Attachment 1 - FINAL Contra Costa County Chevron Richmond Refinery Incident Investigation Report(1).pdf — Richmond City Council, September 24, 2024

CHEVRON RICHMOND REFINERY
FEBRUARY 9, 2021, OIL SPILL INCIDENT INVESTIGATION

THIRD-PARTY REVIEW
AcuTech Group, Inc.
1919 Gallows Rd., Suite 900
Vienna, Virginia 22182 USA
www.acutech-consulting.com

Prepared for:

Contra Costa County
4585 Pacheco Blvd, Suite 100
Martinez, California 94553

June 25, 2024

CHEVRON RICHMOND REFINERY
FEBRUARY 9, 2021, OIL SPILL INCIDENT INVESTIGATION

THIRD-PARTY REVIEW
June 2024 i AcuTech Group, Inc.

Table of Contents

1. Executive Summary ................................................................................................................ 1

2. Introduction ............................................................................................................................. 3

2.1. Background & Objectives ............................................................................................... 3

2.2. Report Format ................................................................................................................. 4

2.3. Review Team .................................................................................................................. 4

3. Scope and Approach ............................................................................................................... 4

4. Evaluation of Incident Investigation ....................................................................................... 6

5. Evaluation of RCA Findings / Root Causes ........................................................................... 7

5.1. Management Systems ..................................................................................................... 8

5.2. Inspection History ......................................................................................................... 10

5.3. Human Factors .............................................................................................................. 11

6. Evaluation of RCA Recommendations / Action Plans ......................................................... 12

6.1. Implementation of Recommendations / Action Plans .................................................. 13

7. Evaluation of Agency Notifications...................................................................................... 15

8. Conclusions ........................................................................................................................... 16

9. Documents Reviewed ........................................................................................................... 16

10. References ............................................................................................................................. 17

11. Appendix ............................................................................................................................... 17

11.1. Scope of Work .......................................................................................................... 17

11.2. Glossary – Abbreviations and Definitions ................................................................ 18

11.3. Public Comments and Responses ............................................................................. 20

12. Addendum A – Copies of Documents Reviewed ................................................................... 1

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THIRD-PARTY REVIEW
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1. EXECUTIVE SUMMARY
Background
On February 9th, 2021, Chevron Richmond Refinery confirmed an oil leak from the 003 line at the Richmond Long Wharf. The leak released approximately 18 barrels of hydrocarbons into the San Francisco bay. Chevron Richmond Refinery issued a level 2 Community Warning System (CWS) Notification via their CWS Terminal by Contra Costa Health (CCH). In response to the incident, CCH - Hazardous Materials Programs (CCHHMP) designated the incident a Major Chemical Accident or Release (MCAR) per Contra Costa County’s (CCC) industrial safety ordinance (ISO) and City of Richmond industrial safety ordinance (RISO) regulatory requirements.

CCH commissioned AcuTech Group, Inc. (AcuTech) to provide a third-party review of the Chevron Richmond Refinery February 9, 2021 oil spill investigation. AcuTech was contracted by CCH to initiate the project on August 13, 2021, but was unable to begin the assessment per the contract until Chevron released the report of their investigation. The contract was again updated, to extend the term only, on June 22, 2022, while awaiting the Chevron report. On August 26, 2022, Chevron provided the report titled “Event Title: February 9, 2021 Richmond Long Wharf Incident, IMPACT ERM Investigation #128842 & LI #192231, September 23, 2021”1, to AcuTech.

AcuTech Scope of Work and Approach
AcuTech’s scope of work was not to conduct an independent investigation but was limited to providing a third-party review of the incident investigation report conducted by Chevron. This involved AcuTech performing the following tasks:

 Reviewing the root cause analysis report to ascertain the completeness of the report and adherence to the requirements and expectations of the ISO or RISO  Developing a set of questions and additional data required to further understand the events leading up to the incident, discovery, mitigation, and recommended actions related to the incident
 Reviewing data provided by Chevron on the response to the event, root cause analysis (RCA) process and mechanical integrity specific aspects for line 003 including the design, construction, maintenance, inspection, procedures, surveillance, and repair  Reviewing Chevron’s follow-up response and status of their recommended actions related to the incident and RCA including the actions taken to date by Chevron to address their findings
 Evaluating agency notifications along with other completed and available agency notification and investigation reports
 Developing an opinion on the RCA and actions by Chevron related to the investigation and follow-up

To aid in completion of the above tasks, AcuTech requested additional documents be provided by Chevron to understand the incident and how they were addressing the findings of their investigation. Questions were posed to Chevron regarding the incident investigation report and Chevron provided written responses along with verbal responses through interviews conducted with Chevron personnel.

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Conclusions
Contributing factors and root causes that led to the Richmond Long Wharf line 003 pipeline leak were identified in the Chevron incident investigation report. Based on the review of these factors, root causes, recommended actions and the Chevron incident investigation report, AcuTech concluded the following:

 The TapRoot® methodology used by Chevron is a recognized commercially available root cause analysis tool that is widely used in industry for this purpose and is referenced in guidance from CCHHMP for compliance with the ISO/RISO. They used this tool and other means (interviews, engineering reviews, further site inspections, records reviews) to determine the root causes and contributing factors.
 Chevron identified two contributing factors and five root causes to the event (Table 1) that AcuTech also believes were the underlying causes and factors leading to the event. The five recommended actions (Table 3) do address preventing reoccurrence of the events of the Richmond Long Wharf oil spill incident and are in line with industry best practices.  Beyond the TapRoot® process, Chevron showed through interviews and actions that they took the incident very seriously and management was directly engaged in understanding the root causes and seeing to the resolution of corrective actions. The Refinery manager held meetings to ensure actions were taken to understand the root causes of the event and take corrective action to prevent reoccurrence. AcuTech believes this is a key purpose of root cause analysis and so the intent of the process was met as addressed by the thoroughness of the investigation and implementation of technical lessons learned.  The root causes identified failures in both Chevron Richmond Refinery’s management of change (MOC) system and fixed equipment asset strategy (FEAS) program for the wharf.

Shortcomings in these two systems played a large role in contributing to this event which Chevron acknowledged through their root cause analysis report conclusions and recommended actions.
o Chevron identified the failures of the mechanical integrity systems adequately with critical introspection and has committed to improved methods for inspection and maintenance of wharf line 003.
o Damage mechanisms for line 003 have been updated and Chevron has made improvements to their processes for inspection and replacement or repair of the line including implementation of the MOC program for pipe material changes.  The five recommended actions were completed by the targeted completion date identified by Chevron in the 30 day follow up report2. These recommended actions address the root causes identified in the incident investigation. Positive changes were made regarding training of MOC and incident investigation by specifically discussing this incident. MOC training also discussed changes in piping type from cement lined to carbon steel pipe would classify as a change needing to follow the MOC process. In addition, updates to process safety related programs such as mechanical integrity inspections using Saturated Low Frequency Eddy Current (SLOFEC), implementing more robust data analyses for repeat pipeline repairs (“bad actors”), and corrections to P&IDs. Chevron is also working to pilot a leak detection technology on one of its Richmond Long Wharf pipelines.

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 The appropriate agencies were notified by Chevron approximately 1 hour after Chevron received the initial public notification. While CCH requires notification as soon as possible or within 15 minutes, it is AcuTech’s opinion that Chevron made all reasonable efforts to meet the requirements of CCH notification while still maintaining good emergency response practices of containing a leak to reduce environmental consequences.

2. INTRODUCTION

2.1. Background & Objectives
Chevron Richmond Refinery had a hydrocarbon leak from a pipeline (003 line, also known as 16 Ballast line) at the Chevron Richmond Long Wharf on February 9, 2021. Per Chevron calculations, up to 18.41 barrels of hydrocarbon leaked into the San Francisco Bay which was a mix of ultra-low sulfur diesel fuel and flush water2. Containment booms were deployed to protect environmentally sensitive sites and shorelines. A Level 2 community warning public health advisory was issued to nearby residents following the CCH - Hazardous Materials Program policy for hazardous materials incident notification.

In response to the incident, CCH - Hazardous Materials Programs designated the incident a Major Chemical Accident or Release (MCAR) per ISO and RISO regulatory requirements.

Section 6.43.090(c)(2) of the RISO (similar to Section 450-8.016(c)(2) of the ISO) allows Contra Costa Health Hazardous Materials Program to conduct an independent root cause analysis of the MCAR. In this case, CCHHMP recommended to the Contra Costa County Industrial Safety Ordinance/Community Warning System Ad Hoc Committee, which is appointed by the County Board of Supervisors, that CCH hire an independent expert to review the root cause investigation report conducted by Chevron.

CCH requested AcuTech Group, Inc. (AcuTech) to provide a proposal to conduct a third-party review of the Chevron Richmond Refinery February 9, 2021 oil spill investigation. AcuTech was contracted by CCH to initiate the project on August 13, 2021, but was unable to begin the assessment per the contract until Chevron released the report of their investigation allowing AcuTech to begin the review. The contract was again updated, to extend the term only, on June 22, 2022, while awaiting the Chevron report. Chevron then provided the report titled “Event Title: February 9, 2021 Richmond Long Wharf Incident, IMPACT ERM Investigation #128842 & LI #192231, September 23, 2021” 1, to AcuTech on August 26, 2022.

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2.2. Report Format
This report includes information requested by CCH including the scope (section 3), evaluations of the following in the Chevron report:
 Incident investigation review; section 4
 Findings / incident causes (root causes); section 5
 Recommendations and action plans; section 6
o Proposed and completed action plans and their current status  Agency Notifications; section 7
 A conclusion is provided in section 8.

2.3. Review Team
The study was conducted by AcuTech Group, Inc. Personnel involved in the review were:
 David Moore, PE, CSP – President and CEO
 David Heller, CSP, CPSA – Senior Principal Engineer, Incident Investigation Specialist
 Alison Ballon – Principal Engineer, Incident Investigation Specialist  Mark Politte – Senior Principal Engineer, Mechanical Integrity Specialist  Ken Min – Senior Engineer, Mechanical Integrity Specialist

3. SCOPE AND APPROACH
The scope for this project was to conduct a third-party review of the RCA investigation of the Chevron Long Wharf Oil Spill incident, including the notification process at the Chevron Richmond Refinery as performed by Chevron. AcuTech’s scope of work was not to conduct an independent investigation of the Long Wharf Line 003 release. The purpose of Chevron’s RCA investigation and report was to adequately address any gaps in the safety program and management practices at the Chevron Richmond Refinery.

As defined by CCH, AcuTech’s scope specifically consisted of:
a. Review the completed RCA report provided by the Chevron Richmond Refinery and interview key members of their investigation. AcuTech’s independent review and investigation, and final report to Contra Costa County include, but not be limited to:
i. Review of the Mechanical Integrity program and how it applies to the pipeline, including:

A. Inspection data of the ballast line;
B. Corrosion monitoring;
C. Determination of the metallurgy and failure route;
D. Procedure for use of the ballast line pre- and post-loading operation; E. Surveillance during use; and
F. Other process safety management systems that may be applicable to this incident.
ii. Review Chevron Richmond Refinery’s action plan to ensure that the recommendations and action plans are addressing the findings from the incident investigation;

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A. NOTE: due to the length of time that passed since the incident occurred, the original scope was expanded to evaluate how action plans were addressed and ensuring recommended actions were completed as intended iii. Review the creation of the incident/event timeline; and iv. Review the Chevron Richmond Refinery’s notification process. b. Review other completed and available investigation reports from the Coast Guard, the Oil Spill and Prevention Response team from California Department of Fish and Wildlife, and CalOSHA.
c. Take part in a public participation process, which will include the following:
i. Develop a public Oversight Committee to oversee the investigation review process; A. Hold a report-out meeting with the Oversight Committee after review of Chevron’s incident investigation report is complete and provide a written completeness evaluation of Chevron’s incident investigation. Contractor will make appropriate changes to the evaluation report based on feedback received from the Oversight Committee; and
B. Hold a public meeting once the written completeness report has been accepted from the Oversight Committee. This report will have a 45-day public comment period during which the public meeting will held, Contractor will listen to the public’s concerns and consider making changes in the report and work with Chevron to complete the evaluation report.

Contractor shall respond to all written comments and comments raised in the public meeting.
ii. Attend and present reports at the following meetings:

A. A public meeting to present the draft evaluation report; and B. Two (2) public meetings to present the final evaluation report to Contra Costa County Board of Supervisors and the Richmond City Council. d. Provide a final evaluation report to the Contra Costa Health Hazardous Materials Programs Director, or designee, which will include the results of its independent review and investigation into the Chevron Long Wharf Oil Spill incident, Chevron’s investigation into the incident (including a RCA), the public comments received during the public comment

Scope covered under items c and d above have not been completed as of this issue of this draft report. After the draft third-party review report is issued, scope item c will commence and timing to complete may vary. A final evaluation report (scope item d) will only be issued after completion of tasks in scope item c.

The approach used by AcuTech to complete the scope of work included the following tasks:
 Reviewing the root cause analysis report to ascertain the completeness of the report and compare the method used and work product to the requirements and expectations of the ISO/RISO requirements for investigating incidents and for handling a MCAR  Developing a set of questions and additional data required to further understand the events leading up to the incident, discovery, mitigation, and recommended actions related to the incident
 Reviewing data provided by Chevron on the response to the event and RCA process

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 Assessing the mechanical integrity program including the design, construction, maintenance, inspection, procedures, surveillance, and repair of line 003 on the Long Wharf
 Interviewing Chevron personnel regarding the investigation process and to determine the policies and procedures employed for mechanical integrity of line 003 including o Investigation Team Lead
o Richmond Refinery Fixed Equipment Inspection Team Lead o Richmond Refinery PSM Manager
 Reviewing Chevron’s follow-up response and status of their actions related to the incident and RCA
 Reviewing draft recommended action completion reports provided by Chevron to evaluate and comment on how recommended actions were completed
 Evaluating agency notifications along with other completed and available agency notification and investigation reports
 Developing an opinion on the RCA and actions by Chevron related to the investigation and follow-up.

4. EV ALUATION OF INCIDENT INVESTIGATION
Chevron’s Richmond Long Wharf incident investigation was conducted using the TapRooT® RCA methodology which is a recognized commercially available root cause analysis tool that is widely used in industry for this purpose. TapRooT® incident investigation system is also referenced in guidance from CCC ISO for compliance with the ISO/RISO as one of the acceptable methodologies of conducting a root cause analysis.

Per Chevron instruction document RI-371, Near Loss, Event Reporting and Incident Investigation, the severity of this incident did not warrant a TapRooT® investigation. This was done to ensure the investigation addressed potential issues relating to management systems and technical systems.

Chevron had an independent leader from corporate HSE in San Ramon to lead the incident investigation and along with a qualified TapRoot investigator providing support. They used this tool and other means (interviews, engineering reviews, further site inspections, records reviews) to determine the root causes and contributing factors.

The investigation began shortly after the incident occurred with the investigation concluding on October 24, 2021 before Chevron provided the last 30-day follow-up report2 to CCH. A copy of the final 30-day follow-up report can be found on the CCH website.

Included in the Chevron incident investigation report is a SnapCharT® event timeline prepared by members of the Chevron incident investigation team. This timeline starts with the install of line 003 in 1948, covers various damages and leaks that occurred in the history of line 003 along with inspection and repairs made prior to the incident. Details are also included in the timeline for day of events beginning with estimated start time of the leak based on pressure drops in the line, confirmation of the leak, when the leak was stopped and ended with installation of the repair clamp on the leak location. The SnapCharT® identified the two contributing factors or contributing causes (shown in Table 1) along with the direct cause which is the leak of line 003. Each of the contributing factors were reviewed using the TapRooT® Root Cause Tree® process to identify

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the appropriate root causes of the incident described in Table 1. Evaluation of the actual contributing factors and root causes is described in section 5.

AcuTech’s review of the incident investigation root cause methodology found the approach to be complete in capturing direct causes, contributing factors, root causes and providing a complete timeline of events. It was also confirmed that the RCA investigation performed by Chevron was in compliance with RISO/ISO requirements including those in Section 6.43.090(c)(1) of the RISO (similar to Section 450-8.016(c)(1) of the ISO).

Beyond the TapRoot® process, Chevron showed through interviews and actions that they took the incident very seriously and management was directly engaged in understanding the root causes and seeing to the resolution of corrective actions. The Refinery manager held meetings to ensure actions were taken to understand the root causes of the event and take corrective action to prevent reoccurrence. AcuTech believes this is a key purpose of root cause analysis and so the intent of the process was met as addressed by the thoroughness of the investigation and implementation of technical lessons learned.

5. EV ALUATION OF RCA FINDINGS / ROOT CAUSES
The Chevron Richmond Wharf incident investigation team identified two contributing factors and five root causes for the 003 line which are provided in Table 1.

Table 1: Contributing Factors and Root Causes (Chevron RCA Report) Contributing Factors and Root Causes
Contributing Factor 1: The cement-lined carbon steel pipe in intermittent use failed due to internal corrosion
 Root Cause 1. The asset strategy for the 003 Line did not include inspection techniques that were adequate for detecting localized corrosion in cement-lined pipe.  Root Cause 2. Loss/Near Loss Reports for prior incidents had not been consistently generated.
 Root Cause 3. There is no formal process to trigger lookbacks on the history of the line that could track “bad actors.”
 Root Cause 4. MOC review may have provided an opportunity to identify any concerns unique to cement-lined piping.

Contributing Factor 2: If the leak was detected and contained sooner, the severity of the event would have been reduced (i.e., Level 1 or 2 instead of Level 3a incident)  Root Cause 5: Leak detection and passive containment at RLW requires further review

AcuTech performed a detailed review of the RCA investigation report evaluating each of the identified contributing factors and root causes. Results of this review are broken down into three sections: management systems, inspection history and human factors. AcuTech did not perform an audit of the evaluated management systems, only reviewed them with respect to the 003 Line pipeline leak.

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AcuTech concluded that this event was a failure to follow good engineering and industry practices for mechanical integrity for piping systems handling hydrocarbons. It was exacerbated by the complexity of the piping system (the length of piping, the concrete lining making inspection more challenging, the location over water, and other factors). It is believed Chevron identified these issues adequately with critical introspection and has committed to improved methods for inspection and maintenance of wharf line 003.

5.1. Management Systems

5.1.1. Management of Change
An effective management of change (MOC) system ensures hazards posed by potential changes are identified and mitigated to the extent possible. Chevron noted in their investigation report that sections of the 003 line were replaced with unlined carbon steel pipe and in several instances, these changes did not go through the standard Richmond Refinery MOC process. AcuTech reviewed several of the MOCs conducted on the 003 line along with changes in the piping that were completed outside of the MOC process.

Section 6.43.090(a)(6) of the RISO requires regulated stationary sources to establish and implement written procedures to manage changes except for replacement in kind.

Changing cement lined carbon steel pipe with unlined carbon steel would be considered a change in design specification and therefore does not meet the definition of a replacement in kind. A MOC should have been completed whenever portions of the 003 line were changed from cement lined carbon steel piping to unlined carbon steel pipe. Section

6.43.090(a)(6)(B) of the RISO also requires that the MOC procedure addresses the following considerations prior to any change being implemented: the technical basis for the proposed change; the impact of change on safety and health; modifications to operating procedures; necessary time period for the change; and authorization requirements for the proposed change. Root cause 4 identified that following the MOC process may have provided the opportunity for relevant parties, such as materials engineering group, to identify concerns of making this change including impacts to the integrity of the piping.

Following the MOC process may have also provided an opportunity to update associated inspection isometrics as the Chevron MOC process does require updating relevant process safety information. Recommended action 2 in Table 3 was developed to address the root cause of failure to conduct MOCs. Chevron confirmed that personnel are trained in their MOC program and to address possible confusion, their MOC training material was updated to include changing of pipe material as an example change that would warrant a MOC.

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5.1.2. Fixed Equipment Asset Strategies Program
Chevron utilizes their internal standard, MFG 525, Manufacturing Instruction for Fixed Equipment Asset Strategies, to implement their fixed equipment asset strategies (FEAS) program which includes piping. The FEAS system is part of Chevron’s Richmond Refinery mechanical integrity program. The program aspects related to the wharf line 003 in question were reviewed in detail including the inspection history, inspection technique, and ultimate failure of the line.

A review of this information found the Chevron FEAS program for the Wharf line 003 to be designed to address the requirements of regulatory standards including those of Contra Costa County Ordinance Chapter 450-8 (ISO) and the City of Richmond Industrial Safety Ordinance (Municipal Code Chapter 6.43, RISO).

The refinery followed industry standards such as API 570 (as described in MFG-525), Piping Inspection Code: In-Service Inspection, Repair, and Alteration of Piping Systems; an inspection code developed and published by the American Petroleum Institute (API).

API 570 covers in-service inspection, rating, repair, and alteration of piping systems and their respective pressure relieving devices. API 570 establishes the requirements and guidelines needed to maintain the safety and mechanical integrity of piping systems after they have been commissioned.

API RP 574, Inspection Practices for Piping System Components, is also followed by the Richmond refinery (as described in MFG-525). It is a recommended practice developed and published by API that discusses inspection practices for piping, tubing, valves (other than control valves), and fittings used in petroleum refineries and chemical plants. This RP describes common piping components, valve types, pipe joining methods, inspection planning processes, inspection intervals and techniques, and types of records. API RP 574 supplements API 570 to provide information and best practices that assist practitioners in the “how to” inspect piping and common piping components.

The Chevron FEAS program is intended to “validate and improve API 570 inspection plans”, as noted in the Chevron investigation report. Per Chevron requirements, an asset strategy is used for operating, monitoring and maintaining fixed equipment to preserve the integrity and process function of such equipment. MFG-525 requires an asset strategy to identify applicable damage mechanisms, determine the need for and define integrity operating windows, and prescribe inspection, testing and preventative maintenance. These requirements are in alignment with those outlined in API 570 and API RP 574.

Another requirement of MFG-525 is to review past inspection findings, repairs, and modifications to ensure they are covered as possible damage mechanisms in the FEAS evaluation. The 003 line was reviewed in 2019 during the initial rollout of the FEAS program and as noted in the investigation report, that review did not identify “potential coating/lining failure” or “under deposit corrosion” as damage mechanisms. However, there were previous failures of the 003 line due to broken or cracked cement lining including one in 2018 which resulted in partial implementation of a SLOFEC technique which can detect this type of damage. The review of line history during the implementation

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of the FEAS program for the 003 line should have identified “coating/lining failure” and “under deposit corrosion” as damage mechanisms and should have resulted in broader implementation of inspection techniques designed to find this type of damage.

The issue of not following MFG-525 and not implementing proper inspection techniques was identified in root cause 1 and root cause 2. Root cause 2 also identified the inconsistency in developing loss/near loss reports for incidents on the 003 line. The Chevron investigation report noted that only two of the four incidents had loss/near loss reports. While some of the incidents may not have required formal investigations, generating such near loss reports allows for trending of the incidents and prompted for proper damage mechanisms to be included in the FEAS of the 003 line.

Root cause 3 took a deeper evaluation into potential shortcomings of MFG-525. As the standard is written, the FEAS should be reviewed after a “trigger event” which would be any event that requires evaluating or updating an asset strategy or creating a new one. This is also a requirement of API 574. However, the Chevron standard does not require any sort of trending review of historical data that could have an impact on the fixed equipment. The investigation report references use of a “bad actor” process that is in place for rotating equipment. In root cause 3, Chevron recognized that reviewing historical data for the 003 line may have also prompted the proper damage mechanism to be included in the asset strategy resulting in a correct inspection technique for this line.

Since the incident, Chevron conducted a full SLOFEC analysis of the entire length of line 003, which is industry best practice for identifying deficiencies in piping systems in this service and design. Damage mechanisms are known, and Chevron has made improvements to their processes for inspection and replacement or repair of the line.

5.2. Inspection History

5.2.1. Ballast Line Inspection Data and Corrosion Monitoring The Chevron investigation report contains a thorough review of the inspection history of the 003 line which was reviewed by AcuTech. In the report, Chevron states that the fixed equipment inspection (FEAS) program would include corrosion monitoring, and AcuTech agrees the program is in line with the applicable industry, regulatory, and refinery standards and practices including API 570 and others. Samples of relevant inspection data were requested and reviewed by AcuTech including external visual inspection reports, operator visual surveillance reports and mechanical integrity computerized data management reports showing thickness data and inspection dates as shown in Table 2. None of the data indicated an imminent failure at the leak location. It should be noted that based on AcuTech’s review of the data provided, inspections were performed at appropriate frequencies and incident recommendations were addressed in a timely manner. AcuTech is in agreement with Chevron’s report statement that their inspection program and developed internal standards (MFG-525) meet the requirements of relevant industry standards and did not identify other concerns regarding the inspection program other than correct implementation.

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Table 2: Inspection Report Data
Inspection Data Inspection Date Standard
Used
Completed
By
Piping Asset Strategy Report Report Date:

November 3, 2022
n/a Chevron
Piping Asset Strategy Report Report Date:

February 10, 2021
n/a Chevron
TML Corrosion Report 8/12/2020 API 570 Chevron
External visual inspection report of
circuit ‘Line 003’
5/8/2020 API 570 Redacted
SLOFEC Report 2/22/2021 API 570 Third Party

5.3. Human Factors

5.3.1. Ballast Line Loading Procedure and Surveillance
AcuTech requested and was provided with a copy of the Marine Transfer Operations Manual. This manual contains instructions for transfer of material through the 003 line and is treated as any other cargo transfer. The procedure has instructions for wharf personnel during pre- and post-transfer of material. During transfer operations, the manual requires a transfer to be continuously monitored by the berth operator. Operations monitor pressure and/or flow in real time on the central control board and can respond to alarms triggered at certain set points.

When transfer lines are not in operation, Chevron provided clarification that wharf operators routinely make rounds performing visual inspections of the lines as part of their shift duties. The 003 line was not in active transfer when the leak occurred therefore the line was not being continuously monitored via board operators.

Chevron identified casual factor 2 that the leak was not mitigated by leak detection and/or passive containment. Root cause 5 was subsequently identified relating to the lack of leak detection and/or passive containment in the wharf. If Chevron had other means of leak detection besides just visual inspections by operations, it is possible that the leak may have been caught earlier and the event severity reduced. This concern was identified and adopted with recommended action 5 in Table 3.

5.3.2. Determination of the Metallurgy and Failure Route A comprehensive postmortem inspection and failure analysis was completed by Chevron as documented in several places in the Chevron investigation report. The exact failure mode of the leak could not be determined until the 003 line segment was removed and a failure analysis completed. Initial visual inspections provided indication of local internal corrosion of a cement lined section of the 003 line causing the leak.

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Chevron performed a test on the 003 line using handheld x-ray fluorescence to confirm the piping consisted of carbon steel, as suspected. A variety of other postmortem field and laboratory tests and inspections were performed on the section of 003 line to evaluate the failure route. Testing concluded the initial findings to be correct that under deposit corrosion was the likely failure mode. This under deposit corrosion determination was based on localized thinning on the interior pipe surface and presence of corrosion scaling.

Specifically, the corrosion scaling composition reviewed by Chevron indicated the presence of oxygen and chlorides which can increase corrosion severity in piping. After reviewing the failure analysis report in detail, AcuTech agrees with Chevron’s findings regarding the determination and decision of the likely failure mode.

5.3.3. Inspection Plan
An inspection plan for Line 003 was developed by Chevron as a result of the 2019 FEAS which was in compliance with API 570, API 574 and internal standards. That inspection plan was then fully implemented by trained inspectors. However, as noted in section 5.1.2, Chevron recognized that the FEAS for the 003 line was lacking proper damage mechanisms resulting in a possible incomplete inspection plan. Since the incident, Chevron has updated the inspection plan for the 003 line and added SLOFEC as alternative means to complete inspections of the line. AcuTech reviewed the updated inspection plan and is in agreement with the revised plan.

6. EV ALUATION OF RCA RECOMMENDATIONS / ACTION PLANS
Chevron identified five recommended actions to address each of the root causes identified from the RCA investigation as noted in their final incident investigation report to CCH. These recommended actions include those shown in Table 3:

Table 3: Recommended Actions (Chevron RCA Report)
Recommended Action Targeted Milestone / Completion Date(s)

1. Review the design and inspection plan that applied to the 003 Line and provide any recommended alternatives. 1/28/2022

2. Communicate/train wharf operations on Loss/Near Loss and Management of Change practices and procedures.
4/29/2022

3. For fixed equipment at the wharf, consider implementing a process and/or utilizing tools similar to the “bad actor” process utilized for rotating equipment. 4/29/2022

4. Review piping and instrumentation diagrams (P&IDs) and inspection isometrics for lines with cement lined piping in hydrocarbon service and other lines whose piping design is unique to the wharf.

Cement-lined piping (4/29/2022)
Other lines unique to
the Wharf (1/27/2023)

5. Review leak detection technologies (e.g., tell tales, cameras, flow/pressure indication, etc.) and/or passive containment technologies. 10/28/2022

CHEVRON RICHMOND REFINERY
FEBRUARY 9, 2021, OIL SPILL INCIDENT INVESTIGATION

THIRD-PARTY REVIEW
June 2024 13 AcuTech Group, Inc.

Based on discussions with Chevron and a review of documentation provided to the Contra Costa County District Attorney’s Office, AcuTech has confirmed that all of the identified recommended actions have been completed and/or implemented by Chevron.

While reviewing the actions and whether they resolved the root causes, it was noted that recommended actions 2, 3, and 4 mainly pertain to Richmond Long Wharf operations and not all the Chevron Richmond Refinery. AcuTech reviewed Chevron document RI-371, Chevron Instruction for Near Loss, Event Reporting, and Incident Investigation. This document states “… for all Level 2 and Level 3 incidents to ensure lessons learned are communicated to all affected personnel.” For this Long Wharf incident, the affected personnel would have been limited to Wharf personnel (including technical staff, supervisors, managers, and operators) and not all refinery staff. Based on interviews with Chevron personnel, AcuTech learned that the Chevron investigation team identified that the wharf was not treated to the same level of integrity management and exhibited signs that the process safety culture was not as robust as the remainder of the facility. Chevron identified these organizational issues and made recommended actions for improving focusing on wharf operations.

During interviews with personnel, Chevron also confirmed that information was disseminated throughout the refinery via a “local reliability site bulletin”. This site bulletin included a variety of lessons learned that also addressed recommended actions 2, 3 and 4. Between the process safety culture at the wharf and Chevron internal standards requiring actions to only be implemented for those areas affected by the incident (i.e., only wharf operations), AcuTech is in agreement with limiting some of the recommended actions to wharf operations.

It is AcuTech’s opinion that recommended actions 1 – 5 developed by Chevron address the root causes identified from the root cause incident investigation.

6.1. Implementation of Recommendations / Action Plans
Recommended action 1 required Chevron to review the inspection plan and provide recommended alternatives. Chevron did complete a SLOFEC inspection across the entire portion of line 003 and not just portions after the incident occurred. While SLOFEC is not required by industry or government regulations, Chevron recognized the advantages of SLOFEC inspection were worth the cost and has added SLOFEC as a supplemental inspection technique at the Richmond Long Wharf to inspect cement-lined piping. The asset strategy for the 003 line moving forward has been revised to include 21 new condition monitoring locations (CMLs), conducting a triennial SLOFEC inspection of the bottom 180 of the pipeline and a triennial ultrasonic thickness inspection for the remaining areas of the pipeline (those that cannot have a SLOFEC inspection). According to Chevron, over 50% of the original 003 pipeline has been air-gapped including the section in the causeway. Removing a large portion of the pipeline, increasing the CMLs, and requiring SLOFEC inspection provides a more robust FEAS for the 003 pipeline. Implementing these changes will improve the identification of potential anomalies on the line 03 piping to help improve the prevention of future leaks.

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THIRD-PARTY REVIEW
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Communication and training on loss/near loss (L/NL) and management of change practices and procedures was completed via a mandatory in-person training for Richmond Long Wharf personnel. The L/NL training covered the requirement to formally investigate any release of hydrocarbons to water and provided an emphasis on the lessons learned from this event. PSM training material on incident investigations was also updated to train personnel that they are required to enter actual and potential incidents into the incident tracking database and investigate appropriately which was one of the factors in root cause 2 (not all incidents were reported and investigated).

MOC training conducted for Richmond Long Wharf operations did address the types of changes requiring a MOC and discussed incorrectly not performing a MOC as related to this incident. Both the wharf personnel MOC training and the optional MOC refresher training did include, an example change requiring a MOC, changing piping material from cement-lined carbon steel pipe to unlined carbon steel pipe. This explicit reference to types of changes speaks to the root cause that MOCs were not performed when previously changing the pipe material on the 003 pipeline.

A data visualization tool to identify pipeline circuit “bad actors” was developed to address recommended action 3. Chevrons “bad actors” process assists in identify repeat repairs on equipment over a defined period of time but prior to this incident, was only in use for rotating equipment. This tool will allow Chevron to monitor integrity threats, inspection recommendations, and history briefs which are then used to determine areas for increased focus and characterized as “bad actors” of wharf piping. Those “bad actors” are then reviewed every 6 months by a cross-functional team including the area inspector, reliability engineer, operations management and others as needed. If needed or deemed appropriate, revisions to the underlying asset strategies are made based on the requirements in MFG-525. This “bad actor” program is in addition to the inspection and review requirements outlined in MFG-525.

Three piping circuits at the Richmond refinery were identified by Chevron with cement lined pipe, one being the 003 pipeline related to this incident and the other two in sump drain lines.

The associated P&IDs and inspection isometrics have since been updated to reflect the cement lined pipe and associated asset strategies have also been updated. Updating the asset strategies ensures appropriate damage mechanisms and additional surveillance activities are properly documented. Recommended action 4 also required a review of P&IDs and inspection isometrics for lines unique to the Richmond Long Wharf which Chevron considered to include:
linear expansion joints, loading arms, vapor collection piping and equipment, large threaded pipe, detonation arrestors, flame arrestors, sumps and sewage tanks. Based on field verification, the associated P&IDs and inspection isometrics were updated, which is standard practice. Chevron also confirmed that no changes were needed to the asset strategies for the corresponding Richmond Long Wharf lines.

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Evaluating various different leak detection and containment technologies, as required in action 5, can present different options with varying degrees of results. AcuTech confirmed that not only were alternate technologies evaluated, Chevron is now proceeding with further measures to pilot one of the proposed leak detection technologies, a hydrocarbon rope sensor, to better understand feasibility and sustainability. The pilot will occur on a fuel oil line at the Richmond Long Wharf which is a heavily used line and sits below other lines which may allow the technology to detect a loss of containment from the piping circuits above.

Passive containment technologies were reviewed including those for secondary containment and booms, both of which Chevron determined to be not feasible. Secondary containment was considered largely unfeasible as it would prohibit the inspection of the bottom of the piping circuits. Given that this is where the leak occurred in this incident, AcuTech is in agreement that installing secondary containment would not be good practice for pipelines over water in the Richmond Long Wharf. Booms along the causeway of the Richmond Long Wharf were deemed not feasible due to restricting access to the piping circuits for both spill response boats and fixed equipment inspectors in work boats. The boats would not be able to jump the booms or have very limited entry points. Costs associated with causeway booms was also a concern of Chevron as they would be exposed to higher damage (location against marine current), require more frequent replacement, and have an overall increased level of maintenance. While booms serve as a first line of defense in oil spill recovery, if they restrict the ability for response or proper maintenance that could serve to increase the severity of the incident.

7. EV ALUATION OF AGENCY NOTIFICATIONS
A review of the notifications made by Chevron found the authorities notified included, but not limited to, those from Contra Costa Health, California Occupational and Health Administration (CalOSHA), U.S. Coast Guard, California Department of Fish and Wildlife and others. These notifications are in alignment with those that would be required for a release of hazardous material to the San Francisco bay. AcuTech did identify that agencies were notified approximately 1 hour after Chevron received the initial public notification and sought further information regarding the timing to ensure compliance with regulations. Agency notification timelines were provided in the CCH 72 hour report3.

The notification to CalOSHA was in compliance with California Code of Regulations, Title 19 Section 2631 (e) which falls under the California Governor’s Office of Emergency Services.

Chevron and CalOSHA settlement reports were reviewed and no items of concern were noted by AcuTech.

The CCH - Hazardous Materials Program includes the Hazardous Materials Incident Notification Policy. According to Section III.E of that policy, CCH requires notification “…as soon as possible or within 15 minutes from discovery of a release….”. Based on interviews with Chevron, it was determined that after the initial public concern was identified, Chevron attempted to confirm the leak was an oil spill and not other ship/barge related issues and then made the appropriate notifications following that determination. It is AcuTech’s opinion that Chevron made all reasonable efforts to meet the requirements of the Contra Costa Health notification requirements

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June 2024 16 AcuTech Group, Inc.
while still maintaining good emergency response practices of containing a leak to reduce environmental consequences.

After the event, various agencies including Contra Costa Health, Department of Fish and Wildlife, and US Coast Guard worked alongside Chevron to ensure potential impacts from the leak were evaluated and thoroughly remediated. Ten liaison reports from the Office of Spill Prevention and Response (OSPR) were reviewed and thoroughly document the collaboration between Chevron and various regulatory agencies to evaluate the spill and its response.

8. CONCLUSIONS
AcuTech was commissioned by Contra Costa County to perform a third-party independent review of the February 9th, 2021 Chevron Long Wharf incident root cause analysis report as further described above. AcuTech conducted the review based on the available data including from documents presented, interviews, and observations.

The evaluation of incident investigation, root causes, actions and agency notifications described in sections 4,5, 6, and 7, respectively, of this report represent our main conclusions with respect to how Chevron conducted the root cause analysis and incident investigation. AcuTech did not identify concerns associated with the Chevron investigation report and believes it to be thorough in nature.

9. DOCUMENTS REVIEWED
The following is a high level list of documents provided by Chevron and reviewed by AcuTech  RI-621: Temporary Leak repairs
 RI-371: Near Loss, Event Reporting, and Incident Investigation  RI-410: Marine Oil Spill Emergency Response
 RI-368: Mechanical Integrity
 MFG-525: Fixed Equipment Asset Strategies
 Marine Transfer Operations Manual, Job Aid for Washing Bert Laters  Spill Preparedness and Emergency Response Plan
 Feb 9, 2021 Wharf 16" Ballast Line Leak - volume estimate  2013 Damage Mechanism Review (DMR) report relevant to Line 003  Agency notifications made after incident
 Reports from USCG, DFW and CalOSHA
 Line 003 Piping Asset Strategy Report
 IDMS data export in excel of the circuit 'Line003'
 External visual inspection report of the circuit 'Line003'  2018 Loss/Near Loss report
 2021 SLOFEC Report
 MOCs discussed in Chevron investigation report
 2023.03.30 Ltr to S Grassini & J Brooks (Response to Contra Costa County District Attorney’s Office)

CHEVRON RICHMOND REFINERY
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THIRD-PARTY REVIEW
June 2024 17 AcuTech Group, Inc.
 Fixed equipment asset strategy for the 003 line
 Chapter 5: Normal Operations in the Equipment Operations Manual  Pressure trend of piping circuit 1611-X005-003 (“003 Line”) from May 2019 through March 2021

10. REFERENCES

1. Chevron. (2021). Event Title: February 9, 2021 Richmond Long Wharf Incident, IMPACT ERM Investigation #128842 & LI #192231, September 23, 2021. Richmond.

2. Chevron. (2021, October 27). Contra Costa Health. Retrieved from 30 Day Follow-up Notification Report: https://cchealth.org/hazmat/data-incident-report/63683412.pdf

3. Chevron. (2021, February 15). Contra Costa Health. Retrieved from 72 hour Inicide Report:
https://cchealth.org/hazmat/data-incident-report/62455645.pdf

11. APPENDIX

11.1. Scope of Work
AcuTech’s scope of work as prescribed in the request for proposal (RFP672021) is shown below:

A. The successful candidate will be reviewing the completed/draft RCA report provided by the Chevron Richmond Refinery as well as opportunity to interview key members of the investigation. CCHS expects the independent review report to include at a minimum the following:

1. Review Mechanical Integrity program and how it applies to the pipeline a. Inspection data of the ballast line
b. Corrosion monitoring
c. Determination of the metallurgy and failure route
d. Procedure for use of the ballast line pre- and post-loading operation e. Surveillance during use
f. Other process safety management systems that may be applicable to this incident

2. The candidate will review Chevron Richmond Refinery’s action plan to address the findings of the incident investigation to ensure that the recommendations and action plans are addressing the findings from the incident investigation.

3. Verification and review of incident / event timeline

4. Verification of agencies notifications process
B. Review other completed and available investigation reports from the Coast Guard and the Oil Spill and Prevention Response team from California Department of Fish and Wildlife, and from Cal/OSHA.

C. The successful candidate will be involved in a Public Participation process.

1. A public oversight committee has been developed that will oversee the investigation review process.

CHEVRON RICHMOND REFINERY
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THIRD-PARTY REVIEW
June 2024 18 AcuTech Group, Inc.
a. The Oversight Committee will assist in selecting the successful contractor company to review the investigation.
b. A report-out meeting will be held with the Oversight committee after review of Chevron’s incident investigation report is complete. The candidate will provide a written completeness evaluation of Chevron’s incident investigation. The Oversight Committee will have the opportunity during this meeting to ask questions and give comments on the draft completeness evaluation. At this meeting the Oversight Committee may ask questions and give suggestions on the evaluation report. The contractor will make appropriate changes to the evaluation report based on the feedback from the Oversight Committee. c. When the written completeness report has been accepted from the feedback from the Oversight Committee, this report will have a 45-day public comment period.

During the 45-day public comment period, a public meeting will be held. The public meeting will be an opportunity for the reviewer to listen to the public’s concerns and consider making changes in the report including working with Chevron to complete the evaluation report. The contractor working with CCHS shall respond to all written comments and comments that are raised in the public meeting.

2. The contractor should expect to attend and present reports at the following meetings:
a. A public meeting (expected to be virtual) to present the draft evaluation report. b. The final evaluation report will include the findings of the independent review of Chevron’s incident investigation and public comments received during the public comment period and the comments from the public meeting and the responses to these comments.
c. Two public meetings will be held to present the final evaluation report to Contra Costa County Board of Supervisors and the Richmond City Council.

11.2. Glossary – Abbreviations and Definitions
Abbreviation Name
API American Petroleum Institute
CalOSHA California Occupational and Health Administration CCC Contra Costa County
CCH Contra Costa Health
CCHHMP Contra Costa Health Hazardous Materials Program
CCR California Code of Regulations
CFR Code of Federal Regulations
CML Condition Monitoring Location
HSE Health, Safety, and Environmental
ISO Industrial Safety Ordinance
L/NL Loss/Near Loss
MCAR Major Chemical Accident or Release
MOC Management of Change
OSHA Occupational Safety and Health Administration
OSPR Office of Spill Prevention and Response
P&ID Piping and Instrumentation Diagram

CHEVRON RICHMOND REFINERY
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June 2024 19 AcuTech Group, Inc.

Abbreviation Name
PSM Process Safety Management
RCA Root Cause Analysis
RISO Richmond Industrial Safety Ordinance
RLW Richmond Long Wharf
SLOFEC Saturated Low Frequency Eddy Current

Term Definition
American Petroleum
Institute (API)
The largest U.S. trade association for the oil and gas industry Article A manufactured item, as defined under 29 CFR 1910.1200(b) and Section 5189 of Title 8 of the California Code of Regulations, that is formed to a specific shape or design during manufacture, that has end use functions dependent in whole or in part upon the shape or design during end use, and that does not release or otherwise result in exposure to a regulated substance under normal conditions of processing and use
Major Change Introduction of a new process, process equipment, or regulated substance, an alteration of process chemistry that results in any change to safe operating limits, or other alteration that introduces a new hazard
Mechanical Integrity The process of ensuring that process equipment is fabricated from the proper materials of construction and is properly installed, maintained, and replaced to prevent failures and accidental releases Mitigation system
(active and passive)
Specific activities, technologies, or equipment designed or deployed to capture or control substances upon loss of containment to minimize exposure of the public or the environment
 Passive mitigation: Equipment, devices, or technologies that function without human, mechanical, or other energy input  Active mitigation: Equipment, devices, or technologies that need human, mechanical, or other energy input to function Process Any activity involving a regulated substance including any use, storage, manufacturing, handling, or the onsite movement of such chemicals, or combination of these activities. For purposes of this definition, any group of vessels which are interconnected and separate vessels which are located such that a highly hazardous chemical could be involved in a potential release shall be considered a single process
Public Any person except employees or contractors at the stationary source
Regulated substance Any substance listed pursuant to section II 2(r)(3) of the Clean Air Act as amended in §68.130 of 40 CFR 68 or in Section 2770.5 of the CalARP regulation
Replacement-in-
Kind
A replacement that satisfies the design specifications

CHEVRON RICHMOND REFINERY
FEBRUARY 9, 2021, OIL SPILL INCIDENT INVESTIGATION

THIRD-PARTY REVIEW
June 2024 20 AcuTech Group, Inc.

Term Definition
Root cause Prime reasons, such as failures of some management systems, that allow faulty design, inadequate training, or improper changes, which lead to an unsafe act or condition, and result in an incident.

Root causes are also known as underlying causes. If root causes were removed, the particular incident would not have occurred Stationary source Any buildings, structures, equipment, installations, or substance- emitting stationary activities that belong to the same industrial group, which are located on one or more contiguous properties, which are under the control of the same person (or persons under common control), and from which an accidental release may occur.

The term stationary source does not apply to transportation, including storage incident to transportation, of any regulated substance or any other extremely hazardous substance under the provisions of this chapter. A stationary source includes transportation containers used for storage not incident to transportation and transportation containers connected to equipment at a stationary source for loading or unloading.

Transportation includes, but is not limited to, transportation subject to oversight or regulation under 49 CFR part 192, 193, or 195, or a state natural gas or hazardous liquid program for which the state has in effect a certification to DOT under 49 U.S.C. Section 60105.

Properties shall not be considered contiguous solely because of a railroad or gas pipeline right-of-way

11.3. Public Comments and Responses
The following pages include the public comments provided on this report, CCH responses, and AcuTech responses.

1 Michael Dossey
From: Charles Allen <[email protected]>
Sent: Friday, August 4, 2023 1:43 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Contra Costa Hazardous Materials Program,
I'm writing to give my feedback to the recently published report on the 2021 Chevron diesel spill. I believe that all people, regardless of their race, the language they speak, or how much money they make, should breathe clean air and be able to drink clean water. When I learned about the diesel spill close to the beaches where people swim, I was concerned and surprised. But I was shocked to learn that in 2018, Chevron had realized that the same pipe was cracked – but didn’t actually fix the problem.

Chevron can’t be trusted to report on themselves, because at the end of the day, the Chevron Corporation cares most about their own bottom line and turning a profit while residents rack up medical bills. Our regulatory agencies, from the county up to the state, should have the capacity, staff power, and oversight to transparently regulate the refinery and should not be made to rely on Chevron’s own self-produced reporting. As people living and working in Contra Costa and in the Bay, we deserve timely, accurate, and unbiased information about the highly toxic materials that Chevron is releasing into the community.

Thank you.

Charles Allen
[email protected]
Oakland, California 94601

1 Michael Dossey
From: Karen Jacques <[email protected]>
Sent: Friday, August 4, 2023 1:44 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Karen Jacques
[email protected]
1209 T St. #3
Sacramento, California 95811

1 Michael Dossey
From: Justin Truong <[email protected]>
Sent: Friday, August 4, 2023 1:44 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Justin Truong
[email protected]
33 Junior Terrace
San Francisco, California 94112

1 Michael Dossey
From: Keira Fullbright <[email protected]>
Sent: Friday, August 4, 2023 1:45 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Keira Fullbright
[email protected]
Belton, South Carolina 29627

1 Michael Dossey
From: Mari Rose Taruc <[email protected]>
Sent: Friday, August 4, 2023 1:45 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Mari Rose Taruc
[email protected]
17th Avenue
Oakland, California 94606

1 Michael Dossey
From: Audrey Chan <[email protected]>
Sent: Friday, August 4, 2023 1:46 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Audrey Chan
[email protected]
Culver City, California 90230

1 Michael Dossey
From: sharon byers <[email protected]>
Sent: Friday, August 4, 2023 1:46 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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sharon byers
[email protected]
13042 Stanbridge Ave
downey, California 90242

1 Michael Dossey
From: Raymonde Czerwinski <[email protected]> Sent: Friday, August 4, 2023 1:48 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Raymonde Czerwinski
[email protected]
Corona, California 92882

1 Michael Dossey
From: geoff silverman <[email protected]>
Sent: Friday, August 4, 2023 1:50 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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geoff silverman
[email protected]
10969 Rochester Ave
Los Angeles, California 90024

1 Michael Dossey
From: Carlos Nunez <[email protected]>
Sent: Friday, August 4, 2023 1:55 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Carlos Nunez
[email protected]
18009 Victory Blvd
Reseda, California 91335

1 Michael Dossey
From: Ounniyom Ounniyom <[email protected]>
Sent: Friday, August 4, 2023 1:59 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Ounniyom Ounniyom
[email protected]
Richmond, California 94806

1 Michael Dossey
From: frolayne carlos <[email protected]>
Sent: Friday, August 4, 2023 2:01 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Contra Costa Hazardous Materials Program,
I'm writing to give my feedback to the recently published report on the 2021 Chevron diesel spill. The pipe oversight and lack of maintenance is unacceptable and puts residents of the area, wildlife and surrounding environment at risk.

We all deserve access to clean air and water and believe that all people, regardless of their race, the language they speak, or how much money they make, should breathe clean air and be able to drink clean water. I am appalled to learn that in 2018, Chevron had realized that the same pipe was cracked – but didn’t actually fix the problem.

Thank you.
frolayne carlos
[email protected]
El Sobrante, California 94803

2 1
Michael Dossey
From: Nicole Ma <[email protected]>
Sent: Friday, August 4, 2023 2:14 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Chevron can’t be trusted to report on themselves, because, at the end of the day, the Chevron Corporation cares most about their own bottom line and turning a profit while residents rack up medical bills. Our regulatory agencies, from the county up to the state, should have the capacity, staff power, and oversight to transparently regulate the refinery and should not be made to rely on Chevron’s own self-produced reporting. As people living and working in Contra Costa and in the Bay, we deserve timely, accurate, and unbiased information about the highly toxic materials that Chevron is releasing into the community.

Thank you.

Nicole Ma
Nicole Ma
[email protected]
Irvine, California 92606

1 Michael Dossey
From: Brenda Guzman <[email protected]>
Sent: Friday, August 4, 2023 2:14 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Brenda Guzman
[email protected]
310 Marina Way S
Richmond, California 94804

1 Michael Dossey
From: Janielle Torregosa <[email protected]>
Sent: Friday, August 4, 2023 2:14 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Janielle Torregosa
[email protected]
Long Beach, California 90815

1 Michael Dossey
From: Ariana Saechao <[email protected]>
Sent: Friday, August 4, 2023 2:23 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Ariana Saechao
[email protected]
2800 Avenue
Richmond, California 94804

1 Michael Dossey
From: Charles Kieser <[email protected]>
Sent: Friday, August 4, 2023 2:26 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Charles Kieser
[email protected]
,

1 Michael Dossey
From: Sarah Matsumoto <[email protected]>
Sent: Friday, August 4, 2023 2:26 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Sarah Matsumoto
[email protected]
Santa Cruz, California 95062

1 Michael Dossey
From: Trang Trinh <[email protected]>
Sent: Friday, August 4, 2023 2:27 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Trang Trinh
[email protected]
Milpitas, California 95035

1 Michael Dossey
From: Gabriel Lautaro <[email protected]>
Sent: Friday, August 4, 2023 2:28 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Gabriel Lautaro
[email protected]
Piedmont, California 94610

1 Michael Dossey
From: Erika Minkowsky <[email protected]>
Sent: Friday, August 4, 2023 2:30 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Erika Minkowsky
[email protected]
Richmond, California 94805

1 Michael Dossey
From: Alexis Georgiou <[email protected]>
Sent: Friday, August 4, 2023 2:38 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Alexis Georgiou
[email protected]
982 Laurie Ave
Santa Clara, California 95054

1 Michael Dossey
From: Clio Soiffe <[email protected]>
Sent: Friday, August 4, 2023 3:12 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Clio Soiffe
[email protected]
2314 E 20th St
Oakland, California 94601

1 Michael Dossey
From: Leah Redwood <[email protected]>
Sent: Friday, August 4, 2023 3:44 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Leah Redwood
[email protected]
2817B California Street
Berkeley, California 94703

1 Michael Dossey
From: Gregory Stevens <[email protected]>
Sent: Friday, August 4, 2023 3:57 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Gregory Stevens
[email protected]
506 Guerrero St.

San Francisco, CA

1 Michael Dossey
From: susan pelican <[email protected]>
Sent: Friday, August 4, 2023 4:12 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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susan pelican
[email protected]
21024 co rd 95
woodland, California 95695

1 Michael Dossey
From: Harvey Hild <[email protected]>
Sent: Friday, August 4, 2023 4:24 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Harvey Hild
[email protected]
Harvey Hild
1430 Weil Rd, Texas 78124-1663

1 Michael Dossey
From: Janine Moore <[email protected]>
Sent: Friday, August 4, 2023 5:17 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Janine Moore
[email protected]
32 Gilman St.

Waterville, Maine 04901

1 Michael Dossey
From: Chris Rose <[email protected]>
Sent: Friday, August 4, 2023 5:45 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Chris Rose
[email protected]
Petaluma, California

1 Michael Dossey
From: Rilriia Kilurden <[email protected]>
Sent: Friday, August 4, 2023 6:47 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Rilriia Kilurden
[email protected]
1305 Pyramid Way Apt. 1A
Sparks, Nevada 89431

1 Michael Dossey
From: Karen Berger <[email protected]>
Sent: Friday, August 4, 2023 7:31 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Karen Berger
[email protected]
4412 Ocean View Bl.

Montrose, California 91020

1 Michael Dossey
From: Roshi <[email protected]>
Sent: Friday, August 4, 2023 8:19 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Roshi
[email protected]
El Cerrito, California 94530

1 Michael Dossey
From: Steven Mazliach <[email protected]>
Sent: Friday, August 4, 2023 8:26 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Steven Mazliach
[email protected]
4334 Geary Blvd, Apt 1
San Francisco, California 94118

1 Michael Dossey
From: Lara Clayman <[email protected]>
Sent: Friday, August 4, 2023 8:49 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Lara Clayman
[email protected]
Oakland, California 94602-3323

1 Michael Dossey
From: Tesla Sampson <[email protected]>
Sent: Friday, August 4, 2023 10:38 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Tesla Sampson
[email protected]
Redwood City, California 94061

1 Michael Dossey
From: Alison Ehara-Brown <[email protected]> Sent: Saturday, August 5, 2023 5:49 AM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Contra Costa Hazardous Materials Program,
I'm writing to give my feedback to the recently published report on the 2021 Chevron diesel spill. I live in and raised my children and I am raising my grandchildren in the shadow of the refinery,
I believe that all people, regardless of their race, the language they speak, or how much money they make, should breathe clean air and be able to drink clean water. When I learned about the diesel spill close to the beaches where people swim, I was concerned and surprised. But I was shocked to learn that in 2018, Chevron had realized that the same pipe was cracked – but didn’t actually fix the problem.

Thank you.

Alison Ehara-Brown
[email protected]
Richmond, California 94804

2 1
Michael Dossey
From: Marinell Daniel <[email protected]>
Sent: Saturday, August 5, 2023 6:25 AM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Marinell Daniel
[email protected]
4070 La Colina Rd.

El Sobrante, California 94803

1 Michael Dossey
From: Rie Takahashi <[email protected]>
Sent: Saturday, August 5, 2023 6:26 AM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Rie Takahashi
[email protected]
Berkeley, California 94703

1 Michael Dossey
From: Nikki Sachs <[email protected]>
Sent: Saturday, August 5, 2023 7:09 AM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Nikki Sachs
[email protected]
Berkeley, California 94702-1753

1 Michael Dossey
From: Jenna Cobb <[email protected]>
Sent: Saturday, August 5, 2023 7:54 AM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Jenna Cobb
[email protected]
270 e Badillo St
Pasadena, California 91106

1 Michael Dossey
From: kathryn vo <[email protected]>
Sent: Saturday, August 5, 2023 11:11 AM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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kathryn vo
[email protected]
Oakland, California 94609

1 Michael Dossey
From: Rochelle Towers <[email protected]>
Sent: Saturday, August 5, 2023 11:33 AM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Rochelle Towers
[email protected]
Oakland, California 94619

1 Michael Dossey
From: Danielle Buma <[email protected]>
Sent: Saturday, August 5, 2023 11:49 AM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Contra Costa Hazardous Materials Program,
I was shocked to learn that in 2018, Chevron realized the pipe was cracked but didn’t fix the problem.

Chevron cares most about their own bottom line. Chevron cannot be trusted to report on themselves.

Thank you,
Danielle Buma
Danielle Buma
[email protected]
Vallejo, California 94590

1 Michael Dossey
From: William Oertel <[email protected]>
Sent: Saturday, August 5, 2023 11:54 AM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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William Oertel
[email protected]
Santa Rosa, California 95407

1 Michael Dossey
From: R Taylor <[email protected]>
Sent: Saturday, August 5, 2023 12:04 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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R Taylor
[email protected]
Los Angeles, California 90064

1 Michael Dossey
From: Kay Fischer <[email protected]>
Sent: Saturday, August 5, 2023 5:32 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Kay Fischer
[email protected]
4099 Howe St.

Oakland, California 94611

1 Michael Dossey
From: Jean Tepperman <[email protected]>
Sent: Saturday, August 5, 2023 6:02 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Contra Costa Hazardous Materials Program,
So who’s independent company is going to be in charge let me guess the governors hand picked team or maybe someone from Berkeley you know the climate change professionals lol maybe we should just fine them or charge them so much for permits to even remove and replace said piping so it makes it harder to even do the work Jean Tepperman
[email protected]
1701 Channing Way
Berkeley, California 94703

1 Michael Dossey
From: Eunice Chung <[email protected]>
Sent: Saturday, August 5, 2023 6:25 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Eunice Chung
[email protected]
Union City, California 94587

1 Michael Dossey
From: MaryAnn Denning <[email protected]>
Sent: Saturday, August 5, 2023 6:49 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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MaryAnn Denning
[email protected]
Corning, New York 14830

1 Michael Dossey
From: Leah Redwood <[email protected]>
Sent: Saturday, August 5, 2023 9:25 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Leah Redwood
[email protected]
2817B California Street
Berkeley, California 94703

1 Michael Dossey
From: [email protected]
Sent: Sunday, August 6, 2023 6:23 AM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Thank you.
[email protected]
,

1 Michael Dossey
From: Diane Dulmage <[email protected]>
Sent: Monday, August 7, 2023 8:20 AM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Diane Dulmage
[email protected]
Richmond, California 94804

1 Michael Dossey
From: JL Angell <[email protected]>
Sent: Monday, August 7, 2023 8:31 AM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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JL Angell
[email protected]
2391 Ponderosa Road
Rescue, California 95672

1 Michael Dossey
From: Jan Warren <[email protected]>
Sent: Monday, August 7, 2023 9:38 AM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Contra Costa Hazardous Materials Program,
The public is beyond tired trying to get regulations to get real measures to protect their health from fossil fuel companies that would rather not maintain the refinery and prefer to take chances, while making more money at the public and nature's health risk. The goal is fix pipes before an accident. Chevron has a bad history of not being proactive. There needs to be more oversight and accountability.

I'm writing to give my feedback to the recently published report on the 2021 Chevron diesel spill. I believe that all people, regardless of their race, the language they speak, or how much money they make, should breathe clean air and be able to drink clean water. When I learned about the diesel spill close to the beaches where people swim, I was concerned and surprised. But I was shocked to learn that in 2018, Chevron had realized that the same pipe was cracked – but didn’t actually fix the problem.

Thank you.

Jan Warren
[email protected]
2 3202 Primrose Ln
Walnut Creek, California 94598-1719

1 Michael Dossey
From: Alex Weisshaus <[email protected]>
Sent: Monday, August 7, 2023 9:44 AM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Thank you.

Alex Weisshaus
[email protected]
San Francisco, California 94110

1 Michael Dossey
From: Erica Cheung <[email protected]>
Sent: Monday, August 7, 2023 9:48 AM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Erica Cheung
[email protected]
Oakland, California 94609

1 Michael Dossey
From: Kristel Rietesel <[email protected]>
Sent: Monday, August 7, 2023 11:00 AM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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-Kristel Rietesel, admin of the Bay Area Clean Air Coalition Kristel Rietesel
[email protected]
Berkeley, California 94708

2 1
Michael Dossey
From: David Gassman <[email protected]>
Sent: Monday, August 7, 2023 1:17 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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David Gassman
[email protected]
389 Belmont Street #111
Oakland, California 94610

1 Michael Dossey
From: Tessa Wardle <[email protected]>
Sent: Monday, August 7, 2023 1:57 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Tessa Wardle
[email protected]
San Geronimo, California 94963

1 Michael Dossey
From: Virginia Morris <[email protected]>
Sent: Monday, August 7, 2023 2:23 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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We are all in this together and all of us need accountability from those polluting and harming this community!
Thank you.

Virginia Morris
[email protected]
Stockton, Kansas z:94606

2 1
Michael Dossey
From: Steve Ongerth <[email protected]>
Sent: Monday, August 7, 2023 5:10 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Steve Ongerth
[email protected]
1200 Brickyard Way, 104
Richmond, California 94801

1 Michael Dossey
From: Lauren Murdock <[email protected]>
Sent: Monday, August 7, 2023 10:13 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Lauren Murdock
[email protected]
3940 Via Lucero, Apt #16
Santa Barbara, California 93110

1 Michael Dossey
From: Karen Kirschling <[email protected]>
Sent: Monday, August 7, 2023 10:14 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Karen Kirschling
[email protected]
San Francisco, California 94117

1 Michael Dossey
From: Betty Kissilove <[email protected]>
Sent: Tuesday, August 8, 2023 2:55 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Betty Kissilove
[email protected]
San Francisco, California 94122

1 Michael Dossey
From: Marinell Daniel <[email protected]>
Sent: Tuesday, August 8, 2023 3:36 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Contra Costa Hazardous Materials Program,
I'm writing to give my feedback to the recently published report on the 2021 Chevron diesel spill. I believe that all people, regardless of their race, the language they speak, or how much money they make, should breathe clean air and be able to drink clean water. When I learned about the diesel spill close to the beaches where friends live and swim. I was concerned and surprised. But I was disgusted and alarmed to learn that in 2018, Chevron had realized that the same pipe was cracked – but didn’t actually fix the problem.

I was raised in Richmond near the refinery and now own my home in El Sobrante. I have see the hazardous chemicals dispersed with flares and polluted air that our young have to breathe. I do not trust Chevron to do right by the community or their workers. I am 84 years old and I am sadden to see the mess we are leaving for the next and future generations to live with.

Regards,
Marinell Daniel
2 Thank you.

Marinell Daniel
[email protected]
4070 La Colina Rd.

El Sobrante, California 94803

1 Michael Dossey
From: Andrea Agrimonti <[email protected]>
Sent: Tuesday, August 8, 2023 8:40 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Andrea Agrimonti
[email protected]
River Forest, Illinois 60305

1 Michael Dossey
From: Diana Bohn <[email protected]>
Sent: Wednesday, August 9, 2023 11:29 AM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

This Message Is From an Untrusted Sender
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Diana Bohn
[email protected]
Saint Louis Road
Berkeley California, California 94707

1 Michael Dossey
From: Allyson Ujimori <[email protected]>
Sent: Wednesday, August 9, 2023 3:05 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Allyson Ujimori
[email protected]
Oakland, California 94610

1 Michael Dossey
From: Tony Marks-Block <[email protected]>
Sent: Wednesday, August 9, 2023 3:06 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Tony Marks-Block
[email protected]
Bella Vista Avenue
Oakland, California 94610

1 Michael Dossey
From: Lolly Lim <[email protected]>
Sent: Wednesday, August 9, 2023 3:06 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Lolly Lim
[email protected]
Los Angeles, California 90028

1 Michael Dossey
From: Quanah Brightman <[email protected]>
Sent: Wednesday, August 9, 2023 3:09 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Quanah Brightman
[email protected]
Richmond, California 94801

1 Michael Dossey
From: Brittany Noble <[email protected]>
Sent: Wednesday, August 9, 2023 3:11 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Brittany Noble
[email protected]
San Francisco, California 94122

1 Michael Dossey
From: Deirdre Snyder <[email protected]>
Sent: Wednesday, August 9, 2023 3:17 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Deirdre Snyder
[email protected]
Oakland, California 94609

1 Michael Dossey
From: Keira Fullbright <[email protected]>
Sent: Wednesday, August 9, 2023 3:21 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Keira Fullbright
[email protected]
Belton, South Carolina 29627

1 Michael Dossey
From: Carman Nareau <[email protected]>
Sent: Wednesday, August 9, 2023 3:39 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Contra Costa Hazardous Materials Program,
I'm writing to give my feedback to the recently published report on the 2021 Chevron diesel spill.

Chevron knew about a crack in the pipe that caused the spill in 2018 but didn’t actually fix the problem. It’s unreasonable to expect that Chevron can be trusted to report on themselves.

Corporations are motivated by profits and are not looking out for residents’ safety.

Our regulatory agencies, from the county up to the state, should have the capacity, staff power, and oversight to transparently regulate the refinery and should not be made to rely on Chevron’s own self-produced reporting. As people living and working in Contra Costa and in the Bay, we deserve timely, accurate, and unbiased information about the highly toxic materials that Chevron is releasing into the community.

Thank you.

Carman Nareau
[email protected]
Emeryville, California 94611

1 Michael Dossey
From: Kaili Kuo <[email protected]>
Sent: Wednesday, August 9, 2023 3:42 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Thank you.

Kaili Kuo
[email protected]
Oakland, California 94609

1 Michael Dossey
From: Kimberly Mark <[email protected]>
Sent: Wednesday, August 9, 2023 3:43 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Thank you.

Kimberly Mark
[email protected]
Oakland, California 94606

1 Michael Dossey
From: Jenna Cobb <[email protected]>
Sent: Wednesday, August 9, 2023 3:45 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Thank you.

Jenna Cobb
[email protected]
270 e Badillo St
Pasadena, California 91106

1 Michael Dossey
From: Kiara Harasaki <[email protected]>
Sent: Wednesday, August 9, 2023 3:48 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Thank you.

Kiara Harasaki
[email protected]
Redondo Beach, California 90278

1 Michael Dossey
From: Connie Lu <[email protected]>
Sent: Wednesday, August 9, 2023 4:01 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Thank you.

Connie Lu
[email protected]
3043 Vin Grande Ct
San Jose, California 95135

1 Michael Dossey
From: Lazuli Trujano <[email protected]>
Sent: Wednesday, August 9, 2023 4:06 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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We demand that Chevron is held accountable, especially when it comes to reporting! Thank you.

Lazuli Trujano
[email protected]
Richmond, California 94805

2 1
Michael Dossey
From: Claire Phillips <[email protected]>
Sent: Wednesday, August 9, 2023 4:07 PM
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Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Thank you.

Claire Phillips
[email protected]
Altadena, California 91001

1 Michael Dossey
From: Charles Loi <[email protected]>
Sent: Wednesday, August 9, 2023 4:25 PM
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Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Charles Loi
[email protected]
San Jose, California 95123

1 Michael Dossey
From: Abtehal Alazzani <[email protected]>
Sent: Wednesday, August 9, 2023 4:42 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Abtehal Alazzani
[email protected]
Richmond, California 94806

1 Michael Dossey
From: Aileen Joy <[email protected]>
Sent: Wednesday, August 9, 2023 5:55 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Thank you.

Aileen Joy
[email protected]
Oakland, California 94611

1 Michael Dossey
From: Paul Crum <[email protected]>
Sent: Wednesday, August 9, 2023 7:20 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Furthermore, having personal experience working on contract at Chevron Standad Oil in El Segundo. CA, I learned that Company Policy required them to put "Leaker Tags" on leaking valves and pipes. It was like working in a war zone with alarms and ambulances daily.

Unfortunately for us these companies are intent on screwing the public for more profits.

Thank you,
/s/Paul Crum
21 Lighthouse Ln,
2 Richmond,
CA 95804-7403
PS: PG&E is also intent on screwing the public thri the PUC.

CC: Congressman Garamendi
Paul Crum
[email protected]
Richmond, California 94804-7403

1 Michael Dossey
From: Alice Grimm <[email protected]>
Sent: Wednesday, August 9, 2023 9:56 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Thank you.

Alice Grimm
[email protected]
Oakland, California 94618

1 Michael Dossey
From: Eli Boeck <[email protected]>
Sent: Thursday, August 10, 2023 6:50 AM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Thank you.

Eli Boeck
[email protected]
Vallejo, California 94590

1 Michael Dossey
From: Elana Story <[email protected]>
Sent: Thursday, August 10, 2023 7:53 AM
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Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Thank you.

Elana Story
[email protected]
Oakland, California 94609

1 Michael Dossey
From: Linda Civitello <[email protected]>
Sent: Thursday, August 10, 2023 8:37 AM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Thank you.

Linda Civitello
[email protected]
Sebastopol, California 95472

1 Michael Dossey
From: Nguyen Werks <[email protected]>
Sent: Thursday, August 10, 2023 9:23 AM
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Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Thank you.

Nguyen Werks
[email protected]
Oakland, California 94601

1 Michael Dossey
From: Stephanie Kubick <[email protected]>
Sent: Thursday, August 10, 2023 9:35 AM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Thank you.

Stephanie
Stephanie Kubick
[email protected]
San Francisco, California 94117

1 Michael Dossey
From: Sue Hurley <[email protected]>
Sent: Thursday, August 10, 2023 3:05 PM
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Thank you.

Sue Hurley
[email protected]
Benicia, California 94510

1 Michael Dossey
From: Noah Haydon <[email protected]>
Sent: Thursday, August 10, 2023 9:00 PM
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Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Noah Haydon
[email protected]
405 91st St
Daly City, California 94015

1 Michael Dossey
From: Gabriel Newman <[email protected]>
Sent: Friday, August 11, 2023 10:23 AM
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Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Thank you.

Gabriel Newman
[email protected]
Lafayette, California 94549

1 Michael Dossey
From: Lara Clayman <[email protected]>
Sent: Friday, August 11, 2023 3:03 PM
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Lara Clayman
[email protected]
Oakland, California 94602

1 Michael Dossey
From: Rebecca Orozco <[email protected]>
Sent: Tuesday, August 15, 2023 10:56 PM
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Rebecca Orozco
[email protected]
Oakland, California 94611

1 Michael Dossey
From: Aviva Kardener <[email protected]>
Sent: Wednesday, August 16, 2023 3:20 PM
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Aviva Kardener
[email protected]
2008 West Street
Oakland, California 94612

1 Michael Dossey
From: Todd Snyder <[email protected]>
Sent: Thursday, August 17, 2023 5:49 PM
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Todd Snyder
[email protected]
San Francisco, California 94115

1 Michael Dossey
From: Nancy Stein <[email protected]>
Sent: Friday, August 18, 2023 12:51 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Chevron in Richmond
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Chevron continues to be a corrupt and lying company that threatens every living being in the bay area.

The Feb 21st spill was inadequately cleaned up by the company, and the $70,000 fine is also inadequate.

Do we need to launch a Chevron boycott to get you to do the right thing? There is not one piece of Chevron publicity that speaks the truth. It is a company bent on destroying the planet to the benefit of a few bloated, ugly billionaires.

Nancy Stein
P.O. Box 28
Pt. Reyes, Ca 94956
1 Michael Dossey
From: Diane Livia <[email protected]>
Sent: Friday, August 18, 2023 12:59 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] ATTN: Michael Dossey. AcuTech not neutral Follow Up Flag: Flag for follow up
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AcuTech should never have been chosen to write the report on Chevron's oil spill on early 2021.

According to SF Baykeeper, AcuTech is not a neutral third party, as was required by local laws governing refinery investigations.

This would appear to not fulfill the legal obligations required of the report on that spell.

Diane Livia
6445 Colby St,
Oakland, CA 94618
1 Michael Dossey
From: Lonna Richmond <[email protected]>
Sent: Friday, August 18, 2023 1:08 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Chevron Oil Spill
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Hello,

I am writing to voice my complaint about AcuTech and their obvious conflict of interest when hired to critique the way Chevron handled the oil spill of 2021 in Richmond.

The people of Richmond–and the Bay–deserve better. That is why I am joining the Baykeeper and community partners and demanding full transparency and accountability from Chevron.

Truthfully, fining Chevron $70,000 for their negligence and mishandling of this spill, is an insult.

This company
earned billions in previous years and $70K is like pocket change to them.

Chevron must get on board and take care of our Bay - anything less is unacceptable.

Sincerely,
Lonna Richmond

‐‐

1 Michael Dossey
From: Aida <[email protected]>
Sent: Friday, August 18, 2023 1:31 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] New Chevron Oil Spill Report Doesn't Smell Correctly - Again Chevron Lies Follow Up Flag: Flag for follow up
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In early 2021, Richmond residents called Baykeeper’s pollution hotline to report a strange sheen on the Bay and a noxious smell in the air. Turns out, they had discovered an oil spill at Chevron’s loading dock. Unfortunately, Chevron itself was unaware that its oil was polluting the Bay until locals reported it.

In the hours and days that followed, Chevron set up a single boom that didn’t contain the oil—the oil’s spread was evident from our drone aerial footage. Chevron also failed to make use of basic containment strategies, such as skimmer boats and absorbent pads to collect the oil.

A local beach was closed to the public due to the oil washing up on shore, and the toxic leak possibly impacted sensitive eelgrass beds nearby that serve as important habitat for fish and wildlife.

Partly motivated by public outrage over Chevron’s ineffective response effort, Contra Costa County Health Services hired a contractor, AcuTech, to investigate the spill and Chevron’s actions. Now, two years later, AcuTech has finally released its report—and they gave Chevron a glowing review. AcuTech’s unreasonably delayed report left many of the public’s questions unanswered and also neglected to assess the most important aspects of the spill: the oil’s toxicity and its impact on the Bay.

Digging deeper, we learned that AcuTech is not a neutral third party, as was required by local laws governing refinery investigations. According to their website, AcuTech holds a number of contracts with Chevron and at least 24 other major oil companies. In fact, out of all the contractors that bid, only AcuTech had an existing financial relationship with Chevron. Despite this, AcuTech failed to publicly disclose their conflict of interest and was hired for the job.
2 Chevron has faced few consequences for the spill. "The refinery filed a legally required report last year, and in response the state issued Chevron a penalty amounting to $70,000," as Baykeeper executive director Sejal Choksi-Chugh pointed out, "That means they paid less than $90 per gallon for the oil they spilled.

That’s not even a slap on the wrist, it’s a fist bump between the agencies and the Chevron execs. Of course the public was angry, and the City Council required this independent investigation. It's just unfortunate AcuTech was not actually independent and let Chevron off the hook."
The people of Richmond, and of the Bay Area, deserve better. That’s why Baykeeper and our community partners are demanding full transparency and accountability from Chevron. If you want to share your concerns and tell our local agencies to force Chevron to be a better neighbor on the Bay, Chevron, either be a "good neighbor" or move your stinking and corrupt business to another planet. Elon Musk should be able to help you and your cronies.

A. Marina, San Francisco Beekeeper
1 Michael Dossey
From: Lora Premo <[email protected]>
Sent: Friday, August 18, 2023 1:55 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Chevron Oil spill SF Bay
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To whom it may concern:

I am horrified to learn that the 2021 oil spill by Chevron has resulted in virtually no consequences — just small fines that are pocket change to an oil company. The people of Richmond, and of the Bay Area, deserve better. There should be full transparency and accountability demanded from Chevron, not simply sweeping another Big Oil disaster under the rug while destroying the health and lives of hundreds of people and decimating irreplaceable ecosystems that KEEP US *ALL* ALIVE. Big Oil’s disdain for the environment affects every human on earth. This is not an “isolated” event, like a single gum wrapper landing on the ground. The sooner we completely cease all use of Big Oil’s products, the better. Events like this will hasten that wonderful day, but this disaster cannot be allowed to go virtually unacknowledged. They made only the most minimal gesture at clean up and to get their attention, they should be fined *billions* of dollars — that’s the only thing that will catch their attention. Even millions are meaningless to these heartless, irresponsible corporations who do not care who or what they destroy in their quest for profits.

Another option could be jail time for the executives. Something genuinely meaningful.

I hope some greater action will be taken now and in the future as these events continue to occur, since we have made it clear to them with these minimal fines that nobody except the general population and the wildlife really cares. And oil companies do not care about human beings or wildlife — they only care about money, and that is where you have to affect them if you are going to effect any change.

2 Sincerely,

Lora Premo

1 Michael Dossey
From: ALICE POLESKY <[email protected]>
Sent: Friday, August 18, 2023 7:03 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] AcuTech's Flawed Report on the Chevron Oil Spill Follow Up Flag: Flag for follow up
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Finally, two years after the spill, AcuTech has finally released its report—and they gave Chevron a glowing review.

AcuTech’s unreasonably delayed report left many of the public’s questions unanswered and also neglected to assess the most important aspects of the spill: the oil’s toxicity and its impact on the Bay.

It turns out that AcuTech is not a neutral third party, as was required by local laws governing refinery investigations.

According to their website, AcuTech holds a number of contracts with Chevron and at least 24 other major oil companies.

In fact, out of all the contractors that bid, only AcuTech had an existing financial relationship with Chevron. Despite this, AcuTech failed to publicly disclose their conflict of interest and was hired for the job.

Chevron has faced few consequences for the spill. The refinery filed a legally required report last year, and in response the state issued Chevron a penalty amounting to $70,000. That means they paid less than $90 per gallon for the oil they spilled. That’s not even a slap on the wrist, it’s a fist bump between the agencies and the Chevron execs.

The people of Richmond, and of the Bay Area, deserve better. We need full transparency and accountability from Chevron.

Sincerely,
Alice Polesky, San Francisco resident and Bay lover

1 Michael Dossey
From: Jenifer Steele <[email protected]>
Sent: Friday, August 18, 2023 7:26 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] oil spill
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Evidently the organization that investigated the Richmond oil spill, AcuTech, has a cozy relationship with Chevron. What’s wrong with you people? We should be phasing out fossil fuels, not give them the green light to despoil the planet. The Earth is dying, and you’re whistling Dixie. Please have better regulations in place to prevent future spills.

Jenifer Steele

2411 Jefferson Avenue
Berkeley, CA 94703

1 Michael Dossey
From: H R <[email protected]>
Sent: Friday, August 18, 2023 9:43 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] hold Chevron accountable
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Contra Costa Health Hazardous Materials Programs,
Chevron’s response to their 2021 oil spill in the SF Bay was inadequate and irresponsible.

Chevron failed to perform even the most basic containment strategies, and this is not acceptable for the people of Richmond, the people of the Bay Area at large, and for wildlife.

We need true transparency and accountability from Chevron, not a report that glosses over the failures they made. Chevron needs to make changes that reflect the situation we all are in with regard to climate change. We cannot afford oil spills and inadequate responses to oil spills.Please hold Chevron accountable.

Thank you,
Hilary Rand (a concerned citizen, a lifetime resident of the Bay Area)

1 Michael Dossey
From: Donna Sharee <[email protected]>
Sent: Sunday, August 20, 2023 12:03 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Oil Spill of 2021
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A local beach was closed to the public due to the oil washing up on shore, and the toxic leak possibly impacted sensitive eelgrass beds nearby that serve as important habitat for fish and wildlife.

Chevron has faced few consequences for the spill. "The refinery filed a legally required report last year, and in response the state issued Chevron a penalty amounting to $70,000," as Baykeeper executive director Sejal Choksi‐Chugh pointed out, "That means they paid less than $90 per gallon for the oil they spilled. That’s not even a slap on the wrist, it’s a fist bump between the agencies and the Chevron execs. Of course the public was angry, and the City Council required this independent investigation. It's just unfortunate AcuTech was not actually independent and let Chevron off the hook." The people of Richmond, and of the Bay Area, deserve better. We are demanding full transparency and accountability from Chevron!

Sincerely,
2 D. Sharee
SF, CA 94112
1 Michael Dossey
From: Querido Galdo <[email protected]>
Sent: Monday, August 21, 2023 4:36 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Accountability for Chevron
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Dear Contra Costa County Health Services,

I am writing because I am truly tired of seeing our county’s primary polluter continually get away with impacting our health with minimal accountability. Why does this continue to happen? Are you not charged with protecting the health of everyone in this county? Why do you continue to let Chevron off the hook with slaps on the wrist, while county residents continue to suffer from the impacts of their negligence and harmful practices?

In the most recent example of your egregious selling out of the very residents you’re charged with protecting, you hired a firm with clear conflicts of interest to investigate Chevron’s completely inadequate spill response. Out of all of the firms that bid on doing this important work, why did you choose the one that is firmly enmeshed with the industry? At best this is some serious lack of due diligence, and at worst it is not only gross negligence in holding polluters accountable—it points to a deep indifference to what your job and mission is supposed to be.

This department needs to get its act together and start really doing its job. If Chevron or other polluters’ activities and negligence impact our county’s health, YOU are one of the key agencies we rely upon to hold them accountable. There MUST be real consequences to their destructive and deadly actions. No more minuscule fines that represent the tiniest fraction of profit for these companies. They must pay significant impactful fines to the degree they impact our communities. And if even these consequential fines don’t change their practices and negligence, they must be shut down in our county. You may think this will negatively impact our tax base—but how much more do their actions cost us in lost health, our most precious resource?

Please stop basically siding with industry and start siding with the community you work for. You don’t work for Chevron—you worn for US.

Sincerely,
Tito Galdo

‐‐
Querido Galdo
Queridomundo Creative LLC
www.queridomundo.com [queridomundo.com]
pronouns: he/him/his [why pronouns?] [forbes.com]

1 Michael Dossey
From: Jenna Saefong <[email protected]>
Sent: Tuesday, August 22, 2023 12:05 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Contra Costa Hazardous Materials Program,
My name is Jenna Saefong and I am writing to give my feedback to the recently published report on the 2021 Chevron diesel spill. I believe that all people, regardless of their race, the language they speak, or how much money they make, should breathe clean air and be able to drink clean water. When I learned about the diesel spill close to the beaches where people swim, I was concerned and surprised. But I was shocked to learn that in 2018, Chevron had realized that the same pipe was cracked – but didn’t actually fix the problem.

Thank you.

Jenna Saefong
[email protected]
Richmond, California 94805

1 Michael Dossey
From: Brandy Khansouvong <[email protected]> Sent: Tuesday, August 22, 2023 12:06 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Thank you.

Brandy Khansouvong
[email protected]
4748 Hartnett Ave
Richmond, California 94804

1 Michael Dossey
From: regina gilligan <[email protected]>
Sent: Tuesday, August 22, 2023 2:29 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Thank you.

Regina Gilligan, Richmond resident
regina gilligan
[email protected]
Richmond, California 94804

1 Michael Dossey
From: Jean Tepperman <[email protected]>
Sent: Wednesday, August 23, 2023 6:16 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Thank you.

Jean Tepperman
[email protected]
1701 Channing Way
Berkeley, California 94703

1 Michael Dossey
From: Emma Ishii <[email protected]>
Sent: Friday, August 25, 2023 11:30 AM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Contra Costa Hazardous Materials Program,
I'm writing to give my feedback to the recently published report on the 2021 Chevron diesel spill.

I believe that all people, regardless of their race, the language they speak, or how much money they make, should breathe clean air and be able to drink clean water. When I learned about the diesel spill close to the beaches where people swim, I was concerned and surprised. But I was shocked to learn that in 2018, Chevron had realized that the same pipe was cracked – but didn’t actually fix the problem.

As people living and working in Contra Costa and in the Bay, we deserve timely, accurate, and unbiased information about the highly toxic materials that Chevron is releasing into the community.

Thank you.

Emma Ishii
[email protected]
2 Oakland, California 94606

1 Michael Dossey
From: Megan Zapanta <[email protected]>
Sent: Saturday, August 26, 2023 6:15 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Contra Costa Hazardous Materials Program,
I am the Richmond Organizing Director of the Asian Pacific Environmental Network and I’m writing to give my feedback to the recently published report on the 2021 Chevron diesel spill.

For years, I have seen the Laotian refugee community face the negative impacts of living in the shadow of the Chevron Refinery.

Thank you.

Megan Zapanta
[email protected]
2 Richmond, California 94806

1 Michael Dossey
From: Kathleen Petricca <[email protected]>
Sent: Sunday, August 27, 2023 1:21 PM
To: Hazmat Arpteam
Subject: [EXTERNAL] Public Comment re: Chevron diesel spill: #ChevronKnew their pipe could leak.

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Thank you.

Kathleen Petricca
[email protected]
Martinez, California 94553

1 Michael Dossey
From: Ben Eichenberg <[email protected]>
Sent: Monday, August 28, 2023 7:17 PM
To: Hazmat Arpteam; ccchazmat
Cc: Claudia Jimenez; [email protected]; [email protected] Subject: [EXTERNAL] Comments of SF Baykeeper on Chevron 2.9.21 Oil Spill Report Attachments: 2023.08.21 Comment re_CCC Report.pdf
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Dear Contra Costa County,

Attached please find the comments of San Francisco Baykeeper on the Chevron Richmond Refinery February 9, 2021, Oil Spill Incident Investigation Third‐Party Review. Please don't hesitate to reach out if you have any questions or concerns.

Best,

‐‐

Keeping an eye on the Bay since 1989
Ben Eichenberg, Staff Attorney (He/Him)
San Francisco Baykeeper 1736 Franklin Street, Suite 800 | Oakland, CA 94612 Office: 510-735-9700 x105
baykeeper.org [baykeeper.org]
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Attn: Michael Dossey: Contra Costa Health Hazardous Materials Programs 4585 Pacheco Blvd., Ste. 100 Martinez, CA 94553 Submitted electronically to: [email protected] Comment Deadline August 28, 2023 Comments of San Francisco Baykeeper Re: Chevron Richmond Refinery February 9, 2021, Oil Spill Incident Investigation Third-Party Review On February 9, 2021, a rupture in a pipeline at the Chevron Richmond Refinery caused hundreds of gallons of petroleum product to spill into San Pablo Bay (“oil spill”). The Oil Spill Incident Investigation Third-Party Review conducted by AcuTech (“AcuTech Oil Spill Report”) under the Richmond Industrial Safety Ordinance (Municipal Code Chapter 6.43, RISO) addresses this oil spill. The AcuTech Oil Spill Report “was limited to providing a third-party review of the incident investigation report conducted by Chevron.” AcuTech Spill Report at 1. This limited investigation is inadequate to fulfill the purposes of the RISO. There are a number of topics—as explored in detail in the comments, below—where the AcuTech Spill Report does not conduct the level of investigation necessary to prevent future leaks. To the extent that these comments venture outside the limitations placed on this investigation by AcuTech and Contra Costa Heath Services, Baykeeper recommends that a full independent investigation be conducted to ensure the safety of Bay Area residents and the health of the Bay. Richmond Industrial Safety Ordinance The RISO is intended to “prevent and reduce the probability of accidental releases of regulated substances that have the potential to cause significant harm to the public health and increase participation by industry and the public to improve accident prevention.” Richmond Municipal Code Chapter 6.43. Further, the RISO recognizes that regulatory requirements are not sufficient to guarantee public health and safety, that the public must be informed and engaged, and that an investigation that thoroughly identifies hazards and assesses risks within a reasonable time frame is the key to preventing future accidents. The City recognizes that regulatory requirements alone will not guarantee public health and safety, and that the public is a key stakeholder in chemical accident prevention, preparedness and response at the local level. Preventing accidental releases of regulated substances is the shared responsibility of industry, government and the public. The first steps toward accident prevention are identifying the hazards and assessing the risks. Once information about chemical hazards in the community is openly shared, industry, government and the community can work together towards reducing the risk to public health and safety. The success of a safety program is dependent upon the cooperation of industrial chemical and oil refining facilities within the City of Richmond. The public must be assured that measures necessary to prevent incidents are being implemented, including changes or actions required by the County of Contra Costa or the stationary source that are necessary to comply with this chapter. Id. at 6.43.020(d)-(e). Critically, the RISO states without qualification that its goal is “[p]reventing and reducing the number, frequency and severity of accidental releases in the City to the greatest extent feasible.” Id. at 6.43.030(i). As described in the following comments, a full independent review of the February 2021 oil spill is both feasible and necessary to accomplish this goal. Environmental Damage The people of Richmond already carry a disproportionate environmental burden, and spills like the one at Chevron’s Longwharf in 2021 exacerbate that burden with additional exposure to toxic pollutants. The spill closed beaches, contaminated the water, and caused fumes that led to residents complaining the area smelled like a gas station. Nevertheless, the official presentation of AcuTech’s Oil Spill Report stated that the spill was contained to the Chevron property and there were no injuries or environmental damage as a result of the spill.1 This statement is false. The following photographs were taken by Baykeeper, with one photo from local media, and show that containment of the spill was inadequate and that the oil and a significant oil sheen spread along a substantial swath of Richmond’s coastline, impacting far more than Chevron property, as was inaccurately stated at AcuTech’s presentation. 1 The video of the AcuTech presentation can be found at https://www.youtube.com/watch?v=Sx1Mf32-io8, with the statement made at 4:16. The slide from Contra Costa Health with the same statement can be found at https://cchealth.org/hazmat/pdf/chevron-incident-2021-0209-Presentation-AcuTech-Report.pdf, slide 3.

Figure 1: Oil escapes containment boom, 2/9/21
Figure 2: Closeup view of oil escaping containment and approaching mixing zone, 2/9/21

Figure 3: ABC7 still photograph of oil escaping boom containment and spreading along Richmond’s shoreline, 2/9/23 No average member of the public looking at the spill response pictured above would agree that the oil was contained or that the response was adequate. The public wants to know why there was oil along the shoreline and on the beaches. Responders should have seen oil on both sides of the boom and should have taken additional action, including putting out additional booms. Instead, Chevron’s spill response put out one boom, watched oil seeping through the boom and spreading along Richmond’s coastline, and did nothing more besides minimal monitoring and waiting for the Coast Guard and the Office of Spill Prevention and Recovery to arrive. Responders had vessels that could have reached that area and that could have been skimming to collect spilled product that was escaping the boom containment or used absorbent pads to try to remove oil from the water, but they chose not to. As a result, the oil spill spread across the waters of the Bay for miles around Chevron’s wharf. Witnesses observed oil befouling beaches and the shoreline for miles in the hours and days that followed the spill. That oil contained numerous toxic chemical compounds. The harmful impacts that those compounds have on marine life are well documented. Those impacts include a decrease in the thickness of fish eggs; damage to fish eggs, larvae, and young fish; damage to habitats which are the breeding areas of many fish and crustaceans; interference with fish breeding; and tainting of fish, crustaceans, mollusks, and algae. For example, the oil spill occurred in an area known for productive Pacific herring spawns and ecologically important eel grass beds. These photographs document the spread of the oil into these eel grass and herring areas, and show impacts to the Miller/Knox Regional Shoreline, “[a] beautifully situated shoreline picnic area, a secluded cove with swimming

beach, a fishing pier at a historic site[,] a hilltop with excellent panoramic views of the North Bay Area and a model railroad museum.”2 The failure to find oiled birds or other wildlife does not mean that there were no environmental impacts. Impact analysis should include impacts to nearby communities. Contra Costa County officials issued a temporary health advisory warning residents of Richmond, North Richmond, and San Pablo who have respiratory sensitivities to stay indoors. Residents for miles around complained of the foul chemical smell that pervaded Richmond’s air in the wake of the Spill. These impacts and injuries to the community should have been evaluated in AcuTech’s Oil Spill Report. Unanswered questions: (1) What was the specific chemical composition of the oil spilled? (2) What was the full extent of the area impacted by the oil spill? (3) If the spreading oil pictured in the above photographs was not considered part of the oil spill, explain what basis there is for that determination, what environmental impacts the spreading oil may have had, and what measures could be taken to prevent those impacts. (4) If the oil on the beaches was not considered part of the oil spill, explain what basis there is for that determination, what environmental impacts the beached oil may have had, and what measures could be taken to prevent those impacts. (5) Why was there no preemptive booming around the Longwharf, and why is there still none, today? (6) What was the full extent of the impact of the fumes on the Richmond residents, did residents have to go to the hospital, were advisories to stay indoors sufficient to protect public health, and what can be done to prevent fumes in the future? Good Governance The close connections between the Chevron Refinery and the agencies that are tasked with regulating and responding to refinery mistakes are not indicators of good governance. A regulated industry should not be on its own oversight committee and should not be making critical decisions about what kind of independent oversight is called for in emergency situations. These markers of good governance are important indicators of the efficacy of spill response and should have been discussed in the AcuTech Oil Spill Report. According to the Report, the Contra Costa Health Hazardous Materials Program “recommended to the Contra Costa County Industrial Safety Ordinance/Community Warning System Ad Hoc Committee, which is appointed by the County Board of Supervisors, that [Contra Costa Health] hire an independent expert to review the root cause investigation report conducted by Chevron.” AcuTech Oil Spill Report at 3. According to media reports, there were four potential contractors for the review, and AcuTech was the only one of the four that had an existing business relationship with Chevron.3 The AcuTech Oil Spill Report should have included a conflict of interest 2 See East Bay Regional Parks website, https://www.ebparks.org/parks/miller-knox. 3 See, e.g., Richmond Confidential, July 13, 2023, available at https://richmondconfidential.org/2023/07/13/richmond-chevron-spill-county-contractor-investigation/. analysis for its own independence and the independence of the committee making recommendations that detailed past and existing contracts with the regulated entity, in this case, Chevron, and explained why Chevron’s participation on committees and with critical decision making did not compromise the integrity of the investigation and Report. Delay and Public Participation The public is inherently excluded from processes that take an undue amount of time and involve significant barriers such as inadequate notice, inaccurate public statements, and incomplete reporting. The oil spill occurred on February 9, 2021. The independent investigation was not begun until August 13, 2021. Even then, Chevron refused to fulfil its obligations under the RISO to provide access and information in a timely manner to the selected independent investigator. See RISO 6.43.090 (c)(1) and (2). Even once this access and information was provided to AcuTech, on August 26, 2022 (notably, Chevron finished its final report on the investigation on October 24, 2021, 10 months before providing it to AcuTech, AcuTech Oil Spill Report at 6), AcuTech still took another ten months to issue its final report on the oil spill that took place now two and a half years ago. AcuTech Oil Spill Report at 3. The AcuTech Oil Spill Report should have addressed these and any other barriers to public participation, at a minimum by answering the following unanswered questions: (1) Why couldn’t the 30-day update report have been released to the public and the Richmond City Council earlier than the end of December 2021 (12/16/21), more than 10 months after the incident occurred? (2) Why was there a more than six-month delay before the independent investigation began, and what impact did that have on the efficacy of the investigation and on public participation? (3) What prevented Chevron from releasing the report requested by AcuTech until August 26, 2022, nearly 19 months after the spill occurred? How could this delay have been prevented? (4) Why did it take AcuTech until June 2023 do release a final report, 10 months after it acquired all information necessary for its review from Chevron, nearly two years after it signed its contract, and two and a half years after the oil spill? Adequate Notification to Authorities According to the AcuTech Oil Spill Report, The appropriate agencies were notified by Chevron approximately 1 hour after Chevron received the initial public notification. While CCH requires notification as soon as possible or within 15 minutes, it is AcuTech’s opinion that Chevron made all reasonable efforts to meet the requirements of CCH notification while still maintaining good emergency response practices of containing a leak to reduce environmental consequences. AcuTech Oil Spill Report at 3. Again, later in its Report evaluating agency notifications, AcuTech states that The CCH - Hazardous Materials Program includes the Hazardous Materials Incident Notification Policy. According to Section III.E of that policy, CCH requires notification “…as soon as possible or within 15 minutes from discovery of a release….”. Based on interviews with Chevron, it was determined that after the initial public concern was identified, Chevron attempted to confirm the leak was an oil spill and not other ship/barge related issues and then made the appropriate notifications following that determination. It is AcuTech’s opinion that Chevron made all reasonable efforts to meet the requirements of the Contra Costa Health notification requirements while still maintaining good emergency response practices of containing a leak to reduce environmental consequences. Id. at 15-16. Chevron’s response, however, was not reasonable. The purpose of agency notification is not to have exact information, as that information can and will be updated as the spill response progresses. The propose of notification is to alert responders that there is an emergency. Every minute counts, and the additional delay, according to AcuTech’s own Report, resulted in a more severe oil spill. Chevron identified casual factor 2 that the leak was not mitigated by leak detection and/or passive containment. Root cause 5 was subsequently identified relating to the lack of leak detection and/or passive containment in the wharf. If Chevron had other means of leak detection besides just visual inspections by operations, it is possible that the leak may have been caught earlier and the event severity reduced. AcuTech Oil Spill Report at 11. Leak detection and response can take many forms, including adequate and timely notice to emergency responders. Because its conclusion that Chevron made all reasonable efforts has no rational basis in the facts in its own Report, AcuTech must reassess its Report and update this section. Other questions about the leak detection are left unanswered in the report that could help mitigate or prevent future emergency situations: (1) How would Chevron’s leak detection and response system work if a heavier product were involved? Here, someone was able to identify the sheen itself, but if it had been a heavier product it would not have been as immediately obvious. (2) Chevron does not have systems in place to tell responders how much has been spilled. In this case, Chevron was not able to estimate how many gallons had been spilled until two days after the event. What systems could be put into place to more accurately measure how much oil is spilled during an event such as this one? (3) A two-hour timeframe is critical for spill response. If responders cannot respond within that time, spill severity is typically much worse. The Report should have evaluated impacts due to spill response times, especially as relates to notice to administrative agencies and responders. (4) The actual time the leak started is not clear from the Report. If someone smelled the leak at 2:30, the leak must have started earlier than 2:30. The Report should pinpoint the actual start time of the leak to accurately evaluate the response and Chevron’s implementation of measures to ensure future safety. Remaining Questions The AcuTech Oil Spill Report is unclear when discussing what problems existed in the past and what solutions were put into place by Chevron to ensure that a similar leak does not occur again in the future. For example, section 5.2 of the Report discusses the inspection history of the line in question and concludes that Chevron conducted a thorough review: “inspections were performed at appropriate frequencies and incident recommendations were addressed in a timely manner.” AcuTech Oil Spill Report at 10. Therefore, AcuTech concludes that Chevron’s “inspection program and developed internal standards (MFG-525) meet the requirements of relevant industry standards.” Id. The Report must be clearer about where problems existed and how those problems have been fixed. If AcuTech means that there was no problem with the MFG-525 standard as implemented by Chevron, and that there has and will be no change of that standard or of Chevron’s inspections, that conclusion should be clearly stated and the Report should explain why an inspection history and regime that did not detect the leak is considered adequate. AcuTech’s discussion of human factors likewise appears inadequate. While the Report identifies “other means of leak detection besides just visual inspections” as a causal factor and root cause, the Report fails to evaluate the visual inspection program. Id. at 11. If “wharf operators routinely make rounds performing visual inspections of the lines as part of their shift duties,” the leak should have been detected. Id. There is no analysis of visual inspections nor explanation of why they failed to detect the leak. Likewise, passive containment is not adequately discussed. The Report should have evaluated the efficacy of permanent containment measures (booms) and whether additional booms would have helped mitigate the severity of the spill. The final version of the Report must be clearer about what problems existed at Chevron’s facility prior to the leak, and what changes have been made to correct those problems. In order to fulfil the purpose of the RISO and adequately inform the public, the Report must lay out each aspect of the inspection of the faulty facilities and Chevron’s response to the oil spill, evaluate each of those aspects, explain which inspections and responses were effective and should be kept unchanged and which should be abandoned or changed, and explain how the changes put in place by Chevron would prevent future disasters. Conclusion AcuTech’s Oil Spill Report is inadequate to achieve the purposes of the RISO and must be updated to achieve those purposes. To the extent those purposes are not served, or the questions posed above by Baykeeper are not answered, a full independent investigation of this spill event is warranted. Overall, the AcuTech Oil Spill Report concludes that the February 9, 2021 Chevron Richmond Longwharf oil spill was preventable. See, e.g., AcuTech Oil Spill Report at 10 (“should have identified ‘coating/lining failure’ and ‘under deposit corrosion’ as damage mechanisms and should have resulted in broader implementation of inspection techniques designed to find this type of damage.”) Earlier problems with the faulty pipeline should have alerted Chevron personnel to the potential problems associated with this type of pipe, and leak detection technologies should have been in place to allow a faster response, and less severe leak. Moreover, the safety culture at the Longwharf facility was not as robust as it could have been, and less robust than the safety culture at the rest of Chevron’s facility. AcuTech Oil Spill Report at 13. These conclusions warrant a full independent investigation: a mere review of Chevron’s own investigation and reporting risks perpetrating the same issues highlighted in the Report. Finally, there is a risk that the AcuTech Oil Spill Report is not accurate or thorough enough to effectively predict and prevent future spills. Governance and public participation issues must be taken into account to establish the reliability of the process used to select and complete the Report. Thank you for considering these comments. Ben Eichenberg Staff Attorney San Francisco Baykeeper Chevron Wharf Oil Spill Public Comment
Public comment period open from 7/13/23 through 8/28/23 CCHHMP reviewed the following email comments sent to [email protected] A form letter was used as the dominant means to send comments ‐ these are noted below as the Generic Message Several individuals sent customized comments ‐ unique messages are listed Who sent what when are noted below
Not every email provided a name or address
Date Received Name Email Sent on Behalf of Address Custom Message Generic Message 1 Generic Message 2 Message Response 8/4/2023 Charles Allen [email protected] [email protected] Oakland, California 94601 X Contra Costa Hazardous Materials Program,
I'm writing to give my feedback to the recently published report on the 2021 Chevron diesel spill. I believe that all people, regardless of their race, the language they speak, or how much money they make, should breathe clean air and be able to drink clean water. When I learned about the diesel spill close to the beaches where people swim, I was concerned and surprised. But I was shocked to learn that in 2018, Chevron had realized that the same pipe was cracked – but didn’t actually fix the problem.

Chevron can’t be trusted to report on themselves, because at the end of the day, the Chevron Corporation cares most about their own bottom line and turning a profit while residents rack up medical bills. Our regulatory agencies, from the county up to the state, should have the capacity, staff power, and oversight to transparently regulate the refinery and should not be made to rely on Chevron’s own self‐produced reporting. As people living and working in Contra Costa and in the Bay, we deserve timely, accurate, and unbiased information about the highly toxic materials that Chevron is releasing into the community.

Thank you.

Please see Response 1
8/4/2023 Karen Jacques [email protected] [email protected] 1209 T St. #3 Sacramento, California 95811 X Please see Response 1
8/4/2023 Justin Truong [email protected] [email protected] 33 Junior Terrace San Francisco, California 94112 X Please see Response 1 8/4/2023 Keira Fullbright [email protected] [email protected] Belton, South Carolina 29627 X Please see Response 1 8/4/2023 Mari Rose Taruc [email protected] [email protected] 17th Avenue Oakland, California 94606 X Please see Response 1
8/4/2023 Audrey Chan [email protected] themselves Culver City, California 90230 X Please see Response 1 8/4/2023 Sharon Byers [email protected] [email protected] 13042 Stanbridge Ave downey, California 90242 X Please see Response 1
8/4/2023 Raymonde Czerwinski [email protected] [email protected] Corona, California 92882 X Please see Response 1 8/4/2023 Geoff Silverman [email protected] [email protected] 10969 Rochester Ave Los Angeles, California 90024 X Please see Response 1
8/4/2023 Carlos Nunez [email protected] themselves 18009 Victory Blvd Reseda, California 91335 X Please see Response 1
8/4/2023 Ounniyom Ounniyom [email protected] [email protected] Richmond, California 94806 X Please see Response 1 8/4/2023 Frolayne Carlos [email protected] [email protected] El Sobrante, California 94803 X Contra Costa Hazardous Materials Program,
I'm writing to give my feedback to the recently published report on the 2021 Chevron diesel spill. The pipe oversight and lack of maintenance is unacceptable and puts residents of the area, wildlife and surrounding environment at risk.

Chevron can’t be trusted to report on themselves, because at the end of the day, the Chevron Corporation cares most about their own bottom line and turning a profit while residents rack up medical bills. Our regulatory agencies, from the county up to the state, should have the capacity, staff power, and oversight to transparently regulate the refinery and should not be made to rely on Chevron’s own self‐produced reporting. As people living and working in Contra Costa and in the Bay, we deserve timely, accurate, and unbiased information about the highly toxic materials that Chevron is releasing into the community.

Thank you.

Please see Response 1
8/4/2023 Nicole Ma [email protected] [email protected] Irvine, California 92606 X Please see Response 1 8/4/2023 Brenda Guzman [email protected] [email protected] 310 Marina Way S Richmond, California 94804 X Please see Response 1
8/4/2023 Janielle Torregosa [email protected] themselves Long Beach, California 90815 X Please see Response 1 8/4/2023 Ariana Saechao [email protected] [email protected] 2800 Avenue Richmond, California 94804 X Please see Response 1
8/4/2023 Charles Kieser [email protected] [email protected] X Please see Response 1 8/4/2023 Sarah Matsumoto [email protected] [email protected] Santa Cruz, California 95062 X Please see Response 1 8/4/2023 Trang Trinh [email protected] [email protected] Milpitas, California 95035 X Please see Response 1 8/4/2023 Gabriel Lautaro [email protected] [email protected] Piedmont, California 94610 X Please see Response 1 8/4/2023 Erika Minkowsky [email protected] [email protected] Richmond, California 94805 X Please see Response 1 8/4/2023 Alexis Georgiou [email protected] [email protected] 982 Laurie Ave Santa Clara, California 95054 X Please see Response 1
8/4/2023 Clio Soiffe [email protected] [email protected] 2314 E 20th St Oakland, California 94601 X Please see Response 1
8/4/2023 Leah Redwood [email protected] [email protected] 2817B California Street Berkeley, California 94703 X Please see Response 1
8/4/2023 Gregory Stevens [email protected] [email protected] 506 Guerrero St.

San Francisco, CA X Please see Response 1
8/4/2023 Susan Pelican [email protected] [email protected] 21024 co rd 95 Woodland, California 95695 X Please see Response 1
8/4/2023 Harvey Hild [email protected] [email protected] Harvey Hild 1430 Weil Rd, Texas 78124‐1663 X Please see Response 1
8/4/2023 Janine Moore [email protected] themselves 32 Gilman St.

Waterville, Maine 04901 X Please see Response 1
8/4/2023 Chris Rose [email protected] [email protected] Petaluma, California X Please see Response 1 8/4/2023 Rilriia Kilurden [email protected] [email protected] 1305 Pyramid Way Apt. 1A Sparks, Nevada 89431 X Please see Response 1
8/4/2023 Karen Berger [email protected] [email protected] 4412 Ocean View Bl.

Montrose, California 91020 X Please see Response 1
8/4/2023 Roshi [email protected] [email protected] El Cerrito, California 94530 X Please see Response 1 8/4/2023 Steven Mazliach [email protected] [email protected] 4334 Geary Blvd, Apt 1 San Francisco, California 94118 X Please see Response 1 8/4/2023 Lara Clayman [email protected] [email protected] Oakland, California 94602‐3323 X Please see Response 1 8/4/2023 Tesla Sampson [email protected] [email protected] Redwood City, California 94061 X Please see Response 1 8/5/2023 Alison Ehara‐Brown [email protected] [email protected] Richmond, California 94804 X Contra Costa Hazardous Materials Program,
I'm writing to give my feedback to the recently published report on the 2021 Chevron diesel spill. I live in and raised my children and I am raising my grandchildren in the shadow of the refinery, I believe that all people, regardless of their race, the language they speak, or how much money they make, should breathe clean air and be able to drink clean water. When I learned about the diesel spill close to the beaches where people swim, I was concerned and surprised. But I was shocked to learn that in 2018, Chevron had realized that the same pipe was cracked – but didn’t actually fix the problem.

Chevron can’t be trusted to report on themselves, because at the end of the day, the Chevron Corporation cares most about their own bottom line and turning a profit while residents rack up medical bills. Our regulatory agencies, from the county up to the state, should have the capacity, staff power, and oversight to transparently regulate the refinery and should not be made to rely on Chevron’s own self‐produced reporting. As people living and working in Contra Costa and in the Bay, we deserve timely, accurate, and unbiased information about the highly toxic materials that Chevron is releasing into the community.

Thank you.

Please see Response 1
8/5/2023 Rie Takahashi [email protected] [email protected] Berkeley, California 94703 X Please see Response 1 8/5/2023 Nikki Sachs [email protected] [email protected] Berkeley, California 94702‐1753 X Please see Response 1 8/5/2023 Jenna Cobb [email protected] [email protected] 270 e Badillo St Pasadena, California 91106 X Please see Response 1
8/5/2023 Kathryn Vo [email protected] [email protected] Oakland, California 94609 X Please see Response 1 8/5/2023 Rochelle Towers [email protected] [email protected] Oakland, California 94619 X Please see Response 1 8/5/2023 Danielle Buma [email protected] [email protected] Vallejo, California 94590 X Contra Costa Hazardous Materials Program,
I was shocked to learn that in 2018, Chevron realized the pipe was cracked but didn’t fix the problem.

Chevron cares most about their own bottom line. Chevron cannot be trusted to report on themselves.

Thank you,
Please see Response 1
8/5/2023 William Oertel [email protected] [email protected] Santa Rosa, California 95407 X Please see Response 1 8/5/2023 R Taylor [email protected] [email protected] Los Angeles, California 90064 X Please see Response 1 8/5/2023 Kay Fischer [email protected] [email protected] 4099 Howe St.

Oakland, California 94611 X Please see Response 1
8/5/2023 Jean Tepperman [email protected] [email protected] 1701 Channing Way Berkeley, California 94703 X
Contra Costa Hazardous Materials Program,
So who’s independent company is going to be in charge let me guess the governors hand picked team or maybe someone from Berkeley you know the climate change professionals lol maybe we should just fine them or charge them so much for permits to even remove and replace said piping so it makes it harder to even do the work 8/5/2023 Eunice Chung [email protected] [email protected] Union City, California 94587 X Please see Response 1 8/5/2023 MaryAnn Denning [email protected] themselves Corning, New York 14830 X Please see Response 1 8/6/2023 [email protected] themselves X Please see Response 1 8/7/2023 Diane Dulmage [email protected] [email protected] Richmond, California 94804 X Please see Response 1 8/7/2023 JL Angell [email protected] themselves 2391 Ponderosa Road Rescue, California 95672 X Please see Response 1
8/7/2023 Jan Warren [email protected] [email protected] 3202 Primrose Ln Walnut Creek, California 94598‐1719 X
Contra Costa Hazardous Materials Program,
The public is beyond tired trying to get regulations to get real measures to protect their health from fossil fuel companies that would rather not maintain the refinery and prefer to take chances, while making more money at the public and nature's health risk. The goal is fix pipes before an accident. Chevron has a bad history of not being proactive. There needs to be more oversight and accountability.

Chevron can’t be trusted to report on themselves, because at the end of the day, the Chevron Corporation cares most about their own bottom line and turning a profit while residents rack up medical bills. Our regulatory agencies, from the county up to the state, should have the capacity, staff power, and oversight to transparently regulate the refinery and should not be made to rely on Chevron’s own self‐produced reporting. As people living and working in Contra Costa and in the Bay, we deserve timely, accurate, and unbiased information about the highly toxic materials that Chevron is releasing into the community.

Thank you.

Please see Response 1
8/7/2023 Alex Weisshaus [email protected] [email protected] San Francisco, California 94110 X Please see Response 1 8/7/2023 Erica Cheung [email protected] themselves Oakland, California 94609 X Please see Response 1 8/7/2023 Kristel Rietesel [email protected] [email protected] Berkeley, California 94708 X Please see Response 1 8/7/2023 David Gassman [email protected] [email protected] 389 Belmont Street #111 Oakland, California 94610 X Please see Response 1
8/7/2023 Tessa Wardle [email protected] [email protected] San Geronimo, California 94963 X Please see Response 1 8/7/2023 Virginia Morris [email protected] [email protected] Stockton, Kansas 94606 X Please see Response 1 8/7/2023 Steve Ongerth [email protected] [email protected] 1200 Brickyard Way, 104 Richmond, California 94801 X Please see Response 1
8/7/2023 Lauren Murdock [email protected] [email protected] 3940 Via Lucero, Apt #16 Santa Barbara, California 93110 X Please see Response 1 8/7/2023 Karen Kirschling [email protected] [email protected] San Francisco, California 94117 X Please see Response 1 8/8/2023 Betty Kissilove [email protected] [email protected] San Francisco, California 94122 X Please see Response 1 8/8/2023 Marinell Daniel [email protected] [email protected] 4070 La Colina Rd.

El Sobrante, California 94803 X
Contra Costa Hazardous Materials Program,
I'm writing to give my feedback to the recently published report on the 2021 Chevron diesel spill. I believe that all people, regardless of their race, the language they speak, or how much money they make, should breathe clean air and be able to drink clean water. When I learned about the diesel spill close to the beaches where friends live and swim. I was concerned and surprised. But I was disgusted and alarmed to learn that in 2018, Chevron had realized that the same pipe was cracked – but didn’t actually fix the problem.

Chevron can’t be trusted to report on themselves, because at the end of the day, the Chevron Corporation cares most about their own bottom line and turning a profit while residents rack up medical bills. Our regulatory agencies, from the county up to the state, should have the capacity, staff power, and oversight to transparently regulate the refinery and should not be made to rely on Chevron’s own self‐produced reporting. As people living and working in Contra Costa and in the Bay, we deserve timely, accurate, and unbiased information about the highly toxic materials that Chevron is releasing into the community.

Regards,
Please see Response 1
8/8/2023 Andrea Agrimonti [email protected] [email protected] River Forest, Illinois 60305 X Please see Response 1 8/9/2023 Diana Bohn [email protected] themselves Saint Louis Road Berkeley California, California 94707 X Please see Response 1 8/9/2023 Allyson Ujimori [email protected] [email protected] Oakland, California 94610 X Please see Response 1 8/9/2023 Tony Marks‐Block [email protected] [email protected] Bella Vista Avenue Oakland, California 94610 X Please see Response 1
8/9/2023 Lolly Lim [email protected] [email protected] Los Angeles, California 90028 X Please see Response 1 8/9/2023 Quanah Brightman [email protected] [email protected] Richmond, California 94801 X Please see Response 1 8/9/2023 Brittany Noble [email protected] [email protected] San Francisco, California 94122 X Please see Response 1 8/9/2023 Deirdre Snyder [email protected] [email protected] Oakland, California 94609 X Please see Response 1 8/9/2023 Carman Nareau [email protected] [email protected] Emeryville, California 94611 X Contra Costa Hazardous Materials Program,
I'm writing to give my feedback to the recently published report on the 2021 Chevron diesel spill.

Chevron knew about a crack in the pipe that caused the spill in 2018 but didn’t actually fix the problem. It’s unreasonable to expect that Chevron can be trusted to report on themselves. Corporations are motivated by profits and are not looking out for residents’ safety.

Our regulatory agencies, from the county up to the state, should have the capacity, staff power, and oversight to transparently regulate the refinery and should not be made to rely on Chevron’s own self‐produced reporting. As people living and working in Contra Costa and in the Bay, we deserve timely, accurate, and unbiased information about the highly toxic materials that Chevron is releasing into the community.

Thank you.

Please see Response 1
8/9/2023 Kaili Kuo [email protected] [email protected] Oakland, California 94609 X Please see Response 1 8/9/2023 Kimberly Mark [email protected] [email protected] Oakland, California 94606 X Please see Response 1 8/9/2023 Kiara Harasaki [email protected] [email protected] Redondo Beach, California 90278 X Please see Response 1 8/9/2023 Connie Lu [email protected] [email protected] 3043 Vin Grande Ct San Jose, California 95135 X Please see Response 1
8/9/2023 Lazuli Trujano [email protected] [email protected] Richmond, California 94805 X Contra Costa Hazardous Materials Program,
I'm writing to give my feedback to the recently published report on the 2021 Chevron diesel spill. I believe that all people, regardless of their race, the language they speak, or how much money they make, should breathe clean air and be able to drink clean water. When I learned about the diesel spill close to the beaches where people swim, I was concerned and surprised. But I was shocked to learn that in 2018, Chevron had realized that the same pipe was cracked – but didn’t actually fix the problem.

Chevron can’t be trusted to report on themselves, because at the end of the day, the Chevron Corporation cares most about their own bottom line and turning a profit while residents rack up medical bills. Our regulatory agencies, from the county up to the state, should have the capacity, staff power, and oversight to transparently regulate the refinery and should not be made to rely on Chevron’s own self‐produced reporting. As people living and working in Contra Costa and in the Bay, we deserve timely, accurate, and unbiased information about the highly toxic materials that Chevron is releasing into the community.

We demand that Chevron is held accountable, especially when it comes to reporting! Thank you.

Please see Response 1
8/9/2023 Claire Phillips [email protected] themselves Altadena, California 91001 X Please see Response 1 8/9/2023 Charles Loi [email protected] [email protected] San Jose, California 95123 X Please see Response 1 8/9/2023 Abtehal Alazzani [email protected] [email protected] Richmond, California 94806 X Please see Response 1 8/9/2023 Aileen Joy [email protected] [email protected] Oakland, California 94611 X Please see Response 1 8/9/2023 Paul Crum [email protected] [email protected] 21 Lighthouse Ln, Richmond, California 94804‐7403 X
Contra Costa Hazardous Materials Program,
I'm writing to give my feedback to the recently published report on the 2021 Chevron diesel spill. I believe that all people, regardless of their race, the language they speak, or how much money they make, should breathe clean air and be able to drink clean water. When I learned about the diesel spill close to the beaches where people swim, I was concerned and surprised. But I was shocked to learn that in 2018, Chevron had realized that the same pipe was cracked – but didn’t actually fix the problem.

Chevron can’t be trusted to report on themselves, because at the end of the day, the Chevron Corporation cares most about their own bottom line and turning a profit while residents rack up medical bills. Our regulatory agencies, from the county up to the state, should have the capacity, staff power, and oversight to transparently regulate the refinery and should not be made to rely on Chevron’s own self‐produced reporting. As people living and working in Contra Costa and in the Bay, we deserve timely, accurate, and unbiased information about the highly toxic materials that Chevron is releasing into the community.

Thank you,
PS: PG&E is also intent on screwing the public thri the PUC.

Please see Response 1
8/9/2023 Alice Grimm [email protected] [email protected] Oakland, California 94618 X Please see Response 1 8/10/2023 Eli Boeck [email protected] [email protected] Vallejo, California 94590 X Please see Response 1 8/10/2023 Elana Story [email protected] [email protected] Oakland, California 94609 X Please see Response 1 8/10/2023 Linda Civitello [email protected] [email protected] Sebastopol, California 95472 X Please see Response 1 8/10/2023 Nguyen Werks [email protected] [email protected] Oakland, California 94601 X Please see Response 1 8/10/2023 Stephanie Kubick [email protected] [email protected] San Francisco, California 94117 X Please see Response 1 8/10/2023 Sue Hurley sue‐[email protected] [email protected] Benicia, California 94510 X Please see Response 1 8/10/2023 Noah Haydon [email protected] [email protected] 405 91st St Daly City, California 94015 X Please see Response 1
8/11/2023 Gabriel Newman [email protected] [email protected] Lafayette, California 94549 X Please see Response 1 8/15/2023 Rebecca Orozco [email protected] [email protected] Oakland, California 94611 X Please see Response 1 8/16/2023 Aviva Kardener [email protected] [email protected] 2008 West Street Oakland, California 94612 X Please see Response 1
8/17/2023 Todd Snyder [email protected] [email protected] San Francisco, California 94115 X Please see Response 1 8/18/2023 Nancy Stein [email protected] themselves P.O. Box 28 Pt. Reyes, Ca 94956 X
Chevron continues to be a corrupt and lying company that threatens every living being in the bay area.

The Feb 21st spill was inadequately cleaned up by the company, and the $70,000 fine is also inadequate.

CCH continues to provide regulatory oversight of
the programs through our triennial audits and via
the onsite engineer.
8/18/2023 Diane Livia [email protected] themselves 6445 Colby St, Oakland, CA 94618 X
AcuTech should never have been chosen to write the report on Chevron's oil spill on early 2021.

According to SF Baykeeper, AcuTech is not a neutral third party, as was required by local laws governing refinery investigations.

This would appear to not fulfill the legal obligations required of the report on that spell.

Please see Response 2
8/18/2023 Lonna Richmond [email protected] themselves X Hello,
I am writing to voice my complaint about AcuTech and their obvious conflict of interest when hired to critique the way Chevron handled the oil spill of 2021 in Richmond.

The people of Richmond–and the Bay–deserve better. That is why I am joining the Baykeeper and community partners and demanding full transparency and accountability from Chevron.

Truthfully, fining Chevron $70,000 for their negligence and mishandling of this spill, is an insult. This company earned billions in previous years and $70K is like pocket change to them.

Chevron must get on board and take care of our Bay ‐ anything less is unacceptable.

Please see Response 2
8/18/2023 Aida Marina [email protected] themselves X
In early 2021, Richmond residents called Baykeeper’s pollution hotline to report a strange sheen on the Bay and a noxious smell in the air. Turns out, they had discovered an oil spill at Chevron’s loading dock. Unfortunately, Chevron itself was unaware that its oil was polluting the Bay until locals reported it.

A local beach was closed to the public due to the oil washing up on shore, and the toxic leak possibly impacted sensitive eelgrass beds nearby that serve as important habitat for fish and wildlife.

It's just unfortunate AcuTech was not actually independent and let Chevron off the hook." The people of Richmond, and of the Bay Area, deserve better. That’s why Baykeeper and our community partners are demanding full transparency and accountability from Chevron. If you want to share your concerns and tell our local agencies to force Chevron to be a better neighbor on the Bay,
Chevron, either be a "good neighbor" or move your stinking and corrupt business to another planet. Elon Musk should be able to help you and your cronies.

Please see Response 2
8/18/2023 Lora Premo [email protected] themselves X
To whom it may concern:

It turns out that AcuTech is not a neutral third party, as was required by local laws governing refinery investigations. According to their website, AcuTech holds a number of contracts with Chevron and at least 24 other major oil companies. In fact, out of all the contractors that bid, only AcuTech had an existing financial relationship with Chevron. Despite this, AcuTech failed to publicly disclose their conflict of interest and was hired for the job.

The people of Richmond, and of the Bay Area, deserve better. We need full transparency and accountability from Chevron.

Please refer to response 2
8/18/2023 Jenifer Steele [email protected] themselves 2411 Jefferson Avenue Berkeley, CA 94703 X
Evidently the organization that investigated the Richmond oil spill, AcuTech, has a cozy relationship with Chevron. What’s wrong with you people? We should be phasing out fossil fuels, not give them the green light to despoil the planet. The Earth is dying, and you’re whistling Dixie. Please have better regulations in place to prevent future spills.

Please refer to Response 2
8/18/2023 Hilary Rand [email protected] themselves a concerned citizen, a lifetime resident of the Bay Area X
Contra Costa Health Hazardous Materials Programs,
Chevron’s response to their 2021 oil spill in the SF Bay was inadequate and irresponsible. Chevron failed to perform even the most basic containment strategies, and this is not acceptable for the people of Richmond, the people of the Bay Area at large, and for wildlife.

CCH thanks you for your response,  it is the mission
of CCH Hazardous Materials Programs to protect
public health and the envrionment.  The Industrial
Safety Ordinance is one of the most stringent
process safety regulations.  While CCH prides itself
on being at the forefront of process safety due to
the implementation of the ordinance the MCAR
trend from 2021‐2023 has promted CCH to start
evaluating the ISO for opportunites to strenthen
these regulations including evaluating the tools we
have in place to hold refineries accountable.   CCH
reports out on the progress of this work at the
ISO/CWS Ad Hoc Meetings, to stay apprised of
future meetings please see https://contra‐
costa.legistar.com/Calendar.aspx.
8/20/2023 Donna Sharee [email protected] themselves SF, CA 94112 X Please refer to Response 2 8/21/2023 Tito Galdo [email protected] themselves X Dear Contra Costa County Health Services,
I am writing because I am truly tired of seeing our county’s primary polluter continually get away with impacting our health with minimal accountability. Why does this continue to happen? Are you not charged with protecting the health of everyone in this county? Why do you continue to let Chevron off the hook with slaps on the wrist, while county residents continue to suffer from the impacts of their negligence and harmful practices?
In the most recent example of your egregious selling out of the very residents you’re charged with protecting, you hired a firm with clear conflicts of interest to investigate Chevron’s completely inadequate spill response. Out of all of the firms that bid on doing this important work, why did you choose the one that is firmly enmeshed with the industry? At best this is some serious lack of due diligence, and at worst it is not only gross negligence in holding polluters accountable—it points to a deep indifference to what your job and mission is supposed to be.

CCH thanks you for your response,  it is the mission
of CCH Hazardous Materials Programs to protect
public health and the envrionment.  The Industrial
Safety Ordinance is one of the most stringent
process safety regulations.  While CCH prides itself
on being at the forefront of process safety due to
the implementation of the ordinance the MCAR
trend from 2021‐2023 has promted CCH to start
evaluating the ISO for opportunites to strenthen
these regulations including evaluating the tools we
have in place to hold refineries accountable.   CCH
reports out on the progress of this work at the
ISO/CWS Ad Hoc Meetings, to stay apprised of
future meetings please see https://contra‐
costa.legistar.com/Calendar.aspx.  On the matter of
conflict of interest, please refer  to Response 2.
8/22/2023 Jenna Saefong [email protected] themselves Richmond, California 94805 X Please refer to Response 1 8/22/2023 Brandy Khansouvong [email protected] [email protected] 4748 Hartnett Ave Richmond, California 94804 X Please refer to Response 1 8/22/2023 Regina Gilligan [email protected] [email protected] Richmond, California 94804 X Please refer to Response 1 8/24/2023 Emma Ishii [email protected] [email protected] Oakland, California 94606 X Please refer to Response 1 8/26/2023 Megan Zapanta [email protected] themselves Richmond, California 94806 X Contra Costa Hazardous Materials Program,
I am the Richmond Organizing Director of the Asian Pacific Environmental Network and I’m writing to give my feedback to the recently published report on the 2021 Chevron diesel spill. For years, I have seen the Laotian refugee community face the negative impacts of living in the shadow of the Chevron Refinery.

Chevron can’t be trusted to report on themselves, because at the end of the day, the Chevron Corporation cares most about their own bottom line and turning a profit while residents rack up medical bills. Our regulatory agencies, from the county up to the state, should have the capacity, staff power, and oversight to transparently regulate the refinery and should not be made to rely on Chevron’s own self‐produced reporting. As people living and working in Contra Costa and in the Bay, we deserve timely, accurate, and unbiased information about the highly toxic materials that Chevron is releasing into the community.

Thank you.

Please refer to Response 1
8/27/2023 Kathleen Petricca [email protected] [email protected] Martinez, California 94553 X Please refer to Response 1 8/28/2023 Ben Eichenberg [email protected] themselves San Francisco Baykeeper 1736 Franklin Street, Suite 800, Oakland, CA 94612 X Too large ‐ 9 pages ‐ see pdf Please refer to Response 3 Summary counts:

Total number of messages received: 117
Total unique (non‐duplicates): 111
Total Generic Messages: 92
Total Custon Messages 19
Contra Costa Health Responses:

1) Response 1
a) Regulatory agencies need capacity, staﬀ power, and oversight to transparently regulate the reﬁnery
Response: CCH thanks you for your comment regarding the 2021 Wharf Oil Spill. CCH agrees with the comments that regulatory agencies need capacity and staﬀ power to regulate not only reﬁneries but all businesses handling hazardous materials in Contra Costa County. CCH currently is in the process of working towards implemen�ng 3 new posi�ons and reorganizing our division to among other things, increase our capacity when Major Chemical Accidents or Releases occur. (More details can be found in the discussion at the 2/22/24 ISO/CWS Ad Hoc mee�ng htps://contra-
costa.granicus.com/MediaPlayer.php?view_id=1&clip_id=3211). CCH through the ISO con�nues to provide oversight to the reﬁnery through our triennial audits. CCH as required through the ISO has an engineer onsite to oversee process safety ac�vi�es.

b) Timely, accurate, and unbiased informa�on
Response: CCH agrees that �mely, accurate, and unbiased informa�on must be made available to the ci�zens of Contra Costa County. From 2021-2023 CCH Hazmat acknowledges that the �meline from incidents occurring to the beginning of the public no�ce period is quite long. The process of forming the oversight commitee, selec�ng a contractor, and ini�a�ng the work does aﬀect the �meline. The process itself is set very inten�onally to have a very strong focus on environmental jus�ce by having a transparent and public process. However, CCH is working to be more nimble when incidents of this severity occur.

CCH has heard the concerns from the community and will be ins�tu�ng changes to our procedure for the future.

CCH is also in the process of evalua�ng our No�ﬁca�on Policy to make changes to the deﬁni�ons around �meliness of no�ﬁca�on required by facili�es. CCH is also seeking to enhance our policy by adding public awareness messaging for Level 1 incidents. In 2023 CCH revised the no�ﬁca�on policy to include text messaging and email messaging for Level 2 incidents with the aim to provide more �mely informa�on around Level 2 incidents.

2) Response 2
Response: CCH thanks you for your comments regarding the 2021 Wharf Oil Spill. CCH hears your concerns about poten�al conﬂicts of interest between Chevron and Acutech. As a part of the RFP process, companies submi�ng proposals are required to disclose any conﬂicts of interest (speciﬁcally work done for the company in the last 3 years). The Acutech proposal submited in 2021 did note that Acutech had performed work for Chevron USA including the Richmond Reﬁnery. Acutech’s proposal noted that the last �me work was performed for Chevron was in 2015. The RPF process is overseen by an Oversight Commitee which for this incident is comprised of CCH employees, Chevron representa�ves (including USW), members of the community (including a member of the hazmat commission), and City of Richmond Representa�ves. This makeup of this team is to ensure the consultant selec�on process is transparent, fair, and equitable. The line of process safety work is highly specialized with few companies who are equipped to do an RCA inves�ga�on or other process safety work and many of these companies also serve as consultants to companies in the industry. The oversight commitee in the evalua�on process selected contractors based on set criteria while also keeping in mind any conﬂicts of interest reported by respondents.

3) Response 3 (select sec�ons of the Baykeepers comments are shown below) The people of Richmond already carry a disproportionate environmental burden, and spills like the one at Chevron’s Longwharf in 2021 exacerbate that burden with additional exposure to toxic pollutants. The spill closed beaches, contaminated the water, and caused fumes that led to residents complaining the area smelled like a gas station.

Nevertheless, the official presentation of AcuTech’s Oil Spill Report stated that the spill was contained to the Chevron property and therewere no injuries or environmental damage as a result of the spill.
1 This statement is false. The following photographs were taken by Baykeeper, with one photo from local media, and show that containment of the spill was inadequate and that the oil and a significant oil sheen spread along a substantial swath of Richmond’s coastline, impacting far more than Chevron property, as was inaccurately stated at AcuTech’s presentation.

Response: The scope of the review done by Acutech was to review the incident investigation report. Information reported on environmental impacts verbally in the meeting was not included in the Acutech report. CCH notes that the basis for stating there was no injuries or environmental damage was taken from the OSPR updates provided to CCH. No adjustment of the report is warranted.

Impact analysis should include impacts to nearby communities. Contra Costa County officials issued a temporary health advisory warning residents of Richmond, North Richmond, and San Pablo who have respiratory sensitivities to stay indoors. Residents for miles around complained of the foul chemical smell that pervaded Richmond’s air in the wake of the Spill.

These impacts and injuries to the community should have been evaluated in AcuTech’s Oil Spill Report.

Unanswered questions:
(1) What was the specific chemical composition of the oil spilled? (2) What was the full extent of the area impacted by the oil spill? (3) If the spreading oil pictured in the above photographs was not considered part of the oil spill, explain what basis there is for that determination, what environmental impacts the spreading oil may have had, and what measures could be taken to prevent those impacts. (4) If the oil on the beaches was not considered part of the oil spill, explain what basis there is for that determination, what environmental impacts the beached oil may have had, and what measures could be taken to prevent those impacts.
(5) Why was there no preemptive booming around the Longwharf, and why is there still none, today?
(6) What was the full extent of the impact of the fumes on the Richmond residents, did residents have to go to the hospital, were advisories to stay indoors sufficient to protect public health, and what can be done to prevent fumes in the future?

Response: The scope of the work done by Acutech was to review the Incident Inves�ga�on/ Root Cause analysis report that was completed by Chevron. The purpose of the II/RCA is to evaluate why the incident happened and to implement correc�ve ac�ons to prevent something similar from occurring again. The scope did not include a community risk assessment. The spill that resulted was of ﬂush water and diesel like material. Per the 10 OSPR updates that CCH received, it was determined by OSPR and the OEHHA that there was no environmental impact to the shorelines nor were there any impacts to ﬁshing as a result of this incident. In response to the ques�on regarding preemp�ve booming, page 15 of the Acutech report states: “Booms along the causeway of the Richmond Long Wharf were deemed not feasible due to restric�ng access to the piping circuits for both spill response boats and ﬁxed equipment inspectors in work boats. The boats would not be able to jump the booms or have very limited entry points. Costs associated with causeway booms was also a concern of Chevron as they would be exposed to higher damage (loca�on against marine current), require more frequent replacement, and have an overall increased level of maintenance. While booms serve as a ﬁrst line of defense in oil spill recovery, if they restrict the ability for response or proper maintenance that could serve to increase the severity of the incident.”

The close connections between the Chevron Refinery and the agencies that are tasked with regulating and responding to refinery mistakes are not indicators of good governance. A regulated industry should not be on its own oversight committee and should not be making critical decisions about what kind of independent oversight is called for in emergency situations.

These markers of good governance are important indicators of the efficacy of spill response and should have been discussed in the AcuTech Oil Spill Report. According to the Report, the Contra Costa Health Hazardous Materials Program “recommended to the Contra Costa County Industrial Safety Ordinance/Community Warning System Ad Hoc Committee, which is appointed by the County Board of Supervisors, that [Contra Costa Health] hire an independent expert to review the root cause investigation report conducted by Chevron.” AcuTech Oil Spill Report at 3. According to media reports, there were four potential contractors for the review, and AcuTech was the only one of the four that had an existing business relationship with Chevron. 3 The AcuTech Oil Spill Report should have included a conflict of interest analysis for its own independence and the independence of the committee making recommendations that detailed past and existing contracts with the regulated entity, in this case, Chevron, and explained why Chevron’s participation on committees and with critical decision making did not compromise the integrity of the investigation and Report.

Response: The Industrial Safety Ordinance allows for the completion of an independent 3 rd party
evaluation for Major Chemical Accidents or releases. CCH has developed a process to oversee these 3
rd party evaluations that allows for transparency, public participation, and ultimately receives direction from the ISO/CWS AdHoc committee on actions to take. The make-up of the oversight committee does include representatives from the facility to be able to speak to any technical issues as part of the process. CCH’s process includes voices from both union and non- union members of the facility. CCH over the last year via the MRC Oversight Committee has seen many opportunities for improvement on this process which are actively being worked on right now including but not limited to changes in: committee member make-up, transparency of information (including making all meeting minutes available to the public (including RFPs)), and determination of criteria which automatically would result in an independent investigation of an incident. Please also see Response 2 which addresses the conflict-of-interest matter.

(1) Why couldn’t the 30-day update report have been released to the public and the Richmond City Council earlier than the end of December 2021 (12/16/21), more than 10 months after the incident occurred?
(2) Why was there a more than six-month delay before the independent investigation began, and what impact did that have on the efficacy of the investigation and on public participation? (3) What prevented Chevron from releasing the report requested by AcuTech until August 26, 2022, nearly 19 months after the spill occurred? How could this delay have been prevented? (4) Why did it take AcuTech until June 2023 do release a final report, 10 months after it acquired all information necessary for its review from Chevron, nearly two years after it signed its contract, and two and a half years after the oil spill?

Response: CCH notes that the ﬁnal 30-day update report was received by CCHHMP on 10/27/21 and was promptly placed on our website at that �me. As noted in the Acutech report, there was a delay in star�ng the inves�ga�on due to the report not being released. The report was not released un�l an agreement was reached between the two par�es regarding conﬁden�al business informa�on. CCH acknowledges that this is a barrier to having the inves�ga�ve work star�ng and is working towards improving the process to prevent such delays from occurring in the future.

In regard to the release of the dra� report for public comment, the process established by CCH allows for a dra� of the report to be release to the oversight commitee ﬁrst for public comment along with a presenta�on by the consultant. The consultant is then tasked with incorpora�ng all comments from the oversight commitee and adjus�ng the report as needed. This was done in April-June of 2023. From about September-January, Acutech worked on the review of the incident inves�ga�on. Due to the process having been delayed so long it came to CCH aten�on that many of the ac�on items from the report were either already completed or close to comple�on. An adjustment to the scope of the work to be done by Acutech was made to include a review of the implementa�on and closure of all the ac�on items to ensure that they were done properly. While this did add �me to the release of the report, CCH felt that it was necessary to have this review added to the scope to provide for a thorough review.

Adequate Notiﬁcation to Authorities According to the AcuTech Oil Spill Report, the appropriate agencies were notiﬁed by Chevron approximately 1 hour after Chevron received the initial public notiﬁcation.

While CCH requires notiﬁcation as soon as possible or within 15 minutes, it is AcuTech’s opinion that Chevron made all reasonable eﬀorts to meet the requirements of CCH notiﬁcation while still maintaining good emergency response practices of containing a leak to reduce environmental consequences. AcuTech Oil Spill Report at 3. Again, later in its Report evaluating agency notiﬁcations, AcuTech states that The CCH - Hazardous Materials Program includes the Hazardous Materials Incident Notiﬁcation Policy.

According to Section III.E of that policy, CCH requires notiﬁcation “…as soon as possible or within 15 minutes from discovery of a release….”. Based on interviews with Chevron, it was determined that after the initial public concern was identiﬁed, Chevron attempted to conﬁrm the leak was an oil spill and not other ship/barge related issues and then made the appropriate notiﬁcations following that determination. It is AcuTech’s opinion that Chevron made all reasonable eﬀorts to meet the requirements of the Contra Costa Health notiﬁcation requirements while still maintaining good emergency response practices of containing a leak to reduce environmental consequences. Id. at 15-16. Chevron’s response, however, was not reasonable. The purpose of agency notiﬁcation is not to have exact information, as that information can and will be updated as the spill response progresses. The propose of notiﬁcation is to alert responders that there is an emergency. Every minute counts, and the additional delay, according to AcuTech’s own Report, resulted in a more severe oil spill. Chevron identiﬁed casual…… Response: The scope of this review was limited to the Incident Inves�ga�on/ Root Cause Analysis which seeks to iden�fy the management system failures which allowed the incident to happen and iden�fy correc�ve ac�ons. No�ﬁca�on to agencies is outside this scope. However, when speaking to incident no�ﬁca�on CCH notes that it is reasonable for a facility to need �me to inves�gate upon receiving informa�on that there is an incident which could be related to their processes. It is the responsibility of the company to no�fy CCH upon conﬁrma�on of an incident. CCH since 2021 has updated the no�ﬁca�on policy to give more guidance around no�ﬁca�on �melines in events where the facility is inves�ga�ng a poten�al incident.

Comments provided by San Francisco Baykeeper
Remaining Questions – Page 9 of Report
The AcuTech Oil Spill Report is unclear when discussing what problems existed in the past and what solutions were put into place by Chevron to ensure that a similar leak does not occur again in the future. For example, section 5.2 of the Report discusses the inspection history of the line in question and concludes that Chevron conducted a thorough review: “inspections were performed at appropriate frequencies and incident recommendations were addressed in a timely manner. ” AcuTech Oil Spill Report at 10. Therefore, AcuTech concludes that Chevron’s “inspection program and developed internal standards (MFG-525) meet the requirements of relevant industry standards. ” Id. The Report must be clearer about where problems existed and how those problems have been ﬁxed. If AcuTech means that there was no problem with the MFG-525 standard as implemented by Chevron, and that there has and will be no change of that standard or of Chevron’s inspections, that conclusion should be clearly stated and the Report should explain why an inspection history and regime that did not detect the leak is considered adequate.  AcuTech response: Based on our review of the Chevron Richmond reﬁnery inspection program, MFG-525 and inspection data provided, there were no problems identiﬁed with the inspection program in relation to relevant industry standards. Chevron inspection program, MFG-525, was not executed as written which was identiﬁed by Chevron in several of their root causes. If the Chevron standard was properly implemented, the correct damage mechanisms, inspections techniques, and coverage should have been identiﬁed for Line 003.

The report will be revised for the following text in red o “AcuTech is in agreement with Chevron’s report statement that their inspection program and developed internal standards (MFG-525) meet the requirements of relevant industry standards and did not identify other concerns regarding the inspection program other than correct implementation. ” (Page 10)

AcuTech’s discussion of human factors likewise appears inadequate. While the Report identiﬁes “other means of leak detection besides just visual inspections” as a causal factor and root cause, the Report fails to evaluate the visual inspection program. Id. at 11. If “wharf operators routinely make rounds performing visual inspections of the lines as part of their shift duties, ” the leak should have been detected. Id. There is no analysis of visual inspections nor explanation of why they failed to detect the leak. Likewise, passive containment is not adequately discussed. The Report should have evaluated the eƯicacy of permanent containment measures (booms) and whether additional booms would have helped mitigate the severity of the spill.  AcuTech response: Operator rounds consistent of surveying and performing visual inspections of all equipment and piping in the wharf area over their shift, typically an 8 to 12 hour period. Routine operator rounds do not provide for under pipe corrosion inspection even by visual means which is where the leak occurred. Since the incident, Chevron completed a more detailed inspection using Saturated Low Frequency Eddy Current (SLOFEC) technology.
 AcuTech Response: Evaluating the eƯicacy of permanent containment measures and the means of incident response was not part of the scope of work provided to AcuTech by CCH.

The contracted scope of work was to conduct a 3rd party review of the Chevron incident report, not to conduct an independent root cause investigation.

The ﬁnal version of the Report must be clearer about what problems existed at Chevron’s facility prior to the leak, and what changes have been made to correct those problems. In order to fulﬁl the purpose of the RISO and adequately inform the public, the Report must lay out each aspect of the inspection of the faulty facilities and Chevron’s response to the oil spill, evaluate each of those aspects, explain which inspections and responses were eƯective and should be kept unchanged and which should be abandoned or changed, and explain how the changes put in place by Chevron would prevent future disasters.
 AcuTech response: AcuTech did evaluate the incident investigation including the cause of the event, the proposed corrective action, and their beneﬁts.

The report will be revised for the following text in red o “Removing a large portion of the pipeline, increasing the CMLs, and requiring SLOFEC inspection provides a more robust FEAS for the 003 pipeline. Implementing these changes will improve the identiﬁcation of potential anomalies on the line 03 piping to help improve the prevention of future leaks. ” (Page 13)

CHEVRON RICHMOND REFINERY
FEBRUARY 9, 2021, OIL SPILL INCIDENT INVESTIGATION

THIRD-PARTY REVIEW
June 2024 AcuTech Group, Inc.

12. ADDENDUM A – COPIES OF DOCUMENTS REVIEWED
The following two documents are attached as copies of information reviewed. All remaining documents reviewed, as identified in section 9 contain confidential business information as determined by Chevron.

 Agency notifications made after incident
 Reports from USCG, DFW and CalOSHA

For CCHS Use Only:

Received By:
__________________
Date Received:
________________
Incident Number:
______________
Copied To:
____________________
Event Classification Level:
_______

ATTENTION: Matt Kaufmann
Hazardous Materials Program Director
Contra Costa Health Services Department
4333 Pacheco Boulevard
Martinez, CA 94553

INCIDENT DATE: February 9, 2021
INCIDENT TIME: 14:36
FACILITY: Chevron Richmond Refinery

PERSON TO CONTACT FOR ADDITIONAL INFORMATION: Patricia Roberts Phone Number: (510) 890-5677

I. SUMMARY OF EVENT

At approximately 14:36, the Refinery Shift Leader (RSL) received a call from a private citizen that there was a sheen observed in the water near the Chevron Richmond Long Wharf. Notifications were made to Long Wharf operations, Chevron Fire Department and Wharf supervision. Operations immediately began investigation into a potential release to the water. Operators in a boat were able to identify a leak in an overhead line. Wharf operations immediately took actions to set up a boom in the water around the leak and to isolate and de-inventory the line. The line was observed to no longer be leaking at 16:30.

II. AGENCIES NOTIFIED, INCLUDING TIME OF NOTIFICATION

After making a determination of potential off-site consequences from a release to the water, in accordance with the Contra Costa County Health Services (CCCHS) incident notification policy, a CWS Level 2 notification was sent.

Primary: Community Warning System (CWS):

• Level 2 CWS activated at approximately 15:43
• CWS Level Update @16:05
• CWS Level Update @16:30
• CWS Level Update @16:54
• CWS Level Update @ 17:37
ACUTECH-09-25-2022_000104

Secondary: Subsequent notifications via telephone to the agencies below

Agency Person Reached Phone Number Time
National Response Center Theatt 800-424-8802 15:20
State Warning Center California
Emergency Management
Agency
Nevar 800-852-7550 15:25
Contra Costa County Health
Services Department
Bryant 925-335-3232 15:35
US Coast Guard Sector San
Francisco Command Center
Heaney 415-399-3530 15:39
CA Dept of Fish and Wildlife –
Office of Spill Prevention and
Response
Message -
Mike Coyne returned
call
916-375-8581 15:50
Contra Costa County Office of
Emergency Services
Heather 925-646-4461 15:53
Richmond Fire/Police Central
Dispatch
284 Deana 510-620-6933 15:55
CA State Lands Commission Message – Chris called
back
562-590-5201 16:13
Regional Water Quality Control
Board
Left Messages 510-622-2369
510-622-2422
510-421-7771
16:15
18:34
18:41
BCDC Oil Spill Program Message – Linda called
back
415-352-3644 16:19

III. AGENCIES RESPONDING, INCLUDING CONTACT NAMES AND PHONE NUMBERS:

At this time, we are aware of the following agencies that have responded.

Bay Area Air Quality Management
District

PHARN, ROGER

415-793-0974

CDFW-OSPR

Caliguire, Michael
12 additional OSPR representatives
916-500-2369

Richmond Fire Department Brownlow, Noah
7 additional RFD representatives
510-778-5028

Contra Costa County Health
Services Dept
Dwight, Sara
10 additional CCHS representatives
925-464-8477

East Bay Regional Parks Love, Alan
2 additional Park representatives
510-881-1833

MSRC

Albert, Tom
1 additional MSRC representative

Oiled Wildlife Care Network
(OWCN)

Hawkins, Jennie
4 additional OWCN representatives
530-979-6099

CAL OSHA

Saxton, Corey

661-343-1214

Richmond Local Police Department Stonebraker, Matt 510-672-4529 ACUTECH-09-25-2022_000105

USCG

Bacon, Taylor
12 additional employees
678-361-7238

IV. EMERGENCY RESPONSE ACTION:

The Chevron Fire Department Incident Command System took lead of the incident for oil spill recovery and clean up.

There was mutual aid (Spill response taskforce) for this event. Everyone listed on the communications responded to this event. Please see section III.

V. IDENTITY OF MATERIAL RELEASED AND ESTIMATED OR KNOWN QUANTITIES:

The quantity of material released is estimated based on currently available information to be between 500 and 750 gallons. The material has been preliminarily characterized based on currently available information to be a diesel type material, with a flash point of 146 F.

VI. METEOROLOGICAL CONDITIONS AT TIME OF EVENT:

Wind Speed (mph) 1 (Long wharf)
Wind Direction
(degree)
228 SW
(Long Wharf)
Precipitation
(inches)

0.00 Temperature (F) 57 (Gertude)

As noted, information based on data received from the Refinery’s Long Wharf or meteorological station which is located near Gertrude Street.

VII. DESCRIPTION OF INJURIES:

There were no injuries associated with this event.

VIII. COMMUNITY IMPACT:

There were no regulatory exceedances based on Ground Level Monitoring data. There are no detects above known health limits based on Air Monitoring data.

Ground Level Monitoring Data Summary
Background Prior to and Maximum Concentration Readings During the event Castro Street Golden Gate Gertrude Street
H2S (ppb)
Background
@ 11:00-
11:59am

3.23 4.09 1.74
H2S (ppb)
Max.

3.86 5.44 2.19
ACUTECH-09-25-2022_000106

SO2 (ppm)
Background
@ 11:00-
11:59am

4.08 5.02 2.20
SO2 (ppm)
Max.

4.20 7.50 2.86

Note: The Cal/OSHA PEL for SO2 is 2,000 ppb (2 ppm) averaged over an 8-hour period. The Cal/OSHA PEL for H2S is 10,000 ppb (10 ppm) averaged over an 8-hour period

Fence Line Air Monitoring Summary

During the release, no detections were seen at fence line air monitoring stations.

Community Air Monitoring Summary

During the time period of the event and following, community air monitoring was conducted in various locations in Point Richmond ranging from the Toll Plaza off Stenmark Drive to other coastal points along the waterline up to Miller/Knox Regional Shoreline off Dornan Drive. All air samples were below detection limits in the community air sampling (LEL, H2S, CO, SO2, NH3, Benzene).

IX. INCIDENT INVESTIGATION RESULTS:

A root cause analysis incident investigation will be conducted to determine the cause of the release.

X. SUMMARIZE INVESTIGATION RESULTS BELOW OR ATTACH COPY OF REPORT:

Results will be determined by the investigation.

XI. SUMMARIZE PREVENTABLE MEASURES TO BE TAKEN TO PREVENT RECURRENCE INCLUDING

MILESTONE AND COMPLETION DATES FOR IMPLEMENTATION
Preventable measures will be determined by the investigation.

ACUTECH-09-25-2022_000107
ACUTECH-09-25-2022_000263
ACUTECH-09-25-2022_000264
ACUTECH-09-25-2022_000265
ACUTECH-09-25-2022_000266
ACUTECH-09-25-2022_000267
ACUTECH-09-25-2022_000268
ACUTECH-09-25-2022_000269
ACUTECH-09-25-2022_000270
ACUTECH-09-25-2022_000271
ACUTECH-09-25-2022_000272
ACUTECH-09-25-2022_000273
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ACUTECH-09-25-2022_000275
ACUTECH-09-25-2022_000276
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ACUTECH-09-25-2022_000280
ACUTECH-09-25-2022_000281
ACUTECH-09-25-2022_000282
ACUTECH-09-25-2022_000283
Director
National Pollution Funds Center
US COAST GUARD STOP 7605
2703 MARTIN LUTHER KING JR AVE SE
WASHINGTON, DC 20593-7605
Staff Symbol: Cm
Phone: 202-795-6071
Toll-Free: 1-800-358-2897
FAX: 202-372-8397
Email: [email protected]
16480
September 1, 2021

CERTIFIED RETURN RECEIPT
7017 2620 0000 2404 0472

CHEVRON CORPORATION
Attn: MR. G. BOSWORTH
841 CHEVRON WAY
RICHMOND CA 94801
RE: CHEVRON RICHMOND OIL SPILL
FPN: A21012
Dear Mr. Bosworth:

This is a follow-up to correspondence sent to you on August 2, 2021 regarding an oil pollution incident.

On February 9, 2021, the Federal On-Scene Coordinator determined that a damaged pipeline at the Chevron Richmond facility resulted in a discharge of oil into the waters of the US. The U.S. Coast Guard initiated pollution removal actions and the Federal Government incurred costs. The Oil Pollution Act of 1990 (33 USC 2701 et seq) provides that the Owner and/or Operator is responsible for the costs incurred.

Based on the information we have received regarding this case, the National Pollution Funds Center (NPFC) has determined that you are liable for these costs. If you have any evidence that would refute this assertion, please forward it to me, at your earliest opportunity or call me at the toll-free number below. A bill with supporting cost documentation is attached to this letter (Enclosure 1). In compliance with various laws and regulations, personal information contained in the supporting documentation has been redacted.

This is a request for reimbursement of the costs incurred responding to this pollution incident, not a penalty or fine.

Liability for pollution removal costs is in addition to other liabilities which may result from this incident, including, but not limited to, any damages or other pollution removal costs or any civil or administrative penalties arising from the incident.

Payment should be made by check or money order payable to the U.S. Coast Guard. Please write the amount paid in space indicated on the enclosed tear-off portion at the bottom of the invoice. Enclose this tear-off strip with your check, and mail in the enclosed windowed envelope.

Send your payment to: USCG Oil Spill Cost Recovery
RE: A21012
P.O. Box 979116
St. Louis, MO 63197-9000
Please note that the Oil Pollution Act requires that any unpaid portion of the bill is subject to interest which will begin to accrue 30 days after the date of the bill. Any payments received after this date will be first applied to the interest and then to the principal.

If you cannot pay this bill in a single payment and wish to discuss a payment plan, or if you feel you are unable to pay this bill, please contact me as soon as possible at the toll-free number below.

ACUTECH-09-25-2022_000284
Subj: CHEVRON RICHMOND 16480
September 1, 2021

2 Please understand that this is the only written notification you will receive from the NPFC and that Federal law requires that we forward unpaid debts to the Department of Justice for potential litigation or to the Department of Treasury's Debt Management Services (DMS) for collection. DMS charges additional fees for their collection efforts. I encourage you to read the “Explanation of Costs” (Enclosure 2) and “Rights and Collection Alternatives” (Enclosure 3) which provides greater detail on some of the items that I have covered in this letter.

The Internal Revenue Service requires that we collect your Tax Payer Identification Number as part of collection process. Form W-9 (Enclosure 4) is provided for this purpose. Please return this with any correspondence that you send us.

If you have any questions, you may contact me at the National Pollution Funds Center, at 202-795-6071 or 1-800- 358-2897 or by email. Your cost to close this matter will only increase over time. Please note the Federal Project Number (A21012) on all correspondence to insure proper credit to your account and a timely and accurate resolution of this matter.

S i n c e r e l y ,

RICHARD R. BOES
Case Officer
U.S. Coast Guard

Enclosure: (1) BILL # A21012-001-21
(2) Explanation of Costs
(3) Rights and Collections Alternatives
(4) IRS Form W-9

BOES.RICHARD.R.1
016774460
Digitally signed by
BOES.RICHARD.R.1016774460
Date: 2021.09.01 14:02:06 -04'00'
ACUTECH-09-25-2022_000285
Keep this portion of the statement for your records. Return receipt at bottom with payment. $21,884.16
$0.00
$0.00

NATIONAL POLLUTION

FUNDS CENTER
To:

FPN:

DESCRIPTION
This is a bill for U.S. Government costs. See second page for list of charges.

AMOUNT
Principal Due
Accrued Interest
This invoice reflects collections received to date totaling:

Total Due $21,884.16
A21012
Oil Spill Cost Recovery
RE: FPN A21012-001-21
P.O. Box 979116
St. Louis, MO 63197-9000
Send Payment To:

Tear along perforation ...

Your billing address (please pen-and-ink any errors or changes):
$21,884.16
United States Coast Guard
P.O. Box 979116
St. Louis, MO 63197-9000
Amount Paid
$
A21012-001-21RE: FPN

UNITED STATES

CHEVRON CORPORATION
841 CHEVRON WAY
RICHMOND CA 94801

CHEVRON CORPORATION
841 CHEVRON WAY
RICHMOND CA 94801
This bill does not include, among other things, any other removal costs, damages, or any administrative or civil penalty which has been or may be accessed. Interest is charged on balances over 30 days past due. Interest rate is market-based and is subject to change pursuant to OPA Â§1005, 33 USC 2705; current rate is .08% per annum. The terms of this bill are controlling; no other terms affixed to any payment are acceptable.

TAX I.D. NUMBER 54-6010204
Case Officer: Boes
Please send this remittance advice with your payment in the enclosed envelope. Make check payable to "U.S. Coast Guard" & writ e FPN A21012-001-21 on the check. To avoid additional late fees, we must receive payment by October 1, 2021 Billed on September 1, 2021
Amount Due as of September 1, 2021
Federal Project/Bill Number: A21012-001-21
Federal Project/Bill Number: A21012-001-21
Original Bill Date: September 1, 2021
Date of this Statement (if different): September 1, 2021 United States Coast Guard
Oil Spill Cost Recovery
ACUTECH-09-25-2022_000286
01-SEP-2021
CG Personnel
CG Equipment
$21,861.75
$22.41
$21,884.16Total
Original Bill Date:NATIONAL POLLUTION

FUNDS CENTER
A21012-001-21Federal Project/Bill Number:

Date of this Statement (if different): 01-SEP-2021

ITEMIZED EXPENSES
ACUTECH-09-25-2022_000287

Explanation of Costs

"CG Equipment" Total cost of Coast Guard-owned equipment used during the removal action based on standard hourly rates published in Commandant Instruction 7310.1 (series). Standard rates typically include crew complement, fuel, maintenance, field operational support, administrative support and depreciation.

"CG Personnel" Total cost of Coast Guard personnel (both military and civilian employees), other than crew complements, used to conduct, direct and/or monitor the removal action or settle claims based on standard hourly rates published in Commandant instruction 7310.1 (series). Standard rates reflect average pay, allowances, government contribution to employee benefits (e.g. FICA, medical), training, change of station, and unfunded retirement costs. Actual costs of travel or per diem are not included - see "CG Travel".

ACUTECH-09-25-2022_000288

RIGHTS, RESPONSIBILITIES, COSTS AND COLLECTION ALTERNATIVES

YOUR RIGHTS. You have the right to an explanation of the basis and nature of the debt, an accounting and how we calculated the debt.

If you would like to inspect the documents that form the basis of the debt, please request a copy from the Case Officer assigned to your case. Copies will be provided free of charge. The Case Officer's contact information can be found on the billing letter.

You may dispute the information in the documents, submit additional material for consideration and request that we review or reconsider the determination of the debt . This request should be made within 60 days of the date of the invoice.

You may request a written repayment agreement in lieu of paying the entire balance of your debt at one time.

Reconsideration for other than prompt full payment requires a review of your financial condition, including access to recent income tax returns. If funds are coll ected in excess of the debt, they will be promptly refunded to you, unless prohibited by law.

INSURANCE COVERAGE. If you have insurance coverage, contact your insurance agent to determine whether your policy covers any of the costs you are being billed.

BANKRUPTCY. If you file for bankruptcy, or if you were in bankruptcy at the time of the incident and an automatic stay is in effect, you are not subject to any of fset during the stay. Please notify us of the stay by sending evidence about the bankruptcy proceedings.

JOINT INCOME TAX RETURN. If you file a joint income tax return, contact the Internal Revenue Service before filing your return to protect the share of your spouse's tax return refund. IRS Form 8379 is required.

INTEREST. Any balance not paid within 30 days of the original bill notice is a delinquent balance. A delinquent balance will subject you to additional charges for interest from the date of delinquency.

TREASURY DEPARTMENT DEBT MANAGEMENT SERVICE (DMS). Outstanding debts that are 60 days or older are eligible for referral to the DMS for collection action. In addition, we are required to refer debts that are 120 days delinquent to the DMS for further collection action. If the delinquent debt is referred to DMS for collection, additional fees will be added to the amount due. Those fees will vary based on whether DMS collects the debt directly or through a private co llection agency. Debts may be referred to the Justice Department for collection by litigation at any time.

TREASURY OFFSET PROGRAM (TOP). In addition to the above fees, you may be charged a fee for tax offset or federal salary offset if collection is made through TOP. A separate fee is charged each time a collection is made. The U.S. Treasury is not required to send notice to debtors before it offsets payments.

ADMINISTRATIVE OFFSET. The DMS may collect your debt through administrative offset. DMS may withhold money owed to you by the United States Government. The offset includes:
• Income tax refunds
• Certain Social Security benefits
• Black Lung Program benefits
• Salaries of federal employees (up to 15% of current net disposable pay per pay period until debt is paid). • Retirement benefits , including railroad, federal and military benefits • Vendor or contractor payments
• Travel reimbursements and advances

ACUTECH-09-25-2022_000289

ADMINISTRATIVE WAGE GARNISHMENT (AWG). The DMS may also collect the debt through administrative wage garnishment (AWG) without a court hearing. The DMS may contact your employer and garnish a portion of your net disposable pay. If AWG is used in the collection of the debt, you may request a hearing to review the debt by notification to the agency on or before the 15th business day following the mailing of the administrative wage garnishment notice. The notification will stay the withholding order until the debtor has been provided the requested hearing. Fa ilure to timely request a hearing by notification to the agency on or before the 15th business day following the mailing of the administrative wage garnishment notice will still entitle you to a hearing upon request, but will not delay the withholding order. 31 CFR § 285.11(f).

CONSUMER REPORTING AGENCIES. The debt may be reported to consumer reporting agencies. The information that may be disclosed to consumer reporting agencies includes the debtor's:
• Name and Address
• Social Security Number
• Taxpayer Identification Number
• Amount, status, and history of the debt
• The program under which the debt arose

DELINQUENT DEBTS ARE A BAR TO CERTAIN FEDERAL PROGRAMS. Debtors owing money to the U.S. Government are barred from obtaining federal loans, including student loans and FHA mortgages, federal loan insurance, federal grants, or federal guarantees.

PENALTIES FOR MAKING FALSE STATEMENTS. Information provided by you must represent all material facts and must be true to the best of your knowledge and belief. Misrepresentation of facts in this matter is subject to prosecution under Federal law, including but not limited to 18 USC§ 1001, and 31 USC§ 3729.

ACUTECH-09-25-2022_000290

ACUTECH-09-25-2022_000291

ACUTECH-09-25-2022_000292

ACUTECH-09-25-2022_000293

ACUTECH-09-25-2022_000294

ACUTECH-09-25-2022_000295

ACUTECH-09-25-2022_000296

ACUTECH-09-25-2022_000297

ACUTECH-09-25-2022_000298

Assistant Secretary
August 30
Scott M. Banks
ACUTECH-09-25-2022_000299
The following is an important document from the Occupational Safety and Health Appeals Board

ACUTECH-09-25-2022_000300
OSHAB 400 DECLARATION OF SERVICE BY MAIL OR EMAIL Rev. 06/16

DECLARATION OF SERVICE BY MAIL OR EMAIL

Inspection Number
1514445

I, Nichole Franco, declare:

1. I am at least 18 years of age, not a party to this action, and I am employed in Sacramento County at 2520 Venture Oaks Way, Suite 300, Sacramento, CA 95833.

2. On , I served a copy of the attached Settlement Order in an envelope addressed as shown below and placed the envelope for collection and mailing on the date and at the place shown in item 3 following our ordinary business practices. I am readily familiar with this business’s practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service in a sealed envelope with postage fully prepaid.

3. D
ate mailed: Place mailed: (city, state): Sacramento, CA

4. On , I electronically served the document listed in item 2 as follows:

NAME OF PERSON SERVED ELECTRONIC SERVICE ADDRESS

Denise Cardoso, DOSH Legal [email protected] Rocio Reyes, DOSH Legal [email protected]

DOSH Northern Office [email protected]
Amy Gaylord [email protected]
Keith Koterbay [email protected]

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.

Nichole Franco

(TYPE OR PRINT NAME OF DECLARANT) (SIGNATURE OF DECLARANT) 09/01/2022
ACUTECH-09-25-2022_000301
OSHAB 203 SETTLEMENT ORDER Rev. 1/20

BEFORE THE

STATE OF CALIFORNIA

OCCUPATIONAL SAFETY AND HEALTH

APPEALS BOARD

In the Matter of the Appeal of:

CHEVRON RICHMOND REFINERY
6001 BOLLINGER CANYON RD., T-2052.

SAN RAMON, CA 94583

Employer
Inspection Number
1514445

SETTLEMENT ORDER

The above-entitled matter is resolved pursuant to this Order and as set forth in the attached Summary Table and attached Settlement Agreement.

IT IS SO ORDERED.

Dated: Kevin J. Reedy
Supervising Administrative Law Judge

Pursuant to California Code of Regulations, title 8, section 364.2, subdivision ( e), employer shall post for 30 working days a copy of t he Settlement Order. Posting shall be in a manner as prescribed in Section 356, subdivision (a).

Pursuant to California Code of Regulations, title 8, section 364.2, subdivision ( d), the division shall serve a copy of this disposition on any authorized person representing affected employees if known.

NOTE: If you disagree with this order, you may petition the Appeals Board for reconsideration within 30 days. The petition must comply with the requirements of Labor Code sections 6614 through 6619. Please call the Appeals Board at (916) 274-5751 if you need assistance.

09/01/2022
ACUTECH-09-25-2022_000302
OSHAB 201 SUMMARY TABLE Rev. 02/18

SUMMARY TABLE

OCCUPATIONAL SAFETY AND HEALTH APPEALS BOARD

In the Matter of the Appeal of:

CHEVRON RICHMOND REFINERY
Inspection No.
1514445

Citation Issuance Date: 08/02/2021
C
I
T
A
T
I
O
N
I
T
E
M

SECTION
T
Y
P
E

CITATION/ITEM RESOLUTION
A
F
F
I
R
M
E
D
V
A
C
A
T
E
D

PENALTY

PROPOSED

BY DOSH IN

CITATION

FINAL

PENALTY

ASSESSED
1 1 5189.1 (j) (1 )(A) G AVD amended as forth in
attached Settlement Agreement. A $315.00 $315.00
Sub-Total $315.00 $315.00

Total Amount Due* $315.00

*You may owe more than this amount if you did not appeal one or more citations or items containing penalties.

Please call 415-703-4310 or email [email protected] i f you have any questions .

Abbreviation Key:

G=General R=Regulatory Er=Employer
S=Serious W=Willful Ee=Employee A/R=Accident Related
RG=Repeat General RR=Repeat Regulatory RS=Repeat Serious

PENALTY PAYMENT INFORMATION

1. Please make your cashier’s check, money order, or company check payable to:

Department of Industrial Relations

2. Write the Inspection No. on your payment

3. If sending via US Mail: If sending via Overnight Delivery:

CAL-OSHA Penalties U S Bank Wholesale Lockbox
PO Box 516547 c/o 516547 CAL-OSHA Penalties
Los Angeles, CA 90051-0595 16420 Valley View Ave.

La Mirada, CA 90638-5821

Online Payments can also be made by logging on to http://www.dir.ca.gov/dosh/CalOSHA_PaymentOption.html

-DO NOT send payments to the California Occupational Safety and Health Appeals Board- ACUTECH-09-25-2022_000303
ACUTECH-09-25-2022_000304
ACUTECH-09-25-2022_000305
ACUTECH-09-25-2022_000306
ACUTECH-09-25-2022_000307

Richmond City CouncilSeptember 24, 2024

Richmond City Council
September 24, 2024