Regulatory Flaws, Repeated Violations Put Oil Refinery Employees In danger

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The refining industry faces rising demand for gasoline while contending with aging services. Some date to the early twentieth century, and no major refinery has been constructed since 1976. Regardless of obvious put on and tear, the factories are being pushed to their limits. Critics say this compels some corporations, already operating on a razor-thin profit margin, to have interaction in a excessive-stakes guessing sport: How lengthy can a pump or section of pipe keep in service earlier than it disintegrates? Is it higher to keep gear running, or shut down a complete system for preventive maintenance? Sometimes refinery managers guess improper.

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“All the models are working at greater capacity, greater pressure, increased throughput,” said Russ Elveston, a forensic engineer and security marketing consultant who retired from OSHA’s Houston workplace in 2007. “Hazards have elevated simply because the items operating now produce greater than they did 15 or 20 years in the past. When there’s a release, the outcomes are typically just a little more significant.”

With executives pushing for more production, meanwhile, staff can be “afraid to essentially report what’s wrong,” said Bob Cavnar, a longtime manager within the oil and gasoline industry. Result? “Years and years of deferred maintenance.”

Inner BP documents present that within the years main up to 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 at the refinery — however the message either did not attain or did not register with headquarters in London. “We have now never seen a site the place the notion ‘I may die in the present day’ was so real for thus very many hourly folks,” reads a BP abstract of interviews with Texas Metropolis employees three months earlier than the blast. A business plan circulated eight days before the catastrophe noted “key dangers” for 2005 — including “safety not being considered because the #1 priority” and the prospect that the refinery “kills somebody in the following 12-18 month[s].” (BP recently announced plans to sell the refinery, together with one in California, perhaps by 2013.)

Security guidelines are on the books, however enforcement, if it occurs at all, regularly leads to a standoff: A federal or state agency inspects a refinery, finds violations, issues citations … and waits. Oil corporations routinely problem 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, before the case is closed — a time frame nearly 20 % longer than the typical for all industries, a Heart evaluation of a decade of enforcement data reveals.

Even in incidents the place people died and regulators cited corporations for willful violations — outlined by OSHA as those that involve both an intentional flouting of the law or “plain indifference” to it — corporations virtually always assert that the tragedies had been unforeseeable. Sometimes, the enforcers simply hand over: Practically a quarter of all fines proposed towards refiners from January 2000 via June 2010 have been erased from the books, a dismissal price 2 1/2 occasions that of U.S. industry as a whole, the middle found.

Michael Silverstein, who heads the Washington State Department of Labor & Industries’ Division of Occupational Security and Health and is a former federal OSHA policy director, mentioned the regulatory scheme at both the state and federal ranges is flawed. “Proper now, it is a catch-me-if-you-can system, and the results of being caught are relatively small.”

After its inspection of the Tesoro refinery in October 2008 — 18 months earlier than the hearth that killed Matt Gumbel and his co-workers — Silverstein’s company decreased an already-modest $85,seven-hundred positive to $12,250, and withdrew 14 of 17 alleged violations. He was, in effect, bargaining. His intention? To steer the corporate to drop its attraction and repair issues that might result in a catastrophic accident.

Silverstein stated he selected results over a drawn-out quest for a bigger penalty. “As lengthy as the case was in attraction, Tesoro had no authorized obligation to appropriate the issues cited,” he mentioned. The department insisted on an unbiased safety audit as a part of the settlement.

The April 2 catastrophe in Anacortes brought far larger potential penalties for Tesoro — and expectations that they, too, might be whittled down. The company faces a advantageous of almost $2.4 million for forty four alleged violations, 39 of that are labeled as willful. The state agency alleged that Tesoro “disregarded a host of workplace safety regulations, continued to operate failing gear for years, postponed maintenance [and] inadequately tested for doubtlessly catastrophic damage.”

Once once more, the corporate is interesting.

“We disagree with L&I’s [Labor & Industries’] characterization of Tesoro’s operations at Anacortes and believe — primarily based on obtainable proof and scientific opinions — that most of the company’s conclusions are deeply flawed,” the company stated in a written statement to the center. “We proceed to cooperate with L&I and other investigative bodies and look forward to clarifying the information as the method unfolds.”

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

The muddled regulatory system Silverstein laments didn’t evolve by probability. Fortified by enormous reserves of money, the oil and fuel trade usually will get its method. A notable exception final fall: Its failure to kill a California legislation requiring reductions in greenhouse gases.

In 2010 alone, the business reported spending more than $146 million to foyer the federal authorities. In the course of the 2009-2010 election cycle, it donated $25 million to federal campaigns — mostly Republican, data compiled by the center for Responsive Politics show. The American Petroleum Institute reported spending $6.75 million on federal lobbying last year, the refiners’ affiliation $2.76 million. Oil and gas interests spent one other $forty one.5 million on campaign contributions within the states, which also oversee refineries and other oil firm actions, in the course of the 2009-2010 election cycle, according to the National Institute on Cash in State Politics.

Through the years, the business has fended off a variety of guidelines and reforms. In 2010, it had a hand in killing federal laws that may have elevated the dimensions of civil penalties OSHA may impose, made it easier for the agency to construct criminal instances and forced employers to appropriate hazards whereas contesting citations. The U.S. Chamber of Commerce — to which oil companies have contributed generously — led the charge against the bill.

Now, leveraging the anti-regulatory mood in Washington, the business is attacking a host of guidelines it should follow, most of which contain climate change but a few of which contain health and safety. In a 9-web page letter to Darrell Issa, the new Republican chairman of the Home Committee on Oversight and Government Reform, on January 10, Drevna, of the refiners’ affiliation, complained a couple of “tremendous onslaught of regulatory activity.”

“If left unchecked,” Drevna warned Issa, this onslaught might “threaten the continuation of a considerable portion of domestic refining and petrochemical production and effectively-paying existing American jobs, and the safety of the nation.”


At a refinery, a heat exchanger transfers heat from one liquid to a different with out permitting them to mix, conserving energy that otherwise would be wasted. The exchanger that blew apart in Anacortes, often called Unit E, was put into service in 1972, four years before Matt Gumbel was born. In line with the Washington Division of Labor & Industries, Tesoro final examined welds on the gadget — utilizing a complicated methodology that could detect cracks — in 1998. This was the only time within the exchanger’s 38-12 months life that such an inspection had taken place, the department mentioned; furthermore, it discovered, Tesoro had tested fewer than 20 p.c of the welds and centered on areas least vulnerable to damage. Firm information indicate that a planned 2008 inspection by Tesoro by no means took place, the department stated.

In its assertion to the middle, Tesoro said the heat exchanger that failed “was inspected commonly and was fully compliant with regulations and business requirements. The exchanger underwent exterior inspections as soon as each two years and inside inspections in 1998 and again in 2005 . . .” State officials, however, say there isn’t a proof that the 2005 inspection was of the sort that would have enabled the company to search out cracks in the welds.

In its formal appeal of the state citation, the company denied that it had violated safety rules and mentioned it’d raise any variety of defenses, including “unanticipated employee misconduct.”

A lawsuit filed against Tesoro on February 9 by families of six of the dead staff claims that the company pushed its heat exchangers too laborious, for too lengthy, scrimping on inspections and ignoring signs of bother. Among different things, the lawsuit alleges that in 2001, an exchanger just like Unit E “failed catastrophically as a result of thermal fatigue and crack propagation,” however that Tesoro “willfully disregarded” a company suggestion to examine other exchangers for the same sorts of flaws.

“The plaintiffs’ allegations are incorrect,” countered Tesoro in its assertion. The 2001 incident had completely different causes, the corporate said. Cracks “had formed by means of a degradation mechanism totally totally different from that concerned in the April 2, 2010, incident.”

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

When the welds on Unit E popped, Matt Gumbel and his co-workers had been tending to the leak-prone exchangers being brought on-line after a maintenance shutdown. His father — who was working within the catalytic cracking unit, also recognized as the cat cracker — heard the explosion and felt the concussion.

Paul Gumbel remembers running towards the naphtha hydrotreater unit, the place he knew Matt had been working. “Considered one of the first folks I saw 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 consolation her, he noticed one other woman in unhealthy form, after which a second man — with flames on him. “We acquired him out,” Paul stated. “Then I grabbed a fireplace hose and tried to knock the flames down.”

He stayed on the hose for 20 minutes, nonetheless not knowing his son’s whereabouts. “I had a feeling he was there [in the hydrotreater unit],” Paul mentioned, “however nobody might reply my questions. They made me leave and go sit by a phone.” About 10 minutes later, the telephone rang. Matt, the caller mentioned, had one way or the other gotten out of the unit and was already on his method to Skagit Valley Hospital in Mount Vernon, Washington. By the point his dad and mom and his 32-12 months-outdated sister, Amy, arrived on the hospital, Matt was being prepped for a helicopter experience to a Seattle trauma center. He never regained consciousness and died there on April 24.

When Paul went again to work at Tesoro in June, he felt offended and could not concentrate. He lasted 5 days. “I had a humongous feeling of dread about even going by the gate,” he said. He started seeing a psychiatrist and was diagnosed with publish-traumatic stress disorder, a product of his horrific expertise. After taking medical leave, he returned to the refinery in October as an operator.

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


Preventable tragedies keep occurring at refineries, regardless of considerable info on how one can make them safer.

Many anticipated a 1989 explosion in Texas to bring a few sea change. That blast, so powerful it measured three.5 on the Richter scale, started when a vapor cloud ignited at Phillips sixty six Firm’s Houston Chemical Complex. The explosion — which killed 23 employees and injured 132 — came not fairly five 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 comparable to oil refining and chemical manufacturing to determine dangers and deal with them earlier than an accident could kill, maim or unleash toxic chemicals into neighborhoods. Underneath the so-known as course of security management commonplace, finally copied by many states, companies must have in place a system of inspections, upkeep and emergency procedures to prevent catastrophic fires, explosions and chemical releases. Publicly, affected industries had been supportive — for good purpose, it appeared. “[W]e consider that the advantages of the program justify the investment of resources,” BP America wrote to OSHA in April 1991, noting that “the price of a single incident can complete hundreds of thousands of dollars in restore prices and lost manufacturing capability, not to mention the potential influence on human life.”

While some main accidents could have been averted, the impact of the 1992 rule has been limited. For instance, it apparently did not dissuade BP from reducing 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 at the refinery was overfilled with flammable hydrocarbon liquids and vapors, which poured out and ignited, inflicting a collection of explosions and fires. Fifteen workers died and 180 were harm.

Signs of trouble at the refinery had been plentiful but evidently ignored. In its investigation, the Chemical Security Board discovered that the relief system had overflowed eight times between 1994 and 2004, well earlier than the explosion. None of the eight incidents, the board found, had been properly investigated or acted upon.

After fining BP $21 million for the disaster, OSHA returned to the Texas City refinery in 2009 and found that the corporate had damaged its promise to fix hundreds of hazards. Discovering recent cause for concern, the agency also cited BP for lots of of new violations. Final August, BP agreed to pay $50.6 million for the 270 “failure to abate” violations and spend a minimum of $500 million to upgrade the refinery. But the company is contesting a $31 million superb proposed by OSHA for the brand new violations. Four employees have died at the refinery since 2005, and the corporate has paid $sixty five million to settle criminal and civil Clean Air Act circumstances brought in opposition to it by the U.S. Department of Justice because of the 2005 blast.

In a written statement, BP stated it had “systematically refurbished and inspected major process models” in Texas Metropolis and replaced the antiquated relief system since the accident. A “new culture of openness” exists within its workforce, the corporate mentioned.


The issues aren’t limited to big refiners like BP-Texas City, which processes 437,000 barrels of crude oil per day. In February 2008, OSHA inspected a 58,000-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 $68,250; Delek contested all 16. Two months later, three Delek employees have been taken to the hospital after being burned by oil that spewed from a sewer drain. OSHA cited the company for two more violations and proposed an extra $6,300 in fines. Delek contested.

On November 20, 2008, a pipe ruptured and an explosion tore by two of the refinery’s control rooms, killing one worker and injuring four, one among whom died 13 days later. In Could 2009, OSHA cited Delek for 30 violations — including a willful violation for operating the failed pipe more than 5 years past the retirement date set by the company — and proposed $217,350 in fines. Once more, Delek contested.

In a deposition taken in February 2010 in reference to personal injury lawsuits filed in opposition to Delek, refinery manager Frank Simmons mentioned an investigation by the company revealed that the accident was brought on by a “localized level of very excessive corrosion” on the 31-yr-previous pipe, which carried naphtha and liquefied petroleum gas. “I actually imagine [it] was unforeseeable for us,” Simmons testified. He acknowledged under questioning, nonetheless, that portions of the pipe that failed had been beneath structural minimums established by the American Petroleum Institute. A spokesman for the corporate declined to comment.

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, 4 contract employees had been caught in a storage tank blast at the 105,000-barrel-per-day Navajo refinery in Artesia, N.M. Two of the males died and two have been injured. In the 15 months main as much as the accident, firm officials had reported 22 fires to the brand new Mexico Occupational Well being and Security Bureau. Eight of those fires occurred in January 2010 alone.

In a deposition final November, the refinery’s former well being and safety manager, William Jones, said that Navajo shouldn’t have allowed the employees 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 on this case, based mostly on what Navajo failed to do?” one of many victims’ legal professionals asked throughout the session.

“Yes,” Jones replied.

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

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

Sometimes, it is blind luck that nobody is killed when a unit catches hearth 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 stuffed with naphtha ignited, burning 4 workers in a flash hearth. In November, a 10-inch hydrogen pipe burst, producing a one hundred-foot-excessive fireball and a concussion that broken more than 100 houses, considered one of which was knocked off its basis. Commuter rail traces go close to the refinery.

“Fortuitously,” Chemical Safety Board investigator Don Holmstrom said shortly after the accident, “there was no train present during the blast.”


Drevna, president of the Nationwide Petrochemical & Refiners Affiliation, acknowledged the string of latest accidents in the refining industry. “Have there been incidents? Completely,” he stated. “Do we need to appropriate these? Do we want to prevent these? Completely.” He insisted, however, that these episodes do not sign a pattern and that the industry “does not take economics into consideration” when making choices that could affect security.

Workers interviewed by the middle disagree. They describe a climate during which safety takes a back seat to ramped-up manufacturing. Moderately than schedule high-to-bottom maintenance outages, which take units out of operation for prolonged intervals, gear is being pushed laborious, typically beyond its design life, the staff say. They have a term for it: “Run to failure.”

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

For example, Campbell mentioned, increasing use of heavier, greater-sulfur crude has heightened dangers in coker models, generally the final cease in refining. Residual materials generally known as bottoms are extracted from crude in drums up to ninety feet excessive. To keep up manufacturing, refiners are filling, cooling and emptying the drums more typically than they used to, Campbell mentioned. This puts extra stress on the metallic, and might result in cracking.

In 2003, OSHA and the U.S. Environmental Protection Company issued an alert on the hazards of a apply in coker items that requires the usage of excessive temperatures for long durations to upgrade low-high quality crude. The agencies warned that such operations had resulted in a lot of serious accidents, especially during procedures akin to drum head removal.

In April 2009, as workers eliminated a drum head on the ExxonMobil refinery in Torrance, California, scalding water sprayed a 49-year-outdated operator named Nelson Tan. He survived 18 days before succumbing to second- and third-diploma burns that covered 85 p.c of his physique. It was simply the kind of state of affairs OSHA and the EPA had warned about in 2003.

After contesting three citations issued by the California Division of Occupational Security & Well being, ExxonMobil, which made a revenue of $19 billion in 2009, paid a $24,200 superb for violations related with Tan’s loss of life.

In a statement, ExxonMobil mentioned it “deeply regrets” the incident. “Safety is our first priority, and the loss of life at our facility will not be acceptable, beneath any circumstances. We absolutely cooperated with the Cal-OSHA investigation. We are committed to making certain the well being and security of all the workers at all our facilities.”

Deceptive NUMBERS

The refining trade has a greater injury and illness price than non-public business as a whole. In 2009, the rate for refineries was one case per 100 full-time employees; the speed for all industries was 3.6 cases per 100. The charges had been 2.9 for textile mills, four.1 for coal mines and 7.Eight for motorcar manufacturing plants. “The oil and pure gas trade is changing into an more and more safer place to work, regardless of a job environment that usually entails heavy gear, hazardous supplies, excessive temperatures and high pressure tools,” the American Petroleum Institute mentioned in a written statement. Officials at the institute didn’t respond to repeated interview requests from the center.

However low damage charges, for damaged legs or wrenched backs, say little about systemic mechanical issues, such as leaking valves or corroded pipes, which may lead to fires and explosions. For instance, the injury charge at BP’s Texas Metropolis refinery in 2004, the year earlier than the deadly blast, was about one-third that of the complete refining sector. “I can’t say too strongly to industry leaders: Stop boasting about your security records when you’re literally placing out fires,” Jordan Barab, a U.S. deputy assistant labor secretary, mentioned at a Could 2010 safety conference sponsored by the National Petrochemical & Refiners Affiliation. “You are only undermining your credibility. … Boasting about the great safety record of [the] refinery industry while widows and children are planning funerals does not make you sound like a critical group. And giving awards to your members based solely on a lack of slips, journeys and falls does not make you sound like a critical group.”

Even limited to injuries and deaths, refiners’ safety information are misleading. They do not embrace knowledge on hundreds of contract employees, who typically carry out probably the most hazardous jobs. All 15 workers killed in the BP-Texas Metropolis accident, as an example, have been employed by contractors; the deaths, due to this fact, aren’t attributed to BP in OSHA records. In all, the middle recognized forty four deaths at refineries during the past decade. Practically three-quarters of those killed — 32 — were contract employees.

Despite a special inspection program launched by OSHA in 2007 — and mirrored by most states which have their own safety programs — issues continue to occur at refineries with gorgeous regularity. A Heart evaluation found that 24 of the 58 refineries examined by federal officials as of November 2010 had fires or explosions after the inspections have been opened. On average, OSHA has issued 17 citations and proposed $166,000 in fines per refinery. Given the dimensions and complexity of these operations, nonetheless, 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 skilled in the nuances of process safety administration are devoted to it full time, and they are only in a single location: Houston. As well as, OSHA’s focused inspection program is to finish this year, although officials say they plan to maintain a presence in refineries.

Those who argue for stronger enforcement point to packages in Britain, which requires assiduous planning by firms and thorough reviews by regulators before oil and fuel activities begin, and California, which maintains a gentle presence at refineries quite than simply dropping in, inspecting and writing citations.


Shauna Gumbel tells a narrative about her son, Matt, when he was a toddler. As the 2 of them ran pre-Christmas errands and encountered a succession of Santa Clauses of their hometown of Oak Harbor, Washington, Matt noticed minor differences: One wore glasses, one other gloves, and so forth. “Santa cannot be in all places,” his flustered mom improvised. “He has to have helpers.” Matt was skeptical.

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

Matt’s curiosity and a spotlight to detail served him properly when he grew to become an operator on the Tesoro refinery within the fall of 2007. His father, Paul, who had worked there for six years, had encouraged Matt to use. It was a job that performed to Matt’s strengths. At a refinery — a spot of incessant noise and motion — the one who notices subtleties can make a big distinction. An acrid odor, for example, can signal the presence of a lethal gas. “You need to concentrate to every little thing you are doing and everything that’s going on around you,” Paul stated. “You by no means know what can go improper.”

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

Outdoors the refinery, Matt was a threat-taker. He cherished snowboarding — “not at all times in places 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 pleased with the blue hardhat he earned in 2009, proof that he’d completed his Tesoro training. He and Paul would discuss at length about work; Shauna would eavesdrop, not understanding the terminology however happy to see the bond strengthening between father and son.

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

Matt was in the emergency room, awaiting transport by helicopter to Harborview Medical Middle in Seattle, 60 miles to the south. Paul, Shauna and Amy took off for Seattle by car, arriving round 4:Forty five a.m. There, for the subsequent 22 days, the family’s hopes rose and fell, as famous in Shauna’s on-line journal:

Matty is so robust … he will pull by this soon. (April four)

Matt came by surgery properly. They eliminated all the burned pores and 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 slightly bit (April 14)

Matt had a rough night time. (April 17)

Surgical procedure went well. … [But] after Matt was brought up to his room they could not get his important indicators stable. He’s now going back downstairs in emergency exploratory surgical procedure to try to discover out what’s going on. (April 23)

They did not really know what induced the a number of organ failure and the swelling. … Matt fought a very good combat and I believe his physique was telling us that it was tired and he didn’t have the fight left in him. (April 24)

On May 8, about 500 folks, together with many Tesoro workers, turned out for Matt’s memorial service at Oak Harbor High school. His sister and one of his closest buddies scattered some of Matt’s ashes at his favourite place, a state park overlooking the water and the Olympic Mountains in the gap. The remainder of the ashes are in an urn at Paul and Shauna Gumbel’s dwelling.

Five days after the memorial service, Tesoro invited the household to the scene of the accident. They noticed 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 looked like,” Shauna said. “It was horrifying and mind-boggling.”

Tesoro, in the meantime, appears to have rebounded from last April’s calamity. After a slight dip within the months immediately after the accident, the corporate’s stock price is practically double what it was a 12 months ago. In a December presentation, CEO Greg Goff assured Wall Street analysts that the refinery in Anacortes had been safely restarted and that “insurance recoveries [had been] underway.” Markets for Tesoro’s merchandise were improving, Goff observed. “Our strategic priorities are clear, our plan is focused and the organization is aligned,” state supplies from the presentation. “We are dedicated to driving shareholder worth.”

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