NC0001970_Annual Report_20230328

114 Edinburgh S. Drive, Ste. 200 T 9119.827-08G4
�Ilk TRC Cary, NC 27511 TRCcompanies-corn
March 24, 2023
Dr. Amir Adaryani
Division of Water Quality
North Carolina Department of Environmental Quality
1617 Mail Service Center
Raleigh, North Carolina 27669-1617
Re: 2022 Annual Chloride Reduction Report
Pickles Manufacturing, LLC (formerly Bay Valley Foods, Dean's Pickles)
354 N. Faison Avenue, Faison, North Carolina
NPDES Permit No. NCO001970
TRC Project No.: 534277
Dear Dr. Adaryani,
On behalf of Pickles Manufacturing, LILC (formerly Bay Valley Foods, Dean's Pickles), TRC Engineers
Inc. (TRC, formerly Draper Aden Associates) is pleased to present the 2022 Annual Chloride Reduction
Report for the Faison, NC, facility.
In accordance with Special Condition A. (5) b.: NPDES Permit No. NCO001970, Pickles Manufacturing,
LILC-Faison, NC, continues efforts to study and evaluate chloride removal technologies and chloride
reduction strategies. Enclosed please find a copy of the facility's 2022 Annual Chloride Reduction
Report. Throughout 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. These 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 recent
economically feasible advances in chloride removal technologies applicable to the production
processes employed at Pickles Manufacturing, LLC — Faison, NC. Efforts continue to improve process
control and automation with a focus on reducing brine loss and salt waste.
If you have any questions or comments, please contact us at 919-423-2016.
Sincerely,
TRC Engineers Inc.
Bilgen Yuncu, PhD, PE, PMP
Environmental Engineer/Project Manager
Enclosure
cc: Donovan Brock, Doug Dowden
Jim Hurley, MS, El
Project Environmental Engineer I

TIR C
2022 Annual
Chloride Reduction
Report
Pickles Manufacturing, LLC
(Formerly Bay Valley Foods, Dean's
Pickles)
Faison, NC
NPDES Permit: NCO001970
March 24, 2023
Prep6red by.- Jim Hurley
Project Environmental Engineer I
Prepared For:
Pickles Manufacturing, LLC
354 N. Faison Avenue
Faison, North Carolina 28341
Prepared By:
TRC Engineers Inc.
114 Edinburgh South Drive
Suite 200
Cary, NC 27511
Uz I �!fxl MAN M711 �, I MFIO Is
WIVA
Reviewed and Approved by: Bilgen Yuncu
Environmental Engineer/Project Manager

TIRC
TABLE OF CONTENTS
1.0
BASIC INFORMATION .................................................................................................. 1
2.0
PRODUCTION ............................................................................................................... 1
3.0
EVALUATED/IMPLEMENTED TECHNOLOGIES AND APPROACHES ....................... 4
4.0
TECHNOLOGIES AND APPROACHES CONSIDERED FOR 2022 AND BEYOND ...... 5
4.1 Bypass Salting / No Fermentation Process ........................................................................ 5
4.2 Desalt Process Improvements ............................................................................................ 5
4.3 Brine Reclaim Process Improvement — 5-Gallon Pail Line ................................................. 5
4.4 Wastewater Treatment Process Improvements .................................................................. 6
4.5 Pickle Packers International (PPI) ...................................................................................... 6
4.6 Treatment Technologies ..................................................................................................... 6
5.0
WASTE REDUCTION .................................................................................................... 6
6.0
MONTHLY CHLORIDE DISCHARGES .......................................................................... 7
7.0
ANNUAL AVERAGE INSTREAM CHLORIDE CONCENTRATIONS ............................. 8
TABLES
Table 2.1 Annual Production Units and Ratio of Chloride Discharged to Production
Units.................................................................................................................... 2
Table 2.2 Comparison of Annual Data (2005 — 2022) .......................................................... 3
Table 6.0 Monthly Chloride Discharges 2022 ...................................................................... 7
Table 7.0 Annual Average Instrearn Chloride Concentrations 1997-2022 (mg/L) ................. 8
CHARTS
Chart 1
Annual Average Daily Chloride Discharges
Chart 2
Annual Equivalent Production Units
Chart 3
Pounds of Chloride Discharged per EPU Produced
Chart 4
2022 Monthly Chloride Discharges
Chart 5
Annual Average Instrearn Chloride Concentrations
Chart 6
Total Annual Chloride Discharges 1996-2022
2022 Annual Chloride Reduction Report March 24, 2023
Pickles Manufacturing, LLC — Faison, North Carolina i
TRC Project No. 534277

TIRC
1.0 Basic Information
Pickles Manufacturing, LLC (formerly Bay Valley Foods) — Faison, INIC (PM), 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,
PM maintains its focus on the reduction of chlorides in its waste stream (Chart 1). PM 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. PM 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.
2.0 Production
PM 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 1 O-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, INIC 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 2022 production volume was
5.15 million EPU, a 15.5% decrease from the 2021 volume (6.10 million EPU) (Table 2.1). The
2022 average ratio of chloride discharged in pounds per EPU (0.37) is slightly above the 1996 —
2022 average ratio (0.32) and, also, above the 2018 - 2022 five-year average ratio (also 0.32)
(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 0.006
pounds discharged per EPU per year (Chart 3).
2022 Annual Chloride Reduction Report March 24, 2023
Pickles Manufacturing, LLC — Faison, North Carolina 1
TRC Project No. 534277

4
,Ar TRC
Table 2.1: Annual Production Units and Ratio of Chloride Discharged to Equivalent
Production Units (1996-2022)
�-
Production Year
1996
Production
Equivalent Units
(millions)
5.74
Chloride to Units
Produced Ratio
0.51
1997
NA
NA
1998
NA
NA
1999
7.09
0.37
2000
7.28
0.38
2001
7.59
0.31
2002
8.71
0.28
2003
8.45
0.37
2004
8.32
0.31
2005
8.23
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
5.90
0.26
2018
5.49
0.34
2019
4.83
0.19
2020
4.76
0.42
2021
6.10
0.30
2022
5.15
0.37
Average 1996-2022
7.19
0.32
Average 2018-2022
5.27
0.32
Notes:
NA - Data not available
2022 Annual Chloride Reduction Report March 24, 2023
Pickles Manufacturing, LLC - Faison, North Carolina 2
TRC Project No. 534277

TIRC
Table 2.2: Comparison of Annual Data (2005 - 2022)
Data Description
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
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
1,898,836
Discharge (lbs)
Annual Production
(Equivalent 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
5,152,050
Units)
Chloride Discharge per
Equivalent Unit
0.33
0.35
0.4
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
0.37
(lbs/EPU)
Annual NaCl and CaC12
NaCl: 2,989,800
NaCl: 2,772,594
Use
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
3,392,194
2,793,822
3,348,508
CaC12: 377,370
CaC12: 459,899
(lbs)
Annual Water Use (MG)
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
140.24
91.38
135.88
153.72
123.90
Annual NaCl & CaC12
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
3,342,506
(lbs)
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
0.63
(lbs/EPU)
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.
2022 Annual Chloride Reduction Report March 24, 2023
Pickles Manufacturing, LLC; - Faison, North Carolina 3
TRC Project No. 534277

TIRC
3.0 Evaluated/implemented Technologies and Approaches
Summary of Chloride Reduction Strateaies ImDlemented 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
0 2003, 2004, 2005, 2006 — Evaluate Use of De -Salt Water for Brining and/or Product
Fluming
0 2003, 2004, 2005, 2006 — Evaluate Use of De -Salt Water for Subsequent De -Salting
Operations
0 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 at a cost of $4,500
2009 — Implemented Upgrade Desalting Operation by Installing Four Additional De -
Salt Tanks at a cost of $350,000
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.
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.
2022 Annual Chloride Reduction Report March 24, 2023
Pickles Manufacturing, LLC — Faison, North Carolina 4
TRC Project No. 534277

Alk TIR C
0 2016 - Implemented removal process of excess biomass from Pond 2 with removal
and dewatering of 3727 tons at a cost of $230,000.
0 2016 — Implemented removal and replacement of Pond 2 liner and begin
construction and lining of Pond 3 at a cost of $500,000.
0 2016 — Evaluate Reverse Osmosis and Electrodialysis/Electrodialysis Reversal to
Reduce Chloride at End -of -Pipe. Neither technology was considered feasible due to
cost considerations.
0 2017 — Completed the excess biomass removal from Pond 3 with removal and
dewatering of 1,963 tons at a cost of $336,000.
0 2017 — Completed installing the new liner at Pond 3 on April 1, 2017 at a cost of
$100,000
0 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.
2022 — 2,231 tons of sludge removed at a cost of $51,850
4.0 Technologies and Approaches Considered for 2022 and Beyond
Many projects, programs, process changes, and chloride reduction strategies that were
implemented in the past continued to be utilized into 2022 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.
2022 Annual Chloride Reduction Report March 24, 2023
Pickles Manufacturing, LLC — Faison, North Carolina 5
TRC Project No. 534277

Alk TIR C
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, PM removed biomass accumulation from Pond 1 and
began the process to re -line Pond 1. Sludge removal and liner replacement was completed in
March 2018. Pond 1 aerators were re -wired, and the pond was returned to normal operations
on May 1, 2018. An additional 280 tons of sludge was removed in 2021, and 2,231 tons of
sludge was removed in 2022 at a cost of $51,850 .
Status: Successful improvements were made to the wastewater ponds. Sludge removal costs
to date - $347,850.
4.5 Pickle Packers International (PPI)
PM is a member of, and continues to participate in, the Pickle Packers International
organization. Through participation in this organization, PM 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 PM facility.
The technologies included reverse osmosis, electrodialysis / electrodialysis reversal, chemical
precipitation, product substitution, flow augmentation, and residuals management. PM is
committed to investigating and evaluating any new treatment technology based on technical
applicability and feasibility.
5.0 Waste Reduction
The ongoing waste reduction efforts at the Facility have continued through 2022.
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 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, PM 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.
2022 Annual Chloride Reduction Report March 24, 2023
Pickles Manufacturing, LLC — Faison, North Carolina 6
TRC Project No. 534277

4
,ir TRC
The maximum daily discharge for each month in 2022 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 PIVI facility
are effective.
6.0 Monthly Chloride Discharges
Table 6.0: Monthly Chloride Discharges in 2022
Current Chloride Discharge Limits: Monthly Average Limit = 13,476 lbs/day
Daily Maximum Limit 19,120 Ibs/day
2022 Chloride Discharges
Month
Max
(lbs/day)
Average
(lbs/day)
Total
(lbs)
January
11,435
5,273
163,463
February
11,427
6,983
195,520
March
11,354
9,715
301,152
April
9,756
6,041
181,237
May
9,133
7,001
217,027
June
10,202
5,722
171,660
July
10,445
6,181
191,614
August
7,407
4,642
143,898
September
5,216
2,425
72,750
October
5,337
3,770
116,862
November
3,226
2,361
70,820
December
3,606
2,349
72,829
2022 Annual Chloride Reduction Report March 24, 2023
Pickles Manufacturing, LLC - Faison, North Carolina 7
TRC Project No. 534277

TRC
7.0 Annual Average Instrearn Chloride Concentrations
Table 7.0: Annual Average Instrearn Chloride Concentrations 1997-2022 (mg/L)
Year
1997
Upstream
9.1
Downstream 1
771
Downstream 2
249
Downstream 3
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
2,129
516
249
2008
26
1,284
174
149
2009
38
1,133
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
2021
18
567
225
96
2022
25
892
296
124
2022 Annual Chloride Reduction Report March 24, 2023
Pickles Manufacturing, LLC — Faison, North Carolina 8
TRC Project No. 534277

TIRC
Charts

Pickles Manufacturing LLC - Faison NC
NPIDES: NCO001970
12000
10000
8000
6000
0
0
0
CL
w 4000
W
0
2000
Chart 1
Annual Average Daily Chloride Discharges
199S 1997 1999 2001 2003 2005 2007 2009
Yeai
TRC Engineers — Cary NC
March 24, 2023
pill a �1161 19�141 16�1161 W�141 La�xlyj �101j;�IQPJI

Pickles Manufacturing LLC - Faison NC TRC Engineers — Cary NC
NPIDES: NCO001970 March 24, 2023
Chart 2
Annual Equivalent Production Units (Millions of EPUs)
10
9
8
7
6
Uj
4--
0
LO
C:
0
R
3
2
1
0 1
1995 1997 1999 2001 2003 2005 2007 2009 2011 2013 201S 2017 2019 2021 2023 202S
Year

Pickles Manufacturing LLC - Faison NC TRC Engineers — Cary NC
NPIDES: NCO001970 March 24, 2023
Chart 3
Pounds of Chloride Discharged Per EPU Produced (lbs CI-/EPU)
0.6
0.5
y = -0.0055x+ 11.398
n2 f% I%f%f%n
0.4
LU
0.3
0
0-
0.2
0.1
0 1
1995 1997 1999 2001 2003 2005 2007 2009 2011 2013 2015 2017 2019 2021 2023 2025
Year

Pickles Manufacturing LLC - Faison NC
NPDES: NCO001970
22,000
>- 18,000
16,000
CL
14,000
LA 12,000
0
10,000
U 8,000
%0-.
0
6,000
0
CL 4,000
MIS
11
Chart 4
2022 Monthly Chloride Discharges (pounds per day)
e6
05
Monthly Average Daily Discharge
TRC Engineers — Cary NC
March 24, 2023
44�, S, Oct /VO 0.
Ob t, ' Ile On
rt L '076", 0*7601-
Monthly Maximum Daily Discharge
Monthly Average Daily Discharge Limit — Daily Discharge Limit

Pickles Manufacturing LLC - Faison NC
NPIDES: NCO001970
Chart 5
Annual Average Instrearn Chloride Concentrations
2,200
2,000
1,800
1,600
E 1,400
E2 1,200
1,00D
0
U
80()
600
4c.�_:
200
TRC Engineers — Cary NC
March 24, 2023
0 1 - - - - - — - - — - - - — - - - -
1995 1997 1999 2001 2003 2005 2007 2OD9 2011 2013 2015 2017 2019 2021 2023 2025
Year
0 Upstream (Background) 0 Downstream Point #1 Downstream Point #2 Downstream Point #3
......... Linear (Upstream (Background)) ......... Linear (Downstream Point #1) Linear (Downstream Point #2) ......... Linear (Downstream Point #3)

Pickles Manufacturing LLC - Faison NC
NPIDES: NCO001970
4,000,000
MOM
RJEN�, I
cu
.2 2,000,000
0
1,500,000
0
0-
IIIIIIIIIIIIIIIIIIIII2291,11M
Chart 6
Total Annual Chloride Discharges 1996 - 2022
1995 1997 1999 2001 2003 2005 2007 2009 2011
Year
TRC Engineers — Cary NC
March 24, 2023
2013 2015 2017 2019 2021 2023 2025