Chevron did not effectively identify in the Incident Command structure the damage mechanisms
that could have caused the 4-sidecut piping leak on the day of the incident. The OSHA
Hazardous Waste Operations and Emergency Response (HAZWOPER) standard states that the
Incident Commander “shall identify, to the extent possible, all hazardous substances or conditions
present”31 in an emergency response situation. However, the appropriate technical expertise
necessary to identify the potential for low-silicon, more rapidly corroding piping components in
the 4-sidecut piping was not effectively consulted in the Incident Command structure on August
6, 2012. This lack of knowledge of all potential causes of the 4-sidecut piping leak led the
Incident Commander to direct emergency responders to take actions that may have ultimately
exacerbated the leak and put many Chevron personnel in harm’s way. It also led the Incident
Commander to limit the “hot zone” to a small area that did not consider the possibility of pipe
rupture. When the 4-sidecut piping ruptured, personnel and firefighting equipment positioned in
the “cold zone” were engulfed in the large vapor cloud.