Annual Briefing: Spill Prevention Control and Countermeasure Plan (SPCC) Instrument & Electrical Technical Services Freeport, Texas ____________________ GHRIS CODE:

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

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

–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.) IETS Applicability

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.) Transformer OilB-1292 – 55 gal drum Used OilB-1293 – 55 gal drums Refrigeration OilB-134Various 55 gal drums Used OilB-1343 – 55 gal drum Transformer Oil; T-7B-407 Tank Farm16,000 gal tank Transformer Oil; T-8B-407 Tank Farm16,000 gal tank Transformer Oil; T-9B-407 Tank Farm16,000 gal tank Transformer Oil; T-10B-407 Tank Farm12,000 gal tank Used Oil; D-11B-407 Tank Farm6,000 gal tank Bulk Storage (In Service)

Our Plant’s SPCC Oils Bulk Storage (In Service), continued SPCC Bulk Oil Containers LocationTotal Oil Quantity (Gal.) Transformer Oil; T-801B gal portable tank Transformer Oil; T-802B gal portable tank Transformer Oil; T-803B gal portable tank Transformer Oil; T-814B gal portable tank Transformer Oil; T-826B gal portable tank Transformer Oil; T-827B gal portable tank

Our Plant’s SPCC Oils Electrical Equipment (In Service) Electrical EquipmentLocationTotal Oil Quantity (Gal.) T-129 TransformerB gal T-134 TransformerB gal

Our Facility’s SPCC Oils Key Learning Points – SPCC Regulates the storage of oil The IETS 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

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

Inspection Requirements: –Oil storage vessels (including transformers), above ground piping and diked areas are inspected monthly –Routine GMISS inspections as applicable SPCC Plan Requirements

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 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.

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:

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

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 IETSUpdated SPCC Plan; Revised inspection sheets, figures, training, tables. Certified by PE, and implemented through MOC

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

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 8/15/2011Karin SloughMade ready for MyLearning 2/19/2014Karin SloughReviewed; no changes 10/27/2014Jennifer HillRevised for SPCC plan updates Revision History