Van Wert, OH Water and Wastewater Element Training MESH 3.0 Water Management and Conservation

Definitions Water Source: includes all water coming into a plant from municipal or other third party water supply and on-site/off-site wells Wastewater Source: includes all waters at the site destined for disposal including process wastewater, non-contact cooling water, wash-up water and sanitary (domestic) sources

What Does Eaton Require? Van Wert must be managed in a way that assures compliance with all regulatory requirements AND minimizes the impact of water releases to the community and the environment where the plant operates.

Water and Wastewater Emission Management Process Inventory Water use and wastewater generation Characterize Wastewater content Evaluate Regulatory Requirements Operation Treatment and Disposal Document & Train Employees Step 1. Inventory Water Sources Water Uses & Wastewater generation Wastewater discharges

Step 1: Inventory Van Wert must identify: Sources: all sources of incoming water including municipal water sources and on-site wells; every location in the plant where water is used and where wastewater is generated including machines wash-up water recycled water sanitary sources

Step 1: Inventory Van Wert must identify and/or label: all waste water handling drains all discharge points from the facility (including treatment devices)

Step 1: Inventory Map the location of water sources, discharges, and transport in pipes and trenches: A site should check if sources or uses of water are missing by doing a rough mass balance. Volume in = Volume out + Stormwater - Evaporation

Water and Wastewater Emission Management Process Inventory Water use and wastewater generation Characterize Wastewater content Evaluate Regulatory Requirements Operation Treatment and Disposal Document & Train Employees Step 2. Characterize Wastewater Volume/Flow Wastewater attributes 8

Step 2: Characterization All wastewaters generated by the site must be characterized. This evaluation includes: volume or flow rate; chemical analysis of the wastewater characteristics type and concentration of chemical constituents The plant uses process knowledge, information from SDSs, and chemical analysis to identify all pollutants in the wastewater that could impact the environment.

Step 2: Characterization Characterization must include abnormal operating conditions such as: process upsets, by-passes, start-ups/shut-downs, chemical “dumping” to sewers, maintenance activities, etc.

Water and Wastewater Emission Management Process Inventory Water use and wastewater generation Characterize Wastewater content Evaluate Regulatory Requirements Operation Treatment and Disposal Document & Train Employees Step 3. Evaluate Regulatory Requirements Other (such as third party) 11

Step 3: Evaluation of Regulatory and Other Requirements The site is under an operating National Pollution Discharge Elimination System (NPDES) Permit. This permit limits the kind and amounts of contamination in the water we send to the City of van Wert. Items that we are limited for include: pH Cadmium Lead Zinc Mercury Hexavalent Chromium Total Chromium The site tests daily and we have a 3rd party test weekly to verify our discharge

Step 3: Evaluation of Regulatory and Other Requirements A site is NOT allowed to discharge wastewater without treatment. **Any exception to this requirement MUST be approved by Corporate EHS 13

Water and Wastewater Emission Management Process Inventory Water use and wastewater generation Characterize Wastewater content Evaluate Regulatory Requirements Operation Treatment and Disposal Document & Train Employees Step 4. Operation System Design Collection of wastewater Treatment Disposal 14

Step 4: Operation (Collection, Treatment and Disposal) We must collect and transport wastewater in chemically appropriate piping or trenching. The design of collection systems should be protective of the environment and provide secondary containment in environmentally sensitive areas. Design of wastewater collection systems should also minimize handling of wastewater in areas that could be flooded with storm water. Non-specific, general floor drains should be eliminated wherever possible.

Step 4: Operation (Collection, Treatment and Disposal) Our wastewater treatment system must identify key operating parameters for the system including flow rate, zinc levels, pH, and others per our permit Operating procedures must be developed and deployed to assure that the system is operated at all times in a manner that assures compliance with final discharge limits.

Step 4: Operation (Collection, Treatment and Disposal) Operating procedures must be developed for the wastewater treatment system that address actions to be taken during periods of abnormal production, chemical “dumping”, maintenance activities, and power failure. These procedures should ensure that the plant maintains compliance with permit limitations even under abnormal operating conditions.

Step 4: Operation (Collection, Treatment and Disposal) Plants must include regular documented visual inspection of the operation of the wastewater treatment system, sampling and testing practices, secondary containment and integrity of the collection system into regularly scheduled MESH inspections. If the plant has any issues with the water discharge, the treatment must be shut down and EHS notified .

Step 4: Operation (Collection, Treatment and Disposal) Management of Change Changes to the site’s operation, processes or equipment must include an evaluation of the effects on the site’s water and wastewater inventory, characterization and all requirements described above. Refer to MESH 1.0 – General Requirements/Planning/Management of Change.

Step 5. Document and Train Water and Wastewater Emission Management Process Inventory Water use and wastewater generation Characterize Wastewater content Evaluate Regulatory Requirements Operation Treatment and Disposal Document & Train Employees Step 5. Document and Train Employees and Contractors Regulations and Procedures Monitoring and Inspection 20

Step 5: Document and Train Employees and contractors must receive training as it pertains to their job function including: Operation and maintenance of wastewater sources Operation and maintenance of wastewater collection and treatment systems Operation of wastewater systems under abnormal or emergency conditions Sampling, testing, monitoring and recordkeeping procedures Regulatory, permit, and other requirements Inspection of wastewater systems’ operation and compliance Labeling requirements for collection systems and discharges Any external training and licensing based on regulatory requirements 21