from Pond 1 with an additional
removal and dewatering of 3643 ton at a cost of$368,000.
6

♦ 2016 - Implemented removal process of excess biomass from Pond 2 with removal and
dewatering of 3727 tons at a cost of $230,000.
♦ 2016 — Implemented removal and replacement of Pond 2 liner and begin construction and
lining of Pond 3 at a cost of$500,000.
♦ 2016— Evaluate Reverse Osmosis and Electrodialysis/Electrodialysis Reversal to Reduce
Chloride at End-of-Pipe. Neither technology was considered feasible due to cost
considerations.
♦ 2017 —Completed the excess biomass removal from Pond 3 with removal and dewatering of
1,963 tons at a cost of$336,000.
♦ 2017 —Completed installing the new liner at Pond 3 on April 1, 2017 at a cost of $100,000
♦ 2018 —Completed lining Pond 1. Sludge removal cost totaled $285,000.The three ponds
have been relined.
7

4.0 TECHNOLOGIES & APPROACHES CONSIDERED FOR 2020 AND
BEYOND
Many projects, programs, process changes and chloride reduction strategies implemented in the past
continue to be utilized into 2019, such as:
4.1 Bypass Salting/No Fermentation Process
The proprietary "No Fermentation" process continues to be a significant process improvement and
chloride reduction strategy and will be considered for all future production opportunities where
applicable.
4.2 Desalt Process Improvements
The Faison facility added four portable de-salt tanks for product de-salting. The de-salting process
must be accomplished quickly to support the production schedule, which can result in over de-salting
of the product necessitating the re-addition of salt. The result is excess water use, increased salt use
and ultimately additional chloride discharges. The four portable de-salt tanks enabled the facility to
extend the duration of the de-salt process, which provided improved process control.
Status: Successful process improvements were made to the de-salt process in 2009. Cost Associated
with Improvements - $350,000.
4.3 Brine Reclaim Process Improvement - 5-gallon Pail Line
The installation of catch pans, filter screens, and a brine reclaim tank on the 5-gallon pail line allows for
the capture of overflow brine and eventual reuse, rather than discharged as high chloride concentrated
wastewater.
Status: Successful improvements were made to the brine reclaim system on the 5-gallon pail
processing line in 2009. Cost Associated with Improvements - $4,500.
4.4 Wastewater Treatment Process Improvements
Excess biomass accumulation in Pond 3 was removed and the pond was relined. This project was
completed in April 2017. In 2017, Bay Valley Foods removed biomass accumulation from Pond 1 and
8

began the process to reline Pond 1. Sludge removal was completed in March 2018, and the liner
replacement was completed. Pond 1 aerators were re-wired, and the pond was returned to normal
operations on May 1, 2018.
Status: Successful improvements were made to the wastewater ponds. Sludge removal costs -
$285,000.
4.5 Pickle Packers International (PPI)
Bay Valley Foods is a member of, and continues to participate in, the Pickle Packers International
organization. Through participation in this organization, Bay Valley Foods remains current on new
processing technologies which may include reduced salt use, and wastewater treatment strategies
others in the pickle processing industry may have implemented that result in reduced chlorides in
wastewater discharges.
4.6 Treatment Technologies
Ramboll Environ prepared a Chloride Removal Technology Evaluation Report dated January 12, 2017.
The report identified several technologies potentially applicable to the BV-Faison facility. The
technologies included reverse osmosis, electrodialysis/electrodialysis reversal, chemical precipitation,
product substitution, flow augmentation, and residuals management. Bay Valley Foods, LLC is
committed to investigating and evaluating any new treatment technology based on technical
applicability and feasibility.
9

5.0 WASTE REDUCTION
The ongoing waste reduction efforts at the Facility will continue through 2020.
The facility has formed a cross-functional Pollution Prevention Team which meets on a regular basis to
discuss and evaluate waste generation and chloride reduction opportunities. A comprehensive
pollution prevention program is in place which includes educating employees regarding best waste
management practices and the importance of identifying strategies that can reduce chloride discharges.
Chloride reduction is a primary focus of the Team along with water conservation, efficient utilization of
energy, and waste generation. In addition, the Team considers maintenance practices and other
protocols that may result in brine loss. Finally, the Team is continually evaluating processes for redesign
consideration with respect to improved efficiency and chloride discharge reduction opportunities.
In combination with waste reduction and pollution prevention efforts, Bay Valley Foods, LLC - Faison,
NC continues to focus on preventive maintenance programs and giving a priority assignment to any
maintenance work order involving process equipment that could result in increased discharge of
chlorides. These activities along with employee training help foster and expand a work ethic focused on
waste reduction as well as process improvements.
The maximum daily discharge for each month in 2019 were below the daily maximum limits and the
average monthly discharge was below the monthly average limit (Table#1 and Chart#6). Upstream
chloride concentrations represent background values. An anomalous peak in downstream chloride
concentrations observed in 2007 was attributed to low stream flow conditions throughout the year, a
result of drought conditions. Linear regressions performed on chloride stream concentrations indicate
decreasing trends in Downstream Point#1 and Downstream Point#3, and an increasing trend in
Downstream Point#2. While long-term concentrations are decreasing in Downstream Points #1 and
#3, analysis of the past five years (2015 — 2019) indicate increasing concentrations in Downstream Point
#1.
Chart#5 shows that the average annual chloride discharge decreased from 2007 to 2019. From 2015 to
2019, the concentrations have fluctuated, but have remained lower than the 2007 chloride
concentrations. The provided charts demonstrate that waste reduction efforts at the BVF facility are
effective.
10

Charts

Chart #1
Average Cl- Discharge per Day (lbs/day)
12,000
10,000
8,000
6,000
4,000
‘114111111111111111111111V - 111114111111111k
2,000
0
2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019

Chart #2
Annual Production
(Millions of Equivalent Units Produced)
10.000
9.000 -
8.000
1.1111.1111111111
7.000 - �r
6.000 -
♦
5.000
4.000 -
3.000
1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019

Chart#3
Average Instream Chloride Concentration (lbs per day)
2500 -- — ----
- ° Upstream (Background)
- o Downstream Point#1
❑ Downstream Point#2
o Downstream Point#3
2000 Linear(Downstream Point#1)
----Linear(Downstream Point#2)
— — Linear(Downstream Point#3)
1500 _
1000 -
>13A\ - -
500 0
0
Ts
95
0 a ® e ® a e ° e ° a °---4-8 ° ,
1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019

Chart #4
Cl- Discharged per Equivalent Unit (Ibs)
0.60 -
•
0.50
0.40
r
0.30 IPP .41111kik
0.20
0.10
0.00
1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019

Chart #5
Annual Chloride Discharge
(lbs/year)
4,000,000
3,500,000
3,000,000
2,500,000
2,000,000
1,500,000
1,000,000
500,000
0
1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019

Chart #6
2019 Chloride Limits
30,000 _
—•—Average CL-lbs./day
—is—Max Daily Cl- Lbs.
25,000
20,000
Max Daily Limit 19,120 lbs
15,000 -
Monthly Avg Limit 13,476 lbs
10,000
5;000 11A\N
0
January February March April May June July August September October November December