EATON - CUTLER-HAMMER Asheville, NC Plant

1. EATON - CUTLER-HAMMERAsheville, NC Plant ENVIRONMENTAL MANAGEMENT PROGRAM

2. ENVIRONMENTAL MANAGEMENT PROGRAM During the late 1980’s the Asheville Plant embarked on a commitment to identify, evaluate and implement a waste minimization program. This has resulted in reduced volume of solid hazardous waste hauled offsite, reduced air emissions, and effluent discharges, energy and utilities conservation and successful recycling programs.

3. ENVIRONMENTAL MANAGEMENT PROGRAM • Reviews process that generate waste streams • Develop means to reduce volume, quantity and toxicity of wastes generated. • Research and implement new technologies that are environmentally acceptable. • Employ housekeeping, maintenance, training and inventory control practices that support source reduction and pollution prevention. • Continually strive to reduce all wastes. • Implement recycling when opportunities are identified.

4. ENVIRONMENTAL MANAGEMENT PROGRAM The environmental management successes for Cutler-Hammer’s Asheville manufacturing facility can be categorized under four headings. • Electrical use • Water use • Natural gas use • Environmental improvements

5. ENVIRONMENTAL MANAGEMENT PROGRAM • In mid 1998 the Cutler-Hammer Asheville Plant made a commitment to develop an EMS Program and pursue ISO 14001 Certification. • The facilities environmental policy was constructed through a collaborative effort between top management and the EMS task force.

6. Electrical Improvements • Upgraded Office Lighting • Installed Motion Sensors • Discontinued In-House Furnace Brazing • Compressed Air Upgrade • Greenlights Survey • Installed Energy Management System • Changed Lighting Habits in Factory: Time On / Time Off (Ownership)

7. Electrical Improvements • Changed Habits: Turn machines, fans and task lights off when not needed. • Discontinued use of infrared oven. • Turn off PC’s at end of work day. • Applied for and received new tariff option with CP&L. (LGS-RTP) Large general service - real time pricing • Installed POW R command lighting panels. • Installed programmable control of 17 HVAC Systems.

8. Water Use Improvements • Replaced liquid coolant with cold air guns for milling, drilling and band saws. • Replaced water-cooled compressors with air cooled. • Replaced large cooling tower with 3 small chillers. • Received exemption from mandatory surcharge imposed by the Water Authority during draught. Displayed documented conservation / reduction success during prior 12 months.

9. Water Use Improvements • Cut back volume on sinks, Bradley basins and toilets. • Installed new flush valves. • Posted conservation notices on restroom doors. • Communicated daily draught status with tips in daily bulletins. • Further tweaked counter-flowing and volume at Paint Line Pretreatment. • Extended interval on dumping cleaner tanks (without sacrificing quality)

10. Natural Gas Improvements • Added insulation during re-roofing in 1993. • Building heat retention improved • Boilers operate less • Using recovered heat off air-cooled compressors to help heat plant. • Annual inspection on boiler burners, Paint Line oven burners and pretreatment burners to maintain peak performance. • Renegotiated class of service with Gas Company. Combined two services into one. • Started purchasing transportation gas through a broker at City Gate. • Fixed gas prices for multiple months.

11. Environmental Improvements • Discontinued in-house furnace brazing. • Discontinued use of Cadmium, Silver, Tin and Zinc • Converted from Xylene base to Polyester base varnish. • Changed from foam packaging to recyclable paper Pad-Pac packaging. • Eliminated aerosol cans as a disposable hazardous waste. • Converted from Electro-Coat painting to Power Coating. • Discontinued in-house Electroplating. • Discontinued use of Over-Spray Paint Booth. • Eliminated need for Waste Water Treatment.

12. Baseline of Implementation • ISO 9000 Facility • Strong Environmental Compliance Programs in Place • Functional Emergency Response Team

13. The Certification Process We identified the major tasks that must be completed to obtain certification and set target dates for completion. 1. Write Environmental Policy 10/15/98 2. Form Implementation Task Force 10/15/98 3. Formal Training for Task Force 10/27/98 4. Management Overview of the ISO Standard 10/27/98 5. Identify Significant Environmental Aspects 12/01/98 6. Identify Significant Environmental Impacts 12/01/98 7. Gap Analysis 12/01/98 8. Write Environmental Management Manual 12/30/98 9. Set Environmental Objectives and Targets 01/04/99 10. Write Procedures for Achieving Obj. and Targets 01/04/99

14. The Certification Process (Cont.) 11. Lead Assessor Training 02/15/99 12. Internal Auditor Training 02/15/99 13. Communicate Environmental Procedures/Policy 03/15/99 14. Internal Audits 03/15/99 15. Management Review of ISO 14001 05/07/99 16. Pre-Registration Audit 05/20/99 17. Registration Audit 06/22/99

15. Environmental Policy The Cutler-Hammer Asheville Plant, a manufacturer of electrical distribution equipment, is committed to prevent pollution and to the continual improvement of its Environmental Management System. We commit to comply with all relevant Federal, State, and Local environmental laws and regulations and to follow corporate environmental guidelines as they apply to our business. We further commit to use energy efficiently and to reduce, reuse or recycle materials in an effort to conserve natural resources. We will continually strive to be a good corporate neighbor, to be involved in community activities that positively impact the environment and to use environmentally friendly products in the design and manufacture of our product.

16. EMS Design • Simple but Effective • When writing your EMS manual, don’t promise a lot of things that you can’t deliver or that would be difficult to keep going. (e.g. We will test our Emergency Preparedness Plan weekly.) What you want to do is to test your Emergency Preparedness Plan as often as you feel is necessary for the plan to be effective and state that in your manual.

17. EMS Design • Environment or Auditor • During the process you must constantly question if what you are doing is for the environment or the ISO auditor. Sometimes it is easy to get carried away and forget the main focus of ISO 14001.

18. EMS Design • Design a System • You must constantly ask yourself, am I putting an EMS System together or am I just coming up with pieces that will never fit together. If you don’t put a system together, you will constantly have to message the EMS to make it work - especially at periodic audit (6 month) time. • Use ISO 9000 programs.

19. EMS Design • Pollution Prevention • Determine all of your environmental impacts. This is where pollution takes place. • Have a good method to determine significance. This is where the most pollution takes place. • Operational Controls - This is where pollution is prevented.

20. EMS Design • Operational Controls • More non-conformity is written against this element than any other. • Should have documented work instructions. (Not required by ISO but a good idea.) • Must have a way to monitor and measure operational controls.

21. Example • Aspects • Storage & disposition of hazardous waste • Heating of the Plant • Electricity • Water • Significant Aspects • Use of electricity • Use of water • Monitor & Measure • Monthly bills • Computer tracking • Operational Controls • IMPACC Energy Management System • Communications • Training

22. Team Members • Dave Wright - EHS Manager • Scott Plemmons - Quality Assurance Mgr. • Lana Plemmons - Training Coordinator • Jim Takac - Facilities Manager • Jim Rogers - Process Engineer • Harold Brown - Powder Coating Operator • Sam Godfrey - Maintenance Coach • Rich Dunn - Mfg. Coach Controls

23. Implementation Costs - Man Hours • Dave Wright - 1,200 Hours • Scott Plemmons - 680 Hours • Remainder of the Team - 1,512 Hours • Training Hours • General Awareness - 1,200 Hours • Significant Aspects - 160 Hours

24. EATON - CUTLER-HAMMER ASHEVILLE PLANT ISO 14001 REGISTERED