NC0001970_Annual Chloride Reduction Evaluation Report_20180313

March 13, 2018
RECEIVED/DENR/DWR
Man Klimek, P.E. MAR 21 2018
Director
Division of Water Quality Water resources
NPDES East Unit Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Annual Chloride Reduction Evaluation Report (2017)
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 studyand evaluate chloride removal technologies
g
and
chloride reduction strategies. Please find enclosed a copy of the facility's 2017 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 2017 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(910) 267-4711.
Sincerely,
BAY VALLEY FOODS, LC
Chad Tennant
Plant Manager
Bay Valley Foods, LLC-Faison, NC

ANNUAL CHLORIDE REDUCTION EVALUATION
REPORT
YEAR 2017
For
Bay Valley Foods, LLC - Faison, NC
NPDES Permit No. NC0001970
Prepared for:
Bay Valley Foods, LLC
354 Faison Ave.
Faison, North Carolina 28341
Prepared by:
Solutions-IES, a division of Draper Aden Associates
1101 Nowell Road
Raleigh, North Carolina 27607
March 12, 2018
Project Number 18117804-010701
-704;i4A' /15-at,4.444---
Z"icr-7. ee
Michael W. Branson, P.G. / James Y. Joyner, RSM
Senior Hydrogeologist Senior Consultant
•
So utions -JES
Industrial & Environmental Services
a division of Draper Aden Associates

March 2018
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 2017. 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 2017. There were no exceedances of either the "Monthly Average Discharge Limit"
or the "Daily Maximum Chloride Discharge Limit" in 2017.
Table 2.0; Chart#2 provides annual production information for 2017 and for previous years,
measured in equivalent production units, as well as the pounds of chloride discharged per
equivalent production unit. Production volume in 2017 decreased 13.7% compared to 2016. The
2017 chloride lbs. discharged per production unit ratio increased 15% to 0.26 as compared to 0.22
in 2016. Equally importantly, 2017 data represent a continuous decline in lbs. of chlorides
discharged per equivalent unit of production compared to the long term average of 0.31 lbs
discharged, dating back to the benchmark year of 1996. Over the past five years (2013 to 2017),
the average chloride lbs. per equivalent unit of production is 0.21 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 or stabilized in 2017, as compared to 2016.
Table 4.0 summarizes data pertinent to chloride discharges from 2005 through 2017.
► Bay Valley Foods, LLC - Faison, NC did not exceed the "Daily Maximum Chloride
Discharge Limit" or the "Monthly Average Discharge Limit" in 2017.
► Chlorides discharged per equivalent production unit increased 15% compared to 2016, yet
still reflects a significant decrease compared to the benchmark year of 1996 (0.56 lbs CL-
/Eq. Unit). In 2017 it was calculated at 0.26 pounds of chlorides discharged per equivalent
production unit. (Refer to Chart#3)
1

► The 2017 annual production total of 5.896 million equivalent production units represents a
13.7% decrease from 2016 production throughput. (Refer to Chart#2)
► The calculated annual pounds of chlorides discharged (1,542,683 lbs.) in 2017 is 57% less
than the largest amount discharged in 2007.
► In 2017 Bay Valley Foods continued the process of removing excess biomass from its
wastewater treatment lagoons to improve treatment performance with the removal of 1963
tons, at a cost of$336,000. 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.
► Also in 2017, Bay Valley Foods completed removal and replacement of the Pond 3 liner
and continued construction and lining of Pond 3 at a cost of$100,000. Completion of Pond
1 is anticipated for April 2018.
2

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 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 (Refer to 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.
Table 1.0
2017 Monthly Chloride Discharge Data
Current Chloride Discharge Limits: Monthly Average = 13,476 lb/day
Daily Maximum = 19,120 lb/day
Chloride Discharges (lb/day)
2016
Month
Max Min Avg.
January 5604 1635 2858
February 7797 1953 3576
March 5567 1743 3096
April 7318 829 3750
May 3727 1733 2679
June 10757 2969 4971
July 9184 1855 5843
August 5540 2371 4221
September 5611 3363 4507
October 4972 1430 3244
November 7572 2345 4467
December 10514 3816 7467
' Denotes exceedance of monthly average limit.
** Denotes exceedance daily maximum limit.
3

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3

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 1,497,130 1,542,683
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 7258,154 6,816,632 6,602,658 7,012,627 6,837,706 5,896,035
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 0.22 0.26
Chlorides/
Equivalent
Unit
Annual 119.20 98.03 109.11 94.30 101.78 107.7 115.32 97.60 91.61 114.47 133.60 133.77 114.29
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 4,259,319 6,471,116
NaCI&
CaCI
Purchases
(lbs)
Salt Use 0.54 0.55 0.74 0.71 0.56 0.49 0.25 0.51 0.56 0.49 0.37 0.62 1.10
(lbs.)/
Equivalent
Unit
6

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 case 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 (Refer to Chart#2). 2017 production volume was
5.896 million units, a13.7% decrease from 2016 volume. (6.837 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). Data
from 2017 represents a continuous overall decline in lbs. of chlorides discharged per equivalent
unit of production compared to the long term average of 0.31 lbs discharged, dating back to the
benchmark year of 1996. Over the past five years (2013 to 2017), the average chloride lbs. per
equivalent unit of production is 0.21 lbs./eq.unit. Although 2016 and 2017 indicate a slight increase
in the lbs./eq. unit, it continues to be well below the 2007 maximum.
7

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.
8

1
1

• 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.
• 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
• 2017—Continued lining of Pond 1 with anticipated completion date of April 15, 2018.
Upon completion of this effort, all three ponds will have been relined.
9

1

TECHNOLOGIES & APPROACHES CONSIDERED
FOR 2018 AND BEYOND
Many projects, programs, process changes and chloride reduction strategies implemented in the
past will continue to be utilized into 2018, 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
Excess biomass accumulation in Pond 3 was removed and the pond was relined. This project was
completed in April 2017. Bay Valley Foods continues to address this issue with waste water
biomass at Pond 1 where the biomass has been removed and the pond is being relined. The
completion date is anticipated to be April 15, 2018.
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 that result in reduced chlorides in
wastewater discharges.
10

1

Treatment Technologies
Ramboll Environ prepared a Chloride Removal Technology Evaluation Report dated January 2017.
The report identified several technologies that may be applicable to the BV-Faison facility. The
technologies included reverse osmosis, electrodialysis/electrodialysis reversal, chemical
precipitation, product substitution, flow augmentation, and residuals management. Bay Valley
Foods, LLC is committed to investigating and evaluating any new treatment technology based on
technical applicability and feasibility.
11

WASTE REDUCTION
The ongoing waste reduction efforts at the Facility will continue through 2018.
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.
The results of these waste reduction efforts can be seen in the decreasing trends in the instream
chloride concentrations and average chloride discharge per day. Chart#4 demonstrates that the
upstream chloride is at background concentrations. The anomalous peak for 2007 was attributed
to very low stream flow conditions throughout the year. The chloride concentration from 2007 to
2014 at Downstream Point#1 shows a substantial decrease over time. From 2014 to 2017, the
concentrations have stabilized to very slightly increasing. Downstream Point#2 and Downstream
Point#3 show a similar trend in that the overall reductions in chloride concentrations have
occurred since 2007.
Chart#5 shows that the average chloride discharge in pounds per day (lbs/day) increased from
2009 to 2012, but has steadily decreased from 2012 to 2017. From 2013 to 2017, the
concentrations have fluctuated, but remained significantly lower than the 2007 chloride
concentrations. These charts demonstrate that waste reduction efforts at the BV facility are
effective.
12

13

Chart#1
Annual Chloride Discharges(lbs)
4,000,000
3,500,000 ! r
3,000,000 - 1 -- - -
2,500,000
2,000,000 ----�.....__... -__._..---_......._._
1,500,000 —
i
1,000,000 — —.. _.__......__._..............—._... -- ... — — —
500,000
ri k
2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

Chart#2
Equivalent Units Produced
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
1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

Chart#3
Cl-Discharged per Equivalent Unit
0.60
•
0.50
0.40
0.20
rAik7t2i44*giggigW'' -"
0.10
0.00
1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

•
-6-Upstream (Background)
Chart#4 —s---Downstream Point#1
° Downstream Point#2
Instream Chloride Concentration ° Downstream Point#3
Linear(Downstream Point#1)
----Linear(Downstream Point#2)
— — Linear(Downstream Point#3)
2500
2000
1500
1000
500
°
1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2008 2009 2010 2011 2010 2013 2014 2015 2016 2017
2007

Chart#5
Average CI-Discharge per Day (lbs)
12,000
10,000
4111111111111144
8.000
6.000
4.000 -
2.000
0
2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017