NC0001970_2020 Annual Report (Chloride Reduction)_20210318

Strickland, Bev
From: James Joyner <[e-mail]>
Sent: Thursday, March 18, 2021 2:38 PM
To: Smith, Danny
Cc: Brock, Donovan
Subject: Bay Valley Foods Chloride Reduction Report
Attachments: RPT 21 0312 Chloride Reduction_Final.pdf
WARNING - External email; exercise caution
Attached please find the Bay Valley Foods Chloride Reduction Report for 2020. Please let us know if you have any
questions. Thanks.
James Y. Joyner, II
NC Environmental Team Leader
Draper Aden Associates
Engineering • Surveying • Environmental Services
Lasting Positive Impact®
Phone: [phone] • Mobile [phone]
daa.com
i

Draper Aden Associates
Engineering • Surveying • Environmental Services
114 Edinburgh SOuth Drive
Suite 200
Cary, North Carolina 27511
919.827.0864
www.daa.com
March 15, 2021
Mr. Danny Smith, Director
Division of Water Quality
North Carolina Department of Environmental Quality
1617 Mail Service Center
Raleigh, North Carolina 27669-1617
Re: 2020 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.: 2100309
Dear Mr. Smith,
Via email: [e-mail]
On behalf of Bay Valley Foods, LLC, Draper Aden Associates is pleased to present the 2020 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 2020 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 previous Annual Chloride Reduction Evaluation Reports, there have been
no economically feasible advances 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
James Y. Joyner, II, RSM
Candy E. Elliott, P.G.
Team Leader Project Geologist
Enclosure
cc: Mr. Donovan Brock (1 HC)
Blacksburg • Charlottesville • Manassas • Newport News • Richmond • Virginia Beach
Fayetteville • Raleigh

2020 Annual Chloride
Reduction Report
Bay Valley Foods, LLC - Faison, NC
NPDES Permit No. NC0001970
DAA Project Number
2100309
March 15, 2021
Prepared for
Bay Valley Foods, LLC
354 N. Faison Avenue
Faison, North Carolina 28341
Prepared by
Draper Aden Associates
114 Edinburgh South Drive
Cary, NC 27511
Draper Aden Associates
Engineering • Surveying • Environmental Services

3RD PARTY REVIEW
This Report has been subjected to technical and quality reviews by:
Candy Elliott
Candy Elliott, PG
Project Geologist
William D. Newcomb, PG
William D. Newcomb, PG
Senior Program Manager
Signature
F�
Signature
March 12, 2021
Date
March 10, 2021
Date
March 15, 2021
James Y. Joyner II, RSM
Team Leader
2020 Annual Chloride Reduction Report
Bay Valley Foods, LC — Faison, North Carolina
NPDES Permit No. NC0001970
DAA Project No. 2100309
March 15, 2021
Signature Date

TABLE OF CONTENTS
1.0 BASIC INFORMATION 1
2.0 PRODUCTION 2
3.0 EVALUATED / IMPLEMENTED TECHNOLOGIES AND APPROACHES 5
4.0 TECHNOLOGIES / APPROACHES CONSIDERED FOR 2021 AND BEYOND 7
4.1 Bypass Salting / No Fermentation Process 7
4.2 Desalt Process Improvements 7
4.3 Brine Reclaim Process Improvement - 5-gallon Pail Line 7
4.4 Wastewater Treatment Process Improvements 7
4.5 Pickle Packers International (PPI) 8
4.6 Treatment Technologies 8
5.0 WASTE REDUCTION 9
TABLES
Table 1 Annual Production Units and Chloride to Production Ratio (1996-2020) 3
Table 2 Comparison of All Data (2005 — 2020) 4
Table 3 Monthly Chloride Discharge 2020 10
Table 4 Annual Average Stream Chloride Levels 1997-2020 (mg/L) 11
Chart 1
Chart 2
Chart 3
Chart 4
Chart 5
Chart 6
CHARTS
Average Chloride Discharge
Annual Production
Chloride Discharged (Ibs/equivalent unit)
Chloride Limits
Average Instream Chloride Concentrations
Annual Chloride Discharge 1996-2020
2020 Annual Chloride Reduction Report
Bay Valley Foods, LC — Faison, North Carolina
NPDES Permit No. NC0001970
DAA Project No. 2100309
March 15, 2021

1.0 BASIC INFORMATION
Bay Valley Foods, 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 (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.
2020 Annual Chloride Reduction Report
Bay Valley Foods, LC — Faison, North Carolina
NPDES Permit No. NC0001970
DAA Project No. 2100309
March 15, 2021
1

2.0 PRODUCTION
BVF 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 a 10-ounce jar to 5-gallon bucket. The Equivalent Production Unit
(EPU) 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 through 2006, at which time production peaked at 9.04 million EPU (Tables 1 and 2). Since 2006,
the trend indicates a reduction in production throughput (Chart 2). The 2020 production volume was
4.575 million EPU, a 1.6% decrease from the 2019 volume (4.835 million EPU) (Table 1). The 2020
average ratio of chloride discharged in pounds per EPU (0.42) is above the 1996 — 2020 average ratio
(0.31) and the 2015 - 2020 five-year average ratio (0.29) (Table 1). The increase in chloride discharge
per EPU in 2020 is due to the production of a new product that requires fermenting. Due to the
ongoing commitment from facility leadership, the pounds of chloride discharged per EPU continue to
show a long-term downward trend (Chart 3).
2020 Annual Chloride Reduction Report
Bay Valley Foods, LC — Faison, North Carolina
NPDES Permit No. NC0001970
DAA Project No. 2100309
March 15, 2021
2

Table 1: Annual Production Units and Chloride to Production Ratio (1996-2020)
Production Year
■
Production
Equivalent Units
(millions)
Chloride to Units
Produced Ratio
1996
5.74
0.51
1997
NA
NA
1998
NA
NA
1999
7.09
0.37
2000
7.28
0.38
2001
7.59
0.31
2002
7.84
0.28
2003
8.52
0.37
2004
8.75
0.31
2005
7.86
0.33
2006
9.04
0.35
2007
8.98
0.40
2008
8.57
0.38
2009
8.82
0.35
2010
8.23
0.39
2011
7.85
0.25
2012
7.26
0.20
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
2020
4.76
0.42
Average 1996-2020
7.289
0.31
Average 2015-2020
5.803
0.27
2020 Annual Chloride Reduction Report
Bay Valley Foods, LC - Faison, North Carolina
NPDES Permit No. NC0001970
DAA Project No. 2100309
March 15, 2021
3

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Data Description "I
Annual Chloride Discharge
(Ibs)
Annual Production
(equivalent units)
Chloride Discharge Per
Equivalent Unit
(Ibs/equivalent unit)
Annual NaCI and CaCI Use
(Ibs)
Annual Water Use (MG)
Annual NaCI & CaCI
Purchases
(Ibs)
Salt Use per Equivalent Unit
(Ibs/equivalent unit)

3.0 EVALUATED / IMPLEMENTED TECHNOLOGIES AND APPROACHES
Summary of Chloride Reduction Strategies Implemented and / or Evaluated at Faison, NC
• 1982 through 1990 — Replaced 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.
2020 Annual Chloride Reduction Report
Bay Valley Foods, LC — Faison, North Carolina
NPDES Permit No. NC0001970
DAA Project No. 2100309
March 15, 2021
5

♦ 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.
♦ 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.
2020 Annual Chloride Reduction Report
Bay Valley Foods, LC — Faison, North Carolina
NPDES Permit No. NC0001970
DAA Project No. 2100309
March 15, 2021
6

4.0 TECHNOLOGIES / APPROACHES CONSIDERED FOR 2021 AND BEYOND
Many projects, programs, process changes and chloride reduction strategies implemented in the past
continued to be utilized into 2021 as described in the following sections.
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, BVF removed biomass accumulation from Pond 1 and began the
2020 Annual Chloride Reduction Report
Bay Valley Foods, LC — Faison, North Carolina
NPDES Permit No. NC0001970
DAA Project No. 2100309
March 15, 2021
7

process to re -line 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)
BVF is a member of, and continues to participate in, the Pickle Packers International organization.
Through participation in this organization, BVF 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 BVF facility. The technologies
included reverse osmosis, electrodialysis / electrodialysis reversal, chemical precipitation, product
substitution, flow augmentation, and residuals management. BVF is committed to investigating and
evaluating any new treatment technology based on technical applicability and feasibility.
2020 Annual Chloride Reduction Report
Bay Valley Foods, LC — Faison, North Carolina
NPDES Permit No. NC0001970
DAA Project No. 2100309
March 15, 2021
8

5.0 WASTE REDUCTION
The ongoing waste reduction efforts at the Facility will continue through 2021.
The facility has formed a cross -functional Pollution Prevention Team (Team) that 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 waste best
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, BVF 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 2020 was below the daily maximum limit and the
average monthly discharge was below the monthly average limit (Table 3 and Chart 4). 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 (negative slopes) in Downstream Points #1 and #3, and an increasing trend (slightly
positive slope) in Downstream Point #2 (Chart 5).
The average annual chloride discharge decreased from 2007 to 2020 (Table 4, Chart 6). From 2015 to
2020, chloride concentrations have fluctuated, but have remained below the 2007 concentrations. The
provided charts demonstrate that waste reduction efforts at the BVF facility are effective.
2020 Annual Chloride Reduction Report
Bay Valley Foods, LC — Faison, North Carolina
NPDES Permit No. NC0001970
DAA Project No. 2100309
March 15, 2021
9

Table 3: Monthly Chloride Discharge 2020
Current Chloride Discharge
Monthly Average = 13,476 lb/day
Limits:
Daily Maximums= 19,120 lb/day
Chloride Discharge
(Ib/day)
Month
Max
Min
Avg.
January
5719
1387
3487
February
8109
787
4812
March
7081
2210
4027
April
9434
931
4958
May
8166
3963
5560
June
8714
3298
5717
July
12762
2712
8708
August
14509
8425
10442
September
9693
308
3948
October
9045
2158
5106
November
8629
1678
4399
December
7367
2269
3986
2020 Annual Chloride Reduction Report
Bay Valley Foods, LC — Faison, North Carolina
NPDES Permit No. NC0001970
DAA Project No. 2100309
March 15, 2021
10

Table 4:
Annual Average Stream Chloride Levels 1997-2020 (mg/L)
Year
Upstream
Downstream 1
Downstream 2
Downstream 3
1997
9.1
771
249
132
1998
21
963
271
133
1999
23
616
132
92
2000
22
601
91
66
2001
25
753
123
102
2002
30
790
290
170
2003
20
354
81
60
2004
22
424
52
45
2005
24
768
121
91
2006
23
565
99
74
2007
37
2129
516
249
2008
26
1284
174
149
2009
38
1133
194
140
2010
33
974
314
125
2011
29
900
436
130
2012
64
731
167
159
2013
27
587
98
79
2014
25
310
94
61
2015
20
320
140
70
2016
24
402
252
60
2017
19
482
330
76
2018
23
244
114
53
2019
23
526
214
77
2020
18
243
106
44
2020 Annual Chloride Reduction Report
Bay Valley Foods, LC — Faison, North Carolina
NPDES Permit No. NC0001970
DAA Project No. 2100309
March 15, 2021
11

CHARTS

Chart #1
Average Chloride Discharge
(Ibs/day)

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y = 1.4855x + 170.32
y =-16.004x + 910.26
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