NC0001970_Annual Chloride Reduction Evaluation Report_20150402

I'
March,28, 2015 RECEIVEDIDENI DWR
APR - 2 2015
Alan Klimek,P.E.
Director Water( lithl
n
Division of Water Quality Permitting
NPDES East Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Annual Chloride Reduction Evaluation Report(2013)
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 fmd enclosed a copy of the facility's 2014 Annual
Chloride Reduction Evaluation Report. As stated in previous reports, through the 1980's and the
1990'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 2014 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(800)-768-2283,Ext. 237.
Sincerely,
B Y VALLEY FOODS,LLC
fILQ/vuh1/
Pegg`y�lienr"y
Plant Manager
Bay Valley Foods, LLC-Faison, NC
1

Enclosure
Cc: Bob O'Neill
Chuck Stanton
Donovan Brock
Tim Wolf
2

ANNUAL CHLORIDE
REDUCTION EVALUATION REPORT
YEAR 2014
For
Bay Valley Foods, LLC - Faison, NC
Prepared for the
State of North Carolina
Dept. of Environment and Natural Resources
Division of Water Quality— Water Quality Section
NPDES Permit No. NC0001970
Prepared and/or Reviewed by:
Timothy Wolf, Corporate Environmental Specialist
Bob O'Neil, Sr. Director Environmental, Health, Safety & Security
Donovan Brock, Facility Environmental Contact, BVF-Faison, NC
Peggy Henry, Plant Manager, BVF-Faison, NC
3

March 2015
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 2014. Comparisons are made to previous years including 1996, the benchmark
year.
Table 1.0; Chart#5 summarizes monthly average chloride discharges in pounds per day for
calendar year 2014. There were no exceedances of either the "Monthly Average Discharge Limit'
or the "Daily Maximum Chloride Discharge Limit' in 2014.
Table 2.0; Chart#2 provides annual production information for 2014 and for previous years,
measured in equivalent production units, as well as the pounds of chloride discharged per
equivalent production unit. Production volume in 2014 declined 4.0 %compared to 2013. The
2014 chloride lbs. discharged per production unit ratio increased 9.5%to of 0.21 as compared to
2013. More importantly,2014 data represents a continuous decline in lbs. of chlorides discharged
per equivalent unit of production compared to the long term average of 0.33 lbs discharged, dating
back to the benchmark year of 1996. From 2011 to 2014, the average chloride lbs. per equivalent
unit of production stands at 0.21.
Table 3.0; Chart#4 summarizes 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 continuing decline in chloride
concentration at all monitoring locations, most notably at Downstream Monitoring Point#1, where
the 2014 chloride concentration was the lowest since the inception of monitoring in 1997.
(Refer to Chart#4)
Table 4.0 summarizes data pertinent to chloride discharges from 2000 through 2014.
► Bay Valley Foods, LLC - Faison, NC did not exceed the "Daily Maximum Chloride
Discharge Limit'or the "Monthly Average Discharge Limit" in 2014.
► Chlorides discharged per equivalent production unit increased 9.5%compared to 2013, yet
still reflects a significant decrease compared to the benchmark year of 1996 (0.56 lbs CL-
4

/Eq. Unit). In 2014 it was calculated at 0.21 pounds of chlorides discharged per equivalent
production unit. (Refer to Chart#3)
► The 2014 annual production total of 6.603 million equivalent production units represents a
slight decrease from 2013. (Refer to Chart#2)
► The calculated annual pounds of chlorides discharged (1,418,341 lbs.) in 2014 is the
second lowest annual total on record.
► In 2014 Bay Valley Foods continued the process of removing excess biomass from its
wastewater treatment lagoons to improve treatment performance with the removal of 1,368
tons, at a cost of$148,154. The facility continues to implement best management practices
throughout the food production process aimed at minimizing brine loss and maximizing the
efficient use of salt in the production process.
5

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 inefficient equipment and ongoing efforts in the identification and
implementation of new and innovative reduction opportunities, BVF-Faison maintains its focus on
the reduction of chlorides from its waste stream. 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
2014 Monthly Chloride Discharge Data
Current Chloride Discharge Limits: Monthly Average = 13,476 lb/day
Daily Maximum = 19,120 lb/day
Chloride Discharges (lb/day)
2013
Month
Max Min Avg.
January 4869 318 1507
February 2862 581 1726
March 11792 1834 4543
April 9628 3382 5263
May 8622 3170 5485
June 8232 4072 5762
July 8966 1631 4905
August 6867 2298 4589
September 7119 2499 4644
October 6613 1945 3614
November 6470 976 2522
December 5591 674 2044
' Denotes exceedance of monthly average limit.
• Denotes exceedance daily maximum limit.
6

Table 2.0
Annual Production Numbers& Chloride to Production Ratio
Production Production Chloride to Units Produced
Year Equivalent Ratio
Units (lbs./Eq. Unit)
1996 5.74 0.51
1997 4.95 0.72
1998 6.22 0.59
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 0.30
2005 7.86 0.35
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
7

Table 3.0
Annual Average Stream Chloride Levels (mg/L) _
Year Upstream Downstream Downstream Downstream
1 2 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
8

Table 4.0
COMPARISON OF ALL DATA
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014
Data
Description
Annual 2,748,45 2,468,49 2,857,22 3,157,98 2,584,60 2,742,24 3,133,18 3,589,05 3,259,496 3,090,730 3,193,908 1,962,923 1,464,092 -1,273,754 1,418,341
Chloride 0 5 0 0 9 5 9 4
Discharge
(pounds)
Annual 7,275,37 7,590,54 7,835,62 8,517,18 8,749,94 7,858,54 9,039,50 8,981,99 8,572,000 8,821,135 8,226,436 7,846,314 7,258,154 6,816,632 6,602,658
Production 6 1 7 9 2 4 0 0
(Equivalent
Units)
Lbs.of 0.38 0.33 0.36 0.37 0.30 0.35 0.35 0.40 0.38 0.35 0.39 0.25 0.20 0.19 0.21
Chlorides/
Equivalent
Unit
Annual 92.65 69.77 60.54 73.67 105.45 119.2 98.03 109.11 94.30 101.8 107.7 115.3 97.60 91.61 114.7
Water Use
(MG)
Annual 4,168 3,933 3,825 4,324 3,578 4,409 4,929 6,652 8,104 4,913 4,020 1,998 3,702 3,805 3,228
NaCI&
CaCI
Purchases
(Tons)
Salt Use 1.15 1.04 0.88 1.02 0.86 1.07 1.09 1.48 1.42 1.11 0.98 0.51 1.07 1.12 0.98
(lbs)/
Equivalent
Unit
9

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 quart 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. 2014 production volume was 6.60 million, a 3.3%
decrease from 2013 volume. (6.82 million) As a result of the ongoing commitment from facility
leadership, the pounds of chlorides discharged per equivalent production unit continue to show a
steady downward trend. (Refer to Chart#3)
10

EVALUATED AND/OR IMPLEMENTED
TECHNOLOGIES AND APPROACHES 2013/2014
Wastewater Management
Bay Valley Foods-Faison continued with a significant wastewater treatment improvement project in
2014 involving the removal of excess biomass from one of its three wastewater treatment ponds.
Status:
A total of 1,368 tons of excess biomass was removed, dewatered and disposed of, at a cost of
over$148,154.
11

TECHNOLOGIES & APPROACHES CONSIDERED
FOR 2014 AND BEYOND
Many projects, programs, process changes and chloride reduction strategies implemented in the
past will continue to be utilized into 2014, such as:
Bypass Saltino/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.
Brine Loss Reduction Pickle Conveyor Pump
A significant volume of brine is lost annually during the transfer of processed pickles from
fermentation tanks to totes destined for packaging lines. This lost brine ultimately is discharged as
process wastewater. This project, completed in 2010, involved the installation a catch pan and
modified pump on the transfer conveyor to capture and reclaim brine historically lost during the
transfer process. It is estimated this project reduced annual brine loss by 3,000,000-gallons, which
equates to a reduction of 625 tons of salt being discharged.
Status: Modifications to the pickle conveyor and pump replacement were completed in 2010.
Project Cost was $6,000.
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 which result in reduced chlorides in
wastewater discharges.
12

Treatment Technoloales
Literature review and research did not identify any new or emerging chloride reduction
technologies in 2013. Bay Valley Foods, LLC is committed to investigating and evaluating any new
treatment technology based on technical applicability and feasibility.
13

WASTE REDUCTION
The ongoing waste reduction efforts at the Facility will continue through 2014.
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.
14

•
.1
1
-1
Charts
15
..ll .i. _ .►1i. y - - - .1:1.114 :_�_rn,.; r�L Lar1��.IS6 Jld��

4,000,000
3,500,000
�tItI�I�I�Id�I
2,500,000
2,000,000
1,500,000
1,000,000
go
Chart #1
Annual Chloride Discharges (lbs)
1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014
16

10,000,000
MOM
Mir M
7,000,000
5,000,000
4,000,000
3,000,000
2,000,000
1,000,000
0
Chart #2
Equivalent Units Produced
996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014
17

Chart #3
Cl- Discharged per Equivalent Unit
18

2500
2000
Chart #4
Instream Chloride Concentration
Upstream (Background)
Downstream Point #1
o Downstream Point #2
a Downstream Point #3
Linear (Downstream Point #1)
Linear (Downstream Point #2)
Linear (Downstream Point #3)
19

Chart #5
2014 Chloride Limits
+ Average CL- lbs./day
Max Daily Cl- Lbs.
30,000
— --- --
25,000
— — ---
-----
20,000,.
_
Max Daily Limit 19,120 lbs
0
i..3-fi
15,000
�y, ,g
-
----- -- --
Monthly Avg Limit 13,476lbs
10,D00
5,000
January February March
April May June July August September
October November December
20

Chart #6
Average Cl- Discharge per Day (Ibs)
12,000 T_ _____ - _ -
I n nnn !-
0
1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014
21