The refining trade faces rising demand for gasoline whereas contending with aging services. Some date to the early twentieth century, and no major refinery has been constructed since 1976. Despite obvious put on and tear, the factories are being pushed to their limits. Critics say this compels some companies, already working on a razor-skinny profit margin, to interact in a excessive-stakes guessing sport: How long can a pump or part of pipe keep in service before it disintegrates? Is it better to keep tools operating, or shut down a complete system for preventive maintenance? Sometimes refinery managers guess mistaken.

methanol installation

“All the models are working at greater capacity, increased strain, higher throughput,” said Russ Elveston, a forensic engineer and safety marketing consultant who retired from OSHA’s Houston workplace in 2007. “Hazards have elevated just because the items working now produce more than they did 15 or 20 years in the past. When there’s a release, the results are typically a bit extra vital.”

With executives pushing for extra manufacturing, meanwhile, workers might be “afraid to really report what’s wrong,” mentioned Bob Cavnar, a longtime supervisor in the oil and fuel business. Consequence? “Years and years of deferred maintenance.”

Inside BP documents show that in the years main as much as a 2005 explosion at the company’s refinery in Texas Metropolis, Texas, which killed 15 employees, managers close to the scene agonized over safety practices on the refinery — however the message both didn’t reach or didn’t register with headquarters in London. “We have now never seen a site the place the notion ‘I might die immediately’ was so actual for so very many hourly individuals,” reads a BP summary of interviews with Texas City employees three months earlier than the blast. A business plan circulated eight days earlier than the disaster famous “key dangers” for 2005 — including “security not being viewed as the #1 priority” and the prospect that the refinery “kills somebody in the next 12-18 month[s].” (BP lately announced plans to promote the refinery, together with one in California, maybe by 2013.)

Security guidelines are on the books, however enforcement, if it occurs in any respect, steadily results in a standoff: A federal or state company inspects a refinery, finds violations, points citations … and waits. Oil firms routinely challenge even the most minor allegations, aware that any admission of fault may haunt them if they were sued or prosecuted following an accident. When a refiner appeals, 609 days cross, on common, earlier than the case is closed — a time-frame virtually 20 p.c longer than the average for all industries, a Middle evaluation of a decade of enforcement knowledge shows.

Even in incidents where individuals died and regulators cited firms for willful violations — defined by OSHA as people who contain either an intentional flouting of the law or “plain indifference” to it — corporations nearly always assert that the tragedies have been unforeseeable. Generally, the enforcers merely give up: Nearly a quarter of all fines proposed towards refiners from January 2000 through June 2010 had been erased from the books, a dismissal fee 2 1/2 instances that of U.S. industry as an entire, the middle discovered.

Michael Silverstein, who heads the Washington State Division of Labor & Industries’ Division of Occupational Security and Health and is a former federal OSHA coverage director, stated the regulatory scheme at both the state and federal ranges is flawed. “Right now, it’s a catch-me-if-you-can system, and the consequences of being caught are comparatively small.”

After its inspection of the Tesoro refinery in October 2008 — 18 months earlier than the fireplace that killed Matt Gumbel and his co-workers — Silverstein’s agency reduced an already-modest $85,seven-hundred fine to $12,250, and withdrew 14 of 17 alleged violations. He was, in effect, bargaining. His intention? To influence the company to drop its enchantment and fix problems that would result in a catastrophic accident.

Silverstein mentioned he chose results over a drawn-out quest for an even bigger penalty. “As lengthy as the case was in enchantment, Tesoro had no legal obligation to correct the problems cited,” he mentioned. The department insisted on an impartial security audit as part of the settlement.

The April 2 disaster in Anacortes introduced far higher potential penalties for Tesoro — and expectations that they, too, might be whittled down. The corporate faces a advantageous of almost $2.4 million for forty four alleged violations, 39 of that are categorised as willful. The state agency alleged that Tesoro “disregarded a number of workplace safety laws, continued to function failing tools for years, postponed maintenance [and] inadequately tested for doubtlessly catastrophic harm.”

Once once more, the corporate is interesting.

“We disagree with L&I’s [Labor & Industries’] characterization of Tesoro’s operations at Anacortes and believe — based on available proof and scientific reviews — that many of the company’s conclusions are deeply flawed,” the corporate said in a written assertion to the center. “We continue to cooperate with L&I and different investigative bodies and stay up for clarifying the facts as the process unfolds.”

Silverstein stated the issues discovered at Tesoro are removed from unique. “We as a nation should not have a great grip on this business,” he mentioned. “It can be one factor if these had been just paper violations – refineries were being somewhat bit sloppy at preserving records – but there’s been an unending collection of catastrophic explosions, fires, chemical releases and close to-misses.”

The muddled regulatory system Silverstein laments did not evolve by probability. Fortified by enormous reserves of cash, the oil and gas trade usually gets its means. A notable exception last fall: Its failure to kill a California legislation requiring reductions in greenhouse gases.

In 2010 alone, the industry reported spending more than $146 million to lobby the federal government. Through the 2009-2010 election cycle, it donated $25 million to federal campaigns — mostly Republican, knowledge compiled by the center for Responsive Politics show. The American Petroleum Institute reported spending $6.75 million on federal lobbying final 12 months, the refiners’ association $2.76 million. Oil and fuel pursuits spent another $forty one.5 million on marketing campaign contributions in the states, which additionally oversee refineries and different oil company actions, in the course of the 2009-2010 election cycle, according to the Nationwide Institute on Money in State Politics.

Through the years, the industry has fended off quite a lot of rules and reforms. In 2010, it had a hand in killing federal legislation that may have elevated the size of civil penalties OSHA may impose, made it simpler for the company to build criminal circumstances and pressured employers to correct hazards while contesting citations. The U.S. Chamber of Commerce — to which oil corporations have contributed generously — led the charge in opposition to the invoice.

Now, leveraging the anti-regulatory temper in Washington, the industry is attacking a number of guidelines it must comply with, most of which contain climate change however a few of which contain well being and safety. In a nine-web page letter to Darrell Issa, the new Republican chairman of the House Committee on Oversight and Authorities Reform, on January 10, Drevna, of the refiners’ association, complained a few “great onslaught of regulatory exercise.”

“If left unchecked,” Drevna warned Issa, this onslaught could “threaten the continuation of a substantial portion of domestic refining and petrochemical production and well-paying current American jobs, and the security of the nation.”

FATAL LAPSE IN ANACORTES

At a refinery, a heat exchanger transfers heat from one liquid to another without allowing them to combine, conserving vitality that otherwise can be wasted. The exchanger that blew apart in Anacortes, known as Unit E, was put into service in 1972, 4 years earlier than Matt Gumbel was born. Based on the Washington Department of Labor & Industries, Tesoro last examined welds on the system — using a sophisticated technique that would detect cracks — in 1998. This was the one time within the exchanger’s 38-yr life that such an inspection had taken place, the department said; moreover, it discovered, Tesoro had examined fewer than 20 p.c of the welds and targeted on areas least vulnerable to break. Firm records point out that a deliberate 2008 inspection by Tesoro by no means passed off, the division stated.

In its statement to the middle, Tesoro mentioned the heat exchanger that failed “was inspected frequently and was totally compliant with rules and trade requirements. The exchanger underwent exterior inspections as soon as each two years and inner inspections in 1998 and again in 2005 . . .” State officials, nevertheless, say there isn’t a proof that the 2005 inspection was of the type that may have enabled the corporate to find cracks within the welds.

In its formal appeal of the state quotation, the company denied that it had violated safety guidelines and stated it might elevate any number of defenses, together with “unanticipated worker misconduct.”

A lawsuit filed in opposition to Tesoro on February 9 by families of six of the lifeless employees claims that the corporate pushed its heat exchangers too arduous, for too long, scrimping on inspections and ignoring signs of trouble. Among different issues, the lawsuit alleges that in 2001, an exchanger just like Unit E “failed catastrophically because of thermal fatigue and crack propagation,” however that Tesoro “willfully disregarded” a company recommendation to examine other exchangers for the same sorts of flaws.

“The plaintiffs’ allegations are incorrect,” countered Tesoro in its statement. The 2001 incident had completely different causes, the company mentioned. Cracks “had formed by way of a degradation mechanism completely totally different from that involved in the April 2, 2010, incident.”

The company declined in its assertion to say whether or not the accident was preventable, as regulators asserted, as an alternative stressing that it “deeply regrets the immeasurable impacts” the tragedy has had on workers’ families. Security is “job number one” at Tesoro, the company added, “and we try for steady enchancment in security efficiency.”

When the welds on Unit E popped, Matt Gumbel and his co-employees had been tending to the leak-prone exchangers being brought online after a maintenance shutdown. His father — who was working in the catalytic cracking unit, additionally known because the cat cracker — heard the explosion and felt the concussion.

Paul Gumbel remembers operating toward the naphtha hydrotreater unit, the place he knew Matt had been working. “One in every of the primary folks I noticed inside the unit was obviously deceased,” Paul recalled. “It was a man … unrecognizable.” A girl was burned so badly “I used to be afraid to contact her.” As he tried to comfort her, he noticed one other girl in dangerous shape, after which a second man — with flames on him. “We obtained him out,” Paul said. “Then I grabbed a fireplace hose and tried to knock the flames down.”

He stayed on the hose for 20 minutes, still not figuring out his son’s whereabouts. “I had a feeling he was there [within the hydrotreater unit],” Paul mentioned, “however no person could answer my questions. They made me leave and go sit by a cellphone.” About 10 minutes later, the telephone rang. Matt, the caller said, had by some means gotten out of the unit and was already on his option to Skagit Valley Hospital in Mount Vernon, Washington. By the time his dad and mom and his 32-12 months-previous sister, Amy, arrived on the hospital, Matt was being prepped for a helicopter experience to a Seattle trauma middle. He by no means regained consciousness and died there on April 24.

When Paul went again to work at Tesoro in June, he felt indignant and couldn’t focus. He lasted five days. “I had a humongous feeling of dread about even going via the gate,” he stated. He began seeing a psychiatrist and was diagnosed with put up-traumatic stress disorder, a product of his horrific expertise. After taking medical depart, he returned to the refinery in October as an operator.

Then, one other setback: A boiler backfired. It was nothing, really — and the whole lot. Paul now works within the Tesoro garage, a less tense surroundings than the cat cracker unit.

Classes UNLEARNED

Preventable tragedies keep occurring at refineries, regardless of abundant data on the right way to make them safer.

Many expected a 1989 explosion in Texas to convey about a sea change. That blast, so highly effective it measured three.5 on the Richter scale, started when a vapor cloud ignited at Phillips sixty six Company’s Houston Chemical Complicated. The explosion — which killed 23 workers and injured 132 — got here not quite 5 years after a chemical leak at a Union Carbide pesticide plant in Bhopal, India, had killed thousands.

The Phillips blast prompted a key reform: OSHA’s adoption in 1992 of a rule requiring excessive-hazard industries akin to oil refining and chemical manufacturing to identify dangers and deal with them before an accident might kill, maim or unleash toxic chemicals into neighborhoods. Beneath the so-referred to as process safety management customary, ultimately copied by many states, corporations should have in place a system of inspections, maintenance and emergency procedures to stop catastrophic fires, explosions and chemical releases. Publicly, affected industries were supportive — for good cause, it seemed. “[W]e consider that the advantages of this system justify the investment of assets,” BP America wrote to OSHA in April 1991, noting that “the price of a single incident can total tens of millions of dollars in restore prices and lost manufacturing capability, not to mention the potential affect on human life.”

While some main accidents might have been averted, the effect of the 1992 rule has been limited. As an example, it apparently didn’t dissuade BP from cutting corners and overlooking lessons of the previous at its Texas Metropolis refinery, acquired from Amoco in 1998. On March 23, 2005, an old, poorly designed relief system on the refinery was overfilled with flammable hydrocarbon liquids and vapors, which poured out and ignited, inflicting a series of explosions and fires. Fifteen employees died and 180 were hurt.

Indicators of trouble at the refinery had been plentiful but evidently ignored. In its investigation, the Chemical Safety Board found that the relief system had overflowed eight occasions between 1994 and 2004, properly before the explosion. Not one of the eight incidents, the board found, had been correctly investigated or acted upon.

After fining BP $21 million for the catastrophe, OSHA returned to the Texas Metropolis refinery in 2009 and discovered that the corporate had broken its promise to fix a whole bunch of hazards. Finding fresh cause for concern, the company additionally cited BP for a whole bunch of latest violations. Last August, BP agreed to pay $50.6 million for the 270 “failure to abate” violations and spend at the very least $500 million to improve the refinery. However the corporate is contesting a $31 million high-quality proposed by OSHA for the brand new violations. Four workers have died on the refinery since 2005, and the corporate has paid $sixty five million to settle criminal and civil Clear Air Act instances introduced towards it by the U.S. Department of Justice on account of the 2005 blast.

In a written statement, BP stated it had “systematically refurbished and inspected major process items” in Texas City and changed the antiquated relief system for the reason that accident. A “new tradition of openness” exists inside its workforce, the corporate stated.

MISSED WARNING Signs

The issues aren’t limited to large refiners like BP-Texas City, which processes 437,000 barrels of crude oil per day. In February 2008, OSHA inspected a fifty eight,000-barrel-per-day refinery in Tyler, Texas, operated by Delek U.S. Holdings Inc. The company cited Delek for 16 violations and fined the corporate $sixty eight,250; Delek contested all 16. Two months later, three Delek staff were taken to the hospital after being burned by oil that spewed from a sewer drain. OSHA cited the corporate for 2 extra violations and proposed an additional $6,300 in fines. Delek contested.

On November 20, 2008, a pipe ruptured and an explosion tore by means of two of the refinery’s management rooms, killing one worker and injuring 4, one among whom died 13 days later. In Might 2009, OSHA cited Delek for 30 violations — together with a willful violation for operating the failed pipe greater than 5 years past the retirement date set by the corporate — and proposed $217,350 in fines. Again, Delek contested.

In a deposition taken in February 2010 in connection with private injury lawsuits filed towards Delek, refinery manager Frank Simmons stated an investigation by the corporate revealed that the accident was brought on by a “localized point of very high corrosion” on the 31-yr-outdated pipe, which carried naphtha and liquefied petroleum gasoline. “I actually consider [it] was unforeseeable for us,” Simmons testified. He acknowledged beneath questioning, however, that parts of the pipe that failed had been under structural minimums established by the American Petroleum Institute. A spokesman for the company declined to remark.

All through the trade, warning signs proceed to be missed or disregarded.

On March 2, 2010, a month earlier than the Tesoro accident in Anacortes, four contract staff have been caught in a storage tank blast at the 105,000-barrel-per-day Navajo refinery in Artesia, N.M. Two of the men died and two have been injured. In the 15 months main as much as the accident, firm officials had reported 22 fires to the new Mexico Occupational Health and Safety Bureau. Eight of these fires occurred in January 2010 alone.

In a deposition last November, the refinery’s former health and safety manager, William Jones, said that Navajo mustn’t have allowed the staff to weld on the tank without Navajo’s first testing it for flammable vapors.

“Would you agree that the definition of gross negligence has been met in this case, based on what Navajo didn’t do?” one of the victims’ legal professionals requested during the session.

“Sure,” Jones replied.

Final August, New Mexico regulators hit Navajo with a $707,000 positive. The corporate is appealing.

A spokesman for Navajo’s father or mother, the Holly Corp., declined to remark due to pending lawsuits.

Sometimes, it is blind luck that nobody is killed when a unit catches fireplace or blows up. The Silver Eagle refinery in Woods Cross, Utah, for example, had two major accidents 10 months apart in 2009. In January, a vapor cloud from a storage tank filled with naphtha ignited, burning 4 staff in a flash fire. In November, a ten-inch hydrogen pipe burst, producing a a hundred-foot-high fireball and a concussion that broken greater than 100 homes, certainly one of which was knocked off its foundation. Commuter rail strains pass near the refinery.

“Thankfully,” Chemical Safety Board investigator Don Holmstrom stated shortly after the accident, “there was no practice present during the blast.”

‘RUN TO FAILURE’

Drevna, president of the Nationwide Petrochemical & Refiners Affiliation, acknowledged the string of current accidents in the refining trade. “Have there been incidents? Completely,” he said. “Do we need to correct these? Do we want to prevent those? Completely.” He insisted, nonetheless, that these episodes do not sign a pattern and that the trade “would not take economics into consideration” when making decisions that would affect safety.

Workers interviewed by the center disagree. They describe a climate during which safety takes a again seat to ramped-up manufacturing. Fairly than schedule prime-to-bottom maintenance outages, which take units out of operation for extended intervals, equipment is being pushed onerous, sometimes beyond its design life, the workers say. They have a time period for it: “Run to failure.”

“They’re managing their shareholders’ investments,” Dave Campbell, secretary-treasurer of United Steelworkers Native 675, which represents staff at 5 refineries within the Los Angeles space, said of the oil firms. “The price we pay is with our lives and our health.”

As an illustration, Campbell mentioned, rising use of heavier, increased-sulfur crude has heightened dangers in coker units, usually the final cease in refining. Residual supplies often known as bottoms are extracted from crude in drums as much as ninety ft excessive. To keep up production, refiners are filling, cooling and emptying the drums more usually than they used to, Campbell mentioned. This places more stress on the metal, and might result in cracking.

In 2003, OSHA and the U.S. Environmental Safety Company issued an alert on the hazards of a follow in coker units that requires the usage of excessive temperatures for long periods to improve low-quality crude. The companies warned that such operations had resulted in numerous severe accidents, especially during procedures equivalent to drum head removal.

In April 2009, as workers removed a drum head on the ExxonMobil refinery in Torrance, California, scalding water sprayed a forty nine-12 months-old operator named Nelson Tan. He survived 18 days before succumbing to second- and third-degree burns that coated 85 % of his physique. It was just the form of scenario OSHA and the EPA had warned about in 2003.

After contesting three citations issued by the California Division of Occupational Security & Health, ExxonMobil, which made a revenue of $19 billion in 2009, paid a $24,200 nice for violations linked with Tan’s death.

In a press release, ExxonMobil stated it “deeply regrets” the incident. “Security is our first priority, and the loss of life at our facility will not be acceptable, below any circumstances. We fully cooperated with the Cal-OSHA investigation. We are dedicated to making certain the well being and security of all the employees at all our amenities.”

Misleading NUMBERS

The refining trade has a greater harm and illness charge than private trade as a whole. In 2009, the rate for refineries was one case per a hundred full-time workers; the rate for all industries was 3.6 circumstances per one hundred. The charges were 2.9 for textile mills, 4.1 for coal mines and 7.Eight for motorcar manufacturing plants. “The oil and pure fuel business is changing into an more and more safer place to work, despite a job setting that usually involves heavy tools, hazardous materials, high temperatures and excessive stress tools,” the American Petroleum Institute mentioned in a written statement. Officials on the institute didn’t respond to repeated interview requests from the middle.

However low harm charges, for damaged legs or wrenched backs, say little about systemic mechanical problems, similar to leaking valves or corroded pipes, which might lead to fires and explosions. For instance, the injury price at BP’s Texas Metropolis refinery in 2004, the 12 months earlier than the deadly blast, was about one-third that of your entire refining sector. “I cannot say too strongly to industry leaders: Cease boasting about your safety records when you are literally placing out fires,” Jordan Barab, a U.S. deputy assistant labor secretary, mentioned at a May 2010 security convention sponsored by the National Petrochemical & Refiners Association. “You’re only undermining your credibility. … Boasting about the nice safety record of [the] refinery industry whereas widows and kids are planning funerals doesn’t make you sound like a critical organization. And giving awards to your members primarily based solely on a lack of slips, journeys and falls does not make you sound like a serious group.”

Even restricted to accidents and deaths, refiners’ safety records are misleading. They don’t include knowledge on thousands of contract staff, who typically carry out probably the most hazardous jobs. All 15 staff killed in the BP-Texas Metropolis accident, for example, had been employed by contractors; the deaths, therefore, aren’t attributed to BP in OSHA information. In all, the middle identified 44 deaths at refineries throughout the previous decade. Nearly three-quarters of those killed — 32 — had been contract workers.

Regardless of a particular inspection program launched by OSHA in 2007 — and mirrored by most states that have their very own security packages — problems proceed to occur at refineries with beautiful regularity. A Heart analysis found that 24 of the 58 refineries examined by federal officials as of November 2010 had fires or explosions after the inspections had been opened. On average, OSHA has issued 17 citations and proposed $166,000 in fines per refinery. Given the dimensions and complexity of those operations, nevertheless, inspectors can comb only a fraction of every refinery. Nor does OSHA have many qualified personnel who can give the duty their undivided attention. Solely seven of 320 OSHA inspectors trained in the nuances of process security management are devoted to it full time, and they are only in a single location: Houston. In addition, OSHA’s targeted inspection program is to end this year, although officials say they plan to take care of a presence in refineries.

Those who argue for stronger enforcement point to applications in Britain, which requires assiduous planning by firms and thorough opinions by regulators before oil and fuel activities start, and California, which maintains a gentle presence at refineries fairly than merely dropping in, inspecting and writing citations.

‘HE WASN’T FRIGHTENED’

Shauna Gumbel tells a narrative about her son, Matt, when he was a toddler. As the two of them ran pre-Christmas errands and encountered a succession of Santa Clauses in their hometown of Oak Harbor, Washington, Matt noticed minor differences: One wore glasses, another gloves, and so forth. “Santa can’t be everywhere,” his flustered mother improvised. “He has to have helpers.” Matt was skeptical.

“He at all times seen little issues,” she recalled. “He was by no means afraid to ask questions.”

Matt’s curiosity and a focus to detail served him nicely when he turned an operator on the Tesoro refinery within the fall of 2007. His father, Paul, who had labored there for six years, had encouraged Matt to use. It was a job that performed to Matt’s strengths. At a refinery — a place of incessant noise and action — the one who notices subtleties can make a giant distinction. An acrid odor, as an example, can sign the presence of a lethal gas. “You want to concentrate to every thing you’re doing and everything that’s happening around you,” Paul said. “You never know what can go wrong.”

Nonetheless, Matt appreciated the work. “He wasn’t frightened,” his father stated.

Outside the refinery, Matt was a threat-taker. He cherished snowboarding — “not at all times in locations he should have been,” his mom mentioned — and driving his turbocharged 2008 Mazdaspeed3. Neither loud nor timid, “he was a thinker,” Shauna said. He was happy with the blue hardhat he earned in 2009, proof that he’d completed his Tesoro coaching. He and Paul would discuss at length about work; Shauna would eavesdrop, not understanding the terminology but pleased to see the bond strengthening between father and son.

The night time of the accident, as Paul battled the fire within the naphtha hydrotreater unit and waited for word about Matt, Shauna had the telephone ringer off while she slept at residence. At about 2:15 a.m., her daughter, Amy, woke her. “There’s been an accident at the refinery,” Amy stated. “Matt’s been hurt. Dad’s Okay.” Shauna insisted on driving to Skagit Valley Hospital, to give her one thing else to focus on.

Matt was in the emergency room, awaiting transport by helicopter to Harborview Medical Heart in Seattle, 60 miles to the south. Paul, Shauna and Amy took off for Seattle by automotive, arriving around four:45 a.m. There, for the following 22 days, the household’s hopes rose and fell, as famous in Shauna’s online journal:

Matty is so sturdy … he will pull by means of this soon. (April 4)

Matt came by way of surgery effectively. They eliminated all of the burned skin from his legs from above his ankles up to his thighs. (April 6)

Matt is out of surgery and they’re happy with how he did. (April 9)

He had his eyes open a bit bit (April 14)

Matt had a rough night. (April 17)

Surgery went properly. … [But] after Matt was introduced up to his room they couldn’t get his important indicators stable. He’s now going again downstairs in emergency exploratory surgery to attempt to discover out what’s going on. (April 23)

They didn’t really know what caused the multiple organ failure and the swelling. … Matt fought a superb battle and I believe his body was telling us that it was drained and he didn’t have the struggle left in him. (April 24)

On May eight, about 500 folks, including many Tesoro staff, turned out for Matt’s memorial service at Oak Harbor High school. His sister and one among his closest mates scattered some of Matt’s ashes at his favorite place, a state park overlooking the water and the Olympic Mountains in the space. The remainder of the ashes are in an urn at Paul and Shauna Gumbel’s residence.

5 days after the memorial service, Tesoro invited the household to the scene of the accident. They seen the two heat exchanger banks, still mangled. A company official explained how Matt had walked away from the raging fire. “It was overwhelming to me just to see what it seemed like,” Shauna stated. “It was horrifying and mind-boggling.”

Tesoro, in the meantime, appears to have rebounded from final April’s calamity. After a slight dip in the months immediately after the accident, the company’s stock worth is nearly double what it was a year in the past. In a December presentation, CEO Greg Goff assured Wall Road analysts that the refinery in Anacortes had been safely restarted and that “insurance recoveries [were] underway.” Markets for Tesoro’s merchandise had been enhancing, Goff noticed. “Our strategic priorities are clear, our plan is targeted and the group is aligned,” state materials from the presentation. “We are committed to driving shareholder value.”

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