1. Annual Briefing: Spill Prevention Control and Countermeasure Plan (SPCC) Central Maintenance Services Freeport, Texas ____________________ GHRIS CODE: 281454_365 Press F5 to view in slide-show view

2. Purpose – This training will meet the requirements for the annual Pollution Prevention briefing required of our facility’s Spill Prevention Control and Countermeasures (SPCC) Plan Desired Outcome – Understanding and knowledge of: –SPCC rule and applicability –Facility’s SPCC oils, locations, and equipment –Facility’s SPCC LOPCs events (prior 12 months) –Facility’s SPCC Plan Changes Target Audience – All personnel who work with and/or maintain SPCC oil containers and equipment. Overview

3. SPCC Introduction –Spill Prevention Control and Countermeasure (SPCC) is a Federal Regulation under the Clean Water Act (40 CFR Part 112) –SPCC regulates the storage of Oil* –SPCC is to prevent or minimize spills of oil to navigable water ways *Oil as defined by 40 CFR Part 112 Overview

4. –Total oil storage capacity for the area is greater than 1320 gallons. –Potential for oil to get to the water –The following types of containers do not count toward the 1320 gallon limit: Any container whose capacity is less than 55 gallons Permanently closed containers Mobile Containers that are in DOT service (tank trucks, portable containers, etc.) CMS Applicability

5. Dow has a Work Process to determine SPCC Oils.Work Process to determine SPCC Oils. Our Facility’s SPCC Oils SPCC Bulk Oil Containers LocationTotal Oil Quantity (Gal.) Lubrication OilA-702: Oil Mist System55 gal drum Lapping Vehicle OilB-105 Drum Storage2 – 55 gal drums Coolant Cutting FluidB-105 Drum Storage55 gal drum KeroseneB-105 Drum Storage55 gal drum Hydraulic OilB-105 Drum Storage275 gal tank Used Oil/CoolantB-105: WT-15,000 gal tank Used Oil/CoolantB-105: WT-2165 gal tank New Motor OilB-203 Garage4 – 275 gal tanks Used OilB-203 Garage55 gal drum Bulk Storage (In Service)

6. Our Plant’s SPCC Oils Bulk Storage (In Service), continued SPCC Bulk Oil Containers LocationTotal Oil Quantity (Gal.) Used OilB-203 Garage: STB-12,000 gal tank GasolineA-909 Fuel Island: D-101 17,800 gal tank DieselA-909 Fuel Island: D-100 17,800 gal tank GasolineB-209 Fuel Island: U-1 23,800 gal tank DieselB-209 Fuel Island: R-1 10,900 gal tank DieselB-209 Fuel Island: D-1 23,800 gal tank Hydraulic OilB-412 Tool Room5 – 55 gal drums

7. Bulk Storage (In Service), continued Our Plant’s SPCC Oils SPCC Bulk Oil Containers LocationTotal Oil Quantity (Gal.) Diesel Exhaust FluidB-412 Tool Room55 gal drum Diesel FuelB-412 Tool Room55 gal drum New Motor OilB-412 Tool Room220 gal tank Used OilB-412 Tool Room500 gal tank Gasoline/DieselB-412 Tool Room: Mobile Refueler Baffled: 1,800/500 gal tank truck DieselB-412 Tool Room: Mobile Refueler 1,500 gal tank truck DieselB-412 Tool Room55 gal drum

8. Our Plant’s SPCC Oils Non-Bulk Storage (In Process), Piping and Transfer Racks SPCC PipingLocationTotal Oil Quantity (Gal.) Gasoline/DieselA-909 Fuel Island82 gal/pipe run Gasoline/DieselB-209 Fuel Island75 gal/pipe run

9. Our Plant’s SPCC Oils Electrical Equipment (In Service) Electrical EquipmentLocationTotal Oil Quantity (Gal.) T-201-A TransformerB-201630 gal T-203 TransformerB-20390 gal T-131 TransformerB-105180 gal T-130A TransformerB-105257 gal T-130B TransformerB-105257 gal T-130C TransformerB-105170 gal T-292 TransformerOC-403172 gal T-709 TransformerA-702203 gal

10. Our Facility’s SPCC Oils Key Learning Points – SPCC Regulates the storage of oil The CMS facility is required to comply with SPCC because the total oil storage capacity for the area is greater than 1320 gallons. Dow has an existing Work Process to help assess SPCC oil applicability You are aware of the Plant’s SPCC bulk containers, in- process and electrical equipment Lesson Summary

11. Inspection Requirements: –Inspection for oil sheen or other contamination before draining the diked area is required. –Use Rain Water Discharge Checklist –Assign appropriate WPN as needed –All valves on containment areas are to be closed unless draining the area SPCC Plan Requirements

12. Inspection Requirements: –Oil storage vessels (including transformers), above ground piping and diked areas are inspected monthly* –Oil treatment systems are inspected daily (B- 412) –Routine GMISS inspections as applicable *Inspection frequency at the fuel islands (A-909 and B-209) is weekly SPCC Plan Requirements

13. During the past 12 months, we have experienced the following SPCC oil LOPC events: Review of SPCC Oil LOPC’s SPCC Oil LOPCLOPC Quantity (Gal) LocationPrimary Cause Compilation of past 12 months SPCC oil LOPC events*: 0 (from GIRD) * While 40 CFR 112.1 only requires reviewing spills that “could reasonably be expected to discharge oil in quantities that may be harmful … into or upon the navigable waters of the United States …”, Dow requires including all oil spills to ensure prevention.

14. During the past 12 months, we have implemented the following SPCC oil learnings:  Updated figures and flow diagrams  Updated inspections  Change of weekly to MONTHLY inspections  Updated oil storage locations and capacity Facility’s SPCC Oil Management Learnings Developed NEW SPCC Plan including:

15. Our Facility’s SPCC Oil LOPC’s Our Facility’s SPCC Oil Related Learnings and Changes Key Learning Points – You are aware of the this past year’s SPCC Oil LOPC events in your facility. You are aware of the corrective actions to prevent recurrence of SPCC Oil LOPC events. You are aware of recently developed precautionary measures to prevent SPCC Oil LOPC events. Lesson Summary

16. During the past year, we have changed our Facility’s SPCC Plan: Review of SPCC Oil Plan Changes SPCC Oil Event Primary Contact LocationFollow-Up Actions Developed and implemented new SPCC plan Jennifer HillAll CMSUpdated SPCC Plan; Revised inspection sheets, figures, training, tables. Certified by PE, and implemented through MOC

17. Our Facility’s SPCC Plan Changes Key Learning Points – You are aware of the significant changes to our Plant’s SPCC Oil Plan You are aware of the associated work process updates related to the changes in the Plant’s SPCC Oil Plan. Lesson Summary

18. Revision History Revision historyThe following information documents at least the last 3 changes to this document, with all the changes listed for the last 6 months. DateRevised ByChanges 6/11/2011N. WisbyCreated training 8/11/2011Anna RivierMade ready for MyLearning 10/27/2014Jennifer HillRevised for SPCC plan updates