NC0001970_Annual Chloride Evaluation Report_20160314

BAY VALLEY
F 0 0 t) s
March 10, 2016
DVVR
Alan Klimek, P.E.
Director RECEIVEDINCDE(MAR14Z016
Division of Water Quality Water Quality
NPDES East Unit permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Annual Chloride Reduction Evaluation Report (2015)
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 2015
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 previous Chloride Variance Requests 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 2015 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 VALLEY FOODS, LLC
CALf
Chad Tennant
Plant Manager
Bay Vallee Foods, LLC- Faison, NC
BAY VALLEY FOODS
354 N.FAISON AVENUE
FAISON,NC 28341
910-267-4711
910-267-4869 FAX

Enclosure
Cc: Bob O'Neill
Ernesto Gemoets
Donovan Brock
Tim Wolf
RECEIVED/NCDEQ/DWR
MAR 14 2016
Water Quality
Permitting Section
2

RECEIVED/NCDEQ/DWR
MAR 1 4 ?DIE,
Water Quality
Permitting Section
ANNUAL CHLORIDE
REDUCTION EVALUATION REPORT
YEAR 2015
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 Engineering Manager
Donovan Brock, Facility Environmental Contact, BVF-Faison, NC
Chad Tennant, Plant Manager, BVF-Faison, NC

RECEIVEDINCDEUDWR
MAR 1 4 2016
March 2016
Water Quality
Permitting Section
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 2015. 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 2015. There were no exceedances of either the "Monthly Average Discharge Limit"
or the "Daily Maximum Chloride Discharge Limit" in 2015.
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 2015 increased 5.8 % compared to 2014. The
2014 chloride lbs. discharged per production unit ratio decreased 19% to 0.17 as compared to 0.21
in 2014. Equally importantly, 2015 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. Over the past five years (2011 to 2015),
the average chloride lbs. per equivalent unit of production is 0.20 lbs./eq.unit.
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 long-term decline in chloride
concentration at all monitoring locations. Chloride concentrations at all downstream monitoring
location slightly increased in 2015, as compared to 2014.
(Refer to Chart #4)
Table 4.0 summarizes data pertinent to chloride discharges from 2005 through 2015.
► Bay Valley Foods, LLC - Faison, NC did not exceed the "Daily Maximum Chloride
Discharge Limit" or the "Monthly Average Discharge Limit" in 2015.
► Chlorides discharged per equivalent production unit decreased 19% compared to 2014,and
reflects a significant decrease compared to the benchmark year of 1996 (0.56 lbs CL-/Eq.
3

Unit). In 2015 it was calculated at 0.17 pounds of chlorides discharged per equivalent
production unit. (Refer to Chart #3)
► The 2015 annual production total of 7.013 million equivalent production units represents a
5.8% increase from 2014 production throughput. (Refer to Chart #2)
► The calculated annual pounds of chlorides discharged (1,218,420 lbs.) in 2015 is the 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. That effort will resume again in 2016 when Pond #2 will be
taken out of service and excess biomass will be removed, dewatered and disposed. 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.
4

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
2015 Monthly Chloride Discharge Data
Current Chloride Discharge Limits: Monthly Average = 13,476 lb/day
Daily Maximum = 19,120 lb/day
Chloride Discharges (Ib/day)
2015
Month
Max Min Avg.
January 5352 1440 2977
February 5824 832 3245
March 4106 204 2504
April 7599 3163 4888
May 5422 3407 4035
June 12402 3552 5556
July 7532 2019 4696
August 5746 431 3862
September 4821 1527 2957
October 6701 570 2697
November 1713 561 1079
December 2615 546 1589
* Denotes exceedance of monthly average limit.
Denotes exceedance daily maximum limit.
5

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
2015 7.01 0.17
6

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
2015 20 320 140 70
7

Table 4.0
COMPARISON OF ALL DATA
2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 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
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
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
Chlorides/
Equivalent
Unit
Annual 119.20 98.03 109.11 94.30 101.78 107.7 115.32 97.60 91.61 114.47 133.60
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
NaCI&
CaCI
Purchases
(Tons)
Salt Use 1070.83 1090.55 1481.19 1424.17 1113.92 977.35 509.28 1020.09 1116.39 977.89 742.49
(lbs.)/
Equivalent
Unit
8

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. 2015 production volume was 7.013 million units, a
5.8% increase from 2014 volume. (6.603 million units) As a result of the ongoing commitment
from facility leadership, the pounds of chlorides discharged per equivalent production unit continue
to show a steady long-term downward trend. (Refer to Chart #3)
9

•
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.
10

• 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 1 with an additional
removal and dewatering of 3643 ton at a cost of$368,000.
11

TECHNOLOGIES & APPROACHES CONSIDERED
FOR 2016 AND BEYOND
Many projects, programs, process changes and chloride reduction strategies implemented in the
past will continue to be utilized into 2016, 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
In 2016, Bay Valley Foods will address excess biomass accumulation in Pond 2 of its wastewater
treatment system.
Status: Underway
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.
Treatment Technologies
Literature review and research did not identify any new or emerging chloride reduction
technologies in 2015. Bay Valley Foods, LLC is committed to investigating and evaluating any new
treatment technology based on technical applicability and feasibility.
12

WASTE REDUCTION
The ongoing waste reduction efforts at the Facility will continue through 2016.
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.
13

Charts

4.000.000
3,500,000
3,000.000
2,500,000
2,000, 000
1.500.000
1,000,000
A
Chart #1
Annual Chloride Discharges (Ibs)
1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015
15

10,000,000
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
Chart #2
Equivalent Units Produced
1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015
16

Me
0.50
0.40
0.30
0.20
0.10
HIM
Chart #3
Cl- Discharged per Equivalent Unit
1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015
17

2500
2000
1500
1000
500
41
Chart #4
Instream Chloride Concentration
—Upstream (Background)
—Downstream Point #1
Downstream Point #2
Downstream Point#3
Linear (Downstream Point #1)
Linear (Downstream Point#2)
Linear (Downstream Point#3)
1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2008 2009 2010 2011 2012 2013 2014 2015
2007
18

12.000
10.000
b
AM
4,000
2,000
x
Chart #5
Average Cl- Discharge per Day (Ibs)
1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015
19