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Regina
V
Valero Energy UK Limited (formerly known as Chevron Limited)
and
B&A Contracts Limited

WITNESS STATEMENT OF GREGORY MARK HANGGI

1. I was the Chevron Refinery Manager on 2 June 2011, the date of the Incident. In
this statement I want to convey the continuing contrition felt by those in charge of
the company. I also set out what steps have been taken by Chevron since the tragic
Incident at the Pembroke Refinery in order to seek to ensure that an awful incident
like this can never happen again.

My Background
2. I worked my way up through the business before being appointed as Refinery
Manager in April 2010. I joined Chevron in 1974 as a graduate Chemical Engineer
and held a variety of operational and process safety roles of increasing responsibility
at refineries and petrochemical facilities. This led to me becoming General Manager
of the Cedar Bayou petrochemical facility in July 2000, which was owned by
Chevron Phillips Chemical Company ("Chevron Phillips") (a joint venture between
Chevron and Phillips Petroleum Company). In 2004 I was made Vice President of
Chevron Phillips with responsibilities for, amongst other things, process safety and
health and safety. I became Pembroke Refinery Manager in April 2010.

3. Chevron had agreed the sale of the Pembroke Refinery to Valero prior to June 2011
and ownership transferred in August 2011. I left Pembroke at that time and returned
to the USA to chair a steering committee that Chevron had established to learn
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lessons from the Incident. In 20141 was appointed to a role in which I was
responsible for areas including health and safety and process safety in Chevron's
downstream business. In this role I continued work which had already commenced
to implement lessons learnt from the Incident more widely across Chevron. I retired
in October 2017.

Exhibits
4. Exhibited to this statement is a bundle of documents marked "GH1". Where I refer
to a page number in this statement, I am referring to the corresponding page
number of GH1.

The Incident
5. I want to start by saying a few words about the Incident. I want on behalf of those in
management of the Refinery at the time to express our deep regret that something
like this could have happened and the harm it has caused. I witnessed at first hand
the suffering experienced by the families of the deceased and the effect it has had
both upon the wider workforce at the Refinery and within the local community.

6. We had always been proud of our safety record, and I believed that we were entirely
focused upon and committed to safety before this incident. Our Tenets of
Operation, which is the code of conduct we live by, state: "Do it safely or not at air'
and "There is always time to do it righr'. With all of the procedures and processes
we had in place, I genuinely believed that our staff and those operating on our site
were not only safe but continuously strove to improve safety. Plainly that was not
the case, and this incident was an enormous shock to us all. I understand that
merely saying 'sorry' for what happened is of no comfort to those who were injured
or who have lost loved ones, but nevertheless I am very concerned to ensure that it
is still said in court. I believe that it is essential that it is made clear in open court to
the families, to the Court itself and to the wider public that the company's admitted
failures let down all of those individuals and their families. The company will be
instructing our barrister to do so accordingly, before any attempt is made to embark
upon mitigation. The Court will no doubt understand that it was never our intention
that anything like this would happen.

7. At the date of the Incident I was in the US for the marriage of my son. I returned to
the Refinery the next day and led the Refinery's response activities.

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8. In the aftermath, we sought to provide, as best as we could, support to the families

and those affected. Together with our Human Resources Manager, I met with Anita
Broome, Kathy Riley and Andrew Jenkins' family a few days after the Incident.
Approximately a week later I met with Jack Archer and with Andrew Phillips' family.
During these visits, which were understandably harrowing for everyone, I expressed
our regret and sympathy to the families who were trying to comprehend their
enormous loss. We provided contact information for a grief/mental health service
we had arranged and encouraged the families to contact Chevron if they needed
any assistance. The families impressed on me that they did not want their loved
ones to be forgotten and I personally committed to them that we would learn from
the tragedy in order to prevent this from ever happening again.

9. My major concern at the time was that the families' suffering should not be
aggravated by financial worries in light of the loss of their loved ones. I saw to it that
Chevron provided some immediate financial provision. I then, after a few months,
wrote to the families and Mr Phillips in October 2011, to try to put their minds at
ease so far as financial considerations were concerned. I made it clear in no
uncertain terms that Chevron intended to reach a legal settlement with them,
regardless of liability, and the company would pay them full compensation. Together
with B&A, Chevron agreed to pay for the legal representation of the families and
others so that they could seek independent legal advice as to their civil rights to
seek compensation, including bringing claims for such compensation. As part of
that process interim payments were promptly provided to a number of the families
and other claimants. All but two claims (which relate to PTSD claims) have been
settled.

10. We of course do not seek to claim any praise for paying legal compensation as a
consequence of our corporate breach of duty, but I set this out so that the Court can
be assured that they were paid promptly; and have not had to wait for the conclusion
of the criminal process. We have not taken any defensive stance so far as those
proceedings are concerned. The claims brought by the families and Mr Phillips
were settled for the amounts that were claimed without any attempt to delay or
negotiate smaller sums.

11. Following my initial visits to the families of the deceased outlined above, I returned
to see them again on a number of subsequent occasions. I also visited Andrew
Phillips a number of times at his home once he had been discharged from hospital. I

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needed to understand how they were coping and coming to terms with what had
happened and to see if there was anything further we could do.

12. In the days following the Incident, I also visited and listened to personnel across the
Refinery and had open discussions with them about their feelings. Refinery
personnel were collectively in disbelief and shock and I experienced amongst the
workforce great sorrow and a sense of failure. It was not so much a matter of a loss
of morale, rather a unanimous and committed resolve to prevent this from ever
happening again coupled with a palpable perception of shared loss across the whole
Refinery. Whilst it is a huge site in terms of its size, those that work there are a
community and everybody knows each other. I saw to it that grief/mental health
counsellors were brought to the Refinery and I encouraged all on site to engage with
them.

13. Chevron recognises that this incident has affected lives forever and we have sought
to properly respect the memories of those who died. We facilitated Books of
Remembrance which were bound and presented to each family. We also arranged a
memorial service which was held at St David's Cathedral in November 2011 which I
attended along with other Chevron executives. On the first-year anniversary I
returned to the Refinery and participated in a large service which was held at the
Refinery and for a number of years after that a minute's silence was held at the
Refinery, in which Chevron participated.

14. We also wanted to remember those who died and their communities in a more
permanent way. We undertook a project to install public memorials. Two memorials
were created, a bronze sculpture erected on The Rath in Milford Haven and a stone
bench near to the Mill Ponds at Pembroke Castle. The purpose of the memorials is
to pay tribute to the workforce of the energy industry in Pembrokeshire,
remembering especially those who have lost their lives. We involved the families as
part of this project and also consulted with our Welsh Assembly Member, the County
Council and with council members representing affected constituencies. Some
families visited the craftsmen during fabrication. All the families contributed
remembrances of their loved ones which were inscribed in the monument located in
Milford Haven. Dedication ceremonies were attended by the families along with
numerous Pembrokeshire religious and political leaders including the Archbishop of
Wales, the First Minister and the local Welsh Assembly Member.

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15. In partnership with Pembrokeshire College, I initiated and helped to set up on behalf
of Chevron a process safety education module at the College which Chevron
funded. The intent of this project is to provide a foundation in process safety
requirements for student engineers and vocational training for contractors. Lesson
plans and modules were developed by Chevron together with the College. The
Sector Skills Council provided a letter of support for the course and final
confirmation of accreditation was received in December 2013.

16. I have had the opportunity to read the victim personal statements prepared on
behalf of those who have been injured and the families of those who died. They are
moving and sober reminders of just how much has been lost as a consequence of
this Incident. I am saddened that some have perceived the memorials the company
put in place (as described above) as being more by way of corporate PR. That
could not be further from the truth. From a Chevron perspective I can say that we
struggled long and hard over how the company could pay proper tribute to the
memories of those who died and to the local community, in circumstances where it
was no longer operating the Refinery. At the time we did not receive any feedback
whatsoever to suggest that these memorials were not appreciated or were missing
the mark. We have of course always been sensitive to the reality that no such
matters can in any way make amends, nor do they necessarily provide significant
comfort to those that have lost so much, but the response and engagement we
received at the time led us to believe that they had a positive effect and were not
viewed as a cynical exercise in PR. If that was an underlying impression held by
some then I can offer nothing but apology to them. That was never our intention at
all. With both memorials our sincere intention was to provide lasting memorials to
those who have worked in the industry and to pay special acknowledgment to those
who died in the service of it and to their family members.

Lessons Learnt

17. This Incident has been taken extremely seriously by Chevron. Our immediate
concern was to investigate what happened, and I explain below the steps we took;
including sharing our investigation report with the Health and Safety Executive
(HSE). Once we had identified what had happened, we looked at what lessons
needed to be learnt and how those lessons could be embedded in how we do things
in the future.
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18. I explain first what was done at the Refinery in the immediate aftermath of the
Incident, whilst it was still under Chevron's ownership. I then explain what has been
done more widely across our remaining operations in relation to vacuum truck
(bowsering) activities and tank cleaning.

Actions at Refinery

19. The Refinery Management Team took a number of immediate steps within days of
the Incident and prior to the resumption of vacuum truck operations at the Refinery.
These measures included:-

Vacuum Truck/Bowser Safety

20. We issued site bulletins which emphasised key requirements for bowsering. A copy
of the bulletin issued on 24 June 2011 is at page 1. The requirements emphasised
included:

20.1 All bowsers at site had to be earthed using a marked and verified earthing
point.

20.2 That earthing leads for bowsers had to have continuous visual indicators
attached to them to show whether the bowser remained earthed.

20.3 That conductive hoses had to be used which met British Standard 5958.
This was to ensure that static electricity would be adequately transferred to
the earthing point.

20.4 Mandatory continuity checks were completed on hoses to ensure proper

bonding would dissipate any static charge. A requirement was introduced
that hoses be re-checked at least annually and a record kept for each hose
recording the test.

20.5 Loading rates whilst vacuuming had to be reduced to as low as reasonably

practicable in order to reduce the risk of static electricity build up.

20.6 That bowser operatives had to wear a personal 4-way gas monitor device.
These devices continuously monitor the working environment for four
different hazards, one of which is flammable gases.

Additional safeguards introduced

21. To allow the vapours to dissipate safely, a vent hose was fitted to bowsers. The
bulletins re-emphasised that bowser vent hoses had to be located well down-wind of

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the bowser to prevent bowser vacuum tank vapour discharges from becoming
hazardous by, for example, creating an explosive environment near to an ignition
source.

22. It was also emphasised that once bowser activity had ceased, vehicles had to stand
dormant for a minimum of 2 minutes for any static build-up to dissipate.

23. In addition, the Refinery also reviewed and updated its guidance on identifying the
properties of liquids prior to bowsering and which liquids were permitted to be
bowsered.

Monitoring contractors

24. A new checklist for bowsering operations was developed. This was used by
Refinery personnel to check that bowsering operations on site were being
undertaken in accordance with the bowsering requirements discussed above.

Updated vacuum truck standard

25. We began rewriting our bowser (vacuum truck) standard. As part of this process a
full review of the relevant American Petroleum Industry (API) and applicable British
Standards was undertaken. This work was still on-going when ownership of the
Refinery transferred to Valero in August 2011 and I left the Refinery.

ARU Design and Operations

26. Changes were also made after the Incident to the operation of the Amine Recovery
Unit (ARU} at the Refinery. These changes were made to prevent light
hydrocarbons accumulating in the amine running tank. The changes made were:

26.1 The pump-out from the flare drum and amine sump was re-directed from the
ARU amine running tank to a crude oil storage tank outside the ARU.

26.2 In the event there was a plant "upsef', it was directed that the ARU
regenerators would not be slumped and the contents thereof sent to the
ARU amine running tank.

27. We also undertook a review and confirmed that the engineering design and
operating methods at our other Chevron and joint venture refineries did not present
hazards similar to those at Pembroke.

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Actions taken by Chevron after the sale of the Pembroke Refinery

Sharing information with the Health and Safety Executive

28. Shortly after the Incident, Chevron set up its own internal investigation to understand
what had happened. The Chevron Investigation Team comprised individuals
working at the Pembroke Refinery as well as subject matter experts drawn from
some of our other refineries. The investigation concluded after ownership of the
Refinery had transferred to Valero. The Team produced a Report (a copy of which is
at pages 2 to 29) which identified that the most likely cause of the explosion was
that:

"The ignition source is most likely a static discharge from a non-bonded

polyvinylchloride (PVC) vacuum hose. Static electricity is generated by the
movement of materials, like the flow of liquids though tubes, pipes, etc. If the
liquid has low conductivity (like hydrocarbons) an electric charge can
accumulate on an electrically isolated conductor and a spark generated
between surfaces of sufficiently different potential (electrical charge). One
such example is the flow of hydrocarbon though a non-bonded PVC vacuum
hose creating a spark between the hose and a grounded surface.

The source of fuel was light hydrocarbons present in the tank."

29. This Report was provided to the Health and Safety Executive by our solicitors on
24 April 2012.

30. In addition to the Chevron Investigation Team Report, we also wanted to share with
the wider industry the essential facts of the Incident so that the circumstances could
be understood to avoid a recurrence. We prepared an Industry Safety
Communication Awareness Alert dated May 2012 (pages 30 to 32). The purpose of
the Alert was to highlight the fact that vacuum truck operations had been undertaken
using a non-conductive hose without bonding its fittings to the bowser truck or the
tank, and that there was hydrocarbon vapour in the tank which was ignited by static
electricity. The Alert was sent to the Health and Safety Executive and their
permission sought to disseminate it. Permission was declined by the police and HSE
because their joint investigation was on-going.

31. I left Pembroke in August 2011 and returned to the USA to chair a steering
committee which Chevron had formed which was charged with identifying and
learning lessons from the Incident and implementing improvements. In implementing

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lessons, we were to identify immediate changes to be made and to then consider

more comprehensive improvements. Numerous learnings were implemented. In
2014 I was appointed to a role in which I was responsible for areas including health
and safety and process safety in Chevron's downstream business. In this role I
continued work which had already commenced to implement lessons learnt from the
Incident more widely across Chevron.

Vacuum Truck Safe Operation

Safety Advisories

32. In early 2012 Chevron published two internal bulletins known as advisories. One
was in respect of vacuum truck operations and the potential for static ignition, and
the other one related to static hazards more generally. They identified key issues of
importance, learnings and recommended actions to provide guidance to our
refineries on carrying out vacuum truck operations safely. These advisories were
communicated to the workforce as an interim step whilst we were developing our
new Vacuum Standard {which I discuss below).

33. The vacuum truck advisory {pages 33 to 36) emphasised the hazards associated
with vacuum truck use and the need to understand those hazards. Methods for
preventing vacuum truck incidents were set out.

34. The static hazards advisory (pages 37 to 40) emphasised the hazards associated
with the generation, accumulation, and discharge of static electricity and reinforced
methods for mitigating the hazards of static electricity. Key points which were
emphasised included ensuring that potential hazards for a job were identified before
it commenced, and ensuring that all appropriate mitigations and safety systems
were in place including "Proper bonding AND grounding systems are in place and
are inspected and tested to ensure proper operation before starting worl( .

Technical Authorities

35. In order to ensure that our learning on such things as static and vacuum truck
operation remains up-to-date Chevron maintains a comprehensive centralised
repository of industry standards and regulatory requirements. As standards and
regulations change, they are promptly assessed to determine whether, and if so
how, our standards and procedures need to change. Chevron has also invested
significantly in reviewing industry incidents and building up a repository of

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information on those incidents and considering if there is anything from such

incidents for us to learn from and to implement in our own operations.

36. One outcome of this process has been the institution of a programme we call
"Technical Authority". A Technical Authority is a detailed standard for a potentially
high consequence activity which incorporates current regulatory requirements and
industry standards, as well as lessons learnt from other industry incidents.
Compliance with Technical Authorities is mandatory across all of Chevron's
Downstream and Chemicals operations, including at joint venture operations.

Vacuum Standard

37. The first Technical Authority Chevron issued related to vacuum truck operations (the
"Vacuum Standard"). This was developed following the review we undertook in
2011 of the vacuum truck procedures at each of our different sites, following which
we developed a new common standard. Historically each Chevron location which
used vacuum trucks had its own vacuum truck procedures. Now all operations
using vacuum trucks are required to implement this standard which incorporates the
American Petroleum Institute and other internationally recognised standards and
practices. It has been re-reviewed and updated several times. The current version
of the document is at pages 41 to 63.

38. The topics addressed in the Vacuum Standard include:

38.1 Equipment requirements, including truck design and safety kit requirements.

38.2 Training and contractor verifications; including requirements for employee

and contractor training.

38.3 Permit to Work requirements designed to make work safe to execute.

38.4 Essentials Checklists (which I discuss further below).

38.5 Set up requirements to prevent static build up; for example, how to hook up
hoses and ensure that bowsers and equipment are earthed correctly.

39. There is now a requirement to use an ohm meter to verify that hoses are conductive
(so that a static change does not build up) during vacuum truck operations on site.
Industry standards dictate that the maximum allowable resistance is 1000 ohms
where several hoses and fittings are connected; or 100 ohms for each individual
hose, and 10 ohms for each fitting. Conductivity is checked using the ohm meter
before the truck starts any new activity. Once the vacuuming activity has started,

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another device is used to monitor electrical continuity of the earthing. It shows a

green light if continuity is in place. If continuity is disrupted the light will turn red.
This tells the operator to shut down the truck and re-establish proper continuity.

Vacuum truck Subiect Matter Expert

40. The Vacuum Standard was developed with the assistance of Chevron's Vacuum
Truck Subject Matter Expert. This position was created after the Incident and the
individual who has taken on the role has over 30 years' refinery experience and was
previously responsible for vacuum truck operations at Chevron's Richmond
Refinery. His role is to promote safe vacuum truck use across all of our sites and
there are now vacuum truck specialists at each of those sites with whom the SME
works to achieve this. The site specialists are typically responsible for oversight and
management of the vacuum truck providers at their respective sites and have
received advanced subject matter training.

Hose testing

41. The Vacuum Standard introduces a number of checks to ensure that the hoses
which are used have proper bonding and integrity to make sure that they are
suitable. It is now a requirement that each hose used for vacuum truck operations is
verified annually by Chevron to ensure that it has proper bonding and mechanical
integrity. Every hose is identified individually and is listed in an inventory so that it
can be tracked. It is a requirement that:

41.1 Vacuum hoses must be constructed of conductive material or be thick-walled

hoses with imbedded conductive wiring. Liquid and vent hoses also must be
equipped with lockable connections.

41.2 All core fleet vacuum truck hoses must meet a conductivity requirement of
<100 ohms from end to end (coupling to coupling).

Human Factors in Vacuum Truck Safety

42. Chevron has also undertaken work to revise its existing procedures and integrate
Human Factor concepts into them. Accidents and incidents can be enabled, in part,
by human error. Human Factors is focussed upon trying to ascertain where human
error might creep in and to seek to eliminate it. Human Factors was taken into
account at Pembroke before the Incident, and after the Incident we have done a lot
of further work on Human Factors in relation to different aspects of our operations.

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We have employed Human Factors experts, including a full-time PhD. One output
of this work is the Essentials Checklist.

Vacuum Truck Essentials Checklist

43. With the assistance of a Human Factors expert, Chevron developed and
implemented a vacuum truck safety tool called an Essentials Checklist (a copy of
which is at pages 64 to 65).

44. The purpose behind the Essentials Checklist is to reduce the risk of human error
during vacuum truck operations. This is a simplified checklist which includes only
the essential safeguards to safe vacuum truck operation. The checklist has been
written in a simple straight-forward way with diagrams in order to limit the potential
for it to be misunderstood.

45. It is a requirement that each check on the Essentials Checklist must be completed
and independently verified by the permit issuer (a Chevron employee) as having
been completed immediately before works starts. The checks include ensuring that:

45.1 All safety equipment is present and in working order.

45.2 The type of material being moved is understood by the truck operator.

45.3 The truck has the correct venting in place.

45.4 Hose test verification is current.

45.5 Grounding connections from earth through the truck are correct.

45.6 The grounding continuity is being measured and this has been tested and
recorded.

46. This Checklist has been deployed across Chevron's Downstream operations and is
now being deployed in our Upstream operations as well. We have shared it with
other companies through industry associations and it is posted on the API
(American Petroleum lnstitute)/AFPM (American Fuels and Petrochemical
Manufacturers) website as part of their programme called Advancing Process
Safety.

47. Following the success of the Vacuum Truck Essentials Checklist, Chevron has
created other Human Factor designed Essentials Checklists for other activities
where human error could lead potentially to high consequences, including Confined
Space Entry and Opening Process Equipment.
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Updated vacuum truck and static hazard training for Chevron employees and contractors

48. A training module was developed for the Vacuum Standard. All refinery personnel
are required to complete the training (including contractors). Personnel with direct
vacuum truck responsibilities are required to take refresher training every two years.
The training focuses on potential hazards of vacuum truck operations (including the
generation of static electricity) and how those hazards can be mitigated (through, for
example, ensuring that vacuum trucks are bonded and grounded).

49. Chevron also updated its static training module to emphasise the risk of vacuum
truck static and static hazard prevention requirements. Relevant topics include why
static electricity is a concern, how it can be controlled, and how to set up and test
effective bonding and grounding systems. The training was made mandatory for all
employees working in hydrocarbon facilities and contractors providing vacuum truck
or other vessel loading services. Participants had to take a test at the end of the
training. During 2011-2012, over 6,000 employees and contractors received this
training and it has continued to be provided ever since. Refresher training is
compulsory every two years.

Management of contractors

50. Chevron has updated its procurement process for vacuum truck contractor service
providers. As part of the procurement process, we now specifically perform a service
provider audit conducted by a Chevron Subject Matter Expert. The audit tests the
bidders' knowledge of all relevant standards. We also examine:

50.1 What training is being provided to employees;

50.2 How they manage hose integrity;

50.3 How they manage waste management;

50.4 What equipment standards they apply; and

50.5 What safety equipment they have.

51. Those bidders Chevron contracts with as contractors are required to document the
training of their workforce. Chevron now defines the content of the training and our
Vacuum Truck Subject Matter expert checks that the contractor is delivering the
training. The training must include among other things the following topics:-

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51.1 Static generation - causes and minimisation practices in vacuum truck

transfers.

51.2 The effect of vacuuming on hydrocarbon flash point/volatility.

51.3 Why vacuum trucks should be bonded and grounded.

51.4 The use of an ohm and other meters for continuity testing.

51.5 Specific training for testing, hose connection and system continuity.

51.6 Safe vacuum truck loading, including static minimisation techniques.

51.7 Hazardous Materials Training.

Verification and Audits

52. A further responsibility of the Vacuum Truck Subject Matter Expert is to develop
guidance on how Chevron can verify that vacuum truck operations are occurring
safely at its refineries and that the Vacuum Standard is being complied with. The
Essentials Checklist is one way in which we do this. Other ways include:

52.1 An Updated Permit to Work process: Chevron has updated its Permit to
Work process so that now there is a better dissemination of information
between those involved in a task. I discuss this further below.

52.2 Loss Prevention Observation checklist: Chevron has a behavioural based

safety system known as the Loss Prevention System (LPS). LPS comprises
a collection of tools designed to be used by individuals on site to identify
factors that cause or could cause a loss or an incident. One of those tools is
Loss Prevention Observation (LPO), which involves observing an individual
completing an activity and assessing that person against an agreed standard
or method. The observer is typically a peer of or supervisor of the
individual(s) being observed or a Chevron safety specialist and requirements
are set as to the number of LPOs which have to be completed.

52.3 I have discussed above how a checklist was developed at Pembroke in the
aftermath of the Incident. That checklist has now been developed further and
is used as the standard against which vacuum truck operations are
assessed when undertaking LPOs. A copy of the checklist is at pages 66 to
71. It is longer than the Essentials Checklist because the observer is
assessing how the observee undertakes all aspects of the task, not just the
safe operation essentials (although these are also included in the LPO

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checklist). For example, the LPO checklist includes, amongst other things,
checking:

52.3.1 That the driver is aware of the permit conditions.

52.3.2 That the driver is aware of the constituents of the material to be

bowsered and has verified its hazards with the permit issuer.

52.3.3 That the hoses and cables are in good condition with no signs of
damage.

52.3.4 That the hose construction/type is appropriate for the material and
conditions.

52.3.5 That the vacuum truck is properly earthed and grounded, including
that proper hose bonding and hose connections are in place, and
that a "go/no go" measurement device is being used to measure
that the hose remains conductive.

52.3.6 That the bowser is safely vented, including that the truck's vent
hose extends 50 feet downwind or that there is a vent pipe 12 feet
above the top of the truck.

52.3. 7 That personnel undertaking the bowsering operation and the

bowser itself are equipped with the required safety equipment such
as a 4 element gas monitor, a spill kit and personal protective
equipment.

52.3.8 That the Essentials Checklist has been properly completed, signed
by the work crew and independently verified.

52.4 Additional field verifications: Field verifications of vacuum truck operations

are carried out each month at each site by refinery leadership and visiting
executives and home office staff against the Vacuum Standard. This is done
in order that senior individuals can see for themselves how vacuum truck
operations are being carried out in the field and how this compares to what is
in the Vacuum Standard and whether there are any learning points from
what has been observed.

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52.5 Additional Audit Team: Chevron has now established a team comprised of
individuals with deep specialist technical knowledge which undertakes audits
in addition to the audits I have already mentioned. The intention is to add a
further level of oversight. These individuals now perform very detailed audits
against our Technical Authorities, including the Vacuum Standard. A copy of
the form used by this team for the Vacuum Standard audit is at pages 72 to
88. The results of these assessments are shared across sites so that
learnings arising from one site are implemented globally.

Audits of Contractors

53. Chevron also carries out ongoing reviews and audits of its vacuum truck contractors.
These include regular on site "work in progress" reviews and performance safety
assessments. In particular, as I have mentioned above, we now have at each of our
sites vacuum truck specialists whose responsibilities include conducting audits of
vacuum truck operations taking place at their refinery. These site audits include
verification:

53.1 That all vacuum truck operators have received and passed the Vacuum
Standard training.

53.2 That company and industry standards are being adhered to.

53.3 That personal and truck safety equipment is being used.

53.4 That bonding cables are in good condition.

53.5 That hoses being used have been tagged and are certified.

53.6 That the vacuum truck is earthed.

53.7 That safe venting is being practised.

53.8 That the composition of the liquid being bowsered has been verified.

53.9 That the Essentials Checklist has been completed.

54. At least annually, each contractor is also assessed at each site to revalidate their
continuing service based on their knowledge and the effectiveness of the systems
they have in place. At any time during the year, contractors with poor performance
results will be required to immediately improve or be suspended or have their
contract terminated. The site subject matter specialists I have discussed participate

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in these assessments and there is an emphasis on their being rigorous with

contractors as to the standards of performance expected from them.

Tank Design, Operation and Maintenance

Tank Turnaround Team

55. Almost all tanks at Chevron refineries are in the Blending and Shipping part of the
refinery. The individuals who work in Blending and Shipping are highly experienced
in taking tanks out of service and conducting tank maintenance. The ARU tanks
involved in the Incident were not part of Blending and Shipping and tanks in the
ARU were and are rarely taken out of service. To ensure that we have the
necessary expertise available when taking a tank out of service we have now
embedded a process to ensure that whenever a tank is taken out of service, no
matter where it is on a refinery, it is planned and overseen by individuals from
Blending and Shipping who have deep specialist knowledge and experience in
taking tanks out of service.

56. To this end, we have established within each of our refineries a Tank Turnaround
(cleaning and repair) Team. Each Tank Turnaround Team includes experienced
Blending and Shipping operations and maintenance personnel. Contractors also
form part of this Team.

57. The Tank Turnaround Team typically includes the following personnel:

57.1 Tank Programme Coordinator.

57.2 Operations Representative.

57.3 Maintenance team leaders.

57.4 Maintenance planners.

57.5 Design engineering representatives.

57.6 Process engineers (as needed).

57.7 Safety representatives.

57.8 Equipment integrity representatives.

57.9 Contract services representatives.

58. The Tank Turnaround Team is now responsible for the safe completion of a tank
turnaround from start to finish. The Team defines the scope of the turnaround,
identifying any unique considerations for the tank. This now comprises, for example:

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58.1 Identification of hazards, this includes a specific requirement to identify

whether a tank might contain pyrophoric material. Samples are taken and
analysed to establish whether or not such material is present.

58.2 Identifying the tank design, and specifically whether it contains a syphon
type drain.

58.3 Reviewing the history of previous clean-up procedures on the tank to help
identify any problems encountered in the past.

59. Once all this information has been assembled by the Team. the required permits
identifying safeguards are developed and signed off by all involved including all
contractors.

Permit to Work

60. Permit to Work is a process to define and control the safe execution of maintenance
work in an operating unit. We have updated the process to seek to ensure that
there is better communication between those carrying out an activity.

61. One of the purposes of a permit is to ensure that relevant information in respect of a
job has been communicated between operations (in whose area the work is to be
undertaken) and maintenance (the people undertaking the work). To mitigate the
risk for human error in communicating information relevant to a permit, we have
included, in the computer system used to build permits, hold points (prompts) which
are designed to force face to face communication within the Turnaround Team to
ensure alignment of views and the exchange of information. These include:

61.1 Contractors must meet with planners to agree the method of work.

61.2 There must be a pre-start briefing at the site to confirm that it is safe to start
work. This might include, for example, what gas tests have been done to
test for a flammable atmosphere and what tests have been done to identify
hazardous materials.

61.3 Work can only start if the work crew have signed off to state that such
matters have been considered.

61.4 For potentially high consequence work (including vacuum truck operations).
the Essentials Checklist has to have been completed verifying that critical
safeguards are in place. Each of the checks on the checklist has to be

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signed off by the work crew and, in addition, an independent Chevron

verifier.

Tank Cleaning and Repair Subiect Matter Expert

62. Chevron has created a full-time tank turnaround (cleaning and repair) Subject Matter
Expert position. The person who holds this position has 25 years' experience with
Chevron.

63. This person is available to provide additional assistance to the Tank Turnaround
Teams at each of our refineries. His responsibilities include:

63.1 Improving tank cleaning/maintenance practices and procedures including

introducing new cleaning/repair technologies.

63.2 Maintaining Chevron-specific standards for tank cleaning/maintenance.

63.3 Participating in the development of industry standards on tank maintenance.

For example, Chevron participated in the recent UK Energy Institute update
of their tank cleaning standard.

63.4 Sharing industry lessons learnt with refineries.

Blending and Shipping Subiect Matter Expert

64. Chevron has also created a full time Blending and Shipping Subject Matter Expert
position. The person who holds this position has 21 years' experience with Chevron.
The responsibilities of this role include:

64.1 Leading refinery representatives in the development and deployment of tank

design and operations standards, lessons learnt and best practices.

64.2 Leading the training of Chevron and contractor personnel in proper tank
management.

64.3 Engaging with outside standards-setting organisations.

64.4 Responding to requests for assistance from any of Chevron's global

operations, including non-operated joint ventures.

64.5 Carrying out audits to check that the above things are being done.

Tank Cleaning Standard

65. In the past, Chevron's refineries had local tank cleaning and repair procedures.
Following the Incident, we implemented a standardised Tank Cleaning Standard for

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all our refineries (a copy of which is at pages 89 to 140). It is mandatory that this
Standard is followed across all of our refineries. It describes the precautions and
steps necessary to safely enter and clean atmospheric storage tanks and
incorporates industry guidance including the API and UK Energy Institute
requirements.

66. As I have mentioned, Chevron participated in the most recent update of the Energy
lnstitute's Model Code of Safe Practice Part 16: Tank Cleaning Safety Code, which,
in turn, helped to inform the development of the Tank Cleaning Standard.

67. The Standard is used in conjunction with our standard for safely entering equipment
such as tanks, "MFG 140 Confined Space Entry" and references several other
standards. The topics addressed in the Tank Cleaning Standard include:

67 .1 A description of the hazards associated with cleaning and entering tanks

including fire and explosion, as well as toxic vapours and oxygen deficiency.

67.2 Job planning, including contractor selection, defining the scope of work for
the task to be undertaken, and work permit requirements.

67 .3 Tank isolation requirements and the dangers of static discharge.

67.4 Identifying ignition sources and how to mitigate them.

67 .5 Tank cleaning.

67 .6 Returning a tank to service.

Assessing Hazards in Tank Vapour Spaces

68. The Incident involved the accumulation of light hydrocarbons in the ARU tank. After
the Incident Chevron issued an advisory: "Assessing Hazards in Tank Vapour
Spaces". This advisory set out how tanks can become hazardous when
hydrocarbons build up. Chevron also launched a rigorous assessment of all tanks
on our sites to identify which were vulnerable to this occurrence to check that they
were known about and that mitigations were in place.

Tank Change Checklist

69. One lesson learnt from Pembroke was that we needed to improve awareness of
how process changes can affect tanks, including the contents of tanks. To that end,
a Tank Change Checklist was developed to augment our existing Management of

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Change processes. This new checklist identifies tank-specific issues for employees
to consider when changes are made to processes or equipment. These include:

69.1 Is the tank design suitable for the changed conditions?

69.2 Is the tank capable of withstanding operating upsets and emergencies?

69.3 Do procedures and information systems need to be updated to take account

of the changed conditions and do assessments such as the Vapour Space
LEL assessment for the tank need to be updated?

Tank Process Hazards Analysis: LOPA Template

70. Process Hazard Analysis (PHA) is a systematic assessment of potential hazards

associated with an industrial process. A PHA provides a mechanism for reviewing
processing facilities to confirm that appropriate safeguards are in place and are
effective in reducing risks.

71. Chevron strengthened its tank risk management processes by requiring that the
Tank Change Checklist (described above) is utilised by employees undertaking
PHAs. In addition, a further tank-specific checklist has been developed also to be
used as part of PHAs. It has been developed in accordance with LOPA (Layer of
Protection Analysis) which is intended to complement PHAs and provide further
rigour to the analysis. A copy of the LOPA checklist is at page 141. The PHA/LOPA
template identifies potential hazards and their consequences and suggests possible
steps to mitigate the risks. Potential hazards highlighted on the checklist include:
"High LEL in tank vapor space (cone roof and internal floating roof tanks)" and
"Ingress of incompatible material (e.g. water or light product into hot tank, high vapor
pressure stock into cone roof tank, hot product into high RVP tank, etc.)".

Training
72. In addition to the specific training I have described above, Chevron has also
implemented changes to how our operators and process engineers are trained:

Operators

72.1 Chevron operators are trained through a mixture of classroom learning and
field experience and can only qualify if they have demonstrated, via
assessments, that they understand the unit on which they wish to qualify
including the unit processes and flows and equipment on that unit. Since the
Incident we have re-emphasised the importance of operators knowing in

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detail the piping and routing in their area of responsibility and for an operator
to qualify we have introduced a specific requirement they first must be able
to describe the purpose for and find and follow-out every piping system in
their area of responsibility.

Process Engineer training

72.2 Process engineers are required to do a job handover when they move to a
new position. Checklists were developed post-Incident to facilitate this
process which identify items and provide guidance on how to complete a
successful job handover. One purpose of this is to facilitate the transfer of
unit-specific knowledge from the outgoing to incoming engineer.

Human Factors

73. Chevron has also focused on human factors. Our Environmental, Health and Safety
organisation has been expanded to include safety risks arising from human factors
and construction contractor safety. The intention is to reduce human error. We
have human factors engineers working closely with all refineries in order to integrate
human factors/performance into the existing processes, using common human
factor tools such as critical task analysis, human error analysis and user testing. For
example, Chevron is editing all of its procedures with the help of a computer
software programme called "Smart-Procedures" which finds error-potential language
such as ambiguous wording or task descriptions which are too complicated. In
addition, to reduce errors in task execution, Chevron is reviewing its procedures to
seek to limit the number of steps required for any task and to add pictures for
additional clarity. We have supplemented the work being done by our Human
Factor experts by training 6,000 employees worldwide in Human Factors thinking to
seek to ensure that it is deeply embedded across Chevron.

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STATEMENT OF TRUTH

I believe that the facts stated in this witness statement are true

Signed I

Dated 10 April 2019

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