DONNA H. CARVALHO Senior Counsel Legal Compliance, Environmental Regulatory PHILLIPS 66 Company 2331 CityWest Boulevard Houston, Texas 77042 Phone: (832) 765-1214 Email: Donna.H.Carvalho@n66.com March 9, 2020 Via UPS Overnight Mail Chief Environmental Enforcement Section Environment and Natural Resources Division United States Department of Justice ATTN: Thomas Carroll 150 Street NE, Room 5.113 Washington, DC 2004?7611 Compliance Tracker (AB-17.1) Air Compliance and Compliance Assurance Branch U.S. EPA Region 5 77 W. Jackson Chicago, Illinois 60604 PHILLIPS an Chief, Environmental Bureau Illinois Attorney General?s Of?ce 500 South Second Street Spring?eld, IL 62706 Maureen Wozniak, Counsel Illinois EPA 1021 N. Grand Ave. East PO. Box 19276 Spring?eld, IL 62794?9276 Manager, Compliance and Enforcement Section Illinois EPA 1021 N. Grand Ave. East PO. Box 19276 Spring?eld, IL 62794?9276 RE: Force Majeure Noti?cations Pursuant to Paragraph 129 of Civil Action No. Phillips 66 Company Wood River Re?nery Dear Ladies and Gentlemen: On February the U.S. Centers for Disease Control and Prevention (CDC) announced the ?rst known community spread case of the novel coronavirus within the United States (US). Since then approximately 150 other cases have been identi?ed within the U.S. (See and Phillips 66 Company is conducting pandemic planning and continues to monitor the situation. Ultimately, the transmission and spread of the virus could impact the Company?s performance with the requirements of the above-referenced Consent Decree. No known impact has occurred yet. 1 Updated 6:15 AM ET, Fri February 28, 2020 March 9, 2020 Page 2 of 3 Paragraph 129 of the above referenced Consent Decree (Civil Action requires Phillips 66 to notify the United States and Illinois, within twenty business days of any event which it knows or should have known could result in a delay or impediment to complying with the Consent Decree. Based on this requirement Phillips 66 Company is now submitting this force majeure notice. As noted above, there is no known current impact. However, the facility can foresee potential issues if the Wood River Refinery?s or its contractors? workforce is directly impacted. Planning to prevent and mitigate these potential issues is ongoing. Potential Delays Although no delays have occurred yet, one or more of the following delays/impediments could occur depending upon whether and to what extent the Phillips 66 workforce, including that of its contractors, is impacted by the coronavirus by infection, quarantine, family emergency, etc): 0 Emissions and waste gas cap compliance related to idling or shutting down and restarting units due to limited onsite personnel or other supply or customer disruptions; - Emissions due to parts supply interruptions; - Delays in stack testing due to stack tester unavailability, limited onsite personnel, or not operating in a mode appropriate for stack testing due to personnel, supply or related disruptions; I Delays in Leak Detection and Repair or Benzene Waste NESHAPS monitoring including fence line monitoring due to contractor unavailability, site access limitations or limed onsite personnel; I CEMS repairs, calibration or checks due to unavailability of calibration gas supply, limited onsite personnel, contractor unavailability, not operating in a mode appropriate for calibration or testing, or other personnel, supply, or related disruptions; and - Disruptions in laboratory analysis due to limited onsite personnel or other supply or customer disruptions. This list is not intended to be all inclusive. It does contain the items that Phillips 66 has pre-identi?ed thus far. Length of Time Delay May Persist No delay or impediment currently exists. The Company is continuously monitoring the situation and conducting pandemic planning, which includes planning for operating with a reduced workforce and raw material disruptions, if required. If the Wood River Re?nery is actually affected, this notice will be updated with more speci?c information. The Cause of the Delay or Impediment The cause of the delay or impediment is the ongoing transmission and quick spread of the virus. More information on this virus can be found on the website The ?rst community spread case was identi?ed on February (See March 9, 2020 Page 3 of 3 As the virus continues to be transmitted, it is possible that the Billings Re?nery may have workers or contractors out sick or to care for sick family members and/or that the Company will implement additional social distancing measures. Schedule for and Measures Taken by Phillips 66 to Prevent/Ivlinimize the Delay Phillips 66 is taking a variety of measures on both a corporate and site-speci?c level to limit transmission and spread of the virus and its potential impact on Consent Decree compliance. Among these are: Continuous monitoring of virus transmission and spread; Drills involving working with limited onsite employees; Drills involving working remotely; Development of company policies; Out of of?ce backup plans for key employees; Restrictions on business travel. Please do not hesitate to contact me at the number noted above if you have any questions. This notice will be updated if needed. Respectfully submitted, Donna H. Carvalho ec: r5ardreporting@epa.gov Loukeris.constantinos@epa.gov Gehrig.greg@epa.gov Wagner.william@epa.gov Mcauliffe.marv@epa.gov rcallery@atg.state.i1.us Maureen.Wozniak@Illinois.gov Cc: Tim E. Goedeker, Environmental Manager HSE Re?ning Dean Maniatis, Re?ning HSE Manager Deputy General Counsel, Legal Compliance, Environmental Regulatory Re?nery Manager, WRB Re?ning LP, Wood River Re?nery 2 Updated 6:15 AM ET, Fri February 28, 2020