Water & Wastewater Permitting and Compliance

1. Water & Wastewater Permitting and Compliance • Water Use • Pre-Treatment To POTW • Non-Treated To POTW • NPDES Wastewater • NPDES Dewatering • NPDES Storm Water

2. Water & Wastewater Permitting and Compliance • Water Quality Standards • Meaning to Valmont • General “Water” Summary • Links to Additional Information

3. Water Use • Well Construction Permitting • Water Use/Withdrawal Permitting • Drinking Water/Supply Permitting *NOTE: Monitoring/Record Keeping (i.e., Annual Use, Quality Tests, etc.) • Valmont Locations Typically Utilize City/Municipal Water Supply Sources

4. Pre-Treatment To POTW • Process Wastewaters To On-Site Pre-Treatment Before Discharge To POTW *NOTE: Categorical Limits, Pre-trt. Stds., Const./Ops. Permitting May Apply • POTW Performs Final Treatment To Meet Standards For Discharge Via POTW’s NPDES Permit (I.D. Sig. Cont.) • Treatment Agreement/City Ordinance = Quality/Quantity & Fees, State Permits (Facility & POTW), etc.

5. Non-Treated To POTW • Non-Treated Process Wastewaters Meeting (@ Minimum) Domestic Sewage Quality Criteria (i.e., Non-Contact Cooling/Cooling Tower & Boiler Blow Down, Water Treatment/Softening Systems, Cutting Table Water, etc.) • Domestic Sewage • Treatment Agreement/City Ordinance = Quality/Quantity & Fees, POTW NPDES Permit

6. Pre-treatment Standards • Typically More General In Nature W/ Main Function To Prevent Damage, Pass Through, Bypass, etc. Of A POTW, It’s Collection System, & Ensure That Discharge From POTW To Receiving Stream Meets Water Quality Reqmnts. *NOTE: Specified Limits/Ranges For pH, Temperature, O&G Conc., No Fire Or Explosion, Floating Debris, Toxics, etc. Are A Few Examples

7. NPDES Process/Wastewater • Process Related Wastewater Discharges Direct To Receiving Stream Via Facility Specific NPDES Permit (i.e., Non-Contact Cooling/Cooling Tower & Boiler Blow Down, Water Treatment/ Softening Systems, etc.) • Direct Discharges Meeting Limits/ Stds. (i.e., Water Quality) w/o Add. Trt.---Requirements Change Over Time! *NOTE: Permit, Renewals, Monitoring – DMR’s, etc.

8. Categorical Limits • “Categorical” = Federal For Specific Industry Sector/Process Type • Usually Based On “X” Quantity Of Pollutant(s) Allowed Per Some Unit Of Processing Of Raw Material • Promulgation Of New Regs. Continues

9. NPDES Dewatering • Dewatering Associated w/ Construction Activities Primarily • Also May Utilize For Water Table Management, Aquifer Stress Testing, etc. *NOTE: Permit (Typically “General”), Monitoring – DMR’s, Physical/Visual Exam Documentation, etc.

10. NPDES Storm Water • From “Water & Wastewater” Perspective, Storm Water Is Major Area That Impacts Most Valmont Locations • Permitting & Compliance Covered In Greater Detail Vs. Other “Water & Wastewater” Areas

11. Storm Water Permitting and Compliance • Applicability • Permitting Options • State Status • SWPP Plans • Current Regulatory Focus

12. Storm Water Permitting and Compliance Applicability • Construction > 5 Acres Disturbed/ > 1 Acre Disturbed Is Now Regulated In Some Areas • Industrial – Primarily Applies To The 20XX – 39XX SIC Code Range (Including Manufacturing @ 34XX SIC) --- 11 Categories W/ Defined Activity Exposed To Storm Water --- Defined Activity Includes: Processing Areas Raw Material Storage Access Roads/Rail Lines Finished Product Waste Material Material Handling Areas Shipping/Receiving Industrial Machinery/Eqpt.

13. Storm Water Permitting and Compliance Permitting Options • “General” = Includes Multi-Sector General Permits (MSGP) --- Common Format To Limit Effort • “Individual” = Option But Gamble • “Group” = Originally EPA --- Now Mainly Rolled To State Level --- Many States Don’t Recognize So Forced To Re-apply

14. Storm Water Permitting and Compliance State Status • Re-Issuing in 2002 • Others • California • Indiana • Iowa • Minnesota • Nebraska • Oregon • Utah • Illinois- 2003 • Oklahoma- 2005 • Tennessee- 2006 • Texas- 2006

15. Storm Water Permitting and Compliance SWPP Plans • Detail Permit Requirements • Describe Activities Including Materials Inventory • Identify Sources and Potential Pollutants • Storm Drainage Map • SWPP Team Identification • Best Management Practices (BMPs)

16. Storm Water Permitting and Compliance SWPP Plans • Spill Response Procedures = Needs To Agree/Inter-relate W/ RPCC Plan --- (If Spill Plan Development & Implementation Is Required And/Or Desired) • Training • Inspections • Sampling/Monitoring • Reporting

17. Storm Water Permitting and Compliance Current Regulatory Focus • SWPP Plan Adherence • BMPs • Benchmark Concentrations

18. Water Quality Standards • Primary Focus Of Clean Water Act Is To Provide A Mechanism By Which The Quality Of Our Nation’s Water Resources May Be Sustained For Intended Use(s) • Defined Use Classification (i.e., Swim able/Fishable/Drinkable) For Each Water Body W/ Assoc. Applicable Stds. • Various Permits Regulate Dischargers Accordingly By Process & Pollutants (i.e., BOD5, TSS, O&G, Metals, etc.)

19. Water Quality Standards Con't. • Waste Load Allocations (WLA’s) Are Calcs. Performed To Set Permit Limits For A Particular Facility Discharging Into A Particular Water Body = Take Into Account The Process(es) That Are To Discharge From A Facility, The Receiving Water Body Use Class., etc.. • Many Water Quality Stds. Are Conc. Based = One Size Fits All If Not Categorical (Overall Detailed Situation Specifics Not Always Considered)

20. Water Quality Standards Con't. • Conventional Monitoring Vs./Or In Conjunction W/ Whole Effl.. Toxicity (WET)/Total Max. Daily Load (TMDL) • Perform WET Testing By Exposing Specific Organisms In Lab To Sample Of Effluent From Facility = Look @ Mortality, Reproduction, Weight Gain/Loss & If I.D. “Impact” Vs. Control Must Determine Cause(s) Of Problem • TMDL Details Specifics To Set Limits For Water Body (Not One Size Fits All)

21. What Does This All Mean To Valmont? • The Water Quality Standards Promulgated Over Time Have Been A Significant Driver For Process Improvements In Our Industry • Categorical Limits And NPDES Limits Have Continually Tightened Over Time • Process Improvements Vs. End-Of-Pipe Controls Are Generally Better Solutions (i.e., More Economical) In The Long Run = True Pollution Prevention

22. What Does This All Mean To Valmont? Con't. • Examples Of Process Areas That Have Been Addressed Over The Last 10-20 Years Or So Include: * Acid Recovery System * Cascade Rinse System * Closed Loop Cooling Of Pipe Mills * Non-Contact Vs. Contact Cooling * Air Vs. Water Cooled Compressors

23. What Does This All Mean To Valmont? Con't. • Philosophy Is To Limit Or Eliminate Wastewater Discharges From Facility Locations If May Be Done Reasonably • For Any Potential Project @ Your Facility That May Impact Wastewater Discharges (More Or Less Volume, Higher Or Lower Organic Conc., Addition Or Deletion Of An Outfall, etc.), Please Notify Corp. Env. Early In Project Life Cycle For Evaluation Assistance (Potentially Multi-Media)

24. General "Water" Summary • Read Site Specific Permits & Plans To Determine Applicable Requirements • Need To Prepare A Listing Of Requirements W/ I.D. Of Due Dates • Contact Corp. Env. Personnel To Discuss Any Questions You May Have • Need To Maintain Coverage Under Permits & Plans = Keep Up-To-Date • Need To I.D., Communicate & Help Determine Impact Of Potential Projects

25. General "Water" Summary Con't. • Perform Req. Training, Inspections, Monitoring & Reporting = Document • Need To Maintain Complete & Orderly Files @ Site = Be Ready For Inspections • Communicate Discrepancies To Site Mgt. & Corp. Env. Staff • Review, Modify & Implement BMP’s, Plans, etc. For Benchmark Concentration • Need To Be Proactive Not Reactive

26. Code Of Federal Regulation Links • Subchapter D – Water Programs (40 CFR Parts 100 - 149) * *NPDES Regs. @ Parts 122 – 125 *Toxic Pollutants @ Part 129 *Water Quality Stds. @ Part 131 *Primary & Secondary Drinking Water Stds. @ Parts 141 - 143

27. Code Of Federal Regulation Links Cont. • Subchapter N – Effluent Guidelines & Stds. (40 CFR 400 – 471) * *Categorical Stds. @ Parts 401 – 471 *Pretreatment Stds. @ Part 403 • Subchapter O – Sewage Sludge (40 CFR 501 – 503) *