Delek US Holdings, Inc. 10-Q

ITEM 1. LEGAL PROCEEDINGS In the ordinary conduct of our business, we are from time to time subject to lawsuits, investigations and claims, including environmental claims and employee-related matters. Although we cannot predict with certainty the ultimate resolution of lawsuits, investigations and claims asserted against us, including civil penalties or other enforcement actions, we do not believe that any currently pending legal proceeding or proceedings to which we are a party will have a material adverse effect on our business, financial condition or results of operations. See Note 12 to our condensed consolidated financial statements in Item 1. Financial Statements, of this Quarterly Report on Form 10-Q for further information. As previously disclosed in our Annual Report on Form 10-K for the fiscal year ended December 31, 2025, in September 2025, our subsidiary Alon Refining Krotz Springs, Inc. (“Alon Krotz Springs”) filed a petition for review in the United States Court of Appeals for the District of Columbia Circuit (the “D.C. Court of Appeals”) (case no. 25-1187, consolidated with No. 25-1197) challenging the EPA’s decision that the Krotz Springs refinery was ineligible for a small refinery exemption under the Clean Air Act’s Renewable Fuel Standard program for the 2024 compliance year. On April 7, 2026, the D.C. Court of Appeals ruled in favor of Alon Krotz Springs and the co-petitioner, holding that the EPA’s denial of the small refinery exemption applications was contrary to the plain language of the agency’s own 2014 Eligibility Regulation. The D.C. Court of Appeals vacated the EPA’s orders denying the exemption applications for the 2024 compliance year and remanded the matter to the EPA for further proceedings consistent with its opinion. On August 3, 2026 the EPA granted a full exemption with respect to the Krotz Springs refinery’s 2024 Renewable Fuel Standard obligations. Other claims we are pursuing against the EPA include a proceeding by our subsidiaries Alon Refining Krotz Springs, Inc., Delek Refining, Ltd., Lion Oil Company, LLC and Alon USA, LP in the D.C. Court of Appeals (case numbers 25-1229, 1230, 1231, 1245) filed in October 2025 seeking review of the EPA’s decision to refund expired RINs for the 2019 to 2023 compliance years, and a proceeding by Alon USA, LP in the 5th Circuit Court of Appeals (No. 25-60584) filed in October 2025 with a protective petition filed in the D.C. Court of Appeals (case no. 25-1246) seeking review of the EPA’s decision denying an exemption on the 2020 exemption petition of the Big Spring Refinery. In addition, in May 2026, the Company filed a petition in the U.S. Court of Appeals for the D.C. Circuit challenging the EPA's final rule reallocating small refinery exemption volumes from prior compliance years into the annual Renewable Fuel Standard volume obligations for the 2026 and 2027 compliance years (the "Set 2 Rule"). We are one of numerous refining companies that are parties to this litigation. The petitions for review were recently filed, and the court has not yet entered a scheduling order. Aside from the matters discussed above and disclosure updated in Note 12, there have been no material developments to the proceedings previously reported in our Annual Report on Form 10-K filed on February 27, 2026.