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1.

We understand from your response to prior comments four and eight that measures you have presented as “Cost of product sold (exclusive of depreciation and amortization)” exclude various costs in addition to depreciation and amortization that would be attributable to cost of products sold measures under GAAP. For example, you indicate that amounts reported as direct operating expenses are both inventoriable and excluded in computing gross profit measures in accordance with GAAP. Therefore, it appears revisions will be necessary to address the following points.

•	The “Cost of product sold (exclusive of depreciation and amortization)” label does not adequately describe the amounts you have presented.

•	You are required to present costs of revenues individually for product sales, services, and rentals to comply with Rule 5-03 of Regulation S-X.

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2.

We note that you have excluded depreciation and amortization from various line items on the Statements of Operations without indicating the excluded amounts attributable to each cost or expense category, notwithstanding the related details you have presented in MD&A. If you apply the accommodation outlined in SAB Topic 11.B, in excluding depreciation and amortization from certain costs and expense categories, you should separately report depreciation and amortization that is attributable to each line from which it is excluded.

3.

We note your undertaking to comply with prior comment 7 in future filings. Similarly, please also be sure to give effect to prior comments 5 and 6 by making appropriate revisions to your CD&A and summary compensation tables in future filings. Namely, please expand the disclosure in the Compensation Discussion and Analysis section to disclose the rationale you provide for not issuing equity compensation in these circumstances, as Item 402(b)(2)(iii) of Regulation S-K requires. Please expand footnote 3 to your summary compensation tables to quantify the grant date fair values for the performance units you awarded to Mr. Lipinski in both 2013 and 2015.

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4.

We note your response to prior comment eight concerning the need for reconciliation between non-GAAP measures, including although not limited to your measures of Refining Margin, Refining Margin adjusted for FIFO impact and gross profit excluding flood insurance recovery, and the most directly comparable measures calculated in accordance with GAAP. We understand that you would prefer to limit your disclosure in this regard and instead rely solely on a narrative description of the non-GAAP measures. However, we continue to believe that you should provide quantitative reconciliations for all non-GAAP measures, including the related unit measures that you disclose in the earnings releases and investor presentations of both companies to comply with Item 100(a)(2) of Regulation G.

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5.	Please adhere to the guidance in the preceding comment also with respect to the disclosures of non-GAAP measures in your periodic filings, such as Refining Margin and Refining Margin Per crude oil throughput barrel on pages 60 and 61 of your third quarter interim report, to comply with Item 10(e)(1)(i)(B) of Regulation S-K.

6.	We have raised several comments on the disclosures in the parent filings which appear in part common to filings of the subsidiary. Please address these comments also from the standpoint of the subsidiary with corresponding changes to conform.

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