NC0001970_Annual Chloride Reduction Report_20220329

Draper Aden Associates
Engineering • Surveying • Environmental Services
114 Edinburgh South Drive,Suite 200
Cary,NC 27511
919.827.0864
www.daa.com
March 24, 2022
Mr. Danny Smith, Director RECEIVED
Division of Water Quality
North Carolina Department of Environmental Quality VAR 2 9 2022
1617 Mail Service Center
Raleigh, North Carolina 27669-1617
NCDEQIDWRINPDES
Re: 2021 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.: 2200460
Dear Mr. Smith,
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 2021 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 BayValleyFoods, LLC— Faison, NC. Efforts continue to improve process control/automation focused
p Y p
on reducing brine loss and salt waste.
If you have any questions or comments, please contact us at 919-827-0864.
Sincerely,
Draper Aden Associates
(C:fr7(/-45"1"---'— Foilvvt'
James Y.Joyner, II, RSM Jim Hurley, MS, El
Team Leader Environmental Engineer II
Enclosure
cc: Mr. Donovan Brock (1 HC)
Blacksburg• Charlottesville•Manassas •Newport News•Richmond• Virginia Beach •Raleigh

2021 Annual Chloride
Reduction Report
Bay Valley Foods, LLC - Faison, NC
NPDES Permit No. NC00O1970
DAA Project Number
2200460
RECEIVED
March 25, 2022 MAR 2 9 2022
NCDEUD\RJNI
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

Table of Contents
1.0 Basic Information 1
2.0 Production 2
3.0 Evaluated / Implemented Technologies and Approaches 5
4.0 Technologies and 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
6.0 Monthly Chloride Discharges 10
7.0 Annual Average Stream Chloride Levels 11
Tables
Table 2.1 Annual Production Units and Ratio of Chloride Discharged to Production Units 3
Table 2.2 Comparison of All Data (2005 —2021) 4
Table 6.0 Monthly Chloride Discharges 2021 10
Table 7.0 Annual Average Stream Chloride Levels 1997-2021 (mg/L) 11
Charts
Chart 1 Annual Average Chloride Discharge
Chart 2 Annual Production
Chart 3 Chloride Discharged per Equivalent Production Unit
Chart 4 2021 MonthlyChloride Discharge
9
Chart 5 Average Instream Chloride Concentrations
Chart 6 Total Annual Chloride Discharges 1996-2021
2021 Annual Chloride Reduction Report
Bay Valley Foods, LC—Faison, North Carolina
DAA Project No.2200460
March 25, 2022

1.0 Basic Information
Bay Valley Foods, LLC — Faison, NC (BVF), remains committed to continuing 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 in 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.
2021 Annual Chloride Reduction Report
Bay Valley Foods, LC—Faison, North Carolina
DAA Project No.2200460
March 25, 2022
1

2.0 Production
BVF uses an established formula whereby all production types, in all facilities, are normalized. The
normalized 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 from 1996 through 2006 at which
time, production peaked at 9.04 million EPU (Tables 2.1 and 2.2). Since 2006, the production
throughput has generally decreased (Chart 2). The 2021 production volume was 6.10 million EPU, a
28.1% increase from the 2020 volume (4.76 million EPU) (Table 2.1). The 2021 average ratio of chloride
discharged in pounds per EPU (0.30) is slightly below the 1996— 2021 average ratio (0.31) and matches
the 2017 - 2021 five-year average ratio (0.30) (Table 2.2). Due to the ongoing commitment from facility
leadership, the pounds of chloride discharged per EPU continue to show a long-term downward trend
of approximately 0.01 pound discharged per EPU per year (Chart 3).
2021 Annual Chloride Reduction Report
Bay Valley Foods, LC—Faison, North Carolina
DAA Project No.2200460
March 25, 2022
2

Table 2.1: Annual Production Units and Ratio of Chloride Discharged
to Production Units (1996-2021)
Production Chloride to Units
Production Year Equivalent Units
Produced Ratio
(millions)
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 6.60 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
2021 6.10 0.30
Average 1996-2021 7.27 0.31
Average 2017-2021 5.41 0.30
2021 Annual Chloride Reduction Report
Bay Valley Foods, LC-Faison, North Carolina
DAA Project No.2200460
March 25, 2022
3

Table 2.2: Comparison of All Data (2005 - 2021)
Data Description 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Annual Chloride 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 1,991,004 1,829,264
Discharge (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 4,757,562 6,096,246
(equivalent units)
Chloride Discharge
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 0.42 0.30
(lbs/equivalent unit)
Annual NaCI and NA NA NA NA NA NA NA NA NA NA NA NA NA 3,392,194 2,793,822 3,348,508 3,177,496
CaCI Use (Ibs)
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 NA NA NA
(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 2,831,510 3,478,220
(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 0.52 0.62 0.58 0.70 0.52
(lbs/equivalent unit)
Notes:
NA: Data not available
Annual purchases prior to 2018 calculated from salt use per equivalent unit.Values from 2018 to present represent actual chloride use.
2021 Annual Chloride Reduction Report
Bay Valley Foods, LC-Faison, North Carolina
DAA Project No.2200460
March 25, 2022
4

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. 1,500 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 3,000 ton at a cost of $249,000.
2021 Annual Chloride Reduction Report
Bay Valley Foods, LC—Faison, North Carolina
DAA Project No.2200460
March 25, 2022
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.
• 2021 — 280 tons of sludge removed at a cost of $11,000.
2021 Annual Chloride Reduction Report
Bay Valley Foods, LC—Faison, North Carolina
DAA Project No.2200460
March 25, 2022
6

4.0 Technologies and Approaches Considered for 2021 and Beyond
Many projects, programs, process changes, and chloride reduction strategies that were 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
process to re-line Pond 1. Sludge removal was completed in March 2018, and the liner replacement
2021 Annual Chloride Reduction Report
Bay Valley Foods, LC—Faison, North Carolina
DAA Project No.2200460
March 25,2022
7

was completed. Pond 1 aerators were re-wired, and the pond was returned to normal operations on
May 1, 2018. An additional 280 tons of sludge were removed in 2021.
Status: Successful improvements were made to the wastewater ponds. Sludge removal costs -
$296,000.
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.
2021 Annual Chloride Reduction Report
Bay Valley Foods, LC—Faison, North Carolina
DAA Project No.2200460
March 25, 2022
8

5.0 Waste Reduction
The ongoing waste reduction efforts at the Facility have continued 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
pollutionprevention program is inplace which includes educatingemployees re ardin waste best
p 9 regarding
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 minimizing 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 2021 was below the daily maximum limit and the
average monthly discharge was below the monthly average limit (Table 6.0 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 found in
Table 7 indicate decreasing trends (negative slopes) in Downstream Points #1 and #3, and a slightly
increasing trend (positive slope) in Downstream Point #2 (Chart 5).
The total annual chloride discharge generally decreased from 2007 to 2015 (Table 2.2, Chart 6). From
2015 through 2021, chloride discharges have fluctuated, but have remained well below the 2007 level.
The provided charts demonstrate that waste reduction efforts at the BVF facility are effective.
2021 Annual Chloride Reduction Report
Bay Valley Foods, LC—Faison, North Carolina
DAA Project No.2200460
March 25, 2022
9

6.0 Monthly Chloride Discharges
Table 6.0: Monthly Chloride Discharges in 2021
Monthly Average Limit = 13,476 lbs/day
Current Chloride Discharge Limits:
Daily Maximum Limit = 19,120 lbs/day
Chloride Discharges
Month Max Average Total
(lbs/day) (lbs/day) (Ibs)
January 10,017 4,552 141,097
February 8,379 5,273 147,644
March 11,079 5,887 182,483
April 10,598 5,163 154,880
May 9,537 5,862 181,726
June 7,057 3,216 96,483
July 16,825 7,125 220,878
August 10,641 6,809 211,089 1
September 11,655 5,729 171,883
October 6,771 4,875 151,137
November 4,079 3,078 92,350
December 3,930 2,504 77,614
2021 Annual Chloride Reduction Report
Bay Valley Foods, LC-Faison, North Carolina
DAA Project No.2200460
March 25, 2022
10

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CHARTS

Chart 1
Annual Average Chloride Discharge
(lbs/day)
12,000
10,000
8,000
y = -219.85x + 448125
6,000 -
4,000 ••�.
2000 -
0
79 7996, 9 D. �O �O `�O �O D. �O DO `O
9� 79,� 799 `"O OO �O O� 9 O� O�, O� OS 06 c)O O� �O O� �O O� c'O 7O �O 7> �O>� �O 7O �� �O 7S, 76' 7� O�cp c'O 79 �O ��7

Chart 2
Annual Production
(millions of Equivalent Production Units)
10
8 •-..
y = -0.12x + 8.76
7
6 -
5
4
3
2
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O 7 cD 0 S, 6, 6' O O 0 7 �, Q S 6' 8 9 O 7

Chart 3
Chloride Discharged per Equivalent Production Unit
(Ibs/EPU)
0.45 -
0.40
0.35 .... .....
0.30 .........................................
• ... . ..... . .. .. ..... „ y.=:0.01 x.+ 0.38
.......... ......... ..... ...........
.....
0.20
0.15
0.10
0.05
0.00
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J9 00 O> O� 00 Ov OS 06, O 00 00 70 7J 7� 70 7Q 7� 76, 7� 70 �9 �0 ��

Chart 4
2021 Monthly Chloride Discharge
(lbs/day)
25,000
Average Daily Discharge
(Maximum Daily Discharge
—Daily Limit
Monthly Avg. Limit
20,000
Max Daily Limit 19,120 lbs
15,000
Monthly Avg Limit 13,476 lbs
10,000
5,000
0
January February March April May June July August September October November December

Chart 5
Average Instream Chloride Concentrations
(mg/L)
2,500
- Upstream (Background)
- Downstream Point#1
Downstream Point#2
2,000 Downstream Point#3 —
Linear(Downstream Point#1)
Linear(Downstream Point#2)
— — •Linear(Downstream Point#3)
1,500
1,000
_ -15.384x + 904.68
"500
y = 1.6213x + 169.10
y = -1.6681x + 123.86_
79 79 79 79 c CDO O DO C. DO DO DO DO DO CDO DO O O DO c3O DO DO DO DO )O DO
90 9> 96 99 00 07 O? O?, OQ ff. 06 O, 06 09 70 77 7D 7� 75 7S, 76 7- 76 79 �O �7

Chart 6
Total Annual Chloride Discharge 1996-2021
(Ibs/year)
4,000,000
3,500,000 A
3,000,000
2,500,000 —
y = -79824x + 3E+06• .
2,000,000 ..
1,500,000
1,000,000
500,000
0 I I I I I I I I I I I I I I I I I I I I I I I I 1
79 <9 79 79 CDO DO DO CDO DO DO 0 CDO ‘DO DO DO DO DO DO `,O DO DO `-DO DO CDO DO 7'0
96, 9> 96, 99 00 07 OD 00 057 OS, 06, 0> 00 09 70 77 7cD 70 7,7 76, 76, 7> 76) 79 cDo c-D7