What Delek US Holdings, Inc. told the SEC could break it.

As an independent refiner, Delek's margins are driven by the spread between crude-oil feedstock cost and refined-product prices (the crack spread), plus RIN costs. Its 2025 crude slate was approximately 69.9% WTI, 24.1% Gulf Coast sweet and 6% other, and it purchases more crude than it processes via long-term acreage-dedication and short-term purchase agreements. While it states crude and refined products are readily available commodities (no specific-supplier concentration), it remains fully exposed to crude-oil and product price volatility, crude differentials (WTI vs. Gulf Coast/Midland), and energy-market swings. A core commodity-margin dependence tying profitability to crude and product markets.

“We purchase more crude oil than our refineries process, generally through a combination of long-term acreage dedication agreements and short-term crude oil purchase agreements.”

Delek's entire refining footprint is geographically concentrated: all four of its refineries are located in the Gulf Coast Region (PADD III), and its refined products are marketed primarily in the south-central and southwestern U.S. This concentrates exposure to a single PADD's dynamics — Gulf Coast hurricane risk (which can knock out multiple refineries at once), regional crude differentials and logistics, and regional product demand/pricing. A region-wide disruption (major storm, pipeline outage, regional regulation) would affect a disproportionate share of capacity simultaneously. A genuine single-region refining concentration.

“All four of these refineries are located in the Gulf Coast Region (PADD III)”

As an obligated party under the EPA's Renewable Fuel Standard, Delek must retire Renewable Identification Numbers (RINs) to meet its Renewable Volume Obligations — a large, volatile cost line for independent refiners — and its economics hinge on the contested small-refinery-exemption (SRE) program. On August 22, 2025, the EPA granted Delek full and partial exemptions for substantially all of its 20 SRE petitions for the 2019–2024 calendar years and refunded vintage 2019–2023 RINs it had retired. SRE eligibility, RFS volume mandates and RIN prices are subject to EPA discretion and litigation, so changes could swing compliance costs materially in either direction. A specific, high-impact, refiner-defining regulatory exposure.

“The EPA granted Delek full and partial exemptions for substantially all of our 20 petitions for the 2019-2024 calendar years.”