NC0001970_Annual Report_20190329

•
March 29, 2019
Alan Klimek, P.E. R�G�t\15);p°
Director Nr 0 a 2419
Division of Water Quality
NPDES East Unit eg
wat�r section
1617 Mail Service Center P®rmit',1n9
Raleigh,NC 27699-1617
Re: Annual Chloride Reduction Evaluation Report(2018)
Bay Valley Foods, LLC, - Faison,NC
NPDES Permit No.NC0001970
Dear Mr. Klimek;
In accordance with Special Condition A. (5)b.;NPDES Permit No.NC0001970, Bay Valley Foods,
LLC-Faison,NC (BVF) continues in efforts to study and evaluate chloride removal technologies and
chloride reduction strategies. Please find enclosed a copy of the facility's 2018 Annual Chloride
Reduction Evaluation 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 replacement of wooden fermentation tanks, reducing salt concentration
in brines, process automation, and brine recycling technology. These early efforts resulted in the
most substantial reductions in salt use with subsequent focus on pollution prevention efforts further
reducing chloride discharges to surface water. As noted in our recent Chloride Variance Request
and all 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 again continued through 2018
in the areas of pollution prevention and improved process control/automation, focused on reducing
brine loss and salt waste.
If you have any questions concerning this submittal, please contact me at [phone].
Sincerely,
BAY A LEY FOODS, LLC
Chad Tennant
Plant Manager
Bay Valley Foods, LLC-Faison, NC
Enclosure
Cc: Kisa Baskin
Kaity Lindner
Donovan Brock
Alyssa Berinhout

•
ANNUAL CHLORIDE REDUCTION EVALUATION
REPORT
YEAR 2018
For
Bay Valley Foods, LLC - Faison, NC
NPDES Permit No. NC0001970
Prepared for:
Bay Valley Foods, LLC
354 Faison Ave.
Faison, North Carolina 28341
Prepared by:
Solutions-IES, a division of Draper Aden Associates
1101 Nowell Road
Raleigh, North Carolina 27607
March 29, 2019
Project Number 1 81 1 7804-01 0701
c J (((
Candy E. Elliott, P.G. James Y. Joyner, II, RSM
Project Geologist Environmental Team Leader

March 2019
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 2018. Comparisons are made to previous years including 1996, the benchmark
year.
Table 1.0 and Chart#5 summarize monthly average chloride discharges in pounds per day for
calendar year 2018. There were no exceedances of either the "Monthly Average Discharge Limit"
or the "Daily Maximum Chloride Discharge Limit" in 2018.
Table 2.0 and Chart#2 provide annual production information for 2018 and for previous years,
measured in equivalent production units, as well as the pounds of chloride discharged per
equivalent production unit. Production volume in 2018 decreased 6.9% compared to 2017. The
2018 chloride lbs. discharged per production unit ratio increased 30% to 0.34 as compared to 0.26
in 2017. The increase appears to be anomalous, and the overall trend is decreasing. Over the
past five years (2014 through 2018), the average chloride lbs. per equivalent unit of production is
0.24 lbs./eq.unit.
Table 3.0 and Chart#4 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 is provided back to 1997, when in-stream chloride
concentration monitoring initially became an NPDES permit requirement. In-stream chloride
concentrations at all monitoring locations, including upstream from the facilities wastewater
discharge outfall, peaked in 2007 as a result of extended drought conditions in the Faison area and
subsequent low stream flow in the receiving stream. More normal precipitation in subsequent
years has resulted in in-stream sampling data that shows a long-term decline in chloride
concentration at all monitoring locations. Chloride concentrations at all downstream monitoring
location decreased in 2018, as compared to 2017.
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 2018.
► Chlorides discharged per equivalent production unit increased 30% compared to 2017, yet
still reflects a significant decrease compared to the benchmark year of 1996 (0.56 lbs CL-
/Eq. Unit). In 2018 it was calculated at 0.34 pounds of chlorides discharged per equivalent
production unit. (Refer to Chart#3)
1

► The 2018 annual production total of 5.486million equivalent production units represents a
6.9% decrease from 2017 production throughput. (Refer to Chart#2)
► The calculated annual pounds of chlorides discharged (1,869,489 lbs.) in 2018 is 48% less
than the largest amount discharged in 2007.

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
2018 Monthly Chloride Discharge Data
Current Chloride Discharge Limits: Monthly Average = 13,476 lb/day
Daily Maximum = 19,120 lb/day
Discharges (Ib/day)
2018
Month
Max Min Avg.
January 6168 1110 2989
February 6036 2793 4106
March 12750 5007 7491
April 12740 1439 6909
May 10850 2938 6117
June 8722 6162 7261
July 6584 4059 5419
August 7969 3250 5208
September 5117 2748 4079
October 8278 2958 4693
November 9315 2358 3916
December 4833 268 3098
* Denotes exceedance of monthly average limit.
** Denotes exceedance daily maximum limit.
3

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Table 4.0
COMPARISON OF ALL DATA
2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2018 2018
Data
Description
Annual 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
Chloride
Discharge
(pounds)
Annual 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
Production
(Equivalent
Units)
Lbs.of 0.33 0.35 0.40 0.38 0.35 0.39 0,25 0.20 0.19 0.21 0,17 0,22 0.26 0.34
Chlorides/
Equivalent
Unit
Annual 119.20 98,03 109,11 94.30 101.78 107.7 115.32 9760 91.61 114,47 133,60 133.77 114,29 118,23
Water Use
(MG)
Annual 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
NaCI&
CaCI
Purchases
(lbs)
Salt Use 0.54 0.55 0.74 0.71 0.56 0.49 0.25 0,51 0.56 0.49 0.37 0.62 1.10 1,20
(lbs.)/
Equivalent
Unit
6

PRODUCTION
Bay Valley Foods, LLC - Faison, NC continues to use 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 through 5-gallon buckets. Basically, this unit brings all production to
a case equivalent volume. This allows for a fair comparison of production between facilities, as
well as between production years, and provides a balanced method to evaluate performance.
The Faison, NC facility production requirements increased annually since the benchmark year of
1996, peaking in 2006. In 2006 the production requirement increased to its highest level since the
benchmark year of 1996 to 9.04 million equivalent production units. Since 2006, the trend
indicates a reduction in production throughput (Refer to Chart#2). 2018 production volume was
5.487 million units, a 6.9% decrease from 2017 volume (5.896 million units). As a result of the
ongoing commitment from facility leadership, the pounds of chloride discharged per equivalent
production unit continue to show a steady long-term downward trend. (Refer to Chart#3). Data
from 2018 represents a slight increase in lbs. of chloride discharged per equivalent unit of
production compared to the long term average of 0.32 lbs per equivalent unit discharged, dating
back to the benchmark year of 1996. Over the past five years (2013 to 2018), the average chloride
lbs. per equivalent unit of production is 0.24 lbs./eq.unit. While 2017 and 2018 indicate a slight
increase in the lbs./eq. unit, it continues to be well below the 2007 maximum.
7

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.
8

• 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 I with an additional
removal and dewatering of 3643 ton at a cost of$368,000.
• 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.
9

TECHNOLOGIES & APPROACHES CONSIDERED
FOR 2018 AND BEYOND
Many projects, programs, process changes and chloride reduction strategies implemented in the
past will continue to be utilized into 2018, such as:
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.
Desalt Process Improvements
The Faison facility added four (4) portable de-salt tanks for product de-salting. Currently the de-
salt process has to be accomplished very quickly to support the production schedule. This quick
de-salting process many times results in over de-salting of the product, which in turn requires 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 will provide improved process control.
Status: Successful process improvements were made to the De-Salt process in 2009. Capitol
Cost Associated with Improvements- $350,000.
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.
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 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.
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.
io

Treatment Technologies
Ramboll Environ prepared a Chloride Removal Technology Evaluation Report dated January 2017.
The report identified several technologies that may be applicable to the BV-Faison facility. The
technologies included reverse osmosis, electrodialysis/electrodialysis reversal, chemical
product substitution, flow augmentation, and residuals management. BayValley
precipitation, 9 9
Foods, LLC is committed to investigating and evaluating any new treatment technology based on
technical applicability and feasibility.
Il

WASTE REDUCTION
The ongoing waste reduction efforts at the Facility will continue through 2019
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 results of these waste reduction efforts can be seen in the decreasing trends in the instream
chloride concentrations and average chloride discharge per day. Chart#4 demonstrates that the
upstream chloride is at background concentrations. An anomalous peak in downstream chloride
concentrations observed in 2007 was attributed to low stream flow conditions throughout the year.
The chloride concentration trend from 2007 to 2014 at Downstream Point#1 is decreasing, and
while the trend is stable to slightly increasing from 2014 to 2018. Chloride concentration trends in
Downstream Point#2 and Downstream Point#3 are decreasing from 2007 to 2018.
Chart#5 shows that the average chloride discharge in pounds per day (lbs/day) decreased from
2007 to 2018. From 2014 to 2018, the concentrations have fluctuated, but have remained lower
than the 2007 chloride concentrations. The provided charts demonstrate that waste reduction
efforts at the BV facility are effective.
12

Charts

Chart#1
Annual Chloride Discharges(Ibs)
4.
3.500.000
:::::::
2.000.000
1,500,000 ....__._
1.000.000
500.000
0
2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

Chart#2
Equivalent Units Produced
10,000.000 f-----
9.000.000
8.000.000
7,000.000 — --- ---� —
6.000,000
♦
5.000.000
4.000.000
3.000.000
2.000.000
1.000.000
0 •
1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

Chart#3
Cl- Discharged per Equivalent Unit(Ibs)
0.60
,., ' z4 4s ?`11f S 1 5'%$r,' 1
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050
0.30
020
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0.10 ? ;
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1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

Upstream (Background)
Chart#4 —a-- Downstream Point#1
a Downstream Point#2
Instream Chloride Concentration (lbs per day) a Downstream Point#3
Linear(Downstream Point#1)
----Linear(Downstream Point#2)
— — Linear(Downstream Point#3)
9"
❑ g
2000 �—
1500
a
1000 ta
a
0
500 .._ °_,_ ❑ u
a Q
a a 0
g
a c El— 8 � 8— —o— —6— a— a —
0
1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

Chart#5
Average Cl- Discharge per Day(Ibs)
12.000
0000
8.000
6.000
141141.11111110
4.000 .
2.000
1
2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

Chart#6
Average CL-lbs./day
2018 Chloride Limits
30.000
i I
25.000
- I
20.000 —
Max Daily Limit 19;i20 lbs
15,000
Monthly Avg Limit 13,476 lbs
Vic)
10 000
5 000 _
0
January February March April May June July August September October November December